chevron-down Created with Sketch Beta.
August 02, 2018 News & Announcements

Government Submissions Boxscore

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: Internal Revenue Service, Department of Treasury
DATE: 6/21/2018
CODE SECTION: 512(a)(6)
TITLE: Comments on Internal Revenue Code Section 512(a)(6) Special Rule for Organizations with More than One Unrelated Trade or Business
COMMITTEE: Exempt Organizations
CONTACT: Lisa Johnson, Robert Wexler

TO: Internal Revenue Service, Department of Treasury
DATE: 6/18/2018
CODE SECTION: 199A
TITLE: Comments Concerning the Scope of a Specified Service Trade or Business within the Meaning of Section 199A
COMMITTEE: Partnerships and LLC
CONTACT: C. Wells Hall III

TO: Internal Revenue Service, Department of Treasury
DATE: 6/15/2018
CODE SECTION: various
TITLE: Second Set of Recommendations for 2018-2019 Priority Guidance Plan
COMMITTEE: Capital Recovery and Leasing, Employee Benefits, Exempt Organizations, Foreign Activities of U.S. Taxpayers, Pro Bono & Tax Clinics, Tax Accounting
CONTACT: Lisa Zarlenga

TO: Internal Revenue Service, Department of Treasury
DATE: 6/7/2018
CODE SECTION: 168(k)
TITLE: Comments on Section 168(k) as Amended by P.L. 115-97 on December 22, 2017
COMMITTEE: Partnerships and LLCs, Real Estate, Capital Recovery and Leasing
CONTACT: Ari Beck, John Franco

TO: Senate Finance Committee
DATE: 6/6/2018
CODE SECTION: n/a
TITLE: Comments Concerning H.R. 5444 “Taxpayer First Act”
COMMITTEE: Administrative Practice, Individual and Family Taxation, Civil and Criminal Tax Penalties, Court Procedure and Practice, Pro Bono and Tax Clinics
CONTACT: John Colvin

TO: Internal Revenue Service, Department of Treasury
DATE: 5/31/2018
CODE SECTION: 199A
TITLE: Initial Comments Concerning the Aggregation and Disaggregation of Trade or Business Activities for Purposes of Section 199A
COMMITTEE: Affiliated and Related Corporations, Partnerships and LLCs, Closely Held Business, Real Estate, Corporate Tax, S Corporations
CONTACT: Laura Howell-Smith

TO: Internal Revenue Service, Department of Treasury
DATE: 5/24/2018
CODE SECTION: 59A, 163(j), 164, 168(k), 172, 199A, 245A, 250, 267A, 461, 864(c)(8), 951A, 958(b)(4)
TITLE: First Set of Recommendations for 2018-2019 Priority Guidance Plan
COMMITTEE: 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
CONTACT: Lisa Zarlenga

TO: Internal Revenue Service, Department of Treasury
DATE: 5/2/2018
CODE SECTION: n/a
TITLE: Comments Regarding the OVDP and the Streamlined Procedures
COMMITTEE: Civil & Criminal Tax Penalties
CONTACT: Caroline D. Ciraolo, Niles A. Elber

TO: Office of Management and Budget, Department of the Treasury
DATE: 4/26/2018
CODE SECTION: n/a
TITLE: Letter on the Memorandum of Agreement Dated April 11, 2018 (tax regulations under Executive Order 12866)
COMMITTEE: Section of Taxation
CONTACT: Karen L. Hawkins

TO: Internal Revenue Service, Department of Treasury
DATE: 4/19/2018
CODE SECTION: 170, 4967, 4958
TITLE: Comments to Notice 2017-73 (Donor Advised Funds)
COMMITTEE: Exempt Organizations
CONTACT: Lisa L. Johnsen, David A. Shevlin

TO: Internal Revenue Service, Department of Treasury
DATE: 3/19/2018
CODE SECTION: n/a
TITLE: Comments on Tax Treatment of Cryptocurrency Hard Forks for Taxable Year 2017
COMMITTEE: Teaching Taxation
CONTACT: Omri Marian, Kerry A. Ryan

