ICI Submits Recommendations for 2021-2022 Treasury/IRS Priority Guidance Plan

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June 1, 2021

TO: ICI Members
Tax Committee SUBJECTS: Tax RE: ICI Submits Recommendations for 2021-2022 Treasury/IRS Priority Guidance Plan

 

Notice 2021-18 invited public comment on recommendations for Treasury's 2021-2022 Priority Guidance Plan. ICI submitted the attached letter 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," "Money Market Fund Reform," and "Fund Liquidations."

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

1. Foreign Tax Recoveries from European Union Member States under Santander
2. Electronic Filing of Form 8802, Application of US Residency Certification and Processing of Form 61666, Certification of US Tax Residency
3. Electronic Filing and Permanent Digital Signature Relief
4. IRS Form SS-4 Responsible Party Requirements and Limitations
5. Qualified Interest Income

The ICI submitted a separate letter on retirement security issues.

 

Katie Sunderland
Assistant General Counsel