Small Business Taxes & Management

IRS Pronouncements--2007


Small Business Taxes & ManagementTM--Copyright 2007, A/N Group, Inc.

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Note. The list below contains a synopses of selected revenue rulings, revenue procedures, notices, announcements and regulations beginning with those issued January 1, 2007. The list is limited to those items we believe to be of interest to small to mid-sized businesses, their advisors, CPAs, etc. Rulings, etc. dealing with banks, insurance companies, foreign operations, nonprofits, exotic transactions, etc. are generally excluded. For a similar listing for prior years, go to:

IRS Pronouncements--2006
IRS Pronouncements--2005
IRS Pronouncements--2004
IRS Pronouncements--2003
IRS Pronouncements--2002
IRS Pronouncements--2001
IRS Pronouncements--2000

We've included the IRB (Internal Revenue Bulletin) reference so you can find the full text on the IRS web site. We've tried to make the list as searchable as possible while keeping the descriptions short. Use the "find-in-page" or "find" feature of your browser to search this list. Be sure to try variations of keywords such as "activities" as well as "activity"; "depreciation" as well as "depreciate". You can download any Bulletin at the IRS website. The Applicable Federal Rate and interest rates on over- and underpayments are updated on our IRS Interest Rates page or, for more details go to the IRS AFR page

Notes.

 

New Additions - Bulletin 52

Rev. Rul. 2007-68 (IRB 2007-52) Interest rates; under- and overpayments; first quarter 2008.

Rev. Proc. 2007-72 (IRB 2007-52) Changes to subprime mortgage loans; tax status of certain securitization vehicles holding the loans.

T.D. 9367 (IRB 2007-52) Sec. 3121; definition of salary reduction agreement; public educational institutions and Sec. 501(c)(3) organizations; annuity contracts purchased on behalf of employees.
T.D. 9366 (IRB 2007-52) Sec. 6033; tax exempt organizations; not currently required to file annual information return; annual electronic notice; REG-104942-07

REG-155669-04 (IRB 2007-52) Sec. 6045; information on sale or exchange of standing timber for lump-sum payment; amend term ownership interest; contractural interest in a sale or exchange of standing timber for a lump-sum payment that is fixed and contingent; crops and natural resources do not include standing timber.

Notice 2007-100 (IRB 2007-52) Sec. 409A; correction of certain failures of nonqualified deferred compensation plans; operational failure.
Notice 2007-99 (IRB 2007-52) Distributions from governmental plans and health and accident insurance; Notice 2007-7 modified.

For the full text of these rulings, go to Internal Revenue Bulletin 2007-52.

 

Cumulative Listings - 2007

Revenue Rulings

Rev. Rul. 2007-68 (IRB 2007-52) Interest rates; under- and overpayments; first quarter 2008.
Rev. Rul. 2007-72 (IRB 2007-50) Diagnostic medical procedures; amounts paid deductible; full body scan; pregnancy test.
Rev. Rul. 2007-71 (IRB 2007-50) 2008 covered compensation tables; permitted disparity; Sec. 401; contributions to defined benefit plans.
Rev. Rul. 2007-69 (IRB 2007-49) Payments by U.S. Department of Veterans Affairs; compensated work therapy program; exempt from federal income tax as veterans benefits; Rev. Rul. 65-18 revoked; Rev. Rul. 72-605 amplified.
Rev. Rul. 2007-67 (IRB 2007-48) Mortality tables; single sum distributions; Sec. 417.
Rev. Rul. 2007-65 (IRB 2007-45) Employer's deduction for contributions; limitation on employer's deduction; welfare benefit funds; Sec. 419; qualified direct costs; cash value life insurance policies.
Rev. Rul. 2007-62 (IRB 2007-41) Low-income housing credit; satisfactory bond; bond factor amounts; January through December 2007.
Rev. Rul. 2007-56 (IRB 2007-39) Interest rates; under- and overpayments; fourth quarter 2007.
Rev. Rul. 2007-60 (IRB 2007-38) Revenue rulings obsolete; Rev. Rul. 75-425.
Rev. Rul. 2007-55 (IRB 2007-38) Fringe benefits aircraft valuation formula; Standard Industry Fare Level; SIFL; noncommercial flights; employer provided aircraft.
Rev. Rul. 2007-59 (IRB 2007-37) Bankruptcy effects of disaster and combat zone relief; postponement of time to file a return; Sec. 7508 and 7508A; no change in date return is last due; no change in priority and dischargeability of the tax for bankruptcy purposes.
Rev. Rul. 2007-58 (IRB 2007-37) List of entities treated as qualified pension or retirement plan; Rev. Rul. 94-62 supplemented.
Rev. Rul. 2007-53 (IRB 2007-37) Rev. Rul. 78-369 revoked; inconsistent with regulations under Sec. 6411; tentative allowance.
Rev. Rul. 2007-52 (IRB 2007-37) Sec. 6402; 6411; definition of liability; statutory notice of deficiency; liabilities identified in a proof of claim filing in bankruptcy; tentative carryback adjustment.
Rev. Rul. 2007-51 (IRB 2007-37) Limitations on setoff under Sections 6402 and 6411; IRS may credit overpayment against unassessed tax liabilities determined in statutory notice; tentative carryback adjustment against unassessed liabilities; Rev. Rul. 54-378 clarified.
Rev. Rul. 2007-57 (IRB 2007-36) Sec. 3402; withholding and information reporting applicable to certain amounts paid to winners of poker tournaments.
Rev. Rul. 2007-49 (IRB 2007-31) Sec. 83; restricted stock; post-grant restrictions; restrictions imposed on substantially vested stock causing stock to become substantially nonvested; exchange of stock.
Rev. Rul. 2007-48 (IRB 2007-30) Nonexempt employees' trusts; tax consequences to employees, employer, and trust; highly compensated employees; vesting of employee's interests; Rev. Rul. 74-299 amplified.
Rev. Rul. 2007-47 (IRB 2007-30) Insurance premium; arrangement for reimbursement of inevitable future costs; not requisite insurance risk; Rev. Rul. 89-96 amplified.
Rev. Rul. 2007-46 (IRB 2007-30) Low-Income housing credit; satisfactory bond; bond factor; January through September 2007.
Rev. Rul. 2007-45 (IRB 2007-28) Special use value; farms; 2007 interest rates; Section 2032A election; estate tax.
Rev. Rul. 2007-43 (IRB 2007-28) Sec. 411; partical termination; turnover; presumption of partial termination where turnover rate of employees participating in qualified plan is at least 20 percent.
Rev. Rul. 2007-42 (IRB 2007-28) Sec. 355; corporation holding membership interest in a limited liability company; active conduct of a trade or business; Rev. Rul. 92-17 modified.
Rev. Rul. 2007-39 (IRB 2007-26) Interest rates; over- and underpayments; third quarter beginning July 1, 2007.
Rev. Rul. 2007-41 (IRB 2007-25) Exempt organizations; political campaigns; examples; 501(c)(3) organization.
Rev. Rul. 2007-40 (IRB 2007-25) Partnership property; transfer; transfer of partnership property to partner in satisfaction of guaranteed payment; sale or exchange vs. distribution; Sec. 707(c); 731; 1001.
Rev. Rul. 2007-38 (IRB 2007-25) Insurance companies; aggregation of multiple modified endowment contracts issued by same insurance company; MECs; exchanges; Sec. 1035; 72.
Rev. Rul. 2007-37 (IRB 2007-24) Cancellation of distributorship agreement; sale or exchange of property; capital gain; recapture.
Rev. Rul. 2007-35 (IRB 2007-22) Revenue rulings obsoleted; Rev. Rul. 74-245; 82-45; income subject to foreign legal restrictions; blocked income; Sec. 482.
Rev. Rul. 2007-34 (IRB 2007-22) LIFO Price indexes, March, 2007.
Rev. Rul. 2007-31 (IRB 2007-21) Sec. 118; contributions to the capital of a corporation; nonshareholder contributions; payments received under federal universal service support mechanisms.
Rev. Rul. 2007-30 (IRB 2007-21) Sec. 199; Income attributable to domestic production activities; qualifying in-kind partnerships; partnership engaged in extraction and processing of minerals.
Rev. Rul. 2007-24 (IRB 2007-21) Sec. 1035; certain exchanges of insurance policies; receipt of check issued by insurance company under nonqualified annuity contract is a taxable distribution; check endorsed to a second insurance company for annuity purchase.
Rev. Rul. 2007-28 (IRB 2007-18) Sec. 274; geographical areas included in North American area; Rev. Rul. 2003-109 superseded.
Rev. Rul. 2007-27 (IRB 2007-18) LIFO Price indexes, February, 2007.
Rev. Rul. 2007-26 (IRB 2007-16) ICE Futures; United Kingdom; Reognised Investment Exchange; qualified board of exchange; Sec. 1256(g)(7)(C).
Rev. Rul. 2007-22 (IRB 2007-14) Frivolous tax returns; citizens of a state argument; natural-born citizen; sovereign state.
Rev. Rul. 2007-21 (IRB 2007-14) Frivolous tax returns; summary record of assessment requirement for collection of overdue taxes; Form 23C; Assessment Certificate Summary Record of Assessments.
Rev. Rul. 2007-20 (IRB 2007-14) Frivolous tax returns; voluntary compliance argument.
Rev. Rul. 2007-19 (IRB 2007-14) Frivolous tax returns; wages not taxable income.
Rev. Rul. 2007-18 (IRB 2007-13) LIFO Price indexes, January, 2007.
Rev. Rul. 2007-17 (IRB 2007-13) Fringe benefits; aircraft valuation formula; Standard Industry Fare Level; SIFL; terminal charge; first half of 2007; noncommercial flights.
Rev. Rul. 2007-16 (IRB 2007-13) Interest rates; over- and underpayments; second quarter beginning April 1, 2007.
Rev. Rul. 2007-14 (IRB 2007-12) Obsolete revenue rulings; Rev. Rul. 54-19 (obsoleted in part); 55-132; 56-462; 56-518; 57-505; 58-370; 58-500; 69-212; 71-477.
Rev. Rul. 2007-13 (IRB 2007-11) Investor control and general public; taxation of variable contracts; insurance and annuities; grantor of grantor trust as owner of life insurance contract owned by trust; transfer for valuable consideration; Sec. 101.
Rev. Rul. 2007-12 (IRB 2007-11) Payroll taxes on deferred compensation; accrual method; Sec. 461; Rev. Rul. 69-587 revoked; Rev. Rul. 96-51 amplified.
Rev. Rul. 2007-11 (IRB 2007-9) LIFO Price indexes, December, 2006.
Rev. Rul. 2007-8 (IRB 2007-7) Sec. 357(c)(1) does not apply to transactions that qualify as reorganizations described in 368(a)(1)(A), (C), (D), or (G); Rev. Ruls. 75-161 and 76-188 obsoleted; Rev. Rul. 78-330 modified.
Rev. Rul. 2007-7 (IRB 2007-7) Investor control and general public; taxation of variable contracts; insurance and annuities; beneficial ownership; definition of general public; Rev. Ruls. 81-225 and 2003-92 clarified and amplified.
Rev. Rul. 2007-6 (IRB 2007-5) LIFO Price indexes, November, 2006.
Rev. Rul. 2007-5 (IRB 2007-5) Low-income housing credit; satisfactory bond; bond factor; January through March 2007.
Rev. Rul. 2007-4 (IRB 2007-4) Section 1274A; inflation adjusted numbers for 2007; Rev. Rul. 2005-76 supplemented and superseded.
Rev. Rul. 2007-3 (IRB 2007-4) Executory contract liabilities; when does accrual basis taxpayer incur liablity for services or insurance; year of deduction.
Rev. Rul. 2007-1 (IRB 2007-3) Credit card nonsufficient funds fee; NSF; not interest for tax purposes.

