Florida Bar Requests Relief Under Ownership Attribution Regs

December 2, 2019

 

Internal Revenue Service
CC:PA:LPD:PR (REG-104223-18)
Room 5203
Post Office Box 7604
Ben Franklin Station
Washington, DC 20044

RE: Comments to the Proposed Regulations Concerning the Modification of Section 958(b)

Dear Sir or Madam:

I am pleased to submit the Florida Bar Tax Section's comments to the Proposed Regulations concerning the repeal of Section 958(b)(4).

Principal authors for these comments were Christopher Calllahan, Paul O'Quinn, and Shawn Wolf.

Although the members of the Florida Bar Tax Section who participated in preparing these comments may have clients who would be affected by the proposed regulations, no such member has been engaged by a client to make a government submission with respect to, or otherwise to influence the development or outcome of, the specific subject matter of these comments.

The Florida Bar Tax Section is comprised of approximately 2,000 members.

As always, we will be pleased to provide additional commentary as requested. If you have any questions regarding our comments, please do not hesitate to contact us.

Sincerely,

Janette M. McCurley, Chair
Tax Section
The Florida Bar
Tallahassee, FL