Comments With Respect to
Prop. Treas. Reg. §§ 1.401(A)(4)-8(B)(1) and 9(B)(2)(V)
Governing So-Called “New Comparability Plans”
Table of Contents
The following Comments are the individual views of members of the
Section of Taxation who prepared them and do not represent the position of the American
Bar Association or the Section of Taxation.
This report was prepared by individual members of the Employee Benefits Committee of
the Section of Taxation. The principal responsibility was exercised by Wm. Scott Magargee,
III. Substantive contributions were made by Thomas C. Graves, Kurt L.P. Lawson, and Scott
Magargee. The Comments were reviewed by Kyle N. Brown, Committee Vice Chair, and Diane J.
Fuchs, Committee Chair. They were also reviewed by Cynthia C. Benson of the Section’s
Committee on Government Submissions and by Stuart M. Lewis, Council Director for the
Employee Benefits Committee.
Although many members of the Section of Taxation who participated in preparing these
Comments have clients who would be affected by the federal tax principles addressed by
these Comments or have advised clients on the application of such principles, no such
member (or the firm or organization to which such member belongs) has been engaged by a
client to make a government submission with respect to, or otherwise to influence the
development or outcome of, the specific subject matter of these Comments, with the
exception of Mr. Lewis, whose involvement with these Comments was limited to
nonsubstantive, technical and procedural review.
Contact:
Wm. Scott Magargee, III
(215) 994-2609
scott.magargee@dechert.com
Date: March 23, 2001
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