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IRB 2004-45

Table of Contents
(Dated November 8, 2004)
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This is the table of contents of Internal Revenue Bulletin IRB 2004-45. 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

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 November 2004.

Modification of Rev. Rul. 95-63. Rev. Rul. 95-63, with respect to countries described in section 901(j)(2)(A) of the Code, is modified by providing that Iraq ceased to be described in that section on June 27, 2004. Rev. Rul. 95-63 modified.

Final regulations under section 6050P(c)(2)(D) of the Code provide guidance on the information reporting requirements for discharges of indebtedness by organizations that have a significant trade or business of lending money. These regulations provide that the lending of money is a significant trade or business if money is loaned on a regular and continuing basis.

Section 1(h)(11) of the Code provides that certain dividends paid to an individual shareholder from either a domestic corporation or a “qualified foreign corporation” are subject to tax at the reduced rates applicable to certain capital gains. This notice provides guidance for persons required to make returns and provide statements under section 6042 of the Code (e.g., Form 1099-DIV) regarding distributions with respect to securities issued by a foreign corporation, and for individuals receiving such statements. The notice also describes when a security (or an American depositary receipt in respect of such security) issued by a foreign corporation that is other than ordinary or common stock (such as preferred stock) will satisfy the readily tradable test.

This announcement notifies Archer MSA trustees of their obligation to report the number of Archer MSAs established between January 1, 2004, and June 30, 2004.

EXEMPT ORGANIZATIONS

This announcement is a public notice of the suspension of the federal tax exemption under section 501(p) of the Code of a certain organization that has been designated as supporting or engaging in terrorist activity or supporting terrorism. Contributions made to this organization during the period that the organization’s tax-exempt status is suspended are not deductible for federal tax purposes.

Michael & Laura Gallop Family Foundation of Agoura Hills, CA, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

ADMINISTRATIVE

This procedure provides specifications for filing Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, Electronically or Magnetically. The procedure will be reprinted as the current revision of Publication 1187. Rev. Proc. 2003-83 superseded.



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