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The Greystocke Project submitted comments urging the Treasury and IRS to reinstate the guidance project on "basis of grantor trust assets at death" under section 1014, added to the priority guidance plan for fiscal 2015-16 but dropped from the current plan. 
The Greystocke Project is submitting comments on the proposed regs that would clarify, at long last, that excess deductions on termination on an estate or trust are not per se miscellaneous itemized deductions in the hands of the distributees. 
The Greystocke Project is submitting comments on the proposed regs to relieve exempt orgs other than (c)(3)s, 527s, and nonexempt trusts from the requirement to disclose their substantial contributors.
In the end, despite what a couple of Joint Committee staffers told me about who understood what when the statutory language was being hammered out and what the revenue estimates did or did not assume about clawback, I decided to go ahead and submit comments opposing the proposed regs. Full text appended, and this will get a brief mention in the next issue of Jack Straw.
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