Section 67(e) Trust Investment Expenses Advocacy Documents

Regulatory Comments:

December 5, 2011comment letter on 2011 proposed regulations
February 15, 2011 letter requesting interim guidance for 2010 tax returns
March 8, 2010 letter requesting interim guidance for 2009 tax returns
April 17, 2009 letter with American Bankers Association on proposed regulations
May 23, 2008 comments on proposed regulations
March 12, 2008 letter thanking IRS for interim guidance for 2007 returns
February 8, 2008 letter on need and suggestions for guidance under section 67(e) post-Knight v. Cir.
October 8, 2007comments on proposed regulations and need for extension of comment period and letter to request to testify

Legislative Comments:

Feb. 2013 compendium of legislative proposals (including proposal for full deduction for administration costs of trusts and estates)
May 2, 2012 legislative proposal to Congress on full deduction for administration costs of trusts and estates
September 8, 2008 legislative proposal to Congress

Guidance to Members:

Article (May 2012) on Trust Deductions: Knight, Prop. Regs. Still Govern
Update as of September 15, 2011 - new proposed regulations issued with unbundling requirement once final regulations issued
February 4, 2008 guidance to practitioners filing 2007 Form 1041 post Knight v. Cir.

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