Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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Burke on Repairing Inside Basis Adjustments
Karen C. Burke (San Diego) has published Repairing Inside Basis Adjustments, 58 Tax Law. 639 (2005). Here is the abstract: Optional basis adjustments under Subchapter K have come under increased scrutiny as a result of tax shelter abuses involving partnerships. Recent legislation requires mandatory adjustments under sections 734(b) and 743(b) upon certain distributions of partnership…
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NYSBA Submits Report to IRS on Proposed Regs on Cross-Border Mergers
The New York State Bar Association Tax Section has submitted a report to the IRS on Proposed Regulations on Cross-Border Mergers: Letter from Chair (David B. Hariton) (3 pages) Report No. 1094 (33 pages)
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NYSBA Submits Letter to Congress on Section 470 and Partnership Leasing Transactions
The New York State Bar Association Tax Section has submitted a 16-page letter to the Senate Finance Committee and House Ways & Means Committee on Section 470 and partnership leasing transactions.
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NYSBA Submits Letter to Congress on Offer in Compromise Legislation
The New York State Bar Association Tax Section has submitted an 11-page letter to the Senate Finance Committee and House Ways & Means Committee on the Offer in Compromise Legislation in Highway Bill (H.R. 3).
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NYSBA Submits Report to IRS on Deferred Compensation and Notice 2005-1
The New York State Bar Association Tax Section has submitted a report to the IRS on Section 409A of the Internal Revenue Code and Internal Revenue Service Notice 2005-1: Letter from Chair (David B. Hariton) (3 pages) Report No. 1091 (40 pages)
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ABA Real Property, Probate & Trust Section Proposes Amendments to § 6166
The Business Planning Group of the ABA Section on Real Property, Probate & Trust Law has proposed various amendments to § 6166, which allows closely-held businesses to defer payment of estate tax. The proposal is based on this survey of its members. Executive Summary Report
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ABA Tax Section Submits Comments to IRS on Notice 2005-14 and § 199, Income Attributable to Domestic Production Activities
The ABA Tax Section has submitted comments to the IRS on Notice 2005-14 and § 199, Income Attributable to Domestic Production Activities
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ABA Honors Loretta Collins Argrett
The ABA Commission on Women in the Profession has announced that long-time tax lawyer Loretta Collins Argrett is the winner of a 2005 Margaret Brent Women Lawyers of Achievement Award. The award will be presented at the Women’s Commission’s 15th Annual Margaret Brent Award Luncheon in Chicago on Sunday, August 7, 2005, in conjunction with…
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NYSBA Tax Section Issues Report on New York Tax Issues Relating to Same-Sex Unions
The New York State Bar Association Tax Section has submitted a report on New York State tax issues relating to same-sex unions: Letter from Chair (David B. Hariton) (1 page) Report No. 1090 (51 pages): In New York State, active consideration is being given to legislation that would extend to same-sex couples the opportunity to…
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NYSBA Tax Section Submits Report to IRS on Proposed § 355(e) Regs
The New York State Bar Association Tax Section has submitted a report to the IRS on the proposed regulations dealing with "predecessors" and "successors" in § 355(e) : Letter from Chair (David B. Hariton) (2 pages) Report No. 1089 (25 pages): This report, prepared by the Corporations Committee of the NYSBA Tax Section, comments on…
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NYSBA Submits Comments to IRS on Proposed Regs on Allocation of Basis Under § 358
The New York State Bar Association Tax Section has submitted a report to the IRS on the proposed regulations regarding the allocation of basis under § 358. : Letter from Chair (David B. Hariton) (3 pages) Report No. 1088 (52 pages): This Report of the NYSBA Tax Section comments on Proposed Regulations under § 358…
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NYSBA Tax Section Submits Reports to IRS
The New York State Bar Association Tax Section has submitted several reports to the IRS: Disguised Sales of Partnership Interests (No. 1085) (4/22) Letter (2 pages) Report (30 pages) Reg. §1.367(a)-3(c) (No. 1086) (4/26) Letter (3 pages) Report (22 pages) Section 965 and Notices 2005-10 and 2005-38 (No. 1087) (5/25) Letter (4 pages) Report (32…
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ABA Tax Section Submits Comments to IRS
The ABA Tax Section has submitted four sets of comments to the IRS: Application of § 409A to Transactions Involving Partnerships (26 pages) (5/20) Transition Rule and Effective Date Under § 409A (20 pages) (5/20) Deferral Elections Under § 409A (25 pages) (5/20) Proposed Regulations Regarding the Effect of Pre-Closing Changes in Acquiring Corporation Stock…
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ABA Tax Section Concludes May Meeting Today in Washington, D.C.
The ABA Tax Section concludes its 3-day May meeting today at the Grand Hyatt Hotel (1000 H Street NW ) in Washington, D.C. Of particular interest to Tax Profs today is the Individual Income Tax Program (9:00 – 11:00 am): Chair: Mona Hymel (Arizona) 9:10 – 10:10 am: Simplification Efforts and the Report of…
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ABA Tax Section Continues May Meeting Today in Washington, D.C.
The ABA Tax Section continues its 3-day May meeting today at the Grand Hyatt Hotel (1000 H Street NW ) in Washington, D.C. There are two programs today of particular interest to Tax Profs: 2:30 – 4:00 pm: Calling All Adjuncts, sponsored by the Teaching Taxation Committee Chair: Evelyn Brody (Chicago-Kent) Moderator: Ellen P.…
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ABA Tax Section Kicks Off 3-Day May Meeting Today in Washington, D.C.
The ABA Tax Section kicks off its 3-day May meeting today at the Grand Hyatt Hotel (1000 H Street NW ) in Washington, D.C. For the full list of today’s programs, see here. Today’s event of particular interest to Tax Profs is the annual Woodworth Lecture and Reception from 5:00 – 7:00 pm. Uber Tax…
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ABA Tax Section Submits Comments to IRS
The ABA Tax Section has submitted two sets of comments to the IRS: Recommendations for 2005-2006 Guidance Priority Plan (5 pages) (4/29) Comments on Notice 2003-65 Concerning Section 382(h) Built-In Gains and Losses (32 pages) (4/29)
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NYSBA Submits Report to NYS Tax Department on Nonresident Income Allocations
The New York State Bar Association Tax Section has submitted a report to the New York State Tax Department on New York’s Nonresident Income Allocation Requirements: Analysis and Recommendations: Letter from Chair (David B. Hariton) (2 pages) Report No. 1084 (20 pages): On September 17, 2004 the New York State Department of Taxation and Finance…
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NYSBA Tax Section Submits Report to IRS on Allocation of Foreign Taxes Among Related Persons
The New York State Bar Association Tax Section has submitted a report to the IRS on Regulation § 1.901-2(f)(3) and the Allocation of Foreign Taxes Among Related Persons: Letter from Chair (David B. Hariton) (3 pages) Report No. 1083 (46 pages): This report discusses issues pertinent to the regulation project that has been announced by…
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NYSBA Submits Report to IRS on Disguised Sales of Partnership Interests
The New York State Bar Association Tax Section has submitted a report to the IRS on Disguised Sales of Partnership Interests Responding to Reg-149519-03 Letter from Chair (David B. Hariton) (2 pages) Report No. 1085 (30 pages): This report responds to a Notice of Proposed Rulemaking (REG-149519-03) relating to the treatment of transactions between a…
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ABA Tax Section Submits Comments & Testimony
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…
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ABA Tax Section Hosts 2-Day Tax Planning Conference in London
The ABA Tax Section and the International Bar Association Taxes Committee co-host their fifth annual conference, Tax Planning Strategies—U.S. and Europe, today and tomorrow in London. Topics include disclosure, structured finance, post-acquisition restructuring, and tax harmonization. For the full program, see here.
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ABA Tax Section Offers Teleconference & Webcast Today on Buy-Sell AGreements for LLCs and S Corporations
The ABA Tax Section offers a telconference and webcast today on Buy-Sell Agreements for LLCs and S Corporations as part of its "Last Wednesday" CLE series from 1:00–2:30 p.m. EST: Buy-sell agreements among co-owners or present and future owners of a closely-held business are intended to ensure the smooth future transition of its ownership. They…
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ABA Real Property, Probate & Trust Section Conducts § 6166 Survey
The Business Planning Group of the ABA Section on Real Property, Probate & Trust Law is sponsoring a survey on the effectiveness of § 6166, which allows closely-held businesses to defer payment of estate tax. The Section will use the results of the survey in formulating recommendations for reform. For the preliminary survey results on…
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ABA Sponsors Student Writing Contest in Real Property, Probate & Trust Law
The ABA Section on Real Property, Probate & Trust Law is again sponsoring the Jacques T. Schlenger Student Writing Contest: To enter, submit an essay on a current topic dealing with real property, probate, or trust law. “Real property, probate and trust law” is a broad category containing numerous practice disciplines. Without attempting to define…