The ABA Tax Section has submitted a flurry of comments and testimony to the House, Senate, and IRS:
- Comments on Guidance Concerning the Temporary Dividends Received Deduction for Reinvestment of Foreign Earnings in the United States (§ 965) (51 pages) (4/19)
- Comments on Treatment of Amounts Required to be Capitalized in Certain Transactions to which Treas. Reg. § 1.263(a)-5 Applies (12 pages) (4/15)
- Comments on Distribution Restrictions of § 409A (25 pages) (4/15)
- Comments on § 409A Regarding its Impact on Business Transactions (17 pages) (4/15)
- Comments on § 409A Regarding Funding Issues (10 pages) (4/15)
- Testimony before Subcommittee on Oversight, House Ways and Means Committee (4 pages) (4/14)
- Letter on IRS Funding to Senate (2 pages) (4/14)
- Letter on IRS Funding to House (2 pages) (4/14)



