Tax Section Reports

Guidelines for the Preparation of Tax Section Reports

Tax Section Report Participation Policy

To be notified of new reports via email you must be a member of the Tax Section. To join the Tax Section, contact the Member Resource Center at [email protected] or 1-800-582-2452.

Reports and Letters are all in PDF format in the tabs below.
Please note: Below are the reports from 1986 through the current year. Some of these reports are very large. If you are trying to print them, please wait until the entire file is done downloading. Older reports between 1972 through 1985 are not on this website, however they are available in PDF format by request. Send an email to Kate Tortora and indicate the year and number of the report you need and the PDF will be emailed to you.

Master Index of Reports

Tax Reports 2023

Tax Section Report 1483
Report on Proposed Regulations Concerning Information Reporting for Digital Asset Transactions

Tax Section Report 1482
Report on Selected International Issues Relating to the Corporate Alternative Minimum Tax

Tax Section Report 1481
Report on Proposed Regulations Addressing New York Tax Reform

Tax Section Report 1480
Report on Proposed Regulations Regarding Transfers of Energy Tax Credits Under Section 6418

Tax Section Report 1479
Report on Proposed Section 367(d) Regulations Concerning Repatriation of Intangible Property

Tax Section Report 1478
Report on Notice 2023-27 and Nonfungible Tokens (NFTs)

Tax Section Report 1477
Report on Select Issues with Respect to Section 7874 and Partnerships

Tax Section Report 1476
Report on Foreign Tax Credit Considerations Related to the OECD Global Anti-Base Erosion Model Rules (Pillar Two)

Tax Section Report 1475
Report on the Transferability of Energy Tax Credits Under Section 6418

Tax Section Report 1474
Report on Notice 2023-2

Tax Section Report 1473
Report on Selected Issues Relating to the Corporate Alternative Minimum Tax

Tax Section Report 1472
Comments on the 2023-2024 New York State Executive Budget

Tax Reports 2022

Tax Section Report 1471
Report on NYS Draft Regulations Regarding P.L. 86-272

Tax Section Report 1470
Application of New York False Claims Act to Tax Controversies

Tax Section Report 1469
Report on the Section 4501 Excise Tax on Repurchases of Corporate Stock

Tax Section Report 1468
Report on New York Personal Income Tax Issues Arising from Remote Work and Telecommuting

Tax Section Report 1467
Report on Proposed 2053 Regulations

Tax Section Report 1466
Report on Draft Business Apportionment Factor Regulations

Tax Section Report 1465
Report on the OECD Global Anti-Base Erosion Model Rules (Pillar Two)

Tax Section Report 1464
Report on the Proposed Section 2010 Regulations Defining Exceptions to the Anti-Clawback Rule

Tax Section Report 1463
Report on the Analysis of Potential Design Changes to the Section 1.367(b) Regulations in Light of the Tax Cuts and Jobs Act

Tax Section Report 1462
Report on the Proposed Regulations Regarding PFICs and CFCs held by Partnerships and S Corporations

Tax Section Report 1461
Report on Cryptocurrency and Other Fungible Digital Assets

Tax Section Report 1460
Comments on 2022-2023 New York State Executive Budget

Tax Section Report 1459
Report on Notice 2021-56

Tax Section Report 1458
Report on Section 165(i) and Worthless Stock Deductions

Tax Section Report 1457
Report on Section 382 and CFCs

Tax Section Report 1456
Letter and Comments on Wash Sale Provisions of the House Proposals for the Build Back Better Act

Tax Section Report 1455
Report on NYS Section 612(b)(41)

Tax Section Report 1454
Report on Section 355 Device Prohibition and Section 367(a)

Tax Reports 2021

Tax Section Report 1453
Letter and Comments on Selected Partnership-Related Provisions of the House Proposals for the Build Back Better Act

Tax Section Report 1452
Letter with Further Comments on the Implementation of the New York State Pass-Through Entity Tax

Tax Section Report 1451
Letter on the New York State Pass-Through Entity Tax in the 2021

Tax Section Report 1450
Report on the Proposed “PFIC” Regulations under Sections 1297 and 1298 with Cover Letter

Tax Section Report 1449
Report on New York State 2021-2022 Executive Budget

Tax Section Report 1448
Report on Proposed Regulations Providing Guidance Related to the Foreign Tax Credit

Tax Section Report 1447
Report on Section 163(j) and the COD Income Rules

Tax Section Report 1446
Report on New York State’s Potential Response to Internal Revenue Service Notice 2020-75 and the State’s Resident Tax Credit

Tax Reports 2020

Tax Section Report 1431
Report on Technical Debt Modification Issues under Treasury Regulation Section 1.1001-3

Tax Section Report 1432
Report on Partnership Terminations Following the Tax Cuts and Jobs Act

Tax Section Report 1433
Report on The Taxation of Cryptocurrency

Tax Section Report 1434
Report on Proposed and Final Section 59A Regulations

Tax Section Report 1435
Report on Proposed Foreign Tax Credit Regulations

Tax Section Report 1436
Report on Procedural Guidance for Private Letter Rulings on Divisive Reorganizations: Revenue Procedure 2018-53 and Plan of Reorganization Issues

Tax Section Report 1437
Report on Application for Hardship Exemption under NYS Tax Law Section 171-v(5)

Tax Section Report 1438
Report on Proposed Anti-Conduit Regulation Treating Certain “Hybrid Equity” Transactions as Financings under Treasury Regulation Section 1.881-3

Tax Section Report 1439
Report on Proposed Section 512(a)(6) Regulations

Tax Section Report 1440
Report on Proposed Regulations under Sections 162(f) and 6050X

Tax Section Report 1441
Report on Proposed and Final Regulations Addressing GILTI and Subpart F High-Tax Exceptions

Tax Section Report 1442
Report on Proposed Regulations under Section 1061

Tax Section Report 1443
Report on Tax Consequences to Issuers of Debt Modifications and Exchanges

Tax Section Report 1444
Report on Final and Proposed Section 163(j) Regulations

Tax Section Report 1445
Report on Section 304 in Public M&A Transactions

Tax Reports 2019

Tax Section Report 1407
Report commenting on Proposed Qualified Opportunity Zone Regulations Under Section 1400Z-2

Tax Section Report 1408
Report on the Proposed Foreign Tax Credit Regulations

Tax Section Report 1409
Report on the Proposed Section 59A Regulations

Tax Section Report 1410
Report on the Proposed Section 2010 Regulations

Tax Section Report 1411
Report on Proposed Regulations under Section 267A, 245A(e) and 1503 (d)

Tax Section Report 1412
Report on Proposed Section 163(j) Regulations

Tax Section Report 1413
Comments on 2019-2020 New York State Executive Budget

Tax Section Report 1414
Comments on Section 864(c)(8) Proposed Regulations

Tax Section Report 1415
Report on Final and Proposed Guidance under Section 199A

Tax Section Report 1416
Report on Proposed Regulations under Section 250 (Foreign Derived Intangible Income)

Tax Section Report 1417
Report on the Proposed “May Company” Regulations under Section 337(d)

Tax Section Report 1418
Report on Proposed Qualified Opportunity Zone Regulations under Section 1400Z-2

Tax Section Report 1419
Report on Section 1446(f) Proposed Regulations

Tax Section Report 1420
Report on the Branch Loss Recapture Rules of Section 91

Tax Section Report 1421
Report on Proposed Regulations relating to Section 897(1)

Tax Section Report 1422
Report on the Proposed “PFIC” Regulations under Sections 1291, 1297 and 1298

Tax Section Report 1423
Report on June 2019 GILTI and Subpart F Regulations

Tax Section Report 1424
Report on Proposed Section 4968 Regulations

Tax Section Report 1425
Report on Tax Fungibility of Debt Instruments

Tax Section Report 1426
Report on Proposed Regulations under Section 382(h) Related to Built-in Gain and Loss

Tax Section Report 1427
Report on Proposed Section 861 Regulations

Tax Section Report 1428
Report on New Final and Proposed Regulations Under Section 168(k) Relating to Immediate Expensing of Capital Investments

Tax Section Report 1429
Report on Select Issues under Sections 382 and 108 involving Carryforwards of Recognized Built-in Losses and Business Interest

Tax Section Report 1430
Report on IBOR Transition Proposed Regulations

Tax Reports 2018

Tax Section Letter 1385
Letter commenting on Proposed Regulations Providing Guidance on the Definitions of Registration-Required Obligation and Registered Form

Tax Section Letter and Report 1386
Letter and Report commenting on Notice 2017-57: Alternative Rules for Determining Section 987 Gain or Loss

Tax Section Letter 1387
Letter requesting Immediate Guidance under Sections 864(c)(8) and 1446(f)

Tax Section Letter and Report 1388
Letter and Report commenting on Section 965

Tax Section Letter and Report 1389
Letter and Report commenting on the Mark-to-Market Taxation of Derivatives

Tax Section Letter and Report 1390
Letter and Report commenting on Notice 2017-73 – Donor-Advised Funds

Tax Section Report 1391
Report commenting on 2018-2019 New York Executive Budget

Tax Section Letter and Report 1392
Letter and Report commenting on Section 199A Deduction

Tax Section Letter and Report 1393
Letter and Report commenting on Section 163(j)

Tax Section Letter and Report 1394
Letter and Report commenting on the GILTI Provisions of the Code

Tax Section Letter 1395
Letter relating to the Section 385 Per Se Stock Rules

Tax Section Letter and Report 1396
Letter and Report commenting on Provisions of the New Tax Law Affecting Tax-Exempt Organizations

Tax Section Letter and Report 1397
Letter and Report commenting on Base Erosion and Anti-abuse Tax

Tax Section Letter and Report 1398
Letter and Report addressing 864(c)(8) and 1446(f) of the Internal Revenue Code of 1996

Tax Section Letter and Report 1399
Letter and Report on Foreign Derived Intangible Income

Tax Section Letter and Report 1400
Letter and Report on Proposed Foreign Current Hedging Regulations

Tax Section Letter and R eport 1401
Letter and Report on Proposed Section 965 Regulations

Tax Section Letter and Report 1402
Letter and Report on Previously Taxed Earnings under Section 959

Tax Section Letter and Report 1403
Letter and Report on Proposed Section 199A Regulations

Tax Section Letter and Report 1404
Letter and Report on Proposed Section 245A

Tax Section Letter and Report 1405
Letter and Report on Proposed Regulations Under Section 168(k) Relating to Immediate Expensing of Capital Investments

Tax Section Letter and Report 1406
Letter and Report on Report on Proposed GILTI Regulations

Tax Reports 2017

Tax Section Letter 1362
Letter commenting on Reserved Portions of the FATCA Final Regulations: Foreign Passthru Payments Withholding

Tax Section Letter 1363
Letter commenting on Tax Treatment of Payments to Retired Law Firm Partners Providing Pro Bono Legal Services

Tax Section Letter and Report 1364
Letter and Report commenting on Proposed Section 2801 Regulations

Tax Section Letter and Report 1365
Letter and Report commenting on the Discussion Draft of the Modernization of Derivatives Tax Act of 2016

Tax Section Letter and Report 1366
Letter and Report commenting on Possible Regulations Interpreting Rules Governing Applicable High Yield Discount Obligations

Tax Section Letter and Report 1367
Letter and Report commenting on Fiscal Year 2018 Budget Bill S02006/A03006 – Consolidation of Administrative Hearings

Tax Section Letter and Report 1368
Letter and Report commenting on Proposed Regulations Under Section 514(c)(9)(E)

Tax Section Letter and Report 1369
Letter and Report commenting on Draft Business Apportionment Factor Regulations

Tax Section Letter and Report 1370
Letter and Report commenting on Temporary Regulations Dealing with “Predecessors” and “Successors” under Section 355(e)

Tax Section Letter and Report 1371
Letter and Report commenting on Certain Corporate Reorganization Transactions Followed by “Same-State” Asset Drop-Downs

Tax Section Letter and Report 1372
Letter and Report commenting on Possible Amendments to Regulations Governing the Deductibility of Premium Paid upon the Redemption of Convertible Bonds

Tax Section Letter and Report 1373
Letter and Report commenting on the Application of Section 894 to Effectively Connected Income of Hybrid Entities

Tax Section Letter 1374
Letter commenting on Notice 2017-28: Recommendations for 2017-2018 Priority Guidance Plan

Tax Section Letter and Report 1375
Letter and Report commenting on the Temporary and Proposed Regulations under Section 901(m)

Tax Section Letter 1376
Letter commenting on Notice 2017-38

Tax Section Letter and Report 1377
Letter and Report commenting on Notice 2016-73

Tax Section Letter and Report 1378
Letter and Report commenting on the Proposed Regulations Related to the Partnership Audit Rules of the Bipartisan Budget Act of 2015

Tax Section Letter and Report 1379
Letter and Report commenting on Draft Regulations Regarding Prior Net Operating Loss Conversion (“PNOLC”) Subtraction

Tax Section Report 1380
Report commenting on Recommended Amendments to the New York State Driver’s License Suspension Program

Tax Section Letter and Report 1381
Letter and Report commenting on Revenue Ruling 2017-09 and “North-South” Transactions

Tax Section Letter and Report 1382
Letter and Report commenting on Final, Temporary and Proposed Regulations Under 337 (d) Relating to Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts

Tax Section Report 1383
Report commenting on Debt Issued by Disregarded Entities and Treasury Regulations Section 1.1001-3

Tax Section Letter and Report 1384
Letter and Report commenting on the Treatment of Share Repurchases under Section 355(e)

Tax Reports 2016

Tax Section Letter 1337
Letter Commenting on Proposed Section 367 Regulations; Elimination of the Foreign Goodwill Exception

Tax Section Letter and Report 1338
Letter and Report Commenting on Report on Notice 2015-79

Tax Section Letter and Report 1339
Letter and Report on Draft Business Apportionment Factor Regulations

Tax Section Letter and Report 1340
Letter and Report commenting on final, temporary, and proposed regulations under section 871(m)

Tax Section Letter 1341
Letter Commenting on regulations issued under new section 506

Tax Section Letter and Report 1342
Letter and Report on Notice 2015-59 and Revenue Procedure 2015-43

Tax Section Letter and Report 1343
Letter and Report commenting on Draft Regulations Under Article 9-A relating to Combined Returns

Tax Section Letter and Report 1344
Letter and Report commenting on New York State Tax Law Section 171-v

Tax Section Letter and Report 1345
Letter and Report commenting on Notice 2015-54, issued August 6, 2015

Tax Section Letter 1346
Letter in response to Notice 2016-26, recommendations for 2016-2017 Priority Guidance Plan

Tax Section Letter and Report 1347
Letter and Report commenting on the Partnership Audit Rules of the Bipartisan Budget Act of 2015

Tax Section Letter and Report 1348
Letter and Report commenting on Temporary Regulations Addressing Notional Principal Contracts with Nonperiodic Payments

Tax Section Letter and Report 1349
Letter and Report commenting on Final Regulations on Reorganizations under Section 368(a)(1)(F)

Tax Section Letter and Report 1350
Letter and Report commenting on Proposed and Temporary Regulations on United States Property Held by Controlled Foreign Corporations in Transactions Involving Partnerships

Tax Section Letter and Report 1351
Letter and Report commenting on the Proposed Regulations under Section 385

Tax Section Letter and Report 1352
Letter and Report commenting on the Proposed Regulations under Section 305(c)

Tax Section Letter 1353
Letter commenting on Draft Amendments to Sections 4-6.1, 4-6.3 and 4-6.4 of Subpart 4-6 of the New York State Business Corporation Franchise Tax Regulations

Tax Section Letter and Report 1354
Letter and Report commenting on Changes to FIRPTA under the Protecting Americans from Tax Hikes Act of 2015

Tax Section Letter and Report 1355
Letter and Report commenting on Temporary and Proposed Regulations under Section 337(d) and Section 732(f)

Tax Section Letter and Report 1356
Letter and Report commenting on Proposed Regulations under Section 355 Concerning the Device Prohibition and Active Trade or Business Requirement

Tax Section Letter and Report 1357
Letter and Report on Guaranteed Payments and Preferred Returns; commenting on issues relating to partnerships that provide for preferred returns to one or more partners.

