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 and Letter 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