Internal Revenue Bulletin 2008-26 (PDF rendition): IRS Revenue Rulings

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 200
8-26
June 30, 2008
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2008–27, page 1180.
Interest rates; underpayments and overpayments.The
rates of interest determined under section 6621 of the Code
for the calendar quarter beginning July 1, 2008, will be 5 per-
cent for overpayments (4 percent in the case of a corporation),
5 percent for underpayments, and 7 percent for large corpo-
rate underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 2.5 per-
cent.
Rev. Rul. 2008–31, page 1180.
Interests in notional principal contracts.This ruling holds
that certain interests in notional principal contracts, the returns
on which are calculated by reference to an index based on data
from a geographically and numerically broad range of United
States real estate, are not United States real property interests
under section 897(c)(1) of the Code.
Notice 2008–54, page 1191.
This notice invites public comment relating to elections under
section 864(f) of the Code to allocate and apportion interest ex-
pense on a worldwide affiliated group basis and under section
864(f)(5) to expand a financial institution group of a worldwide
affiliated group.
Announcement 2008–57, page 1192.
This document contains corrections to Rev. Rul. 2008–17,
2008–12 I.R.B. 626, providing guidance to assist a foreign
corporation engaged in the international operation of ships or
aircraft, and its shareholders, in determining whether the for-
eign corporation is organized in a country that grants an “equiv-
alent exemption” from tax for purposes of sections 883(a) and
(c) of the Code. The ruling is also intended to assist a non-
resident alien individual engaged in the international operation
of ships or aircraft in determining whether a country grants an
equivalent exemption from tax for purposes of section 872(b).
As published, two footnotes were inadvertently omitted from
Rev. Rul. 2008–17, Table II (Countries Granting Exemptions
from Tax by Income Tax Convention), Column 9 (Cap Gains).
Rev. Rul. 2008–17 modified.
EMPLOYEE PLANS
Notice 2008–53, page 1188.
Weighted average interest rate update; corporate bond
indices; 30-year Treasury securities; segment rates.
This notice contains updates for the corporate bond weighted
average interest rate for plan years beginning in June 2008;
the 24-month average segment rates; the funding transitional
segment rates applicable for June 2008; and the minimum
present value transitional rates for May 2008.
Announcement 2008–56, page 1192.
Employee stock ownership plans; dividends; section
404(k); reporting.This announcement provides for a change
in the reporting of dividends on employer securities that are
distributed from an employee stock ownership plan under
section 404(k) of the Code. Announcement 85–168 revoked.
EXEMPT ORGANIZATIONS
Announcement 2008–60, page 1194.
A list is provided of organizations now classified as private foun-
dations.
(Continued on the next page)
Announcements of Disbarments and Suspensions begin on page 1195.
Fi
nding Lists begin on page ii.
Index for January through June begins on page vi.

ADMINISTRATIVE
Announcement 2008–58, page 1193.
Announcement 2008–59, page 1193.
These documents contain corrections to final regulations
(T.D. 9398, 2008–24 I.R.B. 1143) providing rules for testing
whether the economic effect of an allocation is substantial
within the meaning of section 704(b) of the Code where
partners are look-through entities or members of a consoli-
dated group. The regulations clarify the application of section
704(b) to partnerships the interests of which are owned by
look-through entities and members of consolidated groups
and, through an example, reiterate the effect of other provi-
sions of the Code on partnership allocations.
June 30, 20082008–26 I.R.B.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax law with
integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
2008–26 I.R.B.June 30, 2008

June 30, 20082008–26 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 897.—
Disposition
of Investment in United
States Real Property
26 CFR 1.897–1: Taxation of foreign investment in
United States real property interests; definition of
terms.
Interests in notional principal con-
tracts.This ruling holds that certain in-
terests in notional principal contracts, the
returns on which are calculated by refer-
ence to an index based on data from a ge-
ographically and numerically broad range
of United States real estate, are not United
States real property interests under section
897(c)(1) of the Code.
Rev. Rul. 2008–31
ISSUE
Is an interest in a notional principal con-
tract, the return on which is calculated by
reference to an index described below ref-
erencing data from a geographically and
numerically broad range of United States
real estate a United States real property in-
terest (“USRPI”) under section 897(c)(1)
of the Code?
FACTS
X maintains and widely publishes an in-
dex (the “Index”) that seeks to measure the
appreciation and depreciation of residen-
tial or commercial real estate values within
a metropolitan statistical area (“MSA”), a
combined statisticalarea (“CSA”) (both
as defined by the United States Office of
Management and Budget), or a similarly
large geographic area within the United
States. The MSA, CSA or similarly large
geographic area has a population exceed-
ing one million people. The Index is cal-
culated by reference to (1) sales prices (ob-
tained from various public records), (2) ap-
praisals and reported income, or (3) similar
objective financial information, each with
respect to a broad range of real property
holdings of unrelated owners within the
relevant geographic area during a relevant
testing period. Using proprietary methods,
this information is weighted, aggregated,
and mathematically translated into the In-
dex.
Because of the
broad-based nature of
the Index, an i
nvestor cannot, as a practical
matter, direc
tly or indirectly, own or lease
a material pe
rcentage of the real estate, the
values of whi
ch are reflected by the Index.
On January 1,
Year 1, FC, a foreign cor-
poration, en
ters into a notional principal
contract (“N
PC”), within the meaning of
sections 1.4
46–3(c)(1) and 1.863–7(a)(1)
of the Incom
e Tax regulations, with unre-
lated count
erparty DC, a domestic corpo-
ration. Nei
ther FC nor DC is related to X.
Pursuant to
the NPC, FC profits if the In-
dex apprec
iates (that is, to the extent the
underlyin
g United States real property in
the partic
ular geographic region appreci-
ates in val
ue) over certain levels. Con-
versely, F
C suffers a loss if the Index de-
preciate
s (or fails to appreciate more than
at a speci
fied rate). During the term of the
NPC, DC do
es not, directly or indirectly,
own or lea
se a material percentage of the
real prop
erty, the values of which are re-
flected
by the Index.
LAW
Section 897(a) provides that gain or loss
from the disposition of a USRPI of a non-
resident alien individual or a foreign cor-
poration shall be taken into account as
effectively connected income under sec-
tion 871(b)(1) or section 882(a)(1), respec-
tively, as if the taxpayer were engaged in a
trade or business within the United States
during the taxable year and as if such gain
or loss were effectively connected with
such trade or business.
A USRPI is generally defined under
section 897(c)(1)(A) as either an interest in
real property located in the United States
or the Virgin Islands, or any interest (other
than an interest solely as a creditor) in any
domestic corporation unless the taxpayer
establishes that such corporation was at no
time a USRPHC during certain periods.
The term “interest in real property” un-
der section 897(c)(6)(A) includes fee own-
ership and co-ownership of land or im-
provements thereon, leaseholds of land or
improvements thereon, options to acquire
land or improvements thereon, and options
to acquire leaseholds of land or improve-
ments thereon.
Section 1.897
–1(c)(1) of the regula-
tions general
ly defines USRPIs to include
any interest,
other than an interest solely
as a creditor
, in real property located in
the United St
ates or the Virgin Islands.
Section 1.89
7–1(d)(2)(i) provides that an
interest in r
eal property other than solely
as a credito
r includes a fee ownership,
co-ownersh
ip, or leasehold interest in real
property, a
time sharing interest in real
property, a
nd a life estate, remainder, or
reversiona
ry interest in such real property.
The term al
so includes any direct or indi-
rect right
to share in the appreciation in
the value,
or in the gross or net proceeds
or profits
generated by, the real property.
HOLDING
Because of the broad-based nature of
the Index, the NPC does not represent a
“direct or indirect right to share in the ap-
preciation in the value ... [of] the real prop-
erty” within the meaning of Treas. Reg.
§ 1.897–1(d)(2). Accordingly, FC’s inter-
est in the NPC calculated by reference to
the Index is not a USRPI under section
897(c)(1).
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Sean W. Mullaney of the Office of
Associate Chief Counsel (International).
For further information regarding this rev-
enue ruling, contact Mr. Mullaney at (202)
622–3860 (not a toll-free call).
Section 6621.—Determina-
tion of Rate of Interest
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayments and
overpayments.The rates of interest de-
termined under section 6621 of the Code
for the calendar quarter beginning July 1,
2008, will be 5 percent for overpayments
(4 percent in the case of a corporation), 5
percent for underpayments, and 7 percent
for large corporate underpayments. The
rate of interest paid on the portion of a
corporate overpayment exceeding $10,000
will be 2.5 percent.
2008–26 I.R.B.1180June 30, 2008

Rev. Rul. 2008–27
Section 6621 of the Internal Revenue
Code establishes the rates for interest
on tax overpayments and tax underpay-
ments. Under section 6621(a)(1), the
overpayment rate is the sum of the federal
short-term rate plus 3 percentage points
(2 percentage points in the case of a cor-
poration), except the rate for the portion
of a corporate overpayment of tax exceed-
ing $10,000 for a taxable period is the
sum of the federal short-term rate plus
0.5 of a percentage point. Under section
6621(a)(2), the underpayment rate is the
sum of the federal short-term rate plus 3
percentage points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under section
6621(a)(2) is determined by substituting
“5 percentage points” for “3 percentage
points.” See section 6621(c) and section
301.6621–3 of the Regulations on Proce-
dure and Administration for the definition
of a large corporate underpayment and
for the rules for determining the appli-
cable date. Section 6621(c) and section
301.6621–3 are generally effective for
periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal
short-term rate for the first month in each
calendar quarter.
Section 6621(b)(2)(A) provides that the
federal short-term rate determined under
section 6621(b)(1) for any month applies
during the first calendar quarter beginning
after that month. Section 6621(b)(3) pro-
vides that the federal short-term rate for
any month is the federal short-term rate de-
termined during that month by the Secre-
tary in accordance with section 1274(d),
rounded to the nearest full percent (or, if
amultipleof
1
/2of 1 percent, the rate is in-
creased to the next highest full percent).
Notice 88–59, 1988–1 C.B. 546, an-
nounced that, in determining the quarterly
interest rates to be used for overpayments
and underpayments of tax under section
6621, the Internal Revenue Service will
use the federal short-term rate based on
daily compounding because that rate is
most consistent with section 6621 which,
pursuant to section 6622, is subject to daily
compounding.
Rounded to the nearest full percent, the
federal short-term rate based on daily com-
pounding determined during the month of
April 2008 is 2 percent. Accordingly, an
overpayment rate of 5 percent (4 percent
in the case of a corporation) and an under-
payment rate of 5 percent are established
for the calendar quarter beginning July 1,
2008. The overpayment rate for the por-
tion of a corporate overpayment exceeding
$10,000 for the calendar quarter beginning
July 1, 2008, is 2.5 percent. The under-
payment rate for large corporate underpay-
ments for the calendar quarter beginning
July 1, 2008, is 7 percent. These rates ap-
ply to amounts bearing interest during that
calendar quarter.
Interest factors for daily compound in-
terest for annual rates of 2.5 percent, 4 per-
cent, 5 percent, and 7 percent are published
in Tables 58, 61, 63, and 67 of Rev. Proc.
95–17, 1995–1 C.B. 556, 612, 615, 617,
and 621.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Wendy Kribell of the Office of
Associate Chief Counsel (Procedure &
Administration). For further informa-
tion regarding this revenue ruling, contact
Ms. Kribell at (202) 622–4570 (not a
toll-free call).
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATE
In 1995–1 C.B.
DAILY RATE TABLE
Before Jul. 1, 1975
6%
Table 2, pg. 557
Jul. 1, 1975—Jan. 31, 1976
9%
Table 4, pg. 559
Feb. 1, 1976—Jan. 31, 19787%
Table 3, pg. 558
Feb. 1, 1978—Jan. 31, 19806%
Table 2, pg. 557
Feb. 1, 1980—Jan. 31, 198212%
Table 5, pg. 560
Feb. 1, 1982—Dec. 31, 198220%
Table 6, pg. 560
Jan. 1, 1983—Jun. 30, 198316%
Table 37, pg. 591
Jul. 1, 1983—Dec. 31, 198311%
Table 27, pg. 581
Jan. 1, 1984—Jun. 30, 198411%
Table 75, pg. 629
Jul. 1, 1984—Dec. 31, 198411%
Table 75, pg. 629
Jan. 1, 1985—Jun. 30, 1985
13%
Table 31, pg. 585
Jul. 1, 1985—Dec. 31, 1985
11%
Table 27, pg. 581
Jan. 1, 1986—Jun. 30, 198610%
Table 25, pg. 579
Jul. 1, 1986—Dec. 31, 19869%
Table 23, pg. 577
June 30, 200811812008–26 I.R.B.

TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1987—Mar. 31, 19878%21
575
9%23
577
Apr. 1, 1987—Jun
. 30, 1987
8%21
575
9%23
577
Jul. 1, 1987—Sep. 30, 19878%21
575
9%23
577
Oct. 1, 1987—Dec. 31, 19879%23
577
10%
25579
Jan. 1, 1988—Ma
r. 31, 1988
10%7362711%
75
629
Apr. 1, 1988—Jun. 30, 19889%71
625
10%73627
Jul. 1, 1988—Sep. 30, 19889%71
625
10%73627
Oct. 1, 1988—D
ec. 31, 1988
10%7362711%
75
629
Jan. 1, 1989—Mar. 31, 198910%
25579
11%27
581
Apr. 1, 1989—Jun. 30, 198911%27
581
12%29
583
Jul. 1, 1989—
Sep. 30, 1989
11%27
581
12%29
583
Oct. 1, 1989—Dec. 31, 198910%
25579
11%27
581
Jan. 1, 1990—Mar. 31, 199010%
25579
11%27
581
Apr. 1, 1990
—Jun. 30, 1990
10%
25579
11%27
581
Jul. 1, 1990—Sep. 30, 199010%
25579
11%27
581
Oct. 1, 1990—Dec. 31, 199010%
25579
11%27
581
Jan. 1, 199
1—Mar. 31, 1991
10%
25579
11%27
581
Apr. 1, 1991—Jun. 30, 19919%23
577
10%
25579
Jul. 1, 1991—Sep. 30, 19919%23
577
10%
25579
Oct. 1, 19
91—Dec. 31, 1991
9%23
577
10%
25579
Jan. 1, 1992—Mar. 31, 19928%696239%71
625
Apr. 1, 1992—Jun. 30, 19927%676218%69623
Jul. 1, 1
992—Sep. 30, 1992
7%676218%69623
Oct. 1, 1992—Dec. 31, 19926%
65
6197%67621
Jan. 1, 1993—Mar. 31, 19936%17
571
7%19
573
Apr. 1,
1993—Jun. 30, 1993
6%17
571
7%19
573
Jul. 1, 1993—Sep. 30, 19936%17
571
7%19
573
Oct. 1, 1993—Dec. 31, 19936%17
571
7%19
573
Jan. 1,
1994—Mar. 31, 1994
6%17
571
7%19
573
Apr. 1, 1994—Jun. 30, 19946%17
571
7%19
573
Jul. 1, 1994—Sep. 30, 19947%19
573
8%21
575
Oct. 1
, 1994—Dec. 31, 1994
8%21
575
9%23
577
Jan. 1, 1995—Mar. 31, 1995
8%21
575
9%23
577
Apr.
1, 1995—Jun. 30, 1995
9%23
577
10%
25579
Jul. 1, 1995—Sep. 30, 1995
8%21
575
9%23
577
Oct. 1, 1995—Dec. 31, 1995
8%21
575
9%23
577
Jan. 1, 1996—Mar. 31, 19968%696239%71
625
Apr
. 1, 1996—Jun. 30, 1996
7%676218%69623
Jul. 1, 1996—Sep. 30, 19968%696239%71
625
Oct. 1, 1996—Dec. 31, 19968%696239%71
62
5
Ja
n. 1, 1997—Mar. 31, 1997
8%21
575
9%23
577
Apr. 1, 1997—Jun. 30, 19978%21
575
9%23
577
Jul. 1, 1997—Sep. 30, 19978%21
57
5
9%23
57
7
Oc
t. 1, 1997—Dec. 31, 1997
8%21
575
9%23
577
Jan. 1, 1998—Mar. 31, 19988%21
575
9%23
577
Apr. 1, 1998—Jun. 30, 19987%19
5
73
8%21
5
75
J
ul. 1, 1998—Sep. 30, 1998
7
%
1
9
573
8
%
2
1
575
Oct. 1, 1998—Dec. 31, 19987%19
573
8%21
575
2008–26 I.R.B.1182June 30, 2008

