Requesting additional clarity on IRS remittance excise tax
The Internal Revenue Service’s proposal on the excise tax on remittance transfers provides clarity around several rules and requirements that are necessary for credit union compliance. America’s Credit Unions filed comments in support of the proposal Friday, also requesting clarity in several areas.
The proposal provides rules and definitions relating to the excise tax imposed on certain remittance transfers that occur after December 31, 2025, as enacted in H.R. 1.
“We support the NPRM adopting existing definitions and exceptions regarding remittance transfers and ask, where possible, for the IRS to continue to prioritize consistency with existing rules,” the letter reads.
America’s Credit Unions seeks additional clarity around:
- Relevant facts and circumstances that the IRS will consider when determining whether a provider or sender structures a transaction for tax-avoidance purposes;
- IRS's anti-conduit authority to disregard or recharacterize a transaction as a method of tax avoidance; and
- Whether the proposal aligns with the Official Interpretation of Regulation E, which states that foreign military bases are treated as located in a State for the purpose of remittance transfer requirements.
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