October 30, 2020
Office of Associate Chief Counsel
Attention: Steve Harrison, Michael Chin, John Lovelace, Sophia Wang, William Kostak,
Anthony McQuillen, Azeka J. Abramoff, Raphael Cohen, and Pamela Lew
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW Washington, DC 20224
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station Washington, D.C. 20224
Via Federal eRulemaking Portal
RE: Comments on REG-107911-18: Rules Concerning the 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-107911-18, proposed rules concerning the limitation on the deduction for business interest expense after amendment of the Internal Revenue Code (Code) by the provisions commonly known as the Tax Cuts and Jobs Act, which was enacted on December 22, 2017, and the Coronavirus Aid, Relief, and Economic Security Act, which was enacted on March 27, 2020, as published in the Federal Register on September 14, 2020.
The attached chart identifies issues arising under REG-107911-18 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-107911-18.
The Chamber appreciates the opportunity to provide this feedback on REG-107911-18. 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.
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, Deputy Chief Counsel (Technical), Office of the Chief Counsel, Internal Revenue Service, U.S. Department of the Treasury