Internal Revenue Bulletin: 2007-45
November 5, 2007
Final regulations under section 330 of title 31 of the U.S. Code provide amendments to the provisions of Circular 230 relating to various non-shelter items. This document reflects the Treasury Department and the IRS consideration of the comments received in response to the proposed regulations and the amendments to section 330 made by the American Jobs Creation Act of 2004, Public Law 108-357. The regulations also include conforming amendments to reflect the final regulations relating to best practices, covered opinions, and other written advice published as T.D. 9165, 2005-1 C.B. 357, and as T.D. 9201, 2005-1 C.B. 1153, but do not otherwise address those final regulations.
Proposed regulations under section 330 of title 31 of the U.S. Code amends section 10.34 of Circular 230 relating to standards with respect to tax returns. On May 25, 2007, the President signed into law the Small Business and Work Opportunity Tax Act of 2007, Public Law 110-28, which amended section 6694(a) of the Code by altering the standards of conduct that must be met to avoid imposition of the penalty for preparing a return that reflects an understatement of liability. The standards with respect to tax returns in section 10.34(a) of the regulations have been amended to reflect the changes to section 6694(a) made by the Small Business and Work Opportunity Act of 2007.
This notice provides that a material advisor required to file a completed Form 8918 by October 31, 2007, will be treated as satisfying the disclosure requirement of regulations section 301.6111-3(d) if the material advisor files Form 8264 instead. If Form 8918 is published on or before October 31, 2007, material advisors may choose to use either Form 8918 or Form 8264 for disclosures required to be filed by October 31, 2007. For disclosures required to be filed after October 31, 2007, material advisors must use Form 8918 (or successor form) unless instructed otherwise by the IRS. Reportable transactions disclosed on the Form 8264 should be disclosed in the manner described in Notice 2004-80, 2004-2 C.B. 963, and Notice 2005-22, 2005-1 C.B. 756.
Cost-of-living adjustments for 2008. This procedure sets forth the cost-of-living adjustments to certain items for 2008 as required under various provisions of the Code and Service guidance. Rev. Procs. 90-12 and 2002-41 modified.
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