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IRB 2003-51

Table of Contents
(Dated December 22, 2003)
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This is the table of contents of Internal Revenue Bulletin IRB 2003-51. 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

Proposed regulations under section 664(b) of the Code concern the characterization of distributions from charitable remainder trusts. The proposed regulations reflect changes made to income tax rates, including the rates applicable to capital gains and certain dividends, by the Taxpayer Relief Act of 1997, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Jobs and Growth Tax Relief Reconciliation Act of 2003. A public hearing is scheduled for March 9, 2004.

Proposed regulations under section 704(c) of the Code provide guidance with respect to the tax treatment of installment obligations and property acquired pursuant to a contract under sections 704(c) and 737.

Option; foreign currency. This notice describes a transaction in which a taxpayer claims a loss upon the assignment of a section 1256 contract to a charity, but fails to report the recognition of gain when the taxpayer's obligation under an offsetting non-section 1256 contract terminates. The notice identifies the described transaction and those that are substantially similar to that transaction as listed transactions. The notice holds that the taxpayer must either recognize gain when the option is assumed by the charity or must recognize the premium at the time the taxpayer's obligations under the option contract terminate.

EMPLOYEE PLANS

Weighted average interest rate update. The weighted average interest rate for December 2003 and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth.

EXEMPT ORGANIZATIONS

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

ESTATE TAX

Proposed regulations under section 664(b) of the Code concern the characterization of distributions from charitable remainder trusts. The proposed regulations reflect changes made to income tax rates, including the rates applicable to capital gains and certain dividends, by the Taxpayer Relief Act of 1997, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Jobs and Growth Tax Relief Reconciliation Act of 2003. A public hearing is scheduled for March 9, 2004.

GIFT TAX

Proposed regulations under section 664(b) of the Code concern the characterization of distributions from charitable remainder trusts. The proposed regulations reflect changes made to income tax rates, including the rates applicable to capital gains and certain dividends, by the Taxpayer Relief Act of 1997, the Internal Revenue Service Restructuring and Reform Act of 1998, and the Jobs and Growth Tax Relief Reconciliation Act of 2003. A public hearing is scheduled for March 9, 2004.

ADMINISTRATIVE

This document removes final regulations sections 1.6152-1 and 301.6152-1 pertaining to section 6152 of the Code.

This document contains corrections to proposed regulations (REG-128203-02, 2003-41 I.R.B. 828) under section 460 of the Code that provide guidance regarding the income tax consequences of certain partnership transactions involving contracts accounted for under a long term contract method of accounting.

This document contains corrections to temporary regulations (T.D. 9090, 2003-43 I.R.B. 891) under section 448(d)(5) of the Code that provide guidance regarding the use of a nonaccrual-experience method by taxpayers using an accrual method of accounting and performing services.

This document contains corrections to proposed regulations (REG-106486-98, 2003-42 I.R.B. 853) under section 1275 of the Code that provide for the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayer's functional currency.



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