Bulletin No. 2007-46 November 13, 2007

REG–114125–07, page 1012. Proposed regulations under section 861 of the Code contain changes to existing final regulations regarding the source of compensation for labor or personal services.

Notice 2007–86, page 990. This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice extends relief to December 31, 2008, except that reliance on the proposed regulations under section 409A is not permitted after December 31, 2007. Notice 2007–78 modified. Section 3 of Notice 2006–79 modified and superseded.

Notice 2007–88, page 993. This notice requests public comment on a proposal to change the process by which taxpayers obtain the consent of the Commissioner of Internal Revenue to change a method of accounting for federal income tax purposes.

EMPLOYEE PLANS

Notice 2007–86, page 990. This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice extends relief to December 31, 2008, except that reliance on the proposed regulations under section 409A is not permitted after December 31, 2007. Notice 2007–78 modified. Section 3 of Notice 2006–79 modified and superseded.

(Continued on the next page)

Announcements of Disbarments and Suspensions begin on page 1015. Finding Lists begin on page ii.

ESTATE TAX

Notice 2007–90, page 1003. This notice provides interim guidance and describes a change in IRS policy regarding section 6166 of the Code, Extension of time for payment of estate tax where estate consists largely of interest in closely held business. The IRS will now determine on a case-by-case basis whether security will be required when a qualifying estate elects under section 6166 to pay all or a part of the estate tax in installments. This notice also informs taxpayers, tax practitioners, executors and other persons who represent estates of what factors the IRS will consider in determining whether an estate making the section 6166 election will be required to provide security.

TAX CONVENTIONS

Announcement 2007–107, page 989. The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first notification” under paragraph 1 of Article 26 (Mutual Agreement Procedure) of the Convention between the United States of America and the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation with respect to taxes on income signed at London on July 24, 2001 (“the Treaty”). The Agreement is entered into under paragraph 3 of Article 26 (Mutual Agreement Procedure).

ADMINISTRATIVE

Ct. D. 2083, page 986. Levies upon third party property to collect taxes owed by another; wrongful levy action. The Supreme Court holds that the Trust missed section 7426(a)(1)’s deadline for challenging a levy, and may not bring the challenge as a tax refund claim under section 1346(a)(1).

Notice 2007–89, page 998. This notice provides interim guidance to employers and payers on their reporting and wage withholding requirements for calendar year 2007 with respect to deferrals of compensation and amounts includible in gross income under section 409A of the Code. The notice also provides interim rules on calculating amounts includible in gross income under section 409A. Notice 2005–1 modified.

November 13, 2007 2007–46 I.R.B.