August 5, 2021

Mr. Peter Blessing
Office of Chief Counsel, International
Associate Chief Counsel
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Mr. Kevin Nichols
International Tax Counsel, Office of Tax Policy
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

Mr. Ronald Gootzeit
Office of Associate Chief Counsel, International
Counsel, Branch 4
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Ms. Kamela Nelan
Attorney-Advisory, Office of Tax Policy
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20224

Mr. John Sweeney
Office of Associate Chief Counsel, International
Special Counsel
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Mr. Subin Seth
Office of Associate Chief Counsel, International
Senior Counsel
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Re: Final Regulations Under Section 1446(f) – Request for Delay

Dear Ladies & Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates your consideration of our comments on the proposed regulations under section 1446(f) relating to transfers of interests in publicly traded partnerships (“PTPs”) by foreign persons as well as our subsequent letter on the final regulations sent on February 24th, 2021 (attached, for reference). While we understand that you are still reviewing our most recent submission, SIFMA would like to reiterate the following concerns that our members view as in need of clarification in order to properly implement the regulations. We fully acknowledge and commend you for the work that
went into drafting and finalizing these regulations as well as the continued engagement of the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) as our members work to operationalize the regulations.