 

Revenue Procedures

Rev. Proc. 2007-72 (IRB 2007-52) Changes to subprime mortgage loans; tax status of certain securitization vehicles holding the loans.
Rev. Proc. 2007-71 (IRB 2007-51) Tax sheltered annuities; written program; public schools; model amendments; Sec. 403(b).
Rev. Proc. 2007-70 (IRB 2007-50) Optional standard mileage rates; business use 50.5 cents; 19 cents for medical and moving; rules for substantiating deductible expenses; Rev. Proc. 2006-49 superseded.
Rev. Proc. 2007-69 (IRB 2007-49) Sec. 45H; small business refiners certification.
Rev. Proc. 2007-67 (IRB 2007-48) Change in accounting method; request to revise year of change for Form 3115 that is pending in national office; modifies period for taking into account a net positive section 481(a) admustment; Rev. Proc. 97-27 modified.
Rev. Proc. 2007-66 (IRB 2007-45) Cost-of-living adjustments for 2008; income tax rates; personal exemption; standard deduction; Rev. Procs. 90-12 and 2002-41 modified.
Rev. Proc. 2007-65 (IRB 2007-45) Sec. 704; 45; requirements for partnerships; safe harbor in allocating wind energy production tax credits.
Rev. Proc. 2007-64 (IRB 2007-42) Requests by corporations for changes in annual accounting periods filed under Rev. Proc. 2006-45; Rev. Proc. 2006-45 modified and clarified.
Rev. Proc. 2007-63 (IRB 2007-42) Per diem amounts; substantiating business expenses of traveling away from home; Rev. Proc. 2006-41 superseded; travel.
Rev. Proc. 2007-62 (IRB 2007-41) S corporations; additional simplified method; late election; late entity classification elections; Rev. Procs. 2003-43, 2004-48 supplemented.
Rev. Proc. 2007-59 (IRB 2007-40) Sec. 704; procedure permits certain partnerships to aggregate gains and losses from qualified financial assets; reverse Sec. 704(c) allocation.
Rev. Proc. 2007-60 (IRB 2007-39) Sec. 179; correction to inflation adjusted amounts; stautory changes; expensing depreciable property; Rev. Proc. 2006-53 modified.
Rev. Proc. 2007-56 (IRB 2007-34) Sec. 7508; 7508A; postponement time-sensitive acts; Armed Forces; combat zone; Presidentially declared disaster; terroristic or military action.
Rev. Proc. 2007-55 (IRB 2007-33) Sec. 42; unused housing credit carryovers allocated to qualified states; 2007.
to qualified states; 2007.
Rev. Proc. 2007-54 (IRB 2007-31) Sec. 42; service establishing procedure for temporary relief; low-income housing owners; housing credit agencies; major disaster areas declared by the President; Rev. Proc. 95-28 superseded.
Rev. Proc. 2007-53 (IRB 2007-30) Accounting for advance trade discounts; Westpac Pacific Food; Advance Trade Discount Method; automatic consent to change; Rev. Proc. 2002-9 modified and amplified.
Rev. Proc. 2007-52 (IRB 2007-30) Procedures for issuing determination letters and rulings; exempt status of organizations under Sec. 501 and 521; revocation and modification of determination letters; Rev. Proc. 90-27 superseded.
Rev. Proc. 2007-49 (IRB 2007-30) Administrative programs; correction programs; retirement plans; Rev. Proc. 2006-27 modified.
Rev. Proc. 2007-48 (IRB 2007-29) Safe harbor method of accounting for rotable spare parts; depreciable assets; automatic consent procedures for change in accounting method; Rev. Rul. 2003-37; Rev. Proc. 2002-9 modified and amplified.
Rev. Proc. 2007-47 (IRB 2007-29) Conditions under which a research agreement does not result in private business use under Sec. 141(b); Rev. Proc. 97-14 modified and superseded.
Rev. Proc. 2007-46 (IRB 2007-29) Sample testamentary charitable lead annuity trust; CLAT.
Rev. Proc. 2007-45 (IRB 2007-29) Sample inter vivos charitable lead annuity trust; CLAT; nongrantor CLAT; alternate provisions; sample trust.
Rev. Proc. 2007-44 (IRB 2007-28) Qualification; determination letters; staggered remedial amendment periods; Rev. Proc. 2005-66 clarified, modified, and superseded; Rev. Proc. 2005-16 modified.
Rev. Proc. 2007-41 (IRB 2007-26) Procedures designating securities and commodities eligible positions for safe harbor valuation regulations.
Rev. Proc. 2007-40 (IRB 2007-26) Requirements for participating as an authorized IRS e-file provider; Rev. Proc. 2005-60 superseded.
Rev. Proc. 2007-39 (IRB 2007-25) Addition to the no-rule rev. proc.; letter rulings or determination letters; whether a transfer is a gift under Sec. 102(a); Rev. Proc. 2007-3 amplified.
Rev. Proc. 2007-38 (IRB 2007-25) Requirements for completing and submitting Form 8655 Reporting Agent Authorization; Rev. Proc. 2003-69 modified and superseded.
Rev. Proc. 2007-35 (IRB 2007-23) Income attributable to domestic production activities; statistical sampling methodologies; Sec. 199.
Rev. Proc. 2007-34 (IRB 2007-23) Qualified production activities income; QPAI; W-2 wages; partnerships and S corporations; calculation at entity level; Sec. 199.
Rev. Proc. 2007-36 (IRB 2007-22) Health Savings Accounts; HSAs; inflation adjustments; Health Opportunity Patient Empowerment Act of 2006 maximum annual contribution changes; inflation adjustments for 2008; Rev. Proc. 2006-53 modified and superseded.
Rev. Proc. 2007-32 (IRB 2007-22) Gaming Industry Tip Compliance Agreement; GITCA; Rev. Proc. 2003-35 superseded; voluntary agreements establishing minimum tip rates for tipped employees.
Rev. Proc. 2007-31 (IRB 2007-19) Qualified mortgage bonds; mortgage credit certificates; national median gross income; Sec. 143; Rev. Proc. 2006-20 obsoleted in part.
Rev. Proc. 2007-30 (IRB 2007-18) Automobile owners and lessees; trucks and vans; depreciation deduction limitations; lease inclusion table; auto lease.
Rev. Proc. 2007-28 (IRB 2007-16) Sec. 911(d)(1); eligibility requires; adverse conditions in a foreign country preclude meeting requirements; list of countries and dates subject to waiver.
Rev. Proc. 2007-27 (IRB 2007-14) Safe harbor under Sec. 527(l); waiver of amounts due for failure to comply with certain reporting requirements; reasonable cause but not willful neglect.
Rev. Proc. 2007-26 (IRB 2007-13) Average area purchase price safe harbor; qualified mortgage bonds; qualified mortgage credit certificates; QMB; MCC; Rev. Proc. 2006-17 obsoleted in part.
Rev. Proc. 2007-25 (IRB 2007-12) Disclosure of certain penalties under Sec. 6707A(e) on forms filed with the U.S. Securities and Exchange Commission; SEC; Rev. Proc. 2005-51 penalty; Rev. Proc. 2005-51 amplified.
Rev. Proc. 2007-23 (IRB 2007-10) Net consideration method; accounting for certain patent cross licensing arrangements; withholding and capitalization purposes.
Rev. Proc. 2007-22 (IRB 2007-10) User fees; From 8802, Application for United States Residency Certification; electronic payment of fees effective April 2, 2007.
Rev. Proc. 2007-21 (IRB 2007-9) Penalty under sec. 6707; 6707A; recission of penalties if violation is with respect to a reportable transaction other than a listed transaction.
Rev. Proc. 2007-20 (IRB 2007-7) Contractural protection filter; reportable transaction; Reg. Sec. 1.6011-4(b)(4); Rev. Proc. 2004-65 modified and superseded.
Rev. Proc. 2007-17 (IRB 2007-4) Pre-Filing Agreement (PFA) program continued; Rev. Proc. 2005-12 superseded.
Rev. Proc. 2007-16 (IRB 2007-4) Automatic consent allowing taxpayer to make change in method of accounting for certain depreciable or amortizable property after its disposition; waiver of two-year rule in Rev. Rul. 90-38; conformance with Reg. Sec. 1.446-1(3)(2)(ii)(d); Rev. Procs. 2000-38, 2000-50, and 2002-9 modified; Rev. Proc. 2004-11 superseded.
Rev. Proc. 2007-14 (IRB 2007-4) Automatic consent to change accounting method for services or insurance to comply with Rev. Rul. 2007-3; Rev. Proc. 2002-9 modified and amplified.
Rev. Proc. 2007-12 (IRB 2007-4) Real estate reporting sale of principal residence; written assurances to be obtained from seller; Rev. Proc. 98-20 superseded.
Rev. Proc. 2007-13 (IRB 2007-3) Services eligible to be evaluated at cost; Sec. 482; Announcement 2006-50; Notice 2007-5.
Rev. Proc. 2007-11 (IRB 2007-2) Maximum vehicle values; special valuation rules; Sec. 1.61-21(d); cents per mile.
Rev. Proc. 2007-8 (IRB 2007-1) User fees for employee plans and exempt organizations; letter rulings; determination letters; Rev. Proc. 2006-8 superseded.
Rev. Proc. 2007-7 (IRB 2007-1) Areas in which rulings will not be issued; Associate Chief Counsel (International); revised procedures; Rev. Proc. 2006-7 superseded.
Rev. Proc. 2007-6 (IRB 2007-1) Employee plans determination letters; revised procedures; qualified status of employee plans; Sec. 401(a); 403(a); 409; 4975; Rev. Proc. 2006-6 superseded.
Rev. Proc. 2007-5 (IRB 2007-1) Technical advice; revised procedures; area managers and appeals offices; employee plans area; actuarial matters; exempt organizations; Rev. Proc. 2006-5 superseded.
Rev. Proc. 2007-4 (IRB 2007-1) Rulings and information letters; issuance procedures; revised procedures; matters relating to code currently under jurisdiction of the Office of the Division Commissioner Tax Exempt and Government Entities; Rev. Proc. 2006-4 superseded.
Rev. Proc. 2007-3 (IRB 2007-1) Areas in which rulings will not be issued; domestic areas; determination letters; Rev. Proc. 2006-3 superseded.
Rev. Proc. 2007-2 (IRB 2007-1) Technical advice; technical expedited advice; technical advice memoranda; TAM; taxpayer rights when field office requests a TAM regarding a tax matter; Rev. Proc. 2006-2 superseded.
Rev. Proc. 2007-1 (IRB 2007-1) Letter rulings; information letters; determination letters; revised procedures; Rev. Proc. 2006-1 superseded.

 

