Internal Revenue Bulletin: 2007-41
October 9, 2007
Table of Contents
Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through December 2007. This ruling provides the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through December 2007.
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 October 2007.
Final regulations under section 21 of the Code conform the rules relating to the child and dependent care credit to statutory changes, including amendments under the Working Families Tax Relief Act of 2004, and address significant issues that have arisen administratively. The regulations are renumbered to conform to the renumbering of the statute. Rev. Ruls. 76-278 and 76-288 obsoleted.
Final regulations under section 853 of the Code generally eliminate country-by-country reporting, by a regulated investment company (RIC) to its shareholders, of foreign source income that the RIC takes into account and foreign taxes that it pays.
Final regulations under section 338 of the Code permit taxpayers to elect to modify the application of the ADSP and AGUB allocation rules of regulations section 1.338-6 as regards nuclear decommissioning funds that do not qualify under section 468A. The election is available in both section 338 and 1060 transactions (in a section 1060 transaction, the election affects allocation of amount realized and basis rather than ADSP and AGUB).
Proposed regulations contain rules on the application of section 704(c)(1)(B) and 737 of the Code to distributions of property after two partnerships engage in an assets-over merger. The regulations provide that section 704(c)(1)(B) applies to newly created section 704(c) gain or loss in property contributed by the transferor partnership to the continuing partnership in an assets-over merger, but does not apply to newly created reverse section 704(c) gain or loss resulting from a revaluation of property in the continuing partnership. They also provide that for purposes of section 737(b), net precontribution gain includes newly created section 704(c) gain or loss in property contributed by the transferor partnership to the continuing partnership in an asset-over merger, but does not include newly created reverse section 704(c) gain or loss resulting from a revaluation of property in the continuing partnership. A public hearing is scheduled for December 5, 2007.
This notice provides transition relief and additional guidance on the application of section 409A of the Code to nonqualified deferred compensation plans. The notice generally extends to December 31, 2008, the deadline to adopt documents that comply with section 409A, subject to limited requirements regarding the timely written designation of a time and form of payment. The notice also provides guidance addressing certain issues raised by the application to employment agreements and cashout features of section 409A and the final regulations, and the application of section 409A(b) to certain trusts and other arrangements to pay for nonqualified deferred compensation.
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