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Treasury Consultation on the Proposed GILTI Regulations

Summary

SIFMA sent recommendations to the Internal Revenue Service regarding the proposed GILTI regulations concerning the changes enacted as part of the Tax Cuts and Jobs Act. SIFMA acknowledges the extraordinary burdens that have been placed on the IRS and the Treasury Department as a result of the need to prescribe timely guidance and commends the drafters for their efforts, and for the progress that they have made.

PDF

Submitted To

Internal Revenue Service

Submitted By

SIFMA

Date

16

November

2018

Excerpt

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.

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