2003 Regulations
"Regulations" are the IRS Commissioner's rules, approved by the Secretary of the Treasury, or the Secretary's delegate, for the application and administration of the Internal Revenue laws. The purpose of regulations is to provide taxpayers, their representatives, and Service personnel with rules of general application so they may clearly understand the taxpayer's rights and duties under the law.
For more information about Regulations, see the Guide to Understanding the Differences Among Official IRS Documents
Regulations are in the Adobe Acrobat PDF format.
Internal Revenue Bulletin Summary pages are in HTML format.
Regulation |
Bulletin |
Date of IRB |
Cross-Ref |
|
REG-209377-89(PDF, 40K) |
IRB #2003-36(HTML) |
Sept. 8, 2003 |
N/A |
Proposed regulations, for purposes of the at-risk limitations under section 465 of the Code, relate to the treatment of amounts borrowed froma person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest. The proposed amendments provide that all activities are subject to the rule that these borrowed amounts do not increase the amount at risk in the activity. |
REG-208199-91(PDF, 88K) |
IRB #2003-40(HTML) |
Oct. 6, 2003 |
N/A |
Proposed regulations under section 6503(j) of the Code concern the use of designated summonses and related summonses and the effect on the period of limitations on assessment when a case is brought with respect to a designated or related summons. |
REG-164754-01(PDF, 68K) |
IRB #2003-22(HTML) |
June 2, 2003 |
N/A |
Proposed regulations under section 61 of the Code provide guidance for federal income, gift, and employment tax purposes on the valuation of economic benefits provided under a split-dollar life insurance arrangement. The regulations supplement proposed regulations published in the Federal Register on July 9, 2002 (REG-164754-01, 2002-30 I.R.B. 212) that provide comprehensive guidance on split-dollar life insurance arrangements for federal income, gift, and employment tax purposes. A public hearing is scheduled for July 29, 2003. |
REG-209500-86; REG-164464-02(PDF, 161K) |
IRB #2003-2(HTML) |
Jan. 13, 2003 |
N/A |
Proposed regulations under sections 401 and 411 of the Code provide rules regarding the requirements that accruals or allocations under certain retirement plans not cease or be reduced because of the attainment of any age. In addition to providing generally applicable rules, the proposed regulations would provide special rules for cash balance plans, and would provide rules for the application of certain nondiscrimination requirements to cash balance plans. A public hearing is scheduled for April 10, 2003. |
REG-163974-02(PDF, 71K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
N/A |
Proposed regulations under section 817 of the Code propose removing provisions of the regulations that apply a look-through rule to assets of a nonregistered partnership for purposes of satisfying the diversification requirements of section 817(h). |
REG-162625-02(PDF, 123K) |
IRB #2003-35(HTML) |
Sept. 2, 2003 |
N/A |
Proposed regulations under section 446 of the Code set out rules relating to the proper timing and source of income of fees received to induce the acquisition of noneconomic residual interests in REMICs. A public hearing is scheduled for November 18, 2003. |
REG-160330-02(PDF, 59K) |
IRB #2003-51(HTML) |
Dec. 22, 2003 |
N/A |
Proposed regulations under section 704(c) of the Code provide guidance with respect to the tax treatment of installment obligations and property acquired pursuant to a contract under sections 704(c) and 737. |
REG-157302-02(PDF, 103K) |
IRB #2003-24(HTML) |
June 16, 2003 |
N/A |
Proposed regulations under section 408 of the Code provide guidance regarding accounts and annuities added to qualified employer plans where such accounts and annuities are to be treated as individual retirement plans. |
REG-157164-02(PDF, 25K) |
IRB #2003-44(HTML) |
Nov. 3, 2003 |
T.D. 9091(PDF, 25K) |
Final, temporary, and proposed regulations under sections 168 and 1400L of the Code provide rules for the additional first-year depreciation allowance. The regulations provide the requirements that must be met for depreciable property to qualify for the additional first-year depreciation allowance and instruct taxpayers how to determine the additional first-year depreciation allowance and the amount of depreciation otherwise allowable for the property. The regulations apply to property acquired by a taxpayer after September 10, 2001 (for the additional 30-percent first-year depreciation allowance), and for property acquired by a taxpayer after May 5, 2003 (for the additional 50-percent first-year depreciation allowance). A public hearing on the proposed regulations is scheduled for December 18, 2003. |
