Internal Revenue Bulletin: 2007-7
February 12, 2007
Insurance companies; closing agreements. This notice requests comments on how the Service may improve the procedures for obtaining closing agreements to correct inadvertent failures of life insurance contracts or annuity contracts to satisfy the requirements of sections 817(h), 7702, or 7702A. The Service is also asking for comments on the four model closing agreements provided in this notice.
Insurance companies; modified endowment contracts. This procedure modifies Rev. Proc. 2001-42, 2001-2 C.B. 212, which provides procedures by which an issuer may remedy an in-advertent non-egregious failure to comply with the modified endowment contract (MEC) rules under section 7702A of the Code. The procedure updates information regarding the indices referenced in Rev. Proc. 2001-42 and also changes one of the indices. It allows the electronic submission of information and templates and changes the address to which payments required under the closing agreement are sent. Rev. Proc. 2001-42 modified and amplified.
This document contains corrections to proposed regulations (REG-208270-86, 2006-42 I.R.B. 698) regarding the determination of the items of income or loss of a taxpayer with respect to a section 987 of the Code qualified business unit as well as the timing, amount character, and source of any section 987 gain or loss.
This document cancels a public hearing on proposed regulations (REG-136806-06, 2006-47 I.R.B. 950) modifying the standards for treating payments in lieu of taxes (PILOTs) as generally applicable taxes for purposes of the private security or payment test under section 141 of the Code.
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