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NAEDA has filed comments with the IRS concerning their notice on dual use property. NADEA followed others in the industry who also filed with the IRS including AED and Caterpillar.
What the IRS will do next is anybody’s guess. The IRS could initiate an Industry Issue Resolution process to negotiate a safe harbor with the industry, develop guidance through some other route, or drop the issue all together. However, given the fact that the IRS itself proposed to undertake this exercise, we think the latter option is the least likely.
Copies of NAEDA's and AED's filings can be found here.