- Highlights of This Issue
- Preface
- Part I. Rulings and Decisions Under the Internal Revenue Codeof 1986
- Part III. Administrative, Procedural, and Miscellaneous
- Part IV. Items of General Interest
- Definition of Terms and Abbreviations
- Numerical Finding List
- Effect of Current Actions on Previously Published Items
- How to get the Internal Revenue Bulletin
Internal Revenue Bulletin: 2008-49
December 8, 2008
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.
Rev. Rul. 2008-52 Rev. Rul. 2008-52
Section 1274A - Inflation adjusted numbers for 2009. This ruling provides the dollar amounts, increased by the 2009 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2008-3 supplemented and superseded.
Rev. Rul. 2008-53 Rev. Rul. 2008-53
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 December 2008.
T.D. 9431 T.D. 9431
Final regulations under section 6039I of the Code implement the authority given the Secretary to require information reporting on employer-owned life insurance contracts.
Notice 2008-106 Notice 2008-106
This notice informs taxpayers that the new 9 percent applicable percentage floor for certain buildings that are placed in service after July 30, 2008 and before December 31, 2013, enacted pursuant to section 3002(a)(1) of the Housing Assistance Tax Act of 2008, applies notwithstanding a pre-Act irrevocable election by the taxpayer to apply to these buildings an applicable percentage that is less than 9 percent.
T.D. 9432 T.D. 9432
Final regulations under section 9037 of the Code change Treasury procedures for making payments from the Presidential Primary Matching Payment Account.
Rev. Proc. 2008-70 Rev. Proc. 2008-70
Insurance companies; loss reserves; discounting unpaid losses. The loss payment patterns and discount factors are set forth for the 2008 accident year. These factors will be used for computing discount unpaid losses under section 846 of the Code. This procedure also corrects the discount factors for the Composite and International (Composite) lines of business for the 2006 and 2007 accident years in Rev. Proc. 2007-9, 2007-1 C.B. 278, and Rev. Proc. 2008-10, 2008-3 I.R.B. 290, for taxpayers that use the composite method of Notice 88-100, 1988-2 C.B. 439. Rev. Procs. 2007-9 and 2008-10 modified.
Rev. Proc. 2008-71 Rev. Proc. 2008-71
Insurance companies; discounting estimated salvage recoverable. The salvage discount factors are set forth for the 2008 accident year. These factors will be used for computing estimated salvage recoverable under section 832 of the Code.
Announcement 2008-117 Announcement 2008-117
This document provides notice of a public hearing on proposed regulations (REG-155087-05, 2008-38 I.R.B. 726) relating to credits and payments for alcohol mixtures, biodiesel mixtures, renewable diesel mixtures, alternative fuel mixtures, and alternative fuel sold for use or used as a fuel, as well as proposed regulations relating to the definition of gasoline and diesel fuel. The public hearing is scheduled for February 9, 2009.
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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 Conventions, 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 substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management 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.—1986 Code. This part includes rulings and decisions based on provisions of the Internal 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, Legislation 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 Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).
Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and 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.
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 December 2008.
This revenue ruling provides various prescribed rates for federal income tax purposes for December 2008 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520. Finally, Table 6 contains the 2009 interest rate for sections 846 and 807.
REV. RUL. 2008-53 TABLE 1 | ||||||||
---|---|---|---|---|---|---|---|---|
Applicable Federal Rates (AFR) for December 2008 | ||||||||
Period for Compounding | ||||||||
Annual | Semiannual | Quarterly | Monthly | |||||
Short-term | ||||||||
AFR | 1.36% | 1.36% | 1.36% | 1.36% | ||||
110% AFR | 1.51% | 1.50% | 1.50% | 1.50% | ||||
120% AFR | 1.64% | 1.63% | 1.63% | 1.62% | ||||
130% AFR | 1.78% | 1.77% | 1.77% | 1.76% | ||||
Mid-term | ||||||||
AFR | 2.85% | 2.83% | 2.82% | 2.81% | ||||
110% AFR | 3.13% | 3.11% | 3.10% | 3.09% | ||||
120% AFR | 3.43% | 3.40% | 3.39% | 3.38% | ||||
130% AFR | 3.71% | 3.68% | 3.66% | 3.65% | ||||
150% AFR | 4.30% | 4.25% | 4.23% | 4.21% | ||||
175% AFR | 5.01% | 4.95% | 4.92% | 4.90% | ||||
Long-term | ||||||||
AFR | 4.45% | 4.40% | 4.38% | 4.36% | ||||
110% AFR | 4.90% | 4.84% | 4.81% | 4.79% | ||||
120% AFR | 5.35% | 5.28% | 5.25% | 5.22% | ||||
130% AFR | 5.80% | 5.72% | 5.68% | 5.65% |
REV. RUL. 2008-53 TABLE 2 | ||||||||
---|---|---|---|---|---|---|---|---|
Adjusted AFR for December 2008 | ||||||||
Period for Compounding | ||||||||
Annual | Semiannual | Quarterly | Monthly | |||||
Short-term adjusted AFR | 2.20% | 2.19% | 2.18% | 2.18% | ||||
Mid-term adjusted AFR | 3.82% | 3.78% | 3.76% | 3.75% | ||||
Long-term adjusted AFR | 5.40% | 5.33% | 5.29% | 5.27% |
REV. RUL. 2008-53 TABLE 3 | |
---|---|
Rates Under Section 382 for December 2008 | |
Adjusted federal long-term rate for the current month | 5.40% |
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) | 5.40% |
REV. RUL. 2008-53 TABLE 4 | |
---|---|
Appropriate Percentages Under Section 42(b)(1) for December 2008 | |
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. | |
Appropriate percentage for the 70% present value low-income housing credit | 7.84% |
Appropriate percentage for the 30% present value low-income housing credit | 3.36% |
REV. RUL. 2008-53 TABLE 5 | |
---|---|
Rate Under Section 7520 for December 2008 | |
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest | 3.4% |
REV. RUL. 2008-53 TABLE 6 | |
---|---|
Rates Under Sections 846 and 807 | |
Applicable rate of interest for 2009 for purposes of sections 846 and 807 | 4.06% |
Section 1274A - Inflation adjusted numbers for 2009. This ruling provides the dollar amounts, increased by the 2009 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2008-3 supplemented and superseded.
This revenue ruling provides the dollar amounts, increased by the 2009 inflation adjustment, for § 1274A of the Internal Revenue Code.
In general, §§ 483 and 1274 determine the principal amount of a debt instrument given in consideration for the sale or exchange of nonpublicly traded property. In addition, any interest on a debt instrument subject to § 1274 is taken into account under the original issue discount provisions of the Code. Section 1274A, however, modifies the rules under §§ 483 and 1274 for certain types of debt instruments.
In the case of a “qualified debt instrument,” the discount rate used for purposes of §§ 483 and 1274 may not exceed 9 percent, compounded semiannually. Section 1274A(b) defines a qualified debt instrument as any debt instrument given in consideration for the sale or exchange of property (other than new § 38 property within the meaning of § 48(b), as in effect on the day before the date of enactment of the Revenue Reconciliation Act of 1990) if the stated principal amount of the instrument does not exceed the amount specified in § 1274A(b). For debt instruments arising out of sales or exchanges before January 1, 1990, this amount is $2,800,000.
In the case of a “cash method debt instrument,” as defined in § 1274A(c), the borrower and lender may elect to use the cash receipts and disbursements method of accounting. In particular, for any cash method debt instrument, § 1274 does not apply, and interest on the instrument is accounted for by both the borrower and the lender under the cash method of accounting. A cash method debt instrument is a qualified debt instrument that meets the following additional requirements: (A) In the case of instruments arising out of sales or exchanges before January 1, 1990, the stated principal amount does not exceed $2,000,000; (B) the lender does not use an accrual method of accounting and is not a dealer with respect to the property sold or exchanged; (C) § 1274 would have applied to the debt instrument but for an election under § 1274A(c); and (D) an election under § 1274A(c) is jointly made with respect to the debt instrument by the borrower and lender. Section 1.1274A-1(c)(1) of the Income Tax Regulations provides rules concerning the time for, and manner of, making this election.
Section 1274A(d)(2) provides that, for any debt instrument arising out of a sale or exchange during any calendar year after 1989, the dollar amounts stated in § 1274A(b) and § 1274A(c)(2)(A) are increased by the inflation adjustment for the calendar year. Any increase due to the inflation adjustment is rounded to the nearest multiple of $100 (or, if the increase is a multiple of $50 and not of $100, the increase is increased to the nearest multiple of $100). The inflation adjustment for any calendar year is the percentage (if any) by which the CPI for the preceding calendar year exceeds the CPI for calendar year 1988. Section 1274A(d)(2)(B) defines the CPI for any calendar year as the average of the Consumer Price Index as of the close of the 12-month period ending on September 30 of that calendar year.
For debt instruments arising out of sales or exchanges after December 31, 1989, the inflation-adjusted amounts under § 1274A are shown in Table 1.
Rev. Rul. 2008-52 Table 1 | ||
---|---|---|
Inflation-Adjusted Amounts Under § 1274A | ||
Calendar Year of Sale or Exchange | 1274A(b) Amount (qualified debt instrument) | 1274A(c)(2)(A) Amount (cash method debt instrument) |
1990 | $2,933,200 | $2,095,100 |
1991 | $3,079,600 | $2,199,700 |
1992 | $3,234,900 | $2,310,600 |
1993 | $3,332,400 | $2,380,300 |
1994 | $3,433,500 | $2,452,500 |
1995 | $3,523,600 | $2,516,900 |
1996 | $3,622,500 | $2,587,500 |
1997 | $3,723,800 | $2,659,900 |
1998 | $3,823,100 | $2,730,800 |
1999 | $3,885,500 | $2,775,400 |
2000 | $3,960,100 | $2,828,700 |
2001 | $4,085,900 | $2,918,500 |
2002 | $4,217,500 | $3,012,500 |
2003 | $4,280,800 | $3,057,700 |
2004 | $4,381,300 | $3,129,500 |
2005 | $4,483,000 | $3,202,100 |
2006 | $4,630,300 | $3,307,400 |
2007 | $4,800,800 | $3,429,100 |
2008 | $4,913,400 | $3,509,600 |
2009 | $5,131,700 | $3,665,500 |
Note: These inflation adjustments were computed using the All-Urban, Consumer Price Index, 1982-1984 base, published by the Bureau of Labor Statistics. |
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
This document contains final regulations concerning information reporting on employer-owned life insurance contracts under section 6039I of the Internal Revenue Code (Code). This final regulation is necessary to provide taxpayers with guidance as to how the requirements of section 6039I should be applied. These regulations generally apply to taxpayers that are engaged in a trade or business and that are directly or indirectly a beneficiary of a life insurance contract covering the life of an insured who is an employee of the trade or business on the date the contract is issued.
Effective Date: These regulations are effective on November 6, 2008.
Applicability Date: These regulations are applicable for tax years ending after November 6, 2008.
The Pension Protection Act of 2006, Public Law 109-280, 120 Stat. 780 (2006), added sections 101(j) and 6039I to the Code concerning employer-owned life insurance contracts.
Section 101(j)(1) provides that, in the case of an employer-owned life insurance contract, the amount of death benefits excluded from gross income under section 101(a)(1) shall not exceed an amount equal to the sum of the premiums and other amounts paid by the policyholder for the contract. For this purpose, an employer-owned life insurance contract is a life insurance contract that (i) is owned by a person engaged in a trade or business and under which such person is directly or indirectly a beneficiary under the contract, and (ii) covers the life of an insured who is an employee with respect to the trade or business on the date the contract is issued. An applicable policyholder is generally a person who owns an employer-owned life insurance contract, or a related person as described in section 101(j)(3).
