January 01, 2006

    2006 Regulatory and Legislative 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. Documents are provided in Adobe Acrobat format unless otherwise indicated.

    U.S. Treasury Dept. & IRS

     I.R.C. §   Submitted  Comments Concerning:
    n/a 12/29/06 Comments on Proposed Regulations Concerning Substantiality of Partnership Allocations Made to “Look-Through” Partners (12/06)
    7216 12/11/06 Comments on Proposed Regulations under Code Section 7216 (12/06)
    n/a 12/04/06 Comments on Proposed Regulations For Cost Sharing Arrangements (12/06)
    1363 11/30/06 Comments on Proposed Regulations Under Section 1363(b) Concerning S Corporation Banks (11/06)
    1.1503(d)-1-1.503(d)-6 11/14/06 Comments on Proposed Regulations Relating to Dual Consolidated Losses (Prop. Reg. §§1.1503(d)-1-1.1503(d)-6) (11/06)
    n/a 10/27/06 Response to Notice 2006-68, Requirement of Partial Payment with Submission of Offer in Compromise (10/06)
    7122 (c)(2)(C) 10/16/06 Comments in Response to Notice 2006-68 Regarding Definition of “Low-Income” and Waiver Authority Under Section 7122 (c)(2)(C) (10/06)
    409A 09/15/06 Section Letter concerning Transition Relief From Certain Requirements of Section 409A of the IRC (09/06)
    n/a 09/15/06 Letter to IRS Oversight Board Measuring IRS Progress in Meeting Long Term Goals (09/06)
    n/a 08/03/06 Response to Notice 2006-68 Regarding Requirement of Partial Payment with Submission of Offers in Compromise (08/06)
    n/a 07/24/06 Regulations Permitting the Revaluation of Partnership Capital Accounts upon Sales of Partnership Interests (07/06)
    10.39 of Circular 230 07/21/06 The Proposed Amendments to Section 10.39 of Circular 230 (07/06)
    409A 07/05/06 Definition of a Plan under Proposed Treasury Regulations under Section 409A (07/06)
    n/a 06/28/06 Recommendations for 2006-2007 Guidance Priority List (06/06)
    409A 06/15/06 Code Section 409A Proposed Regulations Regarding Distribution Issues (06/06)
    409A 06/07/06 Modification of Stock Rights under Proposed Treasury Regulations under Section 409A (06/06)
    n/a 06/06/06 Regarding the Proposed Amendments to Circular 230 (06/06)
    7874 05/19/06 Regarding the Proposed Regulations under Section 7874 (05/06)
    148 05/03/06 Proposed Regulations under Section 148 (05/06)
    Subchapter C 04/24/06 Subchapter C No-Net-Value Regulations Proposals (04/06)
    n/a 04/17/06 Letter to the Chairman and Ranking Members of the Appropriations Committees in the U.S. Congress on IRS Funding to the House
    n/a 04/05/06 Anti-Terrorist Financial Guidelines (04/06)
    411(d)(6) 03/31/06 Proposed Regulations under Section 411(d)(6) (03/06)
    409A 03/09/06 Deferral Elections under IRC Section 409A Proposed Regulations (03/06)
    199 03/03/06 Proposed Regulations under Section 199 (03/06)
    409A 02/27/06 The Valuation of Private Company Stock and Modification of Stock Options and Stock Appreciation Rights under IRC Section 409A Proposed Regulations (02/06)
    409A 02/27/06 Stock Rights and Service Recipient Stock under IRC Section 409A Proposed Regulations (02/06)
    409A 02/22/06 Section Comments on Nonqualified Deferred Compensation Focusing on Foreign Plan Aspects under Internal Revenue Code Section 409A Proposed Regulations (02/06)
    409A 02/16/06 Separation from Service Issues Under Internal Revenue Code Section 409A Proposed Regulations (02/06)
    704(c) 02/01/06 Notice 2005-15 (02/06)
    501(c3) and 4958 01/10/06 Proposed Regulations Under Sections 501 (c)(3) and 4958 of the Internal Revenue Code of 1986 (01/06)

     

    Congress

     To:   Submitted  Document: 
    Finance/
    Ways & Means    		 10/31/06 Comments on H.R. 6264 and S. 4026: The Tax Technical Corrections Act of 2006 (10/06)
    Finance/
    Ways & Means    		 07/31/06 Section Letter Concerning Reconsideration of Section 409A of the Internal Revenue Code (07/06)
    Finance/
    Ways & Means    		 07/24/06 Report on the Uniform Definition of Qualifying Child (07/06)
    Ways & Means 04/06/06 Testimony to Oversight Subcommittee Regarding Simplification of Federal Tax Laws

    Finance/
    Ways & Means

    02/03/06

    		 Section Comments Regarding S.2020 (re: Charitable Organizations) (02/06)
    Finance/ Ways & Means 01/04/06 Comments Regarding S.2020: Tax Relief Act of 2005

     

    Other

     To:   Submitted  Document: 
    US Tax Court 11/13/06 Comments on the Proposed Amendment to Rule 173 (11/06)
    IRS Oversight Board 09/15/06 Section Letter to IRS Oversight Board Concerning Metrics Proposed by the Service's Progress in Meeting its Long-Term Goals
    US Tax Court 02/02/06 Section Comments Concerning the Tax Court's Proposed Interim Rule and Interim Procedures Regarding E-Filing Pilot Program (02/06)

    US Tax Court

    		 02/02/06 Letter to US Tax Court Chief Judge on Privacy Protection for Filings Made with the Court (02/06)