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Announcement 2008–27, page 751.
This document contains the annual report to the public concerning
Advance Pricing Agreements (APAs) and the experience
of the APA Program during calendar year 2007. This
document does not provide guidance regarding the application
of the arm’s length standard. Instead, it reports on the structure
and activities of the APA Program.
INCOME TAX
Rev. Rul. 2008–21, page 734.
Low-income housing credit; satisfactory bond; “bond
factor” amounts for the period January through June
2008. This ruling provides the monthly bond factor amounts
to be used by taxpayers who dispose of qualified low-income
buildings or interests therein during the period January through
June 2008.
T.D. 9383, page 738.
REG–137573–07, page 750.
Final, temporary, and proposed regulations amend regulations
section 1.1502–13(c)(6)(ii)(C), which relates to the redetermination
of intercompany gain as excluded from gross income.
T.D. 9385, page 735.
Final regulations under section 817(h) of the Code make
changes to the regulations concerning diversification requirements.
The changes expand the list of holders whose
beneficial interests in an investment company, partnership, or
trust do not prevent a segregated asset account from looking
through to the assets of the investment company, partnership

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Rev. Rul. 2008–20, page 716.
Federal rates; adjusted federal rates; adjusted federal
long-term rate and the long-term exempt rate. For purposes
of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for April 2008.
T.D. 9378, page 720.
Final regulations under section 6325 of the Code outline specific
procedures for obtaining a release of a federal tax lien or a
discharge of a federal tax lien from property to which it has attached.
The regulations incorporate changes to the Code that
were made by the IRS Restructuring and Reform Act of 1998,
which afford a means for a person whose property is encumbered
by a federal tax lien, but who does not owe the tax giving
rise to the lien, to have his property discharged from the lien.
T.D. 9379, page 715.
REG–153589–06, page 730.
Temporary and proposed regulations under section 1221 of
the Code provide the time and manner for making an election
to treat the sale or exchange of musical compositions or copyrights
in musical works created by the taxpayer as the sale or
exchange of a capital asset.
T.D. 9381, page 694.
Final regulations under section 199 of the Code concern the
amendments made by the Tax Increase Prevention and Reconciliation
Act of 2005 (TIPRA) to section 199, which provides a
deduction for income attributable to domestic production ac

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Rev. Rul. 2008–10, page 676.
Interest rates; underpayments and overpayments. The
rates of interest determined under section 6621 of the Code
for the calender quarter beginning April 1, 2008, will be 6 percent
for overpayments (5 percent in the case of a corporation),
6 percent for underpayments, and 8 percent for large corporate
underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 3.5 percent.
Rev. Rul. 2008–18, page 674.
S corporation; qualified subchapter S subsidiary (QSub).
This ruling describes situations where an S corporation undergoes
a reorganization pursuant to section 368(a)(1)(F) of the
Code where the operating S corporation becomes a QSub of a
newly formed holding company. The ruling holds that the newly
formed parent does not have to make a new S election pursuant
to Rev. Rul. 64–250. The ruling further holds that, effective
1/1/09, the new parent will have to get its own EIN rather
than take over the QSub’s EIN. However, for S corporations
that have previously reorganized under section 368(a)(1)(F) in
a manner described in this ruling, where the parent took the
QSub’s EIN, the parent should continue to use that EIN and the
QSub will have to get a new EIN when it is treated as a separate
corporation. Rev. Rul. 64–250 amplified.
Rev. Rul. 2008–19, page 669.
Insurance companies; interest rate tables. Prevailing
state assumed interest rates are provided for the determination
of reserves under section 807 of the Code for contracts
issued in 2007 and 2008. Rev. Rul. 92–19 supplemented in

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INCOME TAX
Rev. Rul. 2008–14, page 578.
Fringe benefits aircraft valuation formula. The Standard
Industry Fare Level (SIFL) cents-per-mile rates and terminal
charge in effect for the first half of 2008 are set forth for
purposes of determining the value of noncommercial flights
on employer-provided aircraft under section 1.61–21(g) of the
regulations.
Rev. Rul. 2008–16, page 585.
S corporations; charitable contributions. This ruling provides
guidance for S corporations that made charitable contributions
of appreciated property during a taxable year beginning
after December 31, 2005 and before January 1, 2008.
The ruling provides that the amount of the charitable deduction
the shareholder may claim may not exceed the sum of (i) the
shareholder’s pro rata share of the fair market value of the contributed
property over the shareholder’s pro rata share of the
contributed property’s adjusted tax basis, and (ii) the amount
of the Code section 1366(d) loss limitation amount that is allocable
to the contributed property’s basis under regulations
section 1.1366–2(a)(4).
T.D. 9376, page 587.
Final regulations under section 1502 of the Code provide guidance
regarding the manner in which the items (including items
described in section 381(c) but excluding intercompany items
under regulations section 1.1502–13) of a liquidating corporation
are succeeded to and taken into account in cases in which
multiple members acquire the assets of the liquidating corporation
in a complete liquidation to which section 332 applies.
The regulations affect corporations filing consolidated returns.

