Letter to IRS Concerning Notice 2017-28, 2017-2018 Priority Guidance Plan - Sourcing, Partnership, and Effectively Connected Income Matters

Abstract

This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority Guidance Plan. Recommendations in this letter cover the following areas:

1. Modernization of Sourcing of Income and Effectively Connected Income Regulations.

2. Issuance of Revenue Ruling on Partnership Status for Certain Profit-Shifting Structures.

3. Designating MNC Profit-Shifting Structures as Listed Transactions.

4. Profit-Shifting Structures Implemented Following Inversions and Acquisitions by Foreign Acquirers.

Keywords: Profit Shifting, Partnerships, Effectively Connected Income

JEL Classification: H21, H25, K34, E62