U.S. Chamber Comments on REG-104352-18: Rules Regarding Certain Hybrid Arrangements

Friday, February 22, 2019 - 1:45pm
 
February 22, 2019 
 
Office of Associate Chief Counsel (International)
Attention: Shane M. McCarrick and Tracy M. Villecco
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, DC 20224 
 
CC:PA:LPD:PR  (REG-104352-18)
Room 5203
Internal Revenue Service  
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20224 
 
Via Federal eRulemaking Portal 
 
RE: Comments on REG-104352-18: Rules Regarding Certain Hybrid Arrangements 
 
Dear Messrs. McCarrick and Villecco:  
 
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104352-18, guidance regarding certain hybrid arrangements as published in the Federal Register on December 28, 2018.  
 
The attached chart identifies issues arising under REG-104352-18 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 REG104352-18. 
 
The Chamber appreciates the opportunity to provide this feedback on REG-104352-18. 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