Office of Associate Chief Counsel (Tax Exempt and Government Entities)
Via Federal eRulemaking Portal
RE: Comments on REG-122180-18: Certain Employee Remuneration in Excess of $1,000,000 under Internal Revenue Code Section 162(m)
Dear Mr. Enkishev:
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-122180-18: proposed regulations under section 162(m) of the Internal Revenue Code, which limits the deduction for certain employee remuneration in excess of $1,000,000 for federal income tax purposes, as published in the Federal Register on December 20, 2019.
The attached chart identifies issues arising under REG-122180-18 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 REG122180-18.
Caroline L. Harris
David J. Kautter, Assistant Secretary, Office of Tax Policy,