Internal Revenue Bulletin: 2008-2
January 14, 2008
Table of Contents
Foreign currency exchange traded notes. This ruling holds that a foreign currency exchange traded note is debt for U.S. federal tax purposes, even when the initial investment and repayment are made in U.S. dollars and the investor may get back fewer U.S. dollars than it invested. A companion publication to this ruling, Notice 2008-2, will ask for comments on prepaid forward contracts and similar arrangements that are not treated as debt for U.S. federal tax purposes.
Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through March 2008. 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 March 2008.
Section 1274A — Inflation adjusted numbers for 2008. This ruling provides the dollar amounts, increased by the 2008 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2007-4 supplemented and superseded.
This notice provides rules under which a 2-percent shareholder-employee in an S corporation is entitled to the deduction under section 162(l) of the Code for accident and health insurance premiums that are paid or reimbursed by the S corporation and included in the 2-percent shareholder-employee’s gross income.
This notice seeks comments on, among other things, whether the parties to a prepaid forward contract or similar arrangement (that is not otherwise indebtedness for U.S. federal tax purposes) should be required to accrue income/expense during the term of a contract and asks for comments on an appropriate method for accruing income or expense. The notice also asks for comments on various domestic and international issues (including character and source) that would need to be addressed if income/expense accruals were deemed appropriate. This notice is a companion publication to Rev. Rul. 2008-1, which concludes that a prepaid forward contract on foreign currency is treated as debt for federal tax purposes.
On January 1, 2008, the impuesto empresarial a tasa única (IETU), a single rate business tax adopted by Mexico, will become effective. This notice provides that, pending the outcome of a study to determine whether the IETU is a creditable income tax, the IRS will not challenge a taxpayer’s position that the IETU is an income tax that is eligible for a credit under Article 24(1) of the U.S.-Mexico income tax treaty.
This notice provides interim guidance to the public on how to file claims with the IRS Whistleblower Office for payment of awards to persons who detect and report underpayments of tax.
This notice provides guidance under section 152(d) of the Code for determining whether an individual is a qualifying relative for whom the taxpayer may claim a dependency exemption deduction under section 151(c).
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