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Legal Advice Issued by Associate Chief Counsel

 

These documents are legal advice, signed by executives in the National Office of the Office of Chief Counsel and issued to Internal Revenue Service personnel who are national program executives and managers. They are issued to assist Service personnel in administering their programs by providing authoritative legal opinions on certain matters, such as industry-wide issues. See Chief Counsel Notice CC-2007-003 (2-9-2007).

NOTE: These documents cannot be used or cited as precedent.

Number Release Date Subject
AM 2008-010 09/12/2008 Interaction of I.R.C. Section 965 and Rev. Proc. 99-32
AM 2008-009 08/29/2008 UK Pension Rollovers
AM 2008-008 07/11/2008 Applicability of Section 943(c) and (h) to Certain Transactions
AM 2008-007 07/04/2008 Dual Consolidated Losses: Application of the Exception to Foreign Use for Certain Interests in Partnerships or Grantor Trusts
AM 2008-006 05/30/2008 Reporting Requirements Under Section 6038B
AM 2008-005 05/16/2008 Timing of Credit for Foreign Tax Withheld from Wages
AM 2008-004 03/28/2008 Generic Legal Advice for Section 48A
AM 2008-003 02/22/2008 Treatment of Certain Distributions in Complete Liquidation by a REIT
AM 2008-002 02/08/2008 Section 280C(c)(3) - Guidance on Reduced Credit for Increasing Research Activities
AM 2008-001 01/25/2008 Dual Consolidated Losses: Reasonable Cause Requests Relating to Periods Where Assessment of Tax Under Section 6501(a) Is Not Permitted
AM 2007-017 10/31/2007 Applicability of Section 6695A Penalty to Estate & Gift Appraisals
AM 2007-016 09/25/2007 Application of Notice 88-108 to Section 956(a)(1)
AM 2007-015 07/27/2007 Section 162(f) and the Character of Relator Fees under the False Claims Act
AM 2007-014 07/24/2007 Integration of Convertible Notes with Hedges
AM 2007-013 06/15/2007 Exception to the Three-Year Requirement for Residences for Veterans Under Section 143(d)(2)(D)
AM 2007-012 06/08/2007 FIN 48 & Tax Accrual Workpapers
AM 2007-011 05/25/2007 Auxiliary Power Units (APU)
AM 2007-010 05/25/2007 Deductibility of Administrative Expenses of Bankruptcy
AM 2007-009 05/11/2007 Application of Sections 1.461-4(d)(6)(ii) and 1.461-5 to Service Contracts
AM 2007-008 04/20/2007 Lease-In/Lease-Out ("LILO") and Sale-In/Lease-Out ("SILO") Exit Strategy
AM 2007-007 03/23/2007 Taxpayer Use of Section 482 and the Commensurate With Income Standard
AM 2007-006 02/23/2007 Elections Under Section 338 With Respect to Foreign Corporate Targets
AM 2007-005 02/09/2007 Trusts Holding Interests in a Partnership
AM 2007-004 02/02/2007 Variable Purchase Contracts and Share Lending Agreements
AM 2007-003 02/02/2007 Construction Allowances for Short Term Leases of Retail Space Not Subject to Sec. 110
AM 2007-002 01/26/2007 State Tax Credit Transfers
AM 2007-001 01/12/2007 Qualification for FSC benefits and ETI Exclusions
AM 2006-006 10/11/2006 Cost of Restoring Property after Casualty Loss Deduction
AM 2006-005 10/13/2006 Subchapter S Banks and the Special Bank Rules
AM 2006-004 Pulled Adjusted Current Earnings for Certain Mining Property; re-published as CCA 200721019.
AM 2006-003 09/29/2006 Allocation of Capitalizable Mixed Service Costs to Ineligible Property
AM 2006-002 09/29/2006 Allocation under Sections 338 and 1060 to Assets in a Non-Qualified Nuclear Decommissioning Fund Purchased along with a Nuclear Power Plant
AM 2006-001 09/26/2006 Cross-Border Financial Instruments
Hybrid Debt/Equity - Equity in the U.S.