The Bulletin Index-Digest System & Highlights Summaries

Securities Transactions

The following items are Summaries from the "Highlights" page of each Internal Revenue Bulletin, the official weekly publication of the IRS. The Summaries begin in January 1994 and have been compiled through the date shown above. There are no links for the documents issued in 1994 and 1995, but beginning in January 1996 there are links to the full text of all the actual documents. These documents have been extracted from IRS's Internal Revenue Bulletins and are in the Adobe Acrobat PDF format. You will need the appropriate Acrobat Reader installed on your computer to view or print the PDF files.

Notice 97-66 from IR Bulletin No.1997-48
Securities lending transaction notice. Guidance is provided to payors of substitute interest payments made after November 13, 1997, and before January 1, 1999, to comply with the statement requirement of section 871(h)(5) of the Code in order to qualify the payments as portfolio interest payments for purposes of the tax imposed under sections 871 and 881 of the Code. Guidance is also provided to determine the amount of tax imposed and withheld on substitute dividend payments made by one foreign person to another foreign person.

T.D. 8735 from IR Bulletin No. 1997-43
Final regulations under section 861 of the Code relate to the taxation of certain payments made pursuant to a cross-border securities lending transaction.

Notice 97-37 from IR Bulletin No. 1997-27
Elections into mark-to-market accounting. The Service will issue additional guidance on elections under section 1.475(c)-1 of the regulations. This notice also extends the deadline to make a customer paper election on a retroactive basis.

Notice 96-12 from IR Bulletin No. 1996-10
Mark to market for dealers in securities; related parties as customers. This notice describes guidance expected to be issued in proposed regulations concerning whether a taxpayer's transactions with related parties, including members of its consolidated group, may be transactions with customers for purposes of section 475 of the Code.

Notice 94-46 from IR Bulletin No. 1994-18
This notice announces certain rules that will be incorporated into regulations under section 367(a) of the Code.

Rev. Rul. 94-07 from IR Bulletin No. 1994-03
Meaning of security held for investment under section 475 mark-to-market rules. This ruling provides guidance concerning the identification of securities as "held for investment" for purposes of section 475 of the Code, by providing that the term "held for investment" has the same meaning for purposes of section 475 that it has for purposes of section 1236. Rev. Rul. 93-76 modified and clarified.

MARK-TO-MARKET ACCOUNTING METHOD

Announcement 98-40 from IR Bulletin No. 1998-20
This announcement contains corrections to the notice of proposed rulemaking REG-208299-90 (1998-16 I.R.B. 26). The proposed rulemaking under sections 482 and 864 of the Code relates to the allocation among controlled taxpayers and sourcing of income, deductions, and gains and losses from a global dealing operation; rules applying these allocation and sourcing rules to foreign currency transactions and to foreign corporations engaged in a U.S. trade or business; and rules concerning the mark-to-market treatment resulting from hedging activities of a global dealing. The public hearing originally scheduled for July 9, 1998, has been rescheduled for July 14, 1998.

REG-208299-90 from IR Bulletin No. 1998-16
Proposed regulations under sections 482 and 864 of the Code relate to rules for the allocation among controlled taxpayers and sourcing of income, deductions, gains and losses from a global dealing operation; rules applying these allocation and sourcing rules to foreign currency transactions and to foreign corporations engaged in a U.S. trade or business; and rules concerning the mark-to-market treatment resulting from hedging activities of a global dealing. A public hearing will be held on July 9, 1998.

Rev. Proc. 97-43 from IR Bulletin No. 1997-39
Consent to change accounting method to comply with section 475 mark-to-market rules. Automatic consent to change accounting methods is provided to certain taxpayers that become subject to section 475(a) of the Code. In order to receive automatic consent, the taxpayer must file a completed Form 3115, including a list of securities identified under section 475(b)(2), in the manner provided in this revenue procedure.

Rev. Rul. 97-39 from IR Bulletin No. 1997-39
Mark-to-market accounting method for dealers in securities. This ruling provides guidance to enable taxpayers to comply with the mark-to-market requirements of section 475 of the Code. Rev. Ruls. 94-7 and 93-76 clarified, modified, partially obsoleted, and superseded.

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