Government Submissions

    The mission of the Section of Taxation is to serve our members and the public by providing education about taxes and tax systems, and by providing leadership to support the development of an equitable, efficient and workable tax system.

    Government Submissions, Archives & Policy Materials

    All of our policy materials and government comments are gathered here. The policy archives go all the way back to 1997.

    Temporary Regulations under Section 245A, Proposed Regulations under Sections 951A and 958, and Final Regulations under Section 9 (September 11, 2019)
    Proposed Regulations under Section 1297 with respect to PFICs (September 9, 2019)
    Guidance Under Sections 2631(c) and 2010(c)(3) as Modified by Pub. L. No. 115-97 (August 13, 2019)
    Proposed Elimination of Attorney Positions from the IRS Office of Professional Responsibility (August 7, 2019)
    Additional Recommendation for Priority Guidance Plan (July 18, 2019)
    Application of the Active Trade or Business Requirement under Section 355(b) (July 17, 2019)
    Section 4960, Notice 2019-9 and Volunteers Providing Services to Tax-Exempt Organizations (July 12, 2019)
    Proposed Regulations under Section 1446(f) (July 10, 2019)
    The Impact of Proposed Regulations Regarding Investments in Qualified Opportunity Funds Under Section 1400Z-2 on Consolidated Groups (July 8, 2019)
    Proposed Regulations Regarding Investments in Qualified Opportunity Funds Under Section 1400Z-2 (July 1, 2019)
    Information Collection – Change of Address Under OMB Control Number 1545-1163 (July 1, 2019)
    Proposed Revenue Procedure in Notice 2019-07 Regarding Section 199A and Rental Real Estate Enterprises (June 27, 2019)
    Proposed Regulations Addressing Section 250 (June 20, 2019)
    Recommendations for the 2019-2020 Priority Guidance Plan (June 7, 2019)
    Proposed Regulations Addressing Section 59A (May 15, 2019)
    Proposed Regulations under Section 163(j) and its interaction with Section 108 (May 13, 2019)
    Final Regulations Under Section 199A (April 18, 2019)
    Proposed Guidance under Section 168(k) Regarding Consolidated Returns (March 28, 2019)
    Treatment of Applicable Partnership Interests Under Section 1061 (March 22, 2019)
    Proposed Regulations Concerning Foreign Tax Credits (March 18, 2019)
    Impact of the Proposed Regulations under Section 163(j) on Passthrough Entities and their Owners (March 7, 2019)
    Impact of the Proposed Regulations under Section 163(j) on Real Estate (February 28, 2019)
    Definition of Interest in the Proposed Regulations under Section 163(j) (February 26, 2019)
    Treatment of Corporate Taxpayers and Consolidated Groups in Proposed Guidance under section 163(j) (February 26, 2019)
    Treatment of Partnerships in Proposed Regulations under Section 168(k) (February 12, 2019)
    Proposed Regulations under Section 951A in Relation to Passthrough Entities and their Owners (January 16, 2019)
    Proposed Regulations Regarding Investments in Qualified Opportunity Funds Under Section 1400Z-2 (January 10, 2019)
    Qualifying Insurance Corporation Exception from Passive Foreign Investment Company Status under Section 1297(f) (January 3, 2019)
    Recent Changes to the Transcript Delivery System (December 13, 2018)
    Regulatory Implementation of New Section 512(a)(6) in Response to Notice 2018-67 (December 4, 2018)
    Proposed Regulations Concerning Section 951A (November 21, 2018)
    Proposed Regulations Addressing Section 965 (October 29, 2018)
    Proposed Regulations Regarding the Deduction for Qualified Business Income Under Section 199A (October 12, 2018)
    Tax Court Rules of Practice and Procedure Relating to the Appearance and Representation before the Court (October 3, 2018)
    Guidance Regarding Draft 2018 Form 1040 and Related Schedules (October 2, 2018)
    Model Uniform Statute and Regulation for Reporting Adjustments to Federal Taxable Income and Federal Partnership Audit Adjustments (Sep. 10, 2018)
    Guidance Regarding Sections 512(a)(7) and 4960 (August 28, 2018)
    Treatment of Losses and Certain Other Issues with Respect to the Section 199A Deduction (July 23, 2018)
    Regulatory Implementation of New Section 512(a)(6) (June 21, 2018)
    Scope of a Specified Service Trade or Business within the Meaning of Section 199A (June 18, 2018)
    Second Set of Recommendations for 2018-2019 Priority Guidance Plan (June 15, 2018)
    Subchapter K Guidance with Respect to the Interaction of Section 168(k) as amended by PL 115-97 and Certain Provisions of Subchapter K (June 7, 2018)
    Regarding HR 5444 - "Taxpayer First Act" (June 6, 2018)
    Concerning the Aggregation and Disaggregation of Trade or Business Activities for Purposes of Section 199A (May 31, 2018)
    Recommendations for 2018-2019 Priority Guidance Plan (May 24, 2018)
    Regarding the OVDP and Streamlined Procedures (May 2, 2018)
    Memorandum of Agreement dated April 11, 2018 Review of Tax Regulations Under Executive Order 12866 (April 26, 2018)
    Notice 2017-73 regarding donor advised funds (April 19, 2018)
    Tax Treatment of Cryptocurrency Hard Forks for Taxable Year 2017 (March 19, 2018)
    Need for Guidance Under Sections 864(c)(8) and 1446(f) (March 19, 2018)
    Proposed Regulations Issued Under Section 514 (the “Fractions Rule”) (March 15, 2018)
    Letter on RUUPA (February 15, 2018)
    Revenue Procedure 99-21 (February 1, 2018)
    Section 402(b) and Foreign Plans (January 31, 2018)
    Fiscal Year 2018 Funding for the Internal Revenue Service (January 16, 2018)
    Follow-up Letter: Timeliness of Electronic Tax Return after Failed Transmission (January 12, 2018)
    2017 Regulatory and Legislative Submissions
    2016 Regulatory and Legislative Submissions
    2015 Regulatory and Legislative Submissions
    2014 Regulatory and Legislative Submissions
    2013 Regulatory and Legislative Submissions
    2012 Regulatory and Legislative Submissions
    2011 Regulatory and Legislative Submissions
    2010 Regulatory and Legislative Submissions
    2009 Regulatory and Legislative Submissions
    2008 Regulatory and Legislative Submissions
    2007 Regulatory and Legislative Submissions
    2006 Regulatory and Legislative Submissions
    2005 Regulatory and Legislative Submissions
    2004 Regulatory and Legislative Submissions
    2003 Regulatory and Legislative Submissions
    2002 Regulatory and Legislative Submissions
    2001 Regulatory and Legislative Submissions
    2000 Regulatory and Legislative Submissions
    1999 Regulatory and Legislative Submissions
    97-98 Regulatory and Legislative Submissions

    Join the Section of Taxation

    Be a part of the largest, most prestigious group of tax lawyers in the country.

    Join the - Section of Taxation

    Section Publications

    For more than 85 years, the ABA Section of Taxation has delivered outstanding service to its members by dedicating resources to providing the most current information and analysis for tax lawyers and tax professionals.

    Learn More about our - Publications