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IRB 2004-20

Table of Contents
(Dated May 17, 2004)
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This is the table of contents of Internal Revenue Bulletin IRB 2004-20. 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

Royalties; information reporting. This ruling provides guidance concerning the reporting requirements of sections 6041 and 6050N of the Code for payments by publishers to literary agents on behalf of an author.

Final, temporary, and proposed regulations under section 704(b) of the Code provide guidance on the proper allocation of certain foreign tax expenditures of a partnership. A public hearing on the proposed regulations is scheduled for September 14, 2004.

Final, temporary, and proposed regulations under section 704(b) of the Code provide guidance on the proper allocation of certain foreign tax expenditures of a partnership. A public hearing on the proposed regulations is scheduled for September 14, 2004.

Final regulations under section 1296 of the Code provide procedures for certain U.S. persons holding marketable stock in a passive foreign investment company (PFIC) to elect mark to market treatment for that stock under section 1296 and related provisions of sections 1291 and 1295.

Final regulations provide that all activities are subject to the rule under section 465 of the Code that amounts borrowed from a person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest do not increase the amount at risk in the activity.

Proposed regulations under section 358 of the Code adopt a tracing approach in determining the basis of stock and securities received in transactions under sections 355, 368, and certain transactions that qualify under both section 351 and section 368.

Use of statistical sampling under section 274(n). This procedure provides the statistical sampling methodology by which a taxpayer may establish the amount of meal and entertainment expenses excepted from the 50% deduction disallowance of section 274(n)(1) of the Code.

EXEMPT ORGANIZATIONS

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



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