REG-153319-03(PDF, 45K) |
IRB #2003-52(HTML) |
Dec. 29, 2003 |
T.D. 9098(PDF, 45K) |
Temporary and proposed regulations under section 1502 of the Code amend proposed regulations (REG13276003, 200343 I.R.B. 933) and temporary regulations (T.D. 9089, 200343 I.R.B. 906). These regulations provide guidance concerning how a corporation that is a member of a consolidated group reduces its tax attributes when that member realizes discharge of indebtedness income that is excluded from gross income under section 108. |
REG-152524-02(PDF, 56K) |
IRB #2003-22(HTML) |
June 2, 2003 |
T.D. 9057(PDF, 56K) |
A corporation that files a consolidated return that acquires a subsidiary may elect to waive all or a portion of that subsidiary's loss carryovers from a separate return limitation year. Waived loss carryovers are deemed to have expired. Generally, such an election is irrevocable. Temporary and proposed regulations under section 1502 of the Code provide guidance on when a corporation may make a limited amendment to a previous election to waive these loss carryovers. In addition, these regulations permit a selling group to reapportion separate, subgroup, and consolidated section 382 limitations so that an acquiring group may use the loss carryovers that are no longer subject to the previous election. A public hearing on the proposed regulations is scheduled for August 6, 2003. |
REG-151043-02(PDF, 17K) |
IRB #2003-3(HTML) |
Jan. 21, 2003 |
N/A |
Proposed regulations under section 61 of the Code authorize the Commissioner to provide, through administrative guidance, rules for deferring inclusion of advance rentals in gross income to a taxable year other than the year of receipt. |
REG-146893-02, REG-115037-00(PDF, 466K) |
IRB #2003-44(HTML) |
Nov. 3, 2003 |
N/A |
Proposed regulations under section 482 of the Code explain that when controlled taxpayers transfer goods, services, intangibles or other items of value, the amount charged must be consistent with the amount charged at arm's length in the same or comparable transactions. These regulations provide updated guidance on determining the arm's length charge where one controlled taxpayer performs services that benefit one or more other controlled taxpayers. These regulations also provide updated guidance on the allocation among controlled taxpayers of income from intangibles, in particular when one controlled taxpayer performs activities that increase (or are expected to increase) the value of an intangible owned by another controlled taxpayer. A public hearing is scheduled for January 14, 2004. |
REG-146692-03(PDF, 80K) |
IRB #2003-48(HTML) |
Dec. 1, 2003 |
N/A |
Section 103(a) of the Code provides that, generally, interest on bonds issued by state and local governments is excluded from gross income. "Qualified mortgage revenue bonds" may also be qualified bonds. A bond may only be a qualified mortgage revenue bond if the effective rate of mortgage interest on the mortgages provided with the bond proceeds does not exceed the yield on the bonds by more that 1.125 percentage points. The proposed regulations provide rules for calculating the effective rate of mortgage interest. Specifically, the proposed regulations provide that amounts paid for pool mortgage insurance are to be excluded from the calculation (which results in a lower effective rate of mortgage interest). A public hearing is scheduled for January 28, 2004. |
REG-144908-02(PDF, 89K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
N/A |
Proposed regulations under section 6302 of the Code provide an additional exception to the FUTA deposit requirements for employers. The regulations would relieve employers from making deposits of FUTA taxes for a quarter if the amount of accumulated Federal Insurance Contributions Act (FICA) taxes and withheld income taxes for the quarter is less than $2,500. |
REG-143679-02(PDF, 56K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
T.D. 9071(PDF, 56K) |
