Bulletin No. 2008-2 January 14, 2008

Notice 2008–2, page 252. This notice seeks comments on, among other things, whether the parties to a prepaid forward contract or similar arrangement (that is not otherwise indebtedness for U.S. federal tax purposes) should be required to accrue income/expense during the term of a contract and asks for comments on an appropriate method for accruing income or expense. The notice also asks for comments on various domestic and international issues (including character and source) that would need to be addressed if income/expense accruals were deemed appropriate. This notice is a companion publication to Rev. Rul. 2008–1, which concludes that a prepaid forward contract on foreign currency is treated as debt for federal tax purposes.

Notice 2008–3, page 253. On January 1, 2008, the impuesto empresarial a tasa única (IETU), a single rate business tax adopted by Mexico, will become effective. This notice provides that, pending the outcome of a study to determine whether the IETU is a creditable income tax, the IRS will not challenge a taxpayer’s position that the IETU is an income tax that is eligible for a credit under Article 24(1) of the U.S.-Mexico income tax treaty.

Notice 2008–4, page 253. This notice provides interim guidance to the public on how to file claims with the IRS Whistleblower Office for payment of awards to persons who detect and report underpayments of tax.

Notice 2008–5, page 256. This notice provides guidance under section 152(d) of the Code for determining whether an individual is a qualifying relative for whom the taxpayer may claim a dependency exemption deduction under section 151(c).

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