2007 IRS Internal Revenue Bulletins
(IRB) Internal Revenue Bulletin 2007-52 Weekly
Excerpt:
INCOME TAX
Rev. Rul. 2007–68, page 1236.
Interest rates; underpayments and overpayments. The
rates of interest determined under section 6621 of the Code
for the calendar quarter beginning January 1, 2008, will be 7
percent for overpayments (6 percent in the case of a corporation),
7 percent for underpayments, and 9 percent for large
corporate underpayments. The rate of interest paid on the portion
of a corporate overpayment exceeding $10,000 will be 4.5
percent.
T.D. 9365, page 1218.
Final regulations under section 45G of the Code provide rules
for claiming the railroad track maintenance credit for qualified
railroad track maintenance expenditures paid or incurred by a
Class II railroad or Class III railroad and other eligible taxpayers
during the taxable year.
Rev. Proc. 2007–72, page 1257.
This procedure describes the conditions under which changes
to certain subprime mortgage loans will not cause the Internal
Revenue Service to challenge the tax status of certain securitization
vehicles holding the loans.
EMPLOYEE PLANS
Notice 2007–99, page 1243.
Distributions from governmental plans and health and
accident insurance; section 845 of PPA ’06. As a result of
section 845 of the Pension Protection Act of 2006 and section
9(i)(1)(B) and (C) of S. 1974 and H.R. 3361, the pending Pension
Protection Technical Corrections Acts of 2007, Q&A–23
Notes:
(IRB) Internal Revenue Bulletin 2007-51 Weekly
Excerpt:
INCOME TAX
T.D. 9364, page 1177.
REG–115910–07, page 1214.
Temporary and proposed regulations under section 6039I of
the Code will implement the authority given the Secretary to require
information reporting on employer-owned life insurance.
REG–151884–03, page 1200.
Proposed regulations under section 381 of the Code provide
guidance regarding the accounting method or combination of
methods, including inventory methods, to use following certain
corporate reorganizations and tax-free liquidations. The regulations
will clarify and simplify the existing regulations.
EMPLOYEE PLANS
Notice 2007–94, page 1179.
Retirement plans; qualification, list of changes. This notice
sets forth a list of changes referred to in Rev. Proc.
2007–44, 2007–28 I.R.B. 54, pertaining to the statutory, regulatory,
and guidance changes needed for certain requests to
the Service for opinion, advisory, and determination letters for
the 12–month period beginning February 1, 2008.
Rev. Proc. 2007–71, page 1184.
Tax-sheltered annuities; written program; public
schools; model amendments. This procedure sets forth
model amendments that may be adopted in order to satisfy
certain requirements for a definite written program for certain
tax-sheltered annuities under section 403(b) of the Code. This
revenue procedure also provides additional relief for certain
section 403(b) tax-sheltered annuity contracts.
Notes:
(IRB) Internal Revenue Bulletin 2007-50 Weekly
Excerpt:
INCOME TAX
Rev. Rul. 2007–70, page 1158.
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 December 2007.
Rev. Rul. 2007–72, page 1154.
Diagnostic medical procedures. This ruling holds that
amounts paid by individuals for certain diagnostic and similar
procedures and devices aremedical care expenses deductible
under section 213 of the Code.
REG–127770–07, page 1171.
Proposed regulations under section 860G of the Code expand
the list of permitted loan modifications to include certain modifications
of commercial mortgages. Changes to the regulations
are necessary to better accommodate evolving commercial
mortgage industry practices. These changes will affect
lenders, borrowers, servicers, and sponsors of securitizations
of mortgages in REMICs.
Notice 2007–98, page 1160.
This notice announces the phase-out of the qualified hybrid motor
vehicle credit and the new advanced lean burn technology
motor vehicle credit for passenger automobiles and light trucks
manufactured by American Honda Motor Company, Inc., that
are purchased for use or lease in the United States beginning
on January 1, 2008.
Rev. Proc. 2007–70, page 1162.
Optional standard mileage rates. This procedure announces
50.5 cents as the optional rate for deducting or
accounting for expenses for business use of an automobile,
Notes:
Internal Revenue Bulletin 2007-49 Weekly
Excerpt:
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
Notes:
Internal Revenue Bulletin 2007-48 Weekly
Excerpt:
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.
Notes:
Internal Revenue Bulletin 2007-47 Weekly
Excerpt:
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.
Notes:
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.
Internal Revenue Bulletin 2007-46 Weekly
Excerpt:
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.
Notes:
Internal Revenue Bulletin 2007-45 Weekly
Excerpt:
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.
Notes:
Internal Revenue Bulletin 2007-44 Weekly
Excerpt:
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).
.
Notes:
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.
Internal Revenue Bulletin 2007-43 Weekly
Excerpt:
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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