Final, temporary, and proposed regulations under section 338 of the Code provide that the step transaction doctrine will not be applied if a taxpayer makes a valid section 338(h)(10) election with respect to a step in a multi-step transaction, even if the transaction would otherwise qualify as a reorganization if the step, standing alone, is a qualified stock purchase. |
REG-142605-02(PDF, 97K) |
IRB #2003-23(HTML) |
June 9, 2003 |
N/A |
Proposed regulations under sections 263A and 448 of the Code provide rules under which any adjustment under section 481(a) resulting from a change in method of accounting under the regulations will be taken into account over the same number of taxable years that is provided in general guidance. A public hearing is scheduled for August 13, 2003. |
REG-142538-02(PDF, 68K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
T.D. 9070(PDF, 68K) |
Temporary and proposed regulations under section 6104 of the Code provide guidance about the fees which the IRS and exempt organizations may charge for providing copies of material required to be publicly available. |
REG-141669-02(PDF, 118K) |
IRB #2003-34(HTML) |
Aug. 25, 2003 |
N/A |
Proposed regulations under section 6724 of the Code provide rules designed to determine whether the correction of a failure to file a correct information return is considered prompt for purposes of waiving information reporting penalties. A public hearing is scheduled for October 21, 2003. |
REG-141659-02(PDF, 22K) |
IRB #2003-20(HTML) |
May 19, 2003 |
T.D. 9053(PDF, 22K) |
Temporary and proposed regulations under section 6695 of the Code clarify and amend existing regulations to facilitate electronic filing by return preparers. The regulations eliminate the references to manually signed returns. In addition, they provide that the Commissioner may prescribe, in forms, instructions, or other appropriate guidance, the manner in which preparers may satisfy their obligations under section 6107 to furnish returns to taxpayers and to retain copies of returns. |
REG-141402-02 (PDF, 31K) |
IRB #2003-43(HTML) |
Oct. 27, 2003 |
T.D. 9090(PDF, 31K) |
Temporary and proposed regulations under section 448(d)(5) of the Code provide guidance regarding the use of a nonaccrual-experience method by taxpayers using an accrual method of accounting and performing services. A public hearing on the proposed regulations is scheduled for December 10, 2003. Notice 2003-12 obsoleted. Rev. Proc. 2002-9 modified. |
REG-141097-02(PDF, 48K) |
IRB #2003-16(HTML) |
April 21, 2003 |
N/A |
Proposed regulations under section 4251 of the Code relate to the definition of toll telephone service for purposes of the communications excise tax. |
REG-140930-02(PDF, 124K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
N/A |
Proposed regulations provide procedures for current and former IRS employees and contractors to follow when they receive requests and subpoenas for IRS records and information. The regulations also provide procedures for the public to follow when seeking testimony or IRS records in nontax litigation. |
REG-140808-02(PDF, 60K) |
IRB #2003-38(HTML) |
Sept. 22, 2003 |
T.D. 9073(PDF, 60K) |
Temporary and proposed regulations under section 6103 of the Code describe the circumstances under which officers and employees of the IRS, the IRS Office of Chief Counsel, and the Office of Treasury Inspector General for Tax Administration may disclose return information for investigative purposes. The temporary regulations clarify and elaborate on the types and contexts in which investigative disclosures may be made. |
REG-140378-01(PDF, 82K) |
IRB #2003-41(HTML) |
Oct. 14, 2003 |
N/A |
Proposed regulations under section 6334 of the Code relate to property exempt from levy. The regulations have been revised to provide guidance with respect to the procedures for obtaining prior judicial approval of certain principal residence levies and for exemption from levy for certain residences and business assets. The regulations have also been revised to reflect recent legislative changes. |
REG-139768-02(PDF, 29K) |
IRB #2003-10(HTML) |
March 10, 2003 |
T.D. 9042(PDF, 29K) |
Temporary and proposed regulations, primarily under section 5891 of the Code, provide the manner and method of paying and reporting the nondeductible 40-percent excise tax imposed on any person who acquires structured settlement payment rights in a structured settlement factoring transaction. A public hearing on the proposed regulations is scheduled for June 12, 2003. |
