On August 14, 2023, TEI submitted comments in response to a request for comments in proposed regulations under section 6418 regarding the transferability of certain credits to unrelated taxpayers. TEI's comments included concerns over burdensome registration and election requirements and over provisions that substantially limit the taxpayers able to take advantage of the credit transfer regime; requests for clarification on the reasonable cause exception for excessive credit transfers, on a potential trap for the unwary regarding the “paid in cash” requirement, and on a filing issue for taxpayers with a 52/53 week year-end; and a request for additional guidance on audit procedures and enforcement mechanisms.
Committee