Internal Revenue Bulletin: 2007-23
June 4, 2007
Table of Contents
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for June 2007.
Proposed regulations under section 355 of the Code provide rules for implementing the separate affiliated group (SAG) rules of section 202 of the Tax Increase Prevention and Reconciliation Act of 2005, which permit all SAG members to be treated as one corporation for purposes of satisfying the active trade or business (ATB) requirement. In addition, the regulations provide guidance explaining (1) when a corporation is attributed trade or business assets and activities of a partnership, (2) when a corporation may use activities of an affiliate or a shareholder to meet the ATB requirement, (3) whether the corporation’s business was acquired in violation of section 355(b) “in a transaction in which gain or loss was recognized in whole or in part,” and (4) other miscellaneous rules.
This notice provides procedures for a vehicle manufacturer to certify that a heavy-duty hybrid vehicle meets certain requirements for the new qualified hybrid motor vehicle credit, and to certify the amount of the credit available with respect to the vehicle. This notice also provides guidance to taxpayers who purchase a heavy-duty hybrid vehicle regarding the conditions under which they may rely on the vehicle manufacturer’s certification.
Qualified production activities income (QPAI) and W-2 wages. This procedure specifies the conditions under which certain partnerships and S corporations may choose to calculate QPAI and W-2 wages as defined in regulations section 1.199-2T(e)(2) at the entity level, as well as the manner for allocating and reporting QPAI and W-2 wages to partners and shareholders for purposes of determining the deduction under section 199.
Income attributable to domestic production activities; statistical sampling. This procedure provides guidance for determining when statistical sampling may be used for purposes of section 199 of the Code and establishes acceptable statistical sampling methodologies.
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