2012 Reports

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 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."