Final regulations under section 199 of the Code revise certain rules and examples relating to the definitions of a qualified film produced by the taxpayer under section 199(c)(4)(A)(i)(II) and (c)(6) and an expanded affiliated group under section 199(d)(4).

Final regulations under section 165 of the Code provide guidance on the availability and character of a deduction for a loss sustained from abandoned stock or other securities.

Final regulations under section 168 of the Code provide guidance regarding the application of normalization accounting rules to balances of excess deferred income taxes and accumulated deferred investment tax credits of public utilities whose assets cease to be public utility property.

Proposed regulations under section 954(d) of the Code provide guidance in cases in which personal property sold by a controlled foreign corporation is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the controlled foreign corporation.

2007 section 45K inflation adjustment factor. This notice announces the applicable inflation adjustment factor and phase-out amount for the nonconventional source fuel credit for the 2007 calendar year.

Proposed regulations under section 432 of the Code provide additional rules for certain multiemployer defined benefit plans that are in effect on July 16, 2006. The regulations affect sponsors and administrators of, and participants in, multiemployer plans that are in either endangered or critical status. The regulations are necessary to implement the new rules set forth in section 432 that are effective for plan years beginning after 2007.

The IRS has revoked its determination that Educate the Children Foundation of Long Beach, CA; CFIDS Walk-A-Thon Committee of Hicksville, NY; Open Doors, Inc., of Duluth, GA; Amalgamated Credit Counselors of Lauderhill, FL; Carter Lake Charitable of Urbandale, IA; Christian Credit Counselors, Inc., of Las Vegas, NV; In Time Youth Group of Ontario, OR; Young Lions Foundation of Sausalito, CA; Charity Connections, Ltd., of Pittsford, NY; and North-Tartan Area Girls Basketball Booster Club of Oakdale, MN, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

Substitution power. This ruling provides guidance regarding whether the corpus of an inter vivos trust is includible in the grantor’s gross estate under section 2036 or 2038 of the Code if the grantor retained the power, exercisable in a nonfiduciary capacity, to acquire property held in the trust by substituting other property of equivalent value. The ruling provides that, for estate tax purposes, the substitution power will not, by itself, cause the value of the trust corpus to be includible in the grantor’s gross estate, provided the trustee has a fiduciary obligation (under local law) to ensure the grantor’s compliance with the terms of this power by satisfying itself that the properties acquired and substituted by the grantor are in fact of equivalent value and further provided that the substitution power cannot be exercised in a manner that can shift benefits among the trust beneficiaries.

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 contains a correction to final regulations (T.D. 9273, 2006-2 C.B. 394) addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is described in both sections 367(b) and 381 of the Code.

This document cancels a public hearing on proposed regulations (REG-114126-07, 2008-6 I.R.B. 410) that provide guidance relating to the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Code.