Chamber of Commerce Is Pleased With Proposed Bond Arbitrage Regs

June 15, 2018

Mr. Spence Hanemann
Attorney
CC:PA:LPD:PR (REG-106977-18)
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044

RE: Arbitrage Investment Restrictions on Tax-Exempt Bonds

Dear Mr. Hanemann:

The U.S. Chamber of Commerce strongly applauds REG-106977-18, which proposes amendments to the tax regulations on the arbitrage investment restrictions under § 148¹ to allow for greater capital investment in public infrastructure.

The Chamber has long championed the need for an infrastructure package that modernizes our outdated and crumbling infrastructure system. The Chamber has proposed a variety of options that can help increase investment tools in financing and funding infrastructure, including building upon existing federal credit instruments such as Private Activity Bonds (PABs) and expanding eligibility and raising caps on PABs. Accordingly, the Chamber appreciates this proposed clarification of the regulatory definition of investment type property under Regs. § 1.148-1(e)(1). It will help ensure investment in public infrastructure is not unnecessarily impeded.

The Chamber appreciates the work of the Treasury and Internal Revenue Service to provide increased access to capital for vital public infrastructure projects. We look forward to working with you to continue to update our tax code and encourage increased investment in our communities.

Sincerely,

Caroline L. Harris

Ed Mortimer

Chamber of Commerce of the United States of America

CC:
David J. Kautter, Assistant Secretary, Office of Tax Policy, U.S. Department of the Treasury
Derek Kan, Under Secretary, Office of the Under Secretary for Transportation Policy, United States Department of Transportation
Alexander H. Herrgott, Associate Director for Infrastructure, White House Council on Environmental Quality, Executive Office of the President