On August 7, MFA submitted a comment letter to the Department of the Treasury and the Internal Revenue Service in response to the list of regulations that Treasury had identified for review pursuant to President Trump’s Executive Order on Identifying and Reducing Tax Regulatory Burdens. In the letter, MFA encouraged Treasury and the IRS to review the final regulations under section 385 of the Internal Revenue Code of 1986. Specifically, MFA encouraged Treasury and the IRS to reconsider: (1) the expanded group and modified expanded group definitions as they apply to investment funds managed by a common investment adviser; (2) withdraw or modify the proposed downward attribution rules; and (3) withdraw language from the adopting release for the final rules that provided for potential amendments to the rules regarding blocker entities used by investment funds.
