New Issues Selected for
IRS Industry Issue Resolution Program

WASHINGTON - The Internal Revenue Service and the Treasury Department today announced new tax issues selected for resolution under the Industry Issue Resolution (IIR) Program. These issues have been identified by business taxpayers, industry associations, and other interested parties as being frequently disputed or burdensome.

The selections for the 2003 IIR Program are:

• Application of Section 382 to U.S. branches of foreign banks (included on the Guidance Priority List as an item under “Guidance under Section 382”).
• Guidance on health care provider incentive payments.
• Guidance on tax treatment of vendor allowances involving buildouts and image upgrades.
• Guidance under Section IRC 4051(a) (2) and (3) regarding “suitable for use.”
• Guidance on reporting procedures for successor organizations following Rev. Proc. 96-60.

“The Industry Issues Resolution program provides a common-sense approach to resolving tax issues identified by the business community,” said Large and Mid-Size Business Division Commissioner Deborah M. Nolan. “Businesses and their representatives meet with IRS legal and technical experts to present their issues. We then try to find a way to resolve these areas of controversy in a way that will be less burdensome to taxpayers and allow us to focus our enforcement resources more appropriately.”

IIR project selections are based on the criteria set forth in Revenue Procedure 2003-36. For each issue selected, a multi-functional team of IRS, Chief Counsel, and Treasury personnel will be assembled. The teams will gather and analyze relevant facts from industry groups and taxpayers for each issue and recommend guidance.

Requests for guidance on tax issues under the IIR program can be submitted at any time to IIR@irs.gov. Submissions received are reviewed semi-annually with selections next being made from issues submitted by August 31, 2003.

Revenue Procedure 2003-36 and related information is available at www.irs.gov. Attached is detailed information regarding the issues submitted for the IIR program.

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