January 01, 2012

2012 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:
482 1/05/2012 Advance Pricing and Mutual Agreement Program
 
108(a), 61(a)(12) 1/17/2012 Guidance under Section 108(a) Concerning the Exclusion of Section 61(a)(12) Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity
892 1/30/2012 Proposed Regulations Issued under Section 892
66(c), 6015(f) 4/7/2012 Comments on Proposed Changes to the Guidelines for Innocent Spouse Relief in Revenue Procedure 2003-61
514 4/9/2012 Comments on the Scope of Section 514 of the Internal Revenue Code
1471, 1472, 1473, 1474 4/13/2012 Proposed Treasury Regulations Relating to the Foreign Account Tax Compliance Offset Provisions of the HIRE Act, P.L. 111-147 Certification & Verification
671 5/3/2012 Comments in Response to Notice 2011-101
  5/3/2012 Comments on the Use of Schedule UTP by the Internal Revenue Service Large Business and International Division
469 5/4/2012 Comments on Proposed Regulations Issued Under Section 469
382 5/8/2012 Comments Concerning Notice 2010-50
103, 141 5/9/2012 Comments on Management Contract Guidelines Under Rev. Proc. 97-13
871(m) 5/15/2012 Comments on Proposed Regulations Issued Under Section 871(m)
704 5/22/2012 Comments on Proposed Regulations Removing the Substantial Economic Effect De Minimis Rule
1471-1474 6/15/2012 Comments on Proposed Regulations Under the Foreign Account Tax Compliance Offset Provisions of the HIRE Act Relating to Insurance Issues
368 6/26/2012 Comments Concerning Measurement of Continuity of Interest In Reorganizations
  8/3/2012 Response to Notice 2011-1
4944(c) 8/8/2012 Comments on New Examples of Program-Related Investments in Proposed Regulations Section 53.4944-3(b)
482 9/13/2012 Comments and Recommendations for Guidance to the Transfer Pricing of Related Party Guarantees  
1366 9/17/2012 Comments on Proposed Amendments to Section 1.1366-2 Regulations  
n/a 9/17/2012 Comments on IRS Form 911 Request for Taxpayer Assistance Order  
Circular 230 11/27/2012 Proposed Reg- 138367-06 Relating to Practice Before the IRS  
ERISA 3(21) 12/11/2012 Proposed Regulations Relating to the Definitions of "Fiduciary" and "Investment Advice" Under Section 3(21) of ERISA

 

Congress

To Submitted Document
U.S. Tax Court 3/1/2012 Proposed Amendments to the Rules of the United States Tax Court
House Committee on Ways & Means, Senate Committee on Finance 4/2/2012 Options for Tax Reform to Amend Code Section 6103(e) of the Internal Revenue Code
House Committee on Ways & Means, Senate Committee on Finance 4/4/2012 Options for Tax Reform and Simplification with Respect to Federal Estate, Gift and GST Taxes
Department of the Treasury, Internal Revenue Service 5/17/2012 Recommendations for 2012-2013 Guidance Priority List
House Committee on Ways & Means, Senate Committee on Finance 5/21/2012 Options for Tax Reform in the Provisions of the Internal Revenue Code Affecting Insurance Companies and their Products
House Committee on Ways & Means, Senate Committee on Finance 7/30/2012 Options for Tax Reform in the Area of Tax-Exempt Financing
House Committee on Ways & Means, Senate Committee on Finance 8/23/2012 Options for Tax Reform under Section 382
House Committee on Ways & Means, Senate Committee on Finance 8/23/2012 Options for Tax Reform of Individual Chapter 11 Bankruptcy Cases
House Committee on Ways & Means, Senate Committee on Finance 10/1/2012 Options for Tax Reform in the Transfer Pricing Provisions of the Internal Revenue Code  
House Committee on Ways & Means, Senate Committee on Finance 10/3/2012 Options for Tax Reform Regarding Employee Benefits and Executive Compensation