Section 101(j)(2) provides exceptions to the general rule of section 101(j)(1) in the case of certain employer-owned life insurance contracts with respect to which certain notice and consent requirements are met. Those exceptions are based either on (i) the insured’s status as an employee within 12 months of death or as a highly compensated employee or highly compensated individual, or (ii) the extent to which death benefits are paid to a family member, trust, or estate of the insured employee, or are used to purchase an equity interest in the applicable policyholder from a family member, trust or estate.
Section 6039I provides that every applicable policyholder that owns one or more employer-owned life insurance contracts shall file a return, at such time and in such manner as the Secretary shall prescribe by regulations, showing for each year the contracts are owned—
(1) The number of employees of the applicable policyholder at the end of the year;
(2) The number of such employees insured under such contracts at the end of the year;
(3) The total amount of insurance in force at the end of the year under such contracts;
(4) The name, address, and taxpayer identification number of the applicable policyholder and the type of business in which the policyholder is engaged; and
(5) That the policyholder has a valid consent for each insured employee (or, if not all such consents are obtained, the number of insured employees for whom such consent was not obtained).
Section 6039I(c) provides that any term used in section 6039I that is used in section 101(j) has the same meaning given that term by section 101(j).
Sections 101(j) and 6039I apply to life insurance contracts issued after August 17, 2006, except for a contract issued after that date pursuant to a section 1035 exchange for a contract issued before that date. For this purpose, a material increase in the death benefit or other material change causes the contract to be treated as a new contract except that, in the case of a master contract within the meaning of section 264(f)(4)(E), the addition of covered lives is treated as a new contract only with respect to those additional covered lives.
On November 13, 2007, the IRS published temporary regulations in the Federal Register (T.D. 9364, 2007-51 I.R.B. 1177 [72 FR 63806]), which serve as the basis for a cross-reference notice of proposed rulemaking (REG-115910-07, 2007-51 I.R.B. 1214 [72 FR 63838]). The temporary regulations and notice of proposed rulemaking provide that the Commissioner may prescribe the form and manner of satisfying the reporting requirements imposed by section 6039I on applicable policyholders owning one or more employer-owned life insurance contracts issued after August 17, 2006. Pursuant to these regulations, on January 24, 2008, the IRS released Form 8925, “Report of Employer-Owned Life Insurance Contracts”, for taxpayers to use to comply with the reporting requirements of section 6039I.
No public hearing was requested or held. The IRS received comments from one taxpayer. Those comments primarily concern the notice and consent requirements of section 101(j), rather than the reporting requirements of section 6039I. Accordingly, this Treasury decision adopts the proposed regulations without substantive change and removes the corresponding temporary regulations. In order to make the regulations more useful to taxpayers, this Treasury decision sets forth the information that is enumerated in section 6039I and required to be reported under that provision. The IRS and Treasury Departments will continue to consider the comments received in connection with any future published guidance under section 101(j).
It has been determined that this Treasury Decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to this regulation.
In accordance with the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby certified that the regulations will not have a significant economic impact on a substantial number of small entities. Even though a substantial number of small entities may be subject to the requirements of section 6039I, these final regulations do not require the reporting of information other than that which is specifically required by section 6039I. Further, the burden associated with completing the prescribed form is minimal because the information required by section 6039I is readily available. Accordingly, the regulations will not have a significant economic impact on a substantial number of small entities and a regulatory flexibility analysis is not required.
Pursuant to section 7805(f) of the Internal Revenue Code, the notice of proposed rulemaking preceding this regulation was submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.
Accordingly, 26 CFR part 1 is amended as follows:
Paragraph 1. The authority citation for part 1 is amended by removing the entry for §1.6039I-1T, and adding an entry in numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.6039I-1 also issued under 26 U.S.C. 6039I. * * *
Par. 2. Section 1.6039I-1 is added to read as follows:
(a) Requirement to report. Section 6039I requires every taxpayer that is an applicable policyholder owning one or more employer-owned life insurance contracts issued after August 17, 2006, to file a return showing the following information for each year the contracts are owned—
(1) The number of employees of the applicable policyholder at the end of the year;
(2) The number of such employees insured under such contracts at the end of the year;
(3) The total amount of insurance in force at the end of the year under such contracts;
(4) The name, address, and taxpayer identification number of the applicable policyholder and the type of business in which the policyholder is engaged; and
(5) That the applicable policyholder has a valid consent for each insured employee (or, if all such consents are not obtained, the number of insured employees for whom such consent was not obtained).
(b) Time and manner of reporting. Applicable policyholders owning one or more employer-owned life insurance contracts issued after August 17, 2006, must provide the information required under §6039I by attaching Form 8925, “Report of Employer-Owned Life Insurance Contracts”, to the policyholder’s income tax return by the due date of that return, or by filing such other form at such time and in such manner as the Commissioner may in the future prescribe.
(c) Effective/applicability date. These regulations are applicable for tax years ending after November 6, 2008.
Par. 3. Section 1.6039I-1T is removed.
Linda E. Stiff,Deputy Commissioner for
Services and Enforcement.
Approved October 16, 2008.
Eric Solomon,Assistant Secretary of
the Treasury (Tax Policy).
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 702
This document contains final regulations under section 9037 of the Internal Revenue Code (Code) relating to the financing of presidential primary campaigns. The regulations relate to Treasury procedures for making payments from the Presidential Primary Matching Payment Account (Primary Account) to eligible primary candidates. These regulations affect all candidates eligible to receive payments from the Primary Account.
Effective Date: These regulations are effective on November 13, 2008.
Applicability Date: For dates of applicability, see §§702.9037-1(b) and 702.9037-2(c).
This document contains amendments to 26 CFR part 702 under section 9037 of the Code. On February 14, 2008, the IRS published temporary regulations (T.D. 9382, 2008-9 I.R.B. 482) in the Federal Register (73 FR 8608). On the same date, the IRS published a notice of proposed rulemaking (REG-149475-07, 2008-9 I.R.B. 510) in the Federal Register (73 FR 8632) cross-referencing the temporary regulations.
The notice of proposed rulemaking provided that, pursuant to section 9036, the Federal Election Commission (Commission) will certify to the Treasury Secretary the full amount of payments to which a candidate is entitled under section 9034. The Treasury Secretary will pay promptly, but not before the start of a Presidential election year, the amounts certified by the Commission from the Primary Account to the candidate. The notice of proposed rulemaking also authorized the Treasury Secretary to provide guidance prescribing rules and procedures for the Primary Account. Contemporaneously with the publication of the notice of proposed rulemaking, the IRS published Rev. Proc. 2008-15, 2008-9 I.R.B. 489, which revises the procedures for making prompt payment from the Primary Account to eligible primary candidates.
The notice of proposed rulemaking invited comments and requests for a public hearing, but no comments were received and no public hearing was requested or held. Accordingly, this Treasury decision adopts the proposed regulations without modification as final regulations.
It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It has also been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because the regulation does not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business.
Accordingly, 26 CFR part 702 is amended as follows:
Paragraph 1. The authority citation for part 702 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 702.9037-1T is removed.
Par. 3. Revise §702.9037-1 to read as follows:
(a) In general. The Secretary will deposit amounts into the Presidential Primary Matching Payment Account (Primary Account) only to the extent that there are amounts in the Presidential Election Campaign Fund (Fund) after the transfers prescribed by §701.9006-1(c) and (d). The Secretary will make this deposit promptly from amounts that have actually been transferred to the Fund under §701.9006-1(a). Any amounts in the Primary Account after October 31 following a presidential election will be returned to the Fund for the purpose of making the transfers prescribed by §701.9006-1(c), (d), and (f) for the next presidential election.
(b) Effective/applicability date. These regulations apply to the Primary Account on or after February 2, 1996.
Par. 4. Section 702.9037-2T is removed.
(a) In general. Pursuant to section 9036, the Federal Election Commission (Commission) will certify to the Secretary the full amount of payment to which a candidate is entitled under section 9034. The Secretary will pay promptly, but not before the start of the matching payment period under section 9032(6), the amounts certified by the Commission from the Presidential Primary Matching Payment Account (Primary Account) to the candidate.
(b) Additional guidance. The Internal Revenue Service may publish guidance in the Internal Revenue Bulletin (see §601.601(d)(2)(ii)(b) of this chapter) prescribing additional rules and procedures for the Primary Account.
(c) Effective/applicability date. These regulations apply to the Primary Account on or after February 2, 1996.
Linda E. Stiff,Deputy Commissioner for
Services and Enforcement.
Approved October 28, 2008.
Eric Solomon,Assistant Secretary of
the Treasury (Tax Policy).
This notice clarifies that the 9 percent applicable percentage floor for non-Federally subsidized new buildings that are placed in service after July 30, 2008, and before December 31, 2013, enacted pursuant to section 3002 of the Housing Assistance Tax Act of 2008 (Pub. L. 110-289) (Act), applies notwithstanding an irrevocable election by the taxpayer under former § 42(b)(2)(A)(ii) of the Internal Revenue Code (now § 42(b)(1)[(A)](ii) of the Code, as amended by the Act) made on or before July 30, 2008.
Section 42(a) of the Code provides that for purposes of § 38, the amount of the low-income housing credit for any taxable year in the credit period shall be an amount equal to (1) the applicable percentage of (2) the qualified basis of each qualified low-income building.
Section 42(b)(1) of the Code, as amended by the Act, provides, in part, that the term “applicable percentage” means, with respect to any building, the appropriate percentage prescribed by the Secretary for the earlier of (i) the month in which such building is placed in service, or (ii) at the election of the taxpayer the month in which the taxpayer and the housing credit agency enter into an agreement with respect to such building (which is binding on such agency, the taxpayer, and all successors in interest) as to the housing credit dollar amount to be allocated to such building. A month may be elected by the taxpayer only if the election is made not later than the 5th day after the close of such month. Such an election, once made, shall be irrevocable. Guidance on the election of the appropriate percentage month can be found under § 1.42-8 of the Income Tax Regulations.
Section 42(b)(1)(B) of the Code, as amended by the Act, provides that the percentages prescribed by the Secretary for any month shall be percentages which will yield over a 10-year period amounts of credit which have a present value equal to (i) 70 percent of the qualified basis of a new building which is not federally subsidized for the taxable year, and (ii) 30 percent of the qualified basis of a building not described in (i).
Section 42(b)(1)(C) of the Code, as amended by the Act, provides that the present value shall be determined as of the last day of the 1st year of the 10-year period referred to in § 42(b)(1)(B) by using a discount rate equal to 72 percent of the average of the annual Federal mid-term rate and the annual Federal long-term rate applicable under § 1274(d)(1) to the month applicable under § 42(b)(1)(A)(i) and (ii) and compounded annually, and by assuming that the credit allowable for any year is received on the last day of such year.
Section § 42(b)(2) of the Code, as amended by the Act, provides that in the case of a new building (A) which is placed in service by the taxpayer after the date of enactment of this paragraph (i.e., July 30, 2008), and before December 31, 2013, and (B) which is not federally subsidized for the taxable year, the applicable percentage shall not be less than 9 percent.
Section § 42(i)(2) of the Code, as amended by the Act, provides that for purposes of § 42(b)(1) a new building shall be treated as “federally subsidized” for any taxable year if, at any time during such taxable year or any prior taxable year, there is or was outstanding any obligation the interest on which is exempt from tax under § 103, the proceeds of which are or were used (directly or indirectly) with respect to the building or the operation thereof.
