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SUMMARY: Contains final and temporary regulations that provide guidance relating to foreign base company sales income in cases in which personal property sold by a controlled foreign corporation is manufactured, produced, or constructed pursuant to a contract manufacturing arrangement or by one or more branches of the controlled foreign corporation.

SUMMARY: The temporary regulations generally allow certain employers to file a Form 944, Employer’s ANNUAL Federal Tax Return, rather than Form 941, Employer’s QUARTERLY Federal Tax Return. The temporary regulations provide an additional method for employers who file Form 941 to determine whether the amount of accumulated employment taxes is considered de minimis.

SUMMARY: The Tax Court held that it has jurisdiction to review whether or not an assessment was properly made even though that issue was not raised by the taxpayer during the course of the CDP hearing because IRC 6330(c)(1) requires that the IRS ascertain whether an assessment was properly made even if the taxpayer does not raise the issue in the course of a collection due process hearing.

 SUMMARY: Held that individual partner defenses to assertion of a penalty against the partnership can only be challenged by a partner in a refund action. In a TEFRA proceeding, the Tax Court has jurisdiction over partnership defenses to asserted penalties but does not have jurisdiction over individual partner defenses. IRC section 6221 and the temporary regulations thereto state that the partners’ only means of raising individual partner defenses to assertion of a partnership penalty is through a refund action.

SUMMARY: Revenue Procedure 2009-10 provides a safe harbor under which the Service will not challenge the treatment of a Payment or Excess Amount received by a money market fund from a fund advisor before January 1, 2010, provided that the money market fund treats the Payment or Excess Amount, as applicable, as short-term capital gain in the taxable year in which it is received.

SUMMARY: Begining Jan 1, 2008 the IRS interest rates will be: Five (5) percent for overpayments (four (4) percent in the case of a corporation; Five (5) percent for underpayments; Seven (7) percent for large corporate underpayments; and two and one-half (2.5) percent for the portion of a corporate overpayment exceeding $10,000