Memo #
31241

Draft Recommendations for 2018-2019 Treasury/IRS Priority Guidance Plan -- Comments Requested
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[31241]

June 7, 2018 TO: Tax Committee RE: Draft Recommendations for 2018-2019 Treasury/IRS Priority Guidance Plan — Comments Requested

 

Notice 2018-43 invites public comment on recommendations for Treasury’s 2018-2019 Priority Guidance Plan.[1] The Institute plans to submit a letter recommending tax items.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2018-2019 Priority Guidance Plan, including guidance regarding:

  1. pass-through of Section 199A deduction for RIC shareholders;
  2. amended Section 451(b);
  3. Section 965 transition tax on deferred foreign income;
  4. Section 163(j) interest expense limitation;
  5. Section 851 investments in CFCs and PFICs;
  6. qualified interest income;
  7. foreign tax recoveries from the EU;
  8. RIC Mod;
  9. deemed distributions under Section 305(c);
  10. cost basis reporting;
  11. FBAR;
  12. ownership tracking requirements under Section 382;
  13. electronic filing of Forms 1120-RIC;
  14. money market fund reform; and
  15. FATCA. 

The letter includes recommendations for guidance to resolve uncertainties arising from the 2017 tax law changes, as well as additional items largely based on prior requests for guidance.[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 katie.sunderland@ici.org by Wednesday, June 13, 2018.

 

Katie Sunderland
Counsel - Tax Law

 

Attachment

endnotes

[1] Notice 2018-43 is available at https://www.irs.gov/pub/irs-drop/n-18-43.pdf 

[2] For a copy of the Institute’s recommendations for the 2017-2018 Priority Guidance Plan, see Institute Memorandum No. 30736 available at https://www.ici.org/my_ici/memorandum/memo30736