This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA Program during calendar year 2007. This document does not provide guidance regarding the application of the arm’s length standard. Instead, it reports on the structure and activities of the APA Program.

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through June 2008. This ruling provides the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through June 2008.

Final, temporary, and proposed regulations amend regulations section 1.1502-13(c)(6)(ii)(C), which relates to the redetermination of intercompany gain as excluded from gross income.

Final, temporary, and proposed regulations amend regulations section 1.1502-13(c)(6)(ii)(C), which relates to the redetermination of intercompany gain as excluded from gross income.

Final regulations under section 817(h) of the Code make changes to the regulations concerning diversification requirements. The changes expand the list of holders whose beneficial interests in an investment company, partnership, or trust do not prevent a segregated asset account from looking through to the assets of the investment company, partnership, or trust, to satisfy the requirements of section 817(h). The regulations also remove the sentence in regulations section 1.817-5(a)(2) that provides that the payment required to remedy an inadvertent diversification failure must be based on the tax that would have been owed by the policyholders if they were treated as receiving the income on the contract.

This notice clarifies, amends, supplements, and supersedes Notice 2008-27, 2008-10 I.R.B. 543, which modified certain special reissuance standards for “qualified tender bonds” under IRS Notice 88-130, 1988-2 C.B. 543, and modified certain aspects of the application of regulations section 1.1001-3 as they apply to tax-exempt bonds. This notice retains the basic rule framework outlined in Notice 2008-27 except that it makes certain technical changes and extends, temporarily, the period of time, from 90 days to 180 days, during which an issuer may hold qualified tender bonds prior to their remarketing without causing such bonds to be treated as retired. This notice also introduces a temporary rule which allows a governmental issuer to purchase and hold its own tax-exempt auction rate bonds for 180 days without causing a retirement or extinguishment of the debt represented by the purchased tax-exempt bonds. Notice 2008-27 clarified, amended, supplemented, and superseded.

This notice provides that a modification of a life insurance split-dollar arrangement that does not include any change to the life insurance contract underlying the arrangement will not be treated as a material change in the life insurance contract underlying the arrangement.

This notice provides interim rules for contingent fees under section 10.27(b)(2) of Circular 230. Specifically, this notice provides (1) A clarification that the “within 120 days of the taxpayer receiving a written notice of the examination of, or a written challenge to the original tax return” language in section 10.27(b)(2)(ii) does not require the IRS to furnish the written notice of examination to a taxpayer as a prerequisite to a practitioner charging a contingent fee and (2) A new exception under section 10.27 that allows practitioners to charge a contingent fee with respect to whistleblower claims under section 7623(b) of the Code. The IRS will apply the interim rules under section 10.27(b)(2) in the notice until the Treasury Department and the IRS amend the regulations.

This document contains corrections to final and temporary regulations (T.D. 9368, 2008-6 I.R.B. 382) regarding the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Code. The regulations affect taxpayers claiming foreign tax credits and provide guidance needed to comply with the statutory changes made by the American Jobs Creation Act of 2004 (AJCA).

This document cancels a public hearing on proposed regulations (REG-141399-07, 2008-8 I.R.B. 470) providing guidance relating to the recapture of overall foreign and domestic losses.