2007 IRS Bulletins
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INCOME TAX Rev. Rul. 2007–69, page 1083. This ruling provides that payments made by the U.S. Department of Veterans Affairs under the compensated work therapy program are exempt from federal income tax as veterans’ benefits. Rev. Rul. 65–18 revoked, Rev. Rul. 72–605 amplified. Notice 2007–95, page 1091. This notice addresses regulations under section 901 of the Code relating to the foreign tax credit. It announces revised effective dates for regulations amending the “legal liability” or “technical taxpayer” rule and the noncompulsory payment rules. Rev. Proc. 2007–68, page 1093. Substitute tax forms and schedules. Requirements are set forth for privately designed and printed federal tax forms and conditions under which the Service will accept computer prepared and computer-generated tax forms and schedules. Rev. Proc. 2007–24 superseded. Rev. Proc. 2007–69, page 1137. This procedure informs small business refiners how to obtain the certification required under section 45H(f) of the Code. EMPLOYEE PLANS REG–133300–07, page 1140. Proposed regulations under section 401 of the Code provide guidance relating to certain automatic contribution arrangements; section 402(c) relating to eligible rollover distributions; section 411(a) relating to forfeitures; and section 4979(f) relat
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INCOME TAX T.D. 9362, page 1050. REG–209020–86, page 1075. Temporary and proposed regulations under section 905 of the Code provide rules relating to a United States taxpayer’s obligation to notify the Internal Revenue Service of a foreign tax redetermination, which is a change in foreign tax liability that may affect the taxpayer’s foreign tax credit. These regulations also provide rules under section 6689 relating to the civil penalty for failure to notify the IRS of a foreign tax redetermination. Notice 2007–93, page 1072. This notice describes how the amendment to section 6404(g) made by the Small Business and Work Opportunity Act of 2007 applies to notices under section 6404(g)(1) that are provided on or after November 26, 2007. Rev. Proc. 2007–67, page 1072. Change in accounting method. This document allows taxpayers, under certain conditions, to request to revise the year of change for a Form 3115, Application for Change in Accounting Method, that is pending in the national office. It also modifies the period for taking into account a net positive section 481(a) adjustment when the Commissioner approves the taxpayer’s request to revise the year of change. Rev. Proc. 97–27 modified. Announcement 2007–110, page 1082. This announcement contains changes in filing procedures for Form 1042–S, Foreign Person’s U.S. Source Income Subject to Withholding, filed electronically or magnetically. These changes are effective immediately.
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INCOME TAX Ct. D. 2084, page 1032. Abatement; interest accruals; federal income taxes. The Supreme Court holds that the Tax Court provides the exclusive forum for judicial review of failure to abate interest under section 6404(e)(1). T.D. 9361, page 1026. Final regulations under section 368 of the Code amend regulations sections 1.368–1(d), 1.368–2(f) and 1.368–2(k) concerning the tax treatment of post-reorganization transfers of assets or stock of a party to the reorganization. REG–134923–07, page 1037. Proposed regulations under section 31 U.S.C. 9701 implement new user fees for the initial and renewed enrollment to become an enrolled actuary. The new user fees established by the regulations reflect the IRS’s costs of overseeing the initial enrollment and renewal of enrollment processes. The regulations establish a $250 user fee for initial enrollment and a $250 user fee for renewal of enrollment. A public hearing is scheduled for November 26, 2007. EXEMPT ORGANIZATIONS Announcement 2007–108, page 1044. A list is provided of organizations now classified as private foundations.
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This information was obtained from the IRS.gov website. E-File Magic does not warrant the accuracy of this information and provides it as a convenience to it’s customers. We encourage you to visit http://www.irs.gov/businesses/lists/0,,id=98230,00.html for the most recent copy of this information.
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SPECIAL ANNOUNCEMENT Announcement 2007–106, page 1021. The announcement for the 2008 IRS Individual e-file Partnership Program will solicit applications from potential partners for participation in the program. The partnership opportunities are a result of RRA 98, which authorized the IRS Commissioner to promote the benefits of and encourage the use of e-file products and services through partnerships with various entities that offer low-cost tax preparation and electronic filing of individual income tax returns for qualified taxpayers. Those applicants that are accepted into the program will have a link(s) and offer description(s) for their products and services posted to IRS.gov (Partners Page). INCOME TAX Ct. D. 2083, page 986. Levies upon third party property to collect taxes owed by another; wrongful levy action. The Supreme Court holds that the Trust missed section 7426(a)(1)’s deadline for challenging a levy, and may not bring the challenge as a tax refund claim under section 1346(a)(1). REG–140206–06, page 1006. Proposed regulations under section 1441 of the Code provide guidance regarding the withholding and reporting obligations of a withholding agent in the case of a self tender by a publicly traded corporation, when a determination is required under section 301 as to whether the distribution is treated as a dividend or a distribution in part or full payment in exchange for stock. A public hearing is scheduled for February 6, 2008.
