Internal Revenue Bulletin: 2007-25
June 18, 2007
Table of Contents
Insurance companies; aggregation of multiple modified endowment contracts (MECs). This ruling holds that if a taxpayer that owns multiple modified endowment contracts issued by the same insurance company in the same calendar year exchanges some of those MECs for new MECs issued by a second insurance company, the new contracts are not aggregated with the remaining contracts.
Partnership property; transfer. This ruling concludes that a transfer of partnership property to a partner in satisfaction of a guaranteed payment under section 707(c) of the Code is a sale or exchange under section 1001, and not a distribution under section 731.
This notice announces that the IRS and Treasury intend to issue regulations under section 367(b) of the Code to address certain triangular reorganizations involving foreign corporations. The regulations will apply to triangular reorganizations where either the parent corporation or its subsidiary are foreign and where the subsidiary acquires from shareholders of the parent, in exchange for property, parent stock that is used to acquire the stock or assets of a target corporation. The regulations make adjustments to the parent and the subsidiary corporations that have the effect of a distribution from the subsidiary to its parent of that amount of property that the subsidiary uses to acquire stock of its parent. Notice 2006-85 amplified.
This notice provides guidance on identifying covered employees for purposes of section 162(m)(3) of the Code. In general, covered employees are the principal executive officer and those officers whose total compensation for that taxable year is required to be reported to shareholders under the Securities Exchange Act by reason of such employee being among the 3 highest compensated officers for the taxable year (other than the principal executive officer or the principal financial officer).
This notice provides guidance relating to the percentage limitations imposed by section 170(b)(1)(E) of the Code on qualified conservation contributions made by individuals.
Addition of section 102(a) to the no-rule rev. proc. This procedure announces that the Service will not issue letter rulings or determination letters on whether a transfer is a gift within the meaning of section 102(a) of the Code. Rev. Proc. 2007-3 amplified.
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