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Jan. 1, 1999—Mar. 31, 19997%19
573
Apr. 1, 1999—Jun. 30, 19998%21
575
Jul. 1, 1999—Sep. 30, 19998%21
575
Oct. 1, 1999—Dec. 31, 19998%21
575
Jan. 1, 2000—Mar. 31, 20008%69623
Apr. 1, 2000—Jun. 30, 20009%71
625
Jul. 1, 2000—Sep. 30, 20009%71
625
Oct. 1, 2000—Dec. 31, 20009%71
625
Jan. 1, 2001—Mar. 31, 20019%23
577
Apr. 1, 2001—Jun. 30, 20018%21
575
Jul. 1, 2001—Sep. 30, 20017%19
573
Oct. 1, 2001—Dec. 31, 20017%19
573
Jan. 1, 2002—Mar. 31, 20026%17
571
Apr. 1, 2002—Jun. 30, 20026%17
571
Jul. 1, 2002—Sep. 30, 20026%17
571
Oct. 1, 2002—Dec. 31, 20026%17
571
Jan. 1, 2003—Mar. 31, 2003
5%15569
Apr. 1, 2003—Jun. 30, 2003
5%15569
Jul. 1, 2003—Sep. 30, 2003
5%15569
Oct. 1, 2003—Dec. 31, 20034%13
567
Jan. 1, 2004—Mar. 31, 20044%61
615
Apr. 1, 2004—Jun. 30, 2004
5%
63617
Jul. 1, 2004—Sep. 30, 20044%61
615
Oct. 1, 2004—Dec. 31, 2004
5%
63617
Jan. 1, 2005—Mar. 31, 20055%15569
Apr. 1, 2005—Jun. 30, 2005
6%17
571
Jul. 1, 2005—Sep. 30, 2005
6%17
571
Oct. 1, 2005—Dec. 31, 2005
7%19
573
Jan. 1, 2006—Mar. 31, 20067%19
573
Apr. 1, 2006—Jun. 30, 20067%19
573
Jul. 1, 2006—Sep. 30, 20068%21
575
Oct. 1, 2006—Dec. 31, 20068%21
575
Jan. 1, 2007—Mar. 31, 20078%21
575
Apr. 1, 2007—Jun. 30, 20078%21
575
Jul. 1, 2007—Sep. 30, 20078%21
575
Oct. 1, 2007—Dec. 31, 20078%21
575
Jan. 1, 2008—Mar. 31, 20087%67621
Apr. 1, 2008—Jun. 30, 20086%
65
619
Jul. 1, 2008—Sep. 30, 2008
5%
63617
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1999—Mar. 31, 19996%17
571
7%19
573
Apr. 1, 1999—Jun. 30, 19997%19
573
8%21
575
Jul. 1, 1999—Sep. 30, 19997%19
573
8%21
575
Oct. 1, 1999—Dec. 31, 19997%19
573
8%21
575
Jan. 1, 2000—Mar. 31, 20007%676218%69623
June 30, 200811832008–26 I.R.B.

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Apr. 1, 2000—Jun. 30, 20008%696239%71
625
Jul. 1, 2000—Sep. 30, 20008%696239%71
625
Oct. 1, 2000—De
c. 31, 2000
8%696239%71
625
Jan. 1, 2001—Mar. 31, 20018%21
575
9%23
577
Apr. 1, 2001—Jun. 30, 20017%19
573
8%21
575
Jul. 1, 2001—S
ep. 30, 2001
6%17
571
7%19
573
Oct. 1, 2001—Dec. 31, 20016%17
571
7%19
573
Jan. 1, 2002—Mar. 31, 2002
5%15569
6%17
571
Apr. 1, 2002—
Jun. 30, 2002
5%15569
6%17
571
Jul. 1, 2002—Sep. 30, 2002
5%15569
6%17
571
Oct. 1, 2002—Dec. 31, 2002
5%15569
6%17
571
Jan. 1, 2003—
Mar. 31, 2003
4%13
5675%15569
Apr. 1, 2003—Jun. 30, 20034%13
5675%15569
Jul. 1, 2003—Sep. 30, 20034%13
5675%15569
Oct. 1, 2003
—Dec. 31, 2003
3%11
565
4%13
567
Jan. 1, 2004—Mar. 31, 20043%
59
6134%61
615
Apr. 1, 2004—Jun. 30, 20044%61
6155%
63617
Jul. 1, 200
4—Sep. 30, 2004
3%
59
6134%61
615
Oct. 1, 2004—Dec. 31, 20044%61
6155%
63617
Jan. 1, 20
05—Mar. 31, 2005
4%13
5675%15569
Apr. 1, 2005—Jun. 30, 20055%15569
6%17
571
Jul. 1, 2005—Sep. 30, 20055%15569
6%17
571
Oct. 1, 2
005—Dec. 31, 2005
6%17
571
7%19
573
Jan. 1, 2
006—Mar. 31, 2006
6%17
571
7%19
573
Apr. 1, 2006—Jun. 30, 20066%17
571
7%19
573
Jul. 1, 2006—Sep. 30, 20067%19
573
8%21
575
Oct. 1,
2006—Dec. 31, 2006
7%19
573
8%21
575
Jan. 1, 2007—Mar. 31, 20077%19
573
8%21
575
Apr. 1, 2007—Jun. 30, 20077%19
573
8%21
575
Jul. 1
, 2007—Sep. 30, 2007
7%19
573
8%21
575
Oct. 1, 2007—Dec. 31, 20077%19
573
8%21
575
Jan. 1, 2008—Mar. 31, 20086%
65
6197%67621
Apr.
1, 2008—Jun. 30, 2008
5%
636176%
65
619
Jul. 1, 2008—Sep. 30, 20084%61
6155%
63617
TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT
1995
–1 C.B.
RATETABL
E
PG
Jan.
1, 1991—Mar. 31, 1991
13%31
585
Apr. 1, 1991—Jun. 30, 199112%29
583
Jul. 1, 1991—Sep. 30, 199112%29
583
Oct
. 1, 1991—Dec. 31, 1991
12%29
583
Jan. 1, 1992—Mar. 31, 199211%
75
629
Apr. 1, 1992—Jun. 30, 199210%73627
Jul
. 1, 1992—Sep. 30, 1992
10%73627
Oct. 1, 1992—Dec. 31, 19929%71
625
Jan. 1, 1993—Mar. 31, 19939%23
57
7
Ap
r. 1, 1993—Jun. 30, 1993
9%23
577
Jul. 1, 1993—Sep. 30, 19939%23
577
2008–26 I.R.B.1184June 30, 2008

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Oct. 1, 1993—Dec. 31, 19939%23
577
Jan. 1, 1994—Mar. 31, 19949%23
577
Apr. 1, 1994—Jun. 30, 19949%23
577
Jul. 1, 1994—Sep. 30, 199410%
25579
Oct. 1, 1994—Dec. 31, 199411%27
581
Jan. 1, 1995—Mar. 31, 1995
11%27
581
Apr. 1, 1995—Jun. 30, 1995
12%29
583
Jul. 1, 1995—Sep. 30, 1995
11%27
581
Oct. 1, 1995—Dec. 31, 1995
11%27
581
Jan. 1, 1996—Mar. 31, 199611%
75
629
Apr. 1, 1996—Jun. 30, 199610%73627
Jul. 1, 1996—Sep. 30, 199611%
75
629
Oct. 1, 1996—Dec. 31, 199611%
75
629
Jan. 1, 1997—Mar. 31, 199711%27
581
Apr. 1, 1997—Jun. 30, 199711%27
581
Jul. 1, 1997—Sep. 30, 199711%27
581
Oct. 1, 1997—Dec. 31, 199711%27
581
Jan. 1, 1998—Mar. 31, 199811%27
581
Apr. 1, 1998—Jun. 30, 199810%
25579
Jul. 1, 1998—Sep. 30, 199810%
25579
Oct. 1, 1998—Dec. 31, 199810%
25579
Jan. 1, 1999—Mar. 31, 19999%23
577
Apr. 1, 1999—Jun. 30, 199910%
25579
Jul. 1, 1999—Sep. 30, 199910%
25579
Oct. 1, 1999—Dec. 31, 199910%
25579
Jan. 1, 2000—Mar. 31, 200010%73627
Apr. 1, 2000—Jun. 30, 200011%
75
629
Jul. 1, 2000—Sep. 30, 200011%
75
629
Oct. 1, 2000—Dec. 31, 200011%
75
629
Jan. 1, 2001—Mar. 31, 200111%27
581
Apr. 1, 2001—Jun. 30, 200110%
25579
Jul. 1, 2001—Sep. 30, 20019%23
577
Oct. 1, 2001—Dec. 31, 20019%23
577
Jan. 1, 2002—Mar. 31, 20028%21
575
Apr. 1, 2002—Jun. 30, 20028%21
575
Jul. 1, 2002—Sep. 30, 20028%21
575
Oct. 1, 2002—Dec. 30, 20028%21
575
Jan. 1, 2003—Mar. 31, 20037%19
573
Apr. 1, 2003—Jun. 30, 20037%19
573
Jul. 1, 2003—Sep. 30, 20037%19
573
Oct. 1, 2003—Dec. 31, 20036%17
571
Jan. 1, 2004—Mar. 31, 20046%
65
619
Apr. 1, 2004—Jun. 30, 20047%67621
Jul. 1, 2004—Sep. 30, 20046%
65
619
Oct. 1, 2004—Dec. 31, 20047%67621
Jan. 1, 2005—Mar. 31, 2005
7%19
573
Apr. 1, 2005—Jun. 30, 2005
8%21
575
Jul. 1, 2005—Sep. 30, 2005
8%21
575
Oct. 1, 2005—Dec. 31, 2005
9%23
577
Jan. 1, 2006—Mar. 31, 20069%23
577
Apr. 1, 2006—Jun. 30, 20069%23
577
Jul. 1, 2006—Sep. 30, 200610%
25579
Oct. 1, 2006—Dec. 31, 200610%
25579
Jan. 1, 2007—Mar. 31, 200710%
25579
Apr. 1, 2007—Jun. 30, 200710%
25579
Jul. 1, 2007—Sep. 30, 200710%
25579
June 30, 200811852008–26 I.R.B.

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Oct. 1, 2007—Dec. 31, 200710%
25579
Jan. 1, 2008—Mar. 31, 20089%71
625
Apr. 1, 2008—Jun. 30, 20088%69623
Jul. 1, 2008—Sep. 30, 20087%67621
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1
, 1995 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1995—Mar. 31, 19956.5%
18
572
Apr. 1, 1995—Jun. 30, 19957.5%
20
574
Jul. 1, 1995—Sep. 30, 19956.5%
18
572
Oct. 1, 1995—Dec. 31, 19956.5%
18
572
Jan. 1, 1996—Mar. 31, 1996
6.5%
66620
Apr. 1, 1996—Jun. 30, 1996
5.5%
64618
Jul. 1, 1996—Sep. 30, 1996
6.5%
66620
Oct. 1, 1996—Dec. 31, 1996
6.5%
66620
Jan. 1, 1997—Mar. 31, 1997
6.5%
18
572
Apr. 1, 1997—Jun. 30, 1997
6.5%
18
572
Jul. 1, 1997—Sep. 30, 1997
6.5%
18
572
Oct. 1, 1997—Dec. 31, 1997
6.5%
18
572
Jan. 1, 1998—Mar. 31, 1998
6.5%
18
572
Apr. 1, 1998—Jun. 30, 1998
5.5%
16
570
Jul. 1, 1998—Sep. 30, 1998
5.5%
16
570
Oct. 1, 1998—Dec. 31, 1998
5.5%
16
570
Jan. 1, 1999—Mar. 31, 1999
4.5%
14
568
Apr. 1, 1999—Jun. 30, 1999
5.5%
16
570
Jul. 1, 1999—Sep. 30, 1999
5.5%
16
570
Oct. 1, 1999—Dec. 31, 1999
5.5%
16
570
Jan. 1, 2000—Mar. 31, 2000
5.5%
64618
Apr. 1, 2000—Jun. 30, 2000
6.5%
66620
Jul. 1, 2000—Sep. 30, 2000
6.5%
66620
Oct. 1, 2000—Dec. 31, 2000
6.5%
66620
Jan. 1, 2001—Mar. 31, 2001
6.5%
18
572
Apr. 1, 2001—Jun. 30, 2001
5.5%
16
570
Jul. 1, 2001—Sep. 30, 2001
4.5%
14
568
Oct. 1, 2001—Dec. 31, 2001
4.5%
14
568
Jan. 1, 2002—Mar. 31, 2002
3.5%
12
566
Apr. 1, 2002—Jun. 30, 2002
3.5%
12
566
Jul. 1, 2002—Sep. 30, 2002
3.5%
12
566
Oct. 1, 2002—Dec. 31, 2002
3.5%
12
566
Jan. 1, 2003—Mar. 31, 2003
2.5%
10
564
Apr. 1, 2003—Jun. 30, 2003
2.5%
10
564
Jul. 1, 2003—Sep. 30, 2003
2.5%
10
564
Oct. 1, 2003—Dec. 31, 2003
1.5%
8
562
Jan. 1, 2004—Mar. 31, 2004
1.5%56
610
Apr. 1, 2004—Jun. 30, 2004
2.5%58
612
Jul. 1, 2004—Sep. 30, 2004
1.5%56
610
Oct. 1, 2004—Dec. 31, 2004
2.5%58
612
Jan. 1, 2005—Mar. 31, 20052.5%
10
564
Apr. 1, 2005—Jun. 30, 20053.5%
12
566
2008–26 I.R.B.1186June 30, 2008

TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS E
XCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Jul. 1, 2005—Sep. 30, 20053.5%
12
566
Oct. 1, 2005—Dec. 31, 20054.5%
14
568
Jan. 1, 2006—Mar. 31, 2006
4.5%
14
568
Apr. 1, 2006—Jun. 30, 2006
4.5%
14
568
Jul. 1, 2006—Sep. 30, 2006
5.5%
16
570
Oct. 1, 2006—Dec. 31, 2006
5.5%
16
570
Jan. 1, 2007—Mar. 31, 2007
5.5%
16
570
Apr. 1, 2007—Jun. 30, 2007
5.5%
16
570
Jul. 1, 2007—Sep. 30, 2007
5.5%
16
570
Oct. 1, 2007—Dec. 31, 2007
5.5%
16
570
Jan. 1, 2008—Mar. 31, 2008
4.5%
62616
Apr. 1, 2008—Jun. 30, 2008
3.5%
60614
Jul. 1, 2008—Sep. 30, 2008
2.5%58
612
June 30, 200811872008–26 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2008–53
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code as in ef-
fect for plan years beginning before 2008.
It also provides guidance on the corpo-
rate bond monthly yield curve (and the
corresponding spot segment rates), the
24-month average segment rates, and
the funding transitional segment rates
under § 430(h)(2). In addition, this no-
tice provides guidance as to the interest
rate on 30-year Treasury securities un-
der § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008, the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I), and the min-
imum present value segment rates under
§ 417(e)(3)(D) as in effect for plan years
beginning after 2007.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004 and by
the Pension Protection Act of 2006 (PPA),
provide that the interest rates used to cal-
culate current liability and to determine
the required contribution under § 412(l)
for plan years beginning in 2004 through
2007 must be within a permissible range
based on the weighted average of the rates
of interest on amounts invested conser-
vatively in long term investment grade
corporate bonds during the 4-year period
ending on the last day before the beginning
of the plan year.
Notice 2004–34, 2004–1 C.B. 848, pro-
vides guidelines for determining the cor-
porate bond weighted average interest rate
and the resulting permissible range of in-
terest rates used to calculate current liabil-
ity. That notice establishes that the corpo-
rate bond weighted average is based on the
monthly composite corporate bond rate de-
rived from designated corporate bond in-
dices. The methodology for determining
the monthly composite corporate bond rate
as set forth in Notice 2004–34 continues to
apply in determining that rate. See Notice
2006–75, 2006–2 C.B. 366.
The composite corporate bond rate for
May 2008 is 6.47 percent. Pursuant to No-
tice 2004–34, the Service has determined
this rate as the average of the monthly
yields for the included corporate bond in-
dices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
Corporate
Bond Weighted
Average90%to100%
June20086.02
5.42
6.02
YIELD CUR
VE AND SEGMENT
RATES
Generall
y for plan years beginning
after 200
7 (except for delayed effective
dates for
certain plans under sections 104,
105, and
106 of PPA), § 430 of the Code
specifi
es the minimum funding require-
ments th
at apply to single employer plans
pursuan
t to § 412. Section 430(h)(2) spec-
ifies t
he interest rates that must be used
to dete
rmine a plan’s target normal cost
and fun
ding target. Under this provision,
presen
t value is generally determined us-
ing thr
ee 24-month average interest rates
(“segmen
t rates”), each of which applies
to cash fl
ows during specified periods.
However,
an election may be made under
§ 430(h)(
2)(D)(ii) to use the monthly yield
curve in
place of the segment rates. For
plan yea
rs beginning in 2008 and 2009, a
transit
ional rule under § 430(h)(2)(G) pro-
vides th
at the segment rates are blended
with th
e corporate bond weighted average
as spec
ified above. An election may be
made un
der § 430(h)(2)(G)(iv) to use the
segmen
t rates without applying the transi-
tional
rule.
Notice
2007–81, 2007–44 I.R.B. 899,
provid
es guidelines for determining the
monthly c
orporate bond yield curve, the
24-month
average corporate bond segment
rates, an
d the funding transitional segment
rates use
d to compute the target normal
cost and
the funding target. Pursuant to
Notice 2
007–81, the monthly corporate
bond yie
ld curve derived from May 2008
data is i
n Table I at the end of this notice.
The spo
t first, second, and third segment
rates f
or the month of May 2008 are, re-
specti
vely, 4.67, 6.36, and 6.77. The three
24-mon
th average corporate bond seg-
ment ra
tes applicable for June 2008 under
the ele
ction of § 430(h)(2)(G)(iv) are as
follo
ws:
First
Segment
Second
Segment
Third
Segment
5.13
6.01
6.53
The transitional segment rates under
§ 430(h)(2)(G) applicable for June 2008,
taking into account the corporate bond
weighted average of 6.02 stated above, are
as follows:
2008–26 I.R.B.1188June 30, 2008

