On August 14, TEI responded to a request for comments concerning proposed regulations under Section 6418 regarding the transferability of certain credits to unrelated taxpayers. TEI’s comments included concerns about burdensome registration and election requirements and about provisions that substantially limit the taxpayers’ ability to take advantage of the credit transfer regime, as well as requests for clarification on he 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, plus a request for additional guidance on audit procedures and enforcement mechanisms.
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