TO: Internal Revenue Service, Department of Treasury
DATE: 3/19/2018
CODE SECTION: 864(c)(8), 1446(f)
TITLE: Comments on Need for Guidance Under Sections 864(c)(8) and 1446(f)
COMMITTEE: U.S. Activities of Foreigners and Tax Treaties
CONTACT: Alan I. Appel

TO: Internal Revenue Service, Department of Treasury
DATE: 3/15/2018
CODE SECTION: 514
TITLE: Comments on Proposed Regulations Issued Under Section 514 (the “Fractions Rule”)
COMMITTEE: Real Estate
CONTACT: Adam Feuerstein, Robert Honigman

TO: Uniform Law Commission
DATE: 2/15/2018
CODE SECTION: n/a
TITLE: Letter on RUUPA
COMMITTEE: State & Local Taxes
CONTACT: Edward Bernert

TO: Internal Revenue Service
DATE: 2/1/2018
CODE SECTION: 99-21
TITLE: Comments on Rev. Proc. 99-21
COMMITTEE: Pro Bono & Tax Clinics
CONTACT: Caleb B. Smith

TO: Internal Revenue Service
DATE: 1/31/2018
CODE SECTION: 402(b)
TITLE: Comments Regarding Section 402(b) and Foreign Plans
COMMITTEE: Employee Benefits
CONTACT: Mark C. Jones

TO: House Committee on Ways & Means and Senate Committee on Finance
DATE: 1/16/2018
CODE SECTION: n/a
TITLE: Letter Regarding Fiscal Year 2018 Funding for the Internal Revenue Service
COMMITTEE: Section of Taxation
CONTACT: Karen L. Hawkins

TO: Internal Revenue Service
DATE: 1/12/2018
CODE SECTION: 6651
TITLE: Follow-up Letter: Timeliness of Electronic Tax Return after Failed Transmission
COMMITTEE: Pro Bono & Tax Clinics
CONTACT: Keith Fogg

TO: Internal Revenue Service
DATE: 12/15/2017
CODE SECTION: 6651
TITLE: Letter Regarding Timeliness of Electronic Tax Return after Failed Transmission
COMMITTEE: Section of Taxation
CONTACT: Keith Fogg

TO: House Committee on Ways & Means and Senate Committee on Finance
DATE: 11/22/2017
CODE SECTION: 212(3)
TITLE: Letter Regarding Deductibility of Expenses For Tax Code Compliance
COMMITTEE: Section of Taxation
CONTACT: Karen L. Hawkins

TO: Internal Revenue Service
DATE: 11/21/2017
CODE SECTION: 501(c)(4)
TITLE: Comments on Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code
COMMITTEE: Exempt Organizations
CONTACT: Elizabeth J. Kingsley, John Pomeranz, and Richard F. Riley, Jr.

TO: Internal Revenue Service
DATE: 10/20/2017
CODE SECTION: 6225, 6226
TITLE: 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
COMMITTEE: Partnerships & LLCs
CONTACT: Terence F. Cuff, Michael Hirschfeld

TO: Internal Revenue Service
DATE: 10/11/2017
CODE SECTION: 501(c)(4)
TITLE: 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))
COMMITTEE: Exempt Organizations
CONTACT: Lisa L. Johnsen

TO: Internal Revenue Service
DATE: 9/13/2017
CODE SECTION: various
TITLE: Comments on Notice 2017-17
COMMITTEE: Tax Accounting
CONTACT: David Auclair

TO: Internal Revenue Service
DATE: 9/11/2017
CODE SECTION: various
TITLE: Comments on New Partnership Audit Regime
COMMITTEE: Administrative Practice
CONTACT: Jennifer E. Breen, George A. Hani

TO: Internal Revenue Service
DATE: 8/15/2017
CODE SECTION: 385
TITLE: Comments on Notice 2017-38 on the Final and Temporary Regulations Under Section 385
COMMITTEE: Corporate Tax
CONTACT: 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.