ADMINISTRATIVE

Notice 2007–57, page 87. This notice describes a transaction in which a U.S. taxpayer uses offsetting positions with respect to foreign currency or other property for the purpose of importing a loss, but not the corresponding gain, in determining U.S. taxable income. The notice alerts taxpayers and their representatives that these transactions are tax avoidance transactions and identifies these transactions, and substantially similar transactions, as listed transactions for purposes of regulations section 1.6011–4(b)(2) and sections 6111 and 6112 of the Code.

Rev. Proc. 2007–47, page 108. This procedure sets forth conditions under which a research agreement does not result in private business use under section 141(b) of the Code. Rev. Proc. 97–14 modified and superseded.

July 16, 2007 2007–29 I.R.B.