The information presented is only of a general nature, intended simply as background material, is current only as of its indicated date, omits many details and special rules and accordingly cannot be regarded as legal or tax advice.

The information presented is not intended to constitute a complete analysis of all tax considerations. Internal Revenue Service regulations generally provide that, for the purpose of avoiding United States federal tax penalties, a taxpayer may rely only on formal written opinions meeting specific regulatory requirements. The information presented does not meet those requirements. Accordingly, the information presented was not intended or written to be used, and a taxpayer cannot use it, for the purpose of avoiding United States federal or other tax penalties or for the purpose of promoting, marketing or recommending to another party any tax-related matters.

Corporate Tax Material
International Tax Material
Partnership and Subchapter S Tax Material
State & Local Tax Material
Exempt Organizations Material
Other Tax Material

Corporate Tax Material

Calls for Tax Law Changes in the Wake of Enron (April 2003). [478K]  Preview the HTML version. [12K]
Excerpts from the Joint Committee on Taxation's Report of Investigation of Enron Corporation and Related Entities Regarding Federal Tax and Compensation Issues, and Policy Recommendations, JCS-3-03 (see also the portion of the Government Printing Office's website entitled Joint Committee on Taxation Committee Prints, 108th Congress).
Volume I, Report [1,927K]

Table of Contents for Volume I [17K]

Table of Contens for Volume II, Appendix A [28K]

Table of Contens for Volume II, Appendix B [212K]

Table of Contens for Volume III, Appendix C [92K]

Table of Contens for Volume III, Appendix D [159K]

Written Testimony of the Joint Committee Staff on the Report, JCX-10-03, February 13, 2003 [118K]

Written Testimony of the Joint Committee Staff on Executive Compensation and Company-Owned Life Insurance, JCX 36-03, April 7, 2003 [131K]

Corporate Tax Bulletin (January 2003). [511K]  Preview the HTML versions of Bush Administration Proposes Eliminating Double Tax on Corporate Earnings [20K] and IRS Grants 15-Day Grace Period for 2002 Inversion Reporting. [5K]

Eliminate the Double Taxation of Corporate Earnings, the U.S. Treasury Department's January 21, 2003 explanation of the President's proposal. [687K]

T.D. 9022, adopting "inversion transaction" reporting temporary regulations. [58K]

Announcement 2003-7, announcing a 15-day grace period for reporting 2002 transactions. [48K]

Corporate Tax Bulletin (April 1997). [376K] Preview the HTML version of the Morris Trust article. [20K] Preview the HTML version of the Shareholder Continuity of Interest article. [10K]

Notice of Proposed Rulemaking, proposing changes to the shareholder continuity of interest rules. [36K]

Proposal for Rationalizing the Treatment of Options and Warrants in Reorganizations (April 1996). [258K] Preview the HTML version. [27K]

New (Old) Issues In Reorganizations: Revenue Procedure 94-76, the "Anti-Yoc Heating" Regulations and the Seagram Case (November 1995). [89K] Preview the HTML version. [54K]

International Tax Material

Significant Changes to U.S. Taxation of Expatriating Citizens and Residents (July 2008). [172K] Preview the HTML version. [21K]
Heroes Earnings Assistance and Relief Tax Act of 2008, P.L. 110-245, § 301 [64K]

Technical Explanation by the Joint Committee on Taxation, pp. 36-46 [56K]

United States and Sweden Sign New Income Tax Treaty Protocol (October 2005). [127K] Preview the HTML version. [8K]

September 30, 2005 Protocol to the U.S.-Sweden Income Tax Treaty. [65K]

September 30, 2005 U.S. Note. [15K]

September 30, 2005 Swedish Note. [17K]

IRS Proposes Section 482 Regulations on Intangible Property and Services (November 2004). [236K] Preview the HTML version. [58K]

Text of the proposed regulations, as published in the Federal Register for September 10, 2003. [199K]

Transfers of Intangible Property under Section 482 (February 1999). [131K] Preview the HTML version. [52K]

Internaltional Tax Bulletin (January 1999). [123K] Preview the HTML version of the foreign partnership reporting article. [29K] Preview the HTML version of the Revenue Procedure 65-17 modification article. [6K] Preview the HTML version of the withholding tax regulation update article. [11K]

Foreign Partnerships

Notice of Proposed Rulemaking, 26 C.F.R. 1.6038-3, 63 F.R. 48144-48148 (Sept. 9, 1998) [37K].

