The comments listed represent the views of the ABA Section of Taxation. They have not been approved by the House of Delegates or the Board of Governors of the American Bar Association and should not be construed as representing the policy of the Association. Documents are provided in Adobe Acrobat format unless otherwise indicated.
December 31, 2003
2004 Regulatory and Legislative Submissions
U.S. Treasury Department & IRS
- Proposed Changes to the Internal Revenue Service’s Classification Settlement Program to Resolve Worker Classification Cases (Dec. 21, 2004)
I.R.C.§: n/a
- Adjustment to Net Unrealized Built-in Gains and Losses (Nov. 23, 2004)
I.R.C.§: 1374
- Pro Rata Share Determinations Under Subpart F (Nov. 22, 2004)
I.R.C.§: 951
- Letter to IRS Oversight Board Regarding IRS Strategic Plan (Nov. 22, 2004)
I.R.C.§: n/a
- Proposed Regulations Relating to the Election Not to Have Automatic Allocation of Generation-Skipping Transfer Tax Exemption Apply to Certain Transfers to a GST Trust - Reg-153841-02 (Oct. 12, 2004)
I.R.C.§: 2632
- Identification of Potential Increased Thresholds and “Safe Harbors” (Sep. 2, 2004)
I.R.C.§: n/a
- Temporary and Proposed Regulations Governing Allocation of Partnership Expenditures for Foreign Taxes - TD 9121; Reg-139792-02 (Aug. 10, 2004)
I.R.C.§: 704
- Proposed Regulations on Continuity of Business Enterprise and Certain Related Issues (July 19, 2004)
I.R.C.§: 368
- Anti–Mixing Bowl Rules in Partnership Mergers - Revenue Ruling 2004-43 (July 13, 2004)
I.R.C.§: 704
- Transfers of Assets Following Putative Reorganizations (May 26, 2004)
I.R.C.§: 368
- Section 501(c)(4) and Political Activity (May 25, 2004)
I.R.C.§: 501
- Recommendations for Treasury-IRS 2004–2005 Guidance Priority List (May 19, 2004)
I.R.C.§: various
- The Effect of Pre-Closing Changes of Acquiror Stock Value on Continuity of Interest (May 14, 2004)
I.R.C.§: 368
- LMSB Productivity Improvement Phase II (May 12, 2004)
I.R.C.§: n/a
- Deposit Requirements for Employment Taxes in Connection with the Exercise of Nonstatutory Stock Options (May 10, 2004)
I.R.C.§: various
- Rev. Proc. 2000-37 Safe Harbor Build-To-Suit Exchanges Involving Leasehold Improvements (May 5, 2004)
I.R.C.§: 1031
- Characterization of a Partnership Liability Under Section 752 Where a Disregarded Entity is a General Partner (April 5, 2004)
I.R.C.§: 752
- Disguised Sales of Partnership Interests (April 2, 2004)
I.R.C.§: 707
- Request for Revenue Ruling on S Corporation Qualifying Director Shares (April 2, 2004)
I.R.C.§: 1361
- Need for Guidance on Portfolio Interest Rules under Sections 871(h) and 881(c) of the Internal Revenue Code (March 18, 2004)
I.R.C.§: 871, 881
- Testimony Regarding Regulations Governing Practice Before the IRS (Feb. 19, 2004)
I.R.C.§: n/a
- Comments Concerning Proposed Revisions to Circular 230 (Feb. 12, 2004)
I.R.C.§: n/a
- Proposal on Incentive Stock Options Under Sections 421, 422 and 424 of the Internal Revenue Code
(Feb. 12, 2004)
I.R.C.§: 421, 422, 424
- Revenue Ruling 2002-41, 2002-28 IRB 75 and Notice 2002-45, 2002-28 IRB 93 (Feb. 6, 2004)
I.R.C.§: various
- Code Section 403(b) Regulations Project (Feb. 5, 2004)
I.R.C.§: 403 - Proposed Changes to Form 656, Offer-in-Compromise (Feb. 4, 2004)
I.R.C.§: n/a
- National Taxpayer Advocate's Practitioner Licensing Proposal (Feb. 4, 2004)
I.R.C.§: various
- Proposed Regulations on the Obligation of Partnerships to Withhold Tax Under Section 1446 on Effectively Connected Taxable Income Allocable to Foreign Partners (Jan. 27, 2004)
I.R.C.§: 1446
- Testimony to IRS Oversight Board (Jan. 26, 2004)
I.R.C.§: n/a
- Proposed Regulations on Treatment of Services and Intangibles Under Section 482 (Jan. 23, 2004)
I.R.C.§: 482
Congress
- Letter and Report Regarding the Alternative Minimum Tax (Nov. 29, 2004)
To: Finance / Ways and Means - Letter Regarding H.R. 1308 – Working Families Tax Relief Act of 2004 (Oct. 18, 2004)
To: Finance / Ways and Means
- Supplemental Response to Senate Finance Committee Roundtable on Nonprofit Organizations, July 22, 2004 (Sep. 15, 2004)
To: Senate Finance Committee
- Comments Regarding Senate Finance Committee Staff Discussion Draft of June 21, 2004 (July 19, 2004)
To: Senate Finance Committee
- Letter Regarding the Whistleblower Rewards Provision in the Jumpstart Our Business Strength (JOBS) Bill (S. 1637) (July 1, 2004)
To: Finance / Ways and Means
- Letter Regarding the Effective Date of Nonqualified Deferred Compensation Plan Restrictions (June 30, 2004)
To: Finance / Ways and Means
- Letter Regarding Pending Tax Legislation (June 30, 2004)
To: Finance / Ways and Means
- Follow-Up to Testimony Regarding Simplification of Federal Tax Laws (April 30, 2004)
To: Rep. Houghton
- Testimony Regarding Simplification of Federal Tax Laws (March 30, 2004)
To: Oversight