REG-138882-02(PDF, 20K) |
IRB #2003-8(HTML) |
Feb. 24, 2003 |
T.D. 9031(PDF, 20K) |
Temporary and proposed regulations under section 121 of the Code provide rules relating to the reduced maximum exclusion of gain from the sale or exchange of property that the taxpayer has not owned and used as the taxpayer's principal residence for two of the preceding five years or when the taxpayer has excluded gain from the sale or exchange of a principal residence within the preceding two years. |
REG-138499-02(PDF, 151K) |
IRB #2003-37(HTML) |
Sept. 15, 2003 |
N/A |
Proposed regulations under section 168 of the Code provide guidance on how to depreciate property for which the use changes in the hands of the same taxpayer. These regulations explain when a change in use occurs and how a taxpayer should determine depreciation in the year of the change in use and subsequent years. A public hearing is scheduled for December 3, 2003. |
REG-138495-02(PDF, 52K) |
IRB #2003-37(HTML) |
Sept. 15, 2003 |
T.D. 9069(PDF, 52K) |
Temporary and proposed regulations under section 1.280F of the Code provide relief from the dollar limits on depreciation imposed by section 280F(a) to taxpayers that use light trucks or vans in their trade or business by amending the definition of "passenger automobile" in order to exclude vans and light trucks that are "qualified nonpersonal use vehicles" as defined in section 1.274-5T(k). |
REG-136890-02(PDF, 52K) |
IRB #2003-49(HTML) |
Dec. 8, 2003 |
T.D. 9095(PDF, 52K) |
Final, temporary, and proposed regulations under section 461 of the Code clarify that the transfer of a taxpayer's note or promise to provide property or services in the future is not a transfer for the satisfaction of a contested liability under section 461(f). A transfer of a taxpayer's stock or the stock or note of a related party also is not a transfer for the satisfaction of a contested liability under section 461(f). The temporary regulations further provide that, in general, economic performance does not occur when a taxpayer transfers money or other property to a trust, escrow account, or court to provide for the satisfaction of a contested workers compensation, tort, or other payment liability. A public hearing on the proposed regulations is scheduled for March 23, 2004. |
REG-133791-02(PDF, 166K) |
IRB #2003-35(HTML) |
Sept. 2, 2003 |
N/A |
Taxpayers may receive a tax credit for certain expenses incurred in conducting qualified research. Proposed regulations under section 41 of the Code provide guidance on the proper method for computing and allocating the research credit for members of a controlled group of corporations or a group of trades or businesses under common control. A public hearing is scheduled for November 13, 2003. REG-105606-99 withdrawn. |
REG-132760-03 (PDF, 24K) |
IRB #2003-43(HTML) |
Oct. 27, 2003 |
T.D. 9089(PDF, 24K) |
Temporary and proposed regulations under section 1502 of the Code provide guidance concerning how a corporation that is a member of a consolidated group reduces its tax attributes when that member realizes discharge of indebtedness income that is excluded from gross income under section 108. |
REG-132483-03(PDF, 135K) |
IRB #2003-34(HTML) |
Aug. 25, 2003 |
N/A |
Proposed regulations under section 141 of the Code revise the definition of nonqualified bonds contained in regulations section 1.141-12 by reducing the amount of outstanding bonds that are nonqualified bonds. Second, the proposed regulations simplify the rules for determining which bonds will be treated as the nonqualified bonds for purposes of the remedial action rules under sections 1.141-12 and 1.142-2. Finally, they clarify the remedial action rules applicable to bonds issued prior to May 16, 1997 (the effective date of the current private activity bond regulations). A public hearing is scheduled for November 4, 2003. Rev. Proc. 93-17 obsolete for actions that occur on or after May 16, 1997. |
REG-131997-02(PDF, 164K) |
IRB #2003-33(HTML) |
Aug. 18, 2003 |
N/A |
Proposed regulations under section 42 of the Code concerning the low-income housing tax credit make amendments to existing regulations to reflect statutory changes made by the Community Renewal Tax Relief Act of 2000. A public hearing is scheduled for September 23, 2003. |
REG-131478-02(PDF, 23K) |
IRB #2003-13(HTML) |
March 31, 2003 |
T.D. 9048(PDF, 23K) |
