Published

October 03, 2018

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On October 3, the U.S. Chamber submitted the following comments to the Treasury Department and the IRS on REG-104226-18, proposed rules relating to §965 transition tax as published in the Federal Register on August 9, 2018

click_here_to_read_the_chamber_letter_reg-104226-18.pdf

click_here_to_read_the_chamber_965_regulations_feedback.pdf

October 3, 2018

The Honorable Steven T. Mnuchin

Secretary of the Treasury

U.S Department of the Treasury

1500 Pennsylvania Avenue, NW

Washington, D.C. 20220

The Honorable Charles P. Rettig

Commissioner

Internal Revenue Service (I.R.S.)

1111 Constitution Avenue, N.W.

Washington, D.C. 20224

The Honorable David J. Kautter

Assistant Secretary (Tax Policy)

U.S. Department of the Treasury

1500 Pennsylvania Avenue, N.W.

Washington, D.C. 20220

The Honorable William M. Paul

Acting Chief Counsel and Deputy Chief

Counsel (Technical)

Internal Revenue Service (I.R.S.)

1111 Constitution Avenue, N.W.

Washington, D.C. 20224

Office of Associate Chief Counsel (International)

Attention: Leni C. Perkins

Internal Revenue Service (I.R.S.)

1111 Constitution Avenue, NW

Washington, D.C. 20224

Office of Associate Chief Counsel (International)

Attention: Karen J. Cate

Internal Revenue Service (I.R.S.)

1111 Constitution Avenue, NW

Washington, D.C. 20224

CC:PA:LPD:PR REG-104226-18

Room 5203

Internal Revenue Service

P.O. Box 7604

Ben Franklin Station

Washington, D.C. 20044

Submitted via Federal eRulemaking Portal

RE: Comments on REG-104226-18 (Proposed Rules Relating to §965 Transition Tax)

Dear Sir or Madam:

The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104226-18, as published in the Federal Register on August 9, 2018.

The attached chart identifies issues arising under REG-104226-18 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 affected Chamber members. These comments may be considered as representing some of the most serious issues, but are not all the issues concerning Chamber members have regarding REG-104226-18.

The Chamber strongly urges Treasury and the I.R.S. to work closely with the business community to implement the recent tax changes in a manner that would ensure as little disruption as possible to normal business operations and encourage 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 you work to implement the new, pro-growth tax code. Thank you for your time and attention.

Sincerely,

Caroline L. Harris

CC: Lafayette “Chip” G. Harter III, Deputy Assistant Secretary (International Tax Affairs),

U.S. Department of the Treasury

Douglas L. Poms, International Tax Counsel, U.S. Department of the Treasury

Brian Jenn, Deputy International Tax Counsel, U.S. Department of the Treasury

Brenda L. Zent, Special Advisor on International Taxation, U.S. Department of the Treasury

Marjorie A. Rollinson, Associate Chief Counsel (International), Internal Revenue Service

Daniel M. McCall, Deputy Associate Chief Counsel (International), Internal Revenue Service

Raymond J. Stahl, Senior Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service

John J. Merrick, Special Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service