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.
INCOME TAX
Notice 2003-67(PDF, 60K)
This notice provides guidance to brokers and individuals for information reporting of payments in lieu of dividends.
T.D. 9080(PDF, 81K)
REG-113112-03(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.
Rev. Rul. 2003-105(PDF, 55K)
Split-dollar life insurance arrangements. Certain previously published revenue rulings are obsoleted to the extent described in this ruling. The previously published rulings are obsoleted in light of T.D. 9092, which provides comprehensive final regulations regarding the federal income, gift, and employment taxation of split-dollar life insurance arrangements. Rev. Ruls. 78-420 and 79-50 obsoleted. Rev. Rul. 66-610 partially obsoleted.
T.D. 9083(PDF, 390K)
Final regulations under section 280G of the Code provide rules for the treatment of golden parachute payments. A golden parachute payment includes certain compensation payments made to certain individuals in connection with a change in ownership or control of a corporation. These rules are effective for payments made on a change in control if the change in control occurs on or after January 1, 2004.
T.D. 9084(PDF, 68K)
Final regulations under section 1503(d) of the Code provide guidance regarding the events that require the recapture of dual consolidated losses. The regulations will facilitate compliance by taxpayers with the dual consolidated loss provisions. The regulations generally provide that certain events will not trigger recapture of a dual consolidated loss or payment of the associated interest charge. The regulations provide for the filing of certain agreements in such cases. This document also makes clarifying and conforming changes to the current regulations.
GIFT TAX
Rev. Rul. 2003-105(PDF, 55K)
Split-dollar life insurance arrangements. Certain previously published revenue rulings are obsoleted to the extent described in this ruling. The previously published rulings are obsoleted in light of T.D. 9092, which provides comprehensive final regulations regarding the federal income, gift, and employment taxation of split-dollar life insurance arrangements. Rev. Ruls. 78-420 and 79-50 obsoleted. Rev. Rul. 66-610 partially obsoleted.
EMPLOYEE PLANS
Announcement 2003-54(PDF, 102K)
Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonbank custodians within the meaning of section 1.408-2(e) of the regulations. In addition, the announcement contains instructions on how errors in the list may be corrected.
T.D. 9079(PDF, 216K)
Final regulations under section 419A of the Code provide guidance regarding whether a welfare benefit fund is part of a ten-or-more employer plan described in section 419A(f)(6).
EMPLOYMENT TAX
Rev. Rul. 2003-105(PDF, 55K)
Split-dollar life insurance arrangements. Certain previously published revenue rulings are obsoleted to the extent described in this ruling. The previously published rulings are obsoleted in light of T.D. 9092, which provides comprehensive final regulations regarding the federal income, gift, and employment taxation of split-dollar life insurance arrangements. Rev. Ruls. 78-420 and 79-50 obsoleted. Rev. Rul. 66-610 partially obsoleted.
EXCISE TAX
T.D. 9083(PDF, 390K)
Final regulations under section 280G of the Code provide rules for the treatment of golden parachute payments. A golden parachute payment includes certain compensation payments made to certain individuals in connection with a change in ownership or control of a corporation. These rules are effective for payments made on a change in control if the change in control occurs on or after January 1, 2004.
TAX CONVENTIONS
Announcement 2003-58(PDF, 33K)
Austria agreement on deferred payments. A copy of the news release issued by the Director, International (U.S. Competent Authority) on August 27, 2003, is set forth.
Announcement 2003-59(PDF, 37K)
This announcement contains the text of a competent authority agreement with the Swiss government that provides guidance on the application of the Limitation on Benefits (LOB) article of the income tax treaty and accompanying revised Memorandum of Understanding (MOU) between the United States and the Swiss Confederation. The agreement sets forth the categories of U.S. residents that will be taken into account for purposes of the derivative benefits ownership tests of the revised MOU.
ADMINISTRATIVE
Notice 2003-65(PDF, 101K)
This notice provides two alternative safe harbors regarding the identification of built-in items under section 382(h) of the Code and requests comments on this subject. Notice 87-79 modified.
REG-208199-91(PDF, 88K)
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.
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