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IRB 2008-36

Table of Contents
(Dated September 8, 2008)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2008-36. 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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Highlights of This Issue

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2008.

Final regulations under section 860G of the Code relate to income that is associated with a residual interest in a Real Estate Mortgage Investment Conduit (REMIC) and that is allocated through certain entities to foreign persons who have invested in those entities. The regulations accelerate the time when income is recognized for withholding tax purposes to conform to the timing of income recognition for general income tax purposes.

Under section 54B of the Code, up to $500,000,000 qualified forestry conservation bonds (QFCBs) may be issued for qualified forestry conservation purposes. The Secretary of the Department of Treasury must allocate the QFCB limitation amount among qualified applicants seeking any portion of the limitation. This notice solicits applications from qualified issuers of QFCBs for an allocation of the limitation and sets forth application requirements.

This procedure provides how, for purposes of sections 105(b), 106(a), 132(h)(2)(B), 220(d)(2), and 223(d)(2) of the Code, the IRS will treat a child of parents who are divorced, separated, or living apart as a dependent of both parents, when the custodial parent has not released the claim to the personal exemption for the child under section 152(e)(2).

This document provides the procedures by which taxpayers may obtain automatic consent for specifically identified changes in methods of accounting described in its APPENDIX. Rev. Proc. 2001-10, section 6.02(1)(a), modified and amplified. Rev. Proc. 2002-9 clarified, modified, amplified, and superseded. Rev. Proc. 2002-28, section 7.02(1)(a), modified and amplified. Rev. Proc. 2007-14 superseded. Rev. Proc. 2008-43 modified.

This procedure provides domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Code for taxable years beginning after December 31, 2006.

EXCISE TAX

Proposed regulations under section 4980G of the Code as amended by the Tax Relief and Health Care Act of 2006 provide guidance on employer contributions to Health Savings Accounts (HSAs). The regulations provide guidance on contributions to nonhighly compensated employees, guidance for employers that offer qualified HSA distributions, and guidance for employers that choose to make the maximum annual HSA contribution on behalf of all employees who are eligible individuals during the last month of the taxable year. The regulations also provide guidance relating to the requirement of a return to accompany payment of the excise tax under section 4980B, 4980D, 4980E, or 4980G and the time for filing that return. A public hearing is scheduled for October 30, 2008.



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