SIFMA Recommendations for 2019-2020 Priority Guidance Plan
Summary
SIFMA’s comments to the Internal Revenue Service (IRS) and U.S. Department of Treasury (Treasury) on guidance projects in the 2019-2020 Priority Guidance Plan as requested by Notice 2019-302. SIFMA members support the decision to prioritize guidance under the Tax Cuts and Jobs Act (TCJA).
Excerpt
June 7, 2019
The Hon. David Kautter
Assistant Secretary for Tax Policy
U.S. Department of Treasury
1500 Pennsylvania Ave. NW
Washington, DC 20005
Michael J. Desmond
Chief Counsel
Internal Revenue Service
1111 Constitution Ave NW
Washington, DC 20024
William M. Paul
Deputy Chief Counsel (Technical)
Internal Revenue Service
1111 Constitution Ave NW
Washington, DC 20024
Re: SIFMA Recommendations for 2019-2020 Priority Guidance Plan
Dear Mr. Kautter, Mr. Desmond and Mr. Paul:
The Securities Industry and Financial Markets Association (SIFMA)1 welcomes the opportunity to comment on guidance projects in the 2019-2020 Priority Guidance Plan as requested by Notice 2019-302. As explained by the Notice, the IRS and Treasury focused their efforts last year on guidance projects necessary to implement the Tax Cuts and Jobs Act, P.L. 115-97, and that prioritizing TCJA guidance during the 2019-2020 plan year will continue. The Notice noted that there were some projects listed in the 2018-2019 plan not related to TCJA that were not completed but that it is expected they will be carried over to the 2019-2020 plan, adding that there will be a limited number of new non-TCJA guidance projects in the coming year.
Our members support the decision to prioritize guidance under TCJA, and we appreciate the opportunity to comment on the proposed regulations under IRC Sections 59A, 163(j), 951A, and 1446(f) among many other new code sections. With regard to pre-TCJA laws and regulations, our members also greatly appreciate the December 2018 proposed regulations issued under FATCA pursuant to the burden reduction mandates of E.O. 13777 and E.O. 137893 and the extension of transition relief under IRC 871(m) in Notice 2018-72. Nevertheless there are additional areas where our members believe guidance would be helpful to resolve important questions faced by our members and their clients. Such guidance would reduce the tax regulatory burden by clarifying existing law.
1 SIFMA is the voice of the U.S. securities industry. We represent the broker-dealers, banks and asset managers whose nearly 1 million employees provide access to the capital markets, raising over $2.5 trillion for businesses and municipalities in the U.S., serving clients with over $18.5 trillion in assets and managing more than $67 trillion in assets for individual and institutional clients including mutual funds and retirement plans. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
2 https://www.irs.gov/pub/irs-drop/n-19-30.pdf