Notice of Proposed Rulemaking, 26 C.F.R. 1.6038B-2, 63 F.R. 48148-48154 (Sept. 9, 1998) [50K].

Notice of Proposed Rulemaking, 26 C.F.R. 1.6046A-1, 63 F.R. 48154-48157 (Sept. 9, 1998) [32K].

IRS Form 8865, Information Return of U.S. Persons with Respect to Certain Foreign Partnerships, 1998-43 I.R.B. 11 (Oct. 9, 1998 draft) [474K].

Instructions to IRS Form 8865, 1998-43 I.R.B. 20 (Oct. 9, 1998 draft) [1,351K].

Modification of Revenue Procedure 65- 17

Announcement 99-1, 1999-2 I.R.B. 41 (Jan. 11, 1999) [38K].

Withholding Regulations

T.D. 8734, 62 F.R. 53387 (Oct. 14, 1997) [710K]

T.D. 8804, 63 F.R. 72183 (Dec. 31, 1998) [63K]

Notice 98-16, 1998-15 I.R.B. 12 (Apr. 13, 1998) [23K]

Revenue Procedure 98-27, 1998-15 I.R.B. 15 (Apr. 13, 1998) [48K]

Notice 99-8, 1999-5 I.R.B. 26 (Feb. 1, 1999) [106K]

Announcement 98-15, 1998-10 I.R.B. 36 (Mar. 9, 1998) [14K]

February 1998 draft Form W-8, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding [94K]

February 1998 draft Form W-8A, Foreign Person's Claim of Income Effectively Connected with the Conduct of a Trade or Business in the United States [66K]

February 1998 draft Form W-8B, Certification for United States Tax Withholding for Foreign Governments and Other Foreign Organizaitons [139K]

February 1998 draft Form W-8C, Certificate of Indermediary for United States Tax Withholding [143K]

Announcement 98-51, 1998-24, I.R.B. 7 (Jun. 15, 1998) [13K]

June 2, 1998 draft Form W-8, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding [94K]

June 2, 1998 draft Instructions to Form W-8 [780K]

June 2, 1998 draft Form W-8A, Foreign Person's Claim of Income Effectively Connected with the Conduct of a Trade or Business in the United States [74K]

June 2, 1998 draft Instructions to Form W-8A [508K]

June 2, 1998 draft Form W-8B, Certification for United States Tax Withholding for Foreign Governments and Other Foreign Organizaitons [115K]

June 2, 1998 draft Instructions to Form W-8B [724K]

June 2, 1998 draft Form W-8C, Certificate of Foreign Indermediary, Foreign Partnership, and Certain U.S. Branches for United States Tax Withholding [151K]

June 2, 1998 draft Instructions to Form W-8C [869K]

Form W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Withholding Tax (Rev. Oct. 1998) [48K]

Instructions for Form W-8BEN [57K]

Form W-8ECI, Certificate of Foreign Person's Claim for Exemption from Withholding on Income Effectively Connected With the Conduct of a Trade or Business in the United States (Rev. Oct. 1998) [44K]

Instructions for Form W-8ECI [32K]

Form W-8EXP, Certificate of Foreign Government or Other Foreign Organization for United States Tax Withholdding (Rev. Oct. 1998) [48K]

Instructions for Form W-8EXP [66K]

Form W-8IMY, Certificate of Foreign Intermediary, Foreign Partnership, or Certain U.S. Branches for United States Tax Withholding (Rev. Oct. 1998) [59K]

Instructions for Form W-8IMY [51K]

Instructions for the Requester of Forms W-8BEN, W-8ECI, W-8EXP, and W-8IMY [48K]

Taxpayer Relief Act of 1997 International Tax Changes (August 1997). [163K] Preview the HTML version. [55K]

Taxpayer Relief Act of 1997 (enrolled version), Foreign Revenue Provisions, §§ 1051-1057, pp. 153-158; Simplification and Other Foreign-Related Provisions, §§ 1101-1175, pp. 176-206. [194K]

