Censure Issued by Consent

Under Title 31, Code of Federal Regulations, Part 10, in lieu of a proceeding being instituted or continued, an attorney, certified public accountant, enrolled agent,

or enrolled actuary, may offer his or her consent to the issuance of a censure. Censure is a public reprimand.

The following individuals have consented to the issuance of a Censure:

Name Address Designation Date of Censure

Villarreal, Ricardo Houston, TX EA September 24, 2007

Meisgeier, Deborah K. Richmond, TX EA October 16, 2007

O’Brien, Colleen D. Winter Park, FL CPA October 24, 2007

Staver, Peter J. Southgate, MI Attorney November 06, 2007

Weiss, Ira Pittsburgh, PA Attorney November 29, 2007

Orr, William S. Kerrville, TX CPA December 04, 2007

Whitsitt, Richard Panama City, FL CPA December 04, 2007

undistributed earnings and post-1986 foreign income taxes as a result of a foreign tax redetermination (temporary) .

• • • • (d) - * (3) - * (iii) * * Example . - - * (i) * * * In 2009, CFC paid its actual foreign tax liability for 2008 of 80u. - * *

(ii) Result in 2009 . If the 20u overaccrual of tax for 2008 were taken into account in 2008, CFC’s general category post-1986 undistributed earnings would be 1,020u, CFC’s general category post-1986 foreign income taxes would be $280, and P would be deemed to pay $27.45 of tax with respect to the 2008 distribution of 100u (100u/1020u x $280 = $27.45). - * *

(iii) - - - As determined in 2011, CFC’s post-1986 undistributed earnings for 2009 are 1350u (1,100u as revised for 2008, less 100u distributed in 2008, plus 350u earned in 2009), and its post-1986 foreign income taxes for 2009 are $281.82 ($200 as revised for 2008, less $18.18 deemed paid in 2008, plus $100 accrued for 2009). As redetermined in 2011, P’s deemed paid credit with respect to the 100u distribution from CFC in 2009 is $20.88 (100u/1350u x $281.82).

• • • • Par. 3. Section 1.905–4T is amended by revising the last sentence of paragraph (b)(4) and the second sentence of paragraph (f)(2)(ii) as follows:

§1.905–4T Notification of foreign tax redetermination (temporary) .

• • • • (b) - *

Foreign Tax Credit: Notification of Foreign Tax Redeterminations; Correction

Announcement 2008–9

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendments.

SUMMARY: This document contains corrections to temporary regulations (T.D. 9362, 2007–48 I.R.B. 1050) that were published in the Federal Register on Wednesday, November 7, 2007 (72 FR 62771) relating to a United States taxpayer’s obligation under section 905(c) of the Internal Revenue Code to notify the IRS of a foreign tax redetermination, which is a change in the taxpayer’s foreign tax liability that may affect the taxpayer’s foreign tax credit and also relating to the civil penalty under section 6689 for failure to notify the IRS of a foreign tax redetermination as required under section 905(c).

DATES: The correction is effective December 19, 2007.

FOR FURTHER INFORMATION CONTACT: Teresa Burridge Hughes, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations (T.D. 9362) that are the subject of the correction are under section 905(c) of the Internal Revenue Code.

Need for Correction

As published, temporary regulations (T.D. 9362) contain errors that may prove to be misleading and are in need of clarification.

- - - -

Correction of Publication

Accordingly, 26 CFR part 1 is corrected by making the following amendments:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 continues to read, in part, as follows:

Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.905–3T is amended by revising the eighth sentence of paragraph (d)(3)(iii) Example .(i), the first sentence of paragraph (d)(3)(iii) Example .(ii), and the third and last sentences of paragraph (d)(3)(iii) Example .(iii) as follows:

§1.905–3T Adjustments to United States tax liability and to the pools of post-1986

February 19, 2008 444 2008–7 I.R.B.

Foreign Tax Credit: Notification of Foreign Tax Redeterminations; Correction

Announcement 2008–11

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to notice of proposed rulemaking by cross-reference to temporary regulations.

SUMMARY: This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG–209020–86, 2007–48 I.R.B. 1075) that was published in the Federal Register on Wednesday, November 7, 2007 (72 FR 62805) relating to a taxpayer’s obligation under section 905(c) of the Internal Revenue Code to notify IRS of a foreign tax redetermination and also relating to the civil penalty under section 6689 for failure to notify the IRS of a foreign tax redetermination as required under section 905(c).

FOR FURTHER INFORMATION CONTACT: Teresa Burridge Hughes at (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The correction notice that is the subject of this document is under section 905(c) of the Internal Revenue Code.

