This is the table of contents of Internal Revenue Bulletin IRB 2008-23_irb. 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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Proposed regulations under section 704(c) of the Code provide that the section 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners. The regulations further provide that a section 704(c) allocation method cannot be used to achieve tax results inconsistent with the intent of subchapter K of the Code.
This procedure describes the conditions under which changes to certain residential mortgage loans will not cause the Service to challenge the tax status of certain securitization vehicles holding the loans or to assert that those modifications create a liability for tax on a prohibited transaction.
Electronic filing; 2008 form specifications. This procedure contains updates and changes to Publication 1220, Specifications for Filing Forms 1098, 1099, 5498 and W-2G Electronically (revised 5-2008). Rev. Proc. 2007-51 superseded.
This procedure modifies Rev. Proc. 2006-9, 2006-1 C.B. 278, which informs taxpayers how to secure an advance pricing agreement (APA) from the APA Program within the Office of Associate Chief Counsel (International). The procedure modifies Rev. Proc. 2006-9 to describe further the types of issues that may be resolved in the APA process. Rev. Proc. 2006-9 modified.
This document contains corrections to proposed regulations (REG-143397-05, 2007-41 I.R.B. 790) relating to rules on the application of sections 704(c)(1)(B) and 737 of the Code to distributions of property after two partnerships engage in an assets-over merger.
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