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December 31, 2014

2015 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 Department & IRS

I.R.C. § Submitted Comments Concerning
959, 961 12/28/2015 Comments on Proposed Regulations Under Sections 959 and 961
501(c)(3) 12/16/2015 Comments on Substantiation Requirement for Certain Contributions
7701 12/3/2015 Comments on Definition of Terms Relating to Marital Status
n/a 11/16/2015 Comments on Notice 2015-72
n/a 11/10/2015 Comments on the U.S. Model Tax Convention Draft Provisions
165(g)(3) 10/30/2015 Comments on the Application of Section 165(g)(3) to S Corporations
n/a 10/14/2015 Comments on 2014 Offshore Voluntary Disclosure Program and the Streamlined Programs
141, 145 10/2/15 Comments on Safe Harbors Under Sections 141 and 145
401(k), (m) 8/31/15 Comments on Mid-Year Amendments to Safe Harbor 401(k) Plans
336(e) 7/21/15 Comments on Section 336(e)
n/a 6/16/15 Recommendations for 2015-2016 Priority Guidance Plan
7874 6/12/2015 Comments on Notice 2014-52
475 5/7/2015 Comments on Mark-to-Market Rules Under Section 475
267(a)(3)(B) 5/7/2015 Comments on Guidance Under Section 267(a)(3)(B)
various 5/7/2015 Comments on Proposed Regulations on Certain Partnership Provisions of the American Jobs Creation Act of 2004
n/a 5/5/2015 Comments on the Definition of Political Subdivision
n/a 3/24/2015 Comments on Notice 2014-21
877A 3/2/2015 Request for Guidance on Tax Status of Certain Expatriates
469 1/20/2015 Comments on Material Participation by a Trust or Estate Under Section 469
856 1/9/2015 Comments on Proposed Regulations Issued Under Section 856



To Submitted Document
House Committee on Ways & Means, Senate Committee on Finance 11/2/2015 Comments on Partnership Tax Audit and Litigation Regime Revisions
Senate Committee on Finance 9/24/2015 Comments on S. 903



To Submitted Document
United States Tax Court 11/10/2015 Comments on Tax Court Rules of Practice and Procedure