U.S. Chamber Comments on REG-104390-18: Guidance Related to Section 951A (Global Intangible Low-Taxed Income)

Tuesday, November 20, 2018 - 9:30am
 
 
November 20, 2018 
  
Office of Associate Chief Counsel (International)
Attention: Melinda E. Harvey and Michael Kaercher
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW Washington, DC 20224 
 
Office of Associate Chief Counsel (Corporate)
Attention: Austin Diamond-Jones and Kevin M. Jacobs
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW Washington, DC 20224 
 
CC:PA:LPD:PR  (REG-104390-18)
Room 5203  
Internal Revenue Service  
P.O. Box 7604  
Ben Franklin Station  
Washington, D.C. 20044 
 
Via Federal eRulemaking Portal 
 
RE: Comments on REG-104390-18: Guidance Related to Section 951A (Global Intangible LowTaxed Income) 
 
Dear Sir or Madam: 
 
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104390-18, guidance related to section 951A, as published in the Internal Revenue Bulletin on October 10, 2018.  
 
The attached chart identifies issues arising under REG-104390-18 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 REG104390-18. 
 
The Chamber appreciates the opportunity to provide this feedback on REG-104390-18. 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