Tax Section Letter and Report 1358
Letter and Report commenting on Proposed Regulations under Section 2704 of the Code

Tax Section Letter and Report 1359
Letter and Report commenting on Proposed Regulations under Section 851 of the Code

Tax Section Letter and Report 1360
Letter and Report commenting on Notice 2016-52, on Splitter Arrangements from Foreign-Initiated Tax Adjustments

Tax Section Letter 1361
Letter commenting on Proposed and Temporary Regulations under Sections 707 and 752

Tax Reports 2015

Tax Section Letter and Report 1336
Letter and Report Commenting on Notice 2015-54, Transfers of Property to Partnerships with Related Foreign Partners and Controlled Transactions Involving Partnerships.

Tax Section Letter and Report 1335
Letter and Report Commenting on the Operation of Section 956(d) in the Context of Multiple Guarantors/Pledgors in Respect of a Single Obligation of a U.S. Person.

Tax Section Letter and Report 1334
Letter and Report Commenting on Draft Amendments to Regulations Regarding Corporations Subject to Article 9-A Tax.

Tax Section Letter and Report 1333
Letter and Report Relating to the Allocation of Earnings and Profits in Connection with Divisive Transactions.

Tax Section Letter and Report 1332
Letter and Report Relating to the Definition of a Creditable Tax for Purposes of Sections 901 and 903.

Tax Section Letter and Report 1331
Letter and Report Relating to the Proposed Revisions to the Limitation on Benefits Article of the U.S. Model Tax Convention.

Tax Section Letter and Report 1330
Letter and Report provides comments on the Proposed Regulations on Disguised Payment for Services.

Tax Section Letter and Report 1329
Letter and Report provides comments on the Proposed Regulations under Section 751(b).

Tax Section Letter and Report 1328
Letter and Report provides comments on Proposed Regulations Regarding Allocation of Income and Deduction of Corporations Joining or Leaving Consolidated Groups.

Tax Section Letter and Report 1327
Letter and Report provides comments Relating to Two of the Proposed Revisions to the U.S. Model Tax Convention.

Tax Section Letter and Report 1326
Letter and Report provides comments on the Material Participation of Trusts and Estates under Sections 469 and 1411 of the Code.

Tax Section Letter and Report 1325
Letter and Report provides comments on the Tax Treaty Consistency Principle.

Tax Section Letter and Report 1324
Letter and Report provides comments on the Non-Ordinary Course Distribution Rules in Notice 2014-52.

Tax Section Letter and Report 1323
Letter and Report provides comments on the Treatment of Exculpatory Liabilities for Purposes of Section 704 and Section 752.

Tax Section Letter 1322
Letter provides comments on Recommendations for 2015-2016 Priority Guidance Plan.

Tax Section Letter and Report 1321
Letter and Report provides comments on Proposed Regulations Issued under Sections 959 and 961.

Tax Section Letter 1320
Letter provides comments on Systems for Holding Consumer and Privately Negotiated Loans in Registered Form to Qualify for the Portfolio Interest Exemption.

Tax Section Report 1319
2015-2016 New York State Executive Budget Report.

Tax Section Letter and Report 1318
Letter and Report provides comments on House Ways and Means Committee Discussion Draft Provisions to Reform the Taxation of Financial Instruments and Corresponding Proposals by the Obama Administration.

Tax Section Letter 1317
Letter provides comments on proposal to modify regulations under Section 336(e) and Section 338.

Tax Section Letter and Report 1316
Letter and Report provides comments on proposed regulations regarding allocation of consideration and allocation and recovery of basis in transactions involving corporate stock or securities.

Tax Section Letter and Report 1315
Letter and Report provides comments on the Gross Receipts Test of Section 165(g)(3)(B).

Tax Reports 2014

Tax Section Letter and Report 1314
This report provides comments on proposed regulations relating to loss duplication in the partnership context.

Tax Section Letter and Report 1313
This report provides comments on treaty resourcing of income provisions.

Tax Section Letter 1312
This report provides comments on guidance under the New York State corporate tax reform provisions.

Tax Section Letter and Report 1311
This report provides comments on the Proposed Regulations Regarding the Allocation of Recourse Partnership Liabilities.

Tax Section Letter and Report 1310
This report provides comments on Kimbell-Diamond Doctrine.

Tax Section Report 1309
This report provides comments on recommended Technical Corrections to 2014 New York State Corporate Tax Reform Legislation.

Tax Section Letter and Report 1308
This report provides comments on temporary regulations issued on January 17, 2014, that disregard, for purposes of Section 7874 of the Code, certain stock issued by a foreign corporation in a transaction related to its acquisition of a domestic entity.

Tax Section Letter and Report 1307
This report provides comments on regulations proposed on January 30, 2014 (the “Proposed Regulations”), concerning the allocation of partnership liabilities under section 752 and disguised sales under section 707.

Tax Section Letter and Report 1306
This report provides comments on the proposed regulations under Section 871(m) about avoidance of withholding tax on U. S. source dividends through derivative transactions.

Tax Section Report 1305
Report 1305 provides “Comments on The Public Discussion Draft of BEPS Action 2: Neutralise the Effects of Hybrid Mismatch Arrangements (Recommendations for Domestic Laws)”.

Tax Section Letter 1304
This report provides recommendations for 2014-2015 priority guidance plan in response to Notice 2014-18.

Tax Section Letter Report 1303
This letter provides comments on Notice 2013-78, which proposes to issue a new revenue procedure that relates to the Mutual Agreement Procedure (the “MAP Notice”) for mitigating double taxation under income tax treaties entered into between the United States and other countries. This letter does not specifically comment on the accompanying Notice 2013-79 (the “APA Notice”), which was issued on the same day as the MAP Notice and which sets forth procedures for Advance Pricing Agreements.

Tax Section Cover Letter and Report 1302
This report provides comments on the Proposed Anti-Loss Importation Regulations Under Sections 362(e)(1) and 334(b)(1)(B) of the Internal Revenue Code.

Tax Section Memorandum Report 1301
This report on the corporate income tax reform proposals in the New York State 2014-2015 Executive Budget comments on certain technical, administrative and conceptual issues raised by the Budget Bill.

Tax Section Cover Letter and Report 1300
This report offers commentary and recommendations on Revenue Procedure 2011-16, which addresses transactions undertaken by real estate investment trusts involving distressed mortgage debt.

Tax Section Memorandum Report 1299
This report provides comments on a proposal to tax New York Trust beneficiaries on their receipt of certain trust distributions (the “Throwback Tax Proposal”) contained in Revenue Article VII, Part I of the 2014-15 New York State Executive Budget (“Part I”).

Tax Section Letter Report 1298
This report makes recommendations for guidance addressing the treatment of foreign tax refunds, under Sections 853 and 905(c) received by a regulated investment company (“RIC”).

Tax Section Cover Letter and Report 1297
This report provides recommendations relating to the current project at the Department of Treasury and the Internal Revenue Service to issue guidance under implementing Revenue Ruling 91-32.

Tax Section Cover Letter and Report 1296
This report provides comments and recommendations on Section 2 of Notice 2007-55 and Possible Administrative Guidance Addressing Sections 897(h)(1) and 1445(e)(6) of the Internal Revenue Code.

Tax Section Cover Letter and Report 1295
This report addresses the FATCA Final Regulations under Sections 1471 through 1474 of the Internal Revenue Code: PFFI Rules; IGAs; Interaction Between the Regulations and Chapters 3 and 61.

Tax Reports 2013

Tax Section Cover Letter and Report 1294
This report focuses primarily on the need for more publicly available information on the guidelines and procedures applicable to the installment agreement process.

Tax Section Cover Letter and Report 1293
This report responds to the New York State Tax Reform and Fairness Commission’s request for recommendations with respect to certain issues relating to the income tax treatment of certain New York State resident trusts.

Tax Section Cover Letter and Report 1292
This report addresses the appropriate role of the step transaction doctrine in determining the U.S. Federal income tax consequences of certain transactions involving stock distributions intended to qualify as tax-free under Section 355 of the Code.

Tax Section Cover Letter and Report 1291
This report discusses the proposed regulations issued under Section 162(m)(6) of the Internal Revenue Code on April 2, 2013.

Tax Section Cover Letter and Report 1290
This report provides comments and recommendations regarding the proposed corporate equity reduction transaction (“CERT”) regulations issued on September 13, 2012.

Tax Section Cover Letter and Report 1289
This report addresses proposed treasury regulation § 1.108-9

Tax Section Cover Letter and Report 1288
This report suggests that the NYS Department of Taxation and Finance issue administrative guidance addressing the procedures for the collection of tax liabilities under NYS Tax Law Section 174-b and related statutory provisions.

Tax Section Cover Letter and Report 1287
This report on Subpart F issues involving currency gain and loss provides comments on the treatment of currency gain as “subpart F income,” and related issues, under selected circumstances.

Tax Section Cover Letter and Report 1286
This report provides comments and recommendations on the proposed regulations regarding the tax treatment of noncompensatory partnership options (“NCOs”) issued by the Treasury Department and the IRS on February 5, 2013.

Tax Section Cover Letter and Report 1285
This report discusses the proposed regulations addressing the treatment under Section 1411 of the Code of income and gains derived from the ownership of stock that is a controlled foreign corporations or a passive foreign investment company, Proposed Regulations 1.1411.10.

Tax Section Cover Letter and Report 1284
This report provides comments and recommendations on the regulations proposed under Section 1411 of the Code on December 3, 2012.

Tax Section Cover Letter and Report 1283
This report provides recommendations for the 2013-2014 Guidance Priority List.

Tax Section Cover Letter and Report 1282
This report provides comments and recommendations on the definitions of “FFI,” “financial account,” and related terms in the final regulations under Sections 1471 through 1474 of the Code, commonly referred to as “FATCA.”

Tax Section Cover Letter and Report 1281
This report requests guidance on the proper tax treatment by the buyer of the assumption of a deferred revenue liability of the seller in a taxable asset acquisition of a business.

Tax Reports 2012

Tax Section Report 1280
This report provides comments on the proposed amendments to the regulations governing practice before the IRS (“Circular 230”) published on September 17, 2012 and addresses the proposed changes to the standards applicable to written tax advice.

Tax Section Report and Letter 1279
This report comments on the temporary “substantial business activities” regulations under Section 7874.

Tax Section Report and Letter 1278
This report comments on the treatment of contingent liabilities in the determination of “insolvency” for purposes of Section 108(a)(1)(B).

Tax Section Report and Letter 1277
This report provides comments and recommendations on temporary and proposed regulations under Section 988(d) of the Code, which address the tax treatment of partial “legouts” of certain foreign currency hedges.

Tax Section Report 1276
This letter comments on final regulations regarding the definition of “publicly traded” under Section 1273 of the Code and related issues.

Tax Section Report and Letter 1275
This report provides comments and recommendations on the proposed regulations under Section 312 of the Code regarding the allocation of earnings and profits in an acquisitive asset reorganization.

Tax Section Report and Letter 1274
This report comments on whether and when partnerships should be required to allocate adjustments under Section 743(b) of the Code to contingent liabilities.

Tax Section Report and Letter 1273
This report provides comments and recommendations on the temporary and proposed regulations under Section 909 and the final “technical taxpayer” regulations under Section 901 of the Code.

Tax Section Report and Letter 1272
This report provides comments on Representative Camp’s International Tax Reform Discussion Draft.

Tax Section Report and Letter 1271
This report proposes that Treasury withdraw loss disallowance regulations under Section 267(b) of the Code in light of subsequent amendments to Section 267(b) and 707(b) of the Code.

Tax Section Report and Letter 1270
This report provides comments and recommendations on the proposed “May Company” regulations under Section 337(d) of the Code.

Tax Section Report and Letter 1269
This report provides comments on Prop. Reg. section 1.1502-91(g)(7), which addresses the determination of “net urealized built-in gain or loss” of a consolidated group under Section 382 of the Code.

Tax Section Report and Letter 1268
This report provides comments on Notice 2012-15, which addresses the application of Section 367 to cross-border stock sales to foreign corporations subject to Section 304 of the Code.

Tax Section Report and Letter 1267
This report provides comments and recommendations on proposed regulations under Sections 1471 through 1474 of the Code (FATCA), as well as on the joint statement on FATCA implementation by the governments of the United States, France, Germany, Italy, Spain, and the United Kingdom.

