Tax Section Reports 2014

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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 Report 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. 

Click here to view the Master Index of NYSBA Tax Section Reports.