RILA Comments on Proposed Section 385 Regulations

The Retail Industry Leaders Association (“RILA”) is the trade association of the world’s largest and most innovative retail companies. RILA members include more than 200 retailers, product manufacturers, and service suppliers, which together account for more than $1.5 trillion in annual sales, millions of American 2 jobs, and more than 100,000 stores, manufacturing facilities, and distribution centers domestically and abroad.

With nearly 18 million Americans employed in retail jobs, and more than 10 million additional jobs supported by retailers, the retail industry is America’s second-largest private employer. As a result of the retail industry’s role as a significant employer, and billions of dollars paid in federal, state, and local taxes by retail, few industries have a greater impact on the U.S. economy than retail. While the retail industry pays an average effective tax rate of 36.4%, many retailers face rates significantly higher than that. In fact, the industry’s effective tax rate is the fourth highest of all 18 major industrial sectors. Thus, taxes are a significant issue for RILA’s members.