2012 Regulatory and Legislative Submissions

U.S. Treasury Dept. & IRS

Advance Pricing and Mutual Agreement Program (1/05/2012)
I.R.C. §: 482
Guidance under Section 108(a) Concerning the Exclusion of Section 61(a)(12) Discharge of Indebtedness Income of a Grantor Trust or a Disregarded Entity (1/17/2012)
I.R.C. §: 108(a), 61(a)(12)
Proposed Regulations Issued under Section 892 (1/30/2012)
I.R.C. §: 892
Comments on Proposed Changes to the Guidelines for Innocent Spouse Relief in Revenue Procedure 2003-61 (4/7/2012)
I.R.C. §: 66(c), 6015(f)
Comments on the Scope of Section 514 of the Internal Revenue Code (4/9/2012)
I.R.C. §: 514
Proposed Treasury Regulations Relating to the Foreign Account Tax Compliance Offset Provisions of the HIRE Act, P.L. 111-147 Certification & Verification (4/13/2012)
I.R.C. §: 1471, 1472, 1473, 1474
Comments in Response to Notice 2011-101 (5/3/2012)
I.R.C. §: 671
Comments on the Use of Schedule UTP by the Internal Revenue Service Large Business and International Division (5/3/2012)
I.R.C. §: n/a
Comments on Proposed Regulations Issued Under Section 469 (5/4/2012)
I.R.C. §: 469
Comments Concerning Notice 2010-50 (5/8/2012)
I.R.C. §: 382
Comments on Management Contract Guidelines Under Rev. Proc. 97-13 ( 5/9/2012)
I.R.C. §: 103, 141
Comments on Proposed Regulations Issued Under Section 871(m) (5/15/2012)
I.R.C. §: 871(m)
Comments on Proposed Regulations Removing the Substantial Economic Effect De Minimis Rule (5/22/2012)
I.R.C. §: 704
Comments on Proposed Regulations Under the Foreign Account Tax Compliance Offset Provisions of the HIRE Act Relating to Insurance Issues (6/15/2012)
I.R.C. §: 1471-1474
Comments Concerning Measurement of Continuity of Interest In Reorganizations (6/26/2012)
I.R.C. §: 368
Response to Notice 2011-1 (8/3/2012)
I.R.C. §: n/a
Comments on New Examples of Program-Related Investments in Proposed Regulations Section 53.4944-3(b) (8/8/2012)
I.R.C. §: 4944(c)
Comments and Recommendations for Guidance to the Transfer Pricing of Related Party Guarantees (9/13/2012)
I.R.C. §: 482
Comments on Proposed Amendments to Section 1.1366-2 Regulations (9/17/2012)
I.R.C. §: 1366
Comments on IRS Form 911 Request for Taxpayer Assistance Order (9/17/2012)
I.R.C. §: n/a
Proposed Reg- 138367-06 Relating to Practice Before the IRS (11/27/2012)
I.R.C. §: Circular 230
Proposed Regulations Relating to the Definitions of "Fiduciary" and "Investment Advice" Under Section 3(21) of ERISA (12/11/2012)
I.R.C. §: ERISA 3(21)

Congress

Proposed Amendments to the Rules of the United States Tax Court (3/1/2012)
To: U.S. Tax Court
Options for Tax Reform to Amend Code Section 6103(e) of the Internal Revenue Code (4/2/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform and Simplification with Respect to Federal Estate, Gift and GST Taxes (4/4/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Recommendations for 2012-2013 Guidance Priority List (5/17/2012)
To: Department of the Treasury, Internal Revenue Service
Options for Tax Reform in the Provisions of the Internal Revenue Code Affecting Insurance Companies and their Products (5/21/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform in the Area of Tax-Exempt Financing (7/30/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform under Section 382 (8/23/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform of Individual Chapter 11 Bankruptcy Cases (8/23/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform in the Transfer Pricing Provisions of the Internal Revenue Code; (10/1/2012)
To: House Committee on Ways & Means, Senate Committee on Finance
Options for Tax Reform Regarding Employee Benefits and Executive Compensation (10/3/2012)
To: House Committee on Ways & Means, Senate Committee on Finance