REG-132760-03

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-141402-02

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.

Section 1(h) of the Code provides that certain dividends paid to an individual shareholder from either a domestic corporation or a “qualified foreign corporation” are subject to tax at the reduced rates applicable to certain capital gains. The term “qualified foreign corporation” is defined to include possessions corporations and certain foreign corporations that are eligible for benefits of certain United States income tax treaties. A foreign corporation that is not otherwise treated as a qualified foreign corporation will be so treated with respect to any dividend it pays if the stock with respect to which the dividend is paid is readily tradable on an established securities market in the United States. This notice defines, for dividends received on or after January 1, 2003, what it means to be readily tradable on an established securities market in the United States.

Steve Brashen Foundation of Bellevue, WA, Clove Hitch Foundation, Inc., of Pompano Beach, FL, and Spring Assistance for Educators of Houston, TX, no longer qualify as organizations to which contributions are deductible under section 170 of the Code.

This notice contains a proposed revenue procedure giving updated guidance to state and local government agencies on how they can serve as employment tax agents, under section 3504 of the Code, for participants in state or local government programs who employ home-care service providers to assist them in their homes. The Service seeks comments on the proposed revenue procedure. Notice 95-18 modified. Rev. Proc. 70-6 modified and superseded, in part. Rev. Proc. 80-4 modified and amplified.

This procedure revokes revenue procedures which describe procedures previously used by the Service for providing copies of returns and return information pursuant to sections 6103 and 6104 of the Code, and states where the current procedures are published. Rev. Procs. 66-3, 84-71, 85-56, 87-21, 94-52, and 97-11 revoked.

Optional standard mileage rates. This procedure announces 37.5 cents as the optional rate for deducting or accounting for expenses for business use of an automobile, 14 cents as the optional rate for use of an automobile as a charitable contribution, and 14 cents as the optional rate for use of an automobile as a medical or moving expense for 2004. It provides rules for substantiating the deductible expenses of using an automobile for business, moving, medical, or charitable purposes. The procedure also revises the limitation on simultaneous use of multiple automobiles to allow a taxpayer using up to four vehicles simultaneously to use the standard mileage rate. Rev. Proc. 2002-61 superseded.