Tax Reports 2002

Tax Report and Letter 1024 
Securitization Reform Measures

Tax Letter 1023 
Proposed exceptions to the tax shelter disclosure requirements of Section 1.6011-4T.

Tax Report and Letter 1022 
Taxation of Straight and Contingent Convertible Debt

Tax Report and Letter 1021 
Comments on Proposed Regulations under Section 280G

Tax Report 1020 
Temporary and proposed regulations interpreting Section 355(e) of the Code.

Tax Report and Letter 1 and 2 1019 
Report No. 1019 and transmittal letters on pending tax shelter legislation.

Tax Report 1018 
Comment on draft New York State proposed regulations relating to nexus implications of a non-resident corporation’s participation in a trade show in New York.

Tax Report and Letter 1017 
Report number 1017 on the treatment of expenditures made in connection with acquiring, creating or enhancing intangible assets. Our report responds to a request for comments set forth in the advance notice of proposed rulemaking (the “Notice”) issued January 17, 2002, 67 Fed. Reg. 3461-02.

Tax Report and Letter 1016 
Report No. 1016 responds to the request for comments made in Revenue Ruling 200 1-46, 2001-42 I.R.B. 321, dealing with multi-step acquisitions (the “Ruling”).

Tax Letter 1015 
Support for passage of bill A.11750 which would conform New York State income tax filing date with the federal date.

Tax Report and Letter 1014 
Outbound Inversion Transactions.

Tax Report 1013 
Treasury/IRS business plan for 2002-2003.

Tax Letter 1012 
Treasury's Plan to Combat Abusive Tax Avoidance Transactions.

Tax Letter 1011 
Legislation Regarding Conversion of an S Corp to a Partnership.

Tax Report and Letter 1010 
The effect on the international provisions of the Internal Revenue Code of defining "statutory" mergers and consolidations under Section 368(a)(1)(A) to include those effected under foreign law.

Tax Letter 1009 
Regarding the circumstances in which a corporate partner will be regarded as engaged in an active trade or business for purposes of Section 355(b) on account of the partner's ownership of an interest in the partnership (guidance supplementing Rev. Rul. 92-17).

Tax Letter 1008 
Letter regarding the effective date of Rev. Proc. 2002-13

Tax Report and Letter 1007 
Simplification of the Internal Revenue Code

Tax Report and Letter 1006 
Section 411(d)(6) of the Internal Revenue Code

Tax Report and Letter 1005 
Taxation of Partnership Options and Convertible Securities.

Tax Report and Letter 1004 
Comments on the Treasury Department's Proposed Regulations Section 1.894-1(d)(2)(ii)-(iv), addressing "Reverse Hybrid Entities" under Internal Revenue Code Section 894 governing the taxation of domestic and foreign taxpayers affected by governing tax treaties.

Tax Report and Letter 1003 
Critique of the Treasury Department's Subpart F Study.

Tax Report and Letter 1002 
Report commenting upon New York City's taxation of shareholders of corporations that have elected S corporation treatment for federal (and perhaps New York State) income tax purposes and particularly as to proposed regulations governing Internal Revenue Code section 338 (h)(10) elections.