For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
2008
5.72
6.026.19
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 417(e)(3)(A)(ii)(II) (prior to
amendment by PPA) defines the appli-
cable interest rate, which must be used
for purposes of determining the minimum
present value of a participant’s benefit
under § 417(e)(1) and (2), as the annual
rate of interest on 30-year Treasury se-
curities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
ble interest rate for a month is the annual
rate of interest on 30-year Treasury secu-
rities as specified by the Commissioner
for that month in revenue rulings, notices
or other guidance published in the Internal
Revenue Bulletin.
The rate of interest on 30-year Treasury
securities for May 2008 is 4.60 percent.
The Service has determined this rate as the
monthly average of the daily determina-
tion of yield on the 30-year Treasury bond
maturing in February 2038.
Generally for plan years beginning after
2007, § 431 specifies the minimum fund-
ing requirements that apply to multiem-
ployer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) pro-
vides that the interest rate used to calculate
current liability for this purpose must be
no more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year Trea-
sury securities during the four-year period
ending on the last day before the beginning
of the plan year. Notice 88–73, 1988–2
C.B. 383, provides guidelines for deter-
mining the weighted average interest rate.
The following rates were determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
30-Year
Treasury
Weighted
Average90%to105%
June2008
4.75
4.284.99
MINIMUM PRESENT VALUE
SEGMENT RATES
Generally for plan years beginning af-
ter December 31, 2007, the applicable in-
terest rates under § 417(e)(3)(D) are seg-
ment rates computed without regard to a
24-month average. For plan years begin-
ning in 2008 through 2011, the applica-
ble interest rate is the monthly spot seg-
ment rate blended with the applicable rate
under § 417(e)(3)(A)(ii)(II) as in effect
for plan years beginning in 2007. Notice
2007–81 provides guidelines for determin-
ing the minimum present value segment
rates. Pursuant to that notice, the min-
imum present value transitional segment
rates determined for May 2008, taking into
account the May 2008 30-year Treasury
rate of 4.60 stated above, are as follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20084.61
4.955.03
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
June 30, 200811892008–26 I.R.B.

Table I
Monthly Yield Curve for May 2008
Maturity YieldMaturity YieldMaturity YieldMaturity YieldMaturity Yield
0.5
3.24
20.5
6.74
40.5
6.78
60.5
6.80
80.5
6.81
1.0
3.79
21.06.7441.06.7861.06.8081.06.81
1.5
4.27
21.5
6.74
41.5
6.78
61.5
6.80
81.5
6.81
2.04.6222.06.7442.06.7862.06.8082.06.81
2.5
4.86
22.5
6.74
42.5
6.78
62.5
6.80
82.5
6.81
3.0
5.01
23.06.7443.06.7863.06.8083.06.81
3.55.1023.5
6.74
43.5
6.78
63.5
6.80
83.5
6.81
4.0
5.18
24.06.7444.06.7864.06.8084.06.81
4.55.2524.5
6.74
44.5
6.78
64.5
6.80
84.5
6.81
5.05.3325.06.7445.06.7865.06.8085.06.81
5.55.4125.5
6.74
45.5
6.78
65.5
6.80
85.5
6.81
6.0
5.50
26.06.7446.06.7866.06.8086.06.81
6.5
5.59
26.5
6.74
46.5
6.78
66.5
6.80
86.5
6.81
7.05.6927.06.7447.06.7867.06.8087.06.81
7.5
5.79
27.56.7547.5
6.78
67.5
6.80
87.5
6.81
8.05.8928.06.7548.0
6.79
68.06.8088.06.81
8.5
5.98
28.56.7548.5
6.79
68.5
6.80
88.5
6.81
9.0
6.07
29.0
6.75
49.06.7969.0
6.80
89.0
6.81
9.56.1629.5
6.75
49.5
6.79
69.56.8089.56.81
10.06.2430.0
6.7550.0
6.79
70.06.80
90.0
6.81
10.5
6.31
30.56.7550.5
6.79
70.5
6.8090.56.81
11.06.3731.06.7651.0
6.79
71.06.80
91.0
6.81
11.5
6.43
31.5
6.76
51.5
6.79
71.5
6.8091.56.81
12.06.4832.06.76
52.0
6.79
72.06.80
92.0
6.81
12.56.5232.5
6.76
52.5
6.79
72.5
6.8092.56.81
13.0
6.56
33.06.76
53.0
6.79
73.06.80
93.0
6.81
13.5
6.59
33.5
6.76
53.5
6.79
73.5
6.8093.56.81
14.06.6234.06.7654.0
6.79
74.06.80
94.0
6.81
14.56.6534.5
6.76
54.5
6.79
74.5
6.8094.56.81
15.0
6.67
35.0
6.77
55.0
6.79
75.0
6.8195.06.81
15.5
6.68
35.5
6.77
55.5
6.79
75.5
6.8195.56.81
16.0
6.69
36.06.77
56.0
6.79
76.06.81
96.0
6.81
16.5
6.70
36.5
6.77
56.5
6.79
76.5
6.8196.56.81
17.06.7137.06.7757.0
6.79
77.06.81
97.0
6.81
17.5
6.72
37.5
6.77
57.5
6.79
77.5
6.8197.56.81
18.06.7238.06.77
58.0
6.79
78.06.81
98.0
6.81
18.5
6.73
38.5
6.77
58.5
6.80
78.5
6.8198.56.81
19.0
6.73
39.0
6.7759.06.80
79.0
6.81
99.0
6.81
19.56.7339.56.7759.56.8079.56.8199.56.81
20.06.7340.06.7760.06.8080.06.81100.06.81
2008–26 I.R.B.1190June 30, 2008

Request for Comments
Regarding Election to Allocate
and Apportion Interest on
a Worldwide Basis Under
Section 864(f)
Notice 2008–54
The purpose of this notice is to request
public comments regarding the elections
under section 864(f)(6) of the Internal
Revenue Code (Code) to allocate and ap-
portion interest expense on a worldwide
affiliated group basis and under section
864(f)(5) to expand a financial institution
group of a worldwide affiliated group.
BACKGROUND
Section 864(f) was added to the Code
by the American Jobs Creation Act of
2004, P.L. 108–357, 118 Stat. 1418 (Oc-
tober 22, 2004). Section 864(f)(6) permits
taxpayers to make a one-time election to
allocate and apportion interest expense on
a worldwide affiliated group basis. In gen-
eral, if the election is made, the domestic
members of the worldwide affiliated group
determine their foreign source taxable
income by allocating and apportioning
their interest expense to such income in
an amount equal to the excess (if any)
of the worldwide affiliated group’s total
interest expense multiplied by a fraction
with a numerator consisting of the world-
wide affiliated group’s foreign assets and
a denominator consisting of the world-
wide affiliated group’s total assets, over
the amount of interest expense of all for-
eign corporations that are members of
the worldwide affiliated group that would
have been allocated and apportioned to
foreign source income of such foreign
members of the worldwide affiliated group
if the rules of section 864(f) were applied
to a group consisting solely of all such
foreign members. Section 864(f)(5) per-
mits a one-time election to expand the
financial institution group of a worldwide
affiliated group thathas made the election
under section 864(f) to allocate interest
expense on a worldwide affiliated group
basis. The elections under section 864(f)
may be made only for the first taxable
year beginning after December 31, 2008,
in which the taxpayer is eligible to make
the election, and are revocable only with
the consent of the Secretary.
REQUEST FOR COMMENTS
The IRS and Treasury Department re-
quest comments on guidance needed re-
garding the elections to allocate and appor-
tion interest expense on a worldwide affil-
iated group basis and to expand the finan-
cial institution group of a worldwide affil-
iated group. Specifically, comments are
requested on any substantive issues that
need to be addressed in advance of the date
of making such elections, which is gener-
ally expected to be the due date (includ-
ing extensions) of an eligible taxpayer’s
return for its first taxable year beginning
after December 31, 2008. Further, com-
ments are requested on whether it is nec-
essary and appropriate to prescribe regu-
lations providing for the direct allocation
and apportionment of interest expense for
purposes of section 864(f), preventing as-
sets or interest expense from being taken
into account more than once, and address-
ing changes in the status of members of
a worldwide affiliated group or financial
institution group (through acquisitions or
otherwise). In addition, comments are re-
quested regarding the treatment of loans
between members of the worldwide affil-
iated group or financial institution group
(or from a member of one group to a mem-
ber of the other group), as well as appro-
priate foreign currency translation conven-
tions relating to asset bases or interest ex-
pense. Comments are also requested on
the extent to which regulations should pro-
vide that bank holding companies, finan-
cial holding companies,and subsidiaries of
a financial institution (described in section
581 or section 591) or of a bank or finan-
cial holding company, should be treated
as includible corporations for purposes of
section 1504 for purposes of applying sec-
tion 864(f) separately to such corporations.
Finally, comments are requested regarding
the standards the IRS should apply to de-
termine whether to grant taxpayers con-
sent to revoke an election under section
864(f)(6) or section 864(f)(5).
Comments should be submitted on or
before September 8, 2008, and should
include a referenceto Notice 2008–54.
Send submissions to CC:PA:LPD:PR
(Notice 2008–54), Room 5203, Inter-
nal Revenue Service, P.O. Box 7604,
Ben Franklin Station, Washington, DC
20044. Submissions may be hand de-
liveredMonday through Fridaybe-
tween the hours of 8 a.m. and 4 p.m.
to CC:PA:LPD:PR (Notice 2008–54),
Courier’s Desk, Internal Revenue Ser-
vice, 1111 Constitution Avenue, NW,
Washington, DC 20044, or sent electron-
ically, via the following e-mail address:
Notice.comments@irscounsel.treas.gov.
Please include “Notice 2008–54” in
the subject line of any electronic
communication. All material submitted
will be available for public inspection and
copying.
DRAFTING INFORMATION
The principal author of this notice is
Jeffrey L. Parry of the Office of Associate
Chief Counsel (International). For further
information regarding this notice, contact
Jeffrey L. Parry at (202) 622–3850 (not a
toll-free call).
June 30, 200811912008–26 I.R.B.

Part IV. Items o
fGeneralInterest
Change in Repo
rting Section
404(k) Divide
nds
Announcement
2008–56
Purpose
This announce
ment provides for a
change in the r
eporting of dividends on
employer secu
rities that are distributed
from an employ
ee stock ownership plan
(“ESOP”) unde
r § 404(k) of the Internal
Revenue Code (
“§ 404(k) dividends”).
Background
Section 404(k
)(1) provides that, in the
case of a C corp
oration, there is allowed as
a deduction fo
r a taxable year the amount
of any applic
able dividend paid in cash by
such corpora
tion during the taxable year
with respect
to applicable employer se-
curities hel
dbyanESOPmaintainedby
the corpora
tion or by a related corpora-
tion within
the meaning of § 409(l)(4).
Section 404
(k)(2)(A) provides, in relevant
part, that t
he term “applicable dividend”
means any d
ividend which, in accordance
with plan p
rovisions, is paid directly to
plan parti
cipants or their beneficiaries; is
paid to the
plan and is distributed in cash
to plan par
ticipants or their beneficiaries
not later
than 90 days after the close of the
plan year
in which paid; or is, at the elec-
tion of pl
an participants or their beneficia-
ries, pai
d to such participants or their bene-
ficiarie
s or paid to the plan and distributed
in cash t
o such participants or their benefi-
ciaries
not later than 90 days after the close
of the pl
an year in which paid.
Plan dis
tributions that are § 404(k) divi-
dends ar
e not subject to the 10% additional
tax unde
r § 72 (see § 72(t)(2)(A)(vi)),
are not e
ligible rollover distributions
(see § 1
.402(c)–2 of the Income Tax
Regula
tions, Q&A–4(e)), are not sub-
ject to
withholding under § 3405 (see
§ 3405(
e)(1)(B)(iv)), and are not taken
into ac
count in determining if required
minim
um distributions have been made
(see §
1.401(a)(9)–5, Q&A–9(b)(5)). For
purpo
ses of § 72, such distributions are
treat
ed as plan distributions paid from a
contr
act that is separate from any other
contract unde
r the plan (see § 1.404(k)–1T,
Q&A–3). In add
ition, backup withholding
under § 3406 do
es not apply to distribu-
tions that are
§ 404(k) dividends because
they are repor
table under § 6047 and not
reportable u
nder § 6041 or 6042.
Announcement
85–168, 1985–48
I.R.B. 40, pr
ovides that “to allow tax-
payers using
short Form 1040A to report
this § 404(k)
dividend income,” a plan
must use Form
1099–DIV. At the time of
the announc
ement, payments reported on
Form 1099–R
and its predecessor forms
could not be
reported on Form 1040A.
The announc
ement further provided that if
§404(k)di
vidends were distributed in the
same year a
s a total qualified distribution,
the entire
amount should be reported on
Form 1099–
R.
New Reporting
Distributions from a plan that are made
in 2009 or later years and that are § 404(k)
dividends must be reported on a Form
1099–R that does not report any other
distributions, in accordance with the in-
structions to the form. Accordingly, if
there are other distributions from the plan
in such years that are not § 404(k) divi-
dends, they must be reported on a separate
Form 1099–R. It is anticipated that the
instructions will require a special code in
box 7 of the form to indicate the special
tax treatment and rollover restrictions ap-
plicable to § 404(k) dividends. Payments
of § 404(k) dividends made directly from
the corporation to the plan participants or
their beneficiaries are reported on Form
1099–DIV in accordancewith the instruc-
tions to that form.
Effect on Other Documents
Announcement 85–168 is revoked.
Correction to Revenue Ruling
2008–17, 2008–12 I.R.B. 626
Announcement 2008–57
This
document contains a correction to
Rev.
Rul. 2008–17, 2008–12 I.R.B. 626,
which was publ
ished in the Internal Rev-
enue Bulletin
on March 24, 2008.
BACKGROUND
The revenue ru
ling (Rev.Rul.
2008–17)that
is the subject of this correc-
tion provides
guidance to assist a foreign
corporation
engaged in the international
operation of
ships or aircraft, and its
shareholder
s, in determining whether the
foreign corp
oration is organized in a coun-
try that gran
ts an “equivalent exemption”
from tax for
purposes of sections 883(a)
and (c) of th
e Internal Revenue Code
(Code). It a
lso assists a nonresident alien
individual
engaged in the international op-
eration of
ships or aircraft in determining
whether a c
ountry grants an equivalent ex-
emption fr
om tax for purposes of section
872(b) of t
he Code.
Part A of Ta
ble I of this revenue rul-
ing provid
es a list of countries that grant
an equiva
lent exemption as evidenced by a
diplomat
ic note exchanged with the United
States. P
art B of Table I provides a list of
countrie
s that grant an equivalent exemp-
tion to U.
S. corporations by statute or de-
cree, or
by not imposing tax on income
from the
international operation of ships
or aircr
aft. Table II of this revenue ruling
provide
s a list of countries that have en-
tered in
to income tax conventions with the
United
States that include a shipping and
air tra
nsport article or a gains article.
NEED FO
R CORRECTION
As publ
ished, in Rev. Rul. 2008–17,
Table I
I (Countries Granting Exemptions
from Ta
xbyIncomeTaxConvention),
Column
9(CapGains),twofootnoteswere
inadv
ertently omitted. Footnote 26 applies
to Cap
Gains for India and footnote 18
appli
es to Cap Gains for New Zealand.
CORRE
CTION OF PUBLICATION
Accor
dingly, the publication of the rev-
enue r
uling (Rev. Rul. 2008–17)iscor-
recte
d as follows: On page 631 of Bul-
letin
No.2008–12, Table II is corrected by
addi
ng footnote 26 to the Cap Gains col-
umn f
or India and footnote 18 to the Cap
Gain
s column for New Zealand as follows:
2008–26 I.R.B.1192June 30, 2008

