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IRB 2007-05

Table of Contents
(Dated January 29, 2007)
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This is the table of contents of Internal Revenue Bulletin IRB 2007-05. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

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

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through March 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 March 2007.

LIFO; price indexes; department stores. The November 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, November 30, 2006.

Final, temporary, and proposed regulations under section 368 of the Code provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction.

Final, temporary, and proposed regulations under section 368 of the Code provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) where no stock and/or securities of the acquiring corporation is issued and distributed in the transaction.

This notice provides guidance under section 954(c)(6) of the Code on dividend, interest, rent and royalty payments that may be excluded from foreign personal holding company income.

This notice announces that the Treasury Department and the Service will amend the regulations addressing substantial assistance rendered by a related person or persons to a controlled foreign corporation (CFC). These amended regulations will limit the types of activities that constitute substantial assistance to certain assistance rendered, directly or indirectly, by a United States person or persons to a related CFC. In addition, in light of the repeal of the foreign base company shipping income rules under subpart F, this notice confirms that income that previously was foreign base company shipping income will continue to be foreign base company income to the extent that it is within the definition of a remaining category of foreign base company income.

EMPLOYEE PLANS

Final regulations under section 409(p) of the Code provide guidance concerning requirements for employee stock ownership plans (ESOPs) holding stock of Subchapter S corporations.

Distribution issues; multiple issues; Pension Protection Act of 2006. This notice provides guidance in the form of questions and answers with respect to certain provisions contained in the Pension Protection Act of 2006, Pub. L. No. 109-280 (PPA ’06), that are effective in 2007 or earlier and are primarily related to distributions described in sections 303, 826, 828, 829, 845, 904, 1102, and 1201 of the statute.

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities. The weighted average interest rate for January 2007 and the resulting permissible range of interest rates used to calculate current liability and to determine the required contribution are set forth.

EXCISE TAX

This notice answers questions raised by Notice 2006-50, 2006-25 I.R.B. 1141. It also provides guidance regarding the standard amounts for individuals and provides rules for the Business and Nonprofit Estimation Method (EM). Notice 2006-50 amplified, clarified, and modified.

ADMINISTRATIVE

Pursuant to section 1397E(e)(2) of the Code, this procedure sets forth the maximum face amount of Qualified Zone Academy Bonds that may be issued for each state for each of the calendar years 2006 and 2007. For this purpose, “State” includes the District of Columbia and the possessions of the United States.

This document contains corrections to temporary regulations (T.D. 9286, 2006-43 I.R.B. 750) providing rules for claiming the railroad track maintenance credit under section 45G of the Code for qualified railroad track maintenance expenditures paid or incurred by a Class II or Class III railroad and other eligible taxpayers during the taxable year.

This document contains corrections to final and temporary regulations (T.D. 9278, 2006-34 I.R.B. 256) regarding the treatment of controlled services transactions under section 482 of the Code and the allocation of income from intangibles, in particular with respect to contributions by a controlled party to the value of an intangible owned by another controlled party.



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