This is the table of contents of Internal Revenue Bulletin IRB 2007-31. 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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Post-grant restrictions. This ruling sets forth the tax consequences under section 83 of the Code when restrictions are imposed on substantially vested stock causing that stock to become substantially nonvested. The ruling holds that if the imposition of such restrictions occurs in the absence of an exchange of stock, the substantially nonvested stock is not subject to section 83. However, if the substantially vested stock is exchanged for substantially nonvested stock, the substantially nonvested stock is subject to section 83.
Final regulations under section 954 of the Code contain rules for determining whether a controlled foreign corporation’s (CFC’s) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception). The regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs.
Temporary and proposed regulations under section 382 of the Code provide guidance regarding the treatment of prepaid income under the built-in gain provisions of section 382(h).
Temporary and proposed regulations under section 382 of the Code provide guidance regarding the treatment of prepaid income under the built-in gain provisions of section 382(h).
This announcement provides notice of a public hearing on proposed regulations (REG-109367-06, 2006-41 I.R.B. 683) clarifying the circumstances in which accounts or notes receivable are “acquired . . . for services rendered” within the meaning of section 1221(a)(4) of the Code. The public hearing is scheduled for August 22, 2007.
General rules and specifications for private printing of substitute forms. This procedure provides requirements for reproducing paper substitutes and for furnishing substitute recipient statements for Forms 1096, 1098, 1099, 5498, W-2G, and 1042-S. It will be reproduced as the next revision of Publication 1179. Rev. Proc. 2007-15 superseded.
The Service is establishing a procedure for temporary relief from certain requirements of section 42 of the Code for owners of low-income housing buildings and housing credit agencies in major disaster areas declared by the President. Rev. Proc. 95-28 superseded.
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