H.Rpt. 105-220, Conference Committee Report, pp. 567-579, 612-646. [259K]

T.D. 8722, Guidance Regarding Claims for Certain Income Tax Convention Benefits , F.R. 35673-35680, July 2, 1997. [55K]

IRS Provides Guidance on 1996 Foreign Trust Changes (July 1997). [163K] Preview the HTML version. [66K]
P.L. 104-188, the Small Business Job Protection Act of 1996. [39K]

H.Rpt. 104-737, Conference Committee Report. [93K]

H.Rpt. 104-542, House Ways & Means Committee Report (H.R. 3286). [168K]

Notice of Proposed Rulemaking, Residence of Trusts and Estates. [41K]

Notice of Proposed Rulemaking, Inboud Grantor Trusts with Foreign Grantors. [132K]

Notice 96-60. [24K]

Notice 96-65. [25K]

Notice 97-18. [56K]

Notice 97-34. [103K]

Notice 97-42. [16K]

IRS Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation, Foreign Estate or Trust, or Foreign Partnership (April 1996). [41K]

IRS Form 3520, Creation of or Transfers to Certain Foreign Trusts (June 1995). [33K]

IRS Form 3520-A, Annual Return of Foreign Trust with U.S. Beneficiaries. [40K]

Internet Commerce Paper from the U.S. Treasury Office of Tax Policy (November 1995). [140K] Preview the HTML version. [6K]

Transfer Pricing Examinations (February 1996). [295K] Preview the HTML version. [67K]

Conference Committee Rejects Controversial U.S. Senate Income Tax Treaty Override and Taxation of 10- Percent Offshore Shareholders (November 1995). [63K] Preview the HTML version. [36K]

Partnership and Subchapter S Tax Material

Congress Proposes to Increase Fund Managers' Taxes on Carried Interests (July 2007). [179K] Preview the HTML version. [14K]
H.R. 2834, the Levin carried interest bill [50K].

Present Law and Analysis Relating to Tax Treatment of Partnership Carried Interests, prepared by the staff of the Joint Committee on Taxation in connection with the July 11, 2007 Senate Finance Committee hearing (July 10, 2007, JCX-41-07) [505K].

Testimony of Treasury Assistant Secretary for Tax Policy Eric Solomon before the Senate Finance Committee on the Taxation of Carried Interests [70K]. As of the date of publication of the bulletin, the Senate Finance Committee maintained links to the opening statements and testimony at its July 11, 2007 hearing and made available a video recording of the full hearing.

Ways and Means Committee press release on the carried interest legislation [58K].

Ways and Means Committee fact sheet on the carried interest legislation [101K].

S. 1624, the Baucus-Grassley publicly traded partnership bill [37K].

The Senate Finance Committee explanation of S. 1624 [28K].

The Senate Finance Committee press release regarding the publicly traded partnership legislation [43K].

H.R. 2785, the Welch publicly traded partnership bill [37K].

Treasury Revisits Guidance on Partnership Interests Exchanged for Services (June 2005). [151K] Preview the HTML version. [23K]

Notice of Proposed Rulemaking, containing the proposed regulations. [87K]

Notice 2005-43, containing the proposed revenue procedure. [76K]

Revenue Procedure 2001-43 [19K]

Revenue Procedure 93-27 [32K]

Partnership Tax Bulletin (January 1999) [120K] Preview the HTML version of the single member entity article. [41K] Preview the HTML version of the foreign partnership reporting article. [29K]

Single Member Entities

Revenue Ruling 99-5, 1999-6 I.R.B. 8 (Feb. 8, 1999) [27K]

Revenue Ruling 99-6, 1999-6 I.R.B. 6 (Feb. 8, 1999) [33K]

Notice 99-6, 1999-3 I.R.B. 12 (Jan. 12, 1999) [28K]

Foreign Partnerships

Notice of Proposed Rulemaking, 26 C.F.R. 1.6038-3, 63 F.R. 48144-48148 (Sept. 9, 1998) [37K].

Notice of Proposed Rulemaking, 26 C.F.R. 1.6038B-2, 63 F.R. 48148-48154 (Sept. 9, 1998) [50K].

Notice of Proposed Rulemaking, 26 C.F.R. 1.6046A-1, 63 F.R. 48154-48157 (Sept. 9, 1998) [32K].