Final, temporary, and proposed regulations under section 1502 of the Code redetermine the basis of stock of a subsidiary member of a consolidated group immediately prior to certain transfers of such stock and certain deconsolidations of a subsidiary member. In addition, the temporary regulations suspend certain losses recognized on the disposition of stock of a subsidiary member. A public hearing on the proposed regulations is scheduled for June 20, 2003. |
REG-130262-03(PDF, 75K) |
IRB #2003-37(HTML) |
Sept. 15, 2003 |
N/A |
Proposed regulations under section 1502 of the Code revise the rules for determining the basis of the stock of the former common parent of a consolidated group after a group structure change. Under the current regulations, the acquiring corporation's basis in the stock of the former common parent is generally redetermined to reflect the former parent's net asset basis. These proposed modifications permit the basis of stock acquired in a fully taxable transaction to reflect the cost of the acquired stock. |
REG-129709-03(PDF, 105K) |
IRB #2003-35(HTML) |
Sept. 2, 2003 |
T.D. 9081(PDF, 105K) |
Temporary and proposed regulations under section 409(p) of the Code provide guidance concerning the requirements for employee stock ownership plans (ESOPs) holding stock of Subchapter S corporations. A public hearing on the proposed regulations is scheduled for November 20, 2003. |
REG-128203-02(PDF, 161K) |
IRB #2003-41(HTML) |
Oct. 14, 2003 |
N/A |
Proposed regulations under section 460 of the Code provide guidance regarding the income tax consequences of certain partnership transactions involving contracts accounted for under a long-term contract method of accounting. |
REG-126485-01(PDF, 24K) |
IRB #2003-9(HTML) |
March 3, 2003 |
T.D. 9038(PDF, 24K) |
Temporary and proposed regulations under section 368 of the Code provide guidance with respect to statutory mergers and consolidations. These regulations also provide that the merger of a domestic corporation into a domestic disregarded entity can qualify as a statutory merger or consolidation. A public hearing on the proposed regulations is scheduled for May 21, 2003. |
REG-126016-01(PDF, 31K) |
IRB #2003-7(HTML) |
Feb. 18, 2003 |
N/A |
Proposed regulations under sections 6662 and 6664 of the Code limit the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or that they have taken a position based upon a regulation being invalid. The regulations also clarify existing regulations with respect to the facts and circumstances that the IRS will consider in determining whether a taxpayer acted with reasonable cause and in good faith in relying on an opinion or advice. |
REG-125638-01(PDF, 189K) |
IRB #2003-5(HTML) |
Feb. 3, 2003 |
N/A |
Proposed regulations explain how section 263(a) of the Code applies to amounts paid to acquire, create, or enhance intangible assets. The regulations also provide safe harbor amortization under section 167(a) for certain intangible assets and explain the manner in which taxpayers may deduct debt issuance costs. A public hearing is scheduled for April 22, 2003. |
REG-124069-02(PDF, 30K) |
IRB #2003-7(HTML) |
Feb. 18, 2003 |
T.D. 9033(PDF, 30K) |
Final, temporary, and proposed regulations under section 6038 of the Code provide that a United States partner must follow the filing requirements that are specified in the instructions for Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships, when the United States partner must file Form 8865 and the foreign partnership completes and files Form 1065, U.S. Return of Partnership Income, or Form 1065-B, U.S. Return for Electing Large Partnerships. This amendment would facilitate revisions to the filing requirements such as electronic filing for Form 8865. A public hearing on the proposed regulations is scheduled for March 12, 2003. |
REG-122917-02(PDF, 262K) |
IRB #2003-27(HTML) |
July 7, 2003 |
N/A |
Proposed regulations under sections 421, 422, 424, and 6039 of the Code provide guidance to taxpayers concerning statutory stock options. A public hearing is scheduled for September 2, 2003. EE-86-88 (LR-279-81, 1984-1 C.B. 715) withdrawn. |
REG-121122-03(PDF, 69K) |
IRB #2003-37(HTML) |
Sept. 15, 2003 |
N/A |
Proposed regulations under section 1042 of the Code provide guidance concerning the notarized statement of purchase requirements for taxpayers electing to defer gain from the sale of certain stock to an employee stock ownership plan. |
