International operation of ships or aircraft; foreign corporation. This ruling assists a foreign corporation engaged in the international operation of ships or aircraft, and its shareholders, in determining whether the foreign corporation is organized in a country that grants an “equivalent exemption” from tax for purposes of section 883(a) and (c) of the Code. The ruling also assists a nonresident alien individual engaged in the international operation of ships or aircraft in determining whether a country grants an equivalent exemption for purposes of section 872(b). The ruling does not, however, provide substantive guidance under section 883. Rev. Ruls. 89-42, 97-31, and 2001-48 modified and superseded.

This notice provides procedures for manufacturers to follow to certify both that a particular make, model, and model year of fuel cell motor vehicle meets the requirements of section 30B(a)(1) and (b) of the Code, and the amount of the credit allowable with respect to the vehicle.

This notice identifies a transaction in which a tax indifferent party contributes one or more distressed assets with a high basis and low fair market value to a trust or series of trusts and sub-trusts, and a U.S. taxpayer acquires an interest in the trust (and/or series of trusts and/or sub-trusts) for the purpose of shifting a built-in loss from the tax indifferent party to the U.S. taxpayer that has not incurred the economic loss.

This notice supersedes Notice 2006-27, 2006-1 C.B. 626, by substantially republishing the guidance contained in that publication while clarifying the meaning of the terms equivalent rating network, equivalent calculation procedure, and eligible contractor. The notice also clarifies the process for removing software from the list of approved software and provides for the extension of the tax credit through December 31, 2008. Notice 2006-27 clarified and superseded. Announcement 2006-88 clarified and superseded.

This notice supersedes Notice 2006-28, 2006-1 C.B. 628, by substantially republishing the guidance contained in that publication while clarifying the meaning of the terms equivalent rating network, equivalent calculation procedure, and eligible contractor. The notice also clarifies the process for removing software from the list of approved software and provides for the extension of the tax credit through December 31, 2008. Notice 2006-28 clarified and superseded. Announcement 2006-88 clarified and superseded.

This procedure provides that the Service will not challenge the accuracy of 2007 returns filed in compliance with Notice 2008-28, 2008-10 I.R.B. 546, by eligible individuals who enter $1.00 in adjusted gross income on their 2007 return for the sole purpose of effectuating the electronic filing of their 2007 tax return.

Automobile owners and lessees. This procedure provides owners and lessees of passenger automobiles (including trucks and vans) with tables detailing the limitations on depreciation deductions for passenger automobiles first placed in service during calendar year 2008 and the amounts to be included in income for passenger automobiles first leased during calendar year 2008.

This procedure provides an alternative dollar-value last-in, first-out (LIFO) pooling method, the Vehicle-Pool Method, for certain resellers of cars and light-duty trucks and provides procedures for obtaining automatic consent to change to that method. The procedure also provides the permissible method of pooling for crossover vehicles under the Alternative LIFO Method and the Used Vehicle Alternative LIFO Method for those resellers that do not choose to use the Vehicle-Pool Method. Rev. Procs. 97-36 and 2001-23 modified.

Alternative mortality tables; disabled individuals; defined benefit plans. This notice provides which mortality tables are permitted to be used to determine present values with respect to individuals who are entitled to benefits under a qualified defined benefit pension plan on account of disability.

Distributions; various issues; Pension Protection Act of 2006 (PPA ’06). This notice provides guidance in the form of questions and answers with respect to certain provisions contained in PPA ’06 that are effective in 2008 and are primarily related to distributions described in sections 302, 824, and 1004 of PPA ’06.

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 March 2008; the 24-month average segment rates; the funding transitional segment rates applicable for March 2008; and the minimum present value transitional rates for February 2008.

Insurance premiums; excise tax consequences. This ruling describes the insurance excise tax consequences (under section 4371 of the Code) of insurance premiums paid by one foreign insurer (foreign insurer) to another (foreign reinsurer). In particular, the ruling addresses the excise tax consequences of such payments where the foreign insurer is eligible for a waiver of the excise tax by income tax treaty but the foreign reinsurer is not. There are two types of insurance excise tax waivers provided by treaty. The ruling addresses both types of waivers. Rev. Rul. 58-612 clarified and amplified.

This announcement sets forth a voluntary compliance initiative that encourages any foreign person who has failed to pay excise taxes due under section 4371 of the Code, or failed to disclose that it has claimed a waiver from the taxes pursuant to an income tax treaty, to become compliant with its obligations. In general, if a taxpayer participates in this initiative in accordance with the terms laid out in this announcement, the IRS will not conduct examinations covering insurance excise tax liabilities arising under the four situations set forth in Rev. Rul. 2008-15 (this Bulletin), or any similar fact pattern, to the extent that premiums are paid or received by the participating taxpayer during any quarterly tax period prior to October 1, 2008.

Insurance premiums; excise tax consequences. This ruling describes the insurance excise tax consequences (under section 4371 of the Code) of insurance premiums paid by one foreign insurer (foreign insurer) to another (foreign reinsurer). In particular, the ruling addresses the excise tax consequences of such payments where the foreign insurer is eligible for a waiver of the excise tax by income tax treaty but the foreign reinsurer is not. There are two types of insurance excise tax waivers provided by treaty. The ruling addresses both types of waivers. Rev. Rul. 58-612 clarified and amplified.

International operation of ships or aircraft; foreign corporation. This ruling assists a foreign corporation engaged in the international operation of ships or aircraft, and its shareholders, in determining whether the foreign corporation is organized in a country that grants an “equivalent exemption” from tax for purposes of section 883(a) and (c) of the Code. The ruling also assists a nonresident alien individual engaged in the international operation of ships or aircraft in determining whether a country grants an equivalent exemption for purposes of section 872(b). The ruling does not, however, provide substantive guidance under section 883. Rev. Ruls. 89-42, 97-31, and 2001-48 modified and superseded.

This announcement sets forth a voluntary compliance initiative that encourages any foreign person who has failed to pay excise taxes due under section 4371 of the Code, or failed to disclose that it has claimed a waiver from the taxes pursuant to an income tax treaty, to become compliant with its obligations. In general, if a taxpayer participates in this initiative in accordance with the terms laid out in this announcement, the IRS will not conduct examinations covering insurance excise tax liabilities arising under the four situations set forth in Rev. Rul. 2008-15 (this Bulletin), or any similar fact pattern, to the extent that premiums are paid or received by the participating taxpayer during any quarterly tax period prior to October 1, 2008.

This notice identifies a transaction in which a tax indifferent party contributes one or more distressed assets with a high basis and low fair market value to a trust or series of trusts and sub-trusts, and a U.S. taxpayer acquires an interest in the trust (and/or series of trusts and/or sub-trusts) for the purpose of shifting a built-in loss from the tax indifferent party to the U.S. taxpayer that has not incurred the economic loss.