INCOME TAX

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.

Notice 2007–58, page 88. This notice solicits comments on potential revisions to the definitions of financial services income, active financing income, and financial services entities as currently set forth in regulations section 1.904–4(e), issued under section 904(d) of the Code. The Treasury Department and the IRS are considering the appropriateness of revising these provisions in light of statutory changes made as part of the American Jobs Creation Act of 2004 to sections 864(f) and 904(d).

Rev. Proc. 2007–45, page 89. Sample inter vivos charitable lead annuity trust (CLAT). This procedure contains sample forms for inter vivos grantor and nongrantor charitable lead annuity trusts. The procedure also contains annotations to the sample trusts and alternate provisions that may be integrated into the sample trusts.

Rev. Proc. 2007–46, page 102. Sample testamentary charitable lead annuity trust (CLAT). This procedure contains a sample form, annotations, and alternate provisions for a testamentary charitable lead annuity trust.

Finding Lists begin on page ii.