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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.
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 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 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 1011
Legislation Regarding Conversion of an S Corp to a Partnership.
Tax Letter 1012
Treasury's Plan to Combat Abusive Tax Avoidance Transactions.
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 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 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 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.