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IRB 2008-46

Table of Contents
(Dated November 17, 2008)
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This is the table of contents of Internal Revenue Bulletin IRB 2008-46. 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

Final, temporary, and proposed regulations under section 901 of the Code provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. The regulations affect taxpayers that claim direct and indirect foreign tax credits. A public hearing on the proposed regulations is scheduled for December 11, 2008.

Final, temporary, and proposed regulations under section 901 of the Code provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. The regulations affect taxpayers that claim direct and indirect foreign tax credits. A public hearing on the proposed regulations is scheduled for December 11, 2008.

Proposed regulations under section 108(e)(8) of the Code provide guidance in determining the discharge of indebtedness income of a partnership that transfers a partnership interest to a creditor in satisfaction of the partnership’s indebtedness. In particular, the regulations address how the fair market value of a partnership interest transferred by the debtor partnership to the creditor in satisfaction of the partnership’s indebtedness is determined. The regulations also provide that section 721 generally applies to a contribution of a partnership’s indebtedness by a creditor to the partnership in exchange for an interest in the partnership. A public hearing is scheduled for February 19, 2009.

EMPLOYEE PLANS

This document solicits comments as to what should be included in implementing regulations (REG-123829-08) under the Genetic Information Nondiscrimination Act of 2008. Comments must be submitted on or before December 9, 2008.

EMPLOYMENT TAX

2009 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OASDI contribution and benefit base for remuneration paid in 2009 and self-employment income earned in taxable years beginning in 2009, and (2) the domestic employee coverage threshold amount for 2009.

EXCISE TAX

This announcement provides guidance to domestic coal producers and exporters regarding the submission of claims for refund of the coal excise tax paid under section 4121 on coal exported on or after October 1, 1990, and on or before October 3, 2008. Claims must be filed by November 3, 2008.

This document solicits comments as to what should be included in implementing regulations (REG-123829-08) under the Genetic Information Nondiscrimination Act of 2008. Comments must be submitted on or before December 9, 2008.

ADMINISTRATIVE

Final regulations under section 7804 of the Code amend 26 CFR 801 to clarify when quantity measures, which are not tax enforcement results, may be used in measuring organizational and employee performance.

This document provides notice of a public hearing on proposed regulations (REG-115457-08, 2008-33 I.R.B. 390) by cross-reference to temporary regulations relating to the simplification of procedures for automatic extensions of time to file certain returns. These simplified procedures are aimed at reducing overall taxpayer burden. The public hearing is scheduled for January 13, 2009.



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