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IRB 2007-12

Table of Contents
(Dated March 19, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-12. 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.

SPECIAL ANNOUNCEMENT

This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA Program during calendar year 2006. This document does not provide guidance regarding the application of the arm’s length standard. Instead, it reports on the structure and activities of the APA Program.

INCOME TAX

Obsolete revenue rulings. As part of the Service’s continuing program of reviewing previously published guidance, this ruling publishes a list of rulings and actions relating to decisions of the Tax Court that are obsolete. Rev. Rul. 54-19 obsoleted in part. Rev. Ruls. 55-132, 56-462, 56-518, 57-505, 58-370, 58-500, 69-212, and 71-477 obsoleted.

Temporary and proposed regulations under section 181 of the Code provide rules relating to deductions for the cost of producing film and television productions.

Temporary and proposed regulations under section 181 of the Code provide rules relating to deductions for the cost of producing film and television productions.

Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

The IRS and Treasury anticipate the launch of a pilot program to solicit greater input from the public in the initial development of certain types of guidance projects. As a model for the pilot program, the IRS and Treasury solicit input from interested parties on whether it is appropriate to amend existing income tax regulations to permit certain modifications to securitized commercial mortgage loans.

This notice invites public comments on draft IRS forms to implement a new information reporting requirement for charities and certain other entities with respect to certain structured insurance contracts. The notice also solicits comments with respect to a Congressionally mandated study being conducted by Treasury and the IRS.

This notice provides modifications and additions to the adjusted limitations on housing expenses for tax year 2006 published in Notice 2006-87, 2006-43 I.R.B. 766, for purposes of section 911 of the Code. Notice 2006-87 modified and supplemented.

This procedure provides additional guidance regarding the disclosure of certain penalties under section 6707A(e) of the Code on forms filed with the U.S. Securities and Exchange Commission. Rev. Proc. 2005-51, 2005-2 C.B. 296, provides that a person who files SEC Form 10-K, Annual Report, must disclose in Item 3 (Legal Proceedings) of Form 10-K the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005-51. This procedure describes how persons who are required to file periodic reports under section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes of those reports, but that file these periodic reports on a form other than a Form 10-K, must make the appropriate disclosures on these other reports in order to avoid additional penalties. Rev. Proc. 2005-51 amplified.

ESTATE TAX

Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

GIFT TAX

Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

EMPLOYMENT TAX

Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

This procedure provides additional guidance regarding the disclosure of certain penalties under section 6707A(e) of the Code on forms filed with the U.S. Securities and Exchange Commission. Rev. Proc. 2005-51, 2005-2 C.B. 296, provides that a person who files SEC Form 10-K, Annual Report, must disclose in Item 3 (Legal Proceedings) of Form 10-K the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005-51. This procedure describes how persons who are required to file periodic reports under section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes of those reports, but that file these periodic reports on a form other than a Form 10-K, must make the appropriate disclosures on these other reports in order to avoid additional penalties. Rev. Proc. 2005-51 amplified.

EXCISE TAX

Proposed regulations under section 6159 of the Code govern the acceptance and rejection of installment agreements, the terms of those agreements and when they may be modified or terminated by the Service, and appeal procedures when the Service makes a rejection or termination decision. The principal purpose of this project is to update the regulations to reflect various amendments to section 6159 and related statutes.

This procedure provides additional guidance regarding the disclosure of certain penalties under section 6707A(e) of the Code on forms filed with the U.S. Securities and Exchange Commission. Rev. Proc. 2005-51, 2005-2 C.B. 296, provides that a person who files SEC Form 10-K, Annual Report, must disclose in Item 3 (Legal Proceedings) of Form 10-K the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005-51. This procedure describes how persons who are required to file periodic reports under section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes of those reports, but that file these periodic reports on a form other than a Form 10-K, must make the appropriate disclosures on these other reports in order to avoid additional penalties. Rev. Proc. 2005-51 amplified.

ADMINISTRATIVE

This procedure provides additional guidance regarding the disclosure of certain penalties under section 6707A(e) of the Code on forms filed with the U.S. Securities and Exchange Commission. Rev. Proc. 2005-51, 2005-2 C.B. 296, provides that a person who files SEC Form 10-K, Annual Report, must disclose in Item 3 (Legal Proceedings) of Form 10-K the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005-51. This procedure describes how persons who are required to file periodic reports under section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes of those reports, but that file these periodic reports on a form other than a Form 10-K, must make the appropriate disclosures on these other reports in order to avoid additional penalties. Rev. Proc. 2005-51 amplified.



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