July 26, 2018

2008 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 Title:
n/a 12/19/08 Comments on Chapter 5 of the April 2008 Consultation Paper on Canada's International Taxation
n/a 11/24/08 Comments on the New “Plan Asset” Rules Under ERISA Section 3(42) Added by the Pension Protection Act of 2006
n/a 11/19/08 Comments Concerning Notice 2008-2
n/a 11/19/08 Comments on the Proposed “Service Provider” Regulations Under Section 408(b)(2) of ERISA
469 11/17/09 Comments in Response to Notice 2008-64
368(a)(1)(D) 10/29/08 Comments Concerning the Treatment of Stock of  the Acquiring Corporation Already Owned by the Target Corporation in a Section 368(a)(1)(D) Reorganization (10/08)
6649 and 6695 08/26/08 Comments on Proposed Regulations Under Section 6694 and 6695 (08/08)
2032 08/08/08 Comments on Proposed Regulations Under Section 2032 Relating to the Alternate Valuation Date Election
6503(j) 07/28/08 Comments Concerning Proposed Regulations Under Section 6503(j) Relating to the Suspension of the Limitations Period for Corporations Facing Designated or Related Summonses
2642(g)(1) 07/16/08 Comments Concerning Proposed Regulations Relating to Extensions of the Time Under Section 2642(g)(1)
n/a 07/16/08 Comments Concerning the Instructions for the Redesigned Form 990 for Tax-Exempt Organizations
n/a 07/15/08 Comments on Notice 2007-88: Proposed Procedural Changes for Obtaining the Commissioner’s Consent to Change a Method of Accounting
6011 and 6111 07/07/08 Supplemental Comments on Proposed Regulations Under Sections 6011 and 6111 of the Internal Revenue Code relating to Patented Transactions (REG-129916-07)
n/a 06/10/08 Comments Concerning Real Estate Investment Trust Liquidations and Notice 2007-55
n/a 06/10/08 Recommendations for 2008-2009 Guidance Priority List
1.367(b)-4(b)(1)(iii) 05/08/08 Comments Concerning Example 4 of Regulation Section 1.367(b)-4(b)(1)(iii)
529 05/05/08 Comments Concerning Guidance under Section 529
409A 05/01/08 Comments on a Correction Program for Nonqualified Deferred Compensation Plan Failures under Section 409A
337(d) 05/01/08 Comments Concerning Final Regulations under Section 337(d) Relating to Conversion Transactions
125 04/29/08 Comments Concerning Proposed Regulations Under Section 125
704(c)(1)(B) and 737 04/18/08 Comments on Proposed Regulations Concerning Consequences of Certain Mergers under Section 704(c)(1)(B) and 737
368(a)(1)(D) 04/16/08 Comments on Proposed and Temporary Regulations Under Code Section 368(a)(1)(D)
6694 04/03/08 Comments on the 2007 Amendment to Section 6694 Preparer Penalty
6011, 6111 01/29/08 Comments Concerning Proposed Regulations under Section 6011 and 6111 of the Internal Revenue Code Relating to Patented Transactions (01/08)
Tax Section Oral Testimony on Reporting of Patented Tax Transactions
n/a 01/23/08 Comments Concerning ERISA Bonding Rules

 

Congress

I.R.C. § Submitted Title:
n/a 12/19/08 Comments on Chapter 5 of the April 2008 Consultation Paper on Canada's International Taxation
n/a 11/24/08 Comments on the New “Plan Asset” Rules Under ERISA Section 3(42) Added by the Pension Protection Act of 2006
n/a 11/19/08 Comments Concerning Notice 2008-2
n/a 11/19/08 Comments on the Proposed “Service Provider” Regulations Under Section 408(b)(2) of ERISA
469 11/17/09 Comments in Response to Notice 2008-64
368(a)(1)(D) 10/29/08 Comments Concerning the Treatment of Stock of  the Acquiring Corporation Already Owned by the Target Corporation in a Section 368(a)(1)(D) Reorganization (10/08)
6649 and 6695 08/26/08 Comments on Proposed Regulations Under Section 6694 and 6695 (08/08)
2032 08/08/08 Comments on Proposed Regulations Under Section 2032 Relating to the Alternate Valuation Date Election
6503(j) 07/28/08 Comments Concerning Proposed Regulations Under Section 6503(j) Relating to the Suspension of the Limitations Period for Corporations Facing Designated or Related Summonses
2642(g)(1) 07/16/08 Comments Concerning Proposed Regulations Relating to Extensions of the Time Under Section 2642(g)(1)
n/a 07/16/08 Comments Concerning the Instructions for the Redesigned Form 990 for Tax-Exempt Organizations
n/a 07/15/08 Comments on Notice 2007-88: Proposed Procedural Changes for Obtaining the Commissioner’s Consent to Change a Method of Accounting
6011 and 6111 07/07/08 Supplemental Comments on Proposed Regulations Under Sections 6011 and 6111 of the Internal Revenue Code relating to Patented Transactions (REG-129916-07)
n/a 06/10/08 Comments Concerning Real Estate Investment Trust Liquidations and Notice 2007-55
n/a 06/10/08 Recommendations for 2008-2009 Guidance Priority List
1.367(b)-4(b)(1)(iii) 05/08/08 Comments Concerning Example 4 of Regulation Section 1.367(b)-4(b)(1)(iii)
529 05/05/08 Comments Concerning Guidance under Section 529
409A 05/01/08 Comments on a Correction Program for Nonqualified Deferred Compensation Plan Failures under Section 409A
337(d) 05/01/08 Comments Concerning Final Regulations under Section 337(d) Relating to Conversion Transactions
125 04/29/08 Comments Concerning Proposed Regulations Under Section 125
704(c)(1)(B) and 737 04/18/08 Comments on Proposed Regulations Concerning Consequences of Certain Mergers under Section 704(c)(1)(B) and 737
368(a)(1)(D) 04/16/08 Comments on Proposed and Temporary Regulations Under Code Section 368(a)(1)(D)
6694 04/03/08 Comments on the 2007 Amendment to Section 6694 Preparer Penalty
6011, 6111 01/29/08 Comments Concerning Proposed Regulations under Section 6011 and 6111 of the Internal Revenue Code Relating to Patented Transactions (01/08)
Tax Section Oral Testimony on Reporting of Patented Tax Transactions
n/a 01/23/08 Comments Concerning ERISA Bonding Rules

 

Other

To Submitted Document:
Advisory Panel on Canada’s System of International Taxation Submission
12/19/08
Comments Regarding Transfer Pricing as Related to Enhancing Canada’s International Tax Advantage
Department of Labor 2/29/08 Comments on the New Service Provider Exemption Under Section 408(b)(17) of ERISA