|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 Report and Letter 1003 |
Critique of the Treasury Department's Subpart F Study.
|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 1005 |
Taxation of Partnership Options and Convertible Securities.
|Tax Report and Letter 1006 |
Section 411(d)(6) of the Internal Revenue Code
|Tax Report and Letter 1007 |
Simplification of the Internal Revenue Code
|Tax Letter 1008 |
Letter regarding the effective date of Rev. Proc. 2002-13
|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 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 1011 |
Legislation Regarding Conversion of an S Corp to a Partnership.
|Tax Letter 1012 |
Treasury's Plan to Combat Abusive Tax Avoidance Transactions.
|Tax Report 1013 |
Treasury/IRS business plan for 2002-2003.
|Tax Report and Letter 1014 |
Outbound Inversion Transactions.
|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 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 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 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 1019 |
Report No. 1019 and transmittal letters on pending tax shelter legislation.
|Tax Report 1020 |
Temporary and proposed regulations interpreting Section 355(e) of the Code.
|Tax Report and Letter 1021 |
Comments on Proposed Regulations under Section 280G
|Tax Report and Letter 1022 |
Taxation of Straight and Contingent Convertible Debt
|Tax Letter 1023 |
Proposed exceptions to the tax shelter disclosure requirements of Section 1.6011-4T.
|Tax Report and Letter 1024 |
Securitization Reform Measures