Table of Contents

• Notice 2008-99
  • FACTS
  • TRANSACTION OF INTEREST
    • Effective Date
    • Participation
    • Time for Disclosure
    • Material Advisor Threshold Amount
    • Penalties
  • REQUESTING COMMENTS
  • DRAFTING INFORMATION
• Rev. Proc. 2008-64
  • SECTION 1. PURPOSE
  • SECTION 2. BACKGROUND
  • SECTION 3. SALE OR EXCHANGE OF QUALIFIED PREFERRED STOCK BY A PARTNERSHIP IN WHICH AN APPLICABLE FINANCIAL INSTITUTION IS A PARTNER
  • SECTION 4. SALE OR EXCHANGE BY AN APPLICABLE FINANCIAL INSTITUTION OF AN INTEREST IN CERTAIN PARTNERSHIPS
  • SECTION 5. DISTRIBUTION OF QUALIFIED PREFERRED STOCK BY CERTAIN PARTNERSHIPS TO A PARTNER THAT IS AN APPLICABLE FINANCIAL INSTITUTION
  • SECTION 6. SALE OR EXCHANGE OF QUALIFIED PREFERRED STOCK BY CERTAIN SUBSIDIARIES OF APPLICABLE FINANCIAL INSTITUTIONS
  • SECTION 7. SALE OR EXCHANGE BY A TAXPAYER OF QUALIFIED PREFERRED STOCK THE BASIS OF WHICH IN THE TAXPAYER’S HANDS IS DETERMINED BY REFERENCE TO THE BASIS OF THAT STOCK IN THE HANDS OF THE PERSON THAT HAD TRANSFERRED IT TO THE TAXPAYER
  • SECTION 8. EFFECTIVE DATE
  • SECTION 9. CONTACT INFORMATION
  • SECTION 10. REQUEST FOR COMMENTS