Recommendations on proposed regulations under Section 1446(f)

Published on:
December 20, 2019
Submitted to:
IRS, Treasury
Submitted by:
SIFMA

Summary

SIFMA provided comments to the Internal Revenue Service (IRS) and U.S. Department of the Treasury (Treasury) regarding Recommendations on proposed regulations under section 1446(f).

Excerpt

December 20, 2019

Mr. Chip Harter

Deputy Assistant Secretary

International Tax Affairs

U.S. Department of the Treasury

1500 Pennsylvania Avenue, NW

Washington, DC 20224

Ms. Erika Nijenhuis

Senior Counsel, Office of Tax Policy

U.S. Department of the Treasury

1500 Pennsylvania Avenue, NW

Washington, DC 20224

Ms. Kamela Nelan

Attorney-Advisor, Office of Tax Policy

U.S. Department of the Treasury

1500 Pennsylvania Avenue, NW

Washington, DC 20224

Mr. Ronald Gootzeit

Office of Associate (Chief Counsel), International

Counsel, Branch 4

Internal Revenue Service

1111 Constitution Avenue, NW

Washington, DC 20224

Mr. John Sweeney

Office of Associate (Chief Counsel), International

Branch Chief, Branch 8

Internal Revenue Service

1111 Constitution Avenue, NW

Washington, DC 20224

Re: Recommendations on proposed regulations under section 1446(f)

Dear Gentlemen and Madams:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to further respond to the request for comments in the Notice of Proposed Rulemaking under Section 1446(f)2 relating to transfers of interests in publicly traded partnerships (“PTPs”) by foreign persons. On July 15, 2019, SIFMA submitted comments to the proposed regulations (the “Prior Letter”)3, which were discussed at a meeting between SIFMA members and individuals from the IRS and Treasury on August 8, 2019. We greatly appreciate your time and efforts in meeting with us and have prepared this letter to address certain questions and concerns raised at the meeting.

Continue Reading

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.