SECTION 3. SCOPE — Internal Revenue Bulletin 2007-3

The following categories of services are eligible for treatment as specified cov

ered services under Temp. Treas. Reg. § 1.482–9T(b)(4)(i):

Payroll:

Compiling and posting employee time and other information needed to calculate periodic compensation to employees. Computing employees’ time worked, production, and commissions. Computing and posting wages and deductions to appropriate accounting records. Preparing paychecks, travel reimbursement and expense reimbursement.
Preparing payroll tax forms (such as the preparation of Forms 940, 941 and W–2 in order to comply with U.S. requirements or similar requirements under another country’s laws).
Administering garnishment and other wage withholding orders.
Other activities similar to those specified in paragraphs (1) through (3).

Premiums for Unemployment, Disability and Workers Compensation:

Processing employees’ unemployment insurance premiums, disability premiums and workers compensation premiums.
Other activities similar to those specified in paragraph (5).

Accounts Receivable:

Compiling, analyzing and recording current credit data and other financial information regarding individuals or firms (including preparing reports with this information for use in decisionmaking).
Compiling and recording billing, accounting and other numerical data for billing purposes. Preparing billing invoices for services rendered or for delivery or shipment of goods.

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Gathering information from accounting records and including that information in the preparation of income, property, sales/use, VAT, excise and other tax returns.
Overseeing audits conducted by tax authorities.
Providing tax advice to businesses to ensure compliance with tax laws, including access to electronic research and tax compliance software.
Reviewing local country tax provisions for purposes of inclusion in the consolidated world-wide provision and preparation of the world-wide tax provision.
Negotiating advance pricing agreements and other local incentives that benefit the consolidated organization.
Other activities similar to those specified in paragraphs (38) through (43).

Health, Safety, Environmental and Regulatory Affairs:

Developing company health, safety, and environment standards, monitoring compliance with such standards, and training affected personnel.
Gathering information and preparing documentation relating to eligibility for or compliance with laws and regulations governing contracts, licenses and permits.
Gathering information, verifying data and preparing documentation relating to compliance with laws and regulations governing financial and securities institutions and financial and real estate transactions. Examining and verifying correctness of, or establishing authenticity of records.
Providing security services ( e.g., executive protection or global headquarters security).
Operating any of the following office machines: photocopying, scanning and facsimile machines.
Providing interoffice service/document delivery, including mailroom services, document management, and graphics, video, and website preparation.
Other activities similar to those specified in paragraphs (14) through (19).

Corporate and Public Relations:

Planning and executing a public relations program or corporate communication policy, including the distribution of internal and external corporate communications, but not to include specific advertising and/or marketing of a product or service.
Other activities similar to those specified in paragraph (21).

Meeting Coordination and Travel Planning:

Coordinating activities of staff and convention personnel to make arrangements for group meetings and conventions.
Negotiating airline, rental car, and hotel contracts.
Assisting in travel arrangements, including providing a system for reservations and ticket purchases.
Managing motor pool and fleet.
Other activities similar to those specified in paragraphs (23) through (26).

Accounting and Auditing:

Gathering and reviewing information in accounting records for use in preparing financial statements.
Computing, classifying, and recording numerical data to maintain accurate and complete financial records, performing any combination of calculating, posting, and verifying duties to obtain primary financial data for use in maintaining accounting records, checking the accuracy of figures, calculations, and postings pertaining to business transactions recorded by other workers; and calculating investment performance and net asset values of investments.
Consolidating legal entity financial results per country for use in statutory financial statements and tax returns and consolidating worldwide results by business area for use in management accounting.
Developing a company-wide accounting manual that prescribes accounting policies and methods to be used and providing related advice.
Performing operational and financial internal audits.
Preparing government census and related forms required by a service recipient’s home country.
Preparing reports required by escheat laws required by a service recipient’s home country.
Completing import/export documentation and arranging for customs payment.
Overseeing audits by customs authorities.
Other activities similar to those specified in paragraphs (28) through (36).

Tax:

Processing tax payments according to prescribed laws and regulations.

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Providing information to applicants regarding open positions, the application and recruiting process, and employment policies.
Providing administrative support that includes sourcing and processing resumes, arranging interview schedules for open positions, preparing offer letters, and entering new employee information into the human resource system.
Establishing and maintaining employee files relating to payroll, performance and other personnel issues.
Assisting with new employee orientations and paperwork.
Implementing recruiting plan and locating potential candidates by working with professional search firms, colleges, universities and professional associations. Organizing and attending job fairs and other recruitment events.
Developing recruiting and marketing materials and assisting in developing and maintaining content for recruiting website.
Analyzing recruiting data and review all job analysis, promotion and placement products.
Posting job opening advertisements in appropriate markets through publications, journals and other media.
Managing company-wide job postings and employee referral program.
Administering a compensation policy, including grading and determining salary ranges for positions.
Other activities similar to those specified in paragraphs (62) through (73).
Providing common health risk management systems development, clinical services, industrial hygiene, alcohol and drug testing services (laboratory analyses done by third parties), and advice to business management on health issues.
Providing guidance and support operations, integrity management support implementation, coaching, and conducting operations integrity management assessments, development and implementation of safety behavior based programs, and incident reporting and accident investigations.
Providing strategies, resources, and training for effective crisis preparedness and response.
Other activities similar to those specified in paragraphs (45) through (51).

