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Comment Letters

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 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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FACT, 10 Orgs Urge Treasury, FinCEN to Complete the Anti-Money Laundering Rule for Asset Managers

The FACT Coalition along with 10 other organizations filed a comment on April 4, 2016 with the Department of the Treasury to finalize the proposed rule issued by the Financial Crimes Enforcement Network (FinCEN) to impose anti-money laundering and suspicious activity reporting requirements on registered investment advisers.  The full letter can be read below or downloaded here.

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Treasury Department

FACT Urges Treasury to Act on Inversions in Letter

The Honorable Jacob J. Lew
Secretary of the Treasury
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220
 

Dear Secretary Lew,

On behalf of the Financial Accountability and Corporate Transparency (FACT) Coalition, I am writing to urge the Department of the Treasury to take all measures within its authority to curtail the ability of corporations to avoid paying taxes by engaging in corporate inversions. Explicitly, FACT believes that the Treasury Department could take further steps to prevent inversions through the use of its regulatory authority under Sections 956 and 7701 of the U.S. Tax Code.

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