TABLE II
C
ountriesGrantingExemptionsfromTaxbyIncomeTaxConvention
15
BASISFOREXEMPTIONTYPESOFSHIPPINGANDAIRCRAFTINCOME
EXEMPTED
2
Countries
And
Territories
Residence
Based
No Flag
Residence
&Flag
Reciprocal
LOB
29
Article
Operating
Income
Full
Rental
(Time
or voyage
charter)
Bare-Boat
Rental
Incidental
Container
Rental
Cap
Gains
****
India
X- XXX
3
X
3
XX
26
****
New Zealand
35
X- XXXX
3
XX
18
****
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 2008–17, 2008–12 I.R.B.
626, is modified.
DRAFTING INFORMATION
The principal author of this announce-
ment is Patricia A. Bray of the Office of
Associate Chief Counsel (International).
For further information regarding this an-
nouncement, contact Patricia A. Bray at
(202) 622–3880 (not a toll-free call).
Partner’s Distributive Share;
Correction
Announcement 2008–58
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations; Correction.
SUMMARY: This document contains a
correction to final regulations (T.D. 9398,
2008–24 I.R.B. 1143) that were published
in theFederal Registeron Monday, May
19, 2008 (73 FR 28699) providing rules
for testing whether the economic effect
of an allocation is substantial within the
meaning of section 704(b) where partners
are look-through entities or members of a
consolidated group. The final regulations
clarify the applicationofsection704(b)
to partnerships the interests of which are
owned by look-through entities and mem-
bers of consolidated groups and, through
an example, reiterate the effect of other
provisions of the Internal Revenue Code
on partnership allocations.
DATES: This correction is effective June
12, 2008 and is applicable on May 19,
2008.
FOR FURTHER INFORMATION
CONTACT: Jonathan E. Cornwell and
Kevin I. Babitz at (202) 622–3050 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are the subject
of this document are under section 704 of
the Internal Revenue Code.
Need for Correction
As published, final regulations (T.D.
9398) contain an error that may prove to
be misleading and is in need of clarifica-
tion.
Correction of Publication
Accordingly, the publication of the final
regulations (T.D. 9398), which were the
subject of FR Doc. E8–11176, is corrected
as follows:
On page 28701, column 2, in the
preamble, under the paragraph head-
ing “B. The Baseline for Comparison in
§ 1.704–1(b)(2)(iii)”, line 2 from the bot-
tom of the second paragraph, the language
“and (2) and the conclusions reached by”
is corrected to read “and (2) and the con-
clusions reached by”.
LaNita Van Dyke,
Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on June 11, 2008,
8:45 a.m., and published in the issue of the Federal Register
for June 12, 2008, 73 F.R. 33301)
Partner’s Distributive Share;
Correction
Announcement 2008–59
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correcting amendments.
SUMMARY: This document contains cor-
rections to final regulations (T.D. 9398,
2008–24 I.R.B. 1143) that were published
in theFederal Registeron Monday, May
19, 2008 (73 FR 28699) providing rules
for testing whether the economic effect
June 30, 200811932008–26 I.R.B.

of an allocation is substantial within the
meaning of section 704(b) where partners
are look-through entities or members of a
consolidated group. The final regulations
clarify the applicationofsection704(b)
to partnerships the interests of which are
owned by look-through entities and mem-
bers of consolidated groups and, through
an example, reiterate the effect of other
provisions of the Internal Revenue Code
on partnership allocations.
DATES: This correction is effective June
12, 2008, and is applicable on May 19,
2008.
FOR FURTHER INFORMATION
CONTACT: Jonathan E. Cornwell and
Kevin I. Babitz at (202) 622–3050 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulationsthat are the subject
of this document are under section 704 of
the Internal Revenue Code.
Need for Correction
As published, final regulations (T.D.
9398) contain errors that may prove to be
misleading and are in need of clarification.
*****
Correction of Publication
Accordingly, 26 CFR part 1 is cor-
rected by making the following correcting
amendments:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.704–1 is amended as
follows:
1. In paragraph (b)(2)(iii)(d)(3), the
last sentence, the language “In the case of
a controlled foreign corporation that is a
look-through entity, the tax attributes to
be taken into account are those of any
person that is a United States shareholder
(as defined in paragraph (b)(2)(iii)(d)(5)
of this section) of the controlled foreign
corporation, or, if theUnited States share-
holder is a look-through entity, a United
States person that owns an interest in such
shareholder directly or indirectly through
one or more look-through entities.” is re-
movedandthelanguage“Inthecaseof
a controlled foreign corporation that is a
look-through entity, the tax attributes to be
taken into account are those of any person
that is a United States shareholder (as de-
fined in paragraph (b)(2)(iii)(d)(5)ofthis
section) of the controlled foreign corpora-
tion, or, if the United States shareholder is
a look-through entity, a United States per-
sonthatownsaninterestinsuchshare-
holder directly or indirectly through one or
more look-through entities.” is added in its
place.
2. In paragraph (b)(5)Example 29., the
fourth sentence, the language “C is a part-
nership with two partners, E, an individ-
ual, and F, a corporation that is member
of a consolidated group within the mean-
ing of § 1.1502–1(h).” is removed and the
language “C is a partnership with two part-
ners, E, an individual, and F, a corporation
that is a member of a consolidated group
within the meaning of § 1.1502–1(h).” is
added in its place.
LaNita Van Dyke,
Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on June 11, 2008,
8:45 a.m., and published in the issue of the Federal Register
for June 12, 2008, 73 F.R. 33301)
Foundations Status of Certain
Organizations
Announcement 2008–60
The following organizations have failed
to establish or have been unable to main-
tain their status as public charities or as op-
erating foundations. Accordingly, grantors
and contributors may not, after this date,
rely on previous rulings or designations
in the Cumulative List of Organizations
(Publication 78), or on the presumption
arising from the filing of notices under sec-
tion 508(b) of the Code. This listing does
notindicate that the organizations have lost
their status as organizations described in
section 501(c)(3), eligible to receive de-
ductible contributions.
Former Public Charities. The follow-
ing organizations (which have been treated
as organizations that are not private foun-
dations described in section 509(a) of the
Code) are now classified as private foun-
dations:
Acquiring Leaders of Tomorrow Today,
Inc., San Antonio, TX
Africa Institute for Biblical Christianty,
Inc., Tampa, FL
American Donor Services, Inc.,
Millington, TN
APWL Legacy Choir, Baltimore, MD
Artists in Residence, New Hope, PA
Birdye’s Performing Arts Outreach, Inc.,
Pine Bluff, AR
Cabaniss Caring, Lynchburg, VA
Center for Development of Scientific
Literacy, Inc., Saratoga Springs, NY
Community Outreachand Supportive
Services, Sumter, SC
Connie Thompson Foundation, Inc.,
Hot Springs, AR
Crossover Broadcast Network,
Incorporated, Santa Ana, CA
CW Film Foundation, Inc.,
San Francisco, CA
Ecumenical Covenant Corporation,
Locust Grove, VA
Education Humanity Foundation,
Columbia, CA
Family Development & Learning Center
of Mercer County, Trenton, NJ
Fireman Al Foundation, Redding, CA
First Choice Family Support Services,
Bellevue, WA
First World Foundation, Inc.,
Washington, DC
Foundation for Neurology Research, Inc.,
Orlando, FL
George Cragg Hopkins, Jr. Arts
Endowment, Inc., Lexington Park, MD
Giles Arthur Harmon Memorial
Scholarship Fund, Inc., Asheville, NC
Haitian American Center for Business
& Economic Development, Inc.,
Snellville, GA
Heirs of Christ, Austin, TX
High Expectations, Inc., Raleigh, NC
HIRE-Dona Rosita II Housing
Development Fund Corporation,
New York, NY
HotSpringsRuralNetwork,Inc.,
Fords, NJ
Human Shelter Research Institute,
Valencia, CA
2008–26 I.R.B.1194June 30, 2008

Humananatura, Incorporated,
Armonk, NY
Infrastructure Education Foundation,
San Francisco, CA
International Sports and Education
Centers, Lakewood, CA
Kansas Avenue Resource Center, Inc.,
Riverside, CA
Kellogg Fellows Leadership Alliance,
Inc., Denver, CO
Kings Dominion World Worship Ministry,
Memphis, TN
Konspire2B Foundation, Potsdam, NY
Little Light Ministries, Charlotte, NC
Ministry to Children, Crosby, TX
MTM Housing and Community
Development Corp., Sacramento, CA
Myhelp, Houston, TX
Myths and Facts, Inc., Forest Hills, NY
Neighborhood Community Outreach,
Incorporated, Jonesboro, GA
Networks Electronic Commerce and
Telecommunications NET Institute,
New York, NY
New Vision Housing Alliance,
Houston, TX
No Other Way Ministry, Fordyce, AR
NOAH Center, Inc., Great Barrington, MA
OEA Educational Foundation,
Columbus, OH
OSHA Assistance & Training Services,
Orange, CA
Post Release Employment Support
Services, Newark, CA
Proceed Community Development
Corporation, Inc., Elizabeth, NJ
Ragtops Museum of Michigan City, Inc.,
Palos Park, IL
Second Bethany Holiness Outreach
Ministries, Memphis, TN
Sheridan Medical Foundation,
Sheridan, WY
Slavic Community Center of Central
America, Sedalia, MO
Southeastern Indiana Workforce
Investment Board, Lawrenceburg, IN
Turn It Around Multi-Community Service
Center, Inc., Los Angeles, CA
United Services for Human Development,
Newark, DE
Zion’s International Mission,
Roanoke, VA
If an organization listed above submits
information that warrants the renewal of
its classification as a public charity or as
a private operating foundation, the Inter-
nalRevenueServicewillissuearulingor
determinationletterwiththerevisedclas-
sification as to foundation status. Grantors
and contributors may thereafter rely upon
such ruling or determination letter as pro-
videdinsection1.509(a)–7oftheIncome
Tax Regulations. It is not the practice of
the Service to announce such revised clas-
sification of foundation status in the Inter-
nal Revenue Bulletin.
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2008-61
TheOfficeofProfessionalResponsi-
bility (OPR) announcesrecent disciplinary
sanctions involving attorneys, certified
public accountants, enrolled agents, en-
rolled actuaries, enrolled retirement plan
agents, and appraisers. These individuals
are subject to the regulations governing
practice before the Internal Revenue Ser-
vice (IRS), which are set out in Title 31,
Code of Federal Regulations, Part 10, and
which are published in pamphlet form as
Treasury Department Circular No. 230.
The regulations prescribe the duties and
restrictions relating to such practice and
prescribe the disciplinary sanctions for
violating the regulations.
The disciplinary sanctions to be im-
posed for violation of the regulations are:
Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to represent taxpayers before
the IRS.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to represent taxpayers before
the IRS during the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand. Un-
like disbarment or suspension, censure
does not affect an individual’s eligibility
to represent taxpayers before the IRS, but
OPR may subject the individual’s future
representations to conditions designed to
promote high standards of conduct.
Monetary penalty—A monetary
penalty may be imposed on an individual
who engages in conduct subject to sanc-
tion or on an employer, firm, or entity
if the individual was acting on its behalf
and if it knew, or reasonably should have
known, of the individual’s conduct.
Disqualification of appraiser—An
appraiser who is disqualified is barred
from presenting evidence or testimony in
any administrative proceeding before the
Department of the Treasury or the IRS.
Under the regulations, attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, and enrolled retirement
plan agents may not assist, or accept assis-
tance from, individuals who are suspended
or disbarred with respect to matters consti-
tuting practice (i.e., representation) before
theIRS,andtheymaynotaidorabetsus-
pended or disbarred individuals to practice
before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision after hearing,
Suspended by decision after hearing,
Censured by decision after hearing,
Monetary penalty imposed after hear-
ing, and Disqualified after hearing—An
administrative law judge (ALJ) conducted
an evidentiary hearing upon OPR’s com-
plaint alleging violation of the regulations
and issued a decision imposing one of
these sanctions. After 30 days from the
issuance of the decision, in the absence of
an appeal, the ALJ’s decision became the
final agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured by
default decision, Monetary penalty im-
posed by default decision, and Disqual-
ified by default decision—An ALJ, after
finding that no answer to OPR’s complaint
had been filed, granted OPR’s motion for a
June 30, 200811952008–26 I.R.B.

default judgment and issued a decision im-
posing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on ap-
peal, and Disqualified by decision on
appeal—The decision of the ALJ was
appealed to the agency appeal authority,
acting as the delegate of the Secretary
of the Treasury, and the appeal authority
issued a decision imposing one of these
sanctions.
Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent—In lieu of a
disciplinary proceeding being instituted
or continued, an individual offered a con-
sent to one of these sanctions and OPR
accepted the offer. Typically, an offer
of consent will provide for: suspension
for an indefinite term; conditions that the
individual must observe during the sus-
pension; and the individual’s opportunity,
after a stated number of months, to file
with OPR a petition for reinstatement af-
firming compliance with the terms of the
consent and affirming current eligibility
to practice (i.e., an active professional
license or active enrollment status). An
enrolled agent or an enrolled retirement
plan agent may also offer to resign in order
to avoid a disciplinary proceeding.
Suspended by decision in expedited
proceeding, Suspended by default de-
cision in expedited proceeding, Sus-
pended by consent in expedited pro-
ceeding—OPR instituted an expedited
proceeding for suspension (based on cer-
tain limited grounds, including loss of a
professional licenseand criminal convic-
tions).
OPR has authority to disclose the
grounds for disciplinary sanctions in these
situations: (1) an ALJ or the Secretary’s
delegate on appeal has issued a decision
on or after September 26, 2007, which was
theeffectivedateofamendmentstothe
regulations that permit making such deci-
sions publicly available; (2) the individual
has settled a disciplinary case by signing
OPR’s “consent to sanction” form, which
requires consenting individuals to admit to
one or more violations of the regulations
and to consent to the disclosure of the in-
dividual’s own return information related
to the admitted violations (for example,
failure to file Federal income tax returns);
or (3) OPR has issued a decision in an
expedited proceeding for suspension.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by the names of states and sec-
ond by the last names of individuals. Un-
less otherwise indicated, section numbers
(e.g., § 10.51) refer to the regulations.
City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Alaska
AnchorageHahn, Frederick H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 5, 2008
Arizona
ScottsdaleRasure, Jr., Charles W. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in Colorado)
Indefinite from
April 21, 2008
California
CovinaCannon, Sheryl K.CPASuspended by default
decision in expedited
proceeding under § 10.82
(revocation of CPA
license)
Indefinite from
March 21, 2008
Sherman OaksDallinger, Timothy G. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 21, 2008
2008–26 I.R.B.1196June 30, 2008

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
California (Continued)
Santa RosaHernandez, BernabeAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 21, 2008
Mission ViejoHuband, Gary S.CPASuspended by consentIndefinite from
April 1, 2008
Palo AltoKent, Paul E.Enrolled AgentCensured by consentIndefinite from
March 24, 2008
ArcadiaPolitis, NicholasJ.AttorneySuspended by consentJanuary 1, 2008
through December
31, 2008
Los AngelesZita, RolandCPASuspended by default
decision in expedited
proceeding under § 10.82
(revocation of CPA
license)
Indefinite from
March 21, 2008
Colorado
LittletonMartinez, Doris LEnrolled AgentCensured by consentIndefinite from
January 16, 2008
Rasure,Jr.,CharlesW.,
See Arizona
DenverReeves, Zak E.Enrolled AgentSuspended by consent
under § 10.82 (conviction
of felony trespass)
Indefinite from
April 14, 2008
Delaware
GeorgetownTyler, III, James B.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (suspension
of attorney license)
Indefinite from
April 21, 2008
Florida
ParklandButler, Richard L.CPASuspended by consentIndefinite from
January 1, 2008
TampaDaly, Terence J.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 5, 2008
Vero BeachHatch, Jr., Ira C.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment)
Indefinite from
March 24, 2008
June 30, 200811972008–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Florida (Continued)
Boca RatonKeeley, III, Joseph F.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 5, 2008
Winter HavenLarue, Scott D.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
March 21, 2008
HollywoodOlin, Mitchell J.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment)
Indefinite from
April 18, 2008
Lynn HavenParker, Jr., Paul R.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under Florida
law, use of child in sexual
performance, promoting
sexual performance
by a child, computer
transmission of child
pornography, and
possession of computer
child pornography)
Indefinite from
May 5, 2008
Ft. LauderdaleSeitel, Loel H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 18
U.S.C. § 371, conspiracy
to make a false statement)
Indefinite from
March 28, 2008
St. PetersburgWatson, Martin K.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
March 21, 2008
Georgia
AtlantaButler, Michael B.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 5, 2008
LawrencevilleChandler, Martin M.CPASuspended by decision
on appeal for violation of
§ 10.51 (failure to timely
file Federal income tax
returns)
Indefinite from
April 30, 2008
2008–26 I.R.B.1198June 30, 2008