Section 42(m)(2)(A) of the Code provides that the housing credit dollar amount allocated to a project shall not exceed the amount the housing credit agency determines is necessary for the financial feasibility of the project and its viability as a qualified low-income housing project throughout the credit period. In making the determination, the housing credit agency shall consider (i) the sources and uses of funds and total financing planned for the project, (ii) any proceeds or receipts expected to be generated by reason of tax benefits, (iii) the percentage of the housing credit dollar amount used for project costs other than the cost of intermediaries (this clause shall not be applied so as to impede the development of projects in hard-to-develop areas), and (iv) the reasonableness of the developmental and operational costs of the project. See also § 1.42-8(a)(5) of the regulations.
For newly constructed and substantially rehabilitated buildings that are not federally subsidized, the applicable percentage (i.e., 70-percent present value credit) has been temporarily increased by the Act to not less than 9 percent. This temporary increase applies to buildings placed in service by the taxpayer after July 30, 2008, and before December 31, 2013. The definition of a “federally subsidized” building has also been changed by the Act to include only those buildings financed with tax-exempt bonds. At issue is the correct applicable percentage to apply in a situation in which a taxpayer, on or before July 30, 2008, irrevocably elected under former § 42(b)(2)(A)(ii) of the Code to apply an applicable percentage that is less than 9 percent, and places in service after July 30, 2008, and before December 31, 2013, a newly constructed or substantially rehabilitated building that is not federally subsidized.
The Service has determined that the 9 percent applicable percentage floor under § 42(b)(2) of the Code, as amended by the Act, will apply to a building that meets the requirements of § 42(b)(2), even if an election under former § 42(b)(2)(A)(ii) was made with respect to such building on or before July 30, 2008. Notwithstanding the application of the 9 percent applicable percentage floor, the housing credit dollar amount allocated to a project shall not exceed the amount the housing credit agency determines is necessary for the financial feasibility of the project and its viability as a qualified low-income housing project throughout the credit period. See § 42(m)(2).
The principal author of this notice is Julie Hanlon Bolton, Office of the Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this notice, contact Ms. Hanlon Bolton at (202) 622-3040 (not a toll-free call).
This revenue procedure prescribes the loss payment patterns and discount factors for the 2008 accident year. These factors will be used for computing discounted unpaid losses under § 846 of the Internal Revenue Code. See Rev. Proc. 2008-10, 2008-3 I.R.B. 290, for background concerning the loss payment patterns and application of the discount factors. This revenue procedure also corrects the discount factors for the Composite and International (Composite) lines of business for the 2006 and 2007 accident years in Rev. Proc. 2007-9, 2007-3 I.R.B. 278, and Rev. Proc. 2008-10, 2008-3 I.R.B. 290, for taxpayers that use the composite method of Notice 88-100, 1988-2 C.B. 439.
This revenue procedure applies to any taxpayer that is required to discount its unpaid losses under § 846 for a line of business using discount factors published by the Secretary.
.01 Rev. Proc. 2007-9, 2007-3 I.R.B. 278, prescribes the loss payment patterns and discount factors for the 2006 accident year. Rev. Proc. 2008-10, 2008-3 I.R.B. 290, prescribes the loss payment patterns and discount factors for the 2007 accident year. An error has been discovered in the composite discount factors for the 2006 and 2007 accident years that were determined for the Composite and International (Composite) lines of business for taxpayers that use the composite method of Notice 88-100, which is used for computing discounted unpaid losses for accident years not separately reported on the annual statement.
.02 Rev. Proc. 2007-9 as corrected for the Composite line of business provides: “Taxpayers that use the composite method of Notice 88-100 should use 90.1284 percent to discount unpaid losses incurred in this line of business in 2006 and prior years that are outstanding at the end of the 2016 taxable year.”
.03 Rev. Proc. 2007-9 as corrected for the International (Composite) line of business provides: “Taxpayers that use the composite method of Notice 88-100 should use 90.1284 percent to discount unpaid losses incurred in this line of business in 2006 and prior years that are outstanding at the end of the 2016 taxable year.”
.04 Rev. Proc. 2008-10 as corrected for the Composite line of business provides: “Taxpayers that use the composite method of Notice 88-100 should use 92.4923 percent to discount unpaid losses incurred in this line of business in 2007 and prior years that are outstanding at the end of the 2017 taxable year.”
.05 Rev. Proc. 2008-10 as corrected for the International (Composite) line of business provides: “Taxpayers that use the composite method of Notice 88-100 should use 92.4923 percent to discount unpaid losses incurred in this line of business in 2007 and prior years that are outstanding at the end of the 2017 taxable year.”
.01 The following tables present separately for each line of business the discount factors under § 846 for accident year 2008. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 2008, which is 4.06 percent, and by assuming all loss payments occur in the middle of the calendar year.
.02 If the groupings of individual lines of business on the annual statement change, taxpayers must discount the unpaid losses on the affected lines of business in accordance with the discounting patterns that would have applied to those unpaid losses based on their classification on the 2005 annual statement. See Rev. Proc. 2008-10, 2008-3 I.R.B. 290, section 2, for additional background on discounting under section 846 and the use of the Secretary’s tables.
.03 Section V of Notice 88-100, 1988-2 C.B. 439, sets forth a composite method for computing discounted unpaid losses for accident years that are not separately reported on the annual statement. The tables separately provide discount factors for taxpayers who elect to use the composite method of section V of Notice 88-100. See Rev. Proc. 2002-74, 2002-2 C.B. 980.
.04 Tables.
Tables of Factors to be Used to Discount Unpaid Losses Incurred in Accident Year 2008 |
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(Interest rate: 4.06 percent) |
Accident and Health (Other Than Disability Income or Credit Disability Insurance) |
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Taxpayers that do not use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the 2008 and later taxable years. |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount all unpaid losses in this line of business that are outstanding at the end of the 2008 taxable year. |
Auto Physical Damage | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 89.4096 | 89.4096 | 10.5904 | 10.3639 | 97.8613 |
2009 | 99.6848 | 10.2752 | 0.3152 | 0.3030 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 0.1576 | 0.1576 | 0.1545 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
Commercial Auto/Truck Liability/Medical | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 23.6718 | 23.6718 | 76.3282 | 70.1942 | 91.9637 |
2009 | 47.5425 | 23.8708 | 52.4575 | 48.6936 | 92.8249 |
2010 | 66.6847 | 19.1421 | 33.3153 | 31.1437 | 93.4816 |
2011 | 81.5105 | 14.8258 | 18.4895 | 17.2843 | 93.4819 |
2012 | 90.0548 | 8.5443 | 9.9452 | 9.2701 | 93.2115 |
2013 | 94.7311 | 4.6763 | 5.2689 | 4.8762 | 92.5459 |
2014 | 97.0602 | 2.3292 | 2.9398 | 2.6982 | 91.7820 |
2015 | 98.1174 | 1.0572 | 1.8826 | 1.7293 | 91.8572 |
2016 | 98.8692 | 0.7518 | 1.1308 | 1.0326 | 91.3161 |
2017 | 99.1160 | 0.2467 | 0.8840 | 0.8228 | 93.0737 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.2467 | 0.6373 | 0.6045 | 94.8560 | |
2019 | 0.2467 | 0.3906 | 0.3774 | 96.6210 | |
2020 and later years | 0.2467 | 0.1439 | 0.1410 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 95.5540 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Composite | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 34.7004 | 34.7004 | 65.2996 | 59.2808 | 90.7829 |
2009 | 58.6076 | 23.9072 | 41.3924 | 37.2999 | 90.1131 |
2010 | 71.7608 | 13.1532 | 28.2392 | 25.3968 | 89.9346 |
2011 | 81.4987 | 9.7379 | 18.5013 | 16.4943 | 89.1521 |
2012 | 87.8488 | 6.3501 | 12.1512 | 10.6863 | 87.9440 |
2013 | 91.4226 | 3.5739 | 8.5774 | 7.4744 | 87.1415 |
2014 | 93.4057 | 1.9831 | 6.5943 | 5.7549 | 87.2720 |
2015 | 94.2280 | 0.8222 | 5.7720 | 5.1498 | 89.2206 |
2016 | 95.4875 | 1.2595 | 4.5125 | 4.0741 | 90.2843 |
2017 | 96.3560 | 0.8685 | 3.6440 | 3.3535 | 92.0287 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.8685 | 2.7754 | 2.6036 | 93.8109 | |
2019 | 0.8685 | 1.9069 | 1.8233 | 95.6199 | |
2020 | 0.8685 | 1.0383 | 1.0114 | 97.4044 | |
2021 and later years | 0.8685 | 0.1698 | 0.1664 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.3096 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Fidelity/Surety | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 25.2328 | 25.2328 | 74.7672 | 71.0916 | 95.0839 |
2009 | 61.1025 | 35.8698 | 38.8975 | 37.3872 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 19.4487 | 19.4487 | 19.0655 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
Financial Guaranty/Mortgage Guaranty | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 7.7824 | 7.7824 | 92.2176 | 88.2568 | 95.7050 |
2009 | 62.1390 | 54.3565 | 37.8610 | 36.3911 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 18.9305 | 18.9305 | 18.5575 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
International (Composite) | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 34.7004 | 34.7004 | 65.2996 | 59.2808 | 90.7829 |
2009 | 58.6076 | 23.9072 | 41.3924 | 37.2999 | 90.1131 |
2010 | 71.7608 | 13.1532 | 28.2392 | 25.3968 | 89.9346 |
2011 | 81.4987 | 9.7379 | 18.5013 | 16.4943 | 89.1521 |
2012 | 87.8488 | 6.3501 | 12.1512 | 10.6863 | 87.9440 |
2013 | 91.4226 | 3.5739 | 8.5774 | 7.4744 | 87.1415 |
2014 | 93.4057 | 1.9831 | 6.5943 | 5.7549 | 87.2720 |
2015 | 94.2280 | 0.8222 | 5.7720 | 5.1498 | 89.2206 |
2016 | 95.4875 | 1.2595 | 4.5125 | 4.0741 | 90.2843 |
2017 | 96.3560 | 0.8685 | 3.6440 | 3.3535 | 92.0287 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.8685 | 2.7754 | 2.6036 | 93.8109 | |
2019 | 0.8685 | 1.9069 | 1.8233 | 95.6199 | |
2020 | 0.8685 | 1.0383 | 1.0114 | 97.4044 | |
2021 and later years | 0.8685 | 0.1698 | 0.1664 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.3096 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Medical Malpractice — Claims-Made | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 4.9425 | 4.9425 | 95.0575 | 85.0276 | 89.4485 |
2009 | 19.9369 | 14.9944 | 80.0631 | 73.1839 | 91.4078 |
2010 | 44.3489 | 24.4120 | 55.6511 | 51.2525 | 92.0962 |
2011 | 64.8374 | 20.4885 | 35.1626 | 32.4331 | 92.2375 |
