On August 7, SIFMA’s Municipal Securities Division provided comments to the Internal Revenue Service (IRS) on IRS Notice 2017-38, “Implementation of Executive Order 13789 (Identifying and Reducing Tax Regulatory Burdens)” and the pending 2016 IRS proposal to redefine “political subdivision” for the purpose of determining issuers who are eligible to issue tax-exempt bonds. SIFMA reiterated our previous position in opposition to the proposed change and urged the Treasury Department to withdraw the proposal.