This is the table of contents of Internal Revenue Bulletin IRB 2008-24. 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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Final regulations under section 704 of the Code clarify that where certain look-through entities (or members of a consolidated group) are partners in a partnership, the tax attributes of the owners of the look-through entities must be taken into account when testing whether the economic effect of an allocation is substantial within the meaning of section 704(b). Through an example, the final regulations also reiterate the effect of other provisions, such as section 482, upon the tax treatment of a partner with respect to the partner’s distributive share under section 704(b).
Final, temporary, and proposed regulations under section 367 of the Code implement the rules announced in Notices 2006-85, 2006-2 C.B. 677, and 2007-48, 2007-25 I.R.B. 1428. The notices announced that Treasury and the IRS would issue regulations under section 367(b) to address transactions where either a parent corporation (P) or its subsidiary (S) (or both) are foreign, and the corporations seek to avoid treating as a distribution the amount of property that S transfers to P or P’s shareholders in exchange for P stock, which S then uses to acquire the stock or assets of another corporation (T) in a triangular reorganization. Notices 2006-85 and 2007-48 obsoleted by T.D. 9400.
Final, temporary, and proposed regulations under section 367 of the Code implement the rules announced in Notices 2006-85, 2006-2 C.B. 677, and 2007-48, 2007-25 I.R.B. 1428. The notices announced that Treasury and the IRS would issue regulations under section 367(b) to address transactions where either a parent corporation (P) or its subsidiary (S) (or both) are foreign, and the corporations seek to avoid treating as a distribution the amount of property that S transfers to P or P’s shareholders in exchange for P stock, which S then uses to acquire the stock or assets of another corporation (T) in a triangular reorganization. Notices 2006-85 and 2007-48 obsoleted by T.D. 9400.
The IRS has revoked its determination that Community Child Care of Portland, OR; Camp Meeting of the Assoc. of the Newark Conf. of the Methodist Episcopal Church of Mount Tabor, NJ; Berryessa PAL Youth Football Club, Inc., of San Jose, CA; Rape Survivors Anonymous World Services, Inc., of Oswego, IL; and Round Rock Band Boosters, Inc., of Round Rock, TX, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.
Supplemental wages; income tax. This ruling provides guidance with respect to income tax withholding in nine different situations involving the payment of supplemental wages. Rev. Ruls. 66-294 and 67-131 obsoleted.
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