Reports 2008

Tax Report and Letter 1174 
Report commenting on proposed regulations under Section 336(e), concerning the treatment of certain stock sales and distributions as asset transfers.

Tax Report and Letter 1173 
Report on international provisions of H.R. 3970 (the Tax Reduction and Reform Act of 2007) and effects of reduction in corporate tax rate.

Tax Report and Letter 1172 
Tax issues arising when a life insurance policy is purchased by an investor with no insurable interest in the insured, known as “investor-owned life insurance.

Tax Report and Letter 1171 
Report on the proposed removal of the “temporary stay” exception from 20 NYCRR Section 105.20(e)(1) concerning taxation of an individual as a resident in New York.

Tax Letter 1170 
Good faith compliance with Section 409A.

Tax Report and Letter 1169 
Report on “commensurate in scope” test introduced in Revenue Ruling 64-182 and the issue of endowment size of certain public charities.

Tax Letter 1168 
Letter commenting on a proposed ruling concerning the tax consequences of using a private trust, company to serve as the trustee of trusts having family members as grantors and beneficiaries.

Tax Letter 1167 
Letter dated November 4, 2008 from David S. Miller to Governor David Paterson recommending the repeal of the stock transfer tax.

Tax Report and Letter 1166 
Report on Proposed Carried Interest and Fee Deferral Legislation

Tax Letter 1165 
Request for Formal Guidance on Tax Consequences of Warrant Exercises

Tax Report and Letter 1164 
Selected Issues in Triangular Reorganizations

Tax Report 1163 
Guidance on Economic Downturn Issues

Tax Report 1162 
Formal Guidance for Stock Buy-Backs and "North and South" Transactions

Tax Report and Letter 1161 
Report on the Proposed Contract Manufacturing Regulations

Tax Report and Letter 1160 
Report on Treatment of Executors' and Trustees' Commissions

Tax Report and Letters A and B 1159 
Report on Prepaid Forward Contracts

Tax Report and Letter 1158 
Distributions in Connection with Acquisitions

Tax Report and Letter 1157 
Tax Exemption for Foreign Sovereigns Under Section 892

Tax Letter 1156 
Notice 2008-20 Intermediary Tax Shelters

Tax Report and Letter 1155 
Revenue Procedure 2003-65

Tax Letter 1154 
Notice 2008-19 and Protected Cell Companies Outside of the Insurance Arena

Tax Report and Letter 1153 
Recommending Repeal of Section 562(c) With Respect to RICs and REITs

Tax Report and Letter 1152 
Treasury Regulations Sections 1.368-1(d) and -2(k)

Tax Report and Letter 1151 
Modifications to Commercial Mortgage Loans Held by a Real Estate Mortgage Investment Conduit (REMIC)

Tax Report and Letter 1150 
Report on Proposed Treasury Regulation Section 1.1502-13(g) Relating to Intercompany Obligations

Tax Report 1149 
Report on the Proposed Amendments to Circular 230 Relating to Standards with Respect to Tax Returns

Tax Letter 1148 
Canadian-U.S. Treaty Protocol -- Payments Through Hybrids

Tax Report 1147 
New York Stock Transfer Tax

Tax Report 1146 
Recent and Proposed Statutory Changes to Tax Return Preparer Penalty Rules of Internal Revenue Code Section 6694 and Related Issues

Tax Report 1145 
Nexus Requirements for Imposition of Business Activity Taxes

Tax Report and Letter 1144 
Final Dual Consolidated Loss Regulations

Tax Report 1143 
Tax Equity for Domestic Partner and Health Beneficiaries Act (S.1556); Tax Equity for Health Plan Beneficiaries Act of 2007 (H.R. 1820).

Tax Report and Letter 1142 
Proposed Regulations Regarding the Active Trade or Business Requirement under Section 355(b).

Tax Report 1141 
Comments on Proposed Amendments to Part 132 of the Personal Income Tax Regulations

Tax Report 1140 
Report on Proposed Regulations Under Section 987