U.S. Chamber Comments on REG-106089-18: Limitation on the Deduction for Business Interest Expense

Monday, February 25, 2019 - 1:15pm
 
February 25, 2019 
 
CC:PA:LPD:PR  (REG-106089-18)
Room 5203
Internal Revenue Service  
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20224 
 
Via Federal eRulemaking Portal 
 
RE: Comments on REG-106089-18: Limitation on the Deduction for Business Interest Expense 
 
Dear Sir or Madam: 
 
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-106089-18, guidance related to the limitation on the deduction for business interest expense after the enactment of recent tax legislation, as published in the Federal Register on December 28, 2018.
 
The attached chart identifies issues arising under REG-106089-18 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 REG106089-18. 
 
The Chamber appreciates the opportunity to provide this feedback on REG-106089-18. 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 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   
 
Zachary King, Attorney (Income Tax and Accounting), Office of the Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury    
 
Charles Gorham, Attorney (Income Tax and Accounting), Office of the Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Susie K. Bird, Attorney (Income Tax and Accounting), Office of the Associate Chief  Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Jaime C. Park, Attorney (Income Tax and Accounting), Office of the Associate Chief  Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Sophia L. Wang, Attorney (Income Tax and Accounting), Office of the Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Kevin M. Jacobs, Attorney (Corporate), Office of the Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Russell G. Jones, Attorney (Corporate), Office of the Associate Chief Counsel, Internal Revenue Service,
U.S. Department of the Treasury 
 
John B. Lovelace,  Attorney (Corporate), Office of the Associate Chief Counsel, Internal  Revenue Service,
U.S. Department of the Treasury 
 
Meghan M. Howard, Attorney (Passthroughs & Special Industries Division), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
William M. Kostak, Attorney (Passthroughs & Special Industries Division), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Anthony J. McQuillen, Attorney (Passthroughs and Special Industries Division), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury 
 
Adrienne M. Mikolashek, Attorney (Passthroughs and Special Industries Division), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury    
 
James A. Quinn, Attorney (Passthroughs and Special Industries Division), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury  
 
Angela E. Holland, Attorney (International), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury  
 
Steven D. Jensen, Attorney (International), Office of Associate Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury  
 
Charles Rioux, Attorney (International), Office of Associate Chief Counsel, Internal  Revenue Service, U.S. Department of the Treasury  
 
Michael Y. Chin, Attorney (Financial Institutions & Products), Office of the Chief  Counsel, Internal Revenue Service, U.S. Department of the Treasury