Regulations

T.D. 9367 (IRB 2007-52) Sec. 3121; definition of salary reduction agreement; public educational institutions and Sec. 501(c)(3) organizations; annuity contracts purchased on behalf of employees.
T.D. 9366 (IRB 2007-52) Sec. 6033; tax exempt organizations; not currently required to file annual information return; annual electronic notice; REG-104942-07.
T.D. 9363 (IRB 2007-49) Sec. 6011; 6033; rules and procedures for filing corporate returns; magnetic media; S corporations; assets of $10 million or more; Froms 1120 and 1120S; private foundations; Sec. 4947 trusts.
T.D. 9362 (IRB 2007-48) Sec. 905; U.S. taxpayer's obligation to notify IRS of a foreign tax redetermination; change that could affect foreign tax credit; Sec. 6689; civil penalty for failure to notify the IRS.
T.D. 9361 (IRB 2007-47) Sec. 368; tax treatment of post-reorganization transfers of assets or stock of a party to the reorganization.
T.D. 9359 (IRB 2007-45) Circular 230; amendments; non-shelter items; best practices; covered opinions; other written advice published as T.D. 9165, 9201.
T.D. 9360 (IRB 2007-43) Sec. 1291; elections; passive foreign investment company excess distribution regime.
T.D. 9354 (IRB 2007-41) Sec. 21; child and dependent care credit; statutory changes; Rev. Ruls. 76-278; 76-288 obsoleted.
T.D. 9353 (IRB 2007-40) Sec. 1045; partnerships and partners; partnership's sale of qualified small business stock; QSB stock; partner's sale of QSB stock distributed by partnership.
T.D. 9356 (IRB 2007-39) Sec. 7701; explanation of treatment of certain disregarded entities; qualified Sub S subsidiaries; single-owner eligible entities; separate from owners for purposes of paying and reporting federal employment and certain excise taxes.
T.D. 9349 (IRB 2007-39) Sec. 125; removal of temporary regulations relating to benefits offered to participants under a cafeteria plan.
T.D. 9352 (IRB 2007-38) Sec. 6112; rules relating to list maintenance obligation of material advisors who must maintain lists under Sec. 6112.
T.D. 9351 (IRB 2007-38) Sec. 6111; rules relating to the disclosure of reportable transactions by material advisors; Sec. 6111; 6112.
T.D. 9350 (IRB 2007-38) Sec. 6011; rules relating to disclosure of reportable transactions; material advisors; Sec. 6111; 6112.
T.D. 9347 (IRB 2007-38) Sec. 6655; estimated tax payments for corporations; Rev. Rul. 67-93, 76-450 and 78-257 obsoleted.
T.D. 9355 (IRB 2007-37) Sec. 6411; REG-118886-06; tentative carryback adjustment reduced by unassessed amounts under certain circumstances; technical revisions.
T.D. 9348 (IRB 2007-37) Sec. 2642; qualified severance of a trust for generation skipping transfer tax purposes; GST.
T.D. 9345 (IRB 2007-36) Sec. 367; 1248; attribution of earnings and profits to shares of controlled foreign corporations involved in nonrecognition transactions; foreign partnership selling stock of corporation.
T.D. 9344 (IRB 2007-36) Sec. 7425; 6343; REG-148951-05 discharge of liens and return of wrongfully levied property; notices and claims.
T.D. 9343 (IRB 2007-36) Sec. 1502; 953; IRS appointment of domestic substitute agent when group's parent is foreign corporation; Sec. 7872.
T.D. 9340 (IRB 2007-36) Sec. 403; 414; 501; tax-shelter annuities; custodial accounts of public schools; tax-exempt organizations; 403(b) contracts.
T.D. 9341 (IRB 2007-35) Sec. 1502; recalculation of basis and excess loss accounts in subsidiary shares; result of intercompany transactions; subsidiary stock treated as worthless.
T.D. 9339 (IRB 2007-35) Sec. 1397E; REG-121475-03; qualified zone academy bonds; QZABs; holders of those bonds.
T.D. 9338 (IRB 2007-35) Sec. 6038; 6038A; information required regarding certain related party transactions of certain foreign corporations and certain foreign-owned domestic corporations; penalties.
T.D. 9337 (IRB 2007-35) Sec. 3402; withholding exemption certificate; IRS notification to employer of marital status and maximum number of withholding exemptions permitted.
T.D. 9336 (IRB 2007-35) Sec. 6012; filing requirements for Subchapter T cooperatives; Form 1120-C; Announcements 84-26 and 84-37 obsoleted.
T.D. 9335 (IRB 2007-34) Sec. 6033; disclosure obligations; prohibited tax shelter transactions; tax-exempt entities are parties.
T.D. 9334 (IRB 2007-34) Sec. 4965; REG-142039-06; requirement of a return to accompany payment of excise taxes; entity-level and manager-level excise taxes; prohibited tax shelter transactions; tax exempt entities.
T.D. 9333 (IRB 2007-33) Sec. 6404; REG-149036-04; suspension of interest, penalty, additional to tax, or additional amounts; listed transactions; undisclosed reportable transactions.
T.D. 9331 (IRB 2007-32) Sec. 408; non-bank trustees; governmental entities.
T.D. 9329 (IRB 2007-32) Sec. 1502; electronic filing of certain statements required of consolidated returns.
T.D. 9330 (IRB 2007-31) Sec. 382; REG-144540-06; treatment of prepaid income under built-in gain provisions.
T.D. 9326 (IRB 2007-31) Sec. 954; controlled foreign corporation; CFC; distributive share of partnership income excluded; foreign personal holding company income.
T.D. 9327 (IRB 2007-28) Sec. 6103; circumstances under which Treasury Department officers or employees may disclose returns and return information.
T.D. 9328 (IRB 2007-27) Sec. 475; safe harbor; dealers in securities and dealers in commodities; election to value positions reported on certain financial statements.
T.D. 9325 (IRB 2007-24) Sec. 401; rules permitting in-service distributions to be made to a participant from a pension plan upon participant's normal retirement age; definition of normal retirement age; Sec. 411(d)(6); elimination of certain in-service distribution rights.
T.D. 9324 (IRB 2007-22) Sec. 402A; taxation of distributions from designated Roth accounts under qualified cash or deferred arrangements under Sec. 401(k).
T.D. 9323 (IRB 2007-20) Sec. 871; exclusion from gross income of portfolio interest paid to nonresident alien individual or foreign corporation; partnerships or trusts with foreign partners, beneficiaries or owners.
T.D. 9321 (IRB 2007-19) Sec. 409A; nonqualifed deferred compensation plans; definition; subject to Sec. 409A; statutory effective date; initial and subsequent deferral elections; time and form of payment; acceleration of payment; Notice 2005-1 obsoleted in part; Notice 2006-4 superseded in part; Notice 2006-64 superseded for taxable years on or after January 1, 2008.
T.D. 9322 (IRB 2007-18) Sec. 1502; REG-156420-06; guidance to corporations filing consolidated returns; anti-avoidance rule; revise anti-loss reimportation rule; disposition of stock of a subsidiary at a loss.
T.D. 9319 (IRB 2007-18) Sec. 415; limitation on benefits and contributions under qualified plans; updates for statutory changes; comforming changes to regulations under Secs. 401(a)(9), 401(k), 457.
T.D. 9320 (IRB 2007-17) Sec. 985; translation rates; translating into dollars amounts transferred by a qualified business unit (QBU) to home office or parent corporation; dollar approximate separate transactions method; DASTM.
T.D. 9318 (IRB 2007-17) Sec. 263A; self-constructed property that is considered produced on a routine and repetitive basis; simplified service cost method; simplified production method; numerous substantially identical assets.
T.D. 9317 (IRB 2007-16) Sec. 199; deduction for income attributable to domestic production activities; transactions involving online software; agricultural and horticultural cooperatives.
T.D. 9316 (IRB 2007-16) Sec. 368; REG-146247-06; continuity of interest requirement for corporate reorganizations; proprietary interest in target corporation preserved; valuation method.
T.D. 9315 (IRB 2007-15) Sec. 1503; dual consolidated losses; exception to general prohibition against uses losses to reduce taxable income of another member; dual resident corporation; Notice 2006-13 obsoleted; Rev. Proc. 2000-42 obsoleted in part.
T.D. 9314 (IRB 2007-14) Sec. 168; 1031; 1033; depreciation of property acquired in a like-kind exchange; involuntary conversion MACRS.
T.D. 9313 (IRB 2007-13) Sec. 368; REG-157834-06; qualifications of certain transactions as reorganizations; 368(a)(1)(D); no stock and/or securities of the acquiring corporation is issued and distributed in the transaction.
T.D. 9312 (IRB 2007-12) Sec. 181; Reg-115403-05; deductions for the cost of producing file and television productions.
T.D. 9311 (IRB 2007-10) Sec. 367; gain recognition agreements; effect on existing agreements; update cross-references; REG-147144-06.
T.D. 9310 (IRB 2007-9) Sec. 412; mortality tables; current liability; pension funding requirements.
T.D. 9308 (IRB 2007-8) Sec. 671; reporting requirements for widely held fixed investment truts; WHFITs.
T.D. 9309 (IRB 2007-7) Sec. 6664; circumstances that end period within which a taxpayer may file an amended return that constitutes a qualified amended return; underpayment; accuracy-related penalty on underpayments.
T.D. 9307 (IRB 2007-7) Sec. 446(e); 1016(a)(2); Changes in accounting methods; changes in depreciation or amortization.
T.D. 9306 (IRB 2007-6) User fees for entering into and restructuring or reinstating installment agreements; $105 and $45.
T.D. 9299 (IRB 2007-6) Sec. 9802; exception to general nondiscrimination requirements; group health plans; church plans evidence of good health.
T.D. 9298 (IRB 2007-6) Sec. 9802; prohibition on group health plans discriminating in eligibility or premiums; limited exception to nondiscrimination requirements.
T.D. 9303 (IRB 2007-5) Sec. 368; REG-125632-06; qualification of certain transactions as reorganizations where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction.
T.D. 9302 (IRB 2007-5) Sec. 409; requirements for employee stock ownership plans; ESOPs; stock of S corporations.
T.D. 9301 (IRB 2007-1) Sec. 63; Housing for individuals displaced by Hurricane Katrina provided by taxpayers in their principal residence; REG-152043-05.
T.D. 9300 (IRB 2007-1) Sec. 6011; regulatory obstacles to electronic filing of certain business income tax returns and other forms; signature requirement; attachments.

