Comment from Money Services Business Association

Summary: The Money Services Business Association (MSBA), representing the non-bank money services industry, opposes several aspects of the proposed regulations for the remittance tax. They argue that the semi-monthly deposit requirement is operationally burdensome for small retail agents, and they request the elimination of the tax-avoidance provision, a change in the timing of tax attachment to when funds are received, and an extension of the transition relief period.