August 26, 2016 Section News

Government Submissions Boxscore

Since January 1, 2016, the Section has coordinated the following government submissions, which can be viewed and downloaded free of charge from the Section’s website at http://www.americanbar.org/groups/taxation/policy.html.

SUBMISSIONS AND COMMENTS ON GOVERNMENT REGULATIONS, ADMINISTRATIVE RULINGS, BLANKET AUTHORITY and ABA POLICY

TO: Internal Revenue Service, Department of the Treasury
DATE: 8/4/16
CODE SECTION: 861
TITLE: Comments on Taxation of Cloud Transactions (from Character Perspective)
COMMITTEE: Foreign Activities of U.S. Taxpayers, U.S. Activities of Foreigners and Tax Treaties
CONTACT: Kimberly T. Majure

TO: Internal Revenue Service, Department of the Treasury
DATE: 7/13/16
CODE SECTION: 385
TITLE: Comments on Proposed Guidance under Section 385 Regarding Treatment in Certain Interests in Corporations as Stock or Indebtedness
COMMITTEE: Corporate Tax
CONTACT: William Alexander

TO: Internal Revenue Service
DATE: 6/27/16
CODE SECTION: n/a
TITLE: Comments Concerning Announcement 2015-19 – Revisions to the Employee Plans Determination Letter Program
COMMITTEE: Employee Benefits
CONTACT: Robert A. Miller, Susan A. Wetzel

TO: Internal Revenue Service
DATE: 6/22/16
CODE SECTION: 501(c)(3), 509(a)(3)(B)(iii)
TITLE: Comments on Certain Requirements for Type III Supporting Organizations
COMMITTEE: Exempt Organizations
CONTACT: David A. Shevlin, Jennifer L. Franklin, Jean Tom

TO: Internal Revenue Service
DATE: 6/22/16
CODE SECTION: n/a
TITLE: Comments on Issues on Which Precendential Guidance is Needed
COMMITTEE: Exempt Organizations
CONTACT: David A. Shevlin

TO: Internal Revenue Service
DATE: 6/20/16
CODE SECTION: 1014(f), 6035, 6662(b)(8)
TITLE: Comments in Response to Proposed Regulations Regarding Consistency in Income Tax Basis
COMMITTEE: Estate and Gift Taxes, Fiduciary Income Tax
CONTACT: George D. Karibjanian

TO: Internal Revenue Service, Department of the Treasury
DATE: 6/6/16
CODE SECTION: n/a
TITLE: Comments on New Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015
COMMITTEE: Administrative Practice, Court Procedure and Practice, Partnerships and LLCs
CONTACT: George A. Hani, Jennifer Breen

TO: Internal Revenue Service, Department of the Treasury
DATE: 6/2/16
CODE SECTION: n/a
TITLE: Recommendations for the 2016-2017 Priority Guidance Plan
COMMITTEE: See Comment Letter for Committee List
CONTACT: George C. Howell, III

TO: Internal Revenue Service
DATE: 5/26/16
CODE SECTION: 2801
TITLE: Comments on Guidance under Section 2801 Regarding the Imposition of Tax on Certain Gifts and Bequests from Covered Expatriates
COMMITTEE: Estate and Gift Taxes,  ABA Section of Real Property, Trust and Estate Law
CONTACT: Scott A. Bowman, Marianne Kayan

TO: Internal Revenue Service
DATE: 5/23/16
CODE SECTION: 721(c)
TITLE: Comments on Notice 2015-54 (Partnership Issues)
COMMITTEE: Partnerships and LLCs
CONTACT: H. Grace Kim, Christopher Trump, Elizabeth Amoni Hall

TO: United States Tax Court
DATE: 5/4/16
CODE SECTION: n/a
TITLE: Comments on Amendments to the Tax Court Rules of Practice and Procedure
COMMITTEE: Court Procedure and Practice
CONTACT: Juan F. Vasquez, Jr.

