Comment from New York State Bar Association Tax Section
New York State Bar Association Tax SectionSupportAdvocacy
Summary: The Tax Section of the New York State Bar Association submitted a report providing specific recommendations and clarifications regarding the proposed regulations under Section 4966. They advocate for several modifications, including removing the "formal" record requirement for separate identification, providing exceptions for certain types of organizations, and clarifying rules on advisory privileges and taxable distributions.
Please see attached Report No. 1489 of the Tax Section of the
New York State Bar Association, which discusses proposed regulations
under Section 4966.