2012 | 80.2530 | 15.4156 | 19.7470 | 18.0245 | 91.2770 |
2013 | 85.7907 | 5.5377 | 14.2093 | 13.1072 | 92.2442 |
2014 | 91.2722 | 5.4815 | 8.7278 | 8.0478 | 92.2082 |
2015 | 93.3314 | 2.0593 | 6.6686 | 6.2739 | 94.0812 |
2016 | 96.1257 | 2.7942 | 3.8743 | 3.6782 | 94.9374 |
2017 | 97.6538 | 1.5281 | 2.3462 | 2.2687 | 96.6961 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 and later years | 1.5281 | 0.8182 | 0.8021 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0440 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Medical Malpractice — Occurrence | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 1.5878 | 1.5878 | 98.4122 | 82.1817 | 83.5076 |
2009 | 4.4720 | 2.8842 | 95.5280 | 82.5760 | 86.4417 |
2010 | 17.7738 | 13.3018 | 82.2262 | 72.3595 | 88.0005 |
2011 | 35.8814 | 18.1076 | 64.1186 | 56.8257 | 88.6260 |
2012 | 52.9447 | 17.0633 | 47.0553 | 41.7266 | 88.6757 |
2013 | 68.4348 | 15.4901 | 31.5652 | 27.6193 | 87.4993 |
2014 | 79.5616 | 11.1268 | 20.4384 | 17.3902 | 85.0861 |
2015 | 85.8198 | 6.2582 | 14.1802 | 11.7123 | 82.5961 |
2016 | 90.1267 | 4.3069 | 9.8733 | 7.7943 | 78.9437 |
2017 | 90.3701 | 0.2434 | 9.6299 | 7.8625 | 81.6469 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.2434 | 9.3865 | 7.9335 | 84.5197 | |
2019 | 0.2434 | 9.1431 | 8.0073 | 87.5770 | |
2020 | 0.2434 | 8.8998 | 8.0841 | 90.8352 | |
2021 | 0.2434 | 8.6564 | 8.1641 | 94.3126 | |
2022 and later years | 0.2434 | 8.4130 | 8.2473 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 86.1528 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Miscellaneous Casualty | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 72.9064 | 72.9064 | 27.0936 | 26.1964 | 96.6888 |
2009 | 93.5836 | 20.6771 | 6.4164 | 6.1673 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 3.2082 | 3.2082 | 3.1450 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 52.5880 | 52.5880 | 47.4120 | 44.2537 | 93.3385 |
2009 | 80.0449 | 27.4570 | 19.9551 | 18.0416 | 90.4110 |
2010 | 86.1625 | 6.1175 | 13.8375 | 12.5336 | 90.5767 |
2011 | 90.7452 | 4.5827 | 9.2548 | 8.3676 | 90.4137 |
2012 | 93.9006 | 3.1555 | 6.0994 | 5.4885 | 89.9844 |
2013 | 95.7613 | 1.8607 | 4.2387 | 3.8132 | 89.9627 |
2014 | 96.8755 | 1.1141 | 3.1245 | 2.8315 | 90.6219 |
2015 | 97.6715 | 0.7960 | 2.3285 | 2.1345 | 91.6659 |
2016 | 98.0329 | 0.3615 | 1.9671 | 1.8524 | 94.1706 |
2017 | 98.6810 | 0.6481 | 1.3190 | 1.2665 | 96.0207 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.6481 | 0.6709 | 0.6568 | 97.8997 | |
2019 and later years | 0.6481 | 0.0228 | 0.0224 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 97.9053 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Other (Including Credit) | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 67.9528 | 67.9528 | 32.0472 | 30.8190 | 96.1676 |
2009 | 89.4609 | 21.5081 | 10.5391 | 10.1299 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 5.2695 | 5.2695 | 5.1657 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
Other Liability — Claims-Made | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 5.8796 | 5.8796 | 94.1204 | 83.2369 | 88.4367 |
2009 | 18.8735 | 12.9938 | 81.1265 | 73.3613 | 90.4283 |
2010 | 41.6840 | 22.8105 | 58.3160 | 53.0709 | 91.0056 |
2011 | 62.5322 | 20.8483 | 37.4678 | 33.9583 | 90.6333 |
2012 | 73.5207 | 10.9885 | 26.4793 | 24.1277 | 91.1189 |
2013 | 82.0036 | 8.4829 | 17.9964 | 16.4539 | 91.4286 |
2014 | 88.6279 | 6.6244 | 11.3721 | 10.3644 | 91.1391 |
2015 | 90.7107 | 2.0828 | 9.2893 | 8.6605 | 93.2317 |
2016 | 94.8439 | 4.1332 | 5.1561 | 4.7959 | 93.0145 |
2017 | 96.2689 | 1.4249 | 3.7311 | 3.5370 | 94.7977 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 1.4249 | 2.3062 | 2.2270 | 96.5683 | |
2019 and later years | 1.4249 | 0.8812 | 0.8639 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 97.0645 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Other Liability — Occurrence | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 13.6594 | 13.6594 | 86.3406 | 74.5578 | 86.3531 |
2009 | 24.8389 | 11.1795 | 75.1611 | 66.1806 | 88.0517 |
2010 | 41.7792 | 16.9403 | 58.2208 | 51.5868 | 88.6055 |
2011 | 58.4995 | 16.7203 | 41.5005 | 36.6249 | 88.2518 |
2012 | 69.5197 | 11.0203 | 30.4803 | 26.8702 | 88.1560 |
2013 | 77.7513 | 8.2316 | 22.2487 | 19.5641 | 87.9336 |
2014 | 84.2243 | 6.4730 | 15.7757 | 13.7553 | 87.1929 |
2015 | 83.2275 | -0.9968 | 16.7725 | 15.3306 | 91.4032 |
2016 | 88.8524 | 5.6249 | 11.1476 | 10.2151 | 91.6347 |
2017 | 91.3852 | 2.5328 | 8.6148 | 8.0461 | 93.3986 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 2.5328 | 6.0820 | 5.7891 | 95.1836 | |
2019 | 2.5328 | 3.5492 | 3.4404 | 96.9345 | |
2020 and later years | 2.5328 | 1.0164 | 0.9964 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.7637 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Private Passenger Auto Liability/Medical | |||||
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Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 42.6108 | 42.6108 | 57.3892 | 54.0511 | 94.1835 |
2009 | 71.5827 | 28.9719 | 28.4173 | 26.6915 | 93.9269 |
2010 | 84.6947 | 13.1120 | 15.3053 | 14.3997 | 94.0826 |
2011 | 92.3556 | 7.6610 | 7.6444 | 7.1693 | 93.7860 |
2012 | 96.2369 | 3.8812 | 3.7631 | 3.5012 | 93.0391 |
2013 | 97.9275 | 1.6907 | 2.0725 | 1.9187 | 92.5799 |
2014 | 98.7719 | 0.8444 | 1.2281 | 1.1352 | 92.4394 |
2015 | 99.2692 | 0.4973 | 0.7308 | 0.6740 | 92.2334 |
2016 | 99.5053 | 0.2361 | 0.4947 | 0.4606 | 93.0998 |
2017 | 99.6440 | 0.1387 | 0.3560 | 0.3378 | 94.8818 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.1387 | 0.2174 | 0.2101 | 96.6446 | |
2019 and later years | 0.1387 | 0.0787 | 0.0772 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 97.0811 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Products Liability — Claims-Made | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 1.0259 | 1.0259 | 98.9741 | 84.7900 | 84.6586 |
2009 | 11.7927 | 10.7667 | 88.2073 | 76.2088 | 86.3973 |
2010 | 29.3642 | 17.5716 | 70.6358 | 61.3781 | 86.8939 |
2011 | 55.1655 | 25.8012 | 44.8345 | 37.5503 | 83.7531 |
2012 | 83.4171 | 28.2516 | 16.5829 | 10.2554 | 61.8434 |
2013 | 64.8933 | -18.5238 | 35.1067 | 29.5679 | 84.2229 |
2014 | 82.3346 | 17.4414 | 17.6654 | 12.9765 | 73.4571 |
2015 | 86.3986 | 4.0640 | 13.6014 | 9.3576 | 68.7991 |
2016 | 76.3310 | -10.0676 | 23.6690 | 20.0075 | 84.5305 |
2017 | 78.7910 | 2.4600 | 21.2090 | 18.3104 | 86.3331 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 2.4600 | 18.7490 | 16.5444 | 88.2412 | |
2019 | 2.4600 | 16.2890 | 14.7066 | 90.2855 | |
2020 | 2.4600 | 13.8290 | 12.7943 | 92.5176 | |
2021 | 2.4600 | 11.3691 | 10.8043 | 95.0326 | |
2022 and later years | 2.4600 | 8.9091 | 8.7336 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 89.2840 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Products Liability — Occurrence | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 5.0466 | 5.0466 | 94.9534 | 80.1653 | 84.4260 |
2009 | 13.6935 | 8.6469 | 86.3065 | 74.5994 | 86.4354 |
2010 | 28.2541 | 14.5606 | 71.7459 | 62.7748 | 87.4961 |
2011 | 41.3083 | 13.0542 | 58.6917 | 52.0070 | 88.6104 |
2012 | 59.3693 | 18.0610 | 40.6307 | 35.6944 | 87.8509 |
2013 | 73.0717 | 13.7024 | 26.9283 | 23.1659 | 86.0279 |
2014 | 74.6612 | 1.5895 | 25.3388 | 22.4849 | 88.7371 |
2015 | 78.9833 | 4.3221 | 21.0167 | 18.9889 | 90.3513 |
2016 | 86.1231 | 7.1398 | 13.8769 | 12.4765 | 89.9085 |
2017 | 88.6931 | 2.5700 | 11.3069 | 10.3614 | 91.6379 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 2.5700 | 8.7369 | 8.1604 | 93.4018 | |
2019 | 2.5700 | 6.1669 | 5.8701 | 95.1869 | |
2020 | 2.5700 | 3.5969 | 3.4868 | 96.9378 | |
2021 and later years | 2.5700 | 1.0269 | 1.0067 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.0919 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Reinsurance — Nonproportional Assumed Property | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 12.9458 | 12.9458 | 87.0542 | 80.8403 | 92.8620 |
2009 | 60.1796 | 47.2338 | 39.8204 | 35.9393 | 90.2535 |
2010 | 80.8225 | 20.6429 | 19.1775 | 16.3406 | 85.2075 |
2011 | 84.9430 | 4.1205 | 15.0570 | 12.8008 | 85.0155 |
2012 | 85.6680 | 0.7250 | 14.3320 | 12.5809 | 87.7821 |
2013 | 80.0452 | -5.6229 | 19.9548 | 18.8276 | 94.3509 |
2014 | 86.7013 | 6.6561 | 13.2987 | 12.8020 | 96.2654 |
2015 | 97.2533 | 10.5520 | 2.7467 | 2.5578 | 93.1205 |
2016 | 97.6721 | 0.4188 | 2.3279 | 2.2344 | 95.9820 |
2017 | 98.8078 | 1.1357 | 1.1922 | 1.1665 | 97.8487 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 and later years | 1.1357 | 0.0564 | 0.0553 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.5477 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Reinsurance — Nonproportional Assumed Liability | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 32.5917 | 32.5917 | 67.4083 | 54.5146 | 80.8723 |
2009 | 33.3995 | 0.8078 | 66.6005 | 55.9039 | 83.9392 |
2010 | 35.4948 | 2.0953 | 64.5052 | 56.0362 | 86.8708 |
2011 | 44.0321 | 8.5373 | 55.9679 | 49.6024 | 88.6265 |
2012 | 64.8299 | 20.7979 | 35.1701 | 30.4004 | 86.4383 |
2013 | 66.4358 | 1.6059 | 33.5642 | 29.9965 | 89.3706 |
2014 | 77.8097 | 11.3738 | 22.1903 | 19.6119 | 88.3805 |
2015 | 82.4438 | 4.6341 | 17.5562 | 15.6809 | 89.3183 |
2016 | 84.1944 | 1.7507 | 15.8056 | 14.5317 | 91.9406 |
2017 | 87.9223 | 3.7279 | 12.0777 | 11.3189 | 93.7176 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 3.7279 | 8.3498 | 7.9757 | 95.5191 | |
2019 | 3.7279 | 4.6219 | 4.4967 | 97.2900 | |
2020 and later years | 3.7279 | 0.8940 | 0.8764 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.6662 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Reinsurance — Nonproportional Assumed Financial Lines | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 8.4783 | 8.4783 | 91.5217 | 82.6377 | 90.2930 |
2009 | 28.0475 | 19.5693 | 71.9525 | 66.0302 | 91.7692 |
2010 | 60.4351 | 32.3875 | 39.5649 | 35.6726 | 90.1622 |
2011 | 82.4448 | 22.0097 | 17.5552 | 14.6688 | 83.5583 |
2012 | 90.2720 | 7.8271 | 9.7280 | 7.2799 | 74.8343 |
2013 | 85.3168 | -4.9551 | 14.6831 | 12.6301 | 86.0181 |
2014 | 88.3777 | 3.0608 | 11.6223 | 10.0206 | 86.2186 |
2015 | 89.9934 | 1.6157 | 10.0066 | 8.7793 | 87.7346 |
2016 | 81.6664 | -8.3269 | 18.3336 | 17.6300 | 96.1625 |
2017 | 91.0491 | 9.3827 | 8.9509 | 8.7745 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 and later years | — | — | — | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 94.5352 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary and Theft) | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 44.5756 | 44.5756 | 55.4244 | 53.5639 | 96.6430 |
2009 | 88.4263 | 41.8507 | 13.5737 | 13.0467 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2010 and later years | 6.7869 | 6.7869 | 6.6531 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2010 taxable year. |
Workers’ Compensation | |||||
---|---|---|---|---|---|
Tax Year | Estimated Cumulative Losses Paid (%) | Estimated Losses Paid Each Year (%) | Unpaid Losses at Year End (%) | Discounted Unpaid Losses at Year End (%) | Discount Factors (%) |
2008 | 19.0410 | 19.0410 | 80.9590 | 69.6415 | 86.0207 |
2009 | 40.2442 | 21.2032 | 59.7558 | 50.8396 | 85.0789 |
2010 | 57.1497 | 16.9055 | 42.8503 | 35.6584 | 83.2162 |
2011 | 67.8601 | 10.7104 | 32.1399 | 26.1804 | 81.4579 |
