Legal Advice Issued by Associate Chief Counsel
These documents are legal advice, signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They are issued to assist Service personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. See CCDM 33.1.2, Chief Counsel’s Legal Advice Program.
NOTE: These documents cannot be used or cited as precedent.
| Number | Release Date | Subject |
|---|---|---|
| AM 2012-004 | 06/01/2012 | Dissolution of California Redevelopment Agencies |
| AM 2012-003 | 05/04/2012 | Worthless Stock Loss on Consolidated Group Subsidiary Stock |
| AM 2012-002 | 04/27/2012 | Application of Income Tax Treaties to Lawful Permanent Resident Employees of Foreign Governments |
| AM 2012-001 | 02/17/2012 | Split Eligible Entity Interests |
| AM 2011-004 | 09/30/2011 | Excessive Payments Received under ARRA Section 1603 |
| AM 2011-003 | 08/26/2011 | Treatment of Check-the-Box Election by a Corporation to be Classified as a Partnership |
| AM 2011-002 | 08/05/2011 | Dual Consolidated Losses: Application of SRLY Rules |
| AM 2011-001 | 02/25/2011 | U.S. Residency Status of PRI A-2 Visa Holders |
| AM 2010-007 | 12/23/2010 | Section 179D Deduction and Certain Partnerships and S Corporations |
| AM 2010-006 | 12/17/2010 | Depositary Receipts Programs |
| AM 2010-005 | 11/12/2010 | Hedge Fund Basket Option Contracts |
| AM 2010-004 | 10/15/2010 | Cellulosic Biofuel Claims |
| AM 2010-003 | 07/16/2010 | Tribal Economic Development Bonds Under Sec. 7871(f) |
| AM 2010-002 | 07/09/2010 | Cellulosic Biofuel and "Black Liquor" Producers |
| AM 2010-001 | 03/12/2010 | Black Liquor; Calculating the Claim |
| AM 2009-015 | 11/06/2009 | Treas. Reg. Sec. 1.882.5 - Guidance on Interest Rate for Excess U.S.-Connected Liabilities |
| AM 2009-014 | 10/30/2009 | Tribal Economic Development Bonds Under Sec. 7871(f) and Build America Bonds |
| AM 2009-013 | 10/23/2009 | Application of Notice 2008-91 to Section 956(a)(1) |
| AM 2009-012 | 10/16/2009 | Entity Classification of Liechtenstein Anstalts and Stiftungs |
| AM 2009-011 | 10/09/2009 | Dual Consolidated Losses: Definition of Foreign Use and Application of Exceptions |
| AM 2009-010 | 10/02/2009 | Lending in the United States by Foreign Person Giving Rise to Effectively Connected Income |
| AM 2009-009 | 09/18/2009 | Computation of Qualified Production Activities Income under Sec. 199(c) and the Exclusion of Certain Items of Gross Income under Sec. 114 and Section 101(d) of the American Jobs Creation Act of 2004 |
| AM 2009-008 | 08/28/2009 | Effect of Hedging on Percentage Depletion Computation |
| AM 2009-007 | 08/21/2009 | Exemption for Lignite from the Black Lung Excise Tax when Extracted with Other Ranks of Coal |
| AM 2009-006 | 07/17/2009 | Application of Section 162(m) to Backdated and Misdated Stock Options |
| AM 2009-005 | 07/06/2009 | U.S. Source Retainer Fees and Ranking and Placement Bonuses Derived by Professional Golf and Tennis Players from On-Court Endorsement Contracts |
| AM 2009-004 | 02/13/2009 | Foreign Government Pension Trusts |
| AM 2009-003 | 02/13/2009 | Application of Foreign Earned Income Exclusion and the Combat Zone Exclusion to Civilian Contractors Working in Combat Zones |
| AM 2009-002 | 02/06/2009 | Federal Agency Audit Program: Classification of Workers Performing Services Pursuant to Personal Services Contracts |
| AM 2009-001 | 01/09/2009 | Proper Method of Allocation and Apportionment of Prior Period Compensation Expense Deductions Under Treas. Reg. Sections 1.861-8 and 1.861-14, Temp. Treas. Reg. Sections 1.861-8T and 1.861-14T, and I.R.C. Section 199 |
