Paul L. Caron
Dean
Pepperdine Caruso
School of Law
NYSBA Tax Section
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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…
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NYSBA Issues Report on Remedying Documentary Noncompliance by § 409A Plans
The New York State Bar Association Tax Section has released a report on Remedying Documentary Noncompliance by Section 409A Plans in Response to Notice 2008-113 (No. 1180): Notice 2008-113, 2008-51 I.R.B. 1305 (Dec. 22, 2008), requests comments on the possibility of establishing a voluntary compliance program that would provide relief to taxpayers that have established…
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NYSBA Releases Tax Reports
The New York State Bar Association has issued tax reports on: Selected Tax Provisons of the 2009-10 NYS Budget (1179) Draft Amendments to Combined Returns Regs (1178) Proposed Regs Under §§ 367, 1248 & 3068 (1177) Treatment of Capital Contributions Under § 382(l)(1) (1176) Rev. Proc. 2008-51 (1175)
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NYSBA Releases Tax Reports
The New York State Bar Association has issued tax reports on: Proposed § 336(e) Regs (1174) International Provisions of H.R. 3970 and Effects of Reduction in Corporate Tax Rate (1173) Investor-Owned Life Insurance (1172)
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NYSBA Releases Report on Proposed Removal of “Temporary Stay” Exception
The New York State Bar Association has issued a letter and report criticizing the proposed removal of the "temporary stay" exception from 20 NYCRR Section 105.20(e)(1) concerning the taxation of a New York state resident (1171).
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NYSBA Releases Tax Reports
The New York State Bar Association has issued several tax reports: Good Faith Compliance with Section 409A (1170) Rev. Rul. 64-182 and the Endowment Size of Certain Public Charities (1169) Using a Private Trust Company as Trustee of Trusts with Family Members as Grantors and Beneficiaries (1168) Repealing the Stock Transfer Tax (1167)
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NYSBA Releases Tax Reports
The New York State Bar Association has issued several tax reports: Report on Proposed Carried Interest and Fee Deferral Legislation (1166) Request for Formal Guidance on Tax Consequences of Warrant Exercises (1165) Selected Issues in Triangular Reorganizations (1164)
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NYSBA Releases Tax Reports
The New York State Bar Association has issued several tax reports: Guidance on Economic Downturn Issues (1163) Formal Guidance for Stock Buy-Backs and "North and South" Transactions (1162) Report on the Proposed Contract Manufacturing Regulations (1161)
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NYSBA Issues Tax Reports
The New York State Bar Association Tax Section has issued several tax reports: IRS Notice 2008-32 (1160) Prepaid Forward Contracts (1159) Distributions in Connection with Acquisitions (1158) Tax Exemption for Foreign Sovereigns Under Section 892 (1157)
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NYSBA Issues Tax Reports
The New York State Bar Association Tax Section has issued several tax reports: Notice 2008-20: Intermediary Tax Shelters (1156) Revenue Procedure 2003-65 (1155) Transactions Between a Risk Protection Buyer and an Individual "Cell" of a "Protected Cell Company" Outside the Insurance Context (1154) Recommending Repeal of Section 562(c) With Respect to RICs and REITs (1153)…
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NYSBA Issues Tax Reports
The New York State Bar Association Tax Section has issued several tax reports: Report Recent and Proposed Statutory Changes to Tax Return Preparer Penalty Rules of Internal Revenue Code Section 6694 and Related Issues (No. 1146) Nexus Requirements for Imposition of Business Activity Taxes (No.1145) Report Final Dual Consolidated Loss Regulations (No. 1144) Tax Equity…
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NYSBA Issues Tax Reports
The New York State Bar Association Tax Section has issued a number of tax reports: Proposed Regulations Regarding the Active Trade or Business Requirement under Section 355(b) (No. 1142) Comments on Proposed Amendments to Part 132 of the Personal Income Tax Regulations (No. 1141) Report on Proposed Regulations Under Section 987 (No. 1140) Definition of…
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NYSBA Submits Comments on Proposed § 901 Regs
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on the proposed § 901 regulations relating to compulsory payments of foreign taxes.
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NYSBA Submits Reports to IRS on Sales of Bearer Bonds and General Powers of Appointment
The New York State Bar Association Tax Section has sent letter and reports to the IRS and Treasury Department on these two items: 1133: Restrictions Imposed on Offers and Sales of Bearer Bonds by the Tax Equity and Fiscal Responsibility Act of 1982 Letter Report 1134: IR-2007-127: Request for Comments Regarding General Powers of Appointment…
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NYSBA Tax Section Submits Comments on the Pension Protection Act of 2006
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on Guidance under the Pension Protection Act of 2006.
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NYSBA Tax Section Submits Comments on Disqualified Investment Corporations
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on disqualified investment corporations as defined in section 355(g).
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NYSBA Tax Section Submits Comments on Proposed Regs on Exchanges of Property for Annuities
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on the proposed regulations regarding exchanges of property for annuities.
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NYSBA Submits Comments on Tax Provision of NYS Budget Bill
The New York State Bar Association Tax Section has sent a letter and report to the New York State Department of Taxation and Finance on the Tax Provisions of the New York State 2007-08 Budget Legislation.
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NYSBA Submits Comments on Model Income Tax Convention
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on the Model Income Tax Convention Released by the Treasury Department. The report was prepared by asn ad hoc committee of the NYSBA Tax Section, consisting principally of members of the Committee on Inbound U.S.…
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NYSBA Tax Section Submits Comments on Material Advisor Rules
The New York State Bar Association Tax Section has sent a letter and report to the IRS and Treasury Department on the proposed regulations regarding portable transaction disclosure and list maintenance rules under §§ 6011, 6111, and 6112.
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NYSBA Tax Section Urges New Gov. Spitzer to Issue More Tax Regs
The New York State Bar Association Tax Section has sent a letter urging new Governor Eliot Spitzer to issue more tax regulations: Unfortunately, the prior administration viewed regulation as burdensome, and imposed a variety of barriers to the prompt promulgation of interpretive tax regulations. We are writing to urge that your Administration take a different…
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NYSBA Tax Section Submits Comments on Differences in Tax Treatment of Domestic and Foreign Partnerships
The New York State Bar Association Tax Section has sent a letter and report to the Treasury Department and IRS on Differences in Tax Treatment of Domestic and Foreign Partnerships.