Internal Revenue Bulletin: 2007-44 |
October 29, 2007 |
Table of Contents
- Highlights of This Issue
- Preface
- Part III. Administrative, Procedural, and Miscellaneous
- Part IV. Items of General Interest
- REG-107592-00; REG-105964-98
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- ADDRESSES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Background
- Explanation of Provisions
- I. Intercompany Obligation Regulations
- A. General application
- B. The deemed satisfaction-reissuance model — Current Regulations and 1998 Proposed Regulations
- C. Revised deemed satisfaction-reissuance model for intragroup and outbound transactions
- 1. Simplified mechanics
- 2. The deemed satisfaction-reissuance amount
- D. Limitations on the application of the deemed satisfaction-reissuance model to intragroup transactions
- 1. Intragroup sections 332, 351, and 361 exchanges
- 2. Intragroup taxable assumption transactions
- 3. Intragroup extinguishments — in general
- 4. Routine intragroup modifications of intercompany obligations
- 5. Other exceptions for intragroup transactions
- E. Material tax benefit rule
- F. Off-market issuance rule
- G. Outbound transactions
- H. Inbound transactions
- I. Other request for comments
- II. Intercompany Insurance Regulations
- A. Current regulations
- B. Single entity treatment for significant insurance members
- C. Request for comments
- Proposed Effective/Applicability Date and Reliance
- Special Analyses
- Comments and Requests for a Public Hearing
- Withdrawal of Proposed Regulations
- Drafting Information
- Announcement 2007-100
- Announcement 2007-102
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Background
- Need for Correction
- Correction of Publication
- PART 1—INCOME TAXES
- § 1.403(b)-2 Definitions.
- § 1.403-3 Exclusion for contributions to purchase section 403(b) contracts.
- § 1.403(b)-4 Contribution limitations.
- § 1.403(b)-6 Timing of distributions and benefits.
- § 1.403(b)-11 Applicable dates.
- § 1.414(c)-5 Certain tax-exempt organizations.
- Announcement 2007-103
- Announcement of Disciplinary
Actions Involving Attorneys, Certified Public Accountants, Enrolled Agents,
and Enrolled Actuaries — Reinstatements, Suspensions, Censures, Disbarments,
and Resignations
- Reinstatement To Practice Before the Internal Revenue Service
- Consent Suspensions From Practice Before the Internal Revenue Service
- Expedited Suspensions From Practice Before the Internal Revenue Service
- Suspensions From Practice Before the Internal Revenue Service After Notice and an Opportunity for a Proceeding
- Disbarments From Practice Before the Internal Revenue Service After Notice and an Opportunity for a Proceeding
- REG-107592-00; REG-105964-98
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
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