Tax Section Report and Letter 1266
This report provides comments and recommendations on proposed regulations regarding the common law “continuity of interest” requirement governing reorganizations under Section 368 of the Code and the application of the “signing date” rule to reorganizations that provide for variable consideration.

Tax Section Report and Letter 1265
This report comments on the income, gift, estate and generation-skipping transfer tax consequences of trust “decanting” transfers.

Tax Section Report and Letter 1264
This report provides comments and recommendations on proposed and temporary regulations under Section 871(m) of the Code.

Tax Section Report and Letter 1263
This letter responds to Notice 2012-25, which requests recommendations for items that should be included on the 2012-2013 Tax Guidance Priority List.

Tax Section Report and Letter 1262
This report provides comments on how a partnership should allocate a recourse liability under Section 752 of the Code in light of the IPO II case when one or more partners are related to persons who bear economic risk of loss with respect to the liability.

Tax Section Report and Letter 1261
This report describes current market practice regarding tax opinions in registered offerings of securities.

Tax Section Report and Letter 1260
This report provides comments and recommendations on the “portability” of Unused Estate Tax Exclusion.

Tax Section Report and Letter 1259
This report provides comments and recommendations on proposed regulations under Section 469 of the Code that would modify the current definition of “limited partner.”

Tax Section Report and Letter 1258
The report provides comments and recommendations on a proposal to broaden the relief currently available from the “segregation” rules under Section 382 to include broader categories of direct or indirect transactions involving less than 5-percent shareholders of a loss corporation.

Tax Section Letter 1257
This report provides comments and recommendations on proposed regulations under Section 892 of the Code, which exempts foreign sovereigns and certain related entities from taxation on certain types of investments in the United States.

Tax Section Report and Letter 1256
This report provides comments on the proposed withdrawal of the “de minimis” exception to the substantiality requirement under the Section 704(b) regulations.

Tax Section Report and Letter 1255
This report requests that Treasury clarify that distressed debt is not treated as “stock” for purposes of Section 382.

Tax Section Report and Letter 1254
This report addresses the tax deductibility under Section 170 of the Code and related sections of the Code of charitable contributions made to be “disregarded” subsidiaries of tax-exempt organizations.

Tax Section Report and Letter 1253
This report provides comments on Notices 2011-34 and 2011-53, including recommendations concerning the obligation of certain foreign financial institutions under FATCA to withhold on “passthru payments.”

Tax Reports 2011

Tax Section Report and Letter 1252
Generally, sections 351(e) and 368(a)(2)(F) deny tax-free treatment for a transaction that qualifies as a section 351 exchange or 368 reorganization where the transaction involves one or more investment companies. This report makes recommendations for the Treasury and IRS to provide guidance that will: ensure the types of transactions Congress was concerned with are subject to recognition, eliminate unintended applications of the provisions, and, provide certainty to taxpayers on significant ambiguities under current law.

Tax Section Report and Letter on draft regulations concerning NYS Offers in Compromise 1251
Comments on the draft amendments to the Offer in Compromise regulations Part 5005 of Chapter VIII of 20 NYCRR to implement recent changes in the Commissioner’s authority to compromise taxes under section 171 (fifteenth) of NY Tax Law

Tax Section Report and Letter 1250
The report addresses issues arising out of the enactment of the Hiring Incentives to Restore Employment Act (the “HIRE Act”) that relate to the issuance of registered debt after March 18, 2012. This report concerns registered debt following the Hire Act.

Tax Section Report and Letter 1249
Report and Letter on the Interaction of Section 909 and Subchapter K

Tax Section Report and Letter 1248
Report on Distressed Debt Instruments

Tax Section Report and Letter 1247
Comments on the Application of Employment Taxes to Partners and on the Interaction of the Section 1401 Tax with the new Section 1411 Tax

Tax Section Letter 1246
Comments on 2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions and Answers

Tax Section Report and Letter 1245
Proposed Regulations Concerning Series Organizations

Tax Section Letter 1244
Treasury Request for Public Comments Regarding Executive Order 13563

Tax Section Letter 1243
Recommendations for 2011-2012 Tax Guidance Priority List

Tax Section Letter 1242
Possible Tax Relief for Disaster-Related Efforts

Tax Section Letter 1241
Draft Form 8939, Allocation of Increases in Basis for Property Acquired From a Decedent; Reporting of Certain 2010 Generation-Skipping Transfers

Tax Section Report and Letter 1240
New York State Bar Association Tax Section Report on Revenue Ruling 99-6

Tax Section Report and Letter 1239
Report of the Tax Section of the New York State Bar Association on Certain Aspects of the Taxation of Securities Loans and the Operation of Section 1058

Tax Section Report and Letter 1238
Report on Notice 2010-49

Tax Section Report and Letter 1237
Report on Proposed Regulations on The Definition of Public Trading

Tax Section Report and Letter 1236
Report on Certain Continued Coverage Under Insured Group Health Plans in Light of the PPACA Nondiscrimination Rules and IRS Notice 2011-1

Tax Section Letter 1235
Proposed Legislation (S.l 072) Creating an Office of the Taxpayer Advocate

Tax Section Report and Letter 1234
Report on Section 871(m)

Tax Section Report and Letter 1233
Report on Nonresident Audit Guidelines of the State of New York

Tax Section Report and Letter 1232
Report on the Management and Control Provision of the “International Tax Competitiveness Act of 2011

Tax Section Report and Letter 1231
Report on Section 901(m)

Tax Section Report and Letter 1230
Claiming Worthlessness for a Failed Subsidiary within a Consolidated Group

Tax Section Report and Letter 1229
Report on Characterizing “Overlap” Transactions Under Subchapter C

Tax Section Report and Letter 1228
Report on Codification of the Economic Substance Doctrine

Tax Reports 2010

Tax Section Report and Letter 1227
Report on Certain International Issues Relating to All-Cash Acquisitive D Reorganizations

Tax Section Letter 1226
Effect of de Minimis OID under Reg. Sec. 1.1001-3(e)(2)

Tax Section Report and Letter 1225
Report on Uncertain Tax Positions in the Context of Mergers, Acquisitions and Spin-offs

Tax Section Report and Letter 1224
Report on Notice 2010-60

Tax Section Report and Letter 1223
Report On Issues Under Section 909 of the Code

Tax Section Report and Letter 1222
Report on Section 367(d)

Tax Section Letter 1221
Report on Medicare Contribution Tax Definition of Net Investment Income

Tax Section Report and Letter 1220
Report on Aggregation Issues Facing Securities Partnerships Under Subchapter K

Tax Section Report and Letter 1219
Report on Partnership Target Allocation

Tax Section Report and Letter 1218
Report on Legislative Proposal Regarding Employment Taxes and Professional Service Businesses

Tax Section Report and Letter 1217
Report on Section 514: Debt-Financed Income Subject to UBIT

Tax Section Report and Letter 1216
New York State Bar Association Tax Section Report on the Rescission Doctrine

Tax Section Letter 1215
Recommendations for 2010-2011 Tax Guidance Priority List

Tax Section Report and Letter 1214
Report on Guidance Under U.S. Income Tax Treaties

Tax Section Letter 1213
Comments on the Proposed Denial of Treaty Benefits for Certain Related-Party Deductible Payments

Tax Section Report and Letter 1212
Report on Ambiguities and Uncertainties in the Original Issue Discount Regulations

Tax Section Report and Letter 1211
Report on Certain Issues Under Section 7874

Tax Section Report and Letter 1210
Report on FDIC-Assisted Taxable Acquisitions

Tax Section Report and Letter 1209
Report on Definition of “Traded on an Established Market” within the Meaning of Section 1273 and Related Issues

Tax Section Report and Letter 1208
New York State Bar Association Tax Section Report on Announcement 2010-9, March 29, 2010

Tax Section Report and Letter 1207
Report Commenting on Select Issues with Respect to the Passive Foreign Investment Company Rules

Tax Section Letter 1206
2010-11 New York State Executive Budget—Comments on Certain Revenue Provisions

Tax Section Report 1205
Report Commenting on 2010-2011 New York State Executive Budget Proposal to Modify Income Taxation of New York Resident Trusts

Tax Section Letters 1, 2 and 3 1204
Estimated Tax Consequences of Roth IRA and New York Estimated Tax Consequences of Roth IRA

Tax Section Report 1203
Report on Proposed Changes to New York State Statute of Limitations on Collection of Unpaid Tax Liabilities

Tax Section Report and Letter 1202
Report on the Request for Comments on Section 704(c) Layers Relating to Partnerships Mergers, Divisions and Tiered Partnerships

Tax Section Report and Letter 1201
Report on Proposed Regulations on Varying Partnership Interests Under Section 706

Tax Section Report 1200
Possible Tax Relief for Haiti Relief Efforts

Tax Section Letter 1199
Comments on the Foreign Account Tax Compliance Legislation

Tax Reports 2009

Tax Report and Letter 1198
Report on the Treatment of Fluctuations in Value under Section 382(l)(3)(C)

Tax Report and Letter 1197
Report On Administration Proposals Regarding Deferral Of Deductions Related To Deferred Foreign Income, Foreign Tax Credit Pooling, And Entity Classification Rules

Tax Letter 1196
Temporary Suspension of AHYDO Rules

Tax Report and Letter 1195
Report on IRS Announcement 2008-115 on FIRPTA Treatment of Rights Granted by a Governmental Unit

Tax Report and Letter 1194
Report on the Rules Governing Reports on Transactions with Foreign Financial Agencies (FBARs)

Tax Report and Letter A and B 1193
Report on Rules Governing Nonqualified Deferred Compensation Under Section 457A

Tax Report and Letter 1192
Report on Temporary Regulations Regarding the Hot Stock Rules Under Section 355(a)(3)(B)

Tax Report and Letter 1191
Temporary and Proposed Regulations Regarding All-Cash Acquisitive D Reorganizations

Tax Letter 1190
Comments on Proposed Modifications to Section 6662 Penalty in America’s Affordable Health Choices Act of 2009

Tax Report and Letter 1189
Report on Qualified Intermediary and Related Withholding and Information Reporting Legislation Proposed by the Administration

Tax Report and Letter 1188
Report on the Application of Anti-Conduit Regulations to Hybrid Entities and Instruments

Tax Letter 1187
Draft Amendments to Residency Rules for Student Housing

Tax Letter 1186
Request for Formal Guidance on FBAR Reporting Obligations

Tax Letter 1185
Recommendations for 2009-2010 Tax Guidance Priority List

Tax Report and Letter 1184
Report On Proposed Regulations Under Sections 108(e)(8) and 721 on Partnership Debt-for-Equity Exchanges

Tax Report and Letter 1183
Report responding to an IRS request for assistance in identifying and addressing issues confronting private foundation investors in Ponzi schemes and other frauds.

Tax Report and Letter 1182
Report on the Cancellation of Indebtedness and AHYDO Rules of Sections 108(i) and 163(e)(5)(F)

Tax Letter 1181
Letter Re Process for Making Appointments to the New York Tax Appeals Tribunal

Tax Report and Letter 1180
Remedying Documentary Noncompliance By Section 409A Plans

Tax Report 1179
Report on Selected Tax Provisons of the 2009-2010 NYS Executive Budget Legislation

Tax Report 1178
Draft Amendments to Regulations With Regard to Combined Returns.

Tax Report and Letter 1177
Proposed Regulations Under Section 367, 1248 and 6038

Tax Report and Letter 1176
Report on the Treatment of Capital Contributions Under Code Section 382(l)(1)

Tax Report 1175
Report on Revenue Procedure 2008-51

Tax Reports 2008

Tax Report and Letter 1174
Report commenting on proposed regulations under Section 336(e), concerning the treatment of certain stock sales and distributions as asset transfers.

Tax Report and Letter 1173
Report on international provisions of H.R. 3970 (the Tax Reduction and Reform Act of 2007) and effects of reduction in corporate tax rate.

Tax Report and Letter 1172
Tax issues arising when a life insurance policy is purchased by an investor with no insurable interest in the insured, known as “investor-owned life insurance.

Tax Report and Letter 1171
Report on the proposed removal of the “temporary stay” exception from 20 NYCRR Section 105.20(e)(1) concerning taxation of an individual as a resident in New York.

Tax Letter 1170
Good faith compliance with Section 409A.

Tax Report 1169
Report on “commensurate in scope” test introduced in Revenue Ruling 64-182 and the issue of endowment size of certain public charities.

Tax Letter 1168
Letter commenting on a proposed ruling concerning the tax consequences of using a private trust, company to serve as the trustee of trusts having family members as grantors and beneficiaries.

Tax Letter 1167
Letter dated November 4, 2008 from David S. Miller to Governor David Paterson recommending the repeal of the stock transfer tax.

Tax Report and Letter 1166
Report on Proposed Carried Interest and Fee Deferral Legislation

Tax Letter 1165
Request for Formal Guidance on Tax Consequences of Warrant Exercises

Tax Report and Letter 1164
Selected Issues in Triangular Reorganizations

Tax Report 1163
Guidance on Economic Downturn Issues

Tax Report 1162
Formal Guidance for Stock Buy-Backs and “North and South” Transactions

Tax Report and Letter 1161
Report on the Proposed Contract Manufacturing Regulations

Tax Report and Letter 1160
Report on Treatment of Executors’ and Trustees’ Commissions

Tax Report and Letters A and B 1159
Report on Prepaid Forward Contracts

Tax Report and Letter 1158
Distributions in Connection with Acquisitions

Tax Report and Letter 1157
Tax Exemption for Foreign Sovereigns Under Section 892

Tax Letter 1156
Notice 2008-20 Intermediary Tax Shelters

Tax Report and Letter 1155
Revenue Procedure 2003-65

Tax Letter 1154
Notice 2008-19 and Protected Cell Companies Outside of the Insurance Arena

Tax Report and Letter 1153
Recommending Repeal of Section 562(c) With Respect to RICs and REITs

Tax Report and Letter 1152
Treasury Regulations Sections 1.368-1(d) and -2(k)

Tax Report and Letter 1151
Modifications to Commercial Mortgage Loans Held by a Real Estate Mortgage Investment Conduit (REMIC)

Tax Report and Letter 1150
Report on Proposed Treasury Regulation Section 1.1502-13(g) Relating to Intercompany Obligations

Tax Report 1149
Report on the Proposed Amendments to Circular 230 Relating to Standards with Respect to Tax Returns

Tax Letter 1148
Canadian-U.S. Treaty Protocol — Payments Through Hybrids

Tax Report 1147
New York Stock Transfer Tax

Tax Report 1146
Recent and Proposed Statutory Changes to Tax Return Preparer Penalty Rules of Internal Revenue Code Section 6694 and Related Issues

Tax Report 1145
Nexus Requirements for Imposition of Business Activity Taxes

Tax Report and Letter 1144
Final Dual Consolidated Loss Regulations

Tax Report 1143
Tax Equity for Domestic Partner and Health Beneficiaries Act (S.1556); Tax Equity for Health Plan Beneficiaries Act of 2007 (H.R. 1820).

