Internal Revenue Bulletin: 2007-15
April 9, 2007
Table of Contents
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 April 2007.
Final regulations under section 1503 of the Code address various dual consolidated loss issues, including exceptions to the general prohibition against using a dual consolidated loss to reduce the taxable income of any other member of the affiliated group. Section 1503(d) generally provides that a dual consolidated loss of a dual resident corporation cannot reduce the taxable income of any other member of the affiliated group unless, to the extent provided in regulations, such loss does not offset the income of any foreign corporation. Similar rules apply to losses of separate units of domestic corporations. Notice 2006-13 obsoleted. Rev. Proc. 2000-42 obsoleted in part.
This notice alerts taxpayers to common mistakes made on individual income tax returns.
Escrow accounts, trusts, and other funds used during deferred exchanges of like-kind property. A revised initial regulatory flexibility analysis discusses the impact on small businesses of proposed regulations (REG-113365-04, 2006-10 I.R.B. 580) relating to the current taxation of qualified escrow accounts, qualified trusts, and other escrow accounts, trusts, and funds used during deferred exchanges of like-kind property. The proposed regulations were published in the Federal Register on February 6, 2006.
This announcement publishes a copy of the news release issued by the Office of the Deputy Commissioner, International, on March 22, 2007. It provides a further extension, until June 30, 2007, of the deadline for current and former U.S.-based employees of foreign embassies, consular offices and missions, and international organizations to participate in a one-time settlement initiative to resolve outstanding tax matters related to their employment.
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