Internal Revenue Bulletin: 2007-28
July 9, 2007
Section 355. Using different scenarios, this ruling addresses whether a corporation that holds a membership interest in a limited liability company that is classified as a partnership for federal tax purposes is engaged in the active conduct of a trade or business for purposes of section 355(b) of the Code. Rev. Rul. 92-17 modified.
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 July 2007.
Proposed regulations under section 199 of the Code modify the definition of a qualified film produced by a taxpayer under regulations section 1.199-3(k); correct section 1.199-7(e), Example 10, of the final regulations; and remove the section 199 closing of the books election for expanded affiliated groups under section 1.199-7(f)(1)(ii) of the final regulations. A public hearing is scheduled for October 2, 2007.
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