IRS Form 8865, Information Return of U.S. Persons with Respect to Certain Foreign Partnerships, 1998-43 I.R.B. 11 (Oct. 9, 1998 draft) [474K].

Instructions to IRS Form 8865, 1998-43 I.R.B. 20 (Oct. 9, 1998 draft) [1,351K].

Small Business Job Protection Act Eases S Corporation Rules (January 1997). [238K] Preview the HTML version. [45K]

Excerpts from H.Rpt. 104-737, the Conference Committee Report on the Act. [199K]

Internal Revenue Service Adopts "Check-the-Box" Classification Regulations (December 1996). [312K] Preview the HTML version. [18K]

T.D. 8697 (Federal Register), adopting the "Check-the-Box" regulations. [79K]

IRS Form 8832 (Entity Classification Election). [38K]

IRS Proposes "Check-the-Box" Classification Regulations (June 1996). [266K] Preview the HTML version. [13K]

Notice of Proposed Rulemaking (Federal Register), proposing the "Check-the-Box" regulations. [70K]

State & Local Tax Material

California Franchise Tax Developments—Fall 2007 (November 2007). [310K]  Preview the HTML version. [72K]

California Franchise Tax Developments—Spring 2007 (October 2007). [309K]  Preview the HTML version. [76K]

State & Local Tax Bulletin (March 2006). [163K]  Preview the HTML versions of DC Court Strikes Down Unincorporated Business Franchise Tax on Nonresident Individuals in Bender v. District of Columbia [9K] and San Francisco Court Rules California LLC Tax Unconstitutional. [7K]

Franchise Tax Board's Attempt to Apply Expense Attribution is Soundly Rejected (November 2005). [115K]  Preview the HTML version. [10K]

California Franchise Tax Developments—Fall 2005 (October 2005). [264K]  Preview the HTML version. [51K]

State & Local Tax Bulletin (June 2005). [306K]  Preview the HTML versions of Current California Franchise Tax Developments [52K] and State Tax Implications of Repatriation of Foreign Earnings. [9K]

California Franchise Tax Developments (April 2005). [234K]  Preview the HTML version. [40K]

California Tax Amnesty . . . Not? (January 2005). [177K]  Preview the HTML version. [46K]

California Franchise, Income and Sales and Use Tax Developments (November 2004). [190K]  Preview the HTML version. [34K]

Current Developments in Property Taxation (June 2004). [178K]  Preview the HTML version. [26K]

State & Local Tax Bulletin (May 2004). [385K]  Preview the HTML versions of Current California Franchise Tax Developments [32K], California Franchise Tax Administrative Procedures [24K] and California Tax Shelter Rules. [47K]

State & Local Tax Bulletin (August 2003). [511K]  Preview the HTML versions of Prompt Action Required to Avoid Overwithholding for New York Nonresident Partners [6K], Legislation Permits Sales and Use Taxpayers to Self-Audit under California's Managed Audit Program [10K] and California Responds to Abusive Tax Schemes. [12K]

State & Local Tax Bulletin (January 2003). [502K]  Preview the HTML versions of California Income Tax Developments [11K] and Supreme Court Reverses Court of Appeals in Geneva Towers. [9K]

Real Estate Withholding Comparative Chart, prepared by the California Franchise Tax Board. [89K]

Streamlined Sales and Use Tax System: Adoption of Landmark Multistate Agreement (November 2002). [498K]  Preview the HTML version. [22K]

November 12, 2002 Streamlined Sales and Use Tax Agreement. [291K]

Is Cessation of a Business Every State's Business or … ? (June 2002). [519K]  Preview the HTML version. [43K]

California Property Tax Alert: September 15th Deadline for Proposition 8 Property Tax Savings (May 2002). [138K]  Preview the HTML version. [8K]

State & Local Tax Bulletin (May 2002). [505K]  Preview the HTML versions of California Manufacturers' Investment Credit [33K] and California Begins Taxing Workers' Compensation Deductibles. [6K]

E-Commerce: United States Sales and Use Tax Considerations (November 2001). [511K]  Preview the HTML version. [25K]

