Document Type

Article

Abstract

I applaud the thought, care, logic, and thoroughness that are reflected in the recently finalized regulations in T.D. 10022 and the proposed regulation in REG-107420-24. I hope the comments set forth below will be useful to you. I am happy to respond to written questions or to discuss the comments herein by phone. If it is decided to hold public hearings and it is possible to provide testimony remotely by phone or electronic medium, then I request that I be allowed to present and discuss some of the matters raised within this submission.

In the following pages, I have provided observations and suggestions concerning both the newly finalized regulations (Reg. sections 1.861-18 and -19) and the newly proposed regulation on cloud sourcing (Prop. Reg. section 1.861-19).

Download

Share

COinS
 
 

To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.