This document contains corrections to proposed regulations (REG-138707-06, 2007-32 I. This document contains a correction to final and temporary regulations (T. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis.
342) that modify final regulations issued under sections 883(a) and (c) of the Code, relating to income derived by foreign corporations from the international operation of ships or aircraft. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis.
Prior to 1991, the Service published acquiescence or nonacquiescence only in certain regular Tax Court opinions.
The Service has expanded its acquiescence program to include other civil tax cases where guidance is determined to be helpful.
The Actions on Decisions published in the weekly Internal Revenue Bulletin are consolidated semiannually and appear in the first Bulletin for July and the Cumulative Bulletin for the first half of the year.
A semiannual consolidation also appears in the first Bulletin for the following January and in the Cumulative Bulletin for the last half of the year.
It also addresses some additional matters regarding Type III supporting organizations in response to changes in the law made by the Pension Protection Act of 2006. Also included in this part are Bank Secrecy Act Administrative Rulings.
“Nonacquiescence” signifies that, although no further review was sought, the Service does not agree with the holding of the court and, generally, will not follow the decision in disposing of cases involving other taxpayers. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. 300) that relate to the exclusion from gross income derived by certain foreign corporations engaged in the international operation of ships or aircraft.The recommendation in every Action on Decision will be summarized as acquiescence, acquiescence in result only, or nonacquiescence.Both “acquiescence” and “acquiescence in result only” mean that the Service accepts the holding of the court in a case and that the Service will follow it in disposing of cases with the same controlling facts.