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IRB 2007-52

Table of Contents
(Dated December 26, 2007)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2007-52. 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

Interest rates; underpayments and overpayments. The rates of interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 2008, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.

Final regulations under section 45G of the Code provide rules for claiming the railroad track maintenance credit for qualified railroad track maintenance expenditures paid or incurred by a Class II railroad or Class III railroad and other eligible taxpayers during the taxable year.

This procedure describes the conditions under which changes to certain subprime mortgage loans will not cause the Internal Revenue Service to challenge the tax status of certain securitization vehicles holding the loans.

EMPLOYEE PLANS

Distributions from governmental plans and health and accident insurance; section 845 of PPA '06. As a result of section 845 of the Pension Protection Act of 2006 and section 9(i)(1)(B) and (C) of S. 1974 and H.R. 3361, the pending Pension Protection Technical Corrections Acts of 2007, Q&A-23 of Notice 2007-7, 2007-5 I.R.B. 395, pertaining to distributions from certain health and accident plans is altered. Notice 2007-7 modified.

This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 409A(a) of the Code in operation (an operational failure), including: (1) methods for correcting certain operational failures during a service provider’s taxable year in which the failure occurs to avoid income inclusion under section 409A(a); (2) transition relief limiting the amount includible in income under section 409A(a) for certain operational failures occurring in a service provider’s taxable year beginning before January 1, 2010, that involve only limited amounts; (3) an outline of, and request for comments on, a potential corrections program that would permit service recipients and service providers to limit the amounts required to be included in income under section 409A(a) due to certain operational failures.

Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in December 2007; the 24-month average segment rates; the funding transitional segment rates applicable for December 2007; and the minimum present value transitional rates for November 2007.

EXEMPT ORGANIZATIONS

Temporary and proposed regulations under section 6033 of the Code describe the time and manner in which certain tax-exempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual electronic notice including certain information required by section 6033(i)(1)(A) through (F).

Temporary and proposed regulations under section 6033 of the Code describe the time and manner in which certain tax-exempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual electronic notice including certain information required by section 6033(i)(1)(A) through (F).

EMPLOYMENT TAX

Final regulations under section 3121 of the Code define the term “salary reduction agreement” for purposes of section 3121(a)(5)(D). The regulations provide guidance to employers (public educational institutions and section 501(c)(3) organizations) purchasing annuity contracts described in section 403(b) on behalf of their employees.

ADMINISTRATIVE

Temporary and proposed regulations under section 6033 of the Code describe the time and manner in which certain tax-exempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual electronic notice including certain information required by section 6033(i)(1)(A) through (F).

Temporary and proposed regulations under section 6033 of the Code describe the time and manner in which certain tax-exempt organizations not currently required to file an annual information return under section 6033(a)(1) are required to submit an annual electronic notice including certain information required by section 6033(i)(1)(A) through (F).

Proposed regulations under section 6045 of the Code provide guidance relating to information on the sale or exchange of standing timber for lump-sum payment. The regulations would amend section 1.6045-4(b)(2) by providing that the term “ownership interest” includes any contractual interest in a sale or exchange of standing timber for a lump-sum payment that is fixed and contingent. The regulations would also amend section 1.6045-4(c) to provide that the terms “crops” and “natural resources” do not include standing timber.



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