Excerpt:

International operation of ships or aircraft; foreign corporation.
This ruling assists a foreign corporation engaged
in the international operation of ships or aircraft, and its shareholders,
in determining whether the foreign corporation is organized
in a country that grants an “equivalent exemption” from
tax for purposes of section 883(a) and (c) of the Code. The ruling
also assists a nonresident alien individual engaged in the international
operation of ships or aircraft in determining whether
a country grants an equivalent exemption for purposes of section
872(b). The ruling does not, however, provide substantive
guidance under section 883. Rev. Ruls. 89–42, 97–31, and
2001–48 modified and superseded.
Notice 2008–33, page 642.
This notice provides procedures for manufacturers to follow
to certify both that a particular make, model, and model year
of fuel cell motor vehicle meets the requirements of section
30B(a)(1) and (b) of the Code, and the amount of the credit
allowable with respect to the vehicle.
Notice 2008–34, page 645.
This notice identifies a transaction in which a tax indifferent
party contributes one or more distressed assets with a high
basis and low fair market value to a trust or series of trusts
and sub-trusts, and a U.S. taxpayer acquires an interest in the
trust (and/or series of trusts and/or sub-trusts) for the purpose
of shifting a built-in loss from the tax indifferent party to the U.S.
taxpayer that has not incurred the economic loss.
Notice 2008–35, page 647.
This notice supersedes Notice 2006–27, 2006–1 C.B. 626, by
substantially republishing the guidance contained in that publi

Notes:

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