Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX
Rev. Rul. 2009–37, page 957.
Interest rates; underpayment and overpayments. The rate for interest determined under section 6621 of the Code
for the calendar quarter beginning January 1, 2010, will be 4 percent for overpayments (3 percent in the case of a corporation), 4 percent for underpayments, and 6 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 1.5 percent.

T.D. 9473, page 945.
Final regulations under section 6159 of the Code relate to the payment of tax liabilities in installments and reflects changes to the law made by the Taxpayer Bill of Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.

REG–111833–99, page 1000.
Proposed regulations under section 7430 of the Code relate to awards of administrative costs and attorneys fees to conform the regulations to the amendments made in the Taxpayer Relief Act of 1997 and the IRS Restructuring and Reform Act of 1998. A public hearing is scheduled for March 10, 2010.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Notice 2009–90, page 859.
This notice provides rules relating to the availability of the production tax credit for refined coal.

Rev. Proc. 2009–48, page 864.
Specifications are set forth for the private printing of paper and laster-printed substitutes for the February 2009 revisions
of Form W-2c, Corrected Wage and Tax Statement, and Form W-3c, Transmittal of Corrected Wage and Tax Statements. Rev. Proc. 2006–19 superseded.

EMPLOYEE PLANS

T.D. 9472, page 850.

Final regulations under section 4980F of the Code provide guidance relating to the section’s application to a plan amendment that is permitted to be effective before the plan amendment’s applicable amendment date. The regulations also reflect certain amendments made to section 4980F by the Pension Protection Act of 2006.

Announcement 2009–85, page 938.
Temporary closing of the determination letter program for adopters of pre-approved defined benefit plans. The Service announces that it will temporarily stop accepting determination letter applications for defined benefit plans filed on Form 5307, beginning February 22, 2010. This announcement does not affect the ability of adopting employers to apply for determination letters on Form 5307 for pre-approved defined contribution plans.

EMPLOYMENT TAX

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

T.D. 9467, page 760.
Final regulations under sections 430 and 436 of the Code provide guidance for single employer defined benefit retirement plans regarding the measurement of assets and liabilities to determine funding requirements and regarding restrictions on payment of benefits by underfunded plans.
EMPLOYEE PLANS
Notice 2009–94, page 848.
2010 cost-of-living adjustments; retirement plans, etc.
This notice sets forth certain cost-of-living adjustments effective January 1, 2010, applicable to the dollar limitations on benefits and contributions under qualified retirement plans. The limitations that are adjusted by reference to section 415(d) will remain unchanged for 2010. Other limitations applicable to deferred compensation plans are also unchanged for 2010. This notice also contains cost-of-living adjustments for several pension-related amounts in restating the data in IR–2009–94 issued October 15, 2009."

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Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2009–38, page 736.
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 2009.

T.D. 9470, page 738.

Final regulations under section 6039 of the Code require corporations to file an information return with the IRS and furnish a written statement to each employee regarding: (i) the corporation’s transfer of stock pursuant to the employee’s exercise of an incentive stock option described in section 422(b); and (ii) transfers of stock by the employee where the stock was acquired pursuant to the exercise of an option described in section 423(c). The time and manner for filing a return and furnishing statements to employees, as well as the information to be contained in the return and furnished to employees, are addressed in these final regulations.

T.D. 9471, page 722.
Final regulations under section 423 of the Code provide the requirements that must be satisfied in order for a plan to meet the definition of an employee stock purchase plan. Section 423 also addresses the individual income tax treatment of stock acquired pursuant to an option granted under an employee stock purchase plan. The regulations update the existing regulations and provide additional guidance in certain areas.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

T.D. 9469, page 687.
Final regulations under section 108 of the Code provide guidance on the manner in which an S corporation reduces its tax attributes under section 108(b) for taxable years in which the S corporation has discharge of indebtedness income that is excluded from gross income under section 108(a).

Notice 2009–89, page 714.
This notice sets forth a process that allows manufactures to certify to the Service that a particular vehicle meets the requirements of section 30D of the Code. Taxpayers purchasing such vehicles can rely on the domestic manufacturer’s (or, in the case of a foreign manufacturer, its domestic distributor’s) certification that a particular make, model, and model year of vehicle qualifies as a plug-in electric drive motor vehicle under section 30D, and certification of the amount of the credit allowable with respect to the vehicle. The notice also defines when the amended section 30D applies. Notices 2009–54 and 2009–58 amplified.