Budgeting:

Compiling data for use by cost estimators in determining cost projections and in preparing budget estimates, including verifying information for completeness, accuracy, and conformance with internal procedures and regulations.
Compiling data to prepare budget and accounting reports for management.
Other activities similar to those specified in paragraphs (53) and (54).

Treasury Activities:

Establishing bank accounts and lock boxes for use by controlled parties, including overdraft facilities and lines of credit.
Providing staff and facilities to hedge currency exposures that arise from operations in the normal course of business. This paragraph does not apply to banks (including investment banks), insurance companies, investment companies, similar entities that provide financial services to the public, and investment funds (including hedge and private equity funds).
Coordinating investment activities in connection with short-term management of cash generated from operations in the normal course of business. This paragraph does not apply to related-party factoring activities, or to banks (including investment banks), insurance companies, investment companies, similar entities that provide financial services to the public, and investment funds (including hedge and private equity funds).
Other activities that are ancillary to the activities specified in paragraphs (56) through (58).

Statistical Assistance:

Compiling data for use in statistical studies.
Other activities similar to those specified in paragraph (60).

Staffing and Recruiting:

Providing staffing support that includes creating job announcements, determining eligibility, evaluating qualifications of candidates, conducting background checks on final candidates, verifying references, developing performance evaluation procedures and forms, and conducting exit interviews for departed employees.
Coordinating with temporary employment agencies, applicants, and management throughout the recruiting process.

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Supporting an organization’s existing local area network (LAN), wide area network (WAN), and Internet system or a segment of a network system, regular maintenance of network hardware and software, monitoring network to ensure network availability to all system users and performing necessary maintenance to support network availability, supervising other network support and client server specialists (including implementing network security measures), but not to include analyzing user needs or developing hardware or software solutions (such as systems integration, website design, writing computer programs, modifying general applications software, or recommending commercially available software).
Other activities similar to those specified in paragraphs (87) through (93).

Legal Services:

General legal services performed on behalf of the taxpayer by in-house legal counsel, including but not limited to, drafting, negotiating and review of contracts or agreements, legal documents, and opinions, representation and advocacy before courts, administrative agencies, arbitrators, legislatures, or other bodies, preparing advice in respect of structuring and reorganization, acquisition, and divestment transactions, and maintaining corporate books and records. Support and administrative functions associated with the above activities (legal research, secretarial, filing and document retrieval, etc.).
Other activities similar to those specified in paragraph (95).

Training and Employee Development:

Assisting in training of personnel including assessing development and training needs, creating and conducting internal development and training programs and communicating training opportunities to personnel.
Arranging for management training on employment law compliance, employer liability avoidance, interviewing, hiring, terminations, promotions, performance reviews, safety, and sexual harassment.
Developing and implementing plans regarding career-development and succession.
Developing and implementing a job evaluation process including procedures and forms.
Other activities similar to those specified in paragraphs (75) through (78).

Benefits:

Developing and implementing employee compensation and benefits including healthcare, life insurance, 401(k), pension, worker’s compensation, unemployment, dental, profit sharing, employee incentive compensation, and employee assistance programs.
Providing benchmarking studies for compensation and other benefit programs.
Providing guidance and direction to employees regarding elections for benefits, applications for benefits and receipt of benefits (including providing assistance to employees in completing all necessary forms).
Arranging annual benefit enrollment meetings and employee benefit seminars.
Processing employee benefits inquiries and complaints, and reconciling billing issues.
Coordinating with hospitals, physicians, insurers, employees, and beneficiaries to facilitate proper and complete utilization of benefits for all employees.
Other activities similar to those specified in paragraphs (80) through (85).

Information and Technology (IT) Services:

Supporting company-wide computer systems including those used in connection with operations, accounting, manufacturing, customer service, human resources, payroll, and email.
Formulating guidelines with respect to the use of IT systems.
Maintaining and repairing IT systems.
Providing telecommunications facilities.
Providing technical assistance and training to users of computer systems and other information technology devices. Answering questions or resolving technical problems relating to computer systems and other information technology devices in person, via telephone or from remote location. Providing assistance concerning the use of computer hardware and software, including printing, installation, word processing, electronic mail, and operating systems, as well as disaster recovery back-up services.
Maintaining and testing existing computer databases (including implementing security measures to safeguard computer databases), but not to include analyzing user needs or developing hardware or software solutions (such as systems integration, website design, writing computer programs, modifying general applications software, or recommending the purchase of commercially available hardware or software).

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revisions. For example, comments are solicited whether warehousing and other functions that support distribution should be eligible for the SCM in light of Temp. Treas. Reg. §1.482–9T(b)(3)(ii)(E) (reselling, distribution ineligible for SCM).

Written comments may be submitted to CC:INTL:Br6 (Rev. Proc. 2007–13), room 4607, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20224. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to: CC:INTL:Br6 (Rev. Proc. 2007–13) Courier’s desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC 20224. Alternatively, taxpayers may submit comments electronically via the following e-mail address: Notice.Comments@irscounsel.treas.gov . Please include “Rev. Proc. 2007–13” in the subject line of any electronic communications.