Tax Report and Letter 1142
Proposed Regulations Regarding the Active Trade or Business Requirement under Section 355(b).

Tax Report 1141
Comments on Proposed Amendments to Part 132 of the Personal Income Tax Regulations

Tax Report 1140
Report on Proposed Regulations Under Section 987

Tax Reports 2007

Tax Report, Letter and Appendix 1139
Definition of “Tax Return Preparer” and Other Issues Under Code Sections 6694, 6695 and 7701(a)(36)

Tax Report and Letter 1138
Proposed Consolidated Return Stock Loss Regulations

Tax Report and Letter 1137
Final Regulations Regarding Allocation of Basis under Section 358 and Related Matters

Tax Report and Letter 1136
Comments in Response to Notice 2007-39 Concerning Monetary Penalties for Certain Prohibited Conduct Under Circular 230.

Tax Report and Letter 1135
Proposed Section 901 Regulations Relating to Compulsory Payments of Foreign Taxes

Tax Report and Letter 1134
Responding to IR-2007-127, Request for Comments Regarding General Powers of Appointment Under IRC Section 2514

Tax Report and Letter 1133
Relating to Restrictions Imposed on Offers and Sales of Bearer Bonds by the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”).

Tax Report and Letter 1132
Guidance under the Pension Protection Act of 2006

Tax Report and Letter 1131
Disqualified Investment Corporations as Defined in Section 355(g).

Tax Report and Letter 1130
Proposed Regulations Regarding Exchanges of Property for Annuities.

Tax Report and Letter 1129
Responding to Notice 2007-21 Concerning Donor-Advised Funds and Supporting Organizations.

Tax Report and Letter 1128
With respect to Tax Provisions of the New York State 2007 — 2008 Budget Legislation (Chapter 60 of the Laws of 2007).

Tax Report and Letter 1127
Model Income Tax Convention Released by the Treasury on November 15, 2006.

Tax Report and Letter 1126
Material advisor rules

Tax Letter 1125
Letter to Hon. Eliot Spitzer on the importance of interpretive and explanatory tax regulations

Tax Report and Letter 1124
Differences in tax treatment of domestic and foreign partnerships

Tax Reports 2006

Tax Report and Letter 1123
Section 954(c)(6)’s exclusion from foreign personal holding company income status for certain payments made by a controlled foreign corporation.

Tax Report and Letter 1122
Responding to Notice 2006-14 which requested comments on certain changes to the regulations under Section 751(b) of the Code

Tax Report and Letter 1121
Authority of the Treasury Department and the IRS to issue regulations under the IRC

Tax Report and Letter 1120
“Zero Basis”

Tax Letter 1119
Two-step “A” reorganizations

Tax Report 1118
NY Innocent Spouse Relief

Tax Report and Letter 1117
“Stuckless” proposed regulations

Tax Report and Letter 1116
Section 4965

Tax Report 1115
Patenting Tax Strategies

Tax Report and Letter 1114
Concerning section 956 and partnerships.

Tax Report and Letter 1113
Report addressing limitation on benefits provisions in treaties and Section 1(h)(11) concerning the definition of “qualified foreign corporation,”

Tax Report and Letter 1112
Report addressing the issue of basis recovery in redemption transactions that are treated as dividend equivalent redemptions under Section 301 of the Code

Tax Report and Letter 1111
Report commenting on guidance to be proposed regarding tax consequences of appointing a family-owned trust company to serve as trustee of a trust for the benefit of family members

Tax Letter 1110
Report commenting on IRS Notice 2005-74 which addresses the effect of various common asset reorganizations on gain recognition agreements (“GRAs”)

Tax Report and Letter 1109
IRC §§6111 and 6112 material advisor rules to law and accounting firms

Tax Letter 1108
Letter dated May 1, 2006 from Kimberly S. Blanchard to Eric Solomon, Acting Deputy Assistant Secretary (Tax Policy), Department of the Treasury, Donald Korb, Chief Counsel, Internal Revenue Service, and Hon. Mark W. Everson, Commissioner, Internal Revenue Service, with suggested revisions to Circular 230 as it applies to written advice from tax practitioners.

Tax Report and Letter 1107
Report on Temporary Treasury Regulations Section 1.7874.1T which addresses the treatment of affiliate-owned stock for purposes of determining whether a foreign corporation is a surrogate foreign corporation under Section 7874

Tax Letter 1106
Letter dated March 17, 2006 from Kimberly S. Blanchard to Hon. Owen W. Johnson, Chair, New York State Senate Finance Committee, and Hon. Herman D. Farrell, Jr., Chair, New York State Assembly Ways and Means Committee, urging amendment to NYS Tax Law Section 1131(1), which currently imposes liability on all partners and members of LLCs for any unpaid sales taxes for such entities, together with reissuance of Report #1035 on Trust Fund Liability for Collection of Sales Tax.

Tax Report and Letter 1105
Report on proposed amendments to NY Tax Law Article 9-A regulations concerning the taxation of corporate partners

Tax Report and Letter 1104
Report on proposed regulations under section 409A of the IRC addressing compensation practices of businesses employing U.S. taxpayers

Tax Report and Letter 1103
Report on final, temporary and proposed Treasury Regulations issued under section 1446 of the IRC relating to the withholding by partnerships of U.S. tax on allocations of effectively-connected taxation income to foreign partners

Tax Report and Letter 1102
Report on proposed Treasury Regulations issued under sections 332, 351 and 368 of the IRC which provide rules regarding formation, reorganizations and liquidations involving insolvent corporations

Tax Report and Letter 1101
Report on Sections 362(e) and 334(b) of the IRC concerning basis adjustment rules for property transferred to a corporate recipient in a tax-free corporate reorganization or a Section 351 transaction, and also in the context of inbound subsidiary liquidations

Tax Reports 2005

Tax Report and Letter 1100
Proposed Dual Consolidated Loss Regulations

Tax Letter 1099
JOBS Act Straddle Amendments.

Tax Report and Letter 1098
Partnership Equity Received in Exchange for Services.

Tax Report and Letter 1097
JCT Proposal on SECA Taxation.

Tax Letter 1096
U.S. Branch Allocation of Interest Expense.

Tax Report and Letter 1095
Credit Default Swaps

Tax Report and Letter 1094
Proposed Regulations Regarding Cross-Border Mergers

Tax Letter 1093
Section 470 Legislation.

Tax Letter 1092
Offer in Compromise Legislation in Highway Bill (H.R. 3).

Tax Report and Letter 1091
Section 409A of the Internal Revenue Code and Internal Revenue Service Notice 2005-1.

Tax Report Letter and Appendix A B 1090
New York State Tax Issues Relating to Same-Sex Unions.

Tax Report and Letter 1089
Report on Proposed Regulations Dealing with “Predecessors” and “Successors” in Section 355(e).

Tax Report and Letter 1088
Report on Proposed Regulations Regarding Allocation of Basis Under Section 358.

Tax Report and Letter 1087
Report No. 1087 with respect to Section 965 and Notices 2005-10 and 2005-38.

Tax Report and Letter 1086
Regs. §1.367(a)-3(c).

Tax Report and Letter 1085
Disguised Sales of Partnership Interests Responding to Reg-149519-03.

Tax Report and Letter 1084
New York’s Nonresident Income Allocation Requirements: Analysis and Recommendations.

Tax Report and Letter 1083
Regulation Section 1.901-2(f)(3) and the Allocation of Foreign Taxes Among Related Persons.

Tax Report and Letter 1082
Effect of Mergers, Acquisitions and Dispositions on the Application of Code Section 965.

Tax Report and Letter 1081
Circular 230 Regulations.

Tax Report and Letter 1080
Report on Disclosure by Material Advisors.

Tax Report and Letter 1079
Proposed Regulations Regarding the Determination of a Shareholder’s “Pro Rata Share” Under Section 951.

Tax Report and Letter 1078
Remic IO Interests

Tax Report and Letter 1077
Proposed Regulations Regarding the Application to Partnerships of Section 1045 Gain Rollover Rules for Qualified Small Business Stock.

Tax Report and Letter 1076
Proposed Regulations under Section 752 Relating to the Allocation of Partnership Liabilities where a Disregarded Entity is an Obligor.

Tax Report and Letter 1075
Application of Section 6700 Penalties to Lawyers: The “Reason to Know” Standard

Tax Reports 2004

Tax Letter 1074
Internal Revenue Code Section 965

Tax Letter 1073
Filing Deadline for Material Advisors under Notice 2004-80

Tax Report and Letter 1072
Report on Proposed Regulations Regarding Continuity of Interest and Pre-Closing Stock Value Fluctuations.

Tax Report and Letter 1071
Report on Notice 2004-37.

Tax Report and Letter 1070
Source, “Effective Connection” of COD Income in Cross-Border Financings.

Tax Report and Letter 1069
Report on Temporary and Proposed Regulations Concerning Allocation of Creditable Foreign Tax Expenditures.

Tax Letter 1068
Senate JOBS Bill Amendments to Section 269

Tax Letter 1067
Proposed Amendments to Qualified Covered Call Rules.

Tax Report and Letter 1066
Definition of “Traded On An Established Market” Within The Meaning of Section 1273.

Tax Report and Letter 1065
Proposed New York State Tax Shelter Legislation.

Tax Report and Letter 1064
Report on Transfers of Assets or Stock Following a Corporate Reorganization.

Tax Letter 1063
Provisions of H.R. 4520 and S. 1637 Relating to the Taxation of Deferred Compensation.

Tax Report and Letter 1062
Report on Proposed Notional Principal Contract Regulations.

Tax Report and Letter 1061
Report on Temporary Regulations Section 1.368-2T Relating to “A” Reorganizations Involving Disregarded Entities.

Tax Report and Letter 1060
Distributions Following Tax-Free Reorganizations.

Tax Report and Letter 1059
Report on Capitalization of Expenses to Repair, Improve or Rehabilitate Tangible Property and Certain Transaction Costs.

Tax Report and Letters A & B 1058
The Governor’s 2004-2005 Budget Bill (Senate 6060/Assembly 9560)

Tax Report and Letter 1057
Proposed Amendments to Circular 230.

Tax Letter 1056
S. 1637 – JOBS Act -Tax Shelter Penalty Provisions.

Tax Letter 1055
H.R. 2896 – Tax Shelter Penalty Provisions

Tax Letter 1054
Proposed Regulations Relating to Notional Principal Contracts with Nonperiodic Payments (REG-166012-02).

Tax Report and Letter 1053
Proposed Regulations Section 1.988-6.

Tax Letter 1052
Revisions to the Confidentiality Provisions of the Tax Shelter Disclosure Regulations.

Tax Report and Letter 1051
Treatment of Variable Stock Consideration In Tax-Free Corporate Reorganizations.

Tax Report and Letter 1050
Continuity of Interest and Pre-Closing Stock Value Fluctuation

Tax Report and Letter 1049
Taxation of Partnership Interests Received for Services and Compensatory Partnership Options

Tax Report and Letter 1048
Proposed Regulations relating to Partnership Options and Convertible Securities

Tax Report and Letter 1047
New York’s Personal Income Tax Withholding Requirements: Analysis and Recommendations

Tax Report and Letter 1046
Section 355(e) “Non-Plan” Issues

Tax Report and Letter 1045
Proposed Regulations under Sections 168(k) and 1400L of the Internal Revenue Code Relating to Additional First Year Depreciation Allowances

Tax Reports 2003

Tax Report and Letter 1044
Proposed Regulations under Sections 421, 422 and 424 of the Internal Revenue Code.

Tax Report and Letter 1043
Reorganizations Involving Insolvent Subsidiaries.

Tax Report and Letter 1042
Treatment of Restricted Stock in Corporate Reorganization Transactions.

Tax Letter 1041
Senate Finance Hearings on tax shelters.

Tax Report and Letter 1040
Report No. 1040 and transmittal letter concerning Announcement 2003-35.

Tax Report 1039
American Jobs Creation Act of 2003

Tax Report and Letter 1038
Simplification of the IRC: Tax Exempt Bonds

Tax Report and Letters A, B, C and D 1037
Certain Legislative Proposals Relating to the Section 163(j) Earnings Stripping Rules.

Tax Report and Letter 1036
Dividend Provisions of the Jobs and Growth Tax Relief Reconciliation Act of 2003.

Tax Report and Letter 1035
Trust Fund Liability for Collection of Sales Tax

Tax Letter 1034
NYS Estimated Tax

Tax Report and Letter 1033
Potentially Abusive Tax Shelter Regulations

Tax Report Examples and Letters 1, 2, 3 and 4 1032
NYSBA Tax Section Summary Report on the Provisions of recent Senate Bills that would Codify the Economic Substance Doctrine plus Economic Substance Examples.

Tax Report and Letter 1031
Proposed Regulations regarding the treatment of expenditures made in connection with intangible assets.

Tax Report and Letters A, B and C 1030
Dividend Exclusion

Tax Report and Letter 1029
Loss Disallowance

Tax Report 1028
Comments on Issues Relating to Circular 230.

Tax Report and Letter 1027
Disguised Sales of Partnership Interests Reponding to Notice 2001-64.

Tax Report and Letters A, B and C 1026
Simplification of the Internal Revenue Code

Tax Report and Letter 1025
Report on Recent Tax Shelter Regulations

Tax Reports 2002

Tax Report and Letter 1024
Securitization Reform Measures

Tax Letter 1023
Proposed exceptions to the tax shelter disclosure requirements of Section 1.6011-4T.

