u.s._chamber_letter_on_reg-104390-18_section_951a_global_intangible_low-taxed_income
feedback_for_reg-104390-18_guidance_related_to_section_951a_global_intangible_low-taxed_income
November 20, 2018
Office of Associate Chief Counsel (International)
Attention: Melinda E. Harvey and Michael Kaercher
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW Washington, DC 20224
Office of Associate Chief Counsel (Corporate)
Attention: Austin Diamond-Jones and Kevin M. Jacobs
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW Washington, DC 20224
CC:PA:LPD:PR (REG-104390-18)
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
Via Federal eRulemaking Portal
RE: Comments on REG-104390-18: Guidance Related to Section 951A (Global Intangible LowTaxed Income)
Dear Sir or Madam:
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104390-18, guidance related to section 951A, as published in the Internal Revenue Bulletin on October 10, 2018.
The attached chart identifies issues arising under REG-104390-18 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 REG104390-18.
The Chamber appreciates the opportunity to provide this feedback on REG-104390-18. 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 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, Chief Counsel (Acting), Office of the Chief Counsel, Internal Revenue Service,
U.S. Department of the Treasury
