U.S. Chamber Comments on REG-101828-19: Guidance Under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income)

Monday, September 16, 2019 - 9:15am
 
September 16, 2019 
  
Office of Associate Chief Counsel (International)
Attention: Joshua P. Roffenbender and Jorge M. Oben Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, D.C. 20224 
 
Internal Revenue Service
CC:PA:LPD:PR  (REG-101828-19)
Room 5203
Post Office Box 7604
Ben Franklin Station
Washington, D.C. 20044 
 
Via Federal eRulemaking Portal 
 
RE: Comments on REG-101828-19: Guidance Under Section 958 (Rules for Determining Stock Ownership) and Section 951A (Global Intangible Low-Taxed Income) 
 
Dear Messrs. Roffenbender and Oben:  
 
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-101828-19, guidance under section 958 (Rules for Determining Stock Ownership) and section 951A (Global Intangible Low-Taxed Income) as published in the Federal Register on June 21, 2019.  
 
The attached chart identifies issues arising under REG-101828-19 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 REG101828-19. 
 
The Chamber appreciates the opportunity to provide this feedback on REG-101828-19. The Chamber strongly urges Treasury and the I.R.S. to continue to work closely with the business community to implement the recent tax changes in a manner to ensure as little disruption as possible to normal business operations and that this law encourages 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 we work to implement our new, pro-growth tax code. Thank you for your time and attention.
 
Sincerely, 
 
Caroline L. Harris 
 
Cc:  Charles P. Rettig, Commissioner, Office of the Commissioner, Internal Revenue Service, U.S. Department of the Treasury  
 
David J. Kautter, Assistant Secretary, Office of Tax Policy, U.S. Department of the Treasury    
 
Lafayette C. Harter, Deputy Assistant Secretary for International Tax Affairs, Office of Tax Policy, U.S. Department of the Treasury  
 
William M. Paul, Deputy Chief Counsel (Technical), Office of the Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury