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    December 31, 2015

    2016 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:
    501(c)(4) 11/16/2016 Comments on Requirement to Provide Notice of Intent to Operate as a Section 501(c)(4) Organization
    2701, 2704 11/2/2016 Comments on Proposed Regulations Under Sections 2701 and 2704
    n/a 10/17/2016 Comments on User Fees for Installment Agreements
    BEPS 8/4/2016 Comments on Cloud Transactions
    385 7/13/2016 Comments on Proposed Regulations under Section 385
    401; 411(d) 6/27/2016 Comments on Announcement 2015-19
    501(c)(3); 509(a)(3)(B)(iii) 6/22/2016 Comments on Type III Supporting Organizations
    4941; 501(c)(3) 6/22/2016 Comments on Precedential Guidance Request
    1014(f); 6035; 6662(b)(8) 6/20/2016 Comments on Consistency in Basis Proposed Regulations
    6221(a) 6/6/2016 Comments on Bipartisan Budget Act of 2015 Partnership Audit Procedures
    n/a 6/2/2016 Recommendations for 2016-2017 Priority Guidance Plan
    2801 5/26/2016 Comments on Guidance under Section 2801
    721(c) 5/23/2016 Comments on Notice 2015-54
    482 5/4/2016 Comments on T.D. 9738
    751(b) 4/27/2016 Comments on Section 751(b) Proposed Regulations
    6015 4/4/2016 Comments on Relief From Joint and Several Liability
    6038 3/23/2016 Comments on Country-by-Country Reporting Proposed Regulations
    1014(f); 6035; 6662(b)(8) 1/25/2016 Comments in Response to Consistency of Income Tax Basis Rules
    446; 956 1/19/2016 Comments on Temporary and Proposed Regulations Under Sections 446 and 956
    482 1/7/2016 Comments on Notice 2015-54
    148 1/4/2016 Comments on Proposed Issue Price Regulations
    7704(d)(1)(E) 1/4/2016 Comments on Proposed Regulations Under Section 7704(d)(1)(E)

     

    Congress

    To Submitted Document
    House Committee on Small Business 9/14/2016 Statement of Jennifer Breen on Behalf of the American Bar Association, Hearing on IRS Audits of Small Business
    Senate Committee on Appropriations, Subcommittee on Financial Services and General Government 3/17/2016 Fiscal Year 2017 Funding for the Internal Revenue Service

     

    Other

    To Submitted Document
    United States Tax Court 5/4/2016 Comments on Amendments to the Tax Court Rules of Practice and Procedure
    Multistate Tax Commission 3/1/2016 Comments on Proposed Draft Amendments to General Allocation and Apportionment Regulations
    United States Department of State 2/17/2016 Comments on the Application of the Tax Benefit Rule to the Cuban Claims Settlement Process
    United States Tax Court 2/10/2016 Comments on Proposed Amendments to the Tax Court Rules of Practice and Procedure to Modify the Signature and Filing Requirements