Reports 2006

Tax Report and Letter 1123 
Section 954(c)(6)’s exclusion from foreign personal holding company income status for certain payments made by a controlled foreign corporation.

Tax Report and Letter 1122 
Responding to Notice 2006-14 which requested comments on certain changes to the regulations under Section 751(b) of the Code

Tax Report and Letter 1121 
Authority of the Treasury Department and the IRS to issue regulations under the IRC

Tax Report and Letter 1120 
"Zero Basis"

Tax Letter 1119 
Two-step "A" reorganizations

Tax Report 1118 
NY Innocent Spouse Relief

Tax Report and Letter 1117 
"Stuckless" proposed regulations 

Tax Report and Letter 1116 
Section 4965

Tax Report 1115 
Patenting Tax Strategies

Tax Report and Letter 1114 
Concerning section 956 and partnerships.

Tax Report and Letter 1113 
Report addressing limitation on benefits provisions in treaties and Section 1(h)(11) concerning the definition of “qualified foreign corporation,”

Tax Report and Letter 1112 
Report addressing the issue of basis recovery in redemption transactions that are treated as dividend equivalent redemptions under Section 301 of the Code

Tax Report and Letter 1111 
Report commenting on guidance to be proposed regarding tax consequences of appointing a family-owned trust company to serve as trustee of a trust for the benefit of family members

Tax Letter 1110 
Report commenting on IRS Notice 2005-74 which addresses the effect of various common asset reorganizations on gain recognition agreements ("GRAs")

Tax Report and Letter 1109 
IRC §§6111 and 6112 material advisor rules to law and accounting firms

Tax Letter 1108 
Letter dated May 1, 2006 from Kimberly S. Blanchard to Eric Solomon, Acting Deputy Assistant Secretary (Tax Policy), Department of the Treasury, Donald Korb, Chief Counsel, Internal Revenue Service, and Hon. Mark W. Everson, Commissioner, Internal Revenue Service, with suggested revisions to Circular 230 as it applies to written advice from tax practitioners.

Tax Report and Letter 1107 
Report on Temporary Treasury Regulations Section 1.7874.1T which addresses the treatment of affiliate-owned stock for purposes of determining whether a foreign corporation is a surrogate foreign corporation under Section 7874

Tax Letter 1106 
Letter dated March 17, 2006 from Kimberly S. Blanchard to Hon. Owen W. Johnson, Chair, New York State Senate Finance Committee, and Hon. Herman D. Farrell, Jr., Chair, New York State Assembly Ways and Means Committee, urging amendment to NYS Tax Law Section 1131(1), which currently imposes liability on all partners and members of LLCs for any unpaid sales taxes for such entities, together with reissuance of Report #1035 on Trust Fund Liability for Collection of Sales Tax.

Tax Report and Letter 1105 
Report on proposed amendments to NY Tax Law Article 9-A regulations concerning the taxation of corporate partners

Tax Report and Letter 1104 
Report on proposed regulations under section 409A of the IRC addressing compensation practices of businesses employing U.S. taxpayers

Tax Report and Letter 1103 
Report on final, temporary and proposed Treasury Regulations issued under section 1446 of the IRC relating to the withholding by partnerships of U.S. tax on allocations of effectively-connected taxation income to foreign partners

Tax Report and Letter 1102 
Report on proposed Treasury Regulations issued under sections 332, 351 and 368 of the IRC which provide rules regarding formation, reorganizations and liquidations involving insolvent corporations

Tax Report and Letter 1101 
Report on Sections 362(e) and 334(b) of the IRC concerning basis adjustment rules for property transferred to a corporate recipient in a tax-free corporate reorganization or a Section 351 transaction, and also in the context of inbound subsidiary liquidations