Proposed regulations under section 7508A of the Code clarify rules relating to the postponement of certain tax-related acts by reason of a Presidentially declared disaster or terroristic or military action. The regulations clarify the scope of relief under section 7508A and specify that interest may be suspended during the postponement period. These changes are necessary to reflect changes in the law made by the Victims of Terrorism Tax Relief Act and current IRS practice.

This notice requests comments with respect to possible expansion of regulations section 1.475(a)-4 (safe harbor valuation regulations) so that financial institutions headquartered outside the United States can qualify to make the election described in regulations section 1.475(a)-4(b).

This procedure provides that the Service will not treat the debt instrument, issued by a corporation pursuant to a binding financial commitment obtained from an unrelated lender that satisfies certain conditions, as an applicable high yield discount obligation (AHYDO) for purposes of sections 163(e)(5) and 163(i) of the Code. As a result, no portion of the corporation’s interest deductions attributable to the debt instrument will be disallowed under section 163(e)(5).

This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sections 401(a), 403(a), 403(b), 408(k), or 408(p) of the Code, but that have not met these requirements for a period of time. This system, the Employee Plans Compliance Resolution System (EPCRS), permits Plan Sponsors to correct these failures and thereby continue to provide their employees with retirement benefits on a tax-favored basis. The components of EPCRS are the Self-Correction Program (SCP), the Voluntary Correction Program (VCP), and the Audit Closing Agreement Program (Audit CAP). Rev. Proc. 2006-27 modified and superseded. Rev. Proc. 2007-49, section 3, modified and superseded.

The IRS has revoked its determination that Ohio Taekwondo Association, Inc., of Cincinnati, OH; The Johnson Foundation of Sandy, UT; Chaim Ministries, Inc., of Los Alamitos, CA; Yes I Can of Burlington, NC; Surviving the System, Inc., of Peoria, AZ; Gravette Medical Center Hospital of Gravette, AR; D & L Carousel Pre-School of Los Angeles, CA; Christmas in April of Mobile, AL; Foundation for Life Enhancement of Dallas, TX; Colgate Residences, Inc., of Houston, TX; Help Ministries, Inc., of Mesa, AZ; CCC Centers of San Antonio, TX; Sunlight Ministries, Inc., of Brookhaven, MS; Consumer Credit Counseling Services of Huntsville, Inc., of Huntsville, AL; Universal Training Center Nonprofit Corporation of Highland, CA; and Deep South Community Development Corporation of Decatur, GA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code.

Final regulations under sections 2036 and 2039 of the Code provide guidance on the portion of property transferred to a trust or otherwise that is properly includible in the grantor’s gross estate if the grantor has retained the use of the property or the right to an annuity, unitrust, or other payment from the property for life, for any period not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death. Rev. Ruls. 76-273 and 82-105 obsoleted.

Proposed regulations under section 7508A of the Code clarify rules relating to the postponement of certain tax-related acts by reason of a Presidentially declared disaster or terroristic or military action. The regulations clarify the scope of relief under section 7508A and specify that interest may be suspended during the postponement period. These changes are necessary to reflect changes in the law made by the Victims of Terrorism Tax Relief Act and current IRS practice.