Internal Revenue Bulletin:  2007-16 

April 16, 2007 

INCOME TAX


Rev. Rul. 2007-25 Rev. Rul. 2007-25

Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through June 2007. This ruling provides the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through June 2007.

Rev. Rul. 2007-26 Rev. Rul. 2007-26

ICE Futures; United Kingdom. This ruling holds that ICE Futures, which is a United Kingdom Recognised Investment Exchange, is a qualified board or exchange within the meaning of section 1256(g)(7)(C) of the Code.

T.D. 9316 T.D. 9316

Final, temporary, and proposed regulations under section 368 of the Code provide guidance regarding the satisfaction of the continuity of interest requirement for corporate reorganizations. The regulations provide that in determining whether a proprietary interest in the target corporation is preserved, the consideration to be exchanged for the proprietary interests in the target corporation shall be valued on the last business day before there is a binding contract that contains fixed consideration.

REG-146247-06 REG-146247-06

Final, temporary, and proposed regulations under section 368 of the Code provide guidance regarding the satisfaction of the continuity of interest requirement for corporate reorganizations. The regulations provide that in determining whether a proprietary interest in the target corporation is preserved, the consideration to be exchanged for the proprietary interests in the target corporation shall be valued on the last business day before there is a binding contract that contains fixed consideration.

T.D. 9317 T.D. 9317

Final and temporary regulations concern the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities. The regulations provide guidance on certain transactions involving online software and clarify the rules regarding the application of section 199 to agricultural and horticultural cooperatives.

REG-158677-05 REG-158677-05

Proposed regulations under section 1361 of the Code clarify that if a bank is an S corporation within the meaning of section 1361(a)(1), its status as an S corporation does not affect the applicability of the special rules for banks under the Code.

Notice 2007-31 Notice 2007-31

This notice announces a new working arrangement for the automatic exchange of information entered into between the Service and the U.S. Virgin Islands Bureau of Internal Revenue. Because of this new working arrangement, the notice provides new interim rules, pending the issuance of regulations under sections 932(c) and 7654(e) of the Code, concerning the statute of limitations on assessment with respect to taxpayers claiming to be bona fide residents of the U.S. Virgin Islands for taxable years ending on or after December 31, 2006. Taxpayers may rely on this notice until regulations are issued. Notice 2007-19 amended and supplemented.

Rev. Proc. 2007-28 Rev. Proc. 2007-28

This document provides guidance to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries for tax year 2006 and the dates those countries are subject to the section 911(d)(4) waiver is provided.


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