Internal Revenue Bulletin:  2007-31 

July 30, 2007 

INCOME TAX


Rev. Rul. 2007-49 Rev. Rul. 2007-49

Post-grant restrictions. This ruling sets forth the tax consequences under section 83 of the Code when restrictions are imposed on substantially vested stock causing that stock to become substantially nonvested. The ruling holds that if the imposition of such restrictions occurs in the absence of an exchange of stock, the substantially nonvested stock is not subject to section 83. However, if the substantially vested stock is exchanged for substantially nonvested stock, the substantially nonvested stock is subject to section 83.

T.D. 9326 T.D. 9326

Final regulations under section 954 of the Code contain rules for determining whether a controlled foreign corporation’s (CFC’s) distributive share of partnership income is excluded from foreign personal holding company income under the exception contained in section 954(i) (active insurance exception). The regulations will affect CFCs that are qualified insurance companies, as defined in section 953(e)(3), that have an interest in a partnership, and U.S. shareholders of such CFCs.

T.D. 9330 T.D. 9330

Temporary and proposed regulations under section 382 of the Code provide guidance regarding the treatment of prepaid income under the built-in gain provisions of section 382(h).

REG-144540-06 REG-144540-06

Temporary and proposed regulations under section 382 of the Code provide guidance regarding the treatment of prepaid income under the built-in gain provisions of section 382(h).

Announcement 2007-66 Announcement 2007-66

This announcement provides notice of a public hearing on proposed regulations (REG-109367-06, 2006-41 I.R.B. 683) clarifying the circumstances in which accounts or notes receivable are “acquired . . . for services rendered” within the meaning of section 1221(a)(4) of the Code. The public hearing is scheduled for August 22, 2007.


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