<!-- TTST:[]: TTC:[]: TTSC:[]: TTT:[IRB]: TTS:[]: TTCP:[IRB 2007-38]: TTCI:[Highlights]: TTB:[]: TTA:[]: TTD:[]: -->

IRB 2007-38

Table of Contents
(Dated September 17, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-38. 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.

INCOME TAX

Life insurance reserves. This ruling provides guidance regarding (1) the amount of life insurance reserves taken into account for a variable contract where some or all of the reserves are accounted for as part of a life insurance company’s separate account reserves and (2) what interest rate is used to calculate required interest under section 812(b)(2)(A) of the Code on life insurance reserves in situations where the amount of those reserves is the tax reserve determined under section 807(d)(2).

Fringe benefits aircraft valuation formula. The Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the second half of 2007 are set forth for purposes of determining the value of noncommercial flights on employer-provided aircraft under section 1.61-21(g) of the regulations.

Revenue rulings obsolete. This ruling obsoletes Rev. Rul. 75-425, 1975-2 C.B. 291, which provides guidance related to the effect of signing a waiver (USCIS Form I-508) under section 247(b) of the Immigration and Nationality Act (8 U.S.C. section 1257(b)) by alien individuals employed in the United States by a foreign government or international organization. Rev. Rul. 75-425 obsoleted.

Final regulations under section 6655 of the Code provide guidance with respect to estimated tax payments by corporations. Rev. Ruls. 67-93, 76-450, and 78-257 obsoleted.

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

EXEMPT ORGANIZATIONS

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

Proposed regulations provide rules relating to information made available by the IRS for public inspection under section 6104(a) of the Code and materials that are made publicly available under section 6110.

ESTATE TAX

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

GIFT TAX

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

EMPLOYMENT TAX

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

EXCISE TAX

Final regulations under section 6011 of the Code modify and clarify the rules relating to the disclosure of reportable transactions under regulations section 1.6011-4. The regulations also make conforming changes to the disclosure rules under regulations sections 20.6011-4, 25.6011-4, 31.6011-4, 53.6011-4, 54.6011-4, and 56.6011-4. These regulations affect taxpayers who must disclose transactions under section 6011 and material advisors under sections 6111 and 6112.

ADMINISTRATIVE

Final regulations under section 6111 of the Code provide rules relating to the disclosure of reportable transactions by material advisors who must disclose transactions under section 6111 and material advisors who maintain lists under section 6112.

Final regulations under section 6112 of the Code provide rules relating to the list maintenance obligation of material advisors who must maintain lists under section 6112.

This document contains corrections to proposed regulations (REG-103842-07, 2007-28 I.R.B. 79) that involve the deduction for income attributable to domestic production activities under section 199 of the Code and that affect taxpayers who produce qualified films under sections 199(c)(4)(A)(i)(II) and (c)(6) and taxpayers who are members of an expanded affiliated group under section 199(d)(4).

This document contains corrections to final regulations (T.D. 9321, 2007-19 I.R.B. 1123) which set forth guidance on the application of secton 409A of the Code to nonqualified deferred compensation plans.

Announcement 2007-80

This document contains corrections to temporary regulations (T.D. 9330, 2007-31 I.R.B. 239) that apply to corporations that have undergone ownership changes within the meaning of section 382 of the Code. The regulations also provide guidance regarding the treatment of prepaid income under the built-in gain provisions of section 382(h).

This document provides a change of location for a public hearing on proposed regulations (REG-119097-05, 2007-28 I.R.B. 74) providing guidance on the portion of a trust properly includible in a grantor’s gross estate under sections 2036 and 2039 of the Code if the grantor has retained the use of property in a trust or the right to annuity, unitrust, or other income payment from such trust for life, for any period not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death.



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.