Internal Revenue Bulletin: 2007-40
October 1, 2007
Table of Contents
Final regulations under section 1045 of the Code relate to partnerships and their partners. The regulations provide rules regarding the deferral of gain on a partnership’s sale of qualified small business stock (QSB stock) and a partner’s sale of QSB stock distributed by a partnership. The regulations also provide rules for a taxpayer (other than a C corporation) who sells QSB stock and purchases replacement QSB stock through a partnership. Rev. Proc. 98-48 modified.
This notice provides guidance to taxpayers to file all Forms 1098-C, Contributions of Motor Vehicles, Boats, and Airplanes, along with Form 1096, Annual Summary and Transmittal of U.S. Information Returns, at the Kansas City Service Center after December 31, 2007. The Internal Revenue Service Center at Ogden remains the location for Forms 1098-C filed on or before December 31, 2007. The Form 1098-C is an information form used by a donee organization to report a contribution of a qualified vehicle with a claimed value of more than $500. Notice 2006-1 modified.
This notice delays the effective date of Rev. Rul. 2006-57, 2006-47 I.R.B. 911. Rev. Rul. 2007-57 provides guidance to employers on the use of smartcards or other electronic media to provide qualified transportation fringes under sections 132(a)(5) and (f) of the Code. The guidance is intended to provide relief to mass transit providers that are currently finding it difficult to update their present systems in order to comply with the Rev. Rul. 2006-57 guidelines prior to the effective date. Rev. Rul. 2006-57 modified.
This notice provides adjusted limitations on housing expenses for tax year 2007 for purposes of section 911 of the Code.
This procedure permits certain partnerships to aggregate gains and losses from an expanded class of qualified financial assets for purposes of making reverse section 704(c) allocations under regulations section 1.704-3(e)(3).
This procedure provides a safe harbor under which companies taxable under Subchapter L do not have to include any portion of the increase for the taxable year in policy cash values of life insurance contracts described in section 264(f)(4)(A) of the Code (ICOLI Contracts) for purposes of applying the insurance company proration rules in sections 807(a)(2), 807(b)(1), 805(a)(4), 812, or 832(b)(5). Stakeholders are asked to comment on the need for additional guidance in this area, specifically with regard to the existence of any non-tax regulatory rules or other requirements that limit an insurance company’s ability to invest in ICOLI Contracts and the effect of any experience rating, inter-insurance, reciprocal, or reinsurance arrangement on transactions involving ICOLI Contracts.
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