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 December 2003.

REG-136890-02

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.

Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contributions to defined benefit plans and permitted disparity.

A list is provided of organizations now classified as private foundations.

This notice sets out transactions that have been identified by the Treasury Department and the IRS as “listed transactions” for purposes of the regulations under sections 6011 and 6111 of the Code. Notice 2001-51 supplemented and superseded.

Transfer to trusts to provide for the satisfaction of contested liabilities. This notice provides that certain transfers to trusts to provide for the satisfaction of contested liabilities under section 461(f) of the Code are listed transactions.

Cost-of-living adjustments for 2004. This procedure provides cost-of-living adjustments for the tax rate tables for individuals, estates, and trusts, the standard deduction amounts, the personal exemption, and several other items that use the adjustment method provided for the tax rate tables. The Service also provides the adjustment for eligible long-term care premiums and another item that uses the adjustment method provided for eligible long-term care premiums.

This document provides updated requirements relating to the composite substitute statement procedures, outlined in Publication 1179, General Rules and Specifications for Substitute Forms 1096, 1098, 1099, 5498, W-2G and 1042-S. These procedures have been revised to allow composite substitute statements to be furnished for Form 1099-DIV and Form 1099-MISC reporting substitute payments in lieu of dividends. All other rules and specifications for preparing substitute forms remain the same. Rev. Proc. 2003-28, 2003-16 I.R.B. 759, modified in part.