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.

SPECIAL ANNOUNCEMENT

Announcement 2009–77, page 567. The Twenty-Second Annual Institute on Current Issues in International Taxation, jointly sponsored by the Internal Revenue Service and the George Washington University Law School, will be held on December 10 and 11, 2009, at the J.W. Marriott Hotel in Washington, D.C.

INCOME TAX

T.D. 9458, page 547. REG–139068–08, page 558. Temporary and proposed regulations under section 1502 of the Code provide for an election under which a consolidated group can avoid immediately taking into account an intercompany item after the liquidation of a target corporation. Pursuant to the election, the liquidation and recontribution will be recharacterized as a cross-chain reorganization, rather than a liquidation or an upstream reorganization followed by a drop of assets.

T.D. 9465, page 542. Final regulations under section 882 of the Code provide guidance on interest allocation for foreign corporations to coordinate with recent income tax treaties; provide guidance on the adoption of a fixed ratio election and a 30–day published LIBOR rate election in the allocation formula; modify the liability reduction election under the branch profits tax; and make miscellaneous technical corrections and clarifications.

T.D. 9466, page 551. REG–108045–08, page 557. Final, temporary, and proposed regulations under sections 6229(c)(2) and 6501(e) of the Code define an omission from

Finding Lists begin on page ii. Index for July through October begins on page iv.