REG-116914-03(PDF, 60K) |
IRB #2003-32(HTML) |
Aug. 11, 2003 |
T.D. 9067(PDF, 60K) |
Temporary and proposed regulations under section 83 of the Code clarify and amend existing regulations to address the transfers of compensatory stock options to related persons. The regulations provide that the transfer of a compensatory stock option to a related person will not be treated as an arm's length transaction for purposes of section 1.83-7 of the regulations. |
REG-116641-01(PDF, 43K) |
IRB #2003-8(HTML) |
Feb. 24, 2003 |
N/A |
Proposed regulations under sections 3406 and 6724 of the Code provide guidance relating to the Taxpayer Identification Number (TIN) Matching Program and to information reporting requirements, information reporting penalties, and backup withholding requirements for payment card transactions. The regulations provide that backup withholding does not apply to payment card transactions if the reportable payments are made through a Qualified Payment Card Agent (QPCA) and the payee is a qualified payee. The regulations also provide special Taxpayer Identification Number (TIN) solicitation rules under section 6724 for payments made through a QPCA. A public hearing is scheduled for May 21, 2003. |
REG-115472-03(PDF, 51K) |
IRB #2003-50(HTML) |
Dec. 15, 2003 |
T.D. 9094(PDF, 51K) |
Final, temporary, and proposed regulations under section 6031(a) of the Code allow the Commissioner to publish in the Internal Revenue Bulletin guidance that excepts, from the partnership income tax reporting requirements, partnerships whose income is primarily from tax-exempt bonds. |
REG-113112-03(PDF, 48K) |
IRB #2003-40(HTML) |
Oct. 6, 2003 |
T.D. 9080(PDF, 48K) |
Final, temporary, and proposed regulations under section 108 of the Code clarify that, in the case of a transaction described in section 381(a) that ends a year in which the distributor or transferor corporation excludes COD income from gross income under section 108(a), any tax attributes to which the acquiring corporation succeeds under section 381, and the basis of property acquired by the acquiring corporation in the transaction, shall reflect the reductions required by sections 108 and 1017. |
REG-113007-99(PDF, 119K) |
IRB #2003-23(HTML) |
June 9, 2003 |
N/A |
Proposed regulations under section 141 of the Code relate to the definition of private activity bond applicable to tax-exempt bonds issued by state and local governments. The proposed regulations affect issuers of tax-exempt bonds and provide needed guidance for applying the private activity bond restrictions to refunding issues. The proposed regulations adopt a general approach for applying the private activity bond restrictions to refunding issues based on the principles for measuring private activity contained in section 141 and the final regulations thereunder. A public hearing is scheduled for September 9, 2003. |
REG-112039-03(PDF, 115K) |
IRB #2003-35(HTML) |
Sept. 2, 2003 |
N/A |
Proposed regulations under section 411 of the Code amend section 1.411(d)-4, of the regulations to reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001. The proposed regulations retain rules under which a defined contribution plan could be amended, but remove the 90-day notice condition. |
REG-110896-98(PDF, 82K) |
IRB #2003-51(HTML) |
Dec. 22, 2003 |
N/A |
Proposed regulations under section 664(b) of the Code concern the characterization of distributions from charitable remainder trusts. The proposed regulations reflect changes made to income tax rates, including the rates applicable to capital gains and certain dividends, by the Taxpayer Relief Act of 1997, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Jobs and Growth Tax Relief Reconciliation Act of 2003. A public hearing is scheduled for March 9, 2004. |
REG-108676-03(PDF, 29K) |
IRB #2003-36(HTML) |
Sept. 8, 2003 |
T.D. 9063(PDF, 29K) |
Temporary and proposed regulations under section 382 of the Code affect loss corporations and provide guidance on whether a loss corporation has an ownership change where a qualified trust described in section 401(a) distributes an ownership interest in an entity. |
REG-108639-99(PDF, 785K) |
IRB #2003-35(HTML) |
Sept. 2, 2003 |
N/A |
