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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)



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



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