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IRB 2003-50

Table of Contents
(Dated December 15, 2003)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2003-50. 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

Qualified conservation contribution. This ruling clarifies the Service's position that a trust is not allowed either a charitable deduction under section 642(c) or a distribution deduction under section 661(a)(2) of the Code with respect to a contribution to charity of trust principal that meets the requirements of a qualified conservation contribution under section 170(h). Rev. Rul. 68-667 amplified.

REG-115472-03

Final, temporary, and proposed regulations under section 6031(a) of the Code allow the Commissioner to publish in the Internal Revenue Bulletin guidance that excepts, from the partnership income tax reporting requirements, partnerships whose income is primarily from tax-exempt bonds.

This notice describes the new simplified reporting regime for taxpayers who hold interests in Canadian registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs). The new reporting regime, which is effective for taxable years beginning after December 31, 2002, is in lieu of the Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner, filing obligations that otherwise apply to U.S. citizens and resident aliens who hold interests in RRSPs and RRIFs and to the custodians of such plans. Notices 97-34 (section II-E), 2003-25, and 2003-57 superseded.

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. This notice provides guidance for persons required to make returns and provide statements under section 6042 (e.g., Form 1099-DIV) regarding distributions with respect to securities issued by a foreign corporation, and for individuals receiving such statements. The notice also describes when a security (or an American depositary receipt in respect to such security) issued by a foreign corporation that is other than ordinary or common stock (such as preferred stock) will satisfy the readily tradable test.

This announcement withdraws proposed regulations (REG-209817-96, 1997-1 C.B. 754) concerning the treatment of obligation-shifting transactions. REG-209817-96 withdrawn.

This document contains corrections to proposed regulations (REG-133791-02, 2003-35 I.R.B. 493) under section 41 of the Code relating to the computation and allocation of the credit for increasing research activities for members of a controlled group of corporations or a group of trades or businesses under common control.

This document contains corrections to final regulations (T.D. 9078, 2003-39 I.R.B. 630) under section 1361 of the Code relating to a qualified subchapter S trust election for testamentary trust.

EMPLOYEE PLANS

Professional employer organizations; employee leasing; plan qualification. This procedure describes certain transitional rules that may be used by defined contribution retirement plans of professional employer organizations. Rev. Proc. 2002-21 amplified.

EXEMPT ORGANIZATIONS

Code Red Cross Training of San Ramon, CA, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

EMPLOYMENT TAX

This notice publishes the tier 2 Railroad Retirement Tax Act (RRTA) tax rates for 2004 under sections 3201(b), 3221(b), and 3211(b) of the Internal Revenue Code for railroad employees, employers, and employee representatives, respectively. For 2004, the tier 2 tax rate on employees is 4.9 percent of compensation and the tier 2 tax rate on employers and employee representatives is 13.1 percent of compensation.

ADMINISTRATIVE

REG-115472-03

Final, temporary, and proposed regulations under section 6031(a) of the Code allow the Commissioner to publish in the Internal Revenue Bulletin guidance that excepts, from the partnership income tax reporting requirements, partnerships whose income is primarily from tax-exempt bonds.

This notice describes the new simplified reporting regime for taxpayers who hold interests in Canadian registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs). The new reporting regime, which is effective for taxable years beginning after December 31, 2002, is in lieu of the Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, and Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner, filing obligations that otherwise apply to U.S. citizens and resident aliens who hold interests in RRSPs and RRIFs and to the custodians of such plans. Notices 97-34 (section II-E), 2003-25, and 2003-57 superseded.



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