Proposed regulations under sections 401(k) and 401(m) of the Code provide guidance on the requirements for certain retirement plans containing cash or deferred arrangements and providing for matching contributions or employee after-tax contributions. These regulations affect certain plans or contracts providing for elective deferrals under section 401(k), matching contributions or employee after-tax contributions under section 401(m), and participants eligible under these plans or contracts. A public hearing is scheduled for November 12, 2003. |
REG-108524-00 (PDF, 250K) |
IRB #2003-42(HTML) |
Oct. 20, 2003 |
N/A |
Proposed regulations under section 1446 of the Code provide guidance with respect to the withholding tax liability of a partnership with income that is effectively connected with its United States trade or business, all or a portion of which is allocable under section 704 to foreign partners. Rev. Procs. 8931 and 9266 obsoleted. |
REG-107618-02(PDF, 87K) |
IRB #2003-27(HTML) |
July 7, 2003 |
T.D. 9061(PDF, 87K) |
Final, temporary, and proposed regulations under section 6081 of the Code provide an automatic extension of time to file certain information returns and exempt organization returns. The temporary regulations remove the requirement for a signature and an explanation to obtain an automatic extension of time to file these returns. |
REG-106736-00(PDF, 210K) |
IRB #2003-28(HTML) |
July 14, 2003 |
T.D. 9062(PDF, 210K) |
Temporary and proposed regulations under section 752 of the Code concern the assumption of a partner's liability, by a partnership, that is not taken into account under section 752(a) and (b) (section 1.752-7 liability). The proposed regulations contained in section 1.752-7 require a partner who has a section 1.752-7 liability assumed by a partnership to reduce the partner's outside basis in the partnership interest by the remaining amount of the section 1.752-7 liability (but not below the adjusted value of that interest) where there is a sale of the partnership interest, a liquidation of the partnership interest, or an assumption of the contingent liability by another partner. The proposed and temporary regulations contained in section 1.752-6T apply section 358(h) to partnerships for the period between October 18, 1999, and June 24, 2003. A public hearing on the proposed regulations is scheduled for October 14, 2003. |
REG-106486-98(PDF, 206K) |
IRB #2003-42(HTML) |
Oct. 20, 2003 |
N/A |
Proposed regulations under section 1275 of the Code provide for the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayer's functional currency. The regulations generally provide that taxpayers should apply the existing rules to nonfunctional currency contingent payment debt instruments in the currency in which the debt instrument is denominated, and should then translate those amounts into the taxpayers' functional currency using the rules provided. In addition, a rule is provided to determine the currency in which the calculations should be made in the case of a multi-currency debt instrument. A public hearing is scheduled for December 3, 2003. |
REG-104385-01(PDF, 29K) |
IRB #2003-12(HTML) |
March 24, 2003 |
N/A |
Proposed regulations under section 168 of the Code provide guidance on the normalization requirements applicable to electric utilities that benefit (or have benefitted) from accelerated depreciation methods or from the investment tax credit permitted under pre-1991 law. A public hearing is scheduled for June 25, 2003. |
REG-103809-03(PDF, 76K) |
IRB #2003-26(HTML) |
June 30, 2003 |
T.D. 9060(PDF, 76K) |
Temporary and proposed regulations incorporate and clarify the phrase "return information reflected on returns" in conformance with the terms of section 6103(j)(5) of the Code. The temporary regulations also remove certain items of return information that the Department of Agriculture no longer needs for conducting the census of Agriculture. |
REG-103580-02(PDF, 95K) |
IRB #2003-9(HTML) |
March 3, 2003 |
N/A |
Proposed regulations under section 721 of the Code describe the tax consequences of certain noncompensatory options and convertible instruments issued by partnerships. The regulations provide that section 721 generally applies to the exercise of a noncompensatory option. The regulations also modify the rules under section 704(b) regarding the determination of the partners' distributive shares of partnership items, and provide that the holder of a noncompensatory option is treated as a partner under certain circumstances. A public hearing is scheduled for May 20, 2003. |
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