Internal Revenue Bulletin: 2008-5
February 4, 2008
Table of Contents
Cell captive guidance. This ruling explains how arrangements between an individual cell and its owner are analyzed for purposes of determining whether there is adequate risk shifting and risk distribution to constitute insurance.
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 January 2008.
Final regulations under section 7216 of the Code update the rules regarding the disclosure and use of tax return information by tax preparers. Among other things, the regulations finalize rules for taxpayers to consent to the disclosure or use of their tax return information by tax return preparers. The regulations either modify or clarify (i) the scope of the circumstances to which the rule apply, (ii) the circumstances in which an income tax return preparer may disclose or use tax return information without taxpayer consent, and (iii) the circumstances in which an income tax return preparer may rely upon a taxpayer’s consent to disclose or use information that the income tax return preparer obtains in connection with the preparation of a return. The regulations are applicable to disclosures or uses of tax return information occurring on or after January 1, 2009.
This notice alerts life insurance companies to federal income tax issues that may arise as a result of the adoption of proposed Actuarial Guideline VACARVM and/or a proposed principles-based approach for calculating statutory reserves for life insurance proposed Life PBR. This notice identifies areas in which the Treasury Department and the Service have concerns and invites comments on these and other issues.
Cell captive guidance. This notice requests comments on a specific framework for determining whether an individual cell or the protected cell company as a whole is treated as an insurance company for federal income tax purposes.
This procedure provides guidance to tax return preparers regarding the format and content of consents to disclose and consents to use tax return information with respect to taxpayers filing a return in the Form 1040 series (e.g., Form 1040, Form 1040NR, Form 1040A, or Form 1040EZ) under regulations section 301.7216-3. This procedure also provides specific requirements for electronic signatures when a taxpayer executes an electronic consent to the disclosure or use of the taxpayer's tax return information.
This document provides advance notice that the Treasury Department and the IRS are considering issuing rules in proposed regulations (REG-136596-07) regarding the disclosure and use of tax return information by tax return preparers. The rules would apply to the marketing of refund anticipation loans (RALs) and certain other products in connection with the preparation of a tax return and, as an exception to the general principle that taxpayers should have control over their tax return information that is reflected in final regulations published in T.D. 9375, provide that a tax return preparer may not obtain a taxpayer’s consent to disclose or use tax return information for the purpose of soliciting taxpayers to purchase such products. This document invites comments from the public regarding these contemplated rules.
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