Comment on FR Doc # E8-03557

Document ID: IRS-2007-0117-0006
Document Type: Public Submission
Agency: Internal Revenue Service
Received Date: May 27 2008, at 11:51 AM Eastern Daylight Time
Date Posted: June 18 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: February 28 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: May 28 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806018b3
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RE: REG-124590-07 , RIN 1545-BG Guidance regarding foreign base company sales income Dear Sirs: The National Foreign Trade Council (NFTC) requests a hearing on the proposed regulations published in the Federal Register on February 28, 2008, in a notice of proposed rulemaking (REG-124590-07) relating to the foreign base company sales income, as defined in section 954(d). The NFTC, organized in 1914, is an association of some 300 U.S. business enterprises engaged in all aspects of international trade and investment. Our membership covers the full spectrum of industrial, commercial, financial, and service activities, and the NFTC therefore seeks to foster an environment in which U.S. companies can be dynamic and effective competitors in the international business arena. The NFTC’s emphasis is to encourage policies that will expand U.S. exports and enhance the competitiveness of U.S. companies by eliminating major tax inequities in the treatment of U.S. companies operating abroad. To achieve this goal, American businesses must be able to participate fully in business activities throughout the world, through the export of goods, services, technology, and entertainment, and through direct investment in facilities abroad. Foreign trade is fundamental to the economic growth of U.S. companies. The intent of the proposed regulations as expressed in the preamble is a welcome development. The global business operations of American companies have evolved over the past several years as new substantive business models are developed to serve customers and consumers in markets around the world. The NFTC appreciates the effort put into modernizing these rules. We have nearly completed our analysis of the proposed rules and examples. We will be following up with written comments very soon. Sincerely, Catherine G. Schultz Vice President for Tax Policy

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