[28934]
April 29, 2015
TO: TAX COMMITTEE No. 18-15 RE: ICI DRAFT RECOMMENDATIONS FOR 2015-2016 TREASURY/IRS PRIORITY GUIDANCE PLAN
Notice 2015-27 invites public comment on recommendations for Treasury’s 2015-2016 Priority Guidance Plan. [1] The Institute plans to submit a letter recommending tax items on Friday, May 1, 2015.
Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2014-2015 Priority Guidance Plan, including guidance regarding: (i) foreign tax recoveries from the EU under Santander, (ii) guidance on certain issues involving deemed dividends on convertible bonds under Section 305(c), (iii) FATCA, (iv) proposed changes to the controlled group regulations, and (v) money market reform tax issues. The letter is largely based on our past recommendations for the annual Priority Guidance Plan. [2] The draft letter includes only tax items; the Institute will submit a separate letter with recommendations regarding retirement plan issues.
If you have comments on this draft, please contact me at 202-326-5826 or ryan.lovin@ici.org by 12PM EST on Friday, May 1, 2015.
Ryan Lovin
Assistant General Counsel
endnotes
[1] Notice 2015-27 is available at http://www.irs.gov/pub/irs-drop/n-15-27.pdf.
[2] For a copy of the Institute’s recommendations for the 2014-2015 Priority Guidance Plan, see Institute Memorandum #28176 available at: http://www.ici.org/my_ici/memorandum/memo28176.