INCOME TAX
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 August 2007.
Final regulations under section 1502 of the Code simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corporations engaged in the international operation of ships or aircraft. The regulations introduce a new qualified U.S. person ownership test to replace the income inclusion test and provide corresponding documentation and reporting rules. The regulations also identify in regulations section 1.883-1(g) certain services as activities that are incidental to the international operation of ships or aircraft. They also explain in regulations section 1.883-1(h) that a foreign country may grant an equivalent exemption solely by means of an income tax convention. A public hearing on the proposed regulations is scheduled for October 24, 2007. Rev. Rul. 2001-48 and Notice 2006-43 modified.
Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corporations engaged in the international operation of ships or aircraft. The regulations introduce a new qualified U.S. person ownership test to replace the income inclusion test and provide corresponding documentation and reporting rules. The regulations also identify in regulations section 1.883-1(g) certain services as activities that are incidental to the international operation of ships or aircraft. They also explain in regulations section 1.883-1(h) that a foreign country may grant an equivalent exemption solely by means of an income tax convention. A public hearing on the proposed regulations is scheduled for October 24, 2007. Rev. Rul. 2001-48 and Notice 2006-43 modified.
Proposed regulations under section 274 of the Code provide rules relating to the deduction for expenses for the use of business aircraft for entertainment of specified individuals. A public hearing is scheduled for October 25, 2007.
EMPLOYEE PLANS
Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations under section 408(a) provide that the Commissioner may, in his discretion, allow governmental entities to act as qualified nonbank trustees for deemed IRAs which are part of the entities’ qualified employer plan within the meaning of section 408(q).
This notice announces the intent of the Treasury Department and the Service to issue guidance under section 457 of the Code, which applies to nonqualified deferred compensation plans of state and local governments and tax exempt entities, concerning the definitions of a bona fide severance pay plan under section 457(e)(11) and a substantial risk of forfeiture under section 457(f)(1)(B). This notice also describes the guidance that the Treasury and the Service anticipate issuing and requests comments on the issues intended to be addressed by such guidance.
This document contains numerous corrections to the preamble of final regulations (T.D. 9321, 2007-19 I.R.B. 1123) setting forth guidance on the application of section 409A to nonqualified compensation plans.
EXEMPT ORGANIZATIONS
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Final regulations under section 1502 of the Code simplify, clarify, or eliminate taxpayer reporting burdens. They also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.