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Tax Section Report and Cover 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 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 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 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 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 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
