<!-- TTST:[]: TTC:[]: TTSC:[]: TTT:[IRB]: TTS:[]: TTCP:[IRB 2007-10]: TTCI:[Highlights]: TTB:[]: TTA:[]: TTD:[]: -->

IRB 2007-10

Table of Contents
(Dated March 5, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-10. 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.

View the original PDF version of this Internal Revenue Bulletin

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.

SPECIAL ANNOUNCEMENT

This document contains a copy of the news release issued by the Office of the Deputy Commissioner, International, on February 13, 2007, extending the deadline to March 30, 2007 for the settlement offered to certain foreign embassy staff.

INCOME TAX

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 2006 and 2007. Rev. Rul. 92-19 supplemented in part.

Final, temporary, and proposed regulations under section 367(a) of the Code provide rules for entering into gain recognition agreements. The regulations clarify the effect that various transactions have on existing gain recognition agreements. Final regulations update certain cross-references in current regulations.

Final, temporary, and proposed regulations under section 367(a) of the Code provide rules for entering into gain recognition agreements. The regulations clarify the effect that various transactions have on existing gain recognition agreements. Final regulations update certain cross-references in current regulations.

This notice provides guidance on rollovers from health Flexible Spending Arrangements (health FSAs) and Health Reimbursement Arrangements (HRAs) to Health Savings Accounts (HSAs) under amendments to the Code by section 302 of the Health Opportunity Patient Empowerment Act of 2006 included in the Tax Relief and Health Care Act of 2006. Notices 2002-45 and 2005-86 modified. Rev. Ruls. 69-141, 2002-41, 2003-102, 2005-24, and 2006-36 modified.

This procedure provides administrative guidance permitting the use of a “Net Consideration Method” of accounting for certain patent cross licensing arrangements. Under the method, only cash and other non-patent-right consideration are taken into account for withholding and capitalization purposes. The procedure also requests comments on the types of arrangements that should be covered by the method.

This announcement notifies Archer MSA trustees and custodians of the obligation to report the number of Archer MSAs established between (1) January 1, 2005, and June 30, 2005, and (2) January 1, 2006, and June 30, 2006.

TAX CONVENTIONS

The United States and the United Kingdom of Great Britain and Northern Ireland (on behalf of the Bailiwick of Jersey) have exchanged diplomatic notes evidencing an agreement for the reciprocal exemption of income from the international operation of ships for taxable years beginning on or after January 1, 1997.

ADMINISTRATIVE

This procedure modifies the payment procedures for user fees applicable to the processing of Form 8802, Application for United States Residency Certification, to allow for the electronic payment of such fees effective April 2, 2007. Rev. Proc. 2006-35 modified.

This document contains corrections to final and temporary regulations (T.D. 9303, 2007-5 I.R.B. 379) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) of the Code.

This document contains corrections to proposed regulations by cross-reference to temporary regulations (REG-125632-06, 2007-5 I.R.B. 415) providing guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) of the Code.



The Internal Revenue Bulletin is produced and published by the Internal Revenue Service and contains IRS pronouncements affecting tax analysis under the Code and the Regulations, including but not limited to Revenue Procedures, Revenue Rulings, Notices and Announcements. Access the IRS site at https://www.irs.gov/help/irsgov-accessibility for information concerning accessibility of IRS materials. While every effort has been made to ensure that the IRB database files available through the TouchTax application are accurate, those using TouchTax for legal research should verify their results against the printed versions of the IRBs available from the IRS.