Internal Revenue Bulletin:  2007-36 

September 4, 2007 

INCOME TAX


Rev. Rul. 2007-57 Rev. Rul. 2007-57

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 September 2007.

T.D. 9340 T.D. 9340

Final regulations provide updated guidance on tax-shelter annuities, custodial accounts of public schools and section 501(c)(3) tax-exempt organizations, and church retirement income accounts, authorized under section 403(b) of the Code. The regulations provide the public with the guidance necessary to comply with the law and will affect sponsors of section 403(b) contracts, administrators, participants and beneficiaries. The regulations also provide guidance relating to the controlled group rules under section 414(c) for entities that are tax-exempt under section 501(a).

T.D. 9343 T.D. 9343

Final regulations under section 1502 of the Code allow the Service to appoint a domestic substitute agent for a consolidated group when the group’s parent is a foreign corporation that is treated as a domestic corporation under section 7872 or as the result of a section 953(d) election.

T.D. 9344 T.D. 9344

Final, temporary, and proposed regulations under section 7425 of the Code relate to discharge of liens and return of wrongfully levied property under section 6343. The regulations clarify that notices and claims are to be sent to the IRS office and official specified in the relevant IRS publications.

REG-148951-05 REG-148951-05

Final, temporary, and proposed regulations under section 7425 of the Code relate to discharge of liens and return of wrongfully levied property under section 6343. The regulations clarify that notices and claims are to be sent to the IRS office and official specified in the relevant IRS publications.

T.D. 9345 T.D. 9345

Final regulations under sections 367 and 1248 of the Code set forth principles for the attribution of earnings and profits to shares of stock of current or former controlled foreign corporations that participate in certain nonrecognition transactions. The final regulations also provide that, for purposes of section 1248, when a foreign partnership sells stock of a corporation, the partners of the partnership are treated as selling their proportionate shares of such stock.

REG-101001-05 REG-101001-05

Proposed regulations under section 165 of the Code provide guidance on the availability and character of a deduction for a loss sustained from abandoned stock or other securities.

REG-128224-06 REG-128224-06

Proposed regulations under section 67 of the Code provide a uniform standard for identifying the types of costs incurred by estates or non-grantor trusts that are fully deductible in calculating adjusted gross income under section 67(e)(1). Costs incurred by estates or non-grantor trusts that are unique to an estate or trust are not miscellaneous itemized deductions that are deductible only to the extent they exceed 2 percent of adjusted gross income. A public hearing is scheduled for November 14, 2007.

Notice 2007-72 Notice 2007-72

Transaction of interest - contribution of successor member interest. This notice describes a transaction in which a taxpayer makes a charitable contribution of an interest in an entity that holds real property and claims a deduction for the contribution that is significantly higher than the amount the taxpayer paid to acquire the interest. This notice identifies the transaction, and substantially similar transactions, as transactions of interest for purposes of regulations section 1.6011-4(b)(6) and sections 6111 and 6112 of the Code; and alerts persons involved with these transactions to certain responsibilities that may arise from their involvement with these transactions.

Notice 2007-73 Notice 2007-73

This notice identifies a transaction that uses a grantor trust, and the purported termination and subsequent re-creation of the grantor trust, for the purpose of allowing the grantor to claim a tax loss greater than any actual economic loss sustained by the taxpayer or to avoid inappropriately the recognition of gain. The notice also alerts persons involved with these transactions to certain responsibilities that may arise from their involvement with these transactions.


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