EMPLOYEE PLANS

T.D. 9464, page 692.
REG–123829–08, page 719.
Final, temporary, and proposed regulations under section 9802 of the Code provide guidance on the requirements that group health plans not charge higher rates based on genetic information, not request or require individuals to undergo genetic tests, and not collect or use genetic information for underwriting purposes.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2009–36, page 650.

2009 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2009, is published as
required by section 995(f) of the Code.

REG–135005–07, page 681.
Proposed regulations under section 1563 of the Code clarify which corporations are included in a controlled group of corporations. The regulations clarify that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.

EMPLOYEE PLANS

Notice 2009–88, page 654.
Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates.
This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in November
2009; the 24-month average segment rates; the funding transitional segment rates applicable for November 2009; and the minimum present value transitional rates for October 2009.

EXEMPT ORGANIZATIONS

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

EMPLOYEE PLANS

REG–159704–03, page 632.
Proposed regulations contain proposed amendments to 20 CFR part 901 relating to the enrollment of actuaries under
section 3042 of the Employee Retirement Income Security Act of 1974 (ERISA). The proposed amendments would update the eligibility requirements for performing actuarial services for ERISA-covered employee pension benefit plans, including the continuing education requirements, and the standards for performing such actuarial services. The proposed
amendments would affect employee pension benefit plans and the actuaries providing actuarial services to those plans.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Notice 2009–85, page 598.
This notice provides guidance under section 877A of the Code, which was enacted by section 301 of the Heroes Earnings Assistance and Relief Act of 2008 (the “Act”) and applies to individuals who expatriate on or after June 17, 2008. Section 877A generally provides that all property of a “covered expatriate” is treated as sold on the day before the individual’s expatriation date. Gain and loss from the deemed sale must be taken into account at that time (subject to a $600,000 exclusion amount, which will be indexed for inflation) unless the individual elects to defer payment of the tax by providing security and waiving treaty rights that would prevent assessment or collection of the deferred tax. There are special rules for deferred compensation items, specified tax deferred accounts, and interests in nongrantor trusts.

Rev. Proc. 2009–50, page 617.
Cost-of-living adjustments for 2010. This procedure sets forth the cost-of-living adjustments to certain items for 2010
due to inflation as required under various provisions of the Code and Service guidance.

EXEMPT ORGANIZATIONS

Announcement 2009–76, page 627.
A list is provided of organizations now classified as private foundations.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2009–35, page 568.
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 2009.

Notice 2009–83, page 588.
Credit for carbon dioxide sequestration under section 45Q. This notice sets forth interim guidance, pending the issuance
of regulations, relating to the credit for carbon dioxide sequestration under section 45Q of the Code. Specifically,
the notice provides guidance on determining eligibility for the credit and the amount of the credit, as well as rules regarding adequate security measures for secure geological storage of carbon dioxide. The notice also sets forth a separate reporting requirement.

EXEMPT ORGANIZATIONS

Announcement 2009–78, page 594.
The IRS has revoked its determination that Concerned Residents of Southeast, Inc., of Brewster, NY, qualifies as an organization described in sections 501(c)(3) and 170(c)(2) of the Code.

ESTATE TAX

T.D. 9468, page 570.
Final regulations under section 2053 of the Code relate to the amount deductible from a decedent’s gross estate for claims against the estate. In addition, the regulations update the provisions relating to the deduction for certain state death taxes to reflect the statutory amendments made in 2001 to sections 2053(d) and 2058.

Excerpt:

"These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

SPECIAL ANNOUNCEMENT

Announcement 2009–77, page 567.
The Twenty-Second 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 10 and 11, 2009, at the J.W. Marriott Hotel in Washington, D.C.

INCOME TAX

T.D. 9458, page 547.
REG–139068–08, page 558.
Temporary and proposed regulations under section 1502 of the Code provide for an election under which a consolidated
group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. Pursuant to the election, the liquidation and recontribution will be recharacterized as a cross-chain reorganization, rather than a liquidation or an upstream reorganization followed by a drop of assets.

T.D. 9465, page 542.
Final regulations under section 882 of the Code provide guidance on interest allocation for foreign corporations to
coordinate with recent income tax treaties; provide guidance on the adoption of a fixed ratio election and a 30–day published LIBOR rate election in the allocation formula; modify the liability reduction election under the branch profits tax; and make miscellaneous technical corrections and clarifications.