Washington Dispatch, June 2008

Ernst & Young comments on proposed contract manufacturing regulations -- IRS temporary regulations issued under Section 367(b); address so-called “killer b” transactions -- IRS clarifies partnership itself is not required to file Form 926 in Section 367(a) transfers -- IRS proposed regulations clarify Section 704(c) anti-abuse rule -- IRS issues final regulations for testing substantiality of allocation under Section 704(b) when partners are look-through entities or consolidated group members -- Rev. Ruling 2008-31: interests in notional principal contract based on broad US real property index not US real property interests under Section 897(c)(1)