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INCOME TAX Rev. Rul. 2007–64, page 953. 2007 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2007, is published as required by section 995(f) of the Code. Rev. Rul. 2007–66, page 956. Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for November 2007. Rev. Proc. 2007–65, page 967. This procedure under sections 704(b) and 45 of the Code provides the necessary requirements for partnerships to meet a safe harbor in allocating wind energy production tax credits. Rev. Proc. 2007–66, page 970. Cost-of-living adjustments for 2008. This procedure sets forth the cost-of-living adjustments to certain items for 2008 as required under various provisions of the Code and Service guidance. Rev. Procs. 90–12 and 2002–41 modified. EMPLOYEE PLANS Rev. Rul. 2007–65, page 949. Employer’s deduction for contributions; limitation on employer’s deduction; welfare benefit funds. This ruling discusses whether an employer’s deductions for contributions to a welfare benefit fund under section 419 of the Code are “qualified direct costs” with respect to premiums paid by a welfare benefit fund on cash value life insurance policies.
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SPECIAL ANNOUNCEMENT Announcement 2007–100, page 922. The Twentieth Annual Institute on Current Issues in International Taxation, jointly sponsored by the Internal Revenue Service and the George Washington University Law School, will be held on December 13 and 14, 2007, at the Grand Hyatt Washington Hotel in Washington, DC. INCOME TAX REG–107592–00, page 908. Proposed regulations under section 1502 of the Code provide guidance regarding the treatment of transactions involving debt obligations and securities between members of a consolidated group, and involving the provision of insurance between members of a consolidated group. REG–105964–98 withdrawn. EMPLOYEE PLANS Notice 2007–81, page 899. Interest rate modifications; Pension Protection Act of 2006; targeted segments. As required by section 430(h)(2) of the Code, as added by the Pension Protection Act of 2006, the corporate bond yield curve; the corporate bond yield curve with modifications; and the methodology used to determine these yield curves are set forth. In addition, this notice provides guidance in determining minimum present values under section 417(e)(3).
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This information was obtained from the IRS.gov website. E-File Magic does not warrant the accuracy of this information and provides it as a convenience to it’s customers. We encourage you to visit http://www.irs.gov/businesses/lists/0,,id=98230,00.html for the most recent copy of this information.
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T.D. 9360, page 860. Final regulations under section 1291 of the Code provide certain elections for taxpayers that continue to be subject to the passive foreign investment company (PFIC) excess distribution regime even though the foreign corporation in which they own stock is no longer treated as a PFIC under section 1297(a) or (e). REG–143326–05, page 873. Proposed regulations under sections 1361, 1362, and 1366 of the Code provide guidance regarding changes to the rules governing S corporations under the American Jobs Creation Act of 2004 (AJCA) and the Gulf Opportunity Zone Act of 2005 (GOZA). The regulations provide guidance on the family shareholder rules, the treatment of electing small business trusts, the allowance of suspended losses to spouses and former spouses of S corporation shareholders, and relief for inadvertently terminated or invalid qualified subchapter S subsidiary elections. The regulations also remove or update various obsolete references in the current regulations. A public hearing is scheduled for January 16, 2008. REG–106143–07, page 881. Proposed regulations under section 148 of the Code provide arbitrage guidance for tax-exempt bonds. A public hearing is scheduled for January 30, 2008. REG–129916–07, page 891. Proposed regulations under section 6011 of the Code add the patented transactions category of reportable transaction to regulations section 1.6011–4. A patented transaction is a transaction for which a taxpayer pays (directly or indirectly) a fee in any amount to a patent holder or the patent holder’s
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Rev. Rul. 2007–61, page 799. This ruling suspends Rev. Rul. 2007–54, 2007–38 I.R.B. 604, and informs taxpayers that Treasury and the Service intend to address the issues considered in Rev. Rul. 2007–54 by regulations. Rev. Rul. 2007–54 suspended. Notice 2007–79, page 809. This notice allows Electronic Return Originators (EROs) to sign the following forms by rubber stamp, mechanical device (such as signature pen), or computer software program: Form 8453, U.S. Individual Income Tax Declaration for an IRS e-file Return; Form 8878, IRS e-file Signature Authorization for Form 4868 or Form 2350; and Form 8879, IRS e-file Signature Authorization. Announcement 2007–88, page 801. This announcement contains an official copy of the diplomatic notes exchanged between the United States and Angola providing for a reciprocal exemption from taxation for income from the international operation of ships and aircraft. It includes the United States offer and the Angola acceptance in Portuguese and an English translation of the Angolan note. EMPLOYEE PLANS REG–113891–07, page 821. Proposed regulations under section 436 of the Code provide guidance regarding benefit restrictions for certain underfunded defined benefit pension plans and regarding the use of certain funding balances maintained for defined benefit pension plans.
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INCOME TAX Rev. Rul. 2007–62, page 767. Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through December 2007. This ruling provides the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through December 2007. Rev. Rul. 2007–63, page 778. Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2007. T.D. 9354, page 759. Final regulations under section 21 of the Code conform the rules relating to the child and dependent care credit to statutory changes, including amendments under the Working Families Tax Relief Act of 2004, and address significant issues that have arisen administratively. The regulations are renumbered to conform to the renumbering of the statute. Rev. Ruls. 76–278 and 76–288 obsoleted. T.D. 9357, page 773. Final regulations under section 853 of the Code generally eliminate country-by-country reporting, by a regulated investment company (RIC) to its shareholders, of foreign source income that the RIC takes into account and foreign taxes that it pays. T.D. 9358, page 769. Final regulations under section 338 of the Code permit taxpayers to elect to modify the application of the ADSP and AGUB allocation rules of regulations section 1.338–6 as regards nuclear
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