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Georgia (Continued)
SavannahJacobs, Jay P.AttorneyDisbarred by defau
lt
decision (appeal
untimely) for vio
lation
of § 10.51 (failur
etofile
and failure to fil
e timely
Federal tax retu
rns)
Indefinite from
May 10, 2007
EvansKey, Jr., William O.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 18
U.S.C. § 371, conspiracy
to commit wire fraud)
Indefinite from
April 21, 2008
Illinois
ChicagoHutchinson, Alan D.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in Indiana)
Indefinite from
April 21, 2008
Indiana
Hutchinson, Alan D.,
See Illinois
Kansas
Overland ParkHuser, Jeffrey H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
Missouri)
Indefinite from
April 29, 2008
LeavenworthThompson, John F.AttorneySuspended by consentIndefinite from
December 1, 2007
Kentucky
LexingtonDevillers, Sean P.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 29, 2008
OwingsvilleMaze, Donald A.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 42
U.S.C. § 1973i(c) & 18
U.S.C. § 2, vote buying,
aiding and abetting, 18
U.S.C.,§1623,false
statements to grand jury)
Indefinite from
May 20, 2008
June 30, 200811992008–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Kentucky (Continued)
LexingtonTreadway, Robert L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 29, 2008
LouisvilleWilliams, David W.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 1, 2008
Louisiana
New OrleansBernstein, David H.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment)
Indefinite from
April 29, 2008
Daly, Barrett B.,
See Mississippi
Maryland
Ellicott CityMcNair, Jr., WilkinsCPASuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 18
U.S.C. § 1343, wire
fraud, 18 U.S.C. § 1957,
money laundering, 26
U.S.C. 7206(1), making
and subscribing to a false
return, and 26 U.S.C.
7202, willfully failing to
collect and pay over tax)
Indefinite from
April 1, 2008
SalisburyWebster, Arthur D.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 29, 2008
Massachusetts
Ladas, Christos G.,
See New York
SpringfieldSiciliano, Anthony J.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 29, 2008
Michigan
PetoskeyFelton, John W.AttorneySuspended by consentIndefinite from
January 1, 2008
2008–26 I.R.B.1200June 30, 2008

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Michigan (Continued)
KentwoodHackett, Robert S.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 18
U.S.C. § 641, conversion
of public monies)
Indefinite from
April 25, 2008
W. BloomfieldTassoni, James D.CPASuspended by consentIndefinite from
March 1, 2008
AdrainWiesman, Walter F.Enrolled AgentSuspended by decision
in expedited proceeding
under § 10.82 (conviction
under Michigan
law, embezzlement
by agent/trustee
$1,000-$20,000)
Indefinite from
May 8, 2008
Minnesota
AitkinRhodes, Bradley C.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 1, 2008
Long LakeSwensen, Michael F.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 29, 2008
Mississippi
DiamondheadDaly, Barrett B.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in Louisiana)
Indefinite from
May 20, 2008
NatchezTatum, Louis M.CPASuspended by consentIndefinite from
January 21, 2008
Missouri
Earth CityDevereux, Michael J.CPASuspended by consentIndefinite from
January 1, 2008
Huser, Jeffrey H.,
See Kansas
Montana
Davison, Patrick P.,
See Oregon
Nebraska
SewardBlevens, Robert I.AttorneySuspended by consentIndefinite from
January 1, 2008
June 30, 200812012008–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
New Hampshire
BedfordBaroody, Edward J.CPASuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 21
U.S.C. § 841(a)(1),
possession with intent
to distribute controlled
substance — cocaine, and
18 U.S.C. § 1957, money
laundering)
Indefinite from
April 1, 2008
New Jersey
PiscatawayDevereaux, Lesly R.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment)
Indefinite from
April 29, 2008
Highland ParkDobkin, Michael A.CPASuspended by decision
on appeal for violation
of § 10.51 (failure to
file Federal income tax
returns)
Indefinite from
April 15, 2008
Feinerman, David A.,
See New York
LinwoodFranks, Jr., Harry E.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 20, 2008
Goldman, Jerome,
See New York
NorthfieldGoloff, Michael A.CPACensured by consentIndefinite from
March 13, 2008
SomersetLynch, Gerald M.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
April 29, 2008
West OrangeSchwartz, Arthur L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 18
U.S.C. § 1001, false
statement in Connecticut)
Indefinite from
April 1, 2008
Cape May Court
House
Waldron, James A.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (conviction
under 26 U.S.C. § 7203,
failure to file income tax
return)
Indefinite from
April 29, 2008
2008–26 I.R.B.1202June 30, 2008

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
New Mexico
Santa FeFisher, Jack R.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in New York)
Indefinite from
April 29, 2008
Rogers, Richard H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license in Ohio)
Indefinite from
May 20, 2008
EdgewoodLowrance, BrendaD.CPASuspended by default
decision in expedited
proceeding under § 10.82
(suspension of CPA
license)
Indefinite from
May 20, 2008
New York
New YorkBlau, Howard L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
May 20, 2008
SyossetFeinerman, David A.AttorneySuspended by decision
in expedited proceeding
under § 10.82 (attorney
disbarment in New
Jersey)
Indefinite from
April 1, 2008
Fisher, Jack R.,
See New Mexico
Gentile, Philip G.,
See Pennsylvania
College PointGoldman, JeromeAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
New Jersey)
Indefinite from
April 29, 2008
West SenecaLadas, Christos G.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(disbarment of attorney
license in Massachusetts)
Indefinite from
May 20, 2008
BriarwoodMunsiff, MayankAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 1, 2008
June 30, 200812032008–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
New York (Continued)
Stony BrookOliver, John P.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 1, 2008
CambridgeOswald, Joseph H.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 29, 2008
Tonelli, Gay Lynn,
See Virginia
Staten IslandVourderis, DennisE.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(conviction under
PL 155.40 01, grand
larceny second degree)
Indefinite from
May 20, 2008
Ohio
Rogers, Richard H.,
See New Mexico
Oklahoma
GoldsbyFranklin, Hershel L.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(suspension of attorney
license)
Indefinite from
April 1, 2008
Oregon
MedfordDavison, Patrick P.CPASuspended by default
decision in expedited
proceeding under § 10.82
(conviction under 15
U.S.C. 80b–6(1), and
80b–17, securities fraud;
revocation of CPA license
in Montana)
Indefinite from
May 20, 2008
SelmaSiemer, Marie E.CPASuspended by consent
for admitted violations
of § 10.51 (failure to file
Federal tax returns, Forms
1040 and 941)
Indefinite from
April 7, 2008
2008–26 I.R.B.1204June 30, 2008

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Pennsylvania
AmblerBreznicky, David M.CPASuspended by consent
for admitted violations
of § 10.51 (failure to
file Federal income tax
returns timely)
Indefinite from
May 1, 2008
EastonGentile, Philip G.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
New York)
Indefinite from
April 29, 2008
PhiladelphiaHall, Blonde GraysonAttorneySuspended by decision
in expedited proceeding
under § 10.82 (conviction
under 26 U.S.C. § 7203F,
failure to file tax returns)
Indefinite from
May 8, 2008
YorkMoul, David B.CPASuspended by default
decision in expedited
proceeding under § 10.82
(revocation of CPA
license)
Indefinite from
April 29, 2008
South Carolina
ColumbiaHerring, H. DewainAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
May 20, 2008
GreenvilleParnell, Christopher L. CPASuspended by default
decision in expedited
proceeding under § 10.82
(suspension of CPA
license)
Indefinite from
May 1, 2008
Texas
RichardsonGrissom, Stephen R.CPASuspended by consentIndefinite from
February 1, 2008
SpringPennoni, Lawrence D. AttorneySuspended by consentIndefinite from
January 1, 2008
PasadenaStanton, Roy B.AttorneySuspended by consentIndefinite from
February 1, 2008
Virginia
WiseEstep, GregoryCPASuspended by default
decision in expedited
proceeding under § 10.82
(suspension of CPA
license)
Indefinite from
April 29, 2008
June 30, 200812052008–26 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Virginia (Continued)
LeesburgTonelli, Gay LynnAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
New York)
Indefinite from
May 20, 2008
Wisconsin
Hales CornersGedlen, James M.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(revocation of attorney
license)
Indefinite from
April 29, 2008
2008–26 I.R.B.1206June 30, 2008

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
June 30, 2008i2008–26 I.R.B.

Numerical Finding List
1
Bulletins 2008–1 through 2008–26
Announcements:
2008-1, 2008-1 I.R.B.246
2008-2, 2008-3 I.R.B.307
2008-3, 2008-2 I.R.B.269
2008-4, 2008-2 I.R.B.269
2008-5, 2008-4 I.R.B.333
2008-6, 2008-5 I.R.B.378
2008-7, 2008-5 I.R.B.379
2008-8, 2008-6 I.R.B.403
2008-9, 2008-7 I.R.B.444
2008-10, 2008-7 I.R.B.445
2008-11, 2008-7 I.R.B.445
2008-12, 2008-7 I.R.B.446
2008-13, 2008-8 I.R.B.480
2008-14, 2008-8 I.R.B.481
2008-15, 2008-9 I.R.B.511
2008-16, 2008-9 I.R.B.511
2008-17, 2008-9 I.R.B.512
2008-18, 2008-12 I.R.B.667
2008-19, 2008-11 I.R.B.624
2008-20, 2008-11 I.R.B.625
2008-21, 2008-13 I.R.B.691
2008-22, 2008-13 I.R.B.692
2008-23, 2008-14 I.R.B.731
2008-24, 2008-13 I.R.B.692
2008-25, 2008-14 I.R.B.732
2008-26, 2008-13 I.R.B.693
2008-27, 2008-15 I.R.B.751
2008-28, 2008-14 I.R.B.733
2008-29, 2008-15 I.R.B.786
2008-30, 2008-16 I.R.B.825
2008-31, 2008-15 I.R.B.787
2008-32, 2008-16 I.R.B.826
2008-33, 2008-16 I.R.B.826
2008-34, 2008-17 I.R.B.849
2008-35, 2008-17 I.R.B.849
2008-36, 2008-16 I.R.B.827
2008-37, 2008-17 I.R.B.850
2008-38, 2008-17 I.R.B.851
2008-39, 2008-18 I.R.B.867
2008-40, 2008-19 I.R.B.941
2008-41, 2008-19 I.R.B.943
2008-42, 2008-19 I.R.B.943
2008-43, 2008-19 I.R.B.944
2008-44, 2008-20 I.R.B.982
2008-45, 2008-20 I.R.B.982
2008-46, 2008-20 I.R.B.983
2008-47, 2008-20 I.R.B.983
2008-48, 2008-20 I.R.B.983
2008-49, 2008-21 I.R.B.1024
2008-50, 2008-21 I.R.B.1024
2008-51, 2008-22 I.R.B.
1040
2008-52, 2008-22 I.R.B.1040
Announcements— Continued:
2008-53, 2008-23 I.R.B.1137
2008-54, 2008-24 I.R.B.1155
2008-55, 2008-25 I.R.B.1178
2008-56, 2008-26 I.R.B.1192
2008-57, 2008-26 I.R.B.1192
2008-58, 2008-26 I.R.B.1193
2008-59, 2008-26 I.R.B.1193
2008-60, 2008-26 I.R.B.1194
2008-61, 2008-26 I.R.B.1195
Court Decisions:
2085, 2008-17 I.R.B.828
2086, 2008-19 I.R.B.905
Notices:
2008-1, 2008-2 I.R.B.251
2008-2, 2008-2 I.R.B.252
2008-3, 2008-2 I.R.B.253
2008-4, 2008-2 I.R.B.253
2008-5, 2008-2 I.R.B.256
2008-6, 2008-3 I.R.B.275
2008-7, 2008-3 I.R.B.276
2008-8, 2008-3 I.R.B.276
2008-9, 2008-3 I.R.B.277
2008-10, 2008-3 I.R.B.277
2008-11, 2008-3 I.R.B.279
2008-12, 2008-3 I.R.B.280
2008-13, 2008-3 I.R.B.282
2008-14, 2008-4 I.R.B.310
2008-15, 2008-4 I.R.B.313
2008-16, 2008-4 I.R.B.315
2008-17, 2008-4 I.R.B.316
2008-18, 2008-5 I.R.B.363
2008-19, 2008-5 I.R.B.366
2008-20, 2008-6 I.R.B.406
2008-21, 2008-7 I.R.B.431
2008-22, 2008-8 I.R.B.465
2008-23, 2008-7 I.R.B.433
2008-24, 2008-8 I.R.B.466
2008-25, 2008-9 I.R.B.484
2008-26, 2008-9 I.R.B.487
2008-27, 2008-10 I.R.B.543
2008-28, 2008-10 I.R.B.546
2008-29, 2008-12 I.R.B.637
2008-30, 2008-12 I.R.B.638
2008-31, 2008-11 I.R.B.592
2008-32, 2008-11 I.R.B.593
2008-33, 2008-12 I.R.B.642
2008-34, 2008-12 I.R.B.645
2008-35, 2008-12 I.R.B.647
2008-36, 2008-12 I.R.B.650
2008-37, 2008-12 I.R.B.654
2008-38, 2008-13 I.R.B.683
2008-39, 2008-13 I.R.B.684
2008-40, 2008-14 I.R.B.725
Notices— Continued:
2008-41, 2008-15 I.R.B.742
2008-42, 2008-15 I.R.B.747
2008-43, 2008-15 I.R.B.748
2008-44, 2008-16 I.R.B.799
2008-45, 2008-17 I.R.B.835
2008-46, 2008-18 I.R.B.868
2008-47, 2008-18 I.R.B.869
2008-48, 2008-21 I.R.B.1008
2008-49, 2008-20 I.R.B.979
2008-50, 2008-21 I.R.B.1010
2008-51, 2008-25 I.R.B.1163
2008-52, 2008-25 I.R.B.1166
2008-53, 2008-26 I.R.B.1188
2008-54, 2008-26 I.R.B.1191
Proposed Regulations:
REG-208199-91, 2008-21 I.R.B.1017
REG-168745-03, 2008-18 I.R.B.871
REG-143716-04, 2008-25 I.R.B.1170
REG-147290-05, 2008-10 I.R.B.576
REG-100798-06, 2008-23 I.R.B.1135
REG-141998-06, 2008-19 I.R.B.911
REG-147775-06, 2008-19 I.R.B.916
REG-153589-06, 2008-14 I.R.B.730
REG-104713-07, 2008-6 I.R.B.409
REG-104946-07, 2008-11 I.R.B.596
REG-110136-07, 2008-17 I.R.B.838
REG-111583-07, 2008-4 I.R.B.319
REG-112196-07, 2008-21 I.R.B.1021
REG-114126-07, 2008-6 I.R.B.410
REG-114942-07, 2008-18 I.R.B.901
REG-119518-07, 2008-17 I.R.B.844
REG-124590-07, 2008-16 I.R.B.801
REG-127391-07, 2008-13 I.R.B.689
REG-136020-07, 2008-24 I.R.B.1154
REG-136701-07, 2008-11 I.R.B.616
REG-137573-07, 2008-15 I.R.B.750
REG-139236-07, 2008-9 I.R.B.491
REG-141399-07, 2008-8 I.R.B.470
REG-143468-07, 2008-17 I.R.B.848
REG-147832-07, 2008-8 I.R.B.472
REG-149475-07, 2008-9 I.R.B.510
REG-151135-07, 2008-16 I.R.B.815
REG-106897-08, 2008-25 I.R.B.1175
REG-108508-08, 2008-19 I.R.B.923
Revenue Procedures:
2008-1, 2008-1 I.R.B.1
2008-2, 2008-1 I.R.B.90
2008-3, 2008-1 I.R.B.110
2008-4, 2008-1 I.R.B.121
2008-5, 2008-1 I.R.B.164
2008-6, 2008-1 I.R.B.192
2008-7, 2008-1 I.R.B.229
2008-8, 2008-1 I.R.B.233
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2007–27 through 2007–52 is in Internal Revenue Bulletin
2007–52, dated December 26, 2007.
2008–26 I.R.B.iiJune 30, 2008

