Tax assessment; partnership. The Supreme Court holds that the proper assessment against the partnership suffices to extend the statute of limitations to collect the tax in a judicial proceeding from the general partners who are liable for the payment of the partnership's debts. United States v. Galletti et al.

Health Savings Account (HSA) - interaction with other health arrangements. This ruling addresses the interaction between Health Savings Accounts (HSAs), health flexible spending arrangements (health FSAs), and health reimbursement arrangements (HRAs).

Credit card annual fees. This ruling holds that credit card annual fees are not interest for federal income tax purposes. Moreover, the ruling holds that credit card annual fees are includible in the gross income by the card issuer when they become due and payable by cardholders under the terms of the credit card agreements.

This notice explains how the changes to section 1(h) of the Code made by the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) apply to capital gain dividends paid (or accounted for as if paid) by regulated investment companies (RICs) and real estate investment trusts (REITs) in taxable years that end on or after May 6, 2003.

Changes in method of accounting for transfers to trusts under section 461(f). This document provides procedures for taxpayers to change their method of accounting for deducting under section 461(f) of the Code amounts transferred to trusts in transactions described in Notice 2003-77, 2003-49 I.R.B. 1182.

This document provides automatic consent procedures for taxpayers to change their method of accounting to a method that complies with Rev. Rul. 2004-52, in this Bulletin, or to the Ratable Inclusion Method for Credit Card Annual Fees described in this revenue procedure. Rev. Proc. 2002-9 modified and amplified.

This procedure describes conditions under which the Commissioner will allow a taxpayer to treat its income from credit card late fees as interest income on a pool of credit card loans. This document also provides automatic consent procedures for a taxpayer to change its method of accounting for credit card late fee income to a method that treats these fees as interest that creates or increases the amount of OID on a pool of credit card loans to which the fees relate. Rev. Proc. 2002-9 modified and amplified.

Joint ventures. This ruling illustrates the tax consequences for a section 501(c)(3) organization that enters into a joint venture with a for-profit organization as an insubstantial part of its activities.

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

Indian tribal government. This ruling provides clarification with regard to an Indian tribal government's ability to qualify as an eligible shareholder under section 1361 of the Code. Specifically, the ruling explains that a federally recognized Indian tribal government does not qualify as a permissible S corporation shareholder under section 1361(b)(1)(B) because it is not treated as an individual subject to individual income taxes under section 1 of the Code. The ruling also explains that a federally recognized Indian Tribe cannot qualify as a permissible S corporation shareholder under section 1361(c)(6) because it is neither a section 501(c)(3) organization, nor a section 401(a) qualified plan, profit-sharing, or stock bonus plan organization.

This procedure provides guidance to regulated investment companies (RICs) who must comply with the asset diversification rules of section 851(b)(3) of the Code. The procedure describes conditions under which a RIC may look through a repurchase agreement (repo) to government securities serving as the underlying collateral to treat itself as the owner of the government securities for purposes of these rules. The procedure is effective for repos held by a RIC on or after August 15, 2001.

This procedure provides a method of accounting under which taxpayers using an accrual method of accounting may defer including all or part of certain advance payments in gross income until the year after the year the payment is received. Rev. Proc. 71-21 modified and superseded and Rev. Proc. 2002-9 modified and amplified.

This announcement provides background information relating to Rev. Proc. 2004-34 in this Bulletin. Rev. Proc. 2004-34 provides a method of accounting under which taxpayers using an accrual method of accounting may defer including all or part of certain advance payments in gross income until the year after the year the payment is received.