Preston v. State Board of Equalization–Application of the California Sales Tax to Intangibles (October 2001). [504K]  Preview the HTML version. [28K]

State Sales Tax Treatment of Bundled Transactions Involving the Purchase of Discounted Cellular Phones and Telecommunications Services (September 2001). [484K]  Preview the HTML version. [25K]

Jeff Vesely's State & Local Tax Update – Western Region (August 2001). [604K]  Preview the HTML version. [94K]

State & Local Tax Bulletin (July 2000). [127K]  Preview the HTML version of the Recent Legislative Changes May Reduce California Transfer Tax Liability [26K], Appellate Court Rules on Timing of Tax Refund Suit [5K], Federal and California Internet Tax Freedom Acts [6K] and Solar Energy Credit Limitation Affirmed [4K] articles.

State & Local Tax Bulletin (February 2000). [54K]  Preview the HTML versions of the California's Interest Offset Provision Found Unconstitutional [4K], New Independent Contractor Reporting Begins in 2001 for California Businesses [3K] and San Francisco Business and Payroll Taxes under Attack [3K] articles.

State & Local Tax Bulletin (December 1998). [100K]  Preview the HTML version of the Separate Company Tax Credit Limitation article. [23K]  Preview the HTML version of the Interest Offset Survives Round Two article. [4K]

State & Local Tax Bulletin (August 1997). [136K] Preview the HTML version of the Preserving Witness Testimony article. [16K] Preview the HTML version of the Upcoming California Unitary Tax Developments article. [10K] Preview the HTML version of the California Supreme Court's Sinclair Paint decision [21K]

California Voters Approve Proposition 218's Property Tax Limitations (December 1996). [256K] Preview the HTML version. [16K]

Impending March 15, 1996 Deadline for Calendar Year Issuers of California Qualified Small Business Stock. [194K] Preview the HTML version. [9K]

FTB Form 3565 (Small Business Stock Questionnaire). [23K]

Federal Statute Now Prohibits State Income Taxation of Certain Pension Income of Nonresidents (February 1996). [225K] Preview the HTML version. [11K]

Conference Committe Report. [72K]

Exempt Organizations Material

February 2001 Exempt Organizations Bulletin. [96K] Preview the HTML version of Treasury Regulations Implement "Intermediate Sanctions" [9K]  and Tax-Exempt Organizations Subject to Increased Disclosure Requirements. [9K]
T.D. 8920, Excise Tax on Excess Benefit Transactions [232K]

Corrections to T.D. 8920 [39K]

T.D. 8818, Public Disclosure of Material Relating to Tax-Exempt Organizations [60K]

T.D. 8861, Private Foundation Disclosure Rules [135K]

Other Tax Material

March 2008 Tax Bulletin. [229K] Preview the HTML versions of IRS 162(m) Ruling Requires Review of Incentive Pay Arrangements [9K] and Supreme Court Decision May Spur Individual and Class Actions Against ERISA Fiduciaries for Defined Contribution Plans. [14K]

Revenue Ruling 2008-13. [64K]

September 2007 Tax Bulletin. [232K] Preview the HTML versions of District Court Holds Tax Accrual Workpapers Are Protected by the Work Product Privilege [13K] and IRS Extends Deadline for Some, But Not All, Section 409A Document Compliance Amendments. [21K]

Notice 2007-78, 2007-41 I.R.B. ___, under I.R.C. § 409A. [68K]

December 2005 Tax Bulletin, The Domestic Production Activities Deduction—Proposed Regulations Under Section 199. [217K] Preview the HTML version. [46K]

Notice of Proposed Rulemaking, including the proposed section 199 regulations, 70 Fed.Reg. 67220 (November 4, 2005) [316K].

Notice 2005-14, 2005-7 I.R.B. 498 [319K].

Statutory language of section 199 from the Conference Committee Report for the American Jobs Creation Act of 2004, H.Rpt. 108-755, pp. 7-12 [62K].

Conference Committee explanation of section 199 from the Conference Committee Report for the American Jobs Creation Act of 2004, H.Rpt. 108-755, pp. 252-262 [71K].

July 21, 2005 letter to Secretary of the Treasury John W. Snow from Senators Charles E. Grassley, Jr. and Max Baucus, Chairman and Ranking Member, respectively, of the Senate Finance Committee and Congressman William M. Thomas, Chairman of the House Ways and Means Committee [382K].

