Government Submissions Boxscore

Vol. 37 No. 4 | August 2018

Government submissions are a key component of the Section’s government relations activities. Since August 15, 2017, the Section has coordinated the following government submissions. The full archive is available to the public on the website: http://www.americanbar.org/groups/taxation/policy.html.

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

TO

DATE

CODE SECTION

TITLE

COMMITTEE

CONTACT

Internal Revenue Service, Department of Treasury

6/21/2018

512(a)(6)

Comments on Internal Revenue Code Section 512(a)(6) Special Rule for Organizations with More than One Unrelated Trade or Business

Exempt Organizations

Lisa Johnson, Robert Wexler

Internal Revenue Service, Department of Treasury

6/18/2018

199A

Comments Concerning the Scope of a Specified Service Trade or Business within the Meaning of Section 199A

Partnerships and LLC

C. Wells Hall III

Internal Revenue Service, Department of Treasury

6/15/2018

various

Second Set of Recommendations for 2018-2019 Priority Guidance Plan

Capital Recovery and Leasing, Employee Benefits, Exempt Organizations, Foreign Activities of U.S. Taxpayers, Pro Bono & Tax Clinics, Tax Accounting

Lisa Zarlenga

Internal Revenue Service, Department of Treasury

6/7/2018

168(k)

Comments on Section 168(k) as Amended by P.L. 115-97 on December 22, 2017

Partnerships and LLCs, Real Estate, Capital Recovery and Leasing

Ari Beck,
John Franco

Senate Finance Committee

6/6/2018

n/a

Comments Concerning H.R. 5444 “Taxpayer First Act”

Administrative Practice, Individual and Family Taxation, Civil and Criminal Tax Penalties, Court Procedure and Practice, Pro Bono and Tax Clinics

John Colvin

Internal Revenue Service, Department of Treasury

5/31/2018

199A

Initial Comments Concerning the Aggregation and Disaggregation of Trade or Business Activities for Purposes of Section 199A

Affiliated and Related Corporations, Partnerships and LLCs, Closely Held Business, Real Estate, Corporate Tax, S Corporations

Laura Howell-Smith

Internal Revenue Service, Department of Treasury

5/24/2018

59A, 163(j), 164, 168(k), 172, 199A, 245A, 250, 267A, 461, 864(c)(8), 951A, 958(b)(4)

First Set of Recommendations for 2018-2019 Priority Guidance Plan

Affiliated and Related Corporations, Partnerships and LLCs, Closely Held Business, Real Estate, Corporate Tax, S Corporations, Foreign Activities of U.S. Taxpayers, Transfer Pricing, Foreign Lawyers Forum, U.S. Activities of Foreigners & Tax Treaties

Lisa Zarlenga

Internal Revenue Service, Department of Treasury

5/2/2018

n/a

Comments Regarding the OVDP and the Streamlined Procedures

Civil & Criminal Tax Penalties

Caroline D. Ciraolo,
Niles A. Elber

Office of Management and Budget, Department of the Treasury

4/26/2018

n/a

Letter on the Memorandum of Agreement Dated April 11, 2018 (tax regulations under Executive Order 12866)

Section of Taxation

Karen L. Hawkins

Internal Revenue Service, Department of Treasury

4/19/2018

170, 4967, 4958

Comments to Notice 2017-73 (Donor Advised Funds)

Exempt Organizations

Lisa L. Johnsen, David A. Shevlin

Internal Revenue Service, Department of Treasury

3/19/2018

n/a

Comments on Tax Treatment of Cryptocurrency Hard Forks for Taxable Year 2017

Teaching Taxation

Omri Marian, Kerry A. Ryan

Internal Revenue Service, Department of Treasury

3/19/2018

864(c)(8), 1446(f)

Comments on Need for Guidance Under Sections 864(c)(8) and 1446(f)

U.S. Activities of Foreigners and Tax Treaties

Alan I. Appel

Internal Revenue Service, Department of Treasury

3/15/2018

514

Comments on Proposed Regulations Issued Under Section 514 (the “Fractions Rule”)

Real Estate

Adam Feuerstein, Robert Honigman

Uniform Law Commission

2/15/2018

n/a

Letter on RUUPA

State & Local Taxes

Edward Bernert

Internal Revenue Service

2/1/2018

99-21

Comments on Rev. Proc. 99-21

Pro Bono & Tax Clinics

Caleb B. Smith

Internal Revenue Service

1/31/2018

402(b)

Comments Regarding Section 402(b) and Foreign Plans

Employee Benefits

Mark C. Jones

House Committee on Ways & Means and Senate Committee on Finance

1/16/2018

n/a

Letter Regarding Fiscal Year 2018 Funding for the Internal Revenue Service

Section of Taxation

Karen L. Hawkins

Internal Revenue Service

1/12/2018

6651

Follow-up Letter: Timeliness of Electronic Tax Return after Failed Transmission

Pro Bono & Tax Clinics

Keith Fogg

Internal Revenue Service

12/15/2017

6651

Letter Regarding Timeliness of Electronic Tax Return after Failed Transmission

Section of Taxation

Keith Fogg

House Committee on Ways & Means and Senate Committee on Finance

11/22/2017

212(3)

Letter Regarding Deductibility of Expenses For Tax Code Compliance

Section of Taxation

Karen L. Hawkins

Internal Revenue Service

11/21/2017

501(c)(4)

Comments on Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code

Exempt Organizations

Elizabeth J. Kingsley, John Pomeranz, and Richard F. Riley, Jr.

Internal Revenue Service

10/20/2017

6225, 6226

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

Partnerships & LLCs

Terence F. Cuff,
Michael Hirschfeld

Internal Revenue Service

10/11/2017

501(c)(4)

Letter Regarding 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))

Exempt Organizations

Lisa L. Johnsen

Internal Revenue Service

9/13/2017

various

Comments on Notice 2017-17

Tax Accounting

David Auclair

Internal Revenue Service

9/11/2017

various

Comments on New Partnership Audit Regime

Administrative Practice

Jennifer E. Breen,
George A. Hani

Internal Revenue Service

8/15/2017

385

Comments on Notice 2017-38 on the Final and Temporary Regulations Under Section 385

Corporate Tax

William D. Alexander

 

 

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.

Advertisement

tt-white-space-300x25
tt-download-the-article
ABA Tax Times, August2018
tt-about-us-300x25

ABA Tax Times (ISSN 2381-5868) (formerly the NewsQuarterly) reports on developments pertaining to taxation, Tax Section news and meeting updates, and other information of professional interest to Tax Section members and other readers.

ABA Tax Times Archive

Editorial Information

tt-contact-us-300x25

Have a question or comment regarding a recent ABA Tax Times article? Click here or send an e-mail directly to taxweb@americanbar.org.

tt-white-space-300x25
att-17aug-promotion-featured-taps-ad.png
Catalyst17_300x250_Static