Internal Revenue Bulletin: 2008-11
March 17, 2008
Table of Contents
Fringe benefits aircraft valuation formula. The Standard Industry Fare Level (SIFL) cents-per-mile rates and terminal charge in effect for the first half of 2008 are set forth for purposes of determining the value of noncommercial flights on employer-provided aircraft under section 1.61-21(g) of the regulations.
S corporations; charitable contributions. This ruling provides guidance for S corporations that made charitable contributions of appreciated property during a taxable year beginning after December 31, 2005 and before January 1, 2008. The ruling provides that the amount of the charitable deduction the shareholder may claim may not exceed the sum of (i) the shareholder’s pro rata share of the fair market value of the contributed property over the shareholder’s pro rata share of the contributed property’s adjusted tax basis, and (ii) the amount of the Code section 1366(d) loss limitation amount that is allocable to the contributed property’s basis under regulations section 1.1366-2(a)(4).
Final regulations under section 1502 of the Code provide guidance regarding the manner in which the items (including items described in section 381(c) but excluding intercompany items under regulations section 1.1502-13) of a liquidating corporation are succeeded to and taken into account in cases in which multiple members acquire the assets of the liquidating corporation in a complete liquidation to which section 332 applies. The regulations affect corporations filing consolidated returns.
Final regulations under section 338 of the Code relate to the determination of the adjusted basis of amortizable section 197 intangible assets in the hands of an insurance company resulting from certain reinsurance transactions, increases in an insurance company’s reserves after a deemed sale, and a carryover to the new (target) insurance company of an election to use the old (target) insurance company’s historical payment pattern to discount unpaid losses. The final regulations apply to insurance companies.
This notice updates procedures for issuers of tax-exempt bonds and tax credit bonds to submit requests for voluntary closing agreements to resolve violations of the Code. Notice 2001-60 modified and superseded.
This notice provides interim guidance on the treatment under section 67 of the Code of investment advisory costs and other costs subject to the 2-percent floor under section 67(a) that are bundled as part of one commission or fee paid to the trustee or executor and are incurred by a trust other than a grantor trust or an estate.
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