January 01, 2017

2017 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. ยง Submitted Comments Concerning:
6651; 7502 12/15/2017 Timeliness of Electronic Tax Return after Failed Transmission
501(c)(4) 11/21/2017 Comments Concerning Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code
6225; 6226 10/20/2017 Comments Regarding Capital Accounts and Basis with Respect to Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015
501(c)(4) 10/11/2017 Request for Comments Concerning Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) on the Internal Revenue Code (82 FR 40228 (2017))
451; 460 9/13/2017 Comments on Notice 2017-17
301 9/11/2017 Comments on New Partnership Audit Regime
385 8/15/2017 Comments on Notice 2017-38 (Regulations Under Section 385)
n/a 8/10/2017 Comments on Proposed Regulations Addressing Elimination of Circular Adjustments to Basis
n/a 8/10/2017 Comments on the Definition of Insurance for Tax Purposes
103 8/10/2017 Comments on Notice 2017-38 (Proposed Regulations Under Section 103)
2701; 2704 8/9/2017 Comments on Notice 2017-38 (Proposed Regulations Under Section 2704)
987 8/9/2017 Comments on Notice 2017-38 (Final Regulations Under Section 987)
n/a 8/8/2017 Comments on Section 6.03 of Rev. Proc. 2017-30, Regarding Sale, Lease or Financing Transactions Method Changes
n/a 6/20/2017 Recommendations for 2017-2018 Priority Guidance Plan
n/a 5/10/2017 Comments on Tax-Exemption of Interest on State and Local Bonds
n/a 5/9/2017 Comments on Recent Practice Changes at Appeals
2; 32; 63; 152 5/8/2017 Comments on the Definition of Dependents [REG-137604-07]
103(a) 5/5/2017 Comments on the Definition of Political Subdivision for Tax-Exempt Bonds and Other Tax-Advantaged Bonds
1362(f) 5/4/2017 Comments on Section 1362(f) Draft Revenue Procedure
1001 3/7/2017 Comments on Modifications of Debt Instruments under Section 1001

 

Congress

To Submitted Comments Concerning:
House Committee on Ways and Means; Senate Committee on Finance 11/22/2017 Deductibility of Expenses For Tax Code Compliance
House Committee on Ways and Means; Senate Committee on Finance 7/20/2017 Centralized Partnership Audit Regime Effective Date