Annuity payments. This ruling addresses the taxation of income received by residents of Puerto Rico and nonresident aliens under life insurance and annuity contracts issued by a foreign branch of a U.S. life insurance company. The ruling holds that income received by nonresident aliens under life insurance and annuity contracts issued by a foreign branch of a U.S. life insurance company is U.S.-source FDAP income. The ruling also holds that income received by bona fide residents of Puerto Rico under life insurance or annuity contracts issued by a Puerto Rican branch of a U.S. life insurance company is U.S.-source income.

Dual resident company. This ruling concludes that a dual resident company, resident in both Country Y and Country X under the domestic laws of those countries, is not entitled to claim benefits under the U.S. income tax convention with Country X if it is treated as a resident of Country Y and not of Country X for purposes of the income tax convention between Country X and Country Y and, as a result, is not liable to tax in Country X by reason of its residence. Rev. Rul. 73-354 obsoleted.

Corporate reorganizations; exchange of debt instruments. This ruling discusses the exchange of a debt security for a debt instrument in a reorganization.

Corporate distributions of property. This ruling addresses the tax consequences of the distribution by a subsidiary to its parent of parent indebtedness that the subsidiary previously purchased from a party unrelated to the parent.

This procedure provides alternative disclosure procedures that are deemed to satisfy a taxpayer’s disclosure obligations under section 1.6011-4 of the regulations for transactions with a significant book-tax difference under section 1.6011-4(b)(6). Taxpayers also may continue to follow the disclosure procedures provided in section 1.6011-4 for disclosing transactions described in section 1.6011-4(b)(6).

Minimum funding standards; amortization; extensions. This procedure sets forth guidelines for requesting extensions of the amortization period of the minimum funding standards with respect to defined benefit plans under section 412(e) of the Code. Rev. Proc. 79-61 superseded. Rev. Proc. 2004-4 modified.

Proposed regulations provide guidance for making the election under section 2632(c) of the Code to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption apply with regard to certain transfers to a GST trust. The regulations also provide guidance for making the election to treat a trust as a GST trust.

This procedure provides a simplified alternate method for certain taxpayers to obtain an extension of time under section 301.9100-3 of the regulations to make an allocation of the generation-skipping transfer exemption in accordance with section 2642(b)(1) of the Code. Notice 2001-50 modified.

Proposed regulations provide guidance for making the election under section 2632(c) of the Code to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption apply with regard to certain transfers to a GST trust. The regulations also provide guidance for making the election to treat a trust as a GST trust.

This procedure provides a simplified alternate method for certain taxpayers to obtain an extension of time under section 301.9100-3 of the regulations to make an allocation of the generation-skipping transfer exemption in accordance with section 2642(b)(1) of the Code. Notice 2001-50 modified.

Final regulations under section 3406 of the Code provide guidance on the information reporting and backup withholding requirements for payment card transactions made through a Qualified Payment Card Agent (QPCA). These regulations provide a limited exception to backup withholding for reportable payments made through a QPCA.

This procedure provides the requirements for a payment card organization to request and obtain an IRS determination that it is a Qualified Payment Card Agent (QPCA) for purposes of the related final regulations under sections 3406 and 6724 of the Code that address the information reporting and backup withholding requirements for payment card transactions.

This document establishes an optional procedure for payors who make payments in the course of their trade or business through payment cards to determine whether the payments are reportable under sections 6041 and 6041A of the Code and the regulations thereunder. This procedure classifies businesses by Merchant Category Codes (MCCs), or other similar codes, according to whether they predominantly furnish services or predominantly provide goods.

Disclosure of returns and return information. Rev. Rul. 54-379 concludes that heirs at law, next of kin, or beneficiaries who are distributees of a person who dies intestate under state law have a “material interest” to receive the decedent’s return information. The statute does not clearly address the application of the “material interest” standard in the context of a taxpayer who dies intestate. Rev. Rul. 54-379 superseded.

Disregarded entities. This ruling concludes that, if an eligible entity has two owners under local law, but one of the owners is, for federal tax purposes, disregarded as an entity separate from the other owner of the eligible entity, then the eligible entity cannot be classified as a partnership and is either disregarded as an entity separate from its owner or an association taxable as a corporation.

Final regulations under section 3406 of the Code provide guidance on the information reporting and backup withholding requirements for payment card transactions made through a Qualified Payment Card Agent (QPCA). These regulations provide a limited exception to backup withholding for reportable payments made through a QPCA.

This procedure provides the requirements for a payment card organization to request and obtain an IRS determination that it is a Qualified Payment Card Agent (QPCA) for purposes of the related final regulations under sections 3406 and 6724 of the Code that address the information reporting and backup withholding requirements for payment card transactions.

This document establishes an optional procedure for payors who make payments in the course of their trade or business through payment cards to determine whether the payments are reportable under sections 6041 and 6041A of the Code and the regulations thereunder. This procedure classifies businesses by Merchant Category Codes (MCCs), or other similar codes, according to whether they predominantly furnish services or predominantly provide goods.