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December 31, 2009

2010 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:
415, 436 12/22/2010 Comments on PBGC proposed rule on reportable events
6662, 6694, 7525 12/07/2010 Comments on Circular 230 Sections 10.2, 10.3, 10.4, 10.5, 10.6, 10.30 and 10.34
909 11/15/2010 Comments on the Effective Date of Section 909
54AA, 148, 1273, 1274 11/09/2010 Comments on Issue Price
  10/10/2010 Comments on the Taxation of Dividend Equivalent
n/a 9/28/2010 Comments on Form 990-PF and Related Instructions
9815 9/15/2010 Comments on Preexisting Condition Exclusions
263(a) 8/23/2010 Comments on Deduction and Capitalization of Expenditures Related to Tangible Property
1471-1474 8/16/2010 Comments on Foreign Account Tax Compliance Offset Provisions of the HIRE Act
1.1275-2(c), 54A(i)(1), 54A(f),54AA(d)(2)(C), 1286 8/04/2010 Comments Concerning Stripping Tax Credits and Notice 2010-28
n/a 8/02/2010 Comments on Department of Labor Proposed Regulations on Participant Fee Disclosure
401(k), 403(b), 411(d)(6), 3401(a) 7/30/2010 Comments on the HEART Act Sections Addressed in IRS Notice 2010-15
various 7/28/2010 Recommendations for the 2010-2011 Treasury-IRS Guidance Priority List
1366 7/26/2010 Comments on Qualification of Debt as Indebtedness of the S Corporation to the Shareholder
n/a 7/22/2010 Comments on Notice 2009-93 Concerning the Pilot Program to Truncate Taxpayer Identification Numbers on Certain Payee Statements
7623 7/15/2010 Comments on Circular 230 Section 10.27
  5/28/10 Comments on Announcements 2010-9, 2010-17 and 2010-30
355(b) 5/26/10 Comments on Proposed Regulations Regarding the Active Trade or Business RequirementUnder Section 355(b)
901 5/6/2010 Comments on Proposed Regulations Regarding the Section 901 Compulsory Payment Requirement
409(a) 4/30/10 Comments on Relief and Guidance on Corrections of Certain Failures of a Nonqualified Deferred Compensation Plan to Comply with Section 409A(a)
301 4/28/10 Comments on Proposed Regulations Regarding Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities
509(a)(3) 4/27/10 Comments on Proposed Regulations Under Section 509(a)(3) Regarding Type III Supporting Organizations
409A 4/19/10 Comments on Notice 2008-115 Reporting and Wage Withholding Requirements with Respect to Amounts Includible in Income Under Section 409A
706 3/12/10 Comments on Proposed Regulations Under Section 706
4944 03/3/10 Comments Concerning Proposed Additional Examples on Program-Related Investments
368 02/26/10 Comments on Temporary and Proposed Regulations Regarding the Measurement of Continuity of Interest Under Section 368
987 02/24/10 Comments Concerning Proposed Regulations Under Section 987
142(a)(6) 02/23/10 Comments Concerning Proposed Regulations on Solid Waste Disposal Facilities
104(a)(2) 02/03/10 Comments on Limitation of Section 104(a)(2) Exclusion
514(c)(9)(E) 01/19/10 Comments Concerning Partnership Allocations Permitted Under Section 514(c)(9)(E)



To: Submitted Document:
Senate Finance Committee, House Ways and Means Committee 12/01/2010 Letter Regarding a Request for Action on Pending Estate & GST Tax Legislation
Senate Finance Committee, House Ways and Means Committee 11/12/2010 Letter Regarding the Treaty Override Provision in H.R. 847
Senate Finance Committee, House Ways and Means Committee 11/05/2010 Comments on Carried Interest Proposals in Senate Amendment 4386 to H.R. 4213
Senate Finance Committee, House Ways and Means Committee 5/11/10 Update of Comments on H.R. 2834 with respect to H.R. 4213
Senate Finance Committee 04/15/10 Hearings on Federal Wealth Transfer Taxes
Senate Finance Committee, House Ways and Means Committee 04/06/10 Comments on H.R. 4169- Technical Correction to ARRA Change in Section 1374 Built-In Gain Tax
Senate Finance Committee, House Ways and Means Committee 04/05/10 Letter Regarding Reform of Federal Wealth Transfer Tax
House/Senate Subcommittee on Financial Services and General Government 04/05/10 Letter Regarding Internal Revenue Service Funding and Comments on Proposed Funding for Assistance to Low-Income Taxpayers