January 01, 2009

    2009 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. ยง Submitted Comments Concerning:
    n/a 11/20/09 Comments on Build America Bonds
    n/a 10/29/09 Comments Concerning Stripping Tax Credits
    170(b)(1)(A)(vi) and 509(a)(2) 08/17/09 Comments Concerning Temporary and Proposed Regulations Implementing the Redesigned Form 990 for Tax-Exempt Organizations and Revising the Public Support Test Under Section 170(b)(1)(A)(vi) and 509(a)(2)
    n/a 07/24/09 Internal Revenue Service Public Forum on Tax Return Preparer Review
    6231(c) 06/11/09 Comments Concerning Proposed Regulations Under Section 6231(c) Relating to the Conversion of Partnership Items to Nonpartnership Items
    n/a 06/09/09 Recommendations for 2009-2010 Guidance Priority List
    6694, 7701 06/04/09 Comments on Proposed Amendments to Circular 230 Section 10.34
    482 06/03/09 Comments on Temporary Cost Sharing Agreements
    108(i) 05/05/09 Comments on the Application of Section 108(i) to Partnerships and Partners
    108(e)(8) 05/04/09 Comments on Proposed Regulations under Section 108(e)(8)
    460 04/27/09 Comments Concerning Proposed Regulations under Section 460
    856(c)(4)(A) 04/22/09 Request for Guidance on the Treatment of Interests in Money Market Mutual Funds under Section 856(c)(4)(A)
    108 02/04/09 Comments on Proposed Regulations under Section 108 Concerning Reduction of S Corporation Tax Attributes
    n/a 01/05/09 Notice 2008-19 and Segregated Arrangements That Do Not Involve Insurance

     

    Congress

    To: Submitted Document:
    Senate Finance Committee, House Ways and Means Committee 12/03/09 Comments on Foreign Account Tax Compliance Act of 2009, H.R. 3933 and S. 1934
    House/Senate Subcommittee on Financial
    Services and General Government    		 07/14/09 ABA Section of Taxation & Section of Real Property, Trust and Estate Law Statement of Policy Regarding Reform of Federal Wealth Transfer Tax
    Senate Finance Committee, House Ways and Means Committee 06/09/09 Statement of Policy Regarding U.S. International Taxation
    House/Senate Subcommittee on Financial
    Services and General Government    		 04/30/09 Joint Statement on Tax Issues in Health Care Reform
    House/Senate Subcommittee on Financial
    Services and General Government    		 04/21/09 Statement of Policy Favoring Reform of Federal Civil Tax Penalties
    House/Senate Subcommittee on Financial
    Services and General Government    		 04/14/09 IRS Funding Letter (House and Senate)

     

    Other

    To: Submitted Document:
    Office of Regulations and Interpretations Employee Benefit Security Administration U.S. Department of Labor 05/27/09 Comments on Regs Relating to the Exemptions for the Provision of Investment Advice Under Sec 408(B)(14) and Sec 408(G) of ERISA
    United States Tax Court 05/27/09 Proposed Amendments to the Rules of the United States Tax Court