Bulletin No. 2007-16 April 16, 2007

REG–158677–05, page 975. Proposed regulations under section 1361 of the Code clarify that if a bank is an S corporation within the meaning of section 1361(a)(1), its status as an S corporation does not affect the applicability of the special rules for banks under the Code.

Notice 2007–31, page 971. This notice announces a new working arrangement for the automatic exchange of information entered into between the Service and the U.S. Virgin Islands Bureau of Internal Revenue. Because of this new working arrangement, the notice provides new interim rules, pending the issuance of regulations under sections 932(c) and 7654(e) of the Code, concerning the statute of limitations on assessment with respect to taxpayers claiming to be bona fide residents of the U.S. Virgin Islands for taxable years ending on or after December 31, 2006. Taxpayers may rely on this notice until regulations are issued. Notice 2007–19 amended and supplemented.

Rev. Proc. 2007–28, page 974. This document provides guidance to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries for tax year 2006 and the dates those countries are subject to the section 911(d)(4) waiver is provided.

ADMINISTRATIVE

Announcement 2007–40, page 978. This document contains corrections to temporary regulations (T.D. 9313, 2007–13 I.R.B. 805) that provide guidance regarding the qualification of certain transactions as reorganizations described in section 368(a)(1)(D) of the Code where no stock and/or securities of the acquiring corporation are issued and distributed in the transaction.