HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2009–33, page 447. Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2009.

T.D. 9463, page 442. Final regulations under section 860G of the Code expand the list of permitted modifications to include certain modifications that are often made to commercial mortgages. Changes to the regulations are necessary to better accommodate evolving practices in the commercial-mortgage industry. These changes will affect lenders, borrowers, servicers, and sponsors of securitizations of mortgages in REMICs.

Notice 2009–78, page 452. This notice announces rules that will be included in regulations identifying stock that is not taken into account for purposes of the ownership test of section 7874 of the Code. Stock generally will not be taken into account for this purpose if, subject to certain exceptions, it is issued in exchange for: (1) cash or cash equivalents; (2) marketable securities; and (3) any other property in a transaction with a principal purpose of avoiding section 7874. This notice also includes provisions regarding stock that is sold in a public offering.

Notice 2009–79, page 454. This notice requests comments about whether additional guidance related to modifications of commercial loans held by investment trusts similar to the changes permitted under regulations section 1.860G–2(b)(3) of the Code is appropriate and the extent to which the requested changes are consistent with the Service position under section 301.7701–4(c) as related

Announcements of Disbarments and Suspensions begin on page 475. Finding Lists begin on page ii.