INCOME TAX

Rev. Rul. 2007–7, page 468. Investor control and general public; taxation of variable contracts; insurance and annuities. This ruling effectively excludes classes of beneficial ownership from the definition of “general public” as defined in Rev. Rul. 81–225, 1981–2 C.B. 12, for purposes of investor control analysis. Investor control analysis is used to determine who owns (and is taxed on) income generated inside of variable contracts ( e.g., variable life insurance contracts or variable annuity contracts). Rev. Ruls. 81–225 and 2003–92 clarified and amplified.

Rev. Rul. 2007–8, page 469. Section 357(c) . Section 357(c)(1) of the Code does not apply to transactions that qualify as reorganizations described in sections 368(a)(1)(A), (C), (D), or (G), and to which section 351 applies, provided certain requirements are satisfied. Rev. Ruls. 75–161 and 76–188 obsoleted. Rev. Rul. 78–330 modified.

T.D. 9305, page 479. Final regulations under section 863 of the Code contain rules governing the source of income from certain space and ocean activities. They also contain rules governing the source of income from certain communications activities. The regulations affect persons who derive income from activities conducted in space or on or under water not within the jurisdiction of a foreign country, possession of the United States, or the United States (in international water). The regulations also affect persons who derive income from transmission of communications.

Finding Lists begin on page ii.