Recommendations on proposed regulations under Section 1446(f)
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.