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IRB 2003-41

Table of Contents
(Dated October 14, 2003)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2003-41. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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Highlights of This Issue

 

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2003.

Final and temporary regulations require the use of taxpayer identifying numbers to properly identify foreign taxpayers for which submissions are made for the reduction or elimination of tax under sections 897 and 1445 of the Code. The regulations also address other miscellaneous items under section 1445.

Final regulations under sections 148 and 141 of the Code relate to the definition of investment-type property and private loan for the arbitrage and private activity restrictions, respectively, applicable to tax-exempt bonds issued by state and local governments. Final regulations relate to certain natural gas and electricity prepayment transactions.

Final regulations under section 883 of the Code concern when a foreign corporation engaged in the international operation of ships or aircraft may exempt its U.S source income from federal income tax. The rules apply to a corporation organized in a foreign country that grants a reciprocal exemption to U.S. corporations, if the foreign corporation satisfies certain ownership requirements.

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.

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.

Qualified community development entity (CDE) loan purchases. The Treasury Department and the Service announce that they will clarify and amend the definition of a qualified low-income community investment under section 1.45D-1T(d)(1)(ii) of the regulations.

TAX CONVENTIONS

This announcement provides the rates for various types of income under new tax conventions. The United States recently exchanged instruments of ratification for a new income tax treaty with the United Kingdom and new protocols for the income tax treaties with Australia and Mexico.

ADMINISTRATIVE

Final regulations under section 7122 of the Code impose a $150.00 user fee for the processing of offers to compromise effective November 1, 2003. The user fee does not apply to offers based on doubt as to liability or offers made by low income taxpayers. The fee will be applied against the amount of the offer or refunded to the taxpayer if the offer is accepted to promote effective tax administration or accepted based on doubt as to collectibility where there has been a determination that, although an amount greater than the amount offered could be collected, collection of more than the amount offered would create economic hardship within the meaning of regulations section 301.6343-1.

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.



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