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Tax Section Reports 2005

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 Report and Letter 1075
Application of Section 6700 Penalties to Lawyers: The "Reason to Know" Standard.

Tax Report and Letter 1076
Proposed Regulations under Section 752 Relating to the Allocation of Partnership Liabilities where a Disregarded Entity is an Obligor.

TAx Report and Letter 1077
Proposed Regulations Regarding the Application to Partnerships of Section 1045 Gain Rollover Rules for Qualified Small Business Stock.

Tax Report and Letter 1078
Remic IO Interests

Tax Report and Letter 1079
Proposed Regulations Regarding the Determination of a Shareholder's "Pro Rata Share" Under Section 951.

Tax Report and Letter 1080
Report on Disclosure by Material Advisors.

Tax Report and Letter 1081
Circular 230 Regulations.

Tax Report and Letter 1082
Effect of Mergers, Acquisitions and Dispositions on the Application of Code Section 965.

Tax Report and Letter 1084
New York's Nonresident Income Allocation Requirements: Analysis and Recommendations.

Tax Report and Letter 1085
Disguised Sales of Partnership Interests Responding to Reg-149519-03.

Tax Report and Letter 1086
Regs. §1.367(a)-3(c).

Tax Report and Letter 1087
Report No. 1087 with respect to Section 965 and Notices 2005-10 and 2005-38.

Tax Report and Letter 1088
Report on Proposed Regulations Regarding Allocation of Basis Under Section 358.

Tax Report and Letter 1089
Report on Proposed Regulations Dealing with "Predecessors" and "Successors" in Section 355(e).

Tax Report Letter and Appendix A B 1090
New York State Tax Issues Relating to Same-Sex Unions.

Tax Report and Letter 1091
Section 409A of the Internal Revenue Code and Internal Revenue Service Notice 2005-1.

Tax Letter 1092
Offer in Compromise Legislation in Highway Bill (H.R. 3).

Tax Letter 1093
Section 470 Legislation.

Tax Report and Letter 1094
Proposed Regulations Regarding Cross-Border Mergers

Tax Report and Letter 1095
Credit Default Swaps

Tax Report and Letter 1096
U.S. Branch Allocation of Interest Expense.

Tax Report and Letter 1097
JCT Proposal on SECA Taxation.

Tax Report and Letter 1098
Partnership Equity Received in Exchange for Services.

Tax Letter 1099
JOBS Act Straddle Amendments.

Tax Report and Letter 1083
Regulation Section 1.901-2(f)(3) and the Allocation of Foreign Taxes Among Related Persons.