TEI Comments on Corporate Tax Reform Implementation Issues and Guidance Priorities.

• Position: Tax Executives Institute

On May 17,2018, TEI submitted comments to the 1RS Office of Associate Chief Counsel (Corporate) concerning the federal corporate income tax issues of greatest mutual concern to TEI members as they work to apply, and comply with, the provisions of Public Law 115-97. TEI's comments, which are reprinted below, were developed by a cross-industry group of senior Federal Tax Committee and Tax Reform Task Force members under the coordination of Watson M. McLeish, Tax Counsel for the Institute.

On behalf of Tax Executives Institute, Inc., thank you for inviting our Executive Director, Eli J. Dicker, and Tax Counsel, Watson M, McLeish, to participate in your roundtable discussion with other stakeholder organizations on April 4. As the preeminent association of in-house tax professionals worldwide, with more than 7,000 members representing a cross-section of the business community, TEI is dedicated to supporting the development and effective implementation of sound tax policy, promoting the uniform and equitable enforcement of the tax laws, and reducing the cost and burden of administration and compliance to the benefit of taxpayers and government alike.

TEI members are responsible for administering the tax affairs of their companies and must contend daily with the provisions of the tax law relating to the operation of business enterprises, including those introduced or amended by Public Law 115-97--of which there are many. We believe the diversity and professional experience of our members enables TEI to bring a balanced and practical perspective to the corporate tax issues raised by Public Law 115-97, and we are eager to assist Treasury and the Service in your important, collective efforts to implement the new law.

As discussed on April 4, the Institutes legal staff has been working with a diverse, cross-industry group of senior TEI members to distill a responsive list of corporate tax guidance priorities in the wake of comprehensive tax reform. The enclosed list is intended to elevate those corporate income tax issues that are of greatest mutual concern to our members as they work to apply and comply with the provisions of Public Law 115-97. Where appropriate, the enclosed list also includes TEI's recommendations for addressing certain issues raised therein. TEI greatly appreciates this opportunity to contribute its input and engage constructively with the Service in the tax reform implementation process. The enclosed comments were developed under the aegis of TEI's Tax Reform Task Force. Watson M. McLeish, Tax Counsel for the Institute, coordinated their preparation. Should you have questions about TEI's comments, please contact Mr. McLeish at 202.470.3600 or wmcleish@tei.org.

Tax Executives Institute, Inc. Corporate Tax Reform Implementation Issues and Guidance Priorities May 17, 2018 Cost Recovery and Accounting Methods Provision Subject Section 13201 of the Act; Temporary 100-percent section 168(k) of the Code Expensing for Certain Business Assets Sections 13201 and 13204 Temporary 100-percent of the Act; section 168 of Expensing for Certain Business the Code Assets; Applicable Recovery Period for Real Property Section 13221 of the Act; Certain Special Rules for section 451 of the Code Taxable Year of Inclusion Cost Recovery and Accounting Methods Provision TEI Comments and Recommendations Section 13201 of the Act; The new bonus depreciation rules in Public section 168(k) of the Code Law 115-97 (the "Act") (1)...