Internal Revenue Bulletin:  2008-26 

June 30, 2008 

INCOME TAX


Rev. Rul. 2008-27 Rev. Rul. 2008-27

Interest rates; underpayments and overpayments. The rates of interest determined under section 6621 of the Code for the calendar quarter beginning July 1, 2008, will be 5 percent for overpayments (4 percent in the case of a corporation), 5 percent for underpayments, and 7 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 2.5 percent.

Rev. Rul. 2008-31 Rev. Rul. 2008-31

Interests in notional principal contracts. This ruling holds that certain interests in notional principal contracts, the returns on which are calculated by reference to an index based on data from a geographically and numerically broad range of United States real estate, are not United States real property interests under section 897(c)(1) of the Code.

Notice 2008-54 Notice 2008-54

This notice invites public comment relating to elections under section 864(f) of the Code to allocate and apportion interest expense on a worldwide affiliated group basis and under section 864(f)(5) to expand a financial institution group of a worldwide affiliated group.

Announcement 2008-57 Announcement 2008-57

This document contains corrections to Rev. Rul. 2008-17, 2008-12 I.R.B. 626, providing guidance to assist a foreign corporation engaged in the international operation of ships or aircraft, and its shareholders, in determining whether the foreign corporation is organized in a country that grants an “equivalent exemption” from tax for purposes of sections 883(a) and (c) of the Code. The ruling is also intended to assist a nonresident alien individual engaged in the international operation of ships or aircraft in determining whether a country grants an equivalent exemption from tax for purposes of section 872(b). As published, two footnotes were inadvertently omitted from Rev. Rul. 2008-17, Table II (Countries Granting Exemptions from Tax by Income Tax Convention), Column 9 (Cap Gains). Rev. Rul. 2008-17 modified.


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