Government Submissions

2019-2021 Government Submissions

The comments listed represent the views of the ABA Section of Taxation. They have not been approved by 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.

BBA Stranded Overpayment Problem (March 24, 2021)

Proposed Regulations under Section 355 Regarding the Allocation of Non-Business Assets for Purposes of the Device Prohibition (March 19, 2021)

Proposed Regulations Regarding User Fees for Estate Tax Closing Letters (March 15, 2021)

Form W-7 and Instructions (February 10, 2021)

Form 8919 for Individual Taxpayers (February 2, 2021)

Information Reporting for SS-8 and SS-8(PR) (February 2, 2021)

Proposed Form 15227 (February 2, 2021)

Review of Regulatory and other Relief to Support Taxpayers during COVID-19 Pandemic (January 15, 2021)

OECD/G20 Inclusive Framework on BEPS Public Consultation Document on the Report on the Pillar One Blueprint (December 14, 2020)

2020 Proposed Regulations under Section 163(j) with Respect to Controlled Foreign Corporations and Their U.S. Shareholders (December 10, 2020)

Proposed Regulations Under Section 162(m) (November 19, 2020)

Final and Proposed Regulations under Section 163(j) (November 2, 2020)

Revenue Procedure 94-69 (October 20, 2020)

Applicable Partnership Interests under Section 1061 (October 5, 2020)

Proposed Regulations under Section 162(f) and Section 6050X (September 22, 2020)

Draft Schedules K-2 and K-3 (September 14, 2020)

COVID-19 and disaster losses under section 165(i) (September 14, 2020)

Notice 2020-36, Proposed Revision of Rev. Proc. 80-27 (September 9, 2020)

Proposed Regulations Under Section 4960 (August 28, 2020)

Appeals Team Case Leaders Conferencing Initiative (August 28, 2020)

Workout-Related Relief in Response to COVID-19 (August 17, 2020)

Impact of Final Regulations under Section 951A on S Corporations and their Shareholders (July 31, 2020)

Notice 2020-43 (Form 1065 and tax basis capital accounts) (July 29, 2020)

Recommendations for 2020-2021 Priority Guidance Plan (July 22, 2020)

Relief Relating to Tax-exempt Financing in Response to COVID-19 (July 21, 2020)

Proposed Regulations under Section 512(a)(6) (June 23, 2020)

Proposed Amendment to Rule 24 of the Tax Court Rules of Practice and Procedure (June 1, 2020)

Tax Implementation of the CARES Act (May 12, 2020)

Specific Substantive and Procedural Provisions Impacted by the COVID-19 Emergency (April 29, 2020)

Delivery of Economic Impact Payments to Low-Income and Vulnerable Individuals (April 13, 2020)

Collections-Related Relief in Response to COVID-19 (April 6, 2020)

Preliminary Comments on Impact on Taxpayers of COVID-19 (April 3, 2020)

Implementation of the Taxpayer First Act (March 20, 2020)

Proposed Regulations under Section 168(k) (February 19, 2020)

Proposed Regulations addressing the Classification of Cloud Transactions and Transactions Involving Digital Content (February 11, 2020)

Proposed Regulations Under Section 337(d) Regarding Partnership Transactions Involving Equity Interests of a Partner (January 29, 2020)

Potential Changes to Rev. Rul. 69-184 (Dec. 9, 2019)

Draft 2019 Form 1065 and Schedule K-1 (December 1, 2019)

Proposed Regulations Under Section 382(h) (November 12, 2019)

Proposed Regulations Under Sections 1291, 1297 and 1298 Regarding PFICs (October 9, 2019)

Proposed Collection Form 4506-T, Request for Transcript of Tax Return (September 19, 2019)

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)

Change of Address under Form 8822 (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)

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Regulatory & legislative submissions dating back to 1997.

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