Office of Associate Chief Counsel (Corporate)
Via Federal eRulemaking Portal
RE: Comments on REG-125710-18: Regulations Under Section 382(h) Related to Built-In Gain and Loss
Dear Mr. Jacobs and Ms. Milnes-Vasquez:
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-125710-18, guidance regarding the items of income and deduction which are included in the calculation of built-in gains and losses under section 382 of the Internal Revenue Code, as published in the Federal Register on September 10, 2019.
The attached chart identifies issues arising under REG-125710-18 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 REG125710-18.
Caroline L. Harris
Cc: Charles P. Rettig, Commissioner, Office of the Commissioner, Internal Revenue Service,