Tax Report and Letter 1022
Taxation of Straight and Contingent Convertible Debt

Tax Report and Letter 1021
Comments on Proposed Regulations under Section 280G

Tax Report 1020
Temporary and proposed regulations interpreting Section 355(e) of the Code.

Tax Report and Letter 1 and 2 1019
Report No. 1019 and transmittal letters on pending tax shelter legislation.

Tax Report 1018
Comment on draft New York State proposed regulations relating to nexus implications of a non-resident corporation’s participation in a trade show in New York.

Tax Report and Letter 1017
Report number 1017 on the treatment of expenditures made in connection with acquiring, creating or enhancing intangible assets. Our report responds to a request for comments set forth in the advance notice of proposed rulemaking (the “Notice”) issued January 17, 2002, 67 Fed. Reg. 3461-02.

Tax Report and Letter 1016
Report No. 1016 responds to the request for comments made in Revenue Ruling 200 1-46, 2001-42 I.R.B. 321, dealing with multi-step acquisitions (the “Ruling”).

Tax Letter 1015
Support for passage of bill A.11750 which would conform New York State income tax filing date with the federal date.

Tax Report and Letter 1014
Outbound Inversion Transactions.

Tax Report 1013
Treasury/IRS business plan for 2002-2003.

Tax Letter 1012
Treasury’s Plan to Combat Abusive Tax Avoidance Transactions.

Tax Letter 1011
Legislation Regarding Conversion of an S Corp to a Partnership.

Tax Report and Letter 1010
The effect on the international provisions of the Internal Revenue Code of defining “statutory” mergers and consolidations under Section 368(a)(1)(A) to include those effected under foreign law.

Tax Letter 1009
Regarding the circumstances in which a corporate partner will be regarded as engaged in an active trade or business for purposes of Section 355(b) on account of the partner’s ownership of an interest in the partnership (guidance supplementing Rev. Rul. 92-17).

Tax Letter 1008
Letter regarding the effective date of Rev. Proc. 2002-13

Tax Report and Letter 1007
Simplification of the Internal Revenue Code

Tax Report and Letter 1006
Section 411(d)(6) of the Internal Revenue Code

Tax Report and Letter 1005
Taxation of Partnership Options and Convertible Securities.

Tax Report and Letter 1004
Comments on the Treasury Department’s Proposed Regulations Section 1.894-1(d)(2)(ii)-(iv), addressing “Reverse Hybrid Entities” under Internal Revenue Code Section 894 governing the taxation of domestic and foreign taxpayers affected by governing tax treaties.

Tax Report and Letter 1003
Critique of the Treasury Department’s Subpart F Study.

Tax Report and Letter 1002
Report commenting upon New York City’s taxation of shareholders of corporations that have elected S corporation treatment for federal (and perhaps New York State) income tax purposes and particularly as to proposed regulations governing Internal Revenue Code section 338 (h)(10) elections.

Tax Reports 2001

Tax Report and Letter 1001
“Report Responding to Notice 2001-44 on the Timing of Income and Loss from Swaps Providing for Contingent Payments” Proposed method for timing of income inclusions and deductions from notational principal contracts (“swaps”) that call for contingent payments (“contingent swaps”).

Tax Report and Letter 1000
Report on deductibility of punitive damages comparing conflicting goals of providing deterrence of wrongful conduct and the application of the Federal income tax to net income.

Tax Report 999
Letter to Congressional Tax Writing Leaders commenting upon pending Tax Shelter deterrent legislation.

Tax Report 998
Letter to Treasury Officials commenting upon modifications to Temporary Regulations governing tax shelter disclosure, registration and listing requirements.

Tax Report and Letter 997
The Straddle Rules under Internal Revenue Code Sections 1092 and 263(g) would (i) provide rules for determining when and into what property certain interest and carrying costs incurred in connection with straddle positions must be capitalized; (ii) provide that certain asset-linked debt instruments may constitute straddle positions and (iii) modify the exception to the straddle rules for “qualified covered call” options. The report discusses each of these issues but focuses its principal attention on the capitalization regime under Code section 263(g).

Tax Report and Letter 996
Analyzes objectives and ramifications of proposed bill that would exclude first $1,000 of capital gains each year, permit deduction of 50% of net capital gains above exclusion amount, shorten long-term holding period to six months, increase deduction of capital losses against ordinary income from $3,000 to $10,000 and index exclusion of gain on sale of principal residence. 7/20/01 report 8/23/01 letter

Tax Report and Letter 995
Comments upon proposed Treasury Regulations amending Circular 230 governing practice before the Treasury Department and the Internal Revenue Service. July 25, 2001.

Tax Report and Letter 994
Report and Transmittal Letter suggesting improvements to the Passive Foreign Investment Company Regulations to prevent the inadvertent classification of foreign corporations engaged in the conduct of active businesses as PFICs. May 22, 2001.

Tax Report 993
Letter to New York City Department of Finance commenting favorably upon the draft Statement of Audit Procedures designed to eliminate the automatic assertion of penalties in all cases where deficiencies are asserted. Dated May 21, 2001

Tax Report 992
Letter to Congress commenting upon HR656 and S 336 permitting taxpayers with average receipts of less than $5 million to use the cash method of accounting even where inventories and receivables are involved. The Tax Section applauds the simplification achieved but expresses concern that the legislation not provide a path to “game” the system through tax avoiding timing of purchases, sales, payments and receipts. Dated April 27, 2001.

Tax Report and Letter 991
Comments on Revised Proposed Treasury Regulations Section 1.355-7, implementing Code Section 355(e). Dated April 10, 2001.

Tax Report and Letter 990
Prepaid Forward Contracts — Taxation of parties to contracts calling for the delivery of property at a specified future date, with payment for that purchase being made at the time of contract. Dated March 26, 2001

Tax Report 989
Letter urging Congress to provide full funding for the Internal Revenue Service to enable it to perform all its essential functions, including adequate audit coverage Dated March 2, 2001.

Tax Letter 988
Letter expressing the Tax Section’s concern with the significant reduction in recent years in the audit rate by the Internal Revenue Service and the reduction in the overall number of Revenue Agents and Tax Auditors.

Tax Letter 987
Tax Fairness Act – Robert H. Scarborough Dated January 23, 2001.

Tax Report 986
Letter dated January 16, 2001 to Hon. Stuart L. Brown, Chief Counsel, Internal Revenue Service and Eric Solomon, Esq., Deputy Assistant Secretary (Tax Policy), Treasury Department, from Robert H. Scarborough regarding Business Plan for 2001

Tax Reports 2000

Tax Section Letter 963
Letter on Business Plan for 2000.

Tax Section Letter 964
Letter on Derivatives Transactions in Corporate Stock.

Tax Section Report 965
Report on Proposed “Straddle” Legislation.

Tax Section Report 966
Report on Proposed Legislation to Amend Section 357.

Tax Section Report 968
Report on Treas. Reg. Sec. 1.355-7.

Tax Section Report 969
Report on Regulations that Define a “Statutory” Merger or Consolidation Under Section 368(a)(1)(A).

Tax Section Letter 970
Joint State/City Power of Attorney.

Tax Section Letter and Report 971
Report on Arbitration Procedure for Appeals — Announcement 2000-4.

Tax Section Letter 972
Letter on Temporary and Proposed Regulations (T.D. 8872) on Asset Transfers for a C Corporation to, or the Qualification of a C Corporation as, a Regulated Investment Company or a Real Estate Investment Trust.

Tax Section Letter and Report 973
Report on Proposed Regulations Relating to Financial Asset Securitization Investment Trusts.

Tax Section Letter and Report 974
Report on Proposed Entity Classification Regulations.

Tax Section Letter 975
Letter Regarding New York State Assembly Bill 8518-A and Senate Bill 5671-A on Offers in Compromise.

Tax Section Letter and Report 976
Report on Proposals Regarding Transfers of REMIC and FASIT Residual Interests.

Tax Section Letter and Report 977
Report on the Treasury’s Proposal to Codify the Economic Substance Doctrine.

Tax Section Letter and Report 978
Report on Possible Revisions to Circular 230 Dealing with Standards of Practice Applicable to Tax Shelter Transactions.

Tax Section Letter 979
Report on Corporate Tax Shelters; Proposed Section 6662A of the Internal Revenue Code.

Tax Section Letter 980
Report on Allocation of Partnership Nonrecourse Liabilities.

Tax Section Letter 981
Letter on New York State Proposed Legislation on Publication Requirement for Certain Charitable Organizations.

Tax Section Letter and Report 982
Report on Tax Shelter Regulations.

Tax Section Letter 983
Letter on Conformity of Federal, State and City Offers in Compromise Statutes.

Tax Section Letter and Report 984
Letter Regarding Possible Reforms to Section 83.

Tax Section Letter 985
Proposed Repeal of the New York State Resident/Nonresident Partnership Allocation Regulations.

Tax Reports 1999

Tax Section Letter 943
Letter on Senate Bill 2358 Amending Active Trade or Business Requirement of Section 355(b)(2)(A).

Tax Section Report 944
Report on Proposed Legislation to Amend Section 357.

Tax Section Report 945
Draft Technical Services Bureau Memorandum on Application of Mortgage Recording Tax to Commercial Credit Line Mortgages.

Tax Section Report 946
Draft Amendments to UBT and GCT Rules.

Tax Section Letter 947
Letter on Maximum Capital Gains Rate.

Tax Section Report 949
Report on Proposed Amendments to Regulations on Effect of Administrative Expenses on Marital and Charitable Deductions.

Tax Section Report 950
Report on Corporate Tax Shelters.

Tax Section Report 951
Report on Fast Pay Arrangements Under Prop. Treas. Reg. Sec. 1.7701(l)-3.

Tax Section Report 952
Report on Proposed Legislation to Re-Impose Tax on S Corporation ESOPs and Report on Certain Tax Accounting Provisions in the Administration’s Revenue Proposals for the Fiscal Year 2000 Budget

Tax Section Letter 953
Letter on Year 2000 Budget, Tracking Stock Proposals.

Tax Section Report 954
Report on Section 1032.

Tax Section Report 955
Report on Proposed Amendments to the Market Discount Rules of Sections 1276 – 1278; Report on Proposed Modification of Tax Provisions Related to Debt for Debt Exchanges; Report on Certain Proposals Relating to Foreign Activities of U.S. Taxpayers.

Tax Section Report 956
Report on Certain Tax Shelter Provisions.

Tax Section Report 957
Report on Legislative Proposals Relating to REITs.

Tax Section Report 958
Report on Control Test of Section 368(c).

Tax Section Report 959
Report on Constructive Ownership Bill.

Tax Section Letter 960
Letter on Relief to Joint Return Files Under New York State Tax Law.

Tax Section Letter 961
Letter on Commuter Tax Repeal.

Tax Section Letter 962
Letter on Commuter Tax Repeal.

Tax Reports 1998

Tax Section Letter 918
Letter on Proposed Part 2392, Reasonable Cause Basis for Cancelling Penalties.

Tax Section Report 919
Report on Proposed Regulations on Public Disclosure of Material Relating to Tax-Exempt Organizations.

Tax Section Letter 920
Letter on Suggested Inclusions in the Treasury Department’s 1998 Business Plan.

Tax Section Report 921
Report on Recent Developments Regarding Worker Classification with Revised Proposals for Reform.

Tax Section Letter 922
Letter on “Distribution of Control” Requirement Under Section 355.

Tax Section Report 923
Report on Foreign Trusts.

Tax Section Report 924
Report on Availability of Foreign Tax Credits Under Notice 98-5.

Tax Section Report 925
Report on Nonqualified Preferred Stock Under the Taxpayer Relief Act of 1997.

Tax Section Letter 926
Letter on Proposed Regulations on Global Dealing Operations.

Tax Section Report 927
Report on Hybrid Branch Arrangements Under Notice 98-11.

Tax Section Report 928
Report on Notional Principal Contract Character and Timing Issues.

Tax Section Report 929
Report on the Imposition of U.S. Withholding Tax on Substitute and Derivative Dividend Payments Received by Foreign Persons.

Tax Section Letter 930
Letter on IRS Restructuring and Reform Bill of 1998 (H.R. 2676).

Tax Section Report 931
Report on Administration Expenses and the Estate Tax Deduction for Charitable and Marital Bequests.

Tax Section Report 932
Report on Conforming Rev. Proc. 77-27 and Rev. Proc. 86-42 to the New Continuity Regulations.

Tax Section Report 933
Report on Constructive Ownership Provisions of H.R. 3170.

Tax Section Report 934
Report on Proposed Amendments to Rules Relating to the New York City Real Property Transfer Tax.

Tax Section Report 935
Report on Reorganizations Involving Disregarded Entities.

Tax Section Report 936
Tax Section Annual Report.

Tax Section Report 937
Report on Proposed Regulations Concerning Qualified Subchapter S Subsidiaries.

Tax Section Report 938
Report on Regulations Concerning the Application of Section 382 to Consolidated Groups.

Tax Section Report 939
Save the Cumulative Bulletin.

Tax Section Letter 940
Letter on Notice 98-38 Regarding Separate Return Limitation Year (SRLY) Rules.

Tax Section Letter 941
Letter on Burden of Proof in Tax Cases.

Tax Section Report 942
Report on Section 355(e).

Tax Reports 1997

Tax Section Report 891
Suggestions for Review of New York Nonresident Audit Guidelines.

Tax Section Report 892
Report is on suggested FASIT Regulations.

Tax Section Report 893
Report on Proposed Regulations Under Code Section 467.

Tax Section Report 894
Report on Section 514(c)(9) Concerning Investment Trusts in Leveraged Real Estate Partnerships by Pension Trusts and Other Qualified Organizations.

Tax Section Letter 895
Letter on Transitional Relief for Certain of the Tax Law Changes Proposed by the President’s 1998 Budget.

Tax Section Report 896
Report on Proposed Regulations on the Definition of Limited Partner for Self-Employment Tax Purposes Under Section 1402.

Tax Section Report 897
Report on Proposed Regulations Relating to a Special Preferred Stock QEF Election.