October 2005 Tax Bulletin, discussing the proposed regulations under section 409A (deferred compensation). Preview the HTML versions of Proposed Section 409A Regulations Provide Increased Flexibility for Nonqualified Deferred Compensation Plans [39K], Stock Compensation Provisions in Proposed Section 409A Regulations [15K] and Proposed Regulations Clarify Application of Section 409A to Foreign Benefit Arrangements [13K].

Proposed section 409A regulations, as published in the October 4, 2005 Federal Register. [272K]

Notice 2005-1. [201K]

Text of section 409A, as enacted as part of the American Jobs Creation Act of 2004 (Conference Committee Report, H.Rpt. 108-755, pp. 221-227). [65K]

Conference Committee explanation for section 409A (Conference Committee Report, H.Rpt. 108-755, pp. 706-724). [80K].

June 2005 Tax Bulletin, New Rules Governing Written Tax Advice. [183K] Preview the HTML version. [9K]

T.D. 9165, December 20, 2004, adopting the new Circular 230 rules [78K].

T.D. 9201, May 19, 2005, revising the Circular 230 rules to exclude written advice issued after a tax return is filed, advice provided by in-house counsel and negative advice and to clarify the meanings of "prominantly disclosed" and "principal purpose" [62K].

Notice of Proposed Rulemaking, December 30, 2003, the precursor to the new Circular 230 rules [60K].

Notice of Proposed Rulemaking, December 20, 2004, proposing rules applicable to "State or local bond opinions" [61K].

Notice 2005-47, providing an interim and expanded definition of "State or local bond opinion" [26K].

January 2005 Tax Bulletin, 2004 Jobs Act: Overhaul of Tax Shelter Rules. [110K] Preview the HTML version. [12K]

Legislative Material

Pages 160-172 of H.Rpt. 108-755 (the Conference Report) containing sections 811-822 of the Act, enacting the new tax shelter provisions [83K].

Pages 582-604 of H.Rpt. 108-755 (the Conference Report) containing the portion of the Explanatory Statement regarding new tax shelter provisions [92K].

October 2004 Tax Bulletin, New Tax Law Brings Broad Changes to Nonqualified Deferred Compensation Arrangements. [169K] Preview the HTML version. [30K]

Legislative Material

Pages 221-227 of H.Rpt. 108-755 (the Conference Report) containing section 855 of the Act, enacting Code section 409A [102K].

Pages 706-724 of H.Rpt. 108-755 (the Conference Report) containing the portion of the Explanatory Statement regarding new section 409A [107K].

August 2003 Tax Bulletin, Proposed Changes in Accounting Treatment of Stock Options Prompt Review of Stock Plan Design. [473K] Preview the HTML version. [12K]

August 2002 Tax Bulletin, Crackdown on Tax Shelters: Current Enforcement Efforts and Calls for Reforms. [529K] Preview the HTML version. [35K]

Administrative Material

U.S. Department of the Treasury, "The Problem of Corporate Tax Shelters: Discussion, Analysis and Legislative Proposals," July 1999 [436K]

Temporary Regulations

T.D. 8875 [140K], T.D. 8876 [153K], T.D. 8877 [150K], the February 2000 temporary regulations

T.D. 8896 [140K], the August 2000 temporary regulations

T.D. 8961 [56K], the August 2001 temporary regulations

T.D. 9000 [62K], the June 2002 temporary regulations

Legislative Material

S. 2498 [279K], the Tax Shelter Transparency Act, as reported from the Senate Finance Committee

Senate Report 107-189 [125K], Senate Finance Committee Report on S. 2498

JCX-19-02 [170K], Joint Committee on Taxation, "Background and Present Law Relating to Tax Shelters," prepared for March 21, 2002 Senate Finance Committee hearing

H.R. 5095 [330K], the American Competiveness and Corporate Accountability Act of 2002, as introduced in the House

May 2002 Tax Bulletin, Victims of Terrorism Tax Relief Act Encourages
Disaster Relief by Employers and Charities. [473K] Preview the HTML version. [10K]
Legislative Material

