Memo #
32656

ICI Submits Recommendations for 2020-2021 Treasury/IRS Priority Guidance Plan
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[32656]

August 4, 2020 TO: ICI Members
ICI Global Members
Tax Committee SUBJECTS: Tax RE: ICI Submits Recommendations for 2020-2021 Treasury/IRS Priority Guidance Plan

 

Notice 2020-47 invited public comment on recommendations for Treasury’s 2020-2021 Priority Guidance Plan. The ICI submitted the attached letter 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 was “Pass-through of Section 199A deduction for RIC shareholders” because it was resolved at the time of submission.

The priority requests for guidance included in the main section of the draft letter, include:

  1. Electronic Filing of Form 8802, Application for US Residency Certification and processing of Form 6166, Certification of US Tax Residency;
  2. Electronic Filing and Signature;
  3. Section 451(b);
  4. Section 163(j) interest expense limitation;[1]
  5. UMBS TBA contracts and diversification under Section 817(h);
  6. Check-the-box election;
  7. Taxable mortgage pools;
  8. Qualified interest income;
  9. Foreign tax recoveries from the EU;
  10. Money market fund reform; and
  11. Fund Liquidations.

The ICI submitted a separate letter on retirement security issues.[2]

 

Katie Sunderland
Assistant General Counsel
 

Attachment

endnotes

[1] The IRS finalized section 163(j) regulations and proposed regulations permitting the pass-through of 163(j) interest dividends on July 28, 2020.

[2] See Institute Letter to Treasury and IRS dated, July 22, 2020, available at: https://www.ici.org/my_ici/memorandum/memo32628