February 26, 2016 Tax Section News

Government Submissions Boxscore

Since August 31, 2015 the Section has coordinated the following government submissions, which are available to the public on 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: 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

TO: Internal Revenue Service
DATE: 12/28/15
CODE SECTION: 959, 961
TITLE: Comments on Proposed Regulations Under Sections 959 and 961
COMMITTEE: Foreign Activities of U.S. Taxpayers
CONTACT: Jeffrey S. Korenblatt

TO: Internal Revenue Service
DATE: 12/16/15
CODE SECTION: 501(c)(3)
TITLE: Comments on Substantiation Requirement for Certain Contributions
COMMITTEE: Exempt Organizations
CONTACT: David A. Shevlin, Caroline W. Waldner, and Justin Zaremby

TO: Internal Revenue Service
DATE: 12/3/15
CODE SECTION: 7701
TITLE: Comments on Definition of Terms Relating to Marital Status
COMMITTEE: Teaching Taxation
CONTACT: Anthony C. Infanti

TO: Internal Revenue Service
DATE: 11/16/15
CODE SECTION: n/a
TITLE: Comments on Notice 2015-72
COMMITTEE: Administrative Practice, Court Procedure and Practice
CONTACT: George Hani, Juan F. Vasquez, Jr.

TO: United States Tax Court
DATE: 11/10/15
CODE SECTION: n/a
TITLE: Comments on Changes to the Tax Court's Rules of Practice and Procedure
COMMITTEE: Court Procedure and Practice, Pro Bono and Tax Clinics
CONTACT: Juan F. Vasquez, Jr., Andrew R. Roberson

TO: Internal Revenue Service, Department of the Treasury
DATE: 11/10/15
CODE SECTION: n/a
TITLE: Comments on U.S. Model Tax Convention Draft Provisions
COMMITTEE: U.S. Activities of Foreigners and Tax Treaties
CONTACT: Michael J. Miller

TO: Senate Committee on Finance, House Committee on Ways and Means
DATE: 11/2/15
CODE SECTION: n/a
TITLE: Comments on Partnership Tax Audit and Litigation Regime Revisions
COMMITTEE: Administrative Practice, Partnerships and LLCs
CONTACT: Kevin Johnson, George Hani

TO: Internal Revenue Service
DATE: 10/30/2015
CODE SECTION: 165(g)(3)
TITLE: Comments on the Application of Section 165(g)(3) to S Corporations
COMMITTEE: S Corporations Committee
CONTACT: Laura D. Howell-Smith

TO: Internal Revenue Service
DATE: 10/14/2015
CODE SECTION: n/a
TITLE: Comments on 2014 Offshore Voluntary Disclosure Program and the Streamlined Programs
COMMITTEE: Civil and Criminal Tax Penalties Committee
CONTACT: Niles Elber and John Colvin

TO: Internal Revenue Service
DATE: 10/2/2015
CODE SECTION: 141, 145
TITLE: Comments on Safe Harbors Under Sections 141 and 145
COMMITTEE: Tax-Exempt Financing Committee
CONTACT: Carol L. Lew

TO: Senate Committee on Finance
DATE: 9/24/2015
CODE SECTION: n/a
TITLE: Comments on S. 903
COMMITTEE: Court Procedure and Practice Committee
CONTACT: Juan F. Vasquez, Jr. and Joshua D. Odintz

TO: Internal Revenue Service
DATE: 8/31/15
CODE SECTION: 401(k), (m)
TITLE: Comments on Mid-Year Amendments to Safe Harbor 401(k) Plans
COMMITTEE: Employee Benefits Committee
CONTACT: Mark A. Bodron, Susan A. Wetzel, Robert A. Miller

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.