Tax Section Report 898
Report on Proposed Regulations on Treatment of Stock Rights Under Sections 354, 355 and 356 of the Internal Revenue Code.

Tax Section Letter 899
Letter Suggesting Possible Additions to the Treasury’s 1997 Business Plan.

Tax Section Letter 900
Letter on Proposed Legislation to Impose Tax on Morris Trust Transactions.

Tax Section Report 901
Constructive Sale Provisions and Amendments to Section 351 in H.R. 846.

Tax Section Report 902
Report on Proposed Regulations on Continuity of Shareholder Interest.

Tax Section Letter 903
Letter on Proposed Regulations on Documentation of Claim for Foreign Tax Credit.

Tax Section Report 904
Comments on Simplification Proposals Announced by the Treasury Department on April 14, 1997.

Tax Section Letter 905
Letter on Tax Basis Indexation of Assets for Inflation.

Tax Section Report 906
Report on Section 355 Relating to Morris Trust Transactions and the Revenue Reconciliation Bill of 1997.

Tax Section Report 907
Report on Proposed Regulations Addressing the Remote Continuity and Continuity of Business Enterprise Requirements.

Tax Section Letter 908
Letter on “Gross Up” Provisions in Debt Obligations and Contingent Payment Debt Under Section 1275 of the Code.

Tax Section Letter 910
Letter on Legislation on New York S Corporations.

Tax Section Letter 911
Letter on Legislation Relating to Dual Resident Taxpayers.

Tax Section Report 912
Report on the National Commission on Restructuring the Internal Revenue Service.

Tax Section Report 913
Report on Proposed Regulations for New York State Offers in Compromise.

Tax Section Report 914
Report on Regulations Relating to Withholding on U.S. Source Investment Income Paid to Fiscally Transparent Entities Under Section 894.

Tax Section Letter 915
Letter on Proposal to Shift Burden of Proof from Taxpayers to the Internal Revenue Service.

Tax Section Report 916
Report on Proposed Regulations on Treatment of Payments Made to U.S. Persons Directly or Indirectly from a Trust of Which a Foreigner is a Grantor.

Tax Section Report 917
Report Recommending Adoption of a New York State and City Franchise Tax Exemption for Corporate Offshore Investment Vehicles.

Tax Reports 1996

Tax Section Letter 860

Letter on 1996 Business Plan.

Tax Section Report 861

Materials from New York State and City Tax Institute.

Tax Section Letter 862

Letter on Administration’s 1995 Tax Proposal to Expand Subpart F Provisions on Income from Notional Principal Contracts and Stock Lending Transactions.

Tax Section Report 863

Report on Temporary and Proposed Regulations on Transactions Involving Stock of the Common Parent of a Consolidated Group (Treas. Reg. Sec. 1.1502-13T(f)(6)).

Tax Section Report 864

Request for Guidance on the Application of New York’s Sales and Use Tax to Out-of-State Vendors.

Tax Section Report 865

Duplicative Taxation of Multistate Residents.

Tax Section Report 866

Tax Section Annual Report.

Tax Section Report 867

Report on Stripped Coupons in Securitization Transactions.

Tax Section Report 868

Report on Short Against the Box Transactions.

Tax Section Letter 869

Letter on Location of Proceedings of the New York State Tax Appeals Tribunal and Division of Tax Appeals.

Tax Section Letter 870

Letter on Proposed Amendments to Code Section 1374.

Tax Section Letter 871

Letter on S. 942, Small Business Regulatory Enforcement Fairness Act of 1996.

Tax Section Letter 872

Letter Objecting to the Effective Date Provisions in the 1997 Fiscal Year Budget.

Tax Section Report 873

Report on Temporary and Proposed Regulations Under Treas. Reg. Sec. 1.367(a)-3T.

Tax Section Letter 874

Letter on the Social Security Domestic Employee Reform Act of 1994.

Tax Section Report 875

Report on Proposed Regulations Under Sections 3121(v) and 3306(r).

Tax Section Letter 876

Letter on Hedging Rules for Consolidated Groups.

Tax Section Report 877

Report on Announcement Regarding Lease Stripping Transactions.

Tax Section Letter 878

Letter on Proposed Reforms to the New York City Unincorporated Business Tax.

Tax Section Report 879

Report on Proposed Regulations Relating to Treas. Reg. Sec. 1.882-5 and Section 884, the Branch Profits Tax and the Branch Level Withholding Tax.

Tax Section Report 880

Statement Before the House Ways and Means Committee on Employment Classification Issues.

Tax Section Report 881

Report on the Treatment of Exchanges of Warrants in Reorganization Transactions.

Tax Section Report 882

Report on Proposed Check the Box Regulations.

Tax Section Letter 883

Letter on Simplification of Section 367 Regulations.

Tax Section Report 884

Report on Proposed Withholding Tax Regulations.

Tax Section Report 885

Report on Post-Reorganization Continuity of Interest.

Tax Section Report 886

Report on Proposed Regulations Relating to Amortizable Bond Premium and Bond Issuance Premium.

Tax Section Report 887

Report on Priorities for Guidance on Recent Legislation Affecting Employee Benefits Plans.

Tax Section Report 888

Report on Proposed Regulations on the Allocation of Loss on the Disposition of Stock and Other Personal Property.

Tax Section Letter 889

Letter on Elimination of the SRLY Regulations.

Tax Section Letter 890

Letter on Proposed Mark-to-Market Accounting by Securities Dealers.

Tax Reports 1995

Tax Section Report 817
Report on Certain Issues Under Code Section 108(c).

Tax Section Report 818
Report on Issues Under Section 197.

Tax Section Report 819
Comments on Proposed New York Estates, Powers and Trusts Law Amendment.

Tax Section Letter 820
Letter on Legislative Restrictions on Tax Regulations.

Tax Section Letter 821
Letter on Tax Basis Indexing Provisions of H.R. 9.

Tax Section Report 822
Report on “Excess Principal Amount” of Securities Under Section 356.

Tax Section Report 823
Report on Notice 94-93 (Inversion Transactions) and Rev. Proc. 94-76 (Downstream Reorganizations).

Tax Section Report 824
Memorandum to NYSBA Executive Committee on Contract with America Indexation Hearings.

Tax Section Letter 825
Letter on Moratorium on State Regulations.

Tax Section Report 826
Comments on Proposed Appeals Mediation Procedure in Announcement 95-2.

Tax Section Report 827
Report on Governor’s 1995-1996 Budget Proposal.

Tax Section Letter 828
Letter on Substantiation of Charitable Contributions Under Code Section 170(f)(8).

Tax Section Report 829
Annual Report of the Tax Section.

Tax Section Letter 830
Letter in Opposition to Federal Regulatory Moratorium on Partnership Anti-Abuse Regulations.

Tax Section Report 831
Proposed Legislation on the Taxation of Expatriation.

Tax Section Report 832
Burden of Proof in Tax Cases.

Tax Section Report 833
Sales Tax on Out-of-State Vendors: Report on Proposed Consumer and Main Street Protection Act of 1995.

Tax Section Report 834
Report on Proposed Regulations Concerning the Tax Treatment of Contingent Payment Debt Instruments.

Tax Section Letter 835
Letter on New York City Unincorporated Business Tax Reform.

Tax Section Letter 836
Letter Urging the Senate Finance Committee to Approve the Income Tax Treaties and Protocols with Canada, France, Kazakhstan, Mexico, Sweden and Ukraine.

Tax Section Letter 837
Letter on Proposed Amendment to Rules Relating to the New York City Real Property Transfer Tax.

Tax Section Report 838
Report on Prop. Treas. Reg. Sec. 1.469-9 Relating to the Application of the Passive Loss Rules to Certain Rental Real Estate Activities.

Tax Section Report 839
Report on Proposed Legislation on Expatriation and Foreign Trusts.

Tax Section Letter 840
Letter on New York State Regulatory Reform.

Tax Section Letter 841
Letter on Proposed Reforms to the New York City Unincorporated Business Tax.

Tax Section Report 842
Report on Proposed Regulations Regarding Private Activity Bonds.

Tax Section Report 843
Report on Code Section 956A.

Tax Section Report 844
Report on Proposed Regulations Defining Publicly Traded Partnerships.

Tax Section Report 845
Report on “Check the Box” Entity Classification System in Notice 95-14.

Tax Section Report 846
Report on Regulations Under Sections 358, 1032 and 1502 Concerning Stock Basis Adjustments in Triangular Reorganizations.

Tax Section Report 847
Report on Proposed Regulations Under Sections 704 and 737.

Tax Section Letter 848
Letter on Legislation Limiting Retroactive Regulations.

Tax Section Letter 849
Letter on Large Partnership Simplification Proposal.

Tax Section Letter 850
Letter on Taxation of Extraordinary Dividends — Proposed Amendments to Code Section 1059.

Tax Section Report 851
Report on Proposed Regulations Section 1.1092(d)-2.

Tax Section Report 852
Report on Proposed Reforms to Administration and Enforcement of Employment Tax and Income Taxes on Individual Workers.

Tax Section Report 853
Taxation of U.S. Stock Gains of Foreign Shareholders and Limitation on Treaty Benefit Provisions.

Tax Section Letter 854
Letter on Limitation on State Taxation of Retirement Income.

Tax Section Report 855
Report on Temporary and Proposed Regulations Regarding Deductibility, Substantiation and Disclosure of Certain Charitable Contributions.

Tax Section Report 856
Comments on Proposed Regulations Relating to Self-Employment Tax Treatment of LLC Members.

Tax Section Report 857
Technical Comments on the Administration’s December 1995 Tax Proposals.

Tax Section Report 858
New York State and New York City Tax Proposals Regarding Attribution of Noninterest Expense.

Tax Section Letter 859
Letter on Rev. Rul. 95-69.

Tax Reports 1994

Tax Section Report 777
Suggestion on Priorities for 1994 IRS Business Plan.

Tax Section Report 778
Report on Regulations Under Sections 163(j) and 7701(l).

Tax Section Report 779
Report on Proposed Regulations Regarding Modification of Debt Instruments.

Tax Section Letter 780
Letter on Proposed Franchise Tax Regulation Relating to Commodity Investment Partnerships.

Tax Section Report 781
Report on Section 475 Mark to Market Regulations.

Tax Section Report 782
Report on Proposed and Temporary Regulations on Character and Timing of Gains and Losses from Hedging Transactions.

Tax Section Report 783
Report on Proposed Regulations Under Section 162(m).

Tax Section Report 784
Tax Section Annual Report.

Tax Section Report 785
Report on Proposed Qualified Electing Fund Election Under Section 1295(a).

Tax Section Report 786
Report on Governor’s 1994-1995 Budget Proposal.

Tax Section Report 787
Report on Business Plan: Assumption of Contingent Liabilities in Asset Acquisitions.

Tax Section Report 788
Report on OID Anti-Abuse Rule.

Tax Section Letter 789
Letter on Business Plan: Substitute Payments in Securities Lending Transactions.

Tax Section Report 790
Report on Treas. Reg. Sec. 1.704-3T and Certain Other Section 704(c) Matters.

Tax Section Report 791
Report on Proposed Amendments to New York State Real Property Transfer Tax and Gains Tax Regulations.

Tax Section Report 792
Report on Proposed Amendments to the Rules of Practice and Procedure of the Division of Tax Appeals.

Tax Section Report 793
Report on Proposed Financial Asset Securitization Investment Trusts (“FASIT”) Legislation.

Tax Section Report 794
Report on Proposed Regulations Under Section 6662(e) of the Internal Revenue Code Relating to the Accuracy-Related Penalty Applicable to Certain Section 482 Adjustments.

Tax Section Letter 795
Letter on Limited Liability Companies Under New York State Law.

Tax Section Letter 796
Letter on New York City Unincorporated Business Tax Reform, Senate Bill No. 1226-B, Assembly Bill No. 8828-A.

Tax Section Report 797
Report on Partnership Anti-Abuse Regulation.

Tax Section Report 798
Report on Final Original Issue Discount Regulations.

Tax Section Letter 799
Letter on New York Nonresident Audit Guidelines.

Tax Section Letter 800
Letter on Tax Policy Study.

Tax Section Letter 801
Letter on Introduction 417 on Conformity Between New York State and City Tax Systems.

Tax Section Letter 802
Letter on State/Federal Conformity in Trust Classification.

Tax Section Report 803
Draft Technical Comments on GATT Revenue Provision Taxing Partnership Distributions of Marketable Securities.

Tax Section Letter 804
Letter on Mediation of Unagreed Audit Cases.

Tax Section Report 805
Report on Business Plan: Yoc Heating Following Section 338 Qualified Stock Purchase.

Tax Section Report 806
Report on Notice 94-46 Under Section 367(a).

Tax Section Letter 807
Letter on 1995 Priorities.

Tax Section Report 808
Report on Prop. Treas. Reg. Sec. 1.305-5 Relating to Constructive Distributions on Preferred Stock.

Tax Section Report 809
Report on the Conformity of New York’s Revised Limited Partnership Act to the R.U.L.P.A. for Purposes of Entity Classification Under Treas. Reg. Sec. 301.7701-2.

Tax Section Letter 810
Letter on Tax Issues for Professional LLCs and LLPs.

Tax Section Report 811
Report on Uniform Self-Employment Tax Treatment of Owners of Interests in Pass-Through Entities.

Tax Section Report 812
Report on Large Partnership Provisions of the 1993 Tax Simplification and Technical Corrections Bill.

Tax Section Report 813
Report on Proposed Intercompany Transaction Consolidated Return Regulations.

Tax Section Report 814
Report on Proposed Conduit Financing Regulations Under Section 7701(l) of the Code.

Tax Section Letter 815
Letter on Application of Proposed Moratorium on Tax Regulations.

Tax Section Report 816
Report on Proposed Amendments to the Rules of Practice and Procedure of the Division of Tax Appeals.

Tax Reports 1993

Tax Section Report 745
Report on Benefit Issues in Mergers and Acquisitions.

Tax Section Letter 746
Letter on Location of New York State Tax Tribunal Hearings.

Tax Section Letter 747
Letter on Proposed Amendments to Circular 230.

Tax Section Report 748
Report on New York Tax Treatment of Limited Liability Companies.

