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IRB 2007-47

Table of Contents
(Dated November 19, 2007)
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This is the table of contents of Internal Revenue Bulletin IRB 2007-47. 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

Abatement; interest accruals; federal income taxes. The Supreme Court holds that the Tax Court provides the exclusive forum for judicial review of failure to abate interest under section 6404(e)(1).

Final regulations under section 368 of the Code amend regulations sections 1.368-1(d), 1.368-2(f) and 1.368-2(k) concerning the tax treatment of post-reorganization transfers of assets or stock of a party to the reorganization.

Proposed regulations under section 31 U.S.C. 9701 implement new user fees for the initial and renewed enrollment to become an enrolled actuary. The new user fees established by the regulations reflect the IRS’s costs of overseeing the initial enrollment and renewal of enrollment processes. The regulations establish a $250 user fee for initial enrollment and a $250 user fee for renewal of enrollment. A public hearing is scheduled for November 26, 2007.

EXEMPT ORGANIZATIONS

A list is provided of organizations now classified as private foundations.

EMPLOYMENT TAX

2008 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OASDI contribution and benefit base for remuneration paid in 2008 and self-employment income earned in taxable years beginning in 2008, and (2) the domestic employee coverage threshold amount for 2008.

ADMINISTRATIVE

Abatement; interest accruals; federal income taxes. The Supreme Court holds that the Tax Court provides the exclusive forum for judicial review of failure to abate interest under section 6404(e)(1).

This document contains corrections to proposed regulations (REG-107592-00, 2007-44 I.R.B. 908) and withdrawal of proposed regulations (REG-105964-98) providing guidance regarding the treatment of transactions involving obligations between members of a consolidated group and the treatment of transactions involving the provision of insurance between members of a consolidated group. These regulations will affect corporations filing consolidated returns.



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.