Revenue Procedures— Continued:
2008-9, 2008-2 I.R.B.258
2008-10, 2008-3 I.R.B.290
2008-11, 2008-3 I.R.B.301
2008-12, 2008-5 I.R.B.368
2008-13, 2008-6 I.R.B.407
2008-14, 2008-7 I.R.B.435
2008-15, 2008-9 I.R.B.489
2008-16, 2008-10 I.R.B.547
2008-17, 2008-10 I.R.B.549
2008-18, 2008-10 I.R.B.573
2008-19, 2008-11 I.R.B.594
2008-20, 2008-20 I.R.B.980
2008-21, 2008-12 I.R.B.657
2008-22, 2008-12 I.R.B.658
2008-23, 2008-12 I.R.B.664
2008-24, 2008-13 I.R.B.684
2008-25, 2008-13 I.R.B.686
2008-26, 2008-21 I.R.B.1014
2008-27, 2008-21 I.R.B.1014
2008-28, 2008-23 I.R.B.1054
2008-29, 2008-22 I.R.B.1039
2008-30, 2008-23 I.R.B.1056
2008-31, 2008-23 I.R.B.1133
Revenue Rulings:
2008-1, 2008-2 I.R.B.248
2008-2, 2008-2 I.R.B.247
2008-3, 2008-2 I.R.B.249
2008-4, 2008-3 I.R.B.272
2008-5, 2008-3 I.R.B.271
2008-6, 2008-3 I.R.B.271
2008-7, 2008-7 I.R.B.419
2008-8, 2008-5 I.R.B.340
2008-9, 2008-5 I.R.B.342
2008-10, 2008-13 I.R.B.676
2008-11, 2008-10 I.R.B.541
2008-12, 2008-10 I.R.B.520
2008-13, 2008-10 I.R.B.518
2008-14, 2008-11 I.R.B.578
2008-15, 2008-12 I.R.B.633
2008-16, 2008-11 I.R.B.585
2008-17, 2008-12 I.R.B.626
2008-18, 2008-13 I.R.B.674
2008-19, 2008-13 I.R.B.669
2008-20, 2008-14 I.R.B.716
2008-21, 2008-15 I.R.B.734
2008-22, 2008-16 I.R.B.796
2008-23, 2008-18 I.R.B.852
2008-24, 2008-18 I.R.B.861
2008-25, 2008-21 I.R.B.986
2008-26, 2008-21 I.R.B.985
2008-27, 2008-26 I.R.B.1180
2008-28, 2008-22 I.R.B.1029
2008-29, 2008-24 I.R.B.1149
2008-30, 2008-25 I.R.B.1156
2008-31, 2008-26 I.R.B.1180
Tax Conventions:
2008-8, 2008-6 I.R.B.403
2008-39, 2008-18 I.R.B.867
Treasury Decisions:
9368, 2008-6 I.R.B.382
9369, 2008-6 I.R.B.394
9370, 2008-7 I.R.B.428
9371, 2008-8 I.R.B.447
9372, 2008-8 I.R.B.462
9373, 2008-8 I.R.B.463
9374, 2008-10 I.R.B.521
9375, 2008-5 I.R.B.344
9376, 2008-11 I.R.B.587
9377, 2008-11 I.R.B.578
9378, 2008-14 I.R.B.720
9379, 2008-14 I.R.B.715
9380, 2008-14 I.R.B.718
9381, 2008-14 I.R.B.694
9382, 2008-9 I.R.B.482
9383, 2008-15 I.R.B.738
9384, 2008-16 I.R.B.792
9385, 2008-15 I.R.B.735
9386, 2008-16 I.R.B.788
9387, 2008-16 I.R.B.789
9388, 2008-17 I.R.B.832
9389, 2008-18 I.R.B.863
9390, 2008-18 I.R.B.855
9391, 2008-20 I.R.B.945
9392, 2008-19 I.R.B.903
9393, 2008-20 I.R.B.975
9394, 2008-21 I.R.B.988
9395, 2008-22 I.R.B.1031
9396, 2008-22 I.R.B.1026
9397, 2008-22 I.R.B.1025
9398, 2008-24 I.R.B.1143
9399, 2008-25 I.R.B.1157
9400, 2008-24 I.R.B.1139
June 30, 2008iii2008–26 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2008–1 through 2008–26
Announcements:
85-168
Revoked by
Ann. 2008-56, 2008-26 I.R.B.1192
2006-88
Clarified and superseded by
Notice 2008-35, 2008-12 I.R.B.647
Notice 2008-36, 2008-12 I.R.B.650
2008-6
Superseded by
Ann. 2008-19, 2008-11 I.R.B.624
Notices:
2001-16
Modified by
Notice 2008-20, 2008-6 I.R.B.406
2001-60
Modified and superseded by
Notice 2008-31, 2008-11 I.R.B.592
2002-44
Superseded by
Notice 2008-39, 2008-13 I.R.B.684
2003-51
Superseded by
Rev. Proc. 2008-24, 2008-13 I.R.B.684
2004-2
Modified by
Notice 2008-52, 2008-25 I.R.B.1166
2004-50
Modified by
Notice 2008-52, 2008-25 I.R.B.1166
2006-27
Clarified and superseded by
Notice 2008-35, 2008-12 I.R.B.647
2006-28
Clarified and superseded by
Notice 2008-36, 2008-12 I.R.B.650
2006-52
Clarified and amplified by
Notice 2008-40, 2008-14 I.R.B.725
2006-77
Clarified and amplified by
Notice 2008-25, 2008-9 I.R.B.484
2006-85
Obsoleted by
T.D. 9400, 2008-24 I.R.B.1139
Notices— Continued:
2006-107
Modified by
Notice 2008-7, 2008-3 I.R.B.276
2007-30
Modified and superseded by
Notice 2008-14, 2008-4 I.R.B.310
2007-45
Modified by
Notice 2008-49, 2008-20 I.R.B.979
2007-48
Obsoleted by
T.D. 9400, 2008-24 I.R.B.1139
2007-54
Clarified by
Notice 2008-11, 2008-3 I.R.B.279
2008-13
Supplemented by
Notice 2008-46, 2008-18 I.R.B.868
2008-27
Clarified, amended, supplemented, and
superseded by
Notice 2008-41, 2008-15 I.R.B.742
Proposed Regulations:
REG-209020-86
Corrected by
Ann. 2008-11, 2008-7 I.R.B.445
REG-107592-00
Partial withdrawal by
Ann. 2008-25, 2008-14 I.R.B.732
REG-149856-03
Hearing scheduled by
Ann. 2008-26, 2008-13 I.R.B.693
REG-143397-05
Corrected by
Ann. 2008-53, 2008-23 I.R.B.1137
REG-147290-05
Hearing scheduled by
Ann. 2008-43, 2008-19 I.R.B.944
REG-109367-06
Withdrawn by
Ann. 2008-41, 2008-19 I.R.B.943
REG-104946-07
Hearing scheduled by
Ann. 2008-47, 2008-20 I.R.B.983
REG-113891-07
Hearing scheduled by
Ann. 2008-4, 2008-2 I.R.B.269
Proposed Regulations— Continued:
REG-114126-07
Corrected by
Ann. 2008-36, 2008-16 I.R.B.827
REG-127770-07
Hearing scheduled by
Ann. 2008-24, 2008-13 I.R.B.692
REG-133300-07
Hearing scheduled by
Ann. 2008-34, 2008-17 I.R.B.849
REG-139236-07
Hearing scheduled by
Ann. 2008-42, 2008-19 I.R.B.943
REG-141399-07
Hearing cancelled by
Ann. 2008-31, 2008-15 I.R.B.787
Revenue Procedures:
97-36
Modified by
Rev. Proc. 2008-23, 2008-12 I.R.B.664
2001-23
Modified by
Rev. Proc. 2008-23, 2008-12 I.R.B.664
2002-9
Modified by
Rev. Proc. 2008-18, 2008-10 I.R.B.573
Modified and amplified by
Rev. Proc. 2008-25, 2008-13 I.R.B.686
2006-9
Modified by
Rev. Proc. 2008-31, 2008-23 I.R.B.1133
2007-1
Superseded by
Rev. Proc. 2008-1, 2008-1 I.R.B.1
2007-2
Superseded by
Rev. Proc. 2008-2, 2008-1 I.R.B.90
2007-3
Superseded by
Rev. Proc. 2008-3, 2008-1 I.R.B.110
2007-4
Superseded by
Rev. Proc. 2008-4, 2008-1 I.R.B.121
2007-5
Superseded by
Rev. Proc. 2008-5, 2008-1 I.R.B.164
2007-6
Superseded by
Rev. Proc. 2008-6, 2008-1 I.R.B.192
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2007–27 through 2007–52 is in Internal Revenue Bulletin 2007–52, dated December 26,
2007.
2008–26 I.R.B.ivJune 30, 2008

Revenue Procedures— Continued:
2007-7
Superseded by
Rev. Proc. 2008-7, 2008-1 I.R.B.229
2007-8
Superseded by
Rev. Proc. 2008-8, 2008-1 I.R.B.233
2007-26
Obsoleted in part by
Rev. Proc. 2008-17, 2008-10 I.R.B.549
2007-31
Obsoleted in part by
Rev. Proc. 2008-19, 2008-11 I.R.B.594
2007-39
Superseded by
Rev. Proc. 2008-3, 2008-1 I.R.B.110
2007-51
Superseded by
Rev. Proc. 2008-30, 2008-23 I.R.B.1056
2007-52
Superseded by
Rev. Proc. 2008-9, 2008-2 I.R.B.258
2008-13
Corrected by
Ann. 2008-15, 2008-9 I.R.B.511
Revenue Rulings:
56-127
Obsoleted by
T.D. 9391, 2008-20 I.R.B.945
58-612
Clarified and amplified by
Rev. Rul. 2008-15, 2008-12 I.R.B.633
64-250
Amplified by
Rev. Rul. 2008-18, 2008-13 I.R.B.674
66-294
Obsoleted by
Rev. Rul. 2008-29, 2008-24 I.R.B.1149
67-131
Obsoleted by
Rev. Rul. 2008-29, 2008-24 I.R.B.1149
89-42
Modified and superseded by
Rev. Rul. 2008-17, 2008-12 I.R.B.626
92-19
Supplemented in part by
Rev. Rul. 2008-19, 2008-13 I.R.B.669
97-31
Modified and superseded by
Rev. Rul. 2008-17, 2008-12 I.R.B.626
Revenue Rulings— Continued:
2001-48
Modified and superseded by
Rev. Rul. 2008-17, 2008-12 I.R.B.626
2005-28
Clarified and superseded by
Rev. Rul. 2008-26, 2008-21 I.R.B.985
2007-4
Supplemented and superseded by
Rev. Rul. 2008-3, 2008-2 I.R.B.249
2008-17
Modified by
Ann. 2008-57, 2008-26 I.R.B.1192
2008-22
Modified by
Ann. 2008-46, 2008-20 I.R.B.983
Treasury Decisions:
8697
Corrected by
Ann. 2008-38, 2008-17 I.R.B.851
9273
Corrected by
Ann. 2008-33, 2008-16 I.R.B.826
9362
Corrected by
Ann. 2008-9, 2008-7 I.R.B.444
Ann. 2008-12, 2008-7 I.R.B.446
9363
Corrected by
Ann. 2008-10, 2008-7 I.R.B.445
9368
Corrected by
Ann. 2008-29, 2008-15 I.R.B.786
Ann. 2008-30, 2008-16 I.R.B.825
9375
Corrected by
Ann. 2008-16, 2008-9 I.R.B.511
9386
Corrected by
Ann. 2008-35, 2008-17 I.R.B.849
9398
Corrected by
Ann. 2008-58, 2008-26 I.R.B.1193
Ann. 2008-59, 2008-26 I.R.B.1193
June 30, 2008v2008–26 I.R.B.

INDEX
Internal Revenue Bulletins 2008–1 through
2008–26
The abbreviation and number in parenthesis following the index entry
refer to the specific item; numbers in roman and italic type following
the parenthesis refers to the Internal Revenue Bulletin in which the item
may be found and the page number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Alternative funding schedule, amortization (Ann 2) 3,307
Automatic contribution agreements,hearing for
REG–133300–07 (Ann 34) 17,849
Benefit restrictions for underfunded pension plans, hearing for
REG–113891–07 (Ann 4) 2,269
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Defined benefit plans:
Accrued benefits (RR 7) 7,419
Measurement of assets and liabilities for pension funding pur-
poses (REG–139236–07) 9,491; hearing scheduled (Ann
42) 19,943
Defined contribution plans:
Diversification of employer securities, extension of certain
transitional rules (Notice 7) 3,276
Diversification requirements for certain defined contribu-
tion plans and to publicly traded employer securities
(REG–136701–07) 11,616
Determination letters, issuing procedures (RP 6) 1,192
Economic stimulus payments, tax-favored accounts (Ann 44) 20,
982
Employee stock ownership plans, dividends reporting (Ann 56)
26,1192
Full funding limitations, weighted average interest rates, seg-
ment rates for:
January 2008 (Notice 17) 4,316
February 2008 (Notice 24) 8,466
March 2008 (Notice 37) 12,654
April 2008 (Notice 45) 17,835
May 2008 (Notice 50) 21,1010
June 2008 (Notice 53) 26,1188
Interim standards under section 6694(a) (Notice 46) 18,868
EMPLOYEE PLANS—Cont.
Letter rulings:
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,110
Associate Chief Counsel (International) (RP 7) 1,229
And general information letters, procedures (RP 4) 1,121
User fees, request for letter rulings (RP 8) 1,233
Master and prototype (M&P) andvolume submitter (VS) plans,
EGTRRA opinion and advisory letters (Ann 23) 14,731
Mortality tables, disability (Notice 29) 12,637
Multiemployer plan funding guidance (REG–151135–07) 16,
815
Pension plan amendments, notice requirements, significantly re-
ducing rate of future benefit accrual (REG–110136–07) 17,
838
Performance-based compensation (RR 13) 10,518
Proposed Regulations:
26 CFR 1.401, 1.402, 1.411, 1.414, and 54.4979; automatic
contribution arrangements, hearing for REG–133300–07
(Ann 34) 17,849
26 CFR 1.401(a)(35)–1, added; diversification requirements
for certain defined contribution plans and to publicly traded
employer securities (REG–136701–07) 11,616
26 CFR 1.411(a)(13)–1, added; 1.411(b)(5)–1, added; hy-
brid retirement plans (REG–104946–07) 11,596; hearing
scheduled (Ann 47) 20,983
26 CFR 1.411(d)–3, amended; 54.4980F–1, amended; no-
tice requirements for certain pension plan amendments
significantly reducing the rate of future benefit accrual
(REG–110136–07) 17,838
26 CFR 1.430; 1.436; benefit restrictions for underfunded
pension plans, hearing for REG–113891–07 (Ann 4) 2,269
26 CFR 1.430(a)–1, (j)–1, added; 54.4971(c)–1, added;
determination of minimum required pension contributions
(REG–108508–08) 19,923
26 CFR 1.430(d)–1, added; 1.430(g)–1, added;
1.430(h)(2)–1, added; 1.430(i)–1, added; measurement
of assets and liabilities for pension funding purposes
(REG–139236–07) 9,491; hearing scheduled (Ann 42)
19,943
26 CFR 1.432(a)–1, (b)–1, added; multiemployer plan fund-
ing guidance (REG–151135–07) 16,815
Qualified retirement plans:
Determination of minimum required pension contributions
(REG–108508–08) 19,923
Distributions (Notice 30) 12,638
Hybrid retirement plans (REG–104946–07) 11,596; hearing
scheduled (Ann 47) 20,983
Stocks, statutory stock options, information reporting require-
ments (Notice 8) 3,276
Supplemental healthinsurance, HIPAA (Notice 23) 7,433
Technical advice to IRS employees (RP 5) 1,164
Transitional guidance for new funding rules and funding-related
benefits limitations under PPA ’06, uniform effective date (No-
tice 21) 7,431
2008–26 I.R.B.viJune 30, 2008

