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.

    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)
    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

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