Internal Revenue Service
CC:PA:LPD:PR (REG-105600-18) Room 5203,
Post Office Box 7604
Ben Franklin Station
Washington, DC 20044

Re: Proposed Foreign Tax Credit Regulations (REG-105600-18)

Ladies and Gentlemen,

This letter and the attached paper provide comments on the proposed foreign tax credit regulations. The comments were prepared by a task force of the Federal Tax Committee of the Securities Industry and Financial Markets Association (“SIFMA”).1

The TCJA made sweeping changes to the U.S. tax treatment of foreign business income: perhaps the most significant in two or three generations. The Treasury Department and the IRS have provided very thoughtful guidance on an exigent timetable.

This letter focuses only on aspects of the proposed regulations with respect to which you have requested comments. We agree with many of the judgments reflected in the proposed regulations. An area where we are not in agreement, but as to which you have not requested comments, relates to the scope of the look-through rules. If you are prepared to reconsider this question, we would be happy to make a supplemental submission concerning it.

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