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December 31, 2013

2014 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:
871(m) 10/17/2014 Comments on Proposed Regulations Issued Under Section 871(m)
356(a)(2) 10/6/2014 Comments Regarding the Sourcing of Earnings and Profits for Boot in Reorganizations
752 9/2/2014 Comments on Proposed Regulations on Recourse Liabilities of Partnerships and Related Parties
707, 752 8/8/2014 Comments on Proposed Regulations under Sections 707 and 752
751, 1234 7/14/2014 The Treatment of Noncompensatory Options on a Partnership Interest
162(m)(6) 7/10/2014 Comments on Proposed Regulations under Section 162(m)(6)
n/a 6/17/2014 Recommendations for 2014-2015 Priority Guidance List
n/a 5/19/2014 Comments on IRS Form SS-8
501(c)(4) 5/7/2014 Comments on 501(c)(4) Exempt Organizations
482 3/18/2014 Comments and Recommendations for Proposed Procedures for Advance Pricing Agreements Set Forth in Notice 2013-79
n/a 3/10/2014 Comments on Notice 2013-78
various 1/30/2014 Comments Concerning Tax Exempt Working Capital Financing, Grants, and Qualified Hedges
various 1/24/2014 Comments Concerning FATCA Regulations Relating to Insurance Issues
n/a 1/23/2014 Comments Concerning Issue Price Definition for Tax Exempt Bonds



To Submitted Document
House Committee on Ways & Means, Senate Committee on Finance 7/29/2014 Proposed Amendment to Section 523(a) of the Bankruptcy Code
House and Senate Appropriations Subcommittees on Financial Services and General Government 7/21/2014 Funding for the Internal Revenue Service in H.R. 5016
Senate and House Appropriations Subcommittees on Legislative Branch 6/27/2014 Funding for the Joint Committee on Taxation
House Committee on Ways & Means, Senate Committee on Finance 6/25/2014 Comments on Summary of Staff Discussion Draft on Reforming Tax Administration
House and Senate Appropriations Subcommittee on Financial Services and General Government 2/10/2014 IRS Funding