RILA Letter on Notice 2018-23 - Transitional Guidance

The Retail Industry Leaders Association (“RILA”) thanks you for the opportunity to provide comments on Notice 2018-23 to the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) concerning proposed regulations with respect to Sections 162(f) and 6050X of the Internal Revenue Code of 1986, as amended (the “Code”).