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

REG–127270–06, page 534. Proposed regulations under section 104 of the Code update the regulations to reflect statutory amendments limiting the section 104(a)(2) exclusion to damages for personal physical injuries or physical sickness and delete the “tort or tort-type rights” test.

EXCISE TAX

Rev. Rul. 2009–34, page 502. Section 4221(e) reciprocal privileges. The list of countries that allow reciprocal privileges for purposes of the exemption for supplies for civil aircraft of foreign registry is updated and restated. Rev. Ruls. 74-346, 75-190, 75-398, and 75-526 superseded.

T.D. 9462, page 504. REG–116614–08, page 536. Final, temporary, and proposed regulations under section 7701 of the Code clarify that a single-owner eligible entity that is generally disregarded as an entity separate from its owner for any purpose, but regarded as a separate entity for certain excise tax purposes, is treated as a corporation for those excise tax purposes. The regulations also make conforming changes to the tax liability rule for disregarded entities and the treatment of entity rule for disregarded entities with respect to employment taxes. The regulations affect disregarded entities in general and, in particular, disregarded entities that pay or pay over certain federal excise taxes or that are required to be registered by the IRS.

Announcements of Disbarments and Suspensions begin on page 537. Finding Lists begin on page ii.