Tax Section Report 749
Comments on Amendments to the Rules Relating to New York City Commercial Rent or Occupancy Tax.

Tax Section Report 750
Report on Regulations to be Issued Under Section 246(c) Restricting the Dividends Received Deduction.

Tax Section Report 751
Report on Proposed Section 382 Option Attribution Rules.

Tax Section Report 752
Use of Partnerships to Circumvent Repeal of General Utilities Doctrine: Report on Proposed Regulations Implementing Notice 89-37.

Tax Section Report 753
Report on New York City Unincorporated Business Tax.

Tax Section Report 754
Tax Section Annual Report.

Tax Section Report 755
Report on Governor’s 1993-1994 Budget Proposals.

Tax Section Letter 756
Letter on Unincorporated Business Tax.

Tax Section Report 757
Report on Generation-Skipping Transfer Tax.

Tax Section Report 758
Report on Proposed Treasury Regulation Section 1.514(c)-2 (Fractions Rule).

Tax Section Letter 759
Letter on H.R. 13 Anti-Deferral Legislation.

Tax Section Letter 760
Letter on New York State and City Tax Treatment of Limited Liability Companies.

Tax Section Letter 761
Letter on Unincorporated Business Tax Legislation.

Tax Section Letter 762
Letter on Effect of Newark Morning Ledger on Proposed Legislation on Amortization of Intangibles.

Tax Section Letter 763
Letter on Draft LLC Tax Legislation.

Tax Section Letter 764
Letter on Limited Liability Companies under New York State Law.

Tax Section Letter 765
Letter on Repeal of the Stock-for-Debt Exception.

Tax Section Report 766
Report on Certain Issues Relating to Troubled Partnerships.

Tax Section Report 767
Report on Proposed Original Issue Discount Regulations.

Tax Section Report 768
Report on Proposed Section 382(l)(5) Regulations.

Tax Section Report 769
Report on Revenue Reconciliation Bill of 1993: Provisions Affecting the Taxation of Capital Gains, Provisions Affecting International Business, and Compensation-Related Provisions.

Tax Section Report 770
Report on Proposed Section 1502 Regulations Concerning Consolidated Return Investment Adjustments.

Tax Section Report 771
Recommended Guidance Relating to $1 Million Limitation on Deductible Compensation Under Section 162(m).

Tax Section Report 772
Report on Proposed Amendment to Rules on the New York City Real Property Transfer Tax.

Tax Section Report 773
Valuation of a Loss Corporation Under Section 382.

Tax Section Report 774
Report on Definition of Subsidiary Under New York State Tax Law.

Tax Section Report 775
Report on Treatment of Contingent Debt Instruments Under Prop. Reg. Sec. 1.1275-4.

Tax Section Report 776A
Report on February 17, 1993 Residency Audit Guidelines: Practical Experience and Suggested Changes.

Tax Section Report 776B
Report on Proposed Regulation Section 1.704-3 Relating to Allocations Under Section 704(c) of the Internal Revenue Code.

Tax Reports 1992

Tax Section Report 705
Report on Proposed Regulations on Methods of Accounting for Notional Principal Contracts.

Tax Section Letter 706
Letter to President Bush in Opposition to Moratorium on Regulations.

Tax Section Report 707
Report on Proposed Section 367(a) and (b) Regulations.

Tax Section Letter 708
Letter on Effect of Pledge of Stock on Ownership Changes Under Section 382.

Tax Section Report 709
Report on Researching New York State and New York City Tax Law.

Tax Section Memorandum Report 710
Memorandum in Opposition to Proposal to Index Capital Gains for Inflation by Regulation.

Tax Section Letter 711
Letter on Repeal of Section 1275(a)(4).

Tax Section Report 712
Opposition to Denial of Interest on Tax Refunds for the Period Between the Date the Tax Was Paid and the Date the Refund Was Claimed (Section 3103 of H.R. 4287).

Tax Section Report 713
Tax Section Annual Report.

Tax Section Report 714
Proposed Regulations on Capitalization of Interest Costs Under Code Section 263A.

Tax Section Report 715
Report on the Proposed Real Estate Mortgage Investment Conduit Regulations.

Tax Section Report 716
Report on Section 304(b)(4).

Tax Section Letter 717
Letter on Section 5803 of H.R. 4210: Prospective Application of Temporary and Proposed Regulations.

Tax Section Report 718
Comments on Proposed Regulations Under Section 338.

Tax Section Report 719
Department of Taxation’s Uniform Procedure Bill.

Tax Section Report 720
Estate and Gift Tax Conformity and Technical Corrections Bill.

Tax Section Report 721
Opposition to Proposed Modification to Section 7430 to Impose Personal Liability on Employees of the IRS.

Tax Section Report 722
Nexus and State Taxation of Partnerships and Corporate Partners: Proposed Amendments to Sections 11-03, 11-04 and 11-06 of Title 19 to the New York City General Corporation Tax Rules.

Tax Section Report 723
Coordination of Deferred Intercompany Transaction Rules with Nonrecognition Provisions.

Tax Section Report 724
Report on Proposed Treasury Regulations Section 1.1504-4 (Definition of “Affiliated Group”).

Tax Section Report 725

Report on Proposed Regulations on Certain Payments Made Pursuant to Securities Lending Transactions.

Tax Section Letter 726

Letter in Support of Establishment of a Functioning Tribunal for New York City Taxes.

Tax Section Letter 727

Supplemental Letter on Proposed Amendments to Sections 11-03, 11-04 and 11-06 of Title 19 of the New York City General Corporation Tax Rules.

Tax Section Letter 728

Letter in Opposition to Proposed Repeal of Stock-for-Debt Exception to COD Income.

Tax Section Letter 729

Letter in Support of Proposed Regulation Defining “Activity” for Purposes of the Passive Activity Loss Rules.

Tax Section Report 730

Report on Escrow Accounts, Settlement Funds and Similar Arrangements Governed by Section 468B(g) of the Internal Revenue Code.

Tax Section Report 731

Comments on Notice 92-12 Regarding Regulations Projects that Should Remain Open.

Tax Section Report 732

New York City Tax Tribunal.

Tax Section Report 733

Report on Proposed Regulations Section 1.882-5.

Tax Section Report 734

Report on the “Bank Loan” Exception to the Portfolio Interest Rules.

Tax Section Report 735

Capital Gains Indexation by Regulation.

Tax Section Report 736

Report on Creation of Federal Right to Contribution/Declaratory Judgment for Section 6672 Liability.

Tax Section Report 737

Report on Final and Proposed Treasury Regulations Under Section 988.

Tax Section Report 738

Comments on Proposed Section 382 and Cost Sharing Regulations.

Tax Section Report 739

Report on Exempt Organization Inurement Issues in the Context of G.C.M. 39862.

Tax Section Letter 740

Letter in Opposition to the Effective Date Repeal of the “30-Day Rule” of Treas. Reg. Sec. 1.1502-76(b)(5).

Tax Section Report 741

Report on Proposed Amendments to Rules Relating to the New York City Commercial Rent or Occupancy Tax.

Tax Section Report 742

Report on Section 597 Proposed Regulations.

Tax Section Letter 743

Letter on Effective Dates of Proposed OID Regulations.

Tax Section Report 744

Report on Audit Guidelines and Regulations Governing New York State Residency Audits.

Tax Reports 1991

Tax Section Report 677
NYS Governor’s Bill on Credit for Income Taxes of Other States and Business Facility Tax Credit.

Tax Section Report 678
Current Issues in the Federal Income Tax Treatment of Regulated Investment Companies.

Tax Section Report 679
Suggested Bankruptcy Tax Revenue Rulings.

Tax Section Report 680
Request for Guidance on the Application of Arkansas Best.

Tax Section Letter 681
Letter on Itemized Deductions for New York State and City Income Taxes.

Tax Section Report 682
Modified Loss Disallowance Regulations of Treas. Reg. Sec. 1.1502-20.

Tax Section Report 683
Objection to Decision to Stop Civil Tax Trial Hearings in New York.

Tax Section Report 684
Report on Subchapter S One Class of Stock Proposed Regulations.

Tax Section Report 685
Comments on Tax Proposals in Governor’s 1991 Budget.

Tax Section Report 686
Provisions of the Revenue Reconciliation Act of 1990 Affecting Debt-for-Debt Exchanges.

Tax Section Report 687
Report on Notice 90-41 and Certain Other Issues Arising Under Section 514(c)(9) of the Internal Revenue Code Relating to Debt-Financed Real Estate Investments by Tax-Exempt Organizations.

Tax Section Report 688
Report on Unrelated Business Income Taxation of Income from Interest Rate Swaps and Similar Instruments.

Tax Section Report 689
Proposed Section 1275 Regulations Concerning Contingent Payment Debt Instruments.

Tax Section Report 690
Classification of COD Income Under the New York Franchise Tax as Subsidiary, Investment or Business Income.

Tax Section Report 691
Report on Section 6621(c) Providing for Increased Interest Rate on Large Corporate Deficiencies and Temp. Treas. Reg. Sec. 301.6621-3T.

Tax Section Report 692
Treatment of Cancellation of Debt Income Under the New York City General Corporation Tax.

Tax Section Report 693
Acquisitions of Discount Debt by Related Parties Under the New Section 108(e)(4) Regulations.

Tax Section Report 694
Proposed Technical Corrections Act Amendment to Section 1445(e)(3) (FIRPTA Withholding on Corporate Distributions).

Tax Section Report 695
Report on Regulations to be Issued Under Section 305(c).

Tax Section Report 696
Report on Proposed Treasury Regulations Under Section 108(e)(8)(A) (“Nominal or Token” Stock).

Tax Section Report 697
New York City Tax Appeals Tribunal.

Tax Section Report 698
Report on Proposed Regulations Relating to the Accuracy Related Penalty.

Tax Section Report 699
Application of the New York State 10% Tax on Gains Derived from Certain Real Property Transfers to Transfers Involving Interests in Troubled Real Estate.

Tax Section Report 700
Proposed Legislation on Amortization of Intangibles.

Tax Section Report 701
Report on Proposed Regulations Under Section 163(j).

Tax Section Report 702
Report on Proposed Section 707 Regulations Concerning Disguised Sales of Property Through Partnerships.

Tax Section Report 703
Report on Proposed Regulations Under Treas. Reg. Sections 1.1502-15, -21 and -22.

Tax Section Report 704
Report on Section 336(e).

Tax Reports 1990

Tax Section Report 639
Report on the National Court of Tax Appeals.

Tax Section Report 640
Report on Simplification of Section 752 Regulations.

Tax Section Report 641
Report on Proposed and Temporary Regulations Relating to Reporting of Treaty-Based Return Positions.

Tax Section Report 642
Report on Section 216(e) of the Internal Revenue Code.

Tax Section Letter 643
Letter on New York State Taxation of Corporate Limited Partners.

Tax Section Letter 644
Letter on Legislation Concerning New York City Tax Tribunal.

Tax Section Report 645
Report on Built-in Gains and the Investment Adjustment Rules in the Consolidated Return Regulations.

Tax Section Letter 646
Letter on Issuance of Advance Rulings by New York City Department of Finance.

Tax Section Report 647
Tax Section Annual Report.

Tax Section Report 648
Report on Proposed Rule Relating to the Definition and Responsibilities of a “Vendor” Under the New York State Sales and Use Tax Law.

Tax Section Letter 649
Letter on the Department of Finance Proposal to Conform the City Tax Tribunal Procedures to Those of the State.

Tax Section Report 650
Report on Section 163(j) of the Internal Revenue Code.

Tax Section Report 651
Proposed Rules on Minimum Continuing Legal Education for Attorneys.

Tax Section Report 652
1990 New York State Budget Bills.

Tax Section Report 653
Report on Department of Taxation and Finance’s Uniform Procedure Bill.

Tax Section Letter 654
Letter Requesting Treasury to Delay Effective Date of Loss Disallowance Rule in T.D. 8294 (Treas. Reg. Sec. 1502-20T).

Tax Section Letter 655
Letter on Simplification of the Internal Revenue Code.

Tax Section Report 656
Report on Section 988 Temporary Regulations.

Tax Section Report 657
Treas. Reg. Sec. 1.1502-20T.

Tax Section Report 658
Department of Taxation and Finance Technical Corrections Bill on Venue for Tax Crimes (S. 5945, A. 8693).

Tax Section Report 659
Statement Regarding the March 22, 1990 “Discussion Draft” Bill Proposing the Repeal of Section 2036(c) and the Replacement Thereof by a New Chapter 14.

Tax Section Report 660
Venue of Criminal Prosecution for Tax Crimes Alleged Under Article 37 of the New York State Tax Law.

Tax Section Report 661
Report on Proposed Amendments to the New York City Real Property Transfer Tax Regulations.

Tax Section Report 662
Report on Inflation Adjustments to the Basis of Capital Assets.

Tax Section Report 663
Report on Proposed and Temporary Regulations Under Section 367(e).

Tax Section Report 664
Report on Proposed Amendments to the New York State Real Property Transfer and Gains Tax Regulations.

Tax Section Report 665
Report on Section 1031 Proposed Treasury Regulations Relating to Deferred Like-Kind Exchanges.

Tax Section Report 666
Proposed Private Letter Rulings.

Tax Section Report 667
Report on Proposed Regulations Relating to Qualified Plan Nondiscrimination Requirements.

Tax Section Report 668
Opposition of the NYSBA to the Budget Summit Agreement to Deny Deductions for Interest Paid by Corporations on Federal Income Tax Deficiencies.

Tax Section Report 669
Estate Freeze Legislation.

Tax Section Report 670
Budget Reconciliation Bill on Restructuring of Troubled Corporations.

Tax Section Report 671
Report on the Federal Income Tax Treatment of Contingent Liabilities in Taxable Asset Acquisition Transactions.

Tax Section Report 672
Report on Section 1031 Proposed Treasury Regulations on Exchanges of Personal and Multiple Properties.

Tax Section Report 673
Report on Proposed Regulations Relating to Economic Performance Requirements of Section 461(h).

Tax Section Report 674
Report on the Role of Section 338 Consistency Rules After the Repeal of the General Utilities Doctrine.

Tax Section Report 675
Report on Proposed Treasury Regulations Under Sections 269 and 382.

