The Clearing House Association submitted a reply to Internal Revenue Service Commissioner Shulman’s request that we provide him with a list of the major areas of current Treasury tax regulations which, in our members’ view, are most in need of additional, clarifying guidance. TCH recommends increased reliance on book-tax conformity generally, recommends a purposive approach under § 382 of the Internal Revenue Code for certain situations not involving the potential for abuse, suggests that the Internal Revenue Service reconsider its position regarding the "all or nothing" rule and other unnecessarily punitive tax consequences of the dual consolidated loss rules and suggests that the Internal Revenue Service clarify that swaps with upfront payments that are notional principal contracts cleared through a U.S. clearinghouse by a controlled foreign corporation of a U.S. shareholder that owns an interest in the clearinghouse do not create “deemed loans” under § 956 of the Internal Revenue Code.