 

Proposed Regulations

REG-155669-04 (IRB 2007-52) Sec. 6045; information on sale or exchange of standing timber for lump-sum payment; amend term ownership interest; contractural interest in a sale or exchange of standing timber for a lump-sum payment that is fixed and contingent; crops and natural resources do not include standing timber.
REG-151884-03 (IRB 2007-51) Sec. 381; accounting method or combination of methods to use following certain corporate reorganizations and tax-free liquidations.
REG-127770-07 (IRB 2007-50) Sec. 860G; list of permitted loan modifications to include certain modifications of commercial mortgages; REMICs.
REG-133300-07 (IRB 2007-49) Sec. 401; 402; 411; 4979; automatic contribution arrangements; eligible rollover distributions; forfeitures; excise tax on certain excess contributions and excess aggregate contributions.
REG-134923-07 (IRB 2007-47) User fees; initial and renewed enrollment to become an enrolled actuary.
REG-114125-07 (IRB 2007-46) Sec. 861; source of compensation for labor or personal services.
REG-104206-06 (IRB 2007-46) Sec. 1441; withholding and reporting obligations of withholding agent; publicly traded corporation; dividend or distribution; exchange for stock.
REG-138637-07 (IRB 2007-45) Circular 230; standards with respect to tax returns; penalty for preparing return that reflects an understatement of tax liability; Small Business and Work Opportunity Tax Act of 2007.
REG-107592-00 (IRB 2007-44) Sec. 1502; transactions involving debt obligations and securities between members of a consolidated group; insurance between consolidated group.
REG-129916-07 (IRB 2007-43) Sec. 6011; patented transactions category added to reportable transactions; patented transaction defined.
REG-143326-05 (IRB 2007-43) Sec. 1361; 1362; 1366; S corporations; family shareholder rules; electing small business trusts; suspended losses to spouses and former spouses; inadvertently terminated or invalid qualified subchapter S subsidiary elections; remove or update obsolete references.
REG-113891-07 (IRB 2007-42) Sec. 436; benefit restrictions for underfunded defined benefit pension plans; funding balances maintained.
REG-143397-05 (IRB 2007-41) Sec. 704; 737; distributions of property after two partnerships engage in an assets-over merger; gain or loss property.
REG-148393-06 (IRB 2007-39) Sec. 402; payment from qualfied plan for accident or health insurance premium general constitutes distribution; distribution taxable in year premium paid; not excluded from gross income under Sec. 104, 104, or 106.
REG-142695-05 (IRB 2007-39) Sec. 125; cafeteria plans; REG-243025-96 and REG-117162-99 withdrawn; Rev. Ruls. 69-141, 2002-41, 2003-102, 2005-24, 2006-36, and Notices 89-110 and 2002-45 modified.
REG-116215-07 (IRB 2007-38) Sec. 6104; 6110; information made available by the IRS for public inspection; materials publicly available.
REG-118719-07 (IRB 2007-37) Sec. 817; diversification requirements; list of holders expanded.
REG-128843-05 (IRB 2007-37) Sec. 2642; generation-skipping transfer tax; GST; severance of trusts; effective under state law.
REG-128224-06 (IRB 2007-36) Sec. 67; types of costs incurred by estates or non-grantor trusts that are fully deductible in calculating adjusted gross income; costs unique to estate or trust; not miscellaneous itemized deductions; deductions to exceed 2 percent of adjusted gross income.
REG-101001-05 (IRB 2007-36) Sec. 165; deduction for a loss sustained from abandoned stock or other securities.
REG-149036-04 (IRB 2007-34) Sec. 6404; suspension of interest, penalties; additions to tax; or additional amounts.
REG-114084-04 (IRB 2007-33) Sec. 42; guidance concerning taxpayers' requests to housing credit agencies to obtain qualified contract for acquisition of low-income housing credit building.
REG-163195-05 (IRB 2007-33) Sec. 3406; backup withholding for reportable payments made through a Qualified Payment Card Agent; QPCA.
REG-128274-03 (IRB 2007-33) Sec. 42; low-income housing credit; amend utility allowances regulations.
REG-147171-05 (IRB 2007-32) Sec. 274; deduction for expenses; business aircraft for entertainment.
REG-119097-05 (IRB 2007-28) Sec. 2036; 2039; portion of trust that is properly includable in grantor's gross estate; retained right to use property.
REG-103842-07 (IRB 2007-28) Sec. 199; modify the definition of qualified film produced by a taxpayer; closing of the books election.
REG-143797-06 (IRB 2007-26) Sec. 4980G; employer comparable contributions; Health Savings Accounts; HSAs.
REG-149856-03 (IRB 2007-24) Sec. 152; dependent child claim by parents divorced, legally separated under a decree of separate maintenance; separated under a written separation agreement or who live apart at all times during the last 6 months of the calendar year.
REG-123365-03 (IRB 2007-23) Sec. 355; separate affiliated group; SAG; treated as one corporation for purposes of active trade or business requirement; ATB; activities of partnership.
REG-143316-03 (IRB 2007-21) Sec. 2953l guidance to determine amount deductible from gross estate for claims against estate under Sec. 2053(a)(3); amount actually paid; potential claims; contested claims; claims by family members and related entities; unenforceable claims; recurring payments.
REG-144859-04 (IRB 2007-20) Sec. 1367; S corporations; definition of open account debt; adjustments in basis of indebtedness of S corporation to a shareholder for shareholder advances and repayments on open account debt.
REG-156779-06 (IRB 2007-17) Sec. 901; determination of amount of taxes paid for purposes of Sec. 901.
REG-158677-05 (IRB 2007-16) Sec. 1361; bank as an S corporation; no effect on special rules for banks under the Code.
REG-153037-01 (IRB 2007-15) Sec. 7603; 7609; how summonses may be served on third-party recordkeepers; third-party summonses subject to notice requirements; suspension of period of limitation if court proceeding challenging summons.
REG-100841-97 (IRB 2007-12) Sec. 6159; acceptance and rejection of installment agreements; terms of agreements; modification and termination by Service; appeal procedures.
REG-159444-04 (IRB 2007-9) Sec. 6325; procedures for obtaining release of federal tax lien; discharge of federal tax lien; person whose property is property is encumbered by a federal tax lien but does not owe the tax giving rise to the lien.
REG-157711-02 (IRB 2007-8) Sec. 358; 362; 1502; consolidated group; transfer of a loss share of subsidiary stock; basis determination; reflection of gains and losses in the bases of members' shares; allocation of investment adjustments; attributes of subsidiary; duplicated loss on transferred shares.

