Internal Revenue Bulletin: 2007-29
July 16, 2007
Table of Contents
This notice describes a transaction in which a U.S. taxpayer uses offsetting positions with respect to foreign currency or other property for the purpose of importing a loss, but not the corresponding gain, in determining U.S. taxable income. The notice alerts taxpayers and their representatives that these transactions are tax avoidance transactions and identifies these transactions, and substantially similar transactions, as listed transactions for purposes of regulations section 1.6011-4(b)(2) and sections 6111 and 6112 of the Code.
This notice solicits comments on potential revisions to the definitions of financial services income, active financing income, and financial services entities as currently set forth in regulations section 1.904-4(e), issued under section 904(d) of the Code. The Treasury Department and the IRS are considering the appropriateness of revising these provisions in light of statutory changes made as part of the American Jobs Creation Act of 2004 to sections 864(f) and 904(d).
Sample inter vivos charitable lead annuity trust (CLAT). This procedure contains sample forms for inter vivos grantor and nongrantor charitable lead annuity trusts. The procedure also contains annotations to the sample trusts and alternate provisions that may be integrated into the sample trusts.
Sample testamentary charitable lead annuity trust (CLAT). This procedure contains a sample form, annotations, and alternate provisions for a testamentary charitable lead annuity trust.
This procedure sets forth conditions under which a research agreement does not result in private business use under section 141(b) of the Code. Rev. Proc. 97-14 modified and superseded.
Safe harbor method of accounting for rotable spare parts. This procedure provides a safe harbor method of accounting to treat rotable spare parts as depreciable assets in accordance with Rev. Rul. 2003-37, 2003-1 C.B. 717, and provides procedures for taxpayers to obtain automatic consent to change to the safe harbor method of accounting. Rev. Proc. 2002-9 modified and amplified.
This announcement alerts the public to the fact that proposed revisions to Form 1118, Foreign Tax Credit — Corporations, are being posted on the IRS website and solicits comments thereon. The revisions of Form 1118 were necessitated by statutory changes made to section 904 of the Code as part of the American Jobs Creation Act of 2004 relating to the number of separate foreign tax credit limitation categories and the effect of overall domestic losses.
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