On March 7, 2017, TEI filed comments with the IRS regarding final, proposed, and temporary regulations addressing the recognition foreign currency gain of qualified business units under section 987. The Institute’s comments focused on the administrative and compliance complexity of the regulations, the costs taxpayers must incur to comply with the rules, the potential elimination of the recognition of economic losses, and the lack of adjustments available to taxpayers under section 481 upon adoption of the method required by the regulations for calculating foreign currency gain or loss, am
On February 22-23, 2017, a delegation from Tax Executives Institute met with the Commissioner of Internal Revenue, John Koskinen, and senior officials of the Internal Revenue Service and with the Treasury Department’s Tax Legislative Counsel, Tom West, and senior officials of Treasury’s Office of Tax Policy. The detailed agendas TEI submitted to the IRS and Treasury Department before the meetings are provided below.
On January 12, 2017, TEI Executive Director Eli Dicker and Tax Counsel Benjamin Shreck participated in a roundtable discussion of the IRS’s administration of country-by-country (CbC) reporting. The discussion focused on the CbC forms, instructions and guidance, external communication and outreach, compliance and enforcement issues, as well as international exchange and use of CbC information.
On June 14, 2016, members from Regions VI and VII enjoyed a wide-ranging and insightful discussion with local and national LB&I executives at the University of Illinois Business Center in Chicago, Illinois. Special congratulations and thanks go out to Region VI leadership, notably RVP Janet Kreilein, who led the planning and organization of this year’s event. LB&I’s recent restructuring and the reengineering of its examination process fostered a lively conversation benefitting both TEI members and LB&I officials.
On March 21, 2016, TEI submitted comments to the IRS regarding proposed regulations (REG-109822-15) that would require certain U.S. headquartered multinational enterprises to report financial and tax information to the IRS on a country-by-country basis. The Institute's comments focused on the need for the final regulations to be consistent with the final report on Action 13 of the OECD's base erosion and profit shifting (BEPS) project to minimize the administrative burden on businesses and permit flexibility in information reporting.
On February 23-24, 2016, a delegation from Tax Executives Institute met with the Commissioner of Internal Revenue, John Koskinen, and senior officials of the Internal Revenue Service and with the Treasury Department’s Assistant Secretary for Tax Policy, Mark Mazur, and senior officials of Treasury’s Office of Tax Policy.
The detailed agendas TEI submitted to the IRS and Treasury Department before the meetings are provided below.
On February 16, 2016, TEI submitted comments to the Internal Revenue Service offering a definition of "minor assembly" for purposes of the domestic production activities deduction ("DPAD") of 26 U.S.C. § 199. We submitted these comments pursuant to the REG-136459-09 notice of proposed rulemaking, which proposed various changes in the regulations surrounding the DPAD. These comments also offered an alternative new Example 9 from what was suggested in REG-136459-09, an example generally regarding as attempting to overturn by regulation the holding in United States v. Dean, 945 F. Supp.
On August 3, 2015, TEI submitted comments to the IRS on proposed regulations (REG-132634-14) relating to qualifying income from activities of publicly traded partnerships with respect to minerals or natural resources. The Institute’s comments focused on how the proposed regulations fail to capture the complex processes and activities carried on by publicly traded partnerships and, as a result, propose rules that are inconsistent with section 7704(d)(1)(E) and its legislative history as previously interpreted and applied by the IRS in 27 years of ruling practice.