 

Notices

Notice 2007-100 (IRB 2007-52) Sec. 409A; correction of certain failures of nonqualified deferred compensation plans; operational failure.
Notice 2007-99 (IRB 2007-52) Distributions from governmental plans and health and accident insurance; Notice 2007-7 modified.
Notice 2007-94 (IRB 2007-51) Retirement plans; qualification; list of changes; determination letters; Rev. Proc. 2007-44.
Notice 2007-98 (IRB 2007-50) Phase-out of qualified hybrid motor vehicle credit; new advanced lean burn technology; American Honda Motor Company; January 1, 2008.
Notice 2007-97 (IRB 2007-49) Defines liquid hydrocarbons derived from biomass; credits and payments provided for alternative fuel and alternative fuel mixtures; Sec. 34; 6426; 6427.
Notice 2007-95 (IRB 2007-49) Section 901; foreign tax credit; revised effective date for regulations amending legal liability or technical taxpayer rule and noncompulsory payment rules.
Notice 2007-93 (IRB 2007-48) Describes how amendment to Sec. 6404(g) applies to notices under Sec. 6404(g)(1) provided after November 26, 2007.
Notice 2007-92 (IRB 2007-47) 2008 social security contribution and benefit base; domestic employee coverage threshold; FICA; OASDI.
Notice 2007-89 (IRB 2007-46) Sec. 409A; interim guidance to employers and payers; reporting and wage withholding requirements for calendar year 2007; deferrals of compensation; amounts includable in gross income; Notice 2005-1 modified.
Notice 2007-90 (IRB 2007-46) Sec. 6166; extension of time for payment of estate tax; interest in closely held business; security for tax; case-by-case determination.
Notice 2007-86 (IRB 2007-46) Additional transition relief; Sec. 409A; deferred compensation; Notice 2007-78 modified; Notice 2007-79 modified and superseded.
Notice 2007-87 (IRB 2007-45) 2008 cost-of-lving adjustments; retirement plans; pension plans; control employees; qualified plans.
Notice 2007-85 (IRB 2007-45) Material advisor; Form 8918 requirement satisfied if Form 8264 filed before October 31, 2007; Form 8918 required after October 31, 2007; reportable transactions.
Notice 2007-84 (IRB 2007-45) Post-retirement medical and life insurance benefits; nondiscrimination; welfare benefit funds; tax treatment of certain trusts providing benefits to owners may not provide benefits claimed.
Notice 2007-83 (IRB 2007-45) Abusive trust arrangements; cash value life insurance; welfare benefit funds; listed transactions.
Notice 2007-80 (IRB 2007-43) Extension of replacement period for livestock sold on account of drought; 4-year replacement period; list of counties experiencing exception, extreme, or severe drought during 12-month period ending August 31, 2007; availability of extension.
Notice 2007-79 (IRB 2007-42) Electronic Return Originators; EROs; sign by rubber stamp, mechanical device, or computer software; Form 8453; Form 8878; From 2350; Form 8879.
Notice 2007-78 (IRB 2007-41) Sec. 409A; transition relief and guidance; nonqualified deferred compensation plan; December 31, 2008 extended deadline; employment agreements; cashout features.
Notice 2007-77 (IRB 2007-40) Sec. 911; limitations on housing expenses for tax year 2007.
Notice 2007-76 (IRB 2007-40) Smartcards; electronic media; qualified transportation fringes; Sec. 132; delay of effective date of Rev. Rul. 2006-57; Rev. Rul. 2006-57 modified.
Notice 2007-70 (IRB 2007-40) Guidance to taxpayers who must file 1098-C; Contributions of Motor Vehicles, Boats,and Airplanes; donee organization.
Notice 2007-74 (IRB 2007-37) Bankruptcy effects of disaster relief for Hurricane Katrina victims who file Sec. 6081 extensions; Sec. 6081; 7508A; priority and dischargeability of tax for bankruptcy purposes; Notice 2006-56 clarified; Rev. Rul. 2007-59 amplified.
Notice 2007-73 (IRB 2007-36) Transaction using grantor trust and purported termination and subsequent re-creation of grantor trust; claiming loss greater than economic loss.
Notice 2007-72 (IRB 2007-36) Transaction of interest; charitable contribution of an interest in an entity holding real property and claiming deduction significantly higher than purchase price; Sec. 6011; 6111; 6112.
Notice 2007-71 (IRB 2007-35) Tax avoidance transaction; offsetting foreign currency options; listed transactions; Notice 2003-81 modified and supplemented.
Notice 2007-69 (IRB 2007-35) Normal retirement age; temporary relief for certain pension plans; change under Sec. 401(a); Rev. Proc. 2007-4 and Notice 2007-3 modified.
Notice 2007-68 (IRB 2007-35) Weighted average interest rate; corporate bond indices; permissible range of interest rates to calculation current liabilty.
Notice 2007-60 (IRB 2007-35) Sec. 355; transition relief; regulations under 1.355-3(b).
Notice 2007-66 (IRB 2007-34) Sec. 42; extension of time for the restoration of low-income housing credit projects; Gulf Opportunity Zone; Hurricane Katrina; GO Zone.
Notice 2007-65 (IRB 2007-34) Sec. 613A; 2007 marginal production rates; percentage depletion.
Notice 2007-64 (IRB 2007-34) Sec. 43; inflation adjustment factor; enhanced oil recovery credit for 2007.
Notice 2007-63 (IRB 2007-33) Repayment of Commodity Credit Corporation loans; CCC; reporting of market gain associated with repayment of nonrecourse marketing assistance loans.
Notice 2007-62 (IRB 2007-32) Sec. 457; nonqualified deferred compensation plans of state and local governments and tax exempt entities; bona fide severance pay plan; substantial risk of forfeiture.
Notice 2007-59 (IRB 2007-30) Qualified Payment Card Agent; QPCA; payment card organization; request for determination.
Notice 2007-58 (IRB 2007-29) Potential revisions to definitions of financial services income, active financing income; Sec. 1.904-4(e); Sec. 904(d).
Notice 2007-57 (IRB 2007-29) Transaction where U.S. taxpayer uses offsetting positions with respect to foreign currency or other property for importing a loss but not gain; tax avoidance transactions; listed transactions; Reg. Sec. 1.6011-4(b)(2); Sec. 6111; 6112.
Notice 2007-54 (IRB 2007-27) Return preparer penalty; transitional relief; Sec. 6694.
Notice 2007-53 (IRB 2007-26) Allocation of credits after 2006; qualifying gasification project program of Sec. 48B; Notice 2006-25 clarified, modified, amplified, and superseded.
