Business Roundtable is an association of chief executive officers of leading U.S. companies working to promote a thriving economy and expanded opportunity for all Americans through sound public policy.
Our members believe that informative, clear and usable disclosures are essential to thriving capital markets and place a high value on modernizing and improving disclosures in a manner that continues to provide material information to investors. We agree that a “step-back” look aimed at improving our disclosure regime is appropriate. We are concerned that immaterial line-item disclosures and duplicative disclosure requirements both burden companies and do not provide investors with information necessary to make informed decisions.
We are concerned that the proposed rule, in its current form, is overly prescriptive, could create additional tax compliance difficulties for the individuals and institutions to which it applies, and would make U.S. financial institutions less globally competitive. The proposed rule will also make it difficult for the institutions that pump capital through the U.S. and global economies to attract top talent. In addition, the proposed rule will create burdensome record keeping and corporate governance requirements.
Business Roundtable believes the approach taken in the Proposed Regulations exceeds the regulatory authority granted to Treasury by Congress under Section 385. Further, the Proposed Regulations are inconsistent with fundamental principles of U.S. tax law, prior regulatory guidance, case law precedents, and Congressional intent.
Business Roundtable has been actively engaged with lawmakers to ensure CTE programs are updated in a way that works for all stakeholders in the system, from students to the business community.
June 27, 2016
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202-2800
Dear Ms. Miller:
If the TPP is not approved this year, the United States will jeopardize a huge opportunity for U.S. growth, jobs and leadership.
Deeper collaboration among Canada, Mexico, and the United States should focus on improving our international competitiveness, supporting economic growth and jobs in our countries, facilitating the legitimate movement of people, goods, services, capital, and energy between our countries, and addressing emerging challenges such as cybersecurity.
Business Roundtable believes the proposed documentation requirements are excessive and have been proposed without adequate consideration of their costs and alternative, less costly procedures.
Business Roundtable has strong concerns about the potential business disruption, significant breadth of impact, and adverse consequences caused by the proposed regulations. Because of these concerns, and the immediate effect of the new rules, I urge Congress to require the Treasury Department to take three immediate actions: (1) extend the comment period by at least 90 days (to October 5, 2016); (2) change the effective date; and (3) provide a thorough and complete economic analysis prior to considering finalizing the regulations.
The proposed guidance, which overturns long-standing tax principles and well-established case law and regulations, will significantly increase the cost of doing business in the United States, and create further obstacles to much needed investment, job creation and economic growth.
Business Roundtable’s interest in CbC reporting stems from the fact that the information requested in these reports includes sensitive competitive business information. Safeguarding the confidentiality of this information is key, which the Treasury’s proposed CbC reporting regulations recognize by providing the same confidentiality protection to CbC reports as to other tax return information.
Business Roundtable believes that investors are entitled to the information necessary to make effective investment and voting decisions to advance a company’s long-term interests. Directors serve a vital role in overseeing a company’s business and management, and information relating to directors’ outside compensation arrangements is important to investors. Accordingly, we join NASDAQ’s call for enhanced transparency on this subject.