- Comments
On Proposed Regulations for Section 6417 Elective Payments of Applicable Credits
Comment letter submitted to the Internal Revenue Service (IRS) in response to Proposed Regulations §§1.6417-1 through 1.6417-6 on Section 6417 Elective Payment of Applicable Credits (IRS REG – 101607-23).
Print Full Comments
Agency Actions
August 14, 2023
Submitted via www.regulations.gov
(IRS REG – 101607-23)
Mr. Douglas W. O’Donnell
Deputy Commissioner for Services and Enforcement
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, D.C. 20224
Ms. Holly Porter
Associate Chief Counsel
Office of the Chief Counsel
Passthroughs & Special Industries (CC:PSI)
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, D.C. 20224
RE: Comments Re: REG – 101607-23 (Proposed §§1.6417-1 through 1.6417-6) Section 6417 Elective Payments of Applicable Credits
Ladies and Gentlemen:
The National Association of Bond Lawyers (“NABL”) appreciates the work of the Internal Revenue Service (IRS) and U.S. Department of Treasury providing guidance pertaining to tax law changes made by the Inflation Reduction Act of 2022 (Pub. L. 117-169) (the “IRA”). We wish to provide comments, attached hereto, to REG-101607-23 (proposed §§1.6417-1 through 1.6417-6) Section 6417 Elective Payments of Applicable Credits. We are also supplementing our comments in our letter, dated November 4, 2022, responding to IRS Notice 2022-49, 2022-43 I.R.B. 321 and Notice 2022-50, 2022-43 I.R.B. 325 (the “November 2022 Letter”),[1] as supplemented by our letter dated March 9, 2023 (the “March 2023 Letter”).[2] Our comments address not only the above-referenced proposed regulations but certain other issues relating to section 6417 of the Internal Revenue Code.
NABL is a nonprofit organization and specialty bar association of approximately 2,500 lawyers whose purposes include, among other things, providing advice and comment at the federal, state, and local levels with respect to legislation affecting state and municipal obligations. NABL believes that participating in the guidance process supports clarification of, and facilitates compliance with, tax laws and regulations. The following comments were prepared by a working group of the NABL Tax Law Committee (whose members are listed in Appendix 1 hereto) and were approved by the NABL Board of Directors.
Thank you in advance for your time and attention on this important matter. We look forward to hearing from you.
Best,
Joseph (Jodie) E. Smith
President
National Association of Bond Lawyers (NABL)
CC:
- Lily Batchelder, Assistant Secretary for Tax Policy, U.S. Department of Treasury
- Brett York, Deputy Tax Legislative Counsel, U.S. Department of Treasury
- Praveen Ayyagari, Attorney-Advisor, Office of Tax Policy, U.S. Department of Treasury
- Helen Hubbard, Associate Chief Counsel, CC:FIP, Internal Revenue Service
- Vassiliki Tsilas, Special Counsel to Associate Chief Counsel, CC:FIP, Internal Revenue Service
- Jian H. Grant, Branch Chief, CC:FIP:B5, Internal Revenue Service
[1] See NABL letter to Ms. Holly Porter re: “NABL Response to IRS Notice 2022-49 and IRS Notice 2022-50” sent on November 4, 2022. Web access: https://www.nabl.org/resources/response-to-irs-requests-on-ira-implementation/
[2] See NABL letter to Ms. Holly Porter re: “Supplemental Comments on IRS Notice 2022-49 and IRS Notice 2022-50” sent on March 9, 2023. Web access: https://www.nabl.org/resources/suppl-comments-ira-notices/
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