TO: Internal Revenue Service
DATE: 5/4/16
CODE SECTION: 482
TITLE: Comments on T.D. 9738
COMMITTEE: Transfer Pricing
CONTACT: John M. Breen

TO: Internal Revenue Service
DATE: 4/27/16
CODE SECTION: 751(b)
TITLE: Comments on Section 751(b) Proposed Regulations
COMMITTEE: Partnerships and LLCs
CONTACT: Howard E. Abrams, Erich P. Hahn

TO: Internal Revenue Service
DATE: 4/4/16
CODE SECTION: 6015
TITLE: Comments on Relief From Joint and Several Liability Under Section 6015
COMMITTEE: Pro Bono and Tax Clinics
CONTACT: Andrew R. Roberson

TO: Internal Revenue Service, Department of the Treasury
DATE: 3/23/16
CODE SECTION: various
TITLE: Comments on Country-by-Country Reporting Proposed Regulations
COMMITTEE: Transfer Pricing, Foreign Activities of U.S. Taxpayers
CONTACT: John M. Breen

TO: Senate and House Appropriations Subcommittees on Financial Services and General Government
DATE: 3/17/16
CODE SECTION: n/a
TITLE: Fiscal Year 2017 Funding for the Internal Revenue Service
COMMITTEE: n/a
CONTACT: George C. Howell, III

TO: Multistate Tax Commission
DATE: 3/1/16
CODE SECTION: n/a
TITLE: Comments on the MTC’s Proposed Draft Amendments to its Model General Allocation and Apportionment Regulations
COMMITTEE: State and Local Taxes
CONTACT: John H. Gadon, Shirley K. Sicilian

TO: Department of State
DATE: 2/17/16
CODE SECTION: n/a
TITLE: Comments on the Application of the Tax Benefit Rule to the Cuban Claims Settlement Process
COMMITTEE: Sales, Exchanges, and Basis
CONTACT: Mary B. Foster

TO: United States Tax Court
DATE: 2/10/16
CODE SECTION: n/a
TITLE: Comments on Proposed Amendments to the Tax Court Rules of Practice and Practice to Modify the Signature and Filing Requirements
COMMITTEE: Court Procedure and Practice
CONTACT: Juan F. Vasquez, Jr.

TO: Internal Revenue Service
DATE: 1/25/16
CODE SECTION: 1014(f), 6035
TITLE: Comments in Response to Consistency of Income Tax Basis Rules
COMMITTEE: Estate and Gift Taxes; Fiduciary Income Tax
CONTACT: Benjamin G. Carter

TO: Internal Revenue Service
DATE: 1/19/16
CODE SECTION: 446, 956
TITLE: Comments on the Temporary and Proposed Regulations Under Sections 446 and 956 Providing Embedded Loan Treatment for Certain Notional Principal Contracts
COMMITTEE: Financial Transactions, Banking and Savings Institutions
CONTACT: Stefan Gottschalk

TO: Internal Revenue Service
DATE: 1/7/16
CODE SECTION: 482
TITLE: Comments on Notice 2015-54
COMMITTEE: Transfer Pricing
CONTACT: John M. Breen

TO: Internal Revenue Service
DATE: 1/4/16
CODE SECTION: 148
TITLE: Comments on Proposed Issue Price Regulations
COMMITTEE: Tax-Exempt Financing
CONTACT: Darren C. McHugh

TO: Internal Revenue Service
DATE: 1/4/16
CODE SECTION: 7704(d)(1)(E)
TITLE: Comments on Proposed Regulations Under Section 7704(d)(1)(E)
COMMITTEE: Energy and Environmental Taxes, Partnerships and LLCs
CONTACT: Barbara S. de Marigny

The technical comments and blanket authority submissions listed in this index represent the views of the ABA Section of Taxation. They have not been approved by the ABA Board of Governors or the ABA House of Delegates and should not be construed as representing the policy of the ABA.