Eminence and SIFMA submitted a comment letter to the Department of the Treasury and the IRS in response to the proposed regulations requiring an inclusion in income in respect of certain “disregarded payment losses”.
The letter highlights the following two recommendations:
- The Proposed DPL Rules should be withdrawn and re-proposed as a standalone notice of
proposed rulemaking, with a new notice-and-comment period. - The partial ownership interest rule in Proposed Regulations Section 1.1503(d)-1(d)(7)(ii) should
not apply unless the specified domestic owner is “related” to the disregarded payment entity
within the meaning of section 954(d)(3).
