U.S. Chamber Comments on REG-104226-18 (Proposed Rules Relating to §965 Transition Tax)

Wednesday, October 3, 2018 - 9:15am
On October 3, the U.S. Chamber submitted the following comments to the Treasury Department and the IRS on REG-104226-18, proposed rules relating to §965 transition tax as published in the Federal Register on August 9, 2018
 
 
 
 
October 3, 2018
 
The Honorable Steven T. Mnuchin   
Secretary of the Treasury               
U.S Department of the Treasury   
1500 Pennsylvania Avenue, NW  
Washington, D.C. 20220 
 
The Honorable Charles P. Rettig
Commissioner 
Internal Revenue Service (I.R.S.) 
1111 Constitution Avenue, N.W.      
Washington, D.C. 20224
 
The Honorable David J. Kautter  
Assistant Secretary (Tax Policy)  
U.S. Department of the Treasury 
1500 Pennsylvania Avenue, N.W. 
Washington, D.C. 20220   
 
The Honorable William M. Paul   
Acting Chief Counsel and Deputy Chief
Counsel (Technical)  
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, N.W.       
Washington, D.C. 20224
 
Office of Associate Chief Counsel (International) 
Attention: Leni C. Perkins   
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, D.C. 20224
 
Office of Associate Chief Counsel (International)     
Attention: Karen J. Cate
Internal Revenue Service (I.R.S.)  
1111 Constitution Avenue, NW  
Washington, D.C. 20224   
 
CC:PA:LPD:PR REG-104226-18
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
 
Submitted via Federal eRulemaking Portal
 
RE: Comments on REG-104226-18 (Proposed Rules Relating to §965 Transition Tax)
 
Dear Sir or Madam:
 
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104226-18, as published in the Federal Register on August 9, 2018.
 
The attached chart identifies issues arising under REG-104226-18 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 affected Chamber members. These comments may be considered as representing some of the most serious issues, but are not all the issues concerning Chamber members have regarding REG-104226-18.     
 
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.    
 
Sincerely,
 
 
Caroline L. Harris
 
 
CC:  Lafayette “Chip” G. Harter III, Deputy Assistant Secretary (International Tax Affairs),
U.S. Department of the Treasury  
 
Douglas L. Poms, International Tax Counsel, U.S. Department of the Treasury  
 
Brian Jenn, Deputy International Tax Counsel, U.S. Department of the Treasury 
 
Brenda L. Zent, Special Advisor on International Taxation, U.S. 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