Tax Section Report 676
Report on Proposed Amendments to the New York City General Corporation Tax Regulations on Investment Capital and Investment Income.

Tax Reports 1989

Tax Section Report 600

Report on Temporary and Proposed Regulations Under Sections 897(d) and (e) and Certain Related Provisions.

Tax Section Report 601

Tax Section Annual Report.

Tax Section Report 602

Report on Draft Proposed Regulations on Investment Capital Under the New York Corporate Franchise Tax (Article 9-A).

Tax Section Report 603

Report on Temporary Section 954 and 957 Regulations on Definitions of Controlled Foreign Corporation, Foreign Base Company Income, and Foreign Personal Holding Company Income.

Tax Section Report 604

Report on 1989 Budget Bills Relating to S. 2447/ A. 3647 and S. 2458/ A. 3658.

Tax Section Report 605

Report on Temporary Section 954 and 957 Regulations on Definitions of a Controlled Foreign Corporation, Foreign Base Company Income, and Foreign Personal Holding Company Income.

Tax Section Letter 606

Report on 1989 Budget Related to Procedural Matters and Corporate Taxes.

Tax Section Letter 607

Letter on Proposed New York State 1989 Budget Bill to Amend the Sales Tax Law.

Tax Section Report 608

Report on the Application of Corporate Alternative Minimum Tax in Bankruptcy Settings.

Tax Section Letter 609

Letter on Draft Bill on Treatment of Mergers, Consolidations and Acquisitions.

Tax Section Report 610

Report on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.

Tax Section Report 611

Report on New York City Proposed Regulations Relating to the Filing of Income and Expense Statements for Real Property.

Tax Section Report 612

Report on the 1988 Proposed Lobbying Regulations Affecting Charities.

Tax Section Report 613

Report on Legislative Proposals for the Establishment of a New York City Tax Appeals Tribunal.

Tax Section Report 614

Report on the 1989 Budget Act Provisions Relating to Corporate Mergers and Acquisitions.

Tax Section Report 615

Report on the “Same Desk” Rule Under P.L.R. 8614060.

Tax Section Letter 616

Letter Supporting Adoption of Section 11 of Departmental Bill No. 5R-89 to Authorize the Commissioner of Finance to Appeal Adverse Determinations of the State Tax Appeals Tribunal.

Tax Section Letter 617

Letter on New York City 1990 Executive Budget Revenue Proposals.

Tax Section Letter 618

Letter Proposing Changes to Treasury Regulations to Correlate with Expected Changes in Securities Law Regulations Relating to Offerings of Securities Abroad.

Tax Section Letter 619

Letter on New York State Department of Taxation and Finance 1989 Legislative Proposal No. 1 Regarding Procedural Rules for State Taxes.

Tax Section Report 620

Report on Allocation of Partnership Debt Regulations.

Tax Section Report 621

Report on Notice 88-130 Concerning the Determination of Reissuance and Retirement of Tax Exempt Obligations Under Sections 103 and 141-150 of the Code.

Tax Section Report 622

Report on New York State Department of Taxation and Finance’s Uniform Procedure Bill.

Tax Section Report 623

Report on Proposed Amendments to Rules of Practice and Procedure of the United States Tax Court.

Tax Section Letter 624

Letter on New York City Conformity to New York State Tax Law.

Tax Section Report 625

Report on Sanctions Imposed by the Section 89 Qualification Rules.

Tax Section Report 626

Report on the Second Installment of Temporary and Proposed Regulations Under Section 469.

Tax Section Report 627

Report on Certain Provisions of the Revenue Reconciliation Act of 1989.

Tax Section Report 628

Report on New York State Taxation of Corporate Limited Partners.

Tax Section Report 629

Report on the 1989 Proposed Regulations Relating to Golden Parachute Payments.

Tax Section Report 630

Report on Tax Accounting for Notional Principal Contracts.

Tax Section Letter 631

Letter on Disparity Between Salaries Paid to Attorneys in the Private Sector and Federal Government Service.

Tax Section Report 632

Report on Proposed Regulations on the Issuance of Bearer Form Debt Obligations.

Tax Section Letter 633

Letter on Certain Provisions of the Revenue Reconciliation Bill of 1989 Opposing the Amendment of Section 163 of the Code.

Tax Section Report 634

Report on Notice 89-37 Regarding the Use of Partnerships to Avoid the Repeal of the General Utilities Doctrine.

Tax Section Letter 635

Letter on Rules of Procedure of the New York City Tax Appeals Tribunal.

Tax Section Report 636

Report on Temporary and Proposed Regulations Relating to Arbitrage Restrictions on Tax-Exempt Bonds.

Tax Section Report 637

Report on Modification of Ruling Procedures and Other Taxpayer Guidance Programs.

Tax Section Report 638

Report on Proposals for Treasury Regulations Under Section 337(d) Relating to Section 355 Distributions.

Tax Reports 1988

Tax Section Report 577

Report on New York State Department of Taxation and Finance’s Uniform Procedure Study Bill.

Tax Section Report 578

Report on Qualified Nonrecourse Financing — Selected Issues to be Addressed in Regulations.

Tax Section Report 579

Supplemental Report on Section 382.

Tax Section Report 580

Tax Section Annual Report.

Tax Section Report 581

Report on Proposed Amendments to Tax Court Rules for Partnership Actions.

Tax Section Report 582

Report on the Omnibus Taxpayer Bill of Rights.

Tax Section Report 583

Report on Issues Concerning the Definition of Publicly Traded Partnerships.

Tax Section Report 584

Report on the Taxation of Shareholder Rights Plans (Poison Pills).

Tax Section Report 585

Preliminary Report on Temporary and Proposed Regulations Under Section 469.

Tax Section Report 586

Report on Jurisdiction of the United State Tax Court.

Tax Section Report 587

Report on Regulation S.

Tax Section Report 588

Report on IRS Advance Notice 87-69 Regarding Private Activity Bonds.

Tax Section Report 589

Report on Temporary and Proposed Regulations Under Section 892 of the Code.

Tax Section Report 590

Report on Combined Reporting for New York Corporate Franchise Tax Purposes.

Tax Section Report 591

Report on Administrative Adjudication of Disputes Involving New York City Taxes: Tax Tribunal Proposals.

Tax Section Report 592

Report on Service Contracts for Qualifying Facilities.

Tax Section Letter 593

Letter on Child Care Credit.

Tax Section Report 594

Report on Developing Country Debt/Equity Swaps.

Tax Section Report 595

Report on Proposed Amendments to the Real Property Transfer Tax Regulations.

Tax Section Report 596

Report on Temporary Branch Profits Tax Regulations.

Tax Section Report 597

Report on Temporary Section 861 Regulations on Allocation of Interest and Other Expense.

Tax Section Report 598

Report on Section 1446 of the Internal Revenue Code.

Tax Section Report 599

Report on Federal Income Tax Treatment of Real Estate Mortgage Investment Conduits.

Tax Reports 1987

Tax Section Report 554

Report on the Branch Profits Tax.

Tax Section Report 555

Report on Proposed Original Issue Discount Regulations.

Tax Section Report 556

Report on Treas. Reg. Sec. 35a.9999-5(f) Relating to the Repeal of the 30% Withholding Tax on Interest.

Tax Section Letter 557

Letter on Physical Location of the Tax Tribunal Offices.

Tax Section Report 558

Report on Proposed Modification of Circular 230.

Tax Section Report 559

Summary Responses to Survey of Members of the Executive Committee of the NYSBA Tax Section on Priority Issues for Providing Taxpayer Guidance.

Tax Section Report 560

Report on Proposed Amendments to New York State Tax Law in Response to the 1986 Federal Tax Law.

Tax Section Report 561

Tax Section Annual Report.

Tax Section Letter 562

Letter on Application of Criminal Sanctions to Persons Found Guilty of Tax Evasion or Crimes Relating to Internal Revenue Laws.

Tax Section Report 563

Comments on Proposed Lobbying Regulations Affecting Charities.

Tax Section Report 564

Report on Issues Concerning Treatment of Master Limited Partnerships for Federal Income Tax Purposes.

Tax Section Report 565

Report on Tax Tribunal Legislation and Proposed Regulations.

Tax Section Report 566

Report on Proposals to Amend New York Corporate Taxation.

Tax Section Report 567

Branch Profits Tax — Additional Issues to be Addressed in Regulations.

Tax Section Report 568

Comments on Proposed Regulations Concerning the Corporate Alternative Minimum Tax Book Income Adjustment.

Tax Section Report 569

Report on the New York City Unincorporated Business Tax.

Tax Section Report 570

Comments on Section 469(k)(3).

Tax Section Report 571

Report on Advance Notice 87-4 Relating to Interest Rate Swaps.

Tax Section Report 572

Report on the Override of U.S. Tax Treaty Provisions by Amendments to the Internal Revenue Code.

Tax Section Report 573

Report on the Proposed Regulations Under Section 163 of the Code Regarding the Allocation of Interest Expense.

Tax Section Report 574

Report on Proposed Regulations Relating to the Allocation of Interest and Other Expenses for Foreign Tax Credit and Certain Other Purposes.

Tax Section Report 575

Report on Civil Tax Penalties.

Tax Section Report 576

Report on Tracking Stock Arrangements.

Tax Reports 1986

Tax Section Report 513

Report on Proposed and Temporary Regulations Under Section 1092.

Tax Section Report 514

Comments on the Foreign Tax Credit Reform Proposal in the President’s Tax Proposals to Congress for Fairness, Growth and Simplicity.

Tax Section Report 515

Report on Effective Dates of Tax Reform Legislation.

Tax Section Letter 516

Letter Supporting Legislation that Would Allow Shareholders of New York Professional Service Corporations to Pay State Income Taxes on the Same Basis as Unincorporated Professionals and Other Residents in New York State.

Tax Section Letter 517

Cover Letter for Report on the Alternative Minimum Tax.

Tax Section Report 518

Report on the Individual Alternative Minimum Tax of the Tax Reform Act of 1985.

Tax Section Letter 519

Letter on Revenue Rulings 86-7 and 86-8 Regarding Section 1256 Contracts.

Tax Section Report 520

Tax Section Annual Report.

Tax Section Report 521

Comments on S. 1974 and H.R. 3980 Prohibiting State Taxation on a Worldwide Unitary Basis.

Tax Section Report 522

Report on H.R. 3838 Provisions Relating to General Utilities Repeal.

Tax Section Report 523

Report on Miscellaneous Corporate Provisions of H.R. 3838.

Tax Section Letter 524

Letter in Opposition to a Proposed Federal Amnesty Program.

Tax Section Report 525

Comments on Proposed Interstate Sales and Use Taxation Act of 1986.

Tax Section Report 526

Report on Net Operating Loss Provisions of H.R. 3838.

Tax Section Report 527

Technical Comments on Senate Finance Committee Version of H.R. 3838.

Tax Section Letter 528

Letter on Investments in Tax-Exempt Obligations.

Tax Section Report 529

Report on the Proposed Foreign Corporation Branch Level Tax.

Tax Section Report 530

Comments on Section 802(e) of H.R. 3838 Regarding the Deductibility of Interest Paid by Financial Institutions Acquiring Qualified Tax-Exempt Obligations.

Tax Section Report 531

Recommendation Regarding New York State’s Response to Federal Tax Reform.

Tax Section Report 532

Supplemental Report on the Proposed Foreign Corporation Branch Level Tax.

Tax Section Report 533

Report on Proposed Disallowance of Deductions for Interest Paid to Certain Related Foreign Parties.

Tax Section Report 534

Technical Comments on the Tax Reform Act of 1986 Relating to the Personal Income Tax.

Tax Section Report 535

Comments on Modifications to the Accelerated Cost Recovery System, the Repeal of the Investment Credit and the Related Effective Dates and Transition Rules in the Tax Reform Act of 1986.

Tax Section Report 536

Report on Insurance Provisions of H.R. 3838.

Tax Section Letter 537

Letter on Proposed Amendments to the System for Administrative Resolution of New York Tax Controversies.

Tax Section Report 538

Report on Certain Corporate Provisions of H.R. 3838.

Tax Section Report 539

Book Income Preference Under the Alternative Minimum Tax.

Tax Section Report 540

Report on a Legislative Proposal on the Federal Tax Treatment of Certain Transactions Involving Listed Option Contracts.

Tax Section Letter 541

Letter on a Proposed Bill to Deny Tax-Exempt Status to Organizations that Perform, Finance or Provide Facilities for Abortions.

Tax Section Letter 542

Letter Supporting the Passive Loss Provisions in the Senate Bill.

Tax Section Letter 543

Letter Reconfirming Strong Opposition to Section 984 of the Senate Amendments to H.R. 3838 that Would Disallow Certain Deductions for Interest Paid to Related Foreign Parties that are Exempt from U.S. Income Tax.

Tax Section Report 544

Report on New York City Department of Finance Proposal Relating to Unincorporated Business Tax.

Tax Section Letter 544B

Letter on Income Inclusion Upon Transfer or License of Intangibles to Related Possessions Corporations and Foreign Corporations

Tax Section Report 545

Effect of the 1986 Act on Business and Investment Activities of Individuals.

Tax Section Report 546

Effect of the 1986 Act on Dispositions of Wealth and Compliance Rules.

Tax Section Report 547

Effect of the 1986 Act on Qualified Retirement Plans.

Tax Section Report 548

Effect of the 1986 Act on Corporate Acquisitions.

Tax Section Report 549

Effect of the 1986 on the Corporate Tax Base.

Tax Section Report 550

Effect of the 1986 Act on Foreign Activities of U.S. Taxpayers and Foreign Taxpayers.

Tax Section Letter 551

Letter on Providing State Legislatures with Federal Tax Data.

Tax Section Report 551B

Statement on Proposal to Extend the New York City Real Property Transfer Tax to Certain Transfers of Controlling Interests in Corporations, Partnerships, Trusts and Other Entities and to Certain Transfers of Stock in Cooperative Housing Corporations.

Tax Section Report 552

Report on Mirror Subsidiaries and a Related Technique.

Tax Section Letter 553

Letter in Further Support of the Recommendation in the Report on Mirror Subsidiaries and a Related Technique.

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Guidelines for the Preparation of Tax Section Reports

Tax Section Report Participation Policy