Public Policy: 2004 Comments, Section of Taxation (ABA

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Comments on Regulations and Administrative Rulings – 2004
The comments listed in this Index represent the individual views of the ABA Section of Taxation members who prepared them. They have not been approved by the Section of Taxation, the House of Delegates or the Board of Governors of the American Bar Association and should not be construed as representing the policy of the Association or of the Section.
Documents are provided in Adobe Acrobat format unless otherwise indicated.
Submissions to U.S. Treasury Dept. & IRS
 I.R.C. §  Submitted  Comments Concerning: 
n/a12/21/04Proposed Changes to the Internal Revenue Service’s Classification Settlement Program to Resolve Worker Classification Cases
137411/23/04Adjustment to Net Unrealized Built-in Gains and Losses
95111/22/04Pro Rata Share Determinations Under Subpart F
263210/12/04Proposed Regulations Relating to the Election Not to Have Automatic Allocation of Generation-Skipping Transfer Tax Exemption Apply to Certain Transfers to a GST Trust (Reg-153841-02)
n/a9/2/04Identification of Potential Increased Thresholds and “Safe Harbors”
7048/10/04Temporary and Proposed Regulations Governing Allocation of Partnership Expenditures for Foreign Taxes (TD 9121; Reg-139792-02)
3687/19/04Proposed Regulations on Continuity of Business Enterprise and Certain Related Issues
7047/13/04Anti–Mixing Bowl Rules in Partnership Mergers (Revenue Ruling 2004-43)
3685/26/04Transfers of Assets Following Putative Reorganizations
5015/25/04Section 501(c)(4) and Political Activity
3685/14/04The Effect of Pre-Closing Changes of Acquiror Stock Value on Continuity of Interest
n/a5/12/04LMSB Productivity Improvement Phase II
various5/10/04Deposit Requirements for Employment Taxes in Connection with the Exercise of Nonstatutory Stock Options
10315/5/04Rev. Proc. 2000-37 Safe Harbor Build-To-Suit Exchanges Involving Leasehold Improvements
7524/5/04Characterization of a Partnership Liability Under Section 752 Where a Disregarded Entity is a General Partner
7074/2/04Disguised Sales of Partnership Interests
13614/2/04Request for Revenue Ruling on S Corporation Qualifying Director Shares
871, 8813/18/04Need for Guidance on Portfolio Interest Rules under Sections 871(h) and 881(c) of the Internal Revenue Code
421, 422, 4242/12/04Proposal on Incentive Stock Options Under Sections 421, 422 and 424 of the Internal Revenue Code
various2/6/04Revenue Ruling 2002-41, 2002-28 IRB 75 and Notice 2002-45, 2002-28 IRB 93
4032/5/04Code Section 403(b) Regulations Project
n/a2/4/04Proposed Changes to Form 656, Offer-in-Compromise
various2/4/04National Taxpayer Advocate's Practitioner Licensing Proposal
14461/27/04Proposed Regulations on the Obligation of Partnerships to Withhold Tax Under Section 1446 on Effectively Connected Taxable Income Allocable to Foreign Partners
4821/23/04Proposed Regulations on Treatment of Services and Intangibles Under Section 482
Submissions to Foreign Revenue Agencies
Code §  Submitted  Comments Concerning: 
n/a1/15/04Canada Customs and Revenue Agency Income Tax Information Circular Number IC 71-17R5

Review Additional Comment Submissions
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Section of Taxation Public Policy Index

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