Public Policy: 2004 Comments, Section of Taxation (ABA

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Comments on Regulations and Administrative Rulings – 2004
The comments listed in this Index represent the individual views of the ABA Section of Taxation members who prepared them. They have not been approved by the Section of Taxation, the House of Delegates or the Board of Governors of the American Bar Association and should not be construed as representing the policy of the Association or of the Section.
Documents are provided in Adobe Acrobat format unless otherwise indicated.

Submissions to U.S. Treasury Dept. & IRS
I.R.C. §	Submitted	Comments Concerning:
n/a	12/21/04	Proposed Changes to the Internal Revenue Service’s Classification Settlement Program to Resolve Worker Classification Cases
1374	11/23/04	Adjustment to Net Unrealized Built-in Gains and Losses
951	11/22/04	Pro Rata Share Determinations Under Subpart F
2632	10/12/04	Proposed Regulations Relating to the Election Not to Have Automatic Allocation of Generation-Skipping Transfer Tax Exemption Apply to Certain Transfers to a GST Trust (Reg-153841-02)
n/a	9/2/04	Identification of Potential Increased Thresholds and “Safe Harbors”
704	8/10/04	Temporary and Proposed Regulations Governing Allocation of Partnership Expenditures for Foreign Taxes (TD 9121; Reg-139792-02)
368	7/19/04	Proposed Regulations on Continuity of Business Enterprise and Certain Related Issues
704	7/13/04	Anti–Mixing Bowl Rules in Partnership Mergers (Revenue Ruling 2004-43)
368	5/26/04	Transfers of Assets Following Putative Reorganizations
501	5/25/04	Section 501(c)(4) and Political Activity
368	5/14/04	The Effect of Pre-Closing Changes of Acquiror Stock Value on Continuity of Interest
n/a	5/12/04	LMSB Productivity Improvement Phase II
various	5/10/04	Deposit Requirements for Employment Taxes in Connection with the Exercise of Nonstatutory Stock Options
1031	5/5/04	Rev. Proc. 2000-37 Safe Harbor Build-To-Suit Exchanges Involving Leasehold Improvements
752	4/5/04	Characterization of a Partnership Liability Under Section 752 Where a Disregarded Entity is a General Partner
707	4/2/04	Disguised Sales of Partnership Interests
1361	4/2/04	Request for Revenue Ruling on S Corporation Qualifying Director Shares
871, 881	3/18/04	Need for Guidance on Portfolio Interest Rules under Sections 871(h) and 881(c) of the Internal Revenue Code
421, 422, 424	2/12/04	Proposal on Incentive Stock Options Under Sections 421, 422 and 424 of the Internal Revenue Code
various	2/6/04	Revenue Ruling 2002-41, 2002-28 IRB 75 and Notice 2002-45, 2002-28 IRB 93
403	2/5/04	Code Section 403(b) Regulations Project
n/a	2/4/04	Proposed Changes to Form 656, Offer-in-Compromise
various	2/4/04	National Taxpayer Advocate's Practitioner Licensing Proposal
1446	1/27/04	Proposed Regulations on the Obligation of Partnerships to Withhold Tax Under Section 1446 on Effectively Connected Taxable Income Allocable to Foreign Partners
482	1/23/04	Proposed Regulations on Treatment of Services and Intangibles Under Section 482

Submissions to Foreign Revenue Agencies
Code §	Submitted	Comments Concerning:
n/a	1/15/04	Canada Customs and Revenue Agency Income Tax Information Circular Number IC 71-17R5

Review Additional Comment Submissions
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Section of Taxation Public Policy Index