H.R. 2884, Victims of Terrorism Tax Relief Act of 2001, which became P.L. 107-134 when signed by President Bush on January 23, 2002. [88K]

Technical Explanation of the Victims of Terrorism Tax Relief Act of 2001 (as passed by the House and Senate on December 20, 2001) by the staff of the Joint Committee on Taxation. [113K]

Estimated Budget Effects of the Victims of Terrorism Tax Relief Act of 2001 (as passed by the House and Senate on December 20, 2001) by the staff of the Joint Committee on Taxation. [17K]

Comparison of the Victims of Terrorism Tax Relief Act of 2001 (as passed by the House on December 13, 2001 and as passed by the Senate) by the staff of the Joint Committee on Taxation. [38K]

Comparison of Estimated Budget Effects of the Victims of Terrorism Tax Relief Act of 2001 (as passed by the House on December 13, 2001 and as passed by the Senate) by the staff of the Joint Committee on Taxation. [18K]

Technical Explanation of the Victims of Terrorism Tax Relief Act of 2001 (as considered by the House on December 13, 2001) by the staff of the Joint Committee on Taxation. [138K]

H.R. 2884, Victims of Terrorism Tax Relief Act of 2001, as passed by the Senate on November 16, 2001. [121K]

Technical Explanation of the Victims of Terrorism Tax Relief Act of 2001 (as passed by the Senate on November 16, 2001) by the staff of the Joint Committee on Taxation. [112K]

H.R. 2884, Victims of Terrorism Relief Act of 2001, as passed by the House of Representatives on September 13, 2001. [34K]

Technical Explanation of the Victims of Terrorism Relief Act of 2001 (as passed by the House on September 13, 2001) by the staff of the Joint Committee on Taxation. [35K]

H.R. 2926, the Air Transportation Safety and System Stabilization Act, which became P.L. 107-42 when signed by President Bush on September 22, 2001. Section 301(a) of this Act extends until November 15, 2001 the due date for the deposit of air transportation taxes and certain other withheld taxes originally due after September 10, 2001 and before November 15, 2001. In addition, the Secretary of the Treasury can extend the November 15th date to as late as January 15, 2002. [67K]

Internal Revenue Service Material

Revenue Procedure 2001-53, providing a list of time-sensitive acts which may be postponed under section 7508 or 7508A of the Code. [190K]

Notice 2001-61, extending the due date for the filing of certain returns and the making of estimated tax payments, tolling for certain periods failure to pay penalties and waiving penalties for certain failures to deposit federal taxes (as the IRS does not have the authority to extend the due date for those deposits) for a broad class of taxpayers affected by the September 11th terrorist attack. [24K]

Notice 2001-63, extending until September 24, 2001 any due date from September 10, 2001 through September 23, 2001 for the filing of returns and claims for refund, the payment of tax (including estimated tax payments), making elections and filing any other federal tax documents for any taxpayer, wherever located, experiencing difficulties arising from the September 11th terrorist attack. [14K]

Notice 2001-68, supplementing Notice 2001-61 by clarifying and expanding the definition of affected taxpayer, listing additional acts for which a postponement is granted and providing other relief. [54K]

Notice 2001-69, in which the IRS states that it will not assert that payments made by an employer to an organization described in section 170(c) of the Code, in exchange for vacation, sick, or personal leave that the employee elects to forgo, constitute gross income or wages of an employee, provided that the payments are made to such organizations before January 1, 2003, and that it will not assert that the opportunity to make such an election results in constructive receipt of gross income or wages for employees. [18K]

Notice 2001-70, taxpayer-elective relief from application of the "mid-quarter" convention under section 168(d)(3) of the Code for taxpayers whose third quarter of the 2001 taxable year includes September 11, 2001. [17K]

Notice 2001-74, expanding the class of taxpayers granted relief from the mid-quarter convention under Notice 2001-70 to include taxpayers whose fourth quarter includes September 11, 2001. [23K]

Notice 2001-77, providing additional air transportation excise tax deposit relief under the Air Transportation Safety and System Stabilization Act (P.L. 107-42). [15K]

Notice 2001-78, while legislation is pending, the IRS will treat payments made by charities to victims of the September 11, 2001 terrorist attacks as related to the charities' exempt purpose if made in good faith under objective standards. [15K]

