(IRB) Internal Revenue Bulletin 2008-13 Weekly
Excerpt:
Rev. Rul. 2008–10, page 676.
Interest rates; underpayments and overpayments. The
rates of interest determined under section 6621 of the Code
for the calender quarter beginning April 1, 2008, will be 6 percent
for overpayments (5 percent in the case of a corporation),
6 percent for underpayments, and 8 percent for large corporate
underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 3.5 percent.
Rev. Rul. 2008–18, page 674.
S corporation; qualified subchapter S subsidiary (QSub).
This ruling describes situations where an S corporation undergoes
a reorganization pursuant to section 368(a)(1)(F) of the
Code where the operating S corporation becomes a QSub of a
newly formed holding company. The ruling holds that the newly
formed parent does not have to make a new S election pursuant
to Rev. Rul. 64–250. The ruling further holds that, effective
1/1/09, the new parent will have to get its own EIN rather
than take over the QSub’s EIN. However, for S corporations
that have previously reorganized under section 368(a)(1)(F) in
a manner described in this ruling, where the parent took the
QSub’s EIN, the parent should continue to use that EIN and the
QSub will have to get a new EIN when it is treated as a separate
corporation. Rev. Rul. 64–250 amplified.
Rev. Rul. 2008–19, page 669.
Insurance companies; interest rate tables. Prevailing
state assumed interest rates are provided for the determination
of reserves under section 807 of the Code for contracts
issued in 2007 and 2008. Rev. Rul. 92–19 supplemented in
Notes:
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