Internal Revenue Bulletins  

October 28, 2002

Internal Revenue Bulletin No. 2002-43

Links to Official IRS Bulletin Documents listed below are in the Adobe Acrobat PDF Format, and require the appropriate Acrobat Reader to view and/or print.

SPECIAL ANNOUNCEMENT

Announcement 2002-96(PDF, 18K)
The Service announces that the Appeals settlement initiative with respect to broad-based leveraged corporate owned life insurance (COLI) plans purchased after June 20, 1986, will be terminated. The Service will vigorously defend or prosecute all future COLI litigation. There will be a 45-day window within which taxpayers will be permitted to enter into the current settlement arrangement by submitting to the Internal Revenue Service a formal written offer to settle.

Announcement 2002-97(PDF, 23K)
Under the terms of this announcement, taxpayers who have engaged in basis-shifting transactions will be given the opportunity to resolve this issue with minimal further examination or other administrative proceedings. Participating taxpayers will enter into a settlement with fixed terms that are specified in the announcement.

INCOME TAX

Notice 2002-69(PDF, 36K)
This notice provides interim guidance for determining interest rates and foreign loss payment patterns for certain foreign insurance companies under section 954(i) of the Code. Comments are requested by March 28, 2003.

Rev. Proc. 2002-67(PDF, 100K)
This document provides procedures for taxpayers who elect to participate in a settlement initiative aimed at resolving tax shelter cases involving “contingent liability transactions” that are the same or similar to those described in Notice 2001-17, 2001-1 C.B. 730. There are two resolution methodologies: a fixed concession procedure and a fast track dispute resolution procedure that includes binding arbitration.

Rev. Proc. 2002-68(PDF, 30K)
Optional election to make monthly 706(a) computations. This procedure allows certain partnerships that invest in assets exempt from taxation under section 103 of the Code to make an election that enables partners to take into account monthly the inclusions required under sections 702 and 707(c). Rev. Proc. 2002-16 modified and superseded.

Rev. Rul. 2002-65(PDF, 12K)
Low-income housing tax credit. This ruling advises taxpayers that rental assistance payments made to a building owner on behalf or in respect of a tenant under the Rent Supplement Payment program or the Rental Assistance Payments program are not grants made with respect to a building or its operation under section 42(d)(5) of the Code.

EMPLOYEE PLANS

Notice 2002-68(PDF, 17K)
Weighted average interest rate update. The weighted average interest rate for October 2002 and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth.

EXEMPT ORGANIZATIONS

Announcement 2002-99(PDF, 18K)
Cedar Rapids Boxing Club, Inc., no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

ADMINISTRATIVE

Announcement 2002-98(PDF, 18K)
Publication 1187, Specifications for Filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, Magnetically or Electronically, will not be revised for Tax Year 2002.

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