Tax News

CCH (cch.taxgroup.com) reports:

  The IRS will not challenge whether a security is readily marketable under Code Sec. 956(c)(2)(J) if the security is of a type that was readily marketable at any time within three years prior to May 12, 2008. The guidance is effective May 12, 2008, and applies to determine whether securities are readily marketable for any day during calendar years 2007 or 2008 for which such determination is relevant for Code Sec. 956(c)(2)(J) purposes. The IRS clarifies that the guidance does not address any other issue relating to the qualification of the transaction under Code Sec. 956(c)(2)(J) or any other federal income tax issue arising under any other Code sections. In addition, no inference should be drawn regarding whether a security would be described in Code Sec. 956(c)(2)(J) if it falls outside the scope of the guidance or whether securities within the scope of the guidance would be readily marketable for purposes of
Code Sec. 956(c)(2)(J) but for this guidance.

Rev. Proc. 2008-26, 2008FED ¶46,429

Other References:

 
Code Sec. 956

  CCH Reference - 2008FED ¶28,576.35

  Tax Research Consultant

  CCH Reference - TRC INTLOUT: 9,256.15