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IRB 2009-24

Table of Contents
(Dated June 15, 2009)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2009-24. 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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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 regulations under section 6045 of the Code provide guidance regarding the information reporting requirements on sales or exchanges of standing timber for lump-sum payments.

This notice provides guidance to employers that seek to claim the work opportunity credit for either of two new targeted groups of employees added to section 51 of the Code in the American Recovery and Reinvestment Tax Act of 2009.

This notice would propose a safe harbor for contracts with a maturity age of 100, which are intended to qualify as life insurance contracts under section 7702 of the Code and avoid characterization as an MEC under section 7702A, provided the contract complies with certain testing methodologies set out in the notice. The notice also asks for comments on several issues related to the use of an age 100 maturity.

This notice provides guidance under section 101(j) of the Code in the form of questions and answers concerning what entities are subject to the information reporting required for employer-owned life insurance contracts and how those entities can provide that information. Section 101(j) was added to the Code by the Pension Protection Act of 2006 to ensure that employees whose lives are insured by their employers are adequately informed of that coverage and its consequences. Section 6039I sets forth corresponding reporting obligations applicable to those employers who obtain life insurance coverage on their employees.

This procedure describes a new pilot program for single issue letter rulings in the context of section 355 distributions. Rev. Procs. 2009-1 and 2009-3 amplified.

TAX CONVENTIONS

This document provides a copy of the Competent Authority Agreement entered into on May 6, 2009, by the Competent Authorities of the United States and the Kingdom of Belgium regarding the arbitration process set forth in the United States-Belgium Income Tax Convention signed on November 27, 2006.

The Competent Authorities of the United States and Belgium have agreed to adopt guidelines regarding the arbitration process set forth in the United States-Belgium Income Tax Convention signed on November 27, 2006.

ADMINISTRATIVE

This document cancels a public hearing on proposed regulations (REG-138326-07, 2009-9 I.R.B. 638) under section 6231 of the Code that allow the IRS to convert partnership items to nonpartnership items when the application of the unified partnership audit and litigation procedures of sections 6221 thru 6234 (TEFRA partnership procedures) with respect to certain tax avoidance transactions interferes with the effective and efficient enforcement of the internal revenue laws.



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