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Tax Section Reports

Tax Section Reports Index

To be notified of new reports via email, send a blank email to:

Reports and Letters are all in PDF format

Please note: Some of these reports are very large. If you are trying to print them, please wait until the entire file is done downloading.

If you need Tax Reports or Letters in a more accessible format, please contact the Bar Center at (518) 463-3200 or e-mail

Tax Section Report and Cover Letter 1252
Generally, sections 351(e) and 368(a)(2)(F) deny tax-free treatment for a transaction that qualifies as a section 351 exchange or 368 reorganization where the transaction involves one or more investment companies. This report makes recommendations for the Treasury and IRS to provide guidance that will: ensure the types of transactions Congress was concerned with are subject to recognition, eliminate unintended applications of the provisions, and, provide certainty to taxpayers on significant ambiguities under current law.

Tax Section Report and Letter 1251 on draft regulations concerning NYS Offers in Compromise
Comments on the draft amendments to the Offer in Compromise regulations Part 5005 of Chapter VIII of 20 NYCRR to implement recent changes in the Commissioner's authority to compromise taxes under section 171 (fifteenth) of NY Tax Law

Tax Section Report and Letter 1250
The report addresses issues arising out of the enactment of the Hiring Incentives to Restore Employment Act (the "HIRE Act") that relate to the issuance of registered debt after March 18, 2012. This report concerns registered debt following the Hire Act.

Tax Section Report and Letter 1249
Report and Letter on the Interaction of Section 909 and Subchapter K

Tax Section Report and Letter 1248
Report on Distressed Debt Instruments

Tax Section Report and Letter 1247
Comments on the Application of Employment Taxes to Partners and on the Interaction of the Section 1401 Tax with the new Section 1411 Tax

Tax Section Letter 1246
Comments on 2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions and Answers

Tax Section Report 1245
Proposed Regulations Concerning Series Organizations

Tax Section 1244
Treasury Request for Public Comments Regarding Executive Order 13563

Tax Section Letter 1243
Recommendations for 2011-2012 Tax Guidance Priority List

Tax Section Letter 1242
Possible Tax Relief for Disaster-Related Efforts

Tax Section Letter 1241
Draft Form 8939, Allocation of Increases in Basis for Property Acquired From a Decedent; Reporting of Certain 2010 Generation-Skipping Transfers

Tax Section Report and Letter 1240
New York State Bar Association Tax Section Report on Revenue Ruling 99-6

Tax Section Report and Letter 1239
Report of the Tax Section of the New York State Bar Association on Certain Aspects of the Taxation of Securities Loans and the Operation of Section 1058

Tax Section Report and Letter 1238
Report on Notice 2010-49

Tax Section Report and Letter 1237
Report on Proposed Regulations on The Definition of Public Trading

Tax Section Report and Letter 1236
Report on Certain Continued Coverage Under Insured Group Health Plans in Light of the PPACA Nondiscrimination Rules and IRS Notice 2011-1

Tax Section Letter 1235
Proposed Legislation (S.l 072) Creating an Office of the Taxpayer Advocate

Tax Section Report and Letter 1234
Report on Section 871(m)

Tax Section Report and Letter 1233
Report on Nonresident Audit Guidelines of the State of New York

Tax Section Report and Letter 1232
Report on the Management and Control Provision of the "International Tax Competitiveness Act of 2011

Tax Section Report and Letter 1231
Report on Section 901(m)

Tax Section Report and Letter 1230
Claiming Worthlessness for a Failed Subsidiary within a Consolidated Group

Tax Section Report and Letter 1229
Report on Characterizing "Overlap" Transactions Under Subchapter C

Tax Section Report and Letter 1228
Report on Codification of the Economic Substance Doctrine