May 18, 2018
Office of Associate Chief Counsel (International) Attention: Leni C. Perkins Internal Revenue Service (I.R.S.), IR-4549 1111 Constitution Avenue, NW Washington, DC 20224
Via Federal eRulemaking Portal
RE: Comments on Notice 2018-26
Dear Ms. Perkins:
The U.S. Chamber of Commerce, the world's largest business federation representing the interests of more than three million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America's free enterprise system, appreciates the opportunity to provide feedback on Notice 2018-26 as published in the Internal Revenue Bulletin on April 16, 2018.
The attached chart identifies issues arising under Notice 2018-26 and provides suggested solutions as well as any additional explanation the Chamber believes would be helpful in addressing the issue. This feedback is the product of extensive conversations with a very wide array of impacted Chamber members. These comments may be considered as representing some of the most serious issues, but are not all the issues concerning Chamber members on Notice 2018-26.
The Chamber strongly urges Treasury and the I.R.S. to work closely with the business community to implement the recent tax changes in a manner that would ensure as little disruption as possible to normal business operations and encourage the U.S. economy to achieve its true growth potential. The Chamber looks forward to working with you to address these and other issues as you work to implement the new, pro-growth tax code. Thank you for your time and attention.
Caroline L. Harris
CC: David J. Kautter, Assistant Secretary, Office of Tax Policy, U.S. Department of the Treasury
William M. Paul, Chief Counsel and Deputy Chief Counsel (Technical) (Acting), Office of the Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury
Lafayette “Chip” G. Harter III, Deputy Assistant Secretary (International Tax Affairs), Department of the Treasury
Douglas L. Poms, International Tax Counsel, Department of the Treasury
Brian Jenn, Deputy International Tax Counsel, Department of the Treasury
Marjorie A. Rollinson, Associate Chief Counsel (International), Internal Revenue Service
Daniel M. McCall, Deputy Associate Chief Counsel (International), Internal Revenue Service
Raymond J. Stahl, Senior Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service
John J. Merrick, Special Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service