Comment from Brownstein Hyatt Farber Schreck

Summary: Brownstein Hyatt Farber Schreck, LLP, representing a client, recommends that the IRS and Treasury include a limited base-erosion payment exception in the 2026-2027 Priority Guidance Plan. They argue that this modification is necessary to avoid double taxation for U.S. multinational businesses regarding payments to a CFC that are already subject to tax on a net basis under Subpart F.