Rev. Proc. 2007-25

Country

Location

Limitation on Housing
Expenses (daily)

Limitation on Housing
Expenses (full year)

Switzerland

Zurich

105.20

38,398

Taiwan

Taipei

122.42

44,685

United Arab Emirates

Abu Dhabi

82.12

29,973

United Arab Emirates

Dubai

116.31

42,452

United Kingdom

Basingstoke

112.60

41,099

United Kingdom

Gibraltar

122.24

44,616

United Kingdom

Surrey

121.51

44,350

SECTION 5. EFFECT ON OTHER
DOCUMENTS
Notice 2006–87 is modified and supplemented.
SECTION 6. EFFECTIVE DATE
This notice is effective for taxable years
beginning on or after January 1, 2006.
SECTION 7. DRAFTING
INFORMATION
The principal author of this notice
is Paul J. Carlino of the Office of Associate Chief Counsel (International). For
further information regarding this notice,
contact Mr. Carlino at (202) 622–3840
(not a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also: Part 1, §§ 6011, 6662, 6662A, 6707A;
1.6011–4.)

Rev. Proc. 2007–25
SECTION 1. PURPOSE
This revenue procedure amplifies Rev.
Proc. 2005–51, 2005–2 C.B. 296, which
provides guidance to persons who may be
required to pay certain penalties under sections 6662(h), 6662A, or 6707A of the Internal Revenue Code, and who may be
required under section 6707A(e) to disclose those penalties on reports filed with
the Securities and Exchange Commission
(“SEC”).
SECTION 2. BACKGROUND
.01 Section 6707A(e), as added by
the American Jobs Creation Act of 2004,

March 19, 2007

Pub. L. No. 108–357, 118 Stat. 1418,
requires a person that is required to file
periodic reports under section 13 or 15(d)
of the Securities Exchange Act of 1934, or
is required to be consolidated with another
person for purposes of those reports, to
disclose in those reports for the periods
specified by the Secretary the requirement
to pay the penalties set forth in section
6707A(e)(2).
.02 Section 4 of Rev. Proc. 2005–51
sets forth the report on which the disclosures must be made, the information that
must be disclosed, and the deadlines by
which persons must make the disclosures
on reports filed with the SEC in order to
avoid additional penalties under section
6707A(e).
.03 Section 4.01 of Rev. Proc. 2005–51
specifically provides that a person who
files SEC Form 10–K, Annual Report, pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934, either separately or consolidated with another person, must disclose in Item 3 (Legal Proceedings) of Form 10–K the requirement
to pay any penalty specified in section 2.05
of Rev. Proc. 2005–51.
.04 After the issuance of Rev. Proc.
2005–51, questions arose regarding persons required to file periodic reports under
section 13 or 15(d) of the Securities Exchange Act of 1934, or required to be consolidated with another person for purposes
of those reports, but that file these periodic
reports on a form other than a Form 10–K.
SECTION 3. SCOPE
This revenue procedure applies to any
person required to pay any penalty described in section 2.05 of Rev. Proc.
2005–51 that is also required to file periodic reports under section 13 or 15(d)
of the Securities Exchange Act of 1934

761

on a form other than a Form 10–K or is
required to be consolidated with another
person for purposes of those reports.
SECTION 4. APPLICATION
.01 A person who files Form 10–KSB,
Annual Report of Small Business Issuers,
pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934, either separately or consolidated with another person,
must disclose in Item 3 (Legal Proceedings) of Form 10–KSB the requirement to
pay any penalty specified in section 2.05
of Rev. Proc. 2005–51.
.02 A person who files Form 11–K, Annual Report of Employee Stock Purchase,
Savings and Similar Plans, must disclose
in the Form 11–K, under the subheading
“Legal Proceedings”, the requirement to
pay any penalty specified in section 2.05
of Rev. Proc. 2005–51.
.03 A person who files Form 20–F, Annual Report of Foreign Private Issuers,
pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934, either separately or consolidated with another person,
must disclose in Item 8 (Financial Information) of Form 20–F, under the subheading “Legal Proceedings”, the requirement
to pay any penalty specified in section 2.05
of Rev. Proc. 2005–51.
.04 A person who files Form 40–F, Annual Report of Certain Canadian Issuers,
pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934, either separately or consolidated with another person,
must disclose in the Annual Information
Form filed as part of the Form 40–F, under the subheading “Legal Proceedings”,
the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005–51.
.05 A person who files Form N–SAR,
Annual Report of Registered Investment
Companies, pursuant to section 13 or 15(d)

2007–12 I.R.B.

of the Securities Exchange Act of 1934,
either separately or consolidated with another person, must disclose in Sub-Item
77E (Legal Proceedings) of Form N–SAR
the requirement to pay any penalty specified in section 2.05 of Rev. Proc. 2005–51.
.06 A person who files Form N–CSR,
Annual Report of Registered Investment
Companies, pursuant to section 13 or
15(d) of the Securities Exchange Act of
1934, either separately or consolidated
with another person, must disclose in
Item 1 (Reports to Stockholders) of Form
N–CSR, under the subheading “Legal
Proceedings”, the requirement to pay any
penalty specified in section 2.05 of Rev.
Proc. 2005–51.
.07 The same procedures described
in sections 4.02 and 4.03 of Rev. Proc.
2005–51 regarding the information that
must be disclosed and the deadlines by
which persons must make the disclosures
on reports filed with the SEC that apply
to Form 10–K apply to Forms 10–KSB,

2007–12 I.R.B.

11–K, 20–F, 40–F, N–SAR, and N–CSR,
as applicable.

collection of information displays a valid
OMB control number.

SECTION 5. EFFECT ON OTHER
DOCUMENTS

SECTION 7. EFFECTIVE DATE

Rev. Proc. 2005–51, 2005–2 C.B. 296,
is amplified.
SECTION 6. PAPERWORK
REDUCTION ACT
The collections of information in Rev.
Proc. 2005–51 have been previously
reviewed and approved by the Office
of Management and Budget in accordance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545–1956. This revenue procedure does
not make substantive changes to those
collections of information.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the

762

This revenue procedure is effective for
any penalty specified in section 2.05 of
Rev. Proc. 2005–51 that relates to a return
or statement the due date for which is after
October 22, 2004.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Matthew S. Cooper of the
Office of the Associate Chief Counsel
(Procedure & Administration). For further
information regarding this revenue procedure, contact Matthew S. Cooper at (202)
622–4940 (not a toll-free call).

March 19, 2007