2012 | 75.5399 | 7.6797 | 24.4601 | 19.4093 | 79.3507 |
2013 | 80.1157 | 4.5758 | 19.8843 | 15.5296 | 78.0994 |
2014 | 82.1828 | 2.0672 | 17.8172 | 14.0513 | 78.8640 |
2015 | 84.4045 | 2.2217 | 15.5955 | 12.3555 | 79.2248 |
2016 | 85.5195 | 1.1150 | 14.4805 | 11.7198 | 80.9346 |
2017 | 86.2855 | 0.7661 | 13.7145 | 11.4141 | 83.2269 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount unpaid losses incurred in this line of business in the 2008 accident year and that are outstanding at the end of the tax year shown. | |||||
2018 | 0.7661 | 12.9484 | 11.0961 | 85.6945 | |
2019 | 0.7661 | 12.1823 | 10.7651 | 88.3666 | |
2020 | 0.7661 | 11.4163 | 10.4207 | 91.2795 | |
2021 | 0.7661 | 10.6502 | 10.0624 | 94.4802 | |
2022 and later years | 0.7661 | 9.8842 | 9.6894 | 98.0298 | |
Taxpayers that use the composite method of Notice 88-100 should use 88.0210 percent to discount unpaid losses incurred in this line of business in 2008 and prior years and that are outstanding at the end of the 2018 taxable year. |
Rev. Proc. 2007-9 and Rev. Proc. 2008-10 are modified as to the composite discount factor to be used by taxpayers that use the composite method of Notice 88-100 under the Composite and International (Composite) lines of business.
This revenue procedure prescribes the salvage discount factors for the 2008 accident year. These factors must be used to compute discounted estimated salvage recoverable under § 832 of the Internal Revenue Code.
Section 832(b)(5)(A) requires that all estimated salvage recoverable (including that which cannot be treated as an asset for state accounting purposes) be taken into account in computing the deduction for losses incurred. Under § 832(b)(5)(A), paid losses are to be reduced by salvage and reinsurance recovered during the taxable year. This amount is adjusted to reflect changes in discounted unpaid losses on nonlife insurance contracts and in unpaid losses on life insurance contracts. An adjustment is then made to reflect any changes in discounted estimated salvage recoverable and in reinsurance recoverable.
Pursuant to § 832(b), the amount of estimated salvage is determined on a discounted basis in accordance with procedures established by the Secretary.
This revenue procedure applies to any taxpayer that is required to discount estimated salvage recoverable under § 832.
.01 The following tables present separately for each line of business the discount factors under § 832 for the 2008 accident year. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 2008, which is 4.06 percent, and by assuming all estimated salvage is recovered in the middle of each calendar year. See Rev. Proc. 2008-11, 2008-3 I.R.B. 301, for background regarding the tables.
.02 These tables must be used by taxpayers irrespective of whether they elected to discount unpaid losses using their own historical experience under § 846.
.03 Section V of Notice 88-100, 1988-2 C.B. 439, provides a composite discount factor to be used in determining the discounted unpaid losses for accident years that are not separately reported on the NAIC Annual Statement. The tables separately provide discount factors for taxpayers who elect to use the composite method. Rev. Proc. 2002-74, 2002-2 C.B. 980, clarifies that for certain insurance companies subject to tax under § 831 the composite method for discounting unpaid losses set forth in Notice 88-100, section V, 1988-2 C.B. 439, is permitted but not required. This revenue procedure further provides alternative methods for computing discounted unpaid losses that are permitted for insurance companies not using the composite method, and sets forth a procedure for insurance companies to obtain automatic consent of the Commissioner to change to one of the methods described in Rev. Proc. 2002-74.
.04 Tables.
Tables of Factors to be Used to Discount Salvage Recoverable With Respect to Losses Incurred in Accident Year 2008 | |
---|---|
(Interest rate: 4.06 percent) | |
Accident and Health (Other Than Disability Income or Credit Disability Insurance) | |
Taxpayers that do not use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable with respect to losses incurred in this line of business in the 2008 accident year as of the end of the 2008 and later taxable years. | |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount all salvage recoverable in this line of business as of the end of the 2008 taxable year. |
Auto Physical Damage | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 97.2331 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Commercial Auto/Truck Liability/Medical | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 92.3526 |
2009 | 92.2970 |
2010 | 92.6408 |
2011 | 92.9897 |
2012 | 93.7281 |
2013 | 93.5170 |
2014 | 91.9508 |
2015 | 92.8642 |
2016 | 96.2378 |
2017 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Composite | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 92.3690 |
2009 | 92.1172 |
2010 | 91.9402 |
2011 | 91.7659 |
2012 | 91.1438 |
2013 | 90.2174 |
2014 | 91.0647 |
2015 | 92.4105 |
2016 | 94.4361 |
2017 | 96.2605 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 96.8444 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Fidelity/Surety | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 93.6954 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Financial Guaranty/Mortgage Guaranty | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 94.7421 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
International (Composite) | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 92.3690 |
2009 | 92.1172 |
2010 | 91.9402 |
2011 | 91.7659 |
2012 | 91.1438 |
2013 | 90.2174 |
2014 | 91.0647 |
2015 | 92.4105 |
2016 | 94.4361 |
2017 | 96.2605 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 96.8444 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Medical Malpractice — Claims-Made | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 92.6642 |
2009 | 93.7424 |
2010 | 92.1505 |
2011 | 92.7778 |
2012 | 92.0831 |
2013 | 87.6889 |
2014 | 84.3189 |
2015 | 90.2868 |
2016 | 96.4445 |
2017 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Medical Malpractice — Occurrence | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 85.5177 |
2009 | 89.9300 |
2010 | 92.2898 |
2011 | 84.2693 |
2012 | 94.7905 |
2013 | 91.4234 |
2014 | 93.0145 |
2015 | 95.8751 |
2016 | 97.0989 |
2017 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Miscellaneous Casualty | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 96.5837 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 93.0068 |
2009 | 92.3990 |
2010 | 92.3201 |
2011 | 92.2569 |
2012 | 91.4462 |
2013 | 89.8725 |
2014 | 91.0239 |
2015 | 93.4483 |
2016 | 94.8485 |
2017 | 96.6142 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Other (Including Credit) | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 95.6448 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Other Liability — Claims-Made | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 88.4208 |
2009 | 89.5374 |
2010 | 87.6521 |
2011 | 90.8781 |
2012 | 92.3590 |
2013 | 94.2379 |
2014 | 93.1673 |
2015 | 91.7716 |
2016 | 97.3613 |
2017 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0675 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Other Liability — Occurrence | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 87.1236 |
2009 | 88.1600 |
2010 | 90.4878 |
2011 | 91.2470 |
2012 | 90.6851 |
2013 | 90.8000 |
2014 | 90.2668 |
2015 | 93.0020 |
2016 | 95.7619 |
2017 | 97.5722 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Private Passenger Auto Liability/Medical | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 94.5329 |
2009 | 94.5579 |
2010 | 94.3102 |
2011 | 93.4459 |
2012 | 92.8620 |
2013 | 92.0891 |
2014 | 92.9858 |
2015 | 94.5440 |
2016 | 94.6149 |
2017 | 96.4088 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Products Liability — Claims-Made | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 88.9426 |
2009 | 51.3741 |
2010 | 53.7803 |
2011 | 90.7115 |
2012 | 80.1341 |
2013 | 91.4320 |
2014 | 59.5121 |
2015 | 90.5055 |
2016 | 91.6367 |
2017 | 92.7680 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 | 94.5598 |
2019 | 96.3623 |
2020 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 95.2929 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Products Liability — Occurrence | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 87.6369 |
2009 | 89.7198 |
2010 | 91.6030 |
2011 | 92.4224 |
2012 | 92.8704 |
2013 | 90.4185 |
2014 | 91.0511 |
2015 | 94.0066 |
2016 | 94.2757 |
2017 | 96.1335 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 95.9730 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Reinsurance — Nonproportional Assumed Property | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 91.0976 |
2009 | 92.7443 |
2010 | 95.6984 |
2011 | 80.1417 |
2012 | 89.8643 |
2013 | 81.5378 |
2014 | 51.4095 |
2015 | 92.8399 |
2016 | 73.3181 |
2017 | 88.1043 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 | 89.8547 |
2019 | 91.6751 |
2020 | 93.5877 |
2021 | 95.6459 |
2022 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 90.7540 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Reinsurance — Nonproportional Assumed Liability | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 86.7636 |
2009 | 90.0422 |
2010 | 91.4998 |
2011 | 88.6312 |
2012 | 90.7036 |
2013 | 91.5709 |
2014 | 91.4636 |
2015 | 93.2257 |
2016 | 95.1632 |
2017 | 96.9140 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 94.8390 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Reinsurance — Nonproportional Assumed Financial Lines | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 87.1652 |
2009 | 85.9016 |
2010 | 89.9069 |
2011 | 78.5011 |
2012 | 90.2511 |
2013 | 80.2802 |
2014 | 90.4154 |
2015 | 90.8197 |
2016 | 97.5152 |
2017 | 98.0298 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary and Theft) | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 94.8844 |
2009 | 96.1174 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2010 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 98.0298 percent to discount salvage recoverable as of the end of the 2010 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
Workers’ Compensation | |
---|---|
Tax Year | Discount Factors (%) |
2008 | 88.3785 |
2009 | 90.4189 |
2010 | 91.2195 |
2011 | 91.1364 |
2012 | 89.6372 |
2013 | 88.2223 |
2014 | 88.8169 |
2015 | 88.5309 |
2016 | 90.7105 |
2017 | 92.4766 |
Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2008 accident year. | |
2018 | 94.2879 |
2019 | 96.1430 |
2020 and later years | 98.0298 |
Taxpayers that use the composite method of Notice 88-100 should use 95.7028 percent to discount salvage recoverable as of the end of the 2018 taxable year with respect to losses incurred in this line of business in 2008 and prior years. |
This document provides notice of public hearing on proposed regulations (REG-155087-05, 2008-38 I.R.B. 726) relating to credits and payments for alcohol mixtures, biodiesel mixtures, renewable diesel mixtures, alternative fuel mixtures, and alternative fuel sold for use or used as a fuel, as well as proposed regulations relating to the definition of gasoline and diesel fuel.
