Letters to Agencies

Comments to SEC in Support of Legal Entity Identifier (LEI) Requirements

The FACT Coalition filed a comment on January 2, 2018 with the U.S. Securities and Exchange Commission (SEC) supporting the agency’s proposal to mandate the disclosure of Legal Entity Identifier (LEI) numbers by public companies and their subsidiaries.  The Coalition also urged requiring all public companies to obtain LEIs, ensuring that the LEIs are disclosed in a machine-readable format, and mandating that companies disclose all of their subsidiaries in their disclosures, rather than simply their “significant” subsidiaries.

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Comments to GSA Urging Non-Proprietary, Open Identifier System in Procurement

The Financial Accountability and Corporate Transparency Coalition (FACT Coalition) submitted the below comments to the General Services Administration (GSA), in response to RFI #ID15170001, urging the agency to adopt a non-proprietary, open identifier system for use in federal procurement that includes the collection of information on the real people who own and control bidders of federal contracts and grants (also known as ‘beneficial owners’).

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FACT Comments to Treasury/IRS in Support of Proposed ‘Serial Inverter’ Rule

Rule Would Help Address Problem of Corporate Tax Inversions

The FACT Coalition submitted comments in support of a proposal from the U.S. Department of the Treasury to combat an egregious corporate tax avoidance technique known as serial inverters.  The rule is one of two Treasury proposals aimed at combatting so-called corporate tax inversions.  FACT also submitted comments supporting the other proposal, which targets “earnings stripping.”

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FACT Comments to Treasury/IRS in Support of Proposed Earnings Stripping Rule

Rule Would Help Address Problem of Corporate Tax Inversions

The FACT Coalition submitted comments in support of a proposal from the U.S. Department of the Treasury to combat an egregious corporate tax avoidance technique known as earnings stripping.  The rule is one of two Treasury proposals aimed at combatting so-called corporate tax inversions.  FACT also submitted comments supporting the other proposal, which targets “serial inverters.”

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FACT Comments to SEC on Concept Release Urge Public Country-by-Country Reporting

Public Disclosure of Country-by-Country Tax Information Would Better Inform Investors

The Financial Accountability and Corporate Transparency (FACT) Coalition submitted comments to the U.S. Securities and Exchange Commission on Wednesday, July 6, 2016 urging that—to better inform investors—the SEC should revise its international tax disclosure framework to specifically require multinational corporations to disclose information on taxes and profits on an annual, country-by-country basis.

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