Internal Revenue Bulletin: 2008-22
June 2, 2008
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 June 2008.
Final regulations under section 368 of the Code amend regulations section 1.368-2(k) to clarify that, where the post-reorganization transfer(s) consists of one or more transfers to the former shareholders of the acquired corporation (other than a former shareholder that is also the acquiring corporation) and the transfer constitutes the receipt by such shareholders of additional consideration for their proprietary interests in the acquired corporation, the transaction as a whole is not afforded protection from application of the step transaction doctrine under section 1.368-2(k). In addition, the regulations clarify that the safe harbor of section 1.368-2(k) shall not apply to a transfer by the former shareholders of the acquired corporation (other than a former shareholder that is also the acquiring corporation) or the surviving corporation, as the case may be, of consideration initially received in the potential reorganization to the issuing corporation or a person related to the issuing corporation.
Final regulations under section 358 of the Code prevent abuse by removing the exception for transfers in which substantially all of the assets associated with a liability are transferred to the person assuming the liability as part of the exchange.
2009 inflation adjusted amounts for Health Savings Accounts (HSAs). This procedure provides the 2009 inflation adjusted amounts for HSAs under section 223 of the Code.
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