Need for Correction

As published, the notice of proposed rulemaking by cross-reference to temporary regulations (REG–209020–86) contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of the notice of proposed rulemaking by cross-reference to the temporary regulations (REG–209020–86), which was the subject of FR Doc. E7–21727, is corrected as follows:

1. On page 62806, column 1, in the preamble, under the caption “ADDRESSES:”, line 8, the language

(4) - - - Because the date for notifying the IRS of the foreign tax redetermination under paragraph (b)(1)(ii) of this section precedes the date of the opening conference concerning the examination of the return for X’s 2008 taxable year, paragraph (b)(3) of this section does not apply, and X must notify the IRS of the foreign tax redetermination by filing an amended return, Form 1118, and the statement required in paragraph (c) of this section for the 2008 taxable year by September 15, 2010.

• • • • (f) - - (2) - - (ii) * * * Such notification must be filed no later than the due date (with extensions) of the original return for the taxpayer’s first taxable year following the taxable year in which these regulations are first applicable. - -

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on December 18, 2007, 8:45 a.m., and published in the issue of the Federal Register for December 19, 2007, 72 F.R. 71787)

Returns Required on Magnetic Media; Correction

Announcement 2008–10

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to final regulations.

SUMMARY: This document contains corrections to final regulations (T.D. 9363, 2007–49 I.R.B. 1084) that were published in the Federal Register on Tuesday, November 13, 2007 (72 FR 63807) relating to the requirements for filing corporate income tax returns and returns of organizations required to file returns under section 6033 on magnetic media pursuant to section 6011(e) of the Internal Revenue Code.

DATES: The correction is effective November 13, 2007.

FOR FURTHER INFORMATION CONTACT: Michael E. Hara, (202) 622–4910 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations (T.D. 9363) that are the subject of this correction are under sections 6011, 6033 and 6037 of the Internal Revenue Code.

Need for Correction

As published, the final regulations (T.D. 9363) contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, the publication of the final regulations (T.D. 9363), which was the subject of FR Doc. E7–22147, is corrected as follows:

1. On page 63808, column 2, in the preamble, under the paragraph heading “ 1. Returns Covered ”, line 11 from the bottom of the column, the language “990 series that are required to be filled” is corrected to read “990 series that are required to be filed”.

2. On page 63809, column 2, in the preamble, under the paragraph heading “ 4. Hardship Waiver ”, lines 6 through 10 of the third paragraph of the column, the language “Providers for Form 1120/1120S; IRS Publication 4206, Modernized e-file information for Authorized e-file Providers of Exempt Organization Filings ; and on the IRS.gov Internet site.” is corrected to read “Providers for Form 1120/1120S; and on the IRS.gov Internet site.”

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on December 12, 2007, 8:45 a.m., and published in the issue of the Federal Register for December 13, 2007, 72 F.R. 70779)

2008–7 I.R.B. 445 February 19, 2008

Need for Correction

As published, temporary regulations (T.D. 9362) contain an error that may prove to be misleading and is in need of clarification.

Correction of Publication

Accordingly, the publication of the temporary regulations (T.D. 9362), which were the subject of FR Doc. E7–21766, is corrected as follows:

On page 62779, column 2, under the paragraph heading “Effective/Applicability Date”, last line of the first paragraph of the column, the language “are first effective.” is corrected to read “are first applicable.”.

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on December 18, 2007, 8:45 a.m., and published in the issue of the Federal Register for December 19, 2007, 72 F.R. 71787)

“CC:PA:LPD:PR (REG–209020–90),” is corrected to read “CC:PA:LPD:PR (REG–209020–86),”.

[§1.905–5 Corrected]

2. On page 62807, column 2, §1.905–5, the word (temporary) is removed from the end of the section title.

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on December 18, 2007, 8:45 a.m., and published in the issue of the Federal Register for December 19, 2007, 72 F.R. 71842)

Foreign Tax Credit: Notification of Foreign Tax Redeterminations; Correction

Announcement 2008–12

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correction to temporary regulations.

SUMMARY: This document contains a correction to temporary regulations (T.D. 9362, 2007–48 I.R.B. 1050) that were published in the Federal Register on Wednesday, November 7, 2007 (72 FR 62771) relating to a United States taxpayer’s obligation under section 905(c) of the Internal Revenue Code to notify the IRS of a foreign tax redetermination, which is a change in the taxpayer’s foreign tax liability that may affect the taxpayer’s foreign tax credit and also relating to the civil penalty under section 6689 for failure to notify the IRS of a foreign tax redetermination as required under section 905(c).

DATES: The correction is effective December 19, 2007.

FOR FURTHER INFORMATION CONTACT: Teresa Burridge Hughes, (202) 622–3850 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The temporary regulations (T.D. 9362) that are the subject of the correction are under section 905(c) of the Internal Revenue Code.

February 19, 2008 446 2008–7 I.R.B.