The public hearing is being held on Monday, February 9, 2009, at 10:00 a.m. The IRS must receive outlines of the topics to be discussed at the public hearing by Friday, January 9, 2009.
The public hearing is being held in the IRS Auditorium, Internal Revenue Service Building, 1111 Constitution Avenue, NW, Washington, DC 20224.
Send Submissions to CC:PA:LPD:PR (REG-155087-05), room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday to CC:PA:LPD:PR (REG-155087-05), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC, or sent electronically via the Federal eRulemaking Portal at www.regulations.gov (IRS-REG-155087-05).
Concerning the regulations, Taylor Cortright (202) 622-3130; concerning submissions of comments, the hearing and/or to be placed on the building access list to attend the hearing Funmi Taylor at (202) 622-7180 (not toll-free numbers).
The subject of the public hearing is the notice of proposed rulemaking (REG-155087-05) that was published in the Federal Register on Tuesday, July 29, 2008 (73 FR 43890).
The rules of 26 CFR 601.601(a)(3) apply to the hearing. Persons who wish to present oral comments at the hearing that submitted written comments by October 27, 2008, must submit an outline of the topics to be addressed and the amount of time to be denoted to each topic (signed original and eight (8) copies)
A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made available, free of charge, at the hearing or in the Freedom of Information Reading Room (FOIA RR) (Room 1621) which is located at the 11th and Pennsylvania Avenue, NW, entrance, 1111 Constitution Avenue, NW, Washington, DC.
Because of access restrictions, the IRS will not admit visitors beyond the immediate entrance area more than 30 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the “FOR FURTHER INFORMATION CONTACT” section of this document.
LaNita Van Dyke,Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions involving attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. These individuals are subject to the regulations governing practice before the Internal Revenue Service (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 imposed 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. Unlike 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 sanction 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, certified public accountants, enrolled agents, enrolled actuaries, and enrolled retirement plan agents may not assist, or accept assistance from, individuals who are suspended or disbarred with respect to matters constituting practice (i.e., representation) before the IRS, and they may not aid or abet suspended 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 hearing, and Disqualified after hearing—An administrative law judge (ALJ) conducted an evidentiary hearing upon OPR’s complaint 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, Suspended by default decision, Censured by default decision, Monetary penalty imposed by default decision, and Disqualified by default decision—An ALJ, after finding that no answer to OPR’s complaint had been filed, granted OPR’s motion for a default judgment and issued a decision imposing one of these sanctions.
Disbarment by decision on appeal, Suspended by decision on appeal, Censured by decision on appeal, Monetary penalty imposed by decision on appeal, 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, Monetary penalty imposed by consent, and Disqualified by consent—In lieu of a disciplinary proceeding being instituted or continued, an individual offered a consent 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 suspension; and the individual’s opportunity, after a stated number of months, to file with OPR a petition for reinstatement affirming 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 decision in expedited proceeding, Suspended by consent in expedited proceeding—OPR instituted an expedited proceeding for suspension (based on certain limited grounds, including loss of a professional license and criminal convictions).
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 the effective date of amendments to the regulations that permit making such decisions 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 individual’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 sanctions appear in the Internal Revenue Bulletin at the earliest practicable date. The sanctions announced below are alphabetized first by the names of states and second by the last names of individuals. Unless otherwise indicated, section numbers (e.g., § 10.51) refer to the regulations.
City and State | Name | Professional Designation | Disciplinary Sanction | Effective Date(s) |
---|---|---|---|---|
California | ||||
San Francisco | Portugal Leon, Jorge E. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from August 8, 2008 |
District of Columbia | ||||
Washington, DC | Roberson, Jr., James O. | Attorney | Suspended by decision in expedited proceeding under § 10.82 (suspension of attorney license in New Jersey) | Indefinite from October 22, 2008 |
Illinois | ||||
Dekalb | Erwin, Scott R. | Attorney | Suspended by decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from October 28, 2008 |
Maryland | ||||
Silver Spring | Alexander, Jr., David | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (attorney disbarment) | Indefinite from October 22, 2008 |
Port Tobacco | Thomas, Robert L. | Enrolled Agent | Suspended by decision in expedited proceeding under § 10.82 (conviction under state law, conspiracy to commit bribery) | Indefinite from October 22, 2008 |
Pikesville | Weinrauch, Aaron D. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (attorney disbarment) | Indefinite from November 4, 2008 |
Accoceek | Wilbon, Bernadette M. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from November 4, 2008 |
Massachusetts | ||||
Springfield | Pellegrino, Matthew A. | Attorney | Suspended by decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from October 22, 2008 |
Missouri | ||||
Florissant | Alderfer, Jr., William K. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from November 4, 2008 |
Ballwin | Dickhaus, Karl W. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from November 4, 2008 |
Nebraska | ||||
Omaha | Switzer, Jr., William L. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (suspension of attorney license) | Indefinite from November 4, 2008 |
New Jersey | ||||
Roberson, Jr., James O., See District of Columbia | ||||
New York | ||||
Buffalo | Brewer, Byron V. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (conviction under 26 U.S.C. § 7203, willful failure to file tax return) | Indefinite from October 22, 2008 |
North Carolina | ||||
Oakboro | Harward, Pete A. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from November 4, 2008 |
Mooreseville | Moffett, Donna M. | CPA | Suspended by decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from November 4, 2008 |
Ohio | ||||
Columbus | Beerman, Jeffrey A. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Lancaster | Boyer, Ronald L. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Cincinnati | Buettner, F. Allen | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Lessburg | Hoskins, Jeffrey J. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (attorney disbarment) | Indefinite from October 28, 2008 |
Mansfield | Schrack, II, James | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Norton | Stamp, James A. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Pennsylvania | ||||
Swoyersville | Capwell, Anthony C. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (suspension of CPA license) | Indefinite from October 28, 2008 |
Tennessee | ||||
Brentwood | Leckrone, James D. | Attorney | Suspended by default decision in expedited proceeding under § 10.82 (conviction under 26 U.S.C. § 7201, filing a false income tax return) | Indefinite from October 28, 2008 |
Wyoming | ||||
Douglas | Gottlob, John C. | CPA | Suspended by default decision in expedited proceeding under § 10.82 (revocation of CPA license) | Indefinite from October 28, 2008 |
Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).
Clarified is used in those instances where the language in a prior ruling is being 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.
Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.
Modified is 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 with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings 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.
Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.
Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes 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 published ruling is first modified and then, as modified, is superseded.
Supplemented is 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 ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.
Suspended is 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.
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 effect:
The following abbreviations in current use and formerly used will appear in material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
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—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D. —Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z —Corporation.
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2008-1 through 2008-26 is in Internal Revenue Bulletin 2008-26, dated June 30, 2008.
Bulletins 2008-27 through 2008-49
Announcements
Article | Issue | Link | Page |
---|---|---|---|
2008-62 | 2008-27 I.R.B. | 2008-27 | 74 |
2008-63 | 2008-28 I.R.B. | 2008-28 | 114 |
2008-64 | 2008-28 I.R.B. | 2008-28 | 114 |
2008-65 | 2008-31 I.R.B. | 2008-31 | 279 |
2008-66 | 2008-29 I.R.B. | 2008-29 | 164 |
2008-67 | 2008-29 I.R.B. | 2008-29 | 164 |
2008-68 | 2008-30 I.R.B. | 2008-30 | 244 |
2008-69 | 2008-32 I.R.B. | 2008-32 | 318 |
2008-70 | 2008-32 I.R.B. | 2008-32 | 318 |
2008-71 | 2008-32 I.R.B. | 2008-32 | 321 |
2008-72 | 2008-32 I.R.B. | 2008-32 | 321 |
2008-73 | 2008-33 I.R.B. | 2008-33 | 391 |
2008-74 | 2008-33 I.R.B. | 2008-33 | 392 |
