Internal Revenue Bulletins  

August 26, 2002

Internal Revenue Bulletin No. 2002-34

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INCOME TAX

REG-106359-02(PDF, 60K)
Proposed regulations under section 482 of the Code clarify that stock-based compensation is taken into account in determining the intangible development costs of a controlled participant in a qualified cost sharing arrangement. The regulations also provide rules for measuring the cost associated with stock-based compensation; clarify that stock-based compensation is appropriately taken into account as a comparability factor for purposes of the comparable profits method; and clarify the coordination of the cost sharing rules with the armís length standard. A public hearing is scheduled for November 20, 2002.

REG-106876-00(PDF, 74K)
Proposed regulations under sections 897 and 1445 of the Code require the use of taxpayer identifying numbers on submissions. The regulations are necessary to properly identify submissions made by foreign taxpayers for the reduction or elimination of tax under these sections. The regulations also address miscellaneous items such as the amendment to section 1445(e)(3) under the Small Business Job Protection Act of 1996. A public hearing is scheduled for November 13, 2002.

REG-106879-00(PDF, 34K)
Proposed regulations under section 1503(d) of the Code provide guidance regarding the events that require the recapture of dual consolidated losses. The regulations generally provide that certain events will not require recapture of a dual consolidated loss and provide for the reporting of certain information in such cases. This document also proposes certain conforming changes to the current regulations. A public hearing is scheduled for December 3, 2002.

REG-133254-02(PDF, 41K)
Proposed regulations under section 6049 of the Code relate to the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to non-resident alien individuals that are residents of certain specified countries. A public hearing is scheduled for December 5, 2002. REG-126100-00 withdrawn.

Rev. Rul. 2002-52(PDF, 18K)
LIFO; price indexes; department stores. The June 2002 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, June 30, 2002.

T.D. 9012(PDF, 24K)
Final regulations under section 7701 of the Code address the applicability of the elective federal tax classification regime (the check-the-box regulations) to business entities wholly owned by a foreign government and to wholly owned nonbank entities of foreign banks. These regulations also provide that the term "entity" for purposes of section 892(a)(2)(B) of the Code includes a partnership.

EXEMPT ORGANIZATIONS

Announcement 2002-75(PDF, 23K)
A list is provided of organizations now classified as private foundations.

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