The Twenty-First Annual Institute on Current Issues in International Taxation, jointly sponsored by the Internal Revenue Service and the George Washington University Law School, will be held on December 8 and 9, 2008, at the J.W. Marriott Hotel in Washington, D.C.

Final regulations under section 1361 of the Code contain guidance on S corporations with respect to the American Jobs Creation Act of 2004 (AJCA) and the Gulf Opportunity Zone Act of 2005 (GOZA). The regulations clarify certain shareholder rules. The regulations provide certain S corporation stock disposition rules for various trusts. The regulations describe information that needs to be provided in the electing small business trust (ESBT) election statement if an ESBT has certain powers. The regulations clarify the definition of a potential current beneficiary of an ESBT in certain situations. The regulations provide that the Commissioner may provide relief for inadvertent qualified subchapter S subsidiary (QSub) terminations and inadvertently invalid QSub elections. The regulations provide for the treatment of losses when S corporation stock is transferred between spouses or incident to divorce. Notice 2005-91 obsoleted.

Proposed regulations under section 336(e) of the Code provide rules that, when finalized, would permit taxpayers to make an election to treat certain sales, exchanges, and distributions of another corporation’s stock as taxable sales of that corporation’s assets.

Section 382. This notice concerns the application of section 382(h) of the Code to banks.

Extension of replacement period for livestock sold on account of drought. This notice explains the circumstances under which the 4-year replacement period under section 1033(e)(2) of the Code is extended for livestock sold on account of drought. The Appendix to this notice contains a list of the counties that experienced exceptional, extreme, or severe drought during the preceding 12-month period ending August 31, 2008. Taxpayers may use this list to determine if an extension is available.

This notice provides that the Treasury Department and the IRS will treat a tax-exempt “qualified tender bond” (as defined in Notice 2008-41) or “tax-exempt commercial paper” (as defined in section 2 of this notice) that is purchased by its “governmental issuer” (as defined in Notice 2008-41) on a temporary basis as continuing in effect without resulting in a reissuance or retirement of the purchased tax-exempt bond if the governmental issuer holds the bond until not later than December 31, 2009. This notice also extends the final date for the purchase of bonds pursuant to a qualified tender right, and the final date on which covered waivers of interest rate caps are disregarded, to December 31, 2009. Notice 2008-41 amended and supplemented.

This procedure provides areas affected by section 409A of the Code in which rulings will not be issued. Rev. Proc. 2008-3 modified and amplified.

This procedure provides guidance with respect to the application of section 1058(a) of the Code to situations in which securities are originally transferred pursuant to an agreement that meets the requirements of section 1058(b), the transferee subsequently defaults under the agreement as a direct or indirect result of its bankruptcy (or the bankruptcy of an affiliate), and as soon as is commercially practicable (but in no event more than 30 days following the default), the transferor applies collateral provided pursuant to the agreement to the purchase of identical securities.

This announcement contains clarification to filing procedures for Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, filed electronically. These changes are effective immediately. Announcement 2008-19 superseded.

This notice provides updated static mortality tables to be used in applying the minimum funding requirements to single employer defined benefit pension plans that do not choose to use generational mortality tables and are not approved to use employer-specific substitute mortality tables. These mortality tables are also used for multiemployer plans for purposes of applying certain funding requirements. These tables apply for purposes of calculating the funding target and other items for valuation dates occurring during the calendar years 2009 through 2013.

This notice provides relief for funding deadlines and other requirements for plans in certain counties affected by Hurricane Ike. Relief is provided pursuant to section 7508A(b) of the Code for certain plans affected by a Presidentially declared disaster.

This procedure provides areas affected by section 409A of the Code in which rulings will not be issued. Rev. Proc. 2008-3 modified and amplified.

This document sets forth the procedure by which the sponsor of a defined benefit plan, other than a multiemployer plan, may request and obtain approval for the use of plan-specific substitute mortality tables in accordance with section 430(h)(3)(C) of the Code and section 303(h)(3)(C) of the Employee Retirement Income Security Act of 1974 (ERISA), as amended. Rev. Proc. 2007-37 updated.

This document contains a correction to final and temporary regulations (T.D. 9417, 2008-37 I.R.B. 693) relating to the averaging of farm and fishing income in computing income tax liability.

This document contains a correction to proposed regulations (REG-161695-04, 2008-37 I.R.B. 699) relating to the averaging of farm and fishing income in computing income tax liability.

This announcement contains clarification to filing procedures for Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, filed electronically. These changes are effective immediately. Announcement 2008-19 superseded.