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IRB 2004-27

Table of Contents
(Dated July 6, 2004)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2004-27. 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

Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.

Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for July 2004.

Final regulations amend the regulations under sections 263A and 448 of the Code to allow taxpayers changing a method of accounting under those sections to take any adjustment under section 481(a) resulting from the change into account over the same number of taxable years that applies to taxpayers changing a method of accounting under the general administrative procedures issued by the Service.

This notice provides transition relief for individuals in states where high deductible health plans (HDHPs) are not available because state laws require health plans to provide certain benefits with a low or no deductible.

This procedure informs owners of qualified low-income housing projects how to obtain the waiver of annual recertification of tenant income provided in section 42(g)(8)(B) of the Code. New Form 8877, Request for Waiver of Annual Income Recertification Requirement for the Low-Income Housing Credit, will be used to make the request. Rev. Proc. 94-64 superseded.

EMPLOYEE PLANS

Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of the Code, if an individual who has coverage for retiree health benefits (“covered individual”) accepts an offer from the employer to waive the coverage in exchange for enhanced pension benefits.

Age-discrimination regulations; proposed withdrawal. Proposed regulations that would have interpreted the provisions of sections 411(b)(1)(H) and 411(b)(2) of the Code will be withdrawn. The mandatory technical advice cases involving cash balance conversions will not be processed while these issues are under consideration by Congress.

EXEMPT ORGANIZATIONS

Mid-South Transportation Management, Inc., of Cincinnati, OH, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

ESTATE TAX

Tax reimbursement clause. This ruling addresses issues presented with respect to a trust whose grantor is treated as its owner. It addresses the gift tax consequences when the grantor pays the income tax attributable to the inclusion of the trust’s income in the grantor’s taxable income. It also addresses the estate tax consequences if, pursuant to the governing instrument or applicable local law, the grantor may or must be reimbursed by the trust for that income tax.

GIFT TAX

Tax reimbursement clause. This ruling addresses issues presented with respect to a trust whose grantor is treated as its owner. It addresses the gift tax consequences when the grantor pays the income tax attributable to the inclusion of the trust’s income in the grantor’s taxable income. It also addresses the estate tax consequences if, pursuant to the governing instrument or applicable local law, the grantor may or must be reimbursed by the trust for that income tax.



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