Supplemental Comments on Federal Power Act Section 203 Blanket Authorizations for Investment Companies (SIFMA AMG)
SIFMA AMG provided comments to the Federal Energy Regulatory Commission replying to certain comments filed in the Notice of Inquiry…
Internal Revenue Service
CC:PA:LPD:PR (REG-104390-18)
Room 5203, Post Office Box 7604
Ben Franklin Station
Washington, DC 20044
Re: Proposed Regulations under Section 951A
Ladies and Gentlemen:
This letter provides comments on behalf of the Securities Industry and Financial Markets Association (“SIFMA”)1 regarding the proposed GILTI regulations.
Our recommendations are set out below. The attached paper describes the rationale for the recommendations, provides examples illustrating the need for them, and sets out suggested language to implement them.
We recommend that:
1. A basis adjustment rule that is designed to prevent taxpayers from applying a single economic loss to derive tax benefits twice should not apply when its effect would be to prevent taxpayers from using the loss even once.