Notice 2001-79, ignoring certain rent holidays in qualified aircraft leases for purposes of section 467 of the Code. [21K]

Notice 2002-7, in which the IRS, the Department of Labor's Pension and Welfare Pension Benefits Administration and the Pension Benefit Guaranty Corporation grant relief to employee benefit plans under the Victims of Terrorism Tax Relief Act of 2001. [23K]

Notice 2002-15, expanding the relief of Notices 2001-61 and 2001-68 by postponing the due date for applying for certain tentative carryback adjustments under section 6411 of the Code. [23K]

Notice 2002-25, granting partial relied from the substantiation requirements of section 170(f)(8) of the Code for charitable contributions made after September 10, 2001 and before January 1, 2002. [16K]

Announcement 2001-101, relief for tax-exempt bond issuers affected by the September 11th terrorist attack. [22K]

Announcement 2001-103, a grant of relief by the IRS, the Department of Labor's Pension and Welfare Benefits Administration and the Pension Benefit Guaranty Corporation (the "PBGC") from certain penalties relating to Forms 5500 due on or before October 15, 2001, as well as the PBGC's statement of relief relating to premiums, reporting and disclosure and certifications. [22K]

Announcement 2001-112, authorizing taxpayers to redesignate estimated tax payments as employment tax deposits. [17K]

Announcement 2001-117, granting extensions to file to partners, shareholders or beneficiaries of passthrough entities entitled to relief under Notice 2001-61. [14K]

Announcement 2001-124, modifying and expanding the relief granted under Announcement 2001-117. [16K]

Internal Revenue Service Publications

IRS Publication 3833 (March 2002), Disaster Relief: Providing Assistance through Charitable Organizations. [57K]

IRS Publication 3920 (February 2002), Tax Relief for Victims of Terrorist Attacks. [134K]

IRS Publication 3921, Help from the Internal Revenue Service for Those Affected by the Terrorist Attacks on America September 11, 2001. [232K]

September 2001 Tax Bulletin, Guidance for Qualified Plans Regarding the 2001 Tax Act and Determination Letter Filings [473K] Preview the HTML version. [10K]
Notice 2001-42, amending qualfied plans to conform to the 2001 Tax Act [25K]

Announcement 2001-77, revision of determination letter process [33K]

Notice 2001-56, effective dates of certain plan-related 2001 Tax Act provisions [30K]

T.D. 8954, final regulations under I.R.C. § 401(a)(4) (June 29, 2001) [84K]

The Future of the Employee Plans Determination Letter Program, an IRS white paper explaining alternatives to the current process [439K]

Notice 2001-57, sample 2001 Tax Act plan amendments [106K]

July 2001 Tax Bulletin [490K] Preview the HTML version of the article on the pension-related provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001. [14K] Preview the HTML version of the new backup withholding rate article. [3K]

Pension Provisions

P.L. 107-16, Table of Contents and Title VI (Pension and Individual Retirement Arrangement Provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001) [204K]

H.Rpt. 107-84, pp. 115-120, 205-306 (Joint Explanatory Statement of the Committee of Conference, Table of Contents and Title VI, Pension and Individual Retirement Arrangement Provisions) [327K]

Backup Withholding Rate

Announcement 2001-80 [48K].

May 2001 Tax Bulletin, Impending May 16, 2001 Deadline for Amendments of Certain Rabbi Trusts. [75K] Preview the HTML version. [9K]

T.D. 8883, final regulations under Internal Revenue Code section 1032. [148K]

Internal Revenue Service Notice 2000-56. [38K]

February 2001 Tax Bulletin, Federal and New York State Tax and Employer-Related Liens. [272K] Preview the HTML version. [131K]

September 1998 Qualified Small Business Stock Update. [93K] Preview the HTML version. [22K]

Internal Revenue Service Restructuring and Reform Act of 1998. [213K] Preview the HTML version. [111K]

Jim Canty's April 1998 letter to Bill Archer, Chairman of the House Ways & Means Committee, concerning the alternative minimum tax. [35K] Preview the HTML version. [14K]

IRS Notice 97-26, specifying certain private delivery services eligible for the "timely mailing/timely filing" rule. [165K] Preview the HTML version. [13K]

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