Notice 2007-52 (IRB 2007-26) Allocation of credits after 2006; qualifying advanced coal project program of Sec. 48A; Notice 2006-24 clarified, modified; amplified, and superseded.
Notice 2007-50 (IRB 2007-25) Guidance on percentage limitation under Sec. 170(b)(1)(E); qualified conservation contributions by individuals.
Notice 2007-49 (IRB 2007-25) Guidance on identifying covered employees for purposes of Sec. 162(m)(3); limit on compensation; public corporations.
Notice 2007-48 (IRB 2007-25) IRS intents to issue regulations; Sec. 367(b); triangular reorganizations involving foreign corporations; Notice 2006-85 amplified.
Notice 2007-47 (IRB 2007-24) IRS intends to amend Reg. Sec. 1.262-1(b)(5) to provide that the cost of a taxpayer's lodging not incurred while traveling away from home may qualify as deductible expenses under Sec. 162; interim guidance.
Notice 2007-46 (IRB 2007-23) Heavy-duty hybrid vehicles; qualified hybrid motor vehicle credit; certify amount of credit; purchasers of qualified vehicle.
Notice 2007-45 (IRB 2007-22) Sec. 501(c)(3) organizations; Form 990-T for public inspection and copying.
Notice 2007-44 (IRB 2007-22) LIFO; price indexes; department stores; Service will no longer publish the Department Store Inventory Price Indexes prepared by Bureau of Labor Statistics but will continue to accept BLS indexes; Rev. Proc. 86-46 modified.
Notice 2007-43 (IRB 2007-22) Sec. 30C; refueling property credit; converted and dual-use refueling property; alternative fuel.
Notice 2007-41 (IRB 2007-21) Public comments invited on recommendations for items that should be included on 2007-2008 Guidance Priority List.
Notice 2007-40 (IRB 2007-21) Renewable electricity production; refined coal productions; Indian coal production; inflation adjustment factors and reference prices.
Notice 2007-39 (IRB 2007-20) Guidance to practitioners, employers, firms, and other entities subject to monetary penalties under 31 U.S.C. section 330 which authorizes the Secretary to regulate attorneys, CPAs, enrolled agents; enrolled actuaries, others who practice before the IRS.
Notice 2007-38 (IRB 2007-18) Sec. 45K; inflation adjustment factor; phaseout; nonconventional source fuel credit for 2006.
Notice 2007-37 (IRB 2007-17) Guidance on credits and payments provided for renewable diesel and renewable diesel mixtures; Secs. 43, 40A, 6426; 6427.
Notice 2007-36 (IRB 2007-17) Sec. 1400N(d); Gulf Opportunity Zone; 50-percent additional first year depreciation; Gulf Opportunity Zone extension property; GO Zone; Notice 2006-77 clarified, modified, and amplified.
Notice 2007-34 (IRB 2007-17) Sec. 409A; split-dollar life insurance arrangements; effective date rules; Sec. 61; 7872.
Notice 2007-31 (IRB 2007-16) Automatic exchange of information between IRS and U.S. Virgin Islands Bureau of Internal Revenue; statute of limitations on assessment; bona fide residents of U.S. Virgin Islands; Notice 2007-19 amended and supplemented.
Notice 2007-35 (IRB 2007-15) Notice alerts taxpayers to common mistakes made on individual income tax returns.
Notice 2007-30 (IRB 2007-14) Lists positions identified as frivolous for purposes of Sec. 6702(c).
Notice 2007-29 (IRB 2007-14) Request for comments regarding allocation of costs under the simplified methods under Sec. 263A; IRS will not challenge inclusion of negative amounts in computing additional costs under Sec. 263A.
Notice 2007-28 (IRB 2007-14) Deductibility; contributions to qualified defined benefit pension plans under Sec. 404(a)(1); combination of plans under Sec. 404(a)(7).
Notice 2007-26 (IRB 2007-14) Clean renewable energy bonds; CREBs; volume cap.
Notice 2007-15 (IRB 2007-12) Modifications and additions to the adjusted limitations on housing expenses; Notice 2006-87; Sec. 911; Notice 2006-87 modified and supplemented.
Notice 2007-24 (IRB 2007-12) Draft forms to implement new information reporting requirement for charities; structured insurance contracts.
Notice 2007-17 (IRB 2007-12) Pilot program; solicit input from public in initial development of certain types of guidance projects.
Notice 2007-19 (IRB 2007-11) Sec. 932; 7654; statute of limitations on assessment; taxpayers claiming to be bona fide residents of U.S. Virgin Islands; new annual information reporting requirement; $75,000 or more of gross income.
Notice 2007-22 (IRB 2007-10) Health Flexible Spending Arrangements; FSAs; Health Reimbursement Arrangements; HRAs; Health Savings Accounts; HSAs; rollovers; Notices 2002-45, 2005-86 modified; Rev. Ruls. 69-141, 2002-41, 2003-102, 2005-24, 2006-36 modified.
Notice 2007-18 (IRB 2007-9) Sec. 4965; tax exempt entities; parties to a prohibited tax shelter transaction.
Notice 2007-14 (IRB 2007-7) Permitted benefits; defined benefit plan; notice of intent to propose regulations.
Notice 2007-12 (IRB 2007-5) Controlled foreign corporation; substantial assistance rendered by a related person or persons; CFC.
Notice 2007-11 (IRB 2007-5) Telephone excise tax; refund; standard amount; business and nonprofit estimation method; Notice 2006-50 amplified, clarified, and modified.
Notice 2007-9 (IRB 2007-5) Sec. 954(c)(6); dividend, interest, rent and royalty payments may be excluded from foreign personal holding company income.
Notice 2007-7 (IRB 2007-5) Guidance with respect to certain provisions of Pension Protection Act of 2006; PPA; distributions described in Sections 303, 826, 829, 845, 904, 1102, 1201.
Notice 2007-10 (IRB 2007-4) Bulgarian entity; entities always treated as corporations under Sec. 7701.
Notice 2007-8 (IRB 2007-3) In-service distributions; Sec. 905 of Pension Protection Act of 2006; IRS considering guidance; Sec. 401(a)(36).
Notice 2007-5 (IRB 2007-3) Modifies effective date; other clarifications; Sec. 482; temporary services regulations; Rev. Proc. 2007-13.
Notice 2007-4 (IRB 2007-2) Extension of transition relief for certain partnerships and other pass-thru entities; Sec. 470; Notice 2005-29; Notice 2006-2; holding tax-exempt property; Sec. 168(h)(6).
Notice 2007-3 (IRB 2007-2) Retirement plans; qualification; list of changes; Rev. Proc. 2005-66; requests to the IRS.
Notice 2007-2 (IRB 2007-2) Transition relief for the use of debit cards for medical expense reimbursements at certain merchants with non-health care related merchant category codes (MCC); drug stores and pharmacies; Rev. Rul. 2003-43 modified.