EMPLOYMENT TAX
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Corporations, S corporation, status in reorganization where
S corporation becomes a QSub of newly formed holding
company, assignment of EINs (RR 18) 13,674
Frivolous tax return positions (Notice 14) 4,310
Interest-free adjustments and claims for refund of employment
taxes (REG–111583–07) 4,319
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions
(RP 1) 1,1
Proposed Regulations:
26 CFR 31.6011(a)–1, –4, –5, amended; 31.6205–1,
amended; 31.6302–0, –1, amended; 31.6402(a)–1, –2,
amended; 31.6413(a)–2, amended; 31.6414–1, amended;
interest-free adjustments and claims for refund of employ-
ment taxes (REG–111583–07) 4,319
Supplemental wages, income tax withholding (RR 29) 24,1149
Technical Advice Memoranda (TAMs) (RP 2) 1,90
ESTATE TAX
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Election to value on alternate valuation date (REG–112196–07)
21,1021
Frivolous tax return positions (Notice 14) 4,310
Grantor’s retained power to substitute assets of equivalent value
(RR 22) 16,796; correction (Ann 46) 20,983
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions
(RP 1) 1,1
Proposed Regulations:
26 CFR 20.2032–1, amended; gross estate, election to value
on alternate valuation date (REG–112196–07) 21,1021
26 CFR 26.2642–7, added; 301.9100–3, amended; regula-
tions under section 2642(g) (REG–147775–06) 19,916
Qualified tuition programs, applicable transfer tax provi-
sions, publication of advance notice of proposed rulemaking
(REG–127127–05) (Ann 17) 9,512
Relief under section 2642(g)(1) (REG–147775–06) 19,916
Technical Advice Memoranda (TAMs) (RP 2) 1,90
EXCISE TAX
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Corporations, S corporation, status in reorganization where
S corporation becomes a QSub of newly formed holding
company, assignment of EINs (RR 18) 13,674
Frivolous tax return positions (Notice 14) 4,310
Insurance excise tax treatment of premiums paid by one foreign
insurer to another (RR 15) 12,633
EXCISE TAX—Cont.
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions
(RP 1) 1,1
Proposed Regulations:
26 CFR 1.430(a)–1, (j)–1, added; 54.4971(c)–1, added;
determination of minimum required pension contributions
(REG–108508–08) 19,923
Qualified retirement plans, determination of minimum required
pension contributions (REG–108508–08) 19,923
Regulations:
26 CFR 1.501(c)(3)–1, amended; 53.4958–2, amended; stan-
dards for recognition of tax-exempt status if private benefit
exists or if an applicable tax-exempt organization has en-
gaged in excess benefit transaction(s) (TD 9390) 18,855
Supplemental healthinsurance, HIPAA (Notice 23) 7,433
Tax-exempt status, standards for recognition if private benefit ex-
ists or if applicable tax-exemptorganization engaged in excess
benefit transaction(s) (TD 9390) 18,855
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Voluntary compliance program for foreign insurers and reinsur-
ers subject to insurance excise tax imposed by section 4371
(Ann 18) 12,667
EXEMPT ORGANIZATIONS
Annual notice to donors regarding pending and settled declara-
tory judgment suits (Ann 1) 1,246
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Declaratory judgment suits (Ann 48) 20,983
Forms:
990-T:
Procedures to request a 501(c)(3) organization’s Form
990-T (Ann 21) 13,691
Public inspection of Form 990-T (Notice 49) 20,979
Frivolous tax return positions (Notice 14) 4,310
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings:
And determination letters:
Areas which will not be issued from Associates Chief
Counsel and Division Counsel (TE/GE) (RP 3) 1,110
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 2,258
And general information letters, procedures (RP 4) 1,121
User fees, request for letter rulings (RP 8) 1,233
List of organizations classifiedas private foundations (Ann 13)
8,480; (Ann 28) 14,733; (Ann 37) 17,850; (Ann 40) 19,941;
(Ann 60) 26,1194
Proposed Regulations:
26 CFR 1.664–1, amended; guidance under section 664
regarding the effect of unrelated business taxable income
(UBTI) on charitable remainder trusts (REG–127391–07)
13,689
June 30, 2008vii2008–26 I.R.B.

EXEMPT ORGANIZATIONS—Cont.
Regulations:
26 CFR 1.501(c)(3)–1, amended; 53.4958–2, amended; stan-
dards for recognition of tax-exempt status if private benefit
exists or if an applicable tax-exempt organization has en-
gaged in excess benefit transaction(s) (TD 9390) 18,855
Revocations (Ann 3) 2,269;(Ann14)8,481; (Ann 20) 11,625;
(Ann 22) 13,692; (Ann 32) 16,826; (Ann 45) 20,982;(Ann
49) 21,1024; (Ann 51) 22,1040; (Ann 54) 24,1155;(Ann55)
25,1178
Tax-exempt status, standards for recognition if private benefit ex-
ists or if applicable tax-exemptorganization engaged in excess
benefit transaction(s) (TD 9390) 18,855
Technical advice to IRS employees (RP 5) 1,164
Transitional relief and filing procedures, charitable trust
(Notice 6) 3,275
Trusts, charitable remainder trusts, calculation of excise tax on
unrelated business taxable income (UBTI) (REG–127391–07)
13,689
GIFT TAX
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Frivolous tax return positions (Notice 14) 4,310
Gift tax valuation declaratory judgment (REG–143716–04) 25,
1170
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions
(RP 1) 1,1
Proposed Regulations:
26 CFR 301.7477–1, revised; declaratory judgments - gift tax
determinations (REG–143716–04) 25,1170
Qualified tuition programs, applicable transfer tax provi-
sions, publication of advance notice of proposed rulemaking
(REG–127127–05) (Ann 17) 9,512
Technical Advice Memoranda (TAMs) (RP 2) 1,90
INCOME TAX
Accounting methods:
Change in method, contributions to capital (RR 30) 25,1156
Procedure for election under section 1361(g) for banks (RP
18) 10,573
Safe harbor method of accounting for payroll taxes (RP 25)
13,686
Accounts and notes receivable, section 1221(a)(4) capital asset
exclusion, REG–109367–06 withdrawn (Ann 41) 19,943
Advance Pricing Agreement (APA) Program:
Annual report to the public, 2007 (Ann 27) 15,751
Types of issues resolved (RP 31) 23,1133
Allocation of section 179D deduction to designers of government
owned buildings, certification requirements for interim light-
ing rule, application of interim lighting rule to unconditioned
garage space (Notice 40) 14,725
INCOME TAX—Cont.
Annual notice to donors regarding pending and settled declara-
tory judgment suits (Ann 1) 1,246
Annuity contracts, partial exchange (RP 24) 13,684
Assumption of liabilities (TD 9397) 22,1025
Calculating and apportioning the section 11(b)(1) additional tax
under section 1561 for controlled groups (TD 9369) 6,394;
(REG–104713–07) 6,409
Capital assets, musical compositions (TD 9379) 14,715;
(REG–153589–06) 14,730
Capitalization of amounts paid to acquire, produce, or improve
tangible property (REG–168745–03) 18,871
Cell captive guidance:
Insurance, protected cell company (Notice 19) 5,366
Insurance, risk shifting and risk distribution (RR 8) 5,340
Certain outbound reorganizations and section 351 exchanges
(Notice 10) 3,277
Charitable contributions:
Appreciated property, Scorporation (RR 16) 11,585
Recordkeeping requirements (Notice 16) 4,315
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Clarification of transitional relief under Notice 2007–54
(Notice 11) 3,279
Coal project program, special allocation round for qualifying ad-
vanced coal projects (Notice 26) 9,487
Consolidated returns:
Intercompany insurance transactions, withdrawal of a portion
of REG–107592–00 (Ann 25) 14,732
Loss disallowance (Notice 9) 3,277
Consumer Price Index (CPI) adjustments, certain loans under
section 1274A for 2008 (RR 3) 2,249
Contingent fees under Circular 230 (Notice 43) 15,748
Corporations:
Amendment to transfers of assets or stock following corporate
reorganization (TD 9396) 22,1026
Certain triangular reorganizations involving foreign corpora-
tions (TD 9400) 24,1139; (REG–136020–07) 24,1154
Determination of surrogate foreign corporation status when
there is an expanded affiliated group (TD 9399) 25,1157
Entity classification, foreign entities, per se corporations (TD
9388) 17,832; (REG–143468–07) 17,848
Health insurance costs of 2-percent shareholder-employees,
S corporation (Notice 1) 2,251
S corporations:
Charitable contributions, appreciated property (RR 16) 11,
585
Status in reorganization where S corporation becomes a
QSub of newly formed holding company, assignment of
EINs (RR 18) 13,674
Succession to items of a liquidating corporation by members
of a consolidated group (TD 9376) 11,587
Credits:
Alternative motor vehicle credit, qualified fuel cell motor ve-
hicles (Notice 33) 12,642
2008–26 I.R.B.viiiJune 30, 2008

INCOME TAX—Cont.
Energy efficient home credit,calculation of heating and cool-
ingenergyconsumption:
Dwelling unit (Notice 35) 12,647
Manufactured home (Notice 36) 12,650
Foreign tax credit:
Redeterminations,correctiontoT.D.9362(Ann9)7,444;
additional correction to TD 9362 (Ann 12) 7,446;cor-
rection to REG–209020–86 (Ann 11) 7,445
Reduction of foreign tax credit limitation categories un-
der section 904(d) (TD 9368) 6,382; corrections (Ann
29) 15,786; additional corrections (Ann 30) 16,825;
(REG–114126–07) 6,410; hearing cancellation (Ann
36) 16,827
Increasing research activities, centralized filing of certain
claims (Notice 39) 13,684
Low-income housing credit:
2008 population figures used for calculation (Notice 22) 8,
465
Indian Housing Block Grant (IHBG) Program (RR 6) 3,
271
Nonconventional source fuel credit, inflation adjustment
factor and phase-out amount for CY 2007 (Notice 44)
16,799
Satisfactory bond, “bond factor” amounts for the period:
January through March 2008 (RR 2) 2,247
January through June 2008 (RR 21) 15,734
Renewable electricity, refined coal, and Indian coal produc-
tion credit, 2008 inflation adjustment (Notice 48) 21,1008
Declaratory judgment suits (Ann 48) 20,983
Deductions:
Certain itemized, federal taxable income (CD 2085) 17,828
Dependency exemption, qualifying relative (Notice 5) 2,256
Depreciation, 2008 limitations on depreciation deductions for
passenger automobiles (RP 22) 12,658
Designated and related summonses, effect on period of lim-
itations on assessment whencase brought with respect to
(REG–208199–91) 21,1017
Disciplinary actions involving attorneys, certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 5) 4,333;
(Ann 52) 22,1040; (Ann 61) 26,1195; announcement of new
format (Ann 50) 21,1024
Disclosure of return information:
In connection with written contracts among the IRS, whistle-
blowers, and legal representatives of whistleblowers (TD
9389) 18,863; (REG–114942–07) 18,901
To the Bureau of the Census (TD 9372) 8,462; (TD 9373) 8,
463; (REG–147832–07) 8,472
Disposition of investment in United States real property:
Interest in notional principal contract (RR 31) 26,1180
Readily marketable security (RP 27) 21,1014
Domestic production activities, Tax Increase Prevention and
Reconciliation Act of 2005 (TIPRA) amendments to section
199 (TD 9381) 14,694
Economic stimulus payments:
Filing instructions (Notice 28) 10,546
Tax-favored accounts (Ann 44) 20,982
INCOME TAX—Cont.
Electronic tax administration, guidance necessary to facilitate –
updating section 7216 regulations (TD 9375) 5,344; correction
(Ann 16) 9,511
Employee leasing arrangements,reimbursement of per diem (RR
23) 18,852
Employer-provided vehicles, cents-per-mile valuation rule, max-
imum vehicle values (RP 13) 6,407;correction(Ann15)9,
511
Exclusion from gross income, update of Rev. Rul. 2001–48 (RR
17) 12,626; correction (Ann 57) 26,1192
Exemptions, dependents, hearing on REG–149856–03 (Ann 26)
13,693
Federal tax lien:
Procedures for obtaining release or discharge (TD 9378) 14,
720
Validity and priority of federal tax lien against certain persons
(REG–141998–06) 19,911
Foreign base company sales income rules, application
(REG–124590–07) 16,801
Foreign currency, debt characterization, exchange traded notes,
prepaid forwards (RR 1) 2,248
Forms:
1098, 1099, 5498 and W-2G, requirements for filing electron-
ically, 2008 revision (RP 30) 23,1056
Use of Form 13976, Itemized Statement Component of Ad-
visee List, section 6112 list (RP 20) 20,980
Frivolous tax return positions (Notice 14) 4,310
Gift tax valuation declaratory judgment (REG–143716–04) 25,
1170
GO Zone bonus depreciation recapture, like-kind exchanges and
involuntary conversions (Notice 25) 9,484
Guidance Priority List, recommendations for 2008–2009 (Notice
47) 18,869
Guidance to:
Government entities regarding a requirement to withhold on
certain payments made by them (Notice 38) 13,683
Tax return preparers, consents to disclose and consents to use
tax return information in the Form 1040 series (RP 12) 5,
368
Health Savings Accounts (HSAs):
Cost-of-living adjustments for inflation for 2009 (RP 29) 22,
1039
Employer comparable contributions (TD 9393) 20,975
Maximum annual HSA contribution (Notice 52) 25,1166
Qualified HSA funding distribution (Notice 51) 25,1163
Income tax returns, 2007, guidance for the Service not challeng-
ing the accuracy of 2007 returns filed in compliance with No-
tice 2008–28 (RP 21) 12,657
Information reporting, donees of qualified intellectual property
contributions (TD 9392) 19,903
Insurance companies:
Application of section 338 (TD 9377) 11,578
Diversification requirements under section 817 (TD 9385) 15,
735
Loss payment patterns and discount factors for the 2007 acci-
dent year (RP 10) 3,290
June 30, 2008ix2008–26 I.R.B.

INCOME TAX—Cont.
Prevailing state assumed interest rate tables, 2008 (RR 19) 13,
669
Proposed AG VACARVM and Proposed Life PBR (Notice
18) 5,363
Salvage discount factors for the 2007 accident year (RP 11) 3,
301
Interest:
Deductibility, application of section 163(d) to noncorporate
limited partner that does not materially participate in a
trader partnership’s trading activity (RR 12) 10,520
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2008 (RR 4) 3,272
February 2008 (RR 9) 5,342
March 2008 (RR 11) 10,541
April 2008 (RR 20) 14,716
May 2008 (RR 24) 18,861
June 2008 (RR 28) 22,1029
Rates:
Underpayments and overpayments, quarter beginning:
April 1, 2008 (RR 10) 13,676
July 1, 2008 (RR 27) 26,1180
Request for comments regarding election to allocate and ap-
portion interest on worldwide basis under section 864(f)
(Notice 54) 26,1191
Interim standards under section 6694(a) (Notice 13) 3,282;sup-
plemental guidance (Notice 46) 18,868
Inventory, dollar-value last-in, first-out (LIFO) pooling method
for certain resellers of cars and light-duty trucks (RP 23) 12,
664
Letter rulings:
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,110
Associate Chief Counsel (International) (RP 7) 1,229
And information letters issued by Associate Offices, determi-
nation letters issued by Operating Divisions (RP 1) 1,1
Life insurance contracts, modifications of split-dollar arrange-
ments (Notice 42) 15,747
Like–kind exchanges, safe harbor, rental property used for per-
sonal purposes (RP 16) 10,547
Listed transaction under sections 6011, 6111, and 6112 (Notice
34) 12,645
Losses, deduction for abandonedstock or securities (TD 9386)
16,788; correction (Ann 35) 17,849
Marketing of refund anticipation loans (RALs) and certain other
products in connection with thepreparation of a tax return
(Ann 7) 5,379
Medicaid rebates (RR 26) 21,985
Mortgage:
Insurance premiums, allocation and information reporting for
2007 (Notice 15) 4,313
Loans held by certain securitization vehicles, modifications
(RP 28) 23,1054
INCOME TAX—Cont.
National and area median gross income figures, guidance for
2008 (RP 19) 11,594
Normalization accounting rules, application (TD 9387) 16,789
Partnerships:
Application of section 163(d) tononcorporate limited partners
in a trader partnership’s trading activity (RR 12) 10,520
Application of sections 704(c)(1)(B) and 737 to distributions
of property after two partnerships engage in an assets-over
merger, correction to REG–143397–05 (Ann 53) 23,1137
Contributed property (REG–100798–06) 23,1135
Look-through entities or members of consolidated group, sub-
stantiality of partnershipallocations (TD 9398) 24,1143;
correction (Ann 58) 26,1193; additional correction (Ann
59) 26,1193
Partner-level items in determining withholding tax, effec-
tively connected U.S. trade or business income allocable to
foreign partners (TD 9394) 21,988
Penalties, substantial understatement, preparer penalty (RP 14)
7,435
Performance-based compensation (RR 13) 10,518
Prepaid forward contracts, exchange traded notes (Notice 2) 2,
252
Preparer signature requirements under section 6695(b)
(Notice 12) 3,280
Presidential Primary Matching Payment Account:
Payments from (RP 15) 9,489
Timing of payments (TD 9382) 9,482; (REG–149475–07) 9,
510
Private foundations, organizations now classified as (Ann 13) 8,
480;(Ann28)14,733; (Ann 37) 17,850; (Ann 40) 19,941;
(Ann 60) 26,1194
Proposed Regulations:
26 CFR 1.132–5, amended; 1.274–5, –5T, revised;
1.280F–6, amended; qualified nonpersonal use vehicles
(REG–106897–08) 25,1175
26 CFR 1.152; dependent child of divorced or separated par-
ents or parents who live apart, hearing on REG–149856–03
(Ann 26) 13,693
26 CFR 1.162–3, –4, revised; 1.162–6, removed; 1.263(a)–0,
amended; 1.263(a)–1 thru –3, revised; 1.263A–1, amended;
guidance regarding deduction and capitalization of expen-
ditures related to tangible property (REG–168745–03) 18,
871
26 CFR 1.162–24, added; 301.9100–4T, amended; travel ex-
penses of state legislators (REG–119518–07) 17,844
26 CFR 1.367(a)–3, amended; 1.367(b)–14, added; treat-
ment of property used to acquire parent stock in certain
triangular reorganizations involving foreign corporations
(REG–136020–07) 24,1154
26 CFR 1.468A–0 thru –9, added; nuclear decommissioning
funds (REG–147290–05) 10,576; hearing scheduled (Ann
43) 19,944
26 CFR 1.664–1, amended; guidance under section 664
regarding the effect of unrelated business taxable income
(UBTI) on charitable remainder trusts (REG–127391–07)
13,689
2008–26 I.R.B.xJune 30, 2008