| AM 2008-013 | 12/19/2008 | Professional Gambler's Wagering Losses and Business Expenses |
| AM 2008-012 | 12/19/2008 | Application of Sec. 172(f) to Costs Included in Inventory Under Sec. 263A |
| AM 2008-011 | 12/12/2008 | Reporting of Wagering Gains and Losses |
| AM 2008-010 | 09/12/2008 | Interaction of I.R.C. Section 965 and Rev. Proc. 99-32 |
| AM 2008-009 | 08/29/2008 | UK Pension Rollovers |
| AM 2008-008 | 07/11/2008 | Applicability of Section 943(c) and (h) to Certain Transactions |
| AM 2008-007 | 07/04/2008 | Dual Consolidated Losses: Application of the Exception to Foreign Use for Certain Interests in Partnerships or Grantor Trusts |
| AM 2008-006 | 05/30/2008 | Reporting Requirements Under Section 6038B |
| AM 2008-005 | 05/16/2008 | Timing of Credit for Foreign Tax Withheld from Wages |
| AM 2008-004 | 03/28/2008 | Generic Legal Advice for Section 48A |
| AM 2008-003 | 02/22/2008 | Treatment of Certain Distributions in Complete Liquidation by a REIT |
| AM 2008-002 | 02/08/2008 | Section 280C(c)(3) - Guidance on Reduced Credit for Increasing Research Activities |
| AM 2008-001 | 01/25/2008 | Dual Consolidated Losses: Reasonable Cause Requests Relating to Periods Where Assessment of Tax Under Section 6501(a) Is Not Permitted |
| AM 2007-017 | 10/31/2007 | Applicability of Section 6695A Penalty to Estate & Gift Appraisals |
| AM 2007-016 | 09/25/2007 | Application of Notice 88-108 to Section 956(a)(1) |
| AM 2007-015 | 07/27/2007 | Section 162(f) and the Character of Relator Fees under the False Claims Act |
| AM 2007-014 | 07/24/2007 | Integration of Convertible Notes with Hedges |
| AM 2007-013 | 06/15/2007 | Exception to the Three-Year Requirement for Residences for Veterans Under Section 143(d)(2)(D) |
| AM 2007-012 | 06/08/2007 | FIN 48 & Tax Accrual Workpapers |
| AM 2007-011 | 05/25/2007 | Auxiliary Power Units (APU) |
| AM 2007-010 | 05/25/2007 | Deductibility of Administrative Expenses of Bankruptcy |
| AM 2007-009 | 05/11/2007 | Application of Sections 1.461-4(d)(6)(ii) and 1.461-5 to Service Contracts |
| AM 2007-008 | 04/20/2007 | Lease-In/Lease-Out ("LILO") and Sale-In/Lease-Out ("SILO") Exit Strategy |
| AM 2007-007 | 03/23/2007 | Taxpayer Use of Section 482 and the Commensurate With Income Standard |
| AM 2007-006 | 02/23/2007 | Elections Under Section 338 With Respect to Foreign Corporate Targets |
| AM 2007-005 | 02/09/2007 | Trusts Holding Interests in a Partnership |
| AM 2007-004 | 02/02/2007 | Variable Purchase Contracts and Share Lending Agreements |
| AM 2007-003 | 02/02/2007 | Construction Allowances for Short Term Leases of Retail Space Not Subject to Sec. 110 |
| AM 2007-002 | 01/26/2007 | State Tax Credit Transfers |
| AM 2007-001 | 01/12/2007 | Qualification for FSC benefits and ETI Exclusions |
| AM 2006-006 | 10/11/2006 | Cost of Restoring Property after Casualty Loss Deduction |
| AM 2006-005 | 10/13/2006 | Subchapter S Banks and the Special Bank Rules |
| AM 2006-004 | Pulled | Adjusted Current Earnings for Certain Mining Property; re-published as CCA 200721019. |
| AM 2006-003 | 09/29/2006 | Allocation of Capitalizable Mixed Service Costs to Ineligible Property |
| AM 2006-002 | 09/29/2006 | Allocation under Sections 338 and 1060 to Assets in a Non-Qualified Nuclear Decommissioning Fund Purchased along with a Nuclear Power Plant |
| AM 2006-001 | 09/26/2006 | Cross-Border Financial Instruments; Hybrid Debt/Equity - Equity in the U.S. |
Page Last Reviewed or Updated: 2012-08-14