 

Announcements

Announcement 2007-116 (IRB 2007-51) Correction to proposed regulations; REG-140206-06; withholding agent's obligation to withhold and report tax.
Announcement 2007-112 (IRB 2007-50) Revision to Rev. Proc. 2007-65; change in language; wind energy partnership.
Announcement 2007-110 (IRB 2007-48) Changes in filing procedures for Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding filed electronically or magnetically.
Announcement 2007-109 (IRB 2007-47) Corrections to proposed regulations; REG-107529-00; REG-105964-98; treatment of transactions involving obligations between members of a consolidated group; provision of insurance between members of a consolidated group.
Announcement 2007-107 (IRB 2007-46) Agreement between United Kingdom; avoidance of double taxation.
Announcement 2007-106 (IRB 2007-46) IRS Individual e-file Partnership Program to solicit applications from potential partners.
Announcement 2007-103 (IRB 2007-44) Corrections to final regulations; T.D. 9353; Section 1405; partnerships and partners.
Announcement 2007-102 (IRB 2007-44) Corrections to final regulations; T.D. 9340; Section 403(b) contracts; public schools and tax-exempt organizations.
Announcement 2007-98 (IRB 2007-43) Corrections to proposed regulations; REG-148393-06; tax treatment of payments by qualified plans for medical or accident insurance.
Announcement 2007-97 (IRB 2007-43) Corrections to proposed regulations; REG-116215-07; Sec. 6104; 6110; information made publicly available by IRS.
Announcement 2007-95 (IRB 2007-43) Corrections to proposed regulations; REG-128244-06; costs incurred by estates or non-grantor trusts; 2-percent floor for miscellaneous itemized deductions; Sec. 67.
Announcement 2007-94 (IRB 2007-42) Corrections to proposed regulations; REG-148951-05; discharge of liens under Sec. 7425 and 6343.
Announcement 2007-93 (IRB 2007-42) Corrections to final and temporary regulations; T.D. 9344; discharge of liens under Sec. 7425 and 6343.
Announcement 2007-90 (IRB 2007-42) Pre-approved defined contribution plans; determination letters; program closed for a temporary period of time; Form 5307.
Announcement 2007-87 (IRB 2007-40) Sec. 509; payout requirements of Type III supporting organizations; whether Type III organization is functionally integrated.
Announcement 2007-80 (IRB 2007-38) Corrections to temporary regulations; T.D. 9330; corporations that have undergone ownership change; Sec. 382; prepaid income; built-in gain provisions.
Announcement 2007-78 (IRB 2007-38) Corrections to final regulations; T.D. 9321; Section 409A; nonqualified deferred compensation plans.
Announcement 2007-77 (IRB 2007-38) REG-103842-07; corrections to proposed regulations; deduction for income attributable to domestic production activities; Sec. 199; qualified films; members of an expanded affiliated group.
Announcement 2007-74 (IRB 2007-35) Corrections to proposed regulations; REG-157711-02; consolidated returns; repeal of General Utilities doctrine; bases in subsidiary stock; reductions in basis on transfer of stock.
Announcement 2007-71 (IRB 2007-33) Corrections to proposed regulations; REG-143601-06; mortality tables; present value; pension funding requirements.
Announcement 2007-68 (IRB 2007-32) Corrections to the preamble of final regulations; Sec. 409A; nonqualified compensation plans; T.D. 9321.
Announcement 2007-63 (IRB 2007-30) Form 5500; elimination of Schedule P.
Announcement 2007-62 (IRB 2007-29) Revisions to Form 1118 Foreign Tax Credit-Corporations posted to IRS Web site.
Announcement 2007-61 (IRB 2007-28) Pre-approved defined benefit plans; GUST amendments; program is being closed.
Announcement 2007-59 (IRB 2007-25) Sec. 401(k); safe harbor plan; qualified Roth contribution; mid-year changes; hardship withdrawals; Sec. 402A; Notice 2007-7.
Announcement 2007-58 (IRB 2007-25) Corrections to final regulations; T.D. 9319; limitation of Sec. 415; updates for statutory changes.
Announcement 2007-57 (IRB 2007-24) Corrections to final regulations; T.D. 9319; limitation of Sec. 415; updates for statutory changes.
Announcement 2007-55 (IRB 2007-23) Roth IRA; rollover; prototype; sponsors of prototype Roth IRAs must amend documents; permit rollover from designated Roth accounts; Sec. 402A.
Announcement 2007-54 (IRB 2007-23) Corrections to proposed regulations; REG-144859-04; treatment of open account debt between S corporations and their shareholders.
Announcement 2007-53 (IRB 2007-23) Corrections to proposed regulations; REG-156779-06; determination of amount of taxes paid for purposes of Section 901.
Announcement 2007-50 (IRB 2007-22) Corrections to final and temporary regulations; T.D. 9322; corporations filing consolidated returns.
Announcement 2007-49 (IRB 2007-21) Correction to final regulations; T.D. 9315; dual consolidated losses.
Announcement 2007-48 (IRB 2007-20) Correction to temporary regulations; T.D. 9313; qualification of certain transactions as reorganizations; Sec. 368(a)(1)(D); no stock or securities of the acquiring corporation issued.
Announcement 2007-47 (IRB 2007-20) Nonbank trustees; 1.408-2(e); list of entities approved to act as nonbank trustees and nonbank custodians.
Announcement 2007-44 (IRB 2007-19) Archer Medical Savings Account; MSA; pilot program; 2005 and 2006 are not cut-off years.
Announcement 2007-40 (IRB 2007-16) Corrections to temporary regulations; T.D. 9313; guidance regarding qualification of certain transactions as reorganizations; Sec. 368(a)(1)(D); no stock and/or securities of the acquiring corporation are issued or distributed.
Announcement 2007-39 (IRB 2007-15) Deadline for current and former U.S.-based employees of foreign embassies, consular offices and missions and international organizations; one-time settlement intitiative to resolve outstanding tax matters; further extension until June 30; 2007.