2008-75 | 2008-33 I.R.B. | 2008-33 | 392 |
2008-76 | 2008-33 I.R.B. | 2008-33 | 393 |
2008-77 | 2008-33 I.R.B. | 2008-33 | 394 |
2008-78 | 2008-34 I.R.B. | 2008-34 | 453 |
2008-79 | 2008-35 I.R.B. | 2008-35 | 568 |
2008-80 | 2008-37 I.R.B. | 2008-37 | 706 |
2008-81 | 2008-37 I.R.B. | 2008-37 | 706 |
2008-82 | 2008-37 I.R.B. | 2008-37 | 708 |
2008-83 | 2008-37 I.R.B. | 2008-37 | 709 |
2008-84 | 2008-38 I.R.B. | 2008-38 | 748 |
2008-85 | 2008-38 I.R.B. | 2008-38 | 749 |
2008-86 | 2008-40 I.R.B. | 2008-40 | 843 |
2008-87 | 2008-40 I.R.B. | 2008-40 | 843 |
2008-88 | 2008-40 I.R.B. | 2008-40 | 843 |
2008-89 | 2008-40 I.R.B. | 2008-40 | 844 |
2008-90 | 2008-41 I.R.B. | 2008-41 | 896 |
2008-91 | 2008-42 I.R.B. | 2008-42 | 963 |
2008-92 | 2008-42 I.R.B. | 2008-42 | 963 |
2008-93 | 2008-41 I.R.B. | 2008-41 | 896 |
2008-94 | 2008-42 I.R.B. | 2008-42 | 964 |
2008-95 | 2008-42 I.R.B. | 2008-42 | 964 |
2008-96 | 2008-43 I.R.B. | 2008-43 | 1010 |
2008-97 | 2008-43 I.R.B. | 2008-43 | 1010 |
2008-98 | 2008-44 I.R.B. | 2008-44 | 1087 |
2008-99 | 2008-44 I.R.B. | 2008-44 | 1089 |
2008-100 | 2008-44 I.R.B. | 2008-44 | 1090 |
2008-101 | 2008-44 I.R.B. | 2008-44 | 1090 |
2008-102 | 2008-43 I.R.B. | 2008-43 | 1011 |
2008-103 | 2008-46 I.R.B. | 2008-46 | 1161 |
2008-104 | 2008-45 I.R.B. | 2008-45 | 1136 |
2008-105 | 2008-48 I.R.B. | 2008-48 | 1219 |
2008-106 | 2008-45 I.R.B. | 2008-45 | 1137 |
2008-107 | 2008-46 I.R.B. | 2008-46 | 1162 |
2008-108 | 2008-46 I.R.B. | 2008-46 | 1165 |
2008-109 | 2008-46 I.R.B. | 2008-46 | 1166 |
2008-110 | 2008-48 I.R.B. | 2008-48 | 1224 |
2008-111 | 2008-48 I.R.B. | 2008-48 | 1224 |
2008-112 | 2008-47 I.R.B. | 2008-47 | 1199 |
2008-113 | 2008-47 I.R.B. | 2008-47 | 1199 |
2008-114 | 2008-48 I.R.B. | 2008-48 | 1226 |
2008-115 | 2008-48 I.R.B. | 2008-48 | 1228 |
2008-116 | 2008-48 I.R.B. | 2008-48 | 1230 |
2008-117 | 2008-49 I.R.B. | 2008-49 | |
2008-118 | 2008-49 I.R.B. | 2008-49 |
Notices
Article | Issue | Link | Page |
---|---|---|---|
2008-55 | 2008-27 I.R.B. | 2008-27 | 11 |
2008-56 | 2008-28 I.R.B. | 2008-28 | 79 |
2008-57 | 2008-28 I.R.B. | 2008-28 | 80 |
2008-58 | 2008-28 I.R.B. | 2008-28 | 81 |
2008-59 | 2008-29 I.R.B. | 2008-29 | 123 |
2008-60 | 2008-30 I.R.B. | 2008-30 | 178 |
2008-61 | 2008-30 I.R.B. | 2008-30 | 180 |
2008-62 | 2008-29 I.R.B. | 2008-29 | 130 |
2008-63 | 2008-31 I.R.B. | 2008-31 | 261 |
2008-64 | 2008-31 I.R.B. | 2008-31 | 268 |
2008-65 | 2008-30 I.R.B. | 2008-30 | 182 |
2008-66 | 2008-31 I.R.B. | 2008-31 | 270 |
2008-67 | 2008-32 I.R.B. | 2008-32 | 307 |
2008-68 | 2008-34 I.R.B. | 2008-34 | 418 |
2008-69 | 2008-34 I.R.B. | 2008-34 | 419 |
2008-70 | 2008-36 I.R.B. | 2008-36 | 575 |
2008-71 | 2008-35 I.R.B. | 2008-35 | 462 |
2008-72 | 2008-43 I.R.B. | 2008-43 | 998 |
2008-73 | 2008-38 I.R.B. | 2008-38 | 717 |
2008-74 | 2008-38 I.R.B. | 2008-38 | 718 |
2008-75 | 2008-38 I.R.B. | 2008-38 | 719 |
2008-76 | 2008-39 I.R.B. | 2008-39 | 768 |
2008-77 | 2008-40 I.R.B. | 2008-40 | 814 |
2008-78 | 2008-41 I.R.B. | 2008-41 | 851 |
2008-79 | 2008-40 I.R.B. | 2008-40 | 815 |
2008-80 | 2008-40 I.R.B. | 2008-40 | 820 |
2008-81 | 2008-41 I.R.B. | 2008-41 | 852 |
2008-82 | 2008-41 I.R.B. | 2008-41 | 853 |
2008-83 | 2008-42 I.R.B. | 2008-42 | 905 |
2008-84 | 2008-41 I.R.B. | 2008-41 | 855 |
2008-85 | 2008-42 I.R.B. | 2008-42 | 905 |
2008-86 | 2008-42 I.R.B. | 2008-42 | 925 |
2008-87 | 2008-42 I.R.B. | 2008-42 | 930 |
2008-88 | 2008-42 I.R.B. | 2008-42 | 933 |
2008-89 | 2008-43 I.R.B. | 2008-43 | 999 |
2008-90 | 2008-43 I.R.B. | 2008-43 | 1000 |
2008-91 | 2008-43 I.R.B. | 2008-43 | 1001 |
2008-92 | 2008-43 I.R.B. | 2008-43 | 1001 |
2008-93 | 2008-43 I.R.B. | 2008-43 | 1002 |
2008-94 | 2008-44 I.R.B. | 2008-44 | 1070 |
2008-95 | 2008-44 I.R.B. | 2008-44 | 1076 |
2008-96 | 2008-44 I.R.B. | 2008-44 | 1077 |
2008-97 | 2008-44 I.R.B. | 2008-44 | 1080 |
2008-98 | 2008-44 I.R.B. | 2008-44 | 1080 |
2008-99 | 2008-47 I.R.B. | 2008-47 | 1194 |
2008-100 | 2008-44 I.R.B. | 2008-44 | 1081 |
2008-101 | 2008-44 I.R.B. | 2008-44 | 1082 |
2008-102 | 2008-45 I.R.B. | 2008-45 | 1106 |
2008-103 | 2008-46 I.R.B. | 2008-46 | 1156 |
2008-105 | 2008-48 I.R.B. | 2008-48 | 1208 |
2008-106 | 2008-49 I.R.B. | 2008-49 |
Proposed Regulations
Article | Issue | Link | Page |
---|---|---|---|
209006-89 | 2008-41 I.R.B. | 2008-41 | 867 |
157711-02 | 2008-44 I.R.B. | 2008-44 | 1087 |
143544-04 | 2008-42 I.R.B. | 2008-42 | 947 |
160868-04 | 2008-45 I.R.B. | 2008-45 | 1115 |
161695-04 | 2008-37 I.R.B. | 2008-37 | 699 |
164965-04 | 2008-34 I.R.B. | 2008-34 | 450 |
142339-05 | 2008-45 I.R.B. | 2008-45 | 1116 |
143453-05 | 2008-32 I.R.B. | 2008-32 | 310 |
146895-05 | 2008-37 I.R.B. | 2008-37 | 700 |
155087-05 | 2008-38 I.R.B. | 2008-38 | 726 |
164370-05 | 2008-46 I.R.B. | 2008-46 | 1157 |
142680-06 | 2008-35 I.R.B. | 2008-35 | 565 |
156779-06 | 2008-46 I.R.B. | 2008-46 | 1160 |
120476-07 | 2008-36 I.R.B. | 2008-36 | 679 |
120844-07 | 2008-39 I.R.B. | 2008-39 | 770 |
128841-07 | 2008-45 I.R.B. | 2008-45 | 1124 |
129243-07 | 2008-27 I.R.B. | 2008-27 | 32 |
138355-07 | 2008-32 I.R.B. | 2008-32 | 311 |
140029-07 | 2008-40 I.R.B. | 2008-40 | 828 |
142040-07 | 2008-34 I.R.B. | 2008-34 | 451 |
142333-07 | 2008-43 I.R.B. | 2008-43 | 1008 |
149404-07 | 2008-40 I.R.B. | 2008-40 | 839 |
149405-07 | 2008-27 I.R.B. | 2008-27 | 73 |
100464-08 | 2008-32 I.R.B. | 2008-32 | 313 |
101258-08 | 2008-28 I.R.B. | 2008-28 | 111 |
102122-08 | 2008-31 I.R.B. | 2008-31 | 278 |
102822-08 | 2008-38 I.R.B. | 2008-38 | 744 |
103146-08 | 2008-37 I.R.B. | 2008-37 | 701 |
106251-08 | 2008-39 I.R.B. | 2008-39 | 774 |
107318-08 | 2008-45 I.R.B. | 2008-45 | 1131 |
115457-08 | 2008-33 I.R.B. | 2008-33 | 390 |
118327-08 | 2008-48 I.R.B. | 2008-48 | 1218 |
121698-08 | 2008-29 I.R.B. | 2008-29 | 163 |
Revenue Procedures
Article | Issue | Link | Page |
---|---|---|---|
2008-32 | 2008-28 I.R.B. | 2008-28 | 82 |
2008-33 | 2008-28 I.R.B. | 2008-28 | 93 |
2008-34 | 2008-27 I.R.B. | 2008-27 | 13 |
2008-35 | 2008-29 I.R.B. | 2008-29 | 132 |
2008-36 | 2008-33 I.R.B. | 2008-33 | 340 |
2008-37 | 2008-29 I.R.B. | 2008-29 | 137 |
2008-38 | 2008-29 I.R.B. | 2008-29 | 139 |
2008-39 | 2008-29 I.R.B. | 2008-29 | 143 |
2008-40 | 2008-29 I.R.B. | 2008-29 | 151 |
2008-41 | 2008-29 I.R.B. | 2008-29 | 155 |
2008-42 | 2008-29 I.R.B. | 2008-29 | 160 |
2008-43 | 2008-30 I.R.B. | 2008-30 | 186 |
2008-44 | 2008-30 I.R.B. | 2008-30 | 187 |
2008-45 | 2008-30 I.R.B. | 2008-30 | 224 |
2008-46 | 2008-30 I.R.B. | 2008-30 | 238 |
2008-47 | 2008-31 I.R.B. | 2008-31 | 272 |
2008-48 | 2008-36 I.R.B. | 2008-36 | 586 |
2008-49 | 2008-34 I.R.B. | 2008-34 | 423 |
2008-50 | 2008-35 I.R.B. | 2008-35 | 464 |
2008-51 | 2008-35 I.R.B. | 2008-35 | 562 |
2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2008-53 | 2008-36 I.R.B. | 2008-36 | 678 |
2008-54 | 2008-38 I.R.B. | 2008-38 | 722 |
2008-55 | 2008-39 I.R.B. | 2008-39 | 768 |
2008-56 | 2008-40 I.R.B. | 2008-40 | 826 |
2008-57 | 2008-41 I.R.B. | 2008-41 | 855 |
2008-58 | 2008-41 I.R.B. | 2008-41 | 856 |
2008-59 | 2008-41 I.R.B. | 2008-41 | 857 |
2008-60 | 2008-43 I.R.B. | 2008-43 | 1006 |
2008-61 | 2008-42 I.R.B. | 2008-42 | 934 |
2008-62 | 2008-42 I.R.B. | 2008-42 | 935 |
2008-63 | 2008-42 I.R.B. | 2008-42 | 946 |
2008-64 | 2008-47 I.R.B. | 2008-47 | 1195 |
2008-65 | 2008-44 I.R.B. | 2008-44 | 1082 |
2008-66 | 2008-45 I.R.B. | 2008-45 | 1107 |
2008-67 | 2008-48 I.R.B. | 2008-48 | 1211 |
2008-69 | 2008-48 I.R.B. | 2008-48 | 1217 |
2008-70 | 2008-49 I.R.B. | 2008-49 | |
2008-71 | 2008-49 I.R.B. | 2008-49 |
Revenue Rulings
Article | Issue | Link | Page |
---|---|---|---|
2008-32 | 2008-27 I.R.B. | 2008-27 | 6 |
2008-33 | 2008-27 I.R.B. | 2008-27 | 8 |
2008-34 | 2008-28 I.R.B. | 2008-28 | 76 |
2008-35 | 2008-29 I.R.B. | 2008-29 | 116 |
2008-36 | 2008-30 I.R.B. | 2008-30 | 165 |
2008-37 | 2008-28 I.R.B. | 2008-28 | 77 |
2008-38 | 2008-31 I.R.B. | 2008-31 | 249 |
2008-39 | 2008-31 I.R.B. | 2008-31 | 252 |
2008-40 | 2008-30 I.R.B. | 2008-30 | 166 |
2008-41 | 2008-30 I.R.B. | 2008-30 | 170 |
2008-42 | 2008-30 I.R.B. | 2008-30 | 175 |
2008-43 | 2008-31 I.R.B. | 2008-31 | 258 |
2008-44 | 2008-32 I.R.B. | 2008-32 | 292 |
2008-45 | 2008-34 I.R.B. | 2008-34 | 403 |
2008-46 | 2008-36 I.R.B. | 2008-36 | 572 |
2008-47 | 2008-39 I.R.B. | 2008-39 | 760 |
2008-48 | 2008-38 I.R.B. | 2008-38 | 713 |
2008-49 | 2008-40 I.R.B. | 2008-40 | 811 |
2008-50 | 2008-45 I.R.B. | 2008-45 | 1098 |
2008-51 | 2008-47 I.R.B. | 2008-47 | 1171 |
2008-52 | 2008-49 I.R.B. | 2008-49 | |
2008-53 | 2008-49 I.R.B. | 2008-49 |
Social Security Contribution and Benefit Base; Domestic Employee Coverage Threshold
Article | Issue | Link | Page |
---|---|---|---|
2008-103 | 2008-46 I.R.B. | 2008-46 | 1156 |
Treasury Decisions
Article | Issue | Link | Page |
---|---|---|---|
9401 | 2008-27 I.R.B. | 2008-27 | 1 |
9402 | 2008-31 I.R.B. | 2008-31 | 254 |
9403 | 2008-32 I.R.B. | 2008-32 | 285 |
9404 | 2008-32 I.R.B. | 2008-32 | 280 |
9405 | 2008-32 I.R.B. | 2008-32 | 293 |
9406 | 2008-32 I.R.B. | 2008-32 | 287 |
9407 | 2008-33 I.R.B. | 2008-33 | 330 |
9408 | 2008-33 I.R.B. | 2008-33 | 323 |
9409 | 2008-29 I.R.B. | 2008-29 | 118 |
9410 | 2008-34 I.R.B. | 2008-34 | 414 |
9411 | 2008-34 I.R.B. | 2008-34 | 398 |
9412 | 2008-37 I.R.B. | 2008-37 | 687 |
9413 | 2008-34 I.R.B. | 2008-34 | 404 |
9414 | 2008-35 I.R.B. | 2008-35 | 454 |
9415 | 2008-36 I.R.B. | 2008-36 | 570 |
9416 | 2008-46 I.R.B. | 2008-46 | 1142 |
9417 | 2008-37 I.R.B. | 2008-37 | 693 |
9418 | 2008-38 I.R.B. | 2008-38 | 713 |
9419 | 2008-40 I.R.B. | 2008-40 | 790 |
9420 | 2008-39 I.R.B. | 2008-39 | 750 |
9421 | 2008-39 I.R.B. | 2008-39 | 755 |
9422 | 2008-42 I.R.B. | 2008-42 | 898 |
9423 | 2008-43 I.R.B. | 2008-43 | 966 |
9424 | 2008-44 I.R.B. | 2008-44 | 1012 |
9425 | 2008-45 I.R.B. | 2008-45 | 1100 |
9426 | 2008-46 I.R.B. | 2008-46 | 1153 |
9427 | 2008-47 I.R.B. | 2008-47 | 1179 |
9428 | 2008-47 I.R.B. | 2008-47 | 1174 |
9429 | 2008-47 I.R.B. | 2008-47 | 1167 |
9430 | 2008-48 I.R.B. | 2008-48 | 1205 |
9431 | 2008-49 I.R.B. | 2008-49 | |
9432 | 2008-49 I.R.B. | 2008-49 |
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2008-1 through 2008-26 is in Internal Revenue Bulletin 2008-26, dated June 30, 2008.
