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IRB 2007-23

Table of Contents
(Dated June 4, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-23. 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

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 June 2007.

Proposed regulations under section 355 of the Code provide rules for implementing the separate affiliated group (SAG) rules of section 202 of the Tax Increase Prevention and Reconciliation Act of 2005, which permit all SAG members to be treated as one corporation for purposes of satisfying the active trade or business (ATB) requirement. In addition, the regulations provide guidance explaining (1) when a corporation is attributed trade or business assets and activities of a partnership, (2) when a corporation may use activities of an affiliate or a shareholder to meet the ATB requirement, (3) whether the corporation’s business was acquired in violation of section 355(b) “in a transaction in which gain or loss was recognized in whole or in part,” and (4) other miscellaneous rules.

This notice provides procedures for a vehicle manufacturer to certify that a heavy-duty hybrid vehicle meets certain requirements for the new qualified hybrid motor vehicle credit, and to certify the amount of the credit available with respect to the vehicle. This notice also provides guidance to taxpayers who purchase a heavy-duty hybrid vehicle regarding the conditions under which they may rely on the vehicle manufacturer’s certification.

Qualified production activities income (QPAI) and W-2 wages. This procedure specifies the conditions under which certain partnerships and S corporations may choose to calculate QPAI and W-2 wages as defined in regulations section 1.199-2T(e)(2) at the entity level, as well as the manner for allocating and reporting QPAI and W-2 wages to partners and shareholders for purposes of determining the deduction under section 199.

Income attributable to domestic production activities; statistical sampling. This procedure provides guidance for determining when statistical sampling may be used for purposes of section 199 of the Code and establishes acceptable statistical sampling methodologies.

EMPLOYEE PLANS

Roth IRA; rollover; prototype. This announcement provides that sponsors of prototype Roth IRAs must amend their prototype Roth IRA documents in order to permit the rollover of amounts from designated Roth accounts described in section 402A of the Code.

EXEMPT ORGANIZATIONS

The IRS has revoked its determination that Freedom Financial Consultants, Inc., of Lakeland, FL; Vista Vision 2000, Inc., of Norfolk, VA; Safeguarding America for Everyone (SAFE) Foundation, Inc., of Upper Marlboro, MD; and Homeownership Foundation of America, Inc., of Baltimore, MD, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

ADMINISTRATIVE

This document contains a correction to proposed regulations (REG-156779-06, 2007-17 I.R.B. 1015) relating to the determination of the amount of taxes paid for purposes of section 901.

This document contains corrections to proposed regulations (REG-144859-04, 2007-20 I.R.B. 1245) relating to the treatment of open account debt between S corporations and their shareholders.



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