Announcement 2007-37 (IRB 2007-15) Additional corrections to proposed regulations; REG-139059-02; rules relating to the child and dependent care credit; Working Families Tax Relief Act of 2005.
Announcement 2007-36 (IRB 2007-15) Corrections to proposed regulations; REG-139059-02; rules relating to the child and dependent care credit; Working Families Tax Relief Act of 2005.
Announcement 2007-35 (IRB 2007-15) Escrow accounts; trusts; other funds used during deferred exchanges of like-kind property.
Announcement 2007-31 (IRB 2007-12) Annual report to public; Advance Pricing Agreements; APAs.
Announcement 2007-32 (IRB 2007-11) Corrections to final regulations; T.D. 9298; provisions prohibiting discrimination based on health factor for group health plans.
Announcement 2007-30 (IRB 2007-11) Notice of hearing; REG-103039-05; obligation of material advisors; disclosure; reportable transactions; Sec. 6011.
Announcement 2007-29 (IRB 2007-11) Notice of hearing; REG-103038-05; obligation of material advisors; disclosure; reportable transactions; Sec. 6011.
Announcement 2007-27 (IRB 2007-11) Notice of hearing; REG-103043-05; obligation of material advisors prepare and maintain lists; reportable transactions; Sec. 6011.
Announcement 2007-26 (IRB 2007-10) Corrections to proposed regulations; REG-125632-06; qualification of certain transactions as reorganizations; Sec. 368(a)(1)(D).
Announcement 2007-25 (IRB 2007-10) Corrections to final and temporary regulations; T.D. 9303; qualification of certain transactions as reorganizations; Sec. 368(a)(1)(D).
Announcement 2007-24 (IRB 2007-10) Archer MSA trustees and custodians; obligation to report number of Archer MSAs.
Announcement 2007-22 (IRB 2007-9) Corrections to final regulations; T.D. 9263; deductions for income attributable to domestic production activities; Section 199.
Announcement 2007-21 (IRB 2007-9) Corrections to final regulations; T.D. 9276; amount of income tax withholding on supplemental wages.
Announcement 2007-18 (IRB 2007-9) Compliance resolution program; permits employers to pay the additional Section 409A taxes; exercise of certain stock options and stock appreciation rights; discounted stock rights.
Announcement 2007-20 (IRB 2007-8) Corrections to final regulations; T.D. 9276; amount of income tax withholding on supplemental wages.
Announcement 2007-17 (IRB 2007-8) Corrections to proposed regulations; REG-121509-00; exclusion from gross income of previously taxed earnings and profits under Sec. 959; basis adjustments under Sec. 961.
Announcement 2007-16 (IRB 2007-8) Due date for filing returns and paying taxes extended to April 17, 2007; Emancipation Day Holiday in District of Columbia.
Announcement 2007-15 (IRB 2007-8) Changes in filing procedures for From 8851, Summary of Archer MSAs.
Announcement 2007-4 (IRB 2007-7) Corrections to proposed regulations; REG-208270-86; determination of items of income or loss of a taxpayer with respect to Section 987; qualified business unit.
Announcement 2007-11 (IRB 2007-6) Corrections to notice of proposed rulemaking; REG-146893-02; controlled services transactions; Sec. 482; allocation of income from intangibles.
Announcement 2007-10 (IRB 2007-6) Corrections to final and temporary regulations; T.D. 9278; controlled services transactions; Sec. 482; allocation of income from intangibles; contributions by a controlled party to the value of an intangible owned by another controlled party.
Announcement 2007-9 (IRB 2007-5) Corrections to final and temporary regulations; T.D. 9278; treatment of controlled services transactions; Sec. 482; allocation of income from intangibles; contributions by a controlled party to the value of an intangible owned by another controlled party.

 

       Links to Individual Bulletins

Internal Revenue Bulletin 2007-1        Internal Revenue Bulletin 2007-27
Internal Revenue Bulletin 2007-2        Internal Revenue Bulletin 2007-28
Internal Revenue Bulletin 2007-3        Internal Revenue Bulletin 2007-29
Internal Revenue Bulletin 2007-4        Internal Revenue Bulletin 2007-30
Internal Revenue Bulletin 2007-5        Internal Revenue Bulletin 2007-31
Internal Revenue Bulletin 2007-6        Internal Revenue Bulletin 2007-32
Internal Revenue Bulletin 2007-7        Internal Revenue Bulletin 2007-33
Internal Revenue Bulletin 2007-8        Internal Revenue Bulletin 2007-34
Internal Revenue Bulletin 2007-9        Internal Revenue Bulletin 2007-35
Internal Revenue Bulletin 2007-10      Internal Revenue Bulletin 2007-36
Internal Revenue Bulletin 2007-11      Internal Revenue Bulletin 2007-37
Internal Revenue Bulletin 2007-12      Internal Revenue Bulletin 2007-38
Internal Revenue Bulletin 2007-13      Internal Revenue Bulletin 2007-39
Internal Revenue Bulletin 2007-14      Internal Revenue Bulletin 2007-40
Internal Revenue Bulletin 2007-15      Internal Revenue Bulletin 2007-41
Internal Revenue Bulletin 2007-16      Internal Revenue Bulletin 2007-42
Internal Revenue Bulletin 2007-17      Internal Revenue Bulletin 2007-43
Internal Revenue Bulletin 2007-18      Internal Revenue Bulletin 2007-44
Internal Revenue Bulletin 2007-19      Internal Revenue Bulletin 2007-45
Internal Revenue Bulletin 2007-20      Internal Revenue Bulletin 2007-46
Internal Revenue Bulletin 2007-21      Internal Revenue Bulletin 2007-47
Internal Revenue Bulletin 2007-22      Internal Revenue Bulletin 2007-48
Internal Revenue Bulletin 2007-23      Internal Revenue Bulletin 2007-49
Internal Revenue Bulletin 2007-24      Internal Revenue Bulletin 2007-50
Internal Revenue Bulletin 2007-25      Internal Revenue Bulletin 2007-51
Internal Revenue Bulletin 2007-26      Internal Revenue Bulletin 2007-52
 


Copyright 2007 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information is not necessarily a complete summary of all materials on the subject.--ISSN 1089-1536


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--Last Update 12/26/07