The Section is active in providing comments to governmental authorities on tax law. Each of our substantive committees is working on at least one comment project on federal or state tax law.  

August 15, 2011
Click here to view the "Comments on Proposed Revenue Procedure, Notice 2011-62"

August 13, 2011
Click here to view the "COGS Comments on Notice 2011-1".

May 11, 2011
Click here to view "Comments on S.B. 1810."
View Exhibit for S.C. 1810.

March 30, 2011
Click here to view "Franchise Tax Comments."

March 28, 2011
Click here to view "Proposed Regulations - Series LLCs and Cell Companies"

February 22, 2011
Click here to view "Proposed changes to Texas Comptroller Practice and Procedure Rul 1.9 concerning position letters."

October 6, 2010
Click here to view "Comments on proposed amendments to Treasury Circular 230"

May 28, 2010
Click here to view the "Comments on Proposal Regarding Uncertain Tax Positions (Announcement 2010-9, 2010-17 and 2010-30)

November 25, 2009
Tax Section comments pursuade Comptroller.

December 1, 2008
Click here to view the "Comments concerning Request for 409A Documentary Compliance Deadline Extension"

October 16, 2008
Click here to view the "Comments concerning Intermediary Transaction Tax Shelters."

June 10, 2008
Click here to view the "Comments concerning the Treasury Regulations under Section 401(a)9."

April 11, 2008
Click here to view the "Comments concerning the Proposed Regulations-Marketing of RALs."

April 10, 2008
Click here to view the "Comments concerning H.R. 3996 and the Taxation of Carried Interests."

March 18, 2008
Click here to read the Tax Section Chair's testimony on Tax Patent Disclosure Regulations.

January 11, 2008
Click here to view the "Comments concerning 34 TAC Section 3.588 Margin: Cost of Goods Sold."

December 21 2007
Click here to view the "Comments on Proposed Treasury Regulations under Section 6011 and Section 6111."

October 12, 2007
Click here to view the "Comments concerning the Texas Comptroller's Draft Rules as published in the Texas Register on September 14, 2007."

September 14, 2007
Click here to view "Letter of Section of Taxation of State Bar of Texas regarding tax patents and H. R. 1908."

September 6, 2007
Click here to view the “Letter of Section of Taxation of State Bar of Texas regarding H.R. 2834 and the Taxation of Carried Interests.”

January 29, 2007
Click here to view "Comments on Proposed Treasury Regulations under Section 6011 (REG-103038-05), Section 6111 (REG-103039-05), and Section 6112 (REG-103043-05)".

January 23, 2007
Click here to view "Comments Concerning House Bill 3, 79th Legislature, 3rd C.S. (2006)".

June 6, 2006
Click here to view "Comments on Regulations Governing Practice Before the Revenue Service".

December 31, 2005
Click here to view "Comments on Proposed Treasury Regulations under Section 409a".

August 22, 2005
Click here to view "Comments on Notice 2005-43" regarding Transfers of Partnership Equity in Connection with the Performance of Services".