Rev. Rul. 2001-46 Comment - Final revised

COMMENTS ON REVENUE RULING 2001-46The following comments are the individual views of the members of the Section ofTaxation who prepared them and do not represent the position of the American Bar Associationor the Section of Taxation.These comments were prepared by individual members of the Committee on CorporateTax of the Section on Taxation. Principal responsibility was exercised by Erik H. Corwin.Substantive contributions were made by Julie A. Divola, Glen A. Kohl, William M. Richardson,Michael L. Schler, Mark J. Silverman, Lea Anne Storum, Benjamin G. Wells, Rose L. Williams,Philip B. Wright, and Mark L. Yecies. The comments were reviewed by Robert H. Wellen of theSection’s Committee on Government Submissions and by Joseph M. Pari, Council Director forthe Committee on Corporate Tax.Although many of the members of the Section of Taxation who participated in preparingthese comments have clients who would be affected by the federal tax principles addressed bythese comments or have advised clients on the application of such principles, no such member(or the firm or organization to which such member belongs) has been engaged by a client tomake a government submission with respect to, or otherwise to influence the development oroutcome of, the specific subject matter of these comments.Contact Person: Erik H. Corwin(202) 663-6883ecorwin@wilmer.comDate: May 1, 2002COMMENTS ON REVENUE RULING 2001-46EXECUTIVE SUMMARYRevenue Ruling 2001-46 clarifies ...