INCOME TAX—Cont.
26 CFR 1.704–3, amended; contributed property
(REG–100798–06) 23,1135
26 CFR 1.704–3, –4, amended; 1.737–2, amended; partner’s
distributive share; correction to REG–143397–05 (Ann 53)
23,1137
26 CFR 1.860A, 1.860G, modifications of commercial mort-
gage loans held by a real estate mortgage investment con-
duit (REMIC), hearing for REG–127770–07 (Ann 24) 13,
692
26 CFR 1.904–0, amended; 1.904(f)–1, –2, amended;
1.904(f)–7, –8, added; 1.904(g)–0 thru –3, added;
1.1502–9, revised; treatment of overall foreign and domes-
tic losses (REG–141399–07) 8,470; hearing cancellation
(Ann 31) 15,787
26 CFR 1.904–2(i), added; 1.904–4, –5, revised; 1.904–7(g),
added; 1.904(f)–12(h), added; reduction of foreign
tax credit limitation categories under section 904(d)
(REG–114126–07) 6,410; hearing cancellation (Ann 36)
16,827
26 CFR 1.954–3, amended; guidance regarding foreign base
company sales income (REG–124590–07) 16,801
26 CFR 1.1221–1, amended; section 1221(a)(4) capi-
tal asset exclusion for accounts and notes receivable,
REG–109367–06 withdrawn (Ann 41) 19,943
26 CFR 1.1221–3, added; time and manner for electing cap-
ital asset treatment for certain self-created musical works
(REG–153589–06) 14,730
26 CFR 1.1502–13, amended; amendment of matching rule
for certain gains on member stock (REG–137573–07) 15,
750
26 CFR 1.1502–13(e)(2)(ii)(C), withdrawn from
REG–107592–00; consolidated returns, intercompany
obligations (Ann 25) 14,732
26 CFR 1.1561–0, –2, added; 1.1563–1, amended; calculating
and apportioning the section 11(b)(1) additional tax under
section 1561 for controlled groups (REG–104713–07) 6,
409
26 CFR 301.6103(j)(1)–1, amended; disclosure of return in-
formation to the Bureau of the Census (REG–147832–07)
8,472
26 CFR 301.6103(n)–2, added; disclosure of return informa-
tion in connection with written contracts among the IRS,
whistleblowers, and legal representatives of whistleblow-
ers (REG–114942–07) 18,901
26 CFR 301.6323(b)–1, (c)–2, (f)–1, (g)–1, (h)–1, amended;
withdrawal of regulations under old section 6323(b)(10)
(REG–141998–06) 19,911
26 CFR 301.6503(j)–1, added; suspension of running of pe-
riod of limitations during a proceeding to enforce or quash
a designated or related summons (REG–208199–91) 21,
1017
26 CFR 301.7477–1, revised; declaratory judgments - gift tax
determinations (REG–143716–04) 25,1170
26 CFR 301.7701–2, amended; classification of certain for-
eign entities (REG–143468–07) 17,848
INCOME TAX—Cont.
26 CFR 702.9037–1, –2, revised; payments from the
Presidential Primary Matching Payment Account
(REG–149475–07) 9,510
Publications:
1220, Specifications for Filing Forms 1098, 1099, 5498 and
W-2G Electronically, 2008 revision (RP 30) 23,1056
Update to Publication 1187, Specifications for Filing Form
1042-S, Foreign Person’s U.S. Source Income Subject
to Withholding, Electronically or Magnetically (Revised
12-2006) (Ann 6) 5,378;(Ann19)11,624
Qualified films under section 199 (TD 9384) 16,792
Qualified mortgage bonds (QMBs) and mortgage credit certifi-
cates (MCCs), average area housing purchase prices for 2008
(RP 17) 10,549
Qualified nonpersonal use vehicles (REG–106897–08) 25,1175
Qualified tuition programs, applicable transfer tax provi-
sions, publication of advance notice of proposed rulemaking
(REG–127127–05) (Ann 17) 9,512
Real estate mortgage investment conduit (REMIC) commercial
mortgage loan modification, hearing for REG–127770–07
(Ann 24) 13,692
Regulations:
26 CFR 1.1–1, amended; 1.170A–1, amended; 1.170A–1T,
removed; 1.861–3, –8, amended; 1.861–3T, removed;
1.871–1, amended; 1.876–1, revised; 1.876–1T, re-
moved; 1.881–1, –5, amended; 1.884–0, amended;
1.884–0T, removed; 1.901–1, amended; 1.901–1T, re-
moved; 1.931–1, revised; 1.931–1T, removed; 1.932–1,
revised; 1.932–1T, removed; 1.933–1, amended; 1.933–1T,
removed; 1.934–1, revised; 1.934–1T, removed; 1.935–1,
amended; 1.935–1T, removed; 1.937–1, amended;
1.937–2, –3, added; 1.937–2T, –3T, removed; 1.957–3,
revised; 1.957–3T, removed; 1.1402(a)–12, revised;
1.1402(a)–12T, removed; 1.6012–1, amended; 1.6038–2,
amended; 1.6038–2T, removed; 1.6046–1, amended;
1.6046–1T, removed; 301.6688–1, revised; 301.6688–1T,
removed; 301.7701(b)–1, –9, amended; 301.7701(b)–1T,
removed; source rules involving U.S. possessions and other
conforming changes (TD 9391) 20,945
26 CFR 1.46–6, amended; 1.168(i)–3, added; application of
normalization accounting rules to balances of excess de-
ferred income taxes and accumulated deferred investment
tax credits of public utilities whose assets cease to be pub-
lic utility property (TD 9387) 16,789
26 CFR 1.165–5, amended; abandonment of stock or other
securities (TD 9386) 16,788;correction(Ann35)17,849
26 CFR 1.197–0, amended; 1.197–2(g)(5)(ii), revised;
1.197–2T, removed; 1.338–0, –1, –11, amended;
1.338–1T, –11T, removed; 1.338(i)–1, amended;
1.381(c)(22)–1(b)(7)(v), amended; 1.846–0, –4, amended;
1.846–2(d), revised; 602.101, amended; application of
section 338 to insurance companies (TD 9377) 11,578
26 CFR 1.199–0 thru –4, –7 thru –9, amended; 1.199–2T, –3T,
–5T, –7T, –8T, removed; 1.199–5, added; TIPRA amend-
ments to section 199 (TD 9381) 14,694
June 30, 2008xi2008–26 I.R.B.

INCOME TAX—Cont.
26 CFR 1.199–0, –3, –7, –8, amended; qualified films under
section 199 (TD 9384) 16,792
26 CFR 1.358–5, added; 1.358–5T, removed; assumption of
liabilities (TD 9397) 22,1025
26 CFR 1.367(a)–3, (a)–3T, (b)–2, (b)–13, amended;
1.367(b)–14T, added; treatment of property used to acquire
parent stock in certain triangular reorganizations involving
foreign corporations (TD 9400) 24,1139
26 CFR 1.367(b)–6, amended; stock transfer rules, carryover
of earnings and taxes, correction to TD 9273 (Ann 33) 16,
826
26 CFR 1.368–2(k), revised; corporate reorganizations,
amendment to transfers of assets or stock following a
reorganization (TD 9396) 22,1026
26 CFR 1.468A–0 thru –8, removed; 1.468A–0T thru –9T,
added; 602.101, amended; nuclear decommissioning funds
(TD 9374) 10,521
26 CFR 1.704–1, amended; partner’s distributive share (TD
9398) 24,1143; correction (Ann 58) 26,1193; additional
correction (Ann 59) 26,1193
26 CFR 1.817–5, amended; diversification requirements for
variable annuity, endowment, and life insurance contracts
under section 817 (TD 9385) 15,735
26 CFR 1.904–0, amended; 1.904(b)–0, added; 1.904(f)–0,
–0T, –1T, –2T, –7, –7T, –8, –8T, added; 1.904(f)–1, –2,
–3, amended; 1.904(g)–0, –0T, –1, –1T, –2, –2T, –3, –3T,
added; 1.904(i)–0, added; 1.904(j)–0, added; 1.1502–9, re-
vised; 1.1502–9T, added; treatment of overall foreign and
domestic losses (TD 9371) 8,447
26 CFR 1.904–0, –2, –2T, –4, –4T, –5, –5T, –7, –7T, amended;
1.904(f)–12, –12T, amended; reduction of foreign tax credit
limitation categories under section 904(d) (TD 9368) 6,
382; corrections (Ann 29) 15,786; additional corrections
(Ann 30) 16,825
26 CFR 1.905–3T, –4T, amended; foreign tax credit, notifica-
tion of foreign tax redeterminations, correction to TD 9362
(Ann 9) 7,444
26 CFR 1.1221–3T, added; time and manner for electing cap-
ital asset treatment for certain self-created musical works
(TD 9379) 14,715
26 CFR 1.1446–0, –3, –5(c)(2), amended; 1.1446–6T, re-
moved; 1.1446–6, added; 1.1446–7, revised; 1.1464–1,
amended; 1.6071–1, revised; 1.6091–1, added; 1.6151–1,
amended; 1.6302–2, revised; 1.6414–1, amended;
301.6402–3, revised; 301.6722–1, revised; 602.101,
amended; special rules to reduce section 1446 withholding
(TD 9394) 21,988
26 CFR 1.1502–13, amended; 1.1502–13T, added; amend-
ment of matching rule for certain gains on member stock
(TD 9383) 15,738
26 CFR 1.1502–47T, added; 1.1561–0T, added; 1.1561–2, re-
moved; 1.1561–2T, amended; 1.1563–1T, amended; calcu-
lating and apportioning the section 11(b)(1) additional tax
under section 1561 for controlled groups (TD 9369) 6,394
INCOME TAX—Cont.
26 CFR 1.1502–80, amended; miscellaneous operating rules
for successor persons, succession to items of the liquidating
corporation (TD 9376) 11,587
26 CFR 1.6050L–2, added; 1.6050L–2T, removed; 602.101,
amended; information returns by donees relating to quali-
fied intellectual property contributions (TD 9392) 19,903
26 CFR 1.7874–1, added; 1.7874–1T, removed; guidance for
determining the ownership percentage in the case of ex-
panded affiliated groups (TD 9399) 25,1157
26 CFR 54.4980G–0, –4, amended; employer comparable
contributions to Health Savings Accounts (HSAs) under
section 4980G (TD 9393) 20,975
26 CFR 300.0, amended; 300.7, .8, added; user fees relating to
enrollment to perform actuarial services (TD 9370) 7,428
26 CFR 301.6020–1, added; 301.6020–1T, removed; substi-
tute for return (TD 9380) 14,718
26 CFR 301.6103(j)(1)–1, amended; disclosure of return in-
formation to the Bureau of the Census (TD 9372) 8,462
26 CFR 301.6103(j)(1)–1T, amended; disclosure of return in-
formation to the Bureau of the Census (TD 9373) 8,463
26 CFR 301.6103(n)–2T, added; disclosure of return informa-
tion in connection with written contracts among the IRS,
whistleblowers, and legal representatives of whistleblow-
ers (TD 9389) 18,863
26 CFR 301.6325–1, amended; 301.6503(f)–1, amended;
301.7426–1, amended; 401.6325–1, removed; release of
lien or discharge of property (TD 9378) 14,720
26 CFR 301.7216–0, added; 301.7216–1, –2, –3, revised;
guidance necessary to facilitate electronic tax administra-
tion, update (TD 9375) 5,344; correction (Ann 16) 9,511
26 CFR 301.7603–1, revised; 301.7603–2, added;
301.7609–1 thru –5, revised; suspension of statutes of
limitations in third-party and John Doe summons disputes
and expansion of taxpayers’ rights to receive notice and
seek judicial review of third-party summonses (TD 9395)
22,1031
26 CFR 301.7701–2(b)(8)(i), amended; simplification of en-
tity classification rules, correction to TD 8697 (Ann 38) 17,
851
26 CFR 301.7701–2(b)(8)(vi), (e)(7), added; 301.7701–2T,
added; classification of certain foreign entities (TD 9388)
17,832
26 CFR 702.9037–1, –2, amended; 702.9037–1T, –2T, added;
payments from the Presidential Primary Matching Payment
Account (TD 9382) 9,482
Reissuance standards for state or local bonds (Notice 27) 10,543;
(Notice 41) 15,742
Returns required on magnetic media, corrections to TD 9363
(Ann 10) 7,445
Revocations, exempt organizations (Ann 3) 2,269;(Ann14)8,
481;(Ann20)11,625; (Ann 22) 13,692; (Ann 32) 16,826;
(Ann 45) 20,982;(Ann49)21,1024;(Ann51)22,1040;(Ann
54) 24,1155; (Ann 55) 25,1178
Safe harbor, guidance for the Service not challenging the accu-
racy of 2007 returns filed in compliance with Notice 2008–28
(RP 21) 12,657
2008–26 I.R.B.xiiJune 30, 2008

INCOME TAX—Cont.
Section 67 limitations on estates or trusts for bundled investment
management and advisory costs (Notice 32) 11,593
Securities, readily marketable for purposes of section
956(c)(2)(J) (RP 26) 21,1014
Simplification of entity classification rules, correction to TD
8697 (Ann 38) 17,851
Standard Industry Fare Level (SIFL) formula (RR 14) 11,578
Stocks:
Amendment to transfers of assets or stock following corporate
reorganization (TD 9396) 22,1026
Losses, deduction for abandoned stock or securities (TD
9386) 16,788; correction (Ann 35) 17,849
Qualified stock purchase (QSP), reverse subsidiary merger,
step transaction (RR 25) 21,986
Redetermination of intercompany gain as excluded from gross
income (TD 9383) 15,738; (REG–137573–07) 15,750
Statutory stock options, information reporting requirements
(Notice 8) 3,276
Stock transfer rules, carryover of earnings and taxes, correc-
tion to TD 9273 (Ann 33) 16,826
Substitute for return (TD 9380) 14,718
Suspension of statutes of limitations in certain summons
disputes, expansion of taxpayers’ rights for third-party sum-
monses (TD 9395) 22,1031
Tax conventions:
Exclusions from gross income, update of Rev. Rul. 2001–48
(RR 17) 12,626
Insurance excise tax treatment of premiums paid by one for-
eign insurer to another (RR 15) 12,633
Updated tax tables for Belgium, Denmark, Finland, and Ger-
many tax conventions (Ann 8) 6,403
U.S.-Germany, guidance on MAP arbitration procedures un-
derGermanTreaty(Ann39)18,867
U.S.-Mexico income tax treaty, treatment of Mexico’s im-
puesto empresarial a tasa unica (IETU) (Notice 3) 2,253
Voluntary compliance program for foreign insurers and rein-
surers subject to insurance excise tax imposed by section
4371 (Ann 18) 12,667
Tax evasion, return-of-capital treatment (CD 2086) 19,905
Tax shelter, listed transactions (Notice 20) 6,406
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Travel expenses of state legislators (REG–119518–07) 17,844
Treatment of overall foreign and domestic losses (TD 9371) 8,
447; (REG–141399–07) 8,470; hearing cancellation (Ann 31)
15,787
Trusts:
Charitable remainder trusts, calculation of excise tax on unre-
lated business taxable income (UBTI) (REG–127391–07)
13,689
Deductions for contributions to qualified nuclear decommis-
sioning trusts (TD 9374) 10,521; (REG–147290–05) 10,
576; hearing scheduled (Ann 43) 19,944
U.S. territories, American Samoa, Guam, the Northern Mariana
Islands, Puerto Rico, U.S. Virgin Islands, source of income,
filing requirements (TD 9391) 20,945
INCOME TAX—Cont.
User fees relating to enrollment to perform actuarial services (TD
9370) 7,428
Voluntary closing agreement program for tax-exempt bonds and
tax credit bonds (TEB VCAP) (Notice 31) 11,592
Wash sales, individual retirement accounts, Roth IRAs (RR 5) 3,
271
Withholding of tax on disposition of United States real property
interests (RP 27) 21,1014
SELF-EMPLOYMENT TAX
Claims submitted to IRS Whistleblower Office under section
7623 (Notice 4) 2,253
Frivolous tax return positions (Notice 14) 4,310
Interim standards under section 6694(a) (Notice 46) 18,868
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions
(RP 1) 1,1
Technical Advice Memoranda (TAMs) (RP 2) 1,90
June 30, 2008xiii2008–26 I.R.B.

2008–26 I.R.B.June 30, 2008

June 30, 20082008–26 I.R.B.

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