Application of regulatory sunset bill to tax regulations.

On July 28, 1995, Tax Executives Institute filed the following comments with the House Committee on Government Reform and Oversight, as well as the House Committee on Ways and Means, on H.R. 994, the Regulatory Sunset and Review Act of 1995. The Institute urged the House to exempt tax rules and regulations from the scope of the bill, which would require government agencies to review existing regulations every seven years and new regulations after three years and then every seven years thereafter. The review process would generally apply to "significant rules' that have resulted in, or are likely to result in, an annual effect on the economy of $100 million. Covered rules that are not reviewed would "sunset." The law itself would sunset after 10 years. TEIS comments were prepared under the aegis of its IRS Administrative Affairs Committee, whose 1994-1995 chair was Robert D. Adams of Halliburton Company.

On behalf of Tax Executives Institute, I am writing to urge that guidance issued by the Internal Revenue Service and the Department of Treasury be specifically exempted from the provisions of H.R. 994, the Regulatory Sunset and Review Act of 1995. The Institute believes that including tax rules and regulations within the scope of the sunset bill would make government less responsive to the needs of the taxpaying public and hence be counterproductive.

Background

Tax Executives Institute is a volunteer association of nearly 5,000 professionals who are responsible for managing the tax affairs of their companies. TEI represents more than 2,700 companies -- a cross-section of the business community. Our members must contend daily with business tax laws, from both tax planning and tax compliance perspectives. The Institute is firmly committed to maintaining a tax system that works -- both for taxpayers and the Internal Revenue Service. We believe the diversity and training of our members enable us to bring a uniquely balanced and practical perspective to your attention.

Discussion

Congress is currently considering legislation that would reform the process under which government rules and regulations are issued. H.R. 994 would, among other things, require government agencies to review existing regulations every seven years and new regulations after three years and then every seven years thereafter. The review process would generally apply to "significant rules' that have resulted in, or are likely to result in, an annual effect on the economy of...