EFTA00301255.txt

"the Senate Finance Committee investigated the EDC program and concluded that... some U.S. taxpayers... were able to gain EDC benefits by falsely claim"

"the GVI created the EDC Program"

"the 2012 closure of the HOVENSA refinery, which had been the Territory's largest private employer"

"BARRY J. HART Partner [at] Winston & Strawn LLP"

"To: Brenda Zent From: Barry J. Hart Date: June 26, 2014"

"GVI March 31, 2011 Submission to Michael F. Mundaca"

"Michael F. Mundaca, Assistant Secretary of Treasury for Tax Policy"

"Mark J. Mazur Assistant Secretary (Tax Policy) Department of the Treasury"

"John A. Koskinen Commissioner Internal Revenue Service"

"William J. Wilkins Chief Counsel Internal Revenue Service"

"Dear Secretary Mazur... I am writing on behalf of the Government of the United States Virgin Islands"

"Dear Secretary Mazur, Commissioner Koskinen, and Mr. Wilkins"

"Dear Secretary Mazur, Commissioner Koskinen, and Mr. Wilkins"

"Assistant Secretary of the Treasury Michael Mundaca"

"Assistant Secretary for Tax Policy, Mark Mazur"

"the GVI submitted a detailed memorandum to Treasury on March 11, 2011 proposing changes"

"WINSTON &STRAWN LLP Honorable Michael F. Mundaca March 31, 2011"

"WINSTON &STRAWN LLP Honorable Michael F. Mundaca March 31, 2011"

"See Letter from USVI Gov. Charles W. Turnbull to The Hon. John W. Snow, Secretary of the Treasury, April 28, 2005"

"The Honorable Michael F. Mundaca Assistant Secretary of the Treasury for Tax Policy"

"Mark Mazur, Assistant Secretary of the Treasury for Tax Policy"

"cc: Governor John de Jongh, Jr."

"In Notice 89-40, 1989-1 CB 681, the IRS announced"

"in 2008, the Treasury issued final regulations (T.D. 9391)"

"WINSTON &STRAWN LLP [header] Honorable Michael F. Mundaca [recipient] March 31, 2011"

"WINSTON &STRAWN LLP [header] Honorable Michael F. Mundaca [recipient] March 31, 2011"

"WINSTON &STRAWN LLP... Honorable Michael F. Mundaca March 31, 2011"

"WINSTON &STRAWN LLP... Honorable Michael F. Mundaca March 31, 2011"

"Congress conferred upon Treasury substantial discretion to 'create exceptions to' the stringent Section 937(a) regime"

"Congress' delegation of broad regulatory authority to Treasury with respect to ECI issues under Section 937(b)"

"both the Treasury Department and the Department of the Interior in connection with their implementation of the Jobs Act in January 2005"

"both the Treasury Department and the Department of the Interior in connection with their implementation of the Jobs Act in January 2005"

"WINSTON & STRAWN LLP Honorable Michael F. Mundaca March 31, 2011"

"Treasury, however, submitted an alternative proposal during the House-Senate Conference Committee deliberations on the Jobs Act that defined residency"

"the GVI proposes that Treasury enact the 30 day Off-Island Travel Exemption"

"WINSTON & STRAWN June 26, 2014 Page 4"

"As one former EDC beneficiary—a hedge-fund management company—explained to the GVI"

"Declaration of Percival Clouden, Appleton v. Comm 'r, No. 7717-10"

"Treasury's highly restrictive regulations governing residency and ECI have all but crippled the USVI's most successful economic development program"

"A copy of a March 31, 2011 memorandum to Michael Mundaca... explaining the need for the request is attached"

"Attached are a May 1, 2014 letter to Mark Mazur, Assistant Secretary of the Treasury for Tax Policy"

"Peter N. Hiebert Barry J. Hart Counsel to the of the U.S. Virgin Islands"

"Peter N. Hiebert Barry J. Hart Counsel to the of the U.S. Virgin Islands"

"To: The Honorable Michael F. Mundaca... From: Peter N. Hiebert... Date: March 31, 2011"

"the Government has committed significant resources to its Economic Development Commission ("EDC") program"

"The USVI Government ("Government") is committed to transforming its economy"

"the (WI requests that Treasury exercise its regulatory authority under Section 937(b) to eliminate this disparate treatment"

"Brenda Zent, Office of International Tax Counsel"

"You have asked the Government of the U.S. Virgin Islands ("OW") to explain why such a liberalization is nenqqary"

"a meeting that Governor de Jongh had with then Assistant Secretary of the Treasury Michael Mundaca in the Summer of 2010"