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INCOME TAX
Rev. Rul. 2008–11, page 541.
Federal rates; adjusted federal rates; adjusted federal
long-term rate and the long-term exempt rate. For purposes
of sections 382, 642, 1274, 1288, and other sections
of the Code, tables set forth the rates for March 2008.
Rev. Rul. 2008–12, page 520.
Application of section 163(d) to limited partners in a
trader partnership. This ruling explains how section 163(d)
of the Code applies to a noncorporate limited partner’s distributive
share of the interest expense allocable to the partnership’s
trade or business of trading securities, if the limited partner
does not materially participate.
Rev. Rul. 2008–13, page 518.
Performance-based compensation. This ruling holds that
compensation paid to an executive is not qualified performance-
based compensation for purposes of section 162(m) of
the Code, even if the compensation is paid upon the attainment
of the performance goal, if the plan agreement or contract provides
for payment of compensation to an executive upon the
attainment of a performance goal or for (1) termination without
“cause” or for “good reason” or (2) voluntary retirement.
T.D. 9374, page 521.
REG–147290–05, page 576.
Final, temporary, and proposed regulations under section 468A
of the Code provide guidance regarding contributions to qualified
nuclear decommissioning trusts, including changes made
to that section by the Energy Policy Act of 2005.

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Notice 2008–25, page 484.
This notice explains how the GO Zone bonus depreciation recapture
provision of section 1400N(d)(5) of the Code applies
to GO Zone property transferred in a like-kind exchange or as
a result of an involuntary conversion. Notice 2006–77 clarified
and amplified.
Notice 2008–26, page 487.
This notice updates and amplifies the qualifying advanced coal
project program of section 48A of the Code by announcing an
immediate beginning of a special allocation round to the pool
of investment credits available for integrated gasification combined
cycle (IGCC) projects using bituminous coal as primary
feedstock.
Rev. Proc. 2008–15, page 489.
This document provides procedures under section 9037 of
the Code for making payments from the Presidential Primary
Matching Payment Account.
Announcement 2008–15, page 511.
This announcement contains corrections to Rev. Proc.
2008–13, 2008–6 I.R.B. 407, relating to maximum vehicle
values for use with the special valuation rules under regulations
section 1.61–21(d) and (e).
Announcement 2008–17, page 512.
This announcement invites comments from the public regarding
transfer tax issues expected to be addressed in forthcoming
proposed regulations (REG–127127–05). The document
also requests comments on several income tax issues and on
rules relating to the election to treat contributions to a Q

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INCOME TAX
T.D. 9371, page 447.
REG–141399–07, page 470.
Final, temporary, and proposed regulations under section 904
of the Code provide rules concerning the treatment of overall
foreign and domestic losses, as well as separate limitation
losses, under sections 904(f) and (g). A public hearing is scheduled
for April 10, 2008.
Notice 2008–22, page 465.
Low-income housing tax credit; private activity bonds.
Resident populations of the 50 states, the District of Columbia,
Puerto Rico, and the insular areas are provided for purposes
of determining the 2008 calendar year (1) state housing credit
ceiling under section 42(h) of the Code, (2) private activity bond
volume cap under section 146, and (3) private activity bond
volume limit under section 142(k).
EMPLOYEE PLANS
Notice 2008–24, page 466.
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 February
2008; the 24-month average segment rates; the funding
transitional segment rates applicable for February 2008; and
the minimum present value transitional rates for January 2008

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EMPLOYEE PLANS
Rev. Rul. 2008–7, page 419.
Accrued benefits; cash balance defined benefit pension
plans; section 411 of the Code. This ruling, which pertains
to a traditional defined benefit pension plan that is amended
in 2001 for the 2002 plan year into a cash balance defined
benefit pension plan containing an accrued benefit formula that
is a lump sum-based benefit, describes the application of the
accrual rules of sections 411(b)(1)(A), (B), and (C) of the Code
to the fact pattern.
Notice 2008–21, page 431.
Funding; effective date; proposed regulations under sections
430 and 436. This notice alerts taxpayers of a uniform
effective date of certain proposed regulations under sections
430 and 436 of the Code. In addition, this notice provides
2008 transitional guidance under section 436 for small plans
with end of the plan year valuation dates.
Notice 2008–23, page 433.
This notice provides a safe harbor with conditions under which
supplemental health insurance is considered excepted from the
requirements of HIPAA and related legislation under chapter
100 (sections 9801–9833) of the Code.
EXCISE TAX
Notice 2008–23, page 433.
This notice provides a safe harbor with conditions under which
supplemental health insurance is considered excepted from the
requirements of HIPAA and related legislation under chapter
100 (sections 9801–9833) of the Code.

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INCOME TAX
T.D. 9368, page 382.
REG–114126–07, page 410.
Final, temporary, and proposed regulations under section 904
of the Code provide transition rules regarding the reduction of
the number of separate foreign tax credit limitation categories
under section 904(d). A public hearing is scheduled for April
22, 2008.
T.D. 9369, page 394.
REG–104713–07, page 409.
Temporary and proposed regulations under section 1561 of
the Code affect component members of a controlled group
of corporations and consolidated groups filing life-nonlife federal
income tax returns. The regulations also provide guidance
for calculating and apportioning between component members
any amount of additional tax and any reduction in the amount
exempted from the alternative minimum tax.
Notice 2008–20, page 406.
This notice identifies the components of the Intermediary
Transaction Tax Shelter transaction listed and described in
Notice 2001–16. The notice also identifies the persons who
are treated as participants in an Intermediary Transaction Tax
Shelter under regulations section 1.6011–4(c)(3)(i)(A). Notice
2001–16 modified.
Rev. Proc. 2008–13, page 407.
This procedure provides the maximum vehicle values for use
with the special valuation rules under regulations sections
1.61–21(d) and (e). These values are indexed for inflation and
must be adjusted annually by referring to the Consumer Pri

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