On the recordAugust 6, 2022
I rise today to engage in a colloquy with the distinguished chairman of the Senate Finance Committee, Senator Wyden. There is some question as to the proper ordering of the calculation of the credit under section 53 and a taxpayer's liability under section 59A, the base erosion and anti-abuse tax. Does the Treasury have authority to issue regulations dealing with potential issues with the ordering of the calculation of the credit under section 53 and the tax under section 59A?
