Section 355. Using different scenarios, this ruling addresses whether a corporation that holds a membership interest in a limited liability company that is classified as a partnership for federal tax purposes is engaged in the active conduct of a trade or business for purposes of section 355(b) of the Code. Rev. Rul. 92-17 modified.

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 July 2007.

Proposed regulations under section 199 of the Code modify the definition of a qualified film produced by a taxpayer under regulations section 1.199-3(k); correct section 1.199-7(e), Example 10, of the final regulations; and remove the section 199 closing of the books election for expanded affiliated groups under section 1.199-7(f)(1)(ii) of the final regulations. A public hearing is scheduled for October 2, 2007.

Section 411(d)(3); partial termination; turnover. This ruling holds that based on its facts and circumstances, there is a presumption of a partial termination within the meaning of section 411(d)(3) of the Code where the turnover rate for employees participating in the qualified plan is at least 20 percent.

Qualification; determination letters; staggered remedial amendment periods. Rev. Proc. 2005-66, containing the Service’s procedures for issuing determination letters pursuant to section 401(a) of the Code with respect to a staggered remedial amendment period system both for plans that are and are not pre-approved, is clarified, modified, and superseded. Rev. Proc. 2005-16 modified.

Pre-approved defined benefit plans; GUST amendments. This announcement states that the program for GUST amendments for pre-approved defined benefit plans is being closed.

Special use value; farms; interest rates. The 2007 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.

Proposed regulations under sections 2036 and 2039 of the Code provide guidance on the portion of a trust that is properly includible in the grantor’s gross estate if the grantor has retained the use of property in a trust or the right to an annuity, unitrust, or other income payment from such a trust for life, for any period not ascertainable without reference to a grantor’s death, or for a period that does not in fact end before the grantor’s death. A public hearing is scheduled for September 26, 2007.

Final regulations under section 6103 of the Code describe the circumstances under which officers or employees of the Treasury Department, a state tax agency, the Social Security Administration, or the Department of Justice, may disclose returns and return information to obtain property or services for tax administration purposes, pursuant to a written contract or agreement.