Draft Recommendations for 2020-2021 Treasury/IRS Priority Guidance Plan - Comments Requested
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June 26, 2020 TO: Tax Committee RE: Draft Recommendations for 2020-2021 Treasury/IRS Priority Guidance Plan - Comments Requested
Notice 2020-47 invites public comment on recommendations for Treasury’s 2020-2021 Priority Guidance Plan. The requests for guidance in this letter are largely based on prior recommendations except for the additions regarding electronic filings and signatures, Certifications of Residency, and fund liquidations.
The only item removed from last year’s requests for guidance is “Pass-through of Section 199A deduction for RIC shareholders” because it has been resolved.
The priority requests for guidance included in the main section of the draft letter, include:
- Electronic Filing and Signatures;
- Electronic Filing of Form 8802, Application for US Residency Certification and processing of Form 6166, Certification of US Tax Residency
- Fund Liquidations
- Section 451(b);
- Section 163(j) interest expense limitation;
- UMBS TBA contracts and diversification under Section 817(h);
- Check-the-box election;
- Taxable mortgage pools;
- Qualified interest income;
- Foreign tax recoveries from the EU; and
- Money market fund reform
We will discuss the recommended items, including the order of priority, at the tax committee meeting on Tuesday, June 30th. Please provide any comments on this draft to Katie Sunderland at katie.sunderland@ici.org by close of business Monday, July 20th.
Katie Sunderland
Assistant General Counsel