The Tax Policy Committee of SFIG submitted a comment letter today, drafted by Mayer Brown, to the IRS regarding the income tax regulations (the “Proposed Regulations”) that were proposed under section 385 of the Internal Revenue Code of 1986, as amended on April 4, 2016. The Committee is concerned that certain provisions of the Proposed Regulations may introduce risk of an adverse structural tax consequence or uncertainty as to the proper tax treatment of securitization notes, in addition to the overbreadth of the rules. SFIG’s letter provided comments requesting changes or clarifications to the Proposed Regulations to ensure that their potential application to securitization transactions does not have a market-chilling effect on the real economy.
The Treasury Department will hold a hearing of the Proposed Regulations on July 14th.
If you would like to join SFIG’s Tax Policy Committee, please contact Amanda.Bateman@sfindustry.org.