U.S. Chamber Comments on REG-104259-18: Guidance Related to the Base Erosion and Anti-Abuse Tax under Section 59A

Friday, February 15, 2019 - 10:15am

 

February 15, 2019

Office of Associate Chief Counsel (International)
Attention: Anand Desai, Brad McCormack,
Sheila Ramaswamy, and Karen Walny
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, DC 20224

Office of Associate Chief Counsel (Corporate)
Attention: Julie T. Wang and John P. Stemwedel
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, DC 20224

CC:PA:LPD:PR
(REG-104259-18)
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20224

Via Federal eRulemaking Portal

RE: Comments on REG-104259-18: Guidance Related to the Base Erosion and Anti-Abuse Tax under section 59A

Dear Sir or Madam:

The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104259-18, guidance related to the base erosion and anti-abuse tax under section 59A, as published in the Federal Register on December 21, 2018.

The attached chart identifies issues arising under REG-104259-18 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 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 REG-104259-18.

The Chamber appreciates the opportunity to provide this feedback on REG-104259-18. 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

William M. Paul, Chief Counsel (Acting), Office of the Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury