Paul L. Caron
Dean
Pepperdine Caruso
School of Law
NYSBA Tax Section
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New Report by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released a new report, Report Number 1525 on Notice 2025-63: [The Report comments] on Notice 2025-63 (the “Notice”), issued by the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) on October 23, 2025. The Notice announces the intention of Treasury and
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released three new reports concerning (1) the 2026-2027 New York State Executive Budget, (2) Section 355 Private Letter Ruling Policies, and (3) Proposed Updates to the Internal Revenue Service Voluntary Disclosure Practice:
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New Report by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released a new report (Report Number 1521) concerning final and proposed Treasury regulations under section 892. Those regulations concern the taxation of certain investments in the United States by foreign government and were published late last year. From the report:
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released two new reports concerning (1) various issues arising under section 704(c)(1)(A) and (2) IRS Notice 2025-72, which addressed the repeal of section 898(c), The Report provides comments and certain recommendations of the Tax Section regarding section 704(c)(1)(A) of the Internal Revenue Code, which governs
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released three new reports concerning (1) the “signing date rule” found in the Treasury Regulations describing the continuity of interest requirement for tax-free reorganizations under section 368, (2) the impact of section 68 and its cap on the availability of itemized deductions for taxpayers in
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Report On Tax Implications Of Cryptocurrency And Other Fungible Digital Assets
New York State Bar Association Tax Section, Report on Cryptocurrency and Other Fungible Assets (Apr. 18, 2022): In recent years, the market for digital assets has evolved in dramatic ways, including exponential growth in both the aggregate value of digital assets and the volume of transactions in digital assets as well as the broad adoption
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Report On Tax Implications Of Cryptocurrency And Other Fungible Digital Assets
New York State Bar Association Tax Section, Report on Cryptocurrency and Other Fungible Assets (Apr. 18, 2022): In recent years, the market for digital assets has evolved in dramatic ways, including exponential growth in both the aggregate value of digital assets and the volume of transactions in digital assets as well as the broad adoption
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ABA, NYSBA Propose Estate & Gift Tax Reforms
The ABA Tax Section has submitted estate, gift, and generation-skipping transfer tax reform ideas (55 pages) to the House Ways & Means Committee and Senate Finance Committee in the following ten categories: Need for Predictability and Stability in Federal Transfer Tax System Unification of the Federal Estate and Gift Tax Exclusion Amounts Portability of the
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NYSBA Tax Section Panel: Tax Reform — What’s All the Noise About?
Several Tax Profs spoke at yesterday's NYSBA Tax Section Annual Meeting on a panel on Tax Reform: What’s All the Noise About?: Steven A. Dean (Brooklyn) (Panel Chair) Joseph Bankman (Stanford) Michael Graetz (Columbia) Stephen Shay (Harvard)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Making IRS Regulations More Effective, Less Burdensome (No. 1244) The IRS’s 2011-12 Guidance Priority List (No. 1243) Tax Relief for Disaster-Related Efforts (No. 1242)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Property Acquired From a Decedent and 2010 GST Transfers (No. 1241) Rev. Rul. 99-6 and the Sale of All of a Partnership’s Equity (No. 1240) Section 1058 and Securities Loans (No. 1239) Notice 2010-49 and the <5% Shareholder Rule in Section 382 (No.
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Nonresident Audit Guidelines of the State of New York (No. 1233) The International Tax Competitiveness Act of 2011 (No. 1232) Section 901(m) (No. 1231) Claiming Worthlessness for a Failed Subsidiary Within a Condolidated Group (No. 1230) Characterizing “Overlap” Transactions Under Subchapter C (No.
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Notice 2010-60 (No. 1224) (Nov. 16, 2010) Section 909 (No. 1223) (Nov. 8, 2010) Section 367(d) (No. 1222) (Oct. 12, 2010) Net Investment Income Under Medicare (No. 1221) (Sept. 29, 2010) Securities Partnerships and Subchapter K (No. 1220) (Sept. 29, 2010)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Partnership Target Allocations (No. 1219) Employment Taxes and Professional Service Businesses (No. 1218) Section 514: Debt-Financed Income Subject to UBIT (No. 1217) The Rescission Doctrine (No. 1216) Recommendations for 2010-11 Tax Guidance Priority List (No. 1215) Guidance Under U.S. Income Tax Treaties
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NYSBA Tax Section Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: New York State Budget Revenue Proposals (No. 1206) New York State Budget Proposal to Modify Taxation of Resident Trusts (No. 1205) Estimated Tax Consequences of Roth IRAs (No. 1204)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Proposed Changes to New York Statute of Limitations on Unpaid Tax Liabilities (No. 1203) Section 704(c) and Partnership Mergers, Divisions and Tiered Partnerships (No. 1202) Proposed § 706 Regs on Varying Partnership Interests (No. 1201) Tax Relief for Haiti Relief Efforts (No. 1200) Foreign Account
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: The Treatment of Fluctuations in Value under § 382(l)(3)(C) (No. 1198) Administration Proposals on Deferral of Deductions Related To Deferred Foreign Income, Foreign Tax Credit Pooling, and Entity Classification (No. 1197)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Temporary Suspension of AHYDO Rules Under § 163(e)(5)(F)(i) (No. 1196) Announcement 2008-115 on FIRPTA Treatment of Rights Granted by a Governmental Unit (No. 1195) Reports on Transactions with Foreign Financial Agencies (FBARs) (No. 1194) Nonqualified Deferred Compensation Under § 457A (No. 1193) Temporary Regulations
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Qualified Intermediary and Related Withholding and Information Reporting Legislation Proposed by the Administration (No. 1089) Proposed Modifications to § 6662 Penalty in America's Affordable Health Choices Act of 2009 (No. 1090) Temporary and Proposed Regulations Regarding All-Cash Acquisitive D Reorganizations (No. 1091)
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Residency Rules for Student Housing (No. 1187) Application of Anti-Conduit Regulations to Hybrid Entities and Instruments (No. 1188)
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WSJ: IRS Uses FBAR to Get Tougher on Offshore Tax Evaders
Wall Street Journal: IRS Gets Tougher on Offshore Tax Evaders, by Laura Sanders: The IRS has stepped up scrutiny of offshore accounts and foreign income, an enforcement campaign that could sweep up tens of thousands of taxpayers. … The IRS is using a once-obscure tax form called the Foreign Bank Account Report, or FBAR, to
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NYSBA Releases Tax Reports
The New York State Bar Association Tax Section has issued tax reports on: Proposed § 108(e)(8) and § 721 Regs on Partnership Debt-for-Equity Exchanges (No. 1184) Recommendations for 2009-2010 Tax Guidance Priority List (No. 1185)
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NYSBA: Tax Issues Faced by Investors in Ponzi Schemes
The New York State Bar Association Tax Section yesterday released a report on Tax Issues Confronting Private Foundation Investors in Ponzi Schemes and Other Frauds.(No. 1183): Bernard L. Madoff … [has] admitted to defrauding investors out of upwards of $65 billion. Although the Madoff fraud has been the main focus of the press and tax commentary, foundations need guidance
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NYSBA: Report on Cancellation of Indebtedness and AHYDO Rules
The New York State Bar Association Tax Section has released a Report on the Cancellation of Indebtedness and AHYDO Rules of §§ 108(i) and 163(e)(5)(F) (No. 1182): This Report provides recommendations for guidance under Sections 108(i) and 163(e)(5)(F), which were enacted as part of the American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5
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NYSBA: State Should Adopt Appointment Process Like U.S. Tax Court
The New York State Bar Association Tax Section has released a report on The Process for Making Appointments to the New York Tax Appeals Tribunal (No. 1181): We believe that the process usually used in the nomination of judges to the U.S. Tax Court can serve as a model for a process that would assist