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IRB 2007-08

Table of Contents
(Dated February 20, 2007)
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This is the table of contents of Internal Revenue Bulletin IRB 2007-08. 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

Final regulations under section 671 of the Code amend regulations section 1.671-5, which provides reporting requirements for widely held fixed investment trusts (WHFITs) to clarify and simplify the application of those rules to both non-mortgage widely held fixed investment trusts and widely held mortgage trusts.

Proposed regulations under sections 358, 362, and 1502 of the Code apply when a corporation, which is a member of a consolidated group, transfers a loss share of subsidiary stock. First, basis is redetermined by reallocating investment adjustments to adjust for disproportionate reflection of gains and losses in the bases of members’ shares. Second, members’ bases in transferred loss shares are reduced (but not below value) by the net positive amount of all investment adjustments applied to the bases of those shares. Finally, the attributes of the subsidiary are reduced to the extent there is a duplicated loss on transferred shares.

This notice provides for the waiver of additions to tax under section 6654(a) of the Code for underpayment of estimated taxes by certain citizens or residents of the United States living abroad. The notice explains the changes in the law as enacted by the passage of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) in May 2006 and who is eligible for the penalty waiver and to what extent.

ADMINISTRATIVE

This notice provides for the waiver of additions to tax under section 6654(a) of the Code for underpayment of estimated taxes by certain citizens or residents of the United States living abroad. The notice explains the changes in the law as enacted by the passage of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA) in May 2006 and who is eligible for the penalty waiver and to what extent.

This announcement contains changes in filing procedures for Form 8851, Summary of Archer MSAs. Rev. Proc. 2001-31, 2001-1 C.B. 1170, will be revised at a future date but will not be available by the due date of the return, March 20, 2007.

This announcement informs the public that the due date for filing returns and paying taxes has been extended to April 17, 2007, as a result of the Emancipation Day Holiday in the District of Columbia.

This document contains corrections to proposed regulations (REG-121509-00, 2006-40 I.R.B. 602) that provide guidance relating to the exclusion from gross income of previously taxed earnings and profits under section 959 of the Code and related basis adjustments under section 961.

This document contains corrections to final regulations (T.D. 9276, 2006-37 I.R.B. 423) that provide for determining the amount of income tax withholding on supplemental wages. The regulations apply to all employers and others making supplemental wage payments to employees.



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