Bulletins 2008-27 through 2008-49
Notices
Old Article | Action | New Article | Issue | Link | Page |
---|---|---|---|---|---|
88-80 | Modified by | Notice 2008-79 | 2008-40 I.R.B. | 2008-40 | 815 |
99-48 | Superseded by | Rev. Proc. 2008-40 | 2008-29 I.R.B. | 2008-29 | 151 |
2000-9 | Obsoleted by | Rev. Proc. 2008-41 | 2008-29 I.R.B. | 2008-29 | 155 |
2004-2 | Amplified by | Notice 2008-59 | 2008-29 I.R.B. | 2008-29 | 123 |
2004-50 | Amplified by | Notice 2008-59 | 2008-29 I.R.B. | 2008-29 | 123 |
2005-11 | Superseded by | T.D. 9425 | 2008-45 I.R.B. | 2008-45 | 1100 |
2005-91 | Obsoleted by | T.D. 9422 | 2008-42 I.R.B. | 2008-42 | 898 |
2006-88 | Modified and superseded by | Notice 2008-60 | 2008-30 I.R.B. | 2008-30 | 178 |
2007-22 | Amplified by | Notice 2008-59 | 2008-29 I.R.B. | 2008-29 | 123 |
2007-36 | Clarified, modified, and amplified by | Rev. Proc. 2008-54 | 2008-38 I.R.B. | 2008-38 | 722 |
2007-52 | Updated and amplified by | Notice 2008-96 | 2008-44 I.R.B. | 2008-44 | 1077 |
2007-53 | Updated by | Notice 2008-97 | 2008-44 I.R.B. | 2008-44 | 1080 |
2008-41 | Amended and supplemented by | Notice 2008-88 | 2008-42 I.R.B. | 2008-42 | 933 |
Proposed Regulations
Old Article | Action | New Article | Issue | Link | Page |
---|---|---|---|---|---|
161695-04 | Corrected by | Ann. 2008-92 | 2008-42 I.R.B. | 2008-42 | 963 |
143453-05 | Hearing cancelled by | Ann. 2008-96 | 2008-43 I.R.B. | 2008-43 | 1010 |
155087-05 | Hearing scheduled by | Ann. 2008-117 | 2008-49 I.R.B. | 2008-49 | |
129243-07 | Corrected by | Ann. 2008-75 | 2008-33 I.R.B. | 2008-33 | 392 |
151135-07 | Hearing scheduled by | Ann. 2008-64 | 2008-28 I.R.B. | 2008-28 | 114 |
101258-08 | Corrected by | Ann. 2008-73 | 2008-33 I.R.B. | 2008-33 | 391 |
102822-08 | Hearing cancelled by | Ann. 2008-116 | 2008-48 I.R.B. | 2008-48 | 1230 |
103146-08 | Hearing scheduled by | Ann. 2008-102 | 2008-43 I.R.B. | 2008-43 | 1011 |
115457-08 | Hearing scheduled by | Ann. 2008-108 | 2008-46 I.R.B. | 2008-46 | 1165 |
Revenue Procedures
Old Article | Action | New Article | Issue | Link | Page |
---|---|---|---|---|---|
92-25 | Superseded by | Rev. Proc. 2008-41 | 2008-29 I.R.B. | 2008-29 | 155 |
92-83 | Obsoleted by | Rev. Proc. 2008-37 | 2008-29 I.R.B. | 2008-29 | 137 |
2001-10 | Section 6.02(1)(a) modified and amplified by | Rev. Proc. 2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2001-42 | Superseded by | Rev. Proc. 2008-39 | 2008-29 I.R.B. | 2008-29 | 143 |
2002-9 | Clarified, modified, amplified, and superseded by | Rev. Proc. 2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2002-9 | Modified and amplified by | Rev. Proc. 2008-43 | 2008-30 I.R.B. | 2008-30 | 186 |
2002-28 | Section 7.02(1)(a) modified and amplified by | Rev. Proc. 2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2002-44 | Modified by | Ann. 2008-111 | 2008-48 I.R.B. | 2008-48 | 1224 |
2002-64 | Superseded by | Rev. Proc. 2008-55 | 2008-39 I.R.B. | 2008-39 | 768 |
2004-44 | Superseded by | Rev. Proc. 2008-67 | 2008-48 I.R.B. | 2008-48 | 1211 |
2005-29 | Superseded by | Rev. Proc. 2008-49 | 2008-34 I.R.B. | 2008-34 | 423 |
2006-27 | Modified and superseded by | Rev. Proc. 2008-50 | 2008-35 I.R.B. | 2008-35 | 464 |
2006-29 | Superseded by | Rev. Proc. 2008-34 | 2008-27 I.R.B. | 2008-27 | 13 |
2006-34 | Superseded by | Rev. Proc. 2008-44 | 2008-30 I.R.B. | 2008-30 | 187 |
2006-44 | Modified by | Ann. 2008-111 | 2008-48 I.R.B. | 2008-48 | 1224 |
2007-9 | Modified by | Rev. Proc. 2008-70 | 2008-49 I.R.B. | 2008-49 | |
2007-14 | Superseded by | Rev. Proc. 2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2007-19 | Superseded by | Rev. Proc. 2008-39 | 2008-29 I.R.B. | 2008-29 | 143 |
2007-37 | Updated by | Rev. Proc. 2008-62 | 2008-42 I.R.B. | 2008-42 | 935 |
2007-42 | Superseded by | Rev. Proc. 2008-32 | 2008-28 I.R.B. | 2008-28 | 82 |
2007-43 | Superseded by | Rev. Proc. 2008-33 | 2008-28 I.R.B. | 2008-28 | 93 |
2007-44 | Modified by | Rev. Proc. 2008-56 | 2008-40 I.R.B. | 2008-40 | 826 |
2007-49 | Section 3 modified and superseded by | Rev. Proc. 2008-50 | 2008-35 I.R.B. | 2008-35 | 464 |
2007-50 | Superseded by | Rev. Proc. 2008-36 | 2008-33 I.R.B. | 2008-33 | 340 |
2007-63 | Superseded by | Rev. Proc. 2008-59 | 2008-41 I.R.B. | 2008-41 | 857 |
2007-66 | Modified and superseded by | Rev. Proc. 2008-54 | 2008-38 I.R.B. | 2008-38 | 722 |
2007-70 | Modified by | Ann. 2008-63 | 2008-28 I.R.B. | 2008-28 | 114 |
2007-72 | Amplified and superseded by | Rev. Proc. 2008-47 | 2008-31 I.R.B. | 2008-31 | 272 |
2008-3 | Modified and amplified by | Rev. Proc. 2008-61 | 2008-42 I.R.B. | 2008-42 | 934 |
2008-4 | Modified by | Rev. Proc. 2008-67 | 2008-48 I.R.B. | 2008-48 | 1211 |
2008-10 | Modified by | Rev. Proc. 2008-70 | 2008-49 I.R.B. | 2008-49 | |
2008-12 | Modified and superseded by | Rev. Proc. 2008-35 | 2008-29 I.R.B. | 2008-29 | 132 |
2008-43 | Modified by | Rev. Proc. 2008-52 | 2008-36 I.R.B. | 2008-36 | 587 |
2008-52 | Modified by | Ann. 2008-84 | 2008-38 I.R.B. | 2008-38 | 748 |
Revenue Rulings
Old Article | Action | New Article | Issue | Link | Page |
---|---|---|---|---|---|
67-213 | Amplified by | Rev. Rul. 2008-40 | 2008-30 I.R.B. | 2008-30 | 166 |
71-234 | Modified by | Rev. Proc. 2008-43 | 2008-30 I.R.B. | 2008-30 | 186 |
76-273 | Obsoleted by | T.D. 9414 | 2008-35 I.R.B. | 2008-35 | 454 |
77-480 | Modified by | Rev. Proc. 2008-43 | 2008-30 I.R.B. | 2008-30 | 186 |
82-105 | Obsoleted by | T.D. 9414 | 2008-35 I.R.B. | 2008-35 | 454 |
91-17 | Amplified by | Rev. Proc. 2008-41 | 2008-29 I.R.B. | 2008-29 | 155 |
91-17 | Amplified by | Rev. Proc. 2008-42 | 2008-29 I.R.B. | 2008-29 | 160 |
91-17 | Superseded in part by | Rev. Proc. 2008-40 | 2008-29 I.R.B. | 2008-29 | 151 |
2005-6 | Amplified by | Rev. Proc. 2008-38 | 2008-29 I.R.B. | 2008-29 | 139 |
2006-57 | Modified by | Notice 2008-74 | 2008-38 I.R.B. | 2008-38 | 718 |
2008-3 | Supplemented and superseded by | Rev. Rul. 2008-52 | 2008-49 I.R.B. | 2008-49 | |
2008-12 | Amplified by | Rev. Rul. 2008-38 | 2008-31 I.R.B. | 2008-31 | 249 |
2008-12 | Clarified by | Ann. 2008-65 | 2008-31 I.R.B. | 2008-31 | 279 |
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