Today's release of proposed regulations to implement the $20 million medical device tax scheduled to go into effect next year drew this response from AdvaMed President and CEO Stephen Ubl: "Studies have shown the tax will cost jobs – as many as 43,000 are at risk -- at a time when the American economy is struggling and US medical technology leadership in the world market is threatened by competitor nations who have grown their industries through more favorable tax and regulatory policies. The anticipated tax has already forced companies to lay off workers and to reduce critical R&D that will help drive the next wave of treatments and cures.

"Failure to repeal the device tax flies in the face of the President's comments during the State of the Union about the need to reform our tax system to make our nation more competitive in the world market, a view shared by members of Congress from both parties. We urge the Administration and Congress to act swiftly to repeal this tax.

"We appreciate the time and effort IRS staff has spent reviewing our comments and considering the issues we raised. Implementing the tax will create a number of complex administrative and technical burdens that must be addressed. The unique characteristics of our industry make it ill-suited for blanket application of existing excise tax authorities, which were drafted for other industries at an earlier time. We will be carefully examining the proposed regulations."

The comments submitted previously by AdvaMed to the IRS regarding the implementation of the device tax may be viewed here. The accompanying letter may be viewed here.