Draft Recommendations for 2021-2022 Treasury/IRS Priority Guidance Plan - Comments Requested
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May 19, 2021
TO: Tax Committee RE: Draft Recommendations for 2021–2022 Treasury/IRS Priority Guidance Plan: Comments Requested
Notice 2021-18 invites public comment on recommendations for Treasury's 2021-2022 Priority Guidance Plan. The requests for guidance in this letter are largely based on prior recommendations except for an addition regarding "IRS Form SS-4 Responsible Party Requirements and Limitations."
Items removed from last year's requests for guidance are "Section 451(b)" and "Section 163(j) Interest Expense Limitation" because they have been resolved. Other items were moved from the main letter of priorities to the appendix of long-standing recommendations. These items include requests for guidance on "Check-the-Box Election," "UMBS TBA Contracts and Diversifications under Section 817(h)," "Taxable Mortgage Pools," and "Money Market Fund Reform."
The priority requests for guidance included in the main section of the draft letter, include:
- Foreign Tax Recoveries from European Union Member States under Santander
- Electronic Filing of Form 8802, Application of US Residency Certification and Processing of Form 61666, Certification of US Tax Residency
- Electronic Filing and Permanent Digital Signature Relief
- IRS Form SS-4 Responsible Party Requirements and Limitations
- Qualified Interest Income
- Fund Liquidations
Please provide any comments to this draft, including on the order of priority, to Katie Sunderland at katie.sunderland@ici.org by close of business Thursday, May 27th.
Katie Sunderland
Assistant General Counsel