Internal Revenue Bulletins  

November 04, 2002

Internal Revenue Bulletin No. 2002-44

Links to Official IRS Bulletin Documents listed below are in the Adobe Acrobat PDF Format, and require the appropriate Acrobat Reader to view and/or print.

SPECIAL ANNOUNCEMENT

Announcement 2002-101(PDF, 31K)
This announcement solicts applications from potential partners to participate in the 2003 IRS Individual e-file Partnership Program. The partnership opportunities are a result of RRA 98, which requires the IRS to receive 80 percent of all returns electronically by 2007. RRA 98 authorized the IRS Commissioner to promote the benefits of and encourage the use of e-file services through partnerships with various entities that offer low cost tax preparation and electronic filing of income tax returns for qualified taxpayers. Those applicants that are accepted as partners will have a link(s) and description(s) of their services placed on the IRS website at www.irs.gov (IRS e-file Partners Page).

INCOME TAX

Announcement 2002-100(PDF, 24K)
This document contains corrections to proposed regulations under section 1503(d) of the Code (REG-106879-00, 2002-34 I.R.B. 402) relating to the events that require the recapture of dual consolidated losses.

Announcement 2002-102(PDF, 18K)
This document changes the date of a scheduled public hearing and extends the public comment period on proposed regulations (REG-136311-01, 2002-36 I.R.B. 485) that relate to when a foreign corporation engaged in the international operation of ships or aircraft may exclude its U.S. source income from gross income for U.S. federal income tax purposes. The hearing is rescheduled from November 12, 2002, to November 25, 2002.

Notice 2002-70(PDF, 26K)
This notice alerts taxpayers and their representatives about certain reinsurance transactions intended to shift income to offshore related companies purported to be insurance companies that are subject to little or no U.S. federal income tax. These transactions often do not generate the federal tax benefits that taxpayers claim are allowable for federal income tax purposes. This notice also alerts taxpayers, their representatives, and promoters of these transactions, to certain reporting and record keeping obligations and penalties that they may be subject to with respect to these transactions.

REG-112306-00(PDF, 90K)
Proposed regulations under section 1296 of the Code contain procedures for certain United States persons holding marketable stock in a passive foreign investment company (PFIC) to elect mark to market treatment for that stock. A public hearing is scheduled for November 6, 2002.

REG-150313-01(PDF, 122K)
Proposed regulations under sections 302, 304, and other sections of the Code provide guidance regarding the treatment of the basis of redeemed stock when a distribution in redemption of such stock is treated as a dividend. The regulations also provide guidance regarding certain acquisitions of stock by related corporations that are treated as distributions in redemption of stock. A public hearing is scheduled for February 20, 2003.

Rev. Rul. 2002-69(PDF, 39K)
Business expenses; interest; lease-in/lease-out transactions. A taxpayer may not deduct currently, under sections 162 and 163 of the Code, rent and interest paid or incurred in connection with a lease-in/lease-out (LILO) transaction that properly is characterized as conferring only a future interest in property. rr 99-14 modified and superseded.

Rev. Rul. 2002-71(PDF, 26K)
Notional principal contract (NPC). This ruling provides guidance on the timing of recognition of gain or loss on the termination of a notional principal contract that hedges a portion of the term of a debt instrument issued by the taxpayer.

Rev. Rul. 2002-72(PDF, 17K)
Low-income housing credit; satisfactory bond; ´┐Żbond factor´┐Ż amounts for the period October through December 2002. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period October through December 2002. This ruling also provides a summary of the bond factor amounts for dispositions occurring during the period January through September 2002.

EMPLOYEE PLANS

REG-124667-02(PDF, 70K)
Proposed regulations under section 417 of the Code would consolidate the content requirements applicable to explanations of qualified joint and survivor annuities and qualified preretirement survivor annuities payable from certain retirement plans. In addition, these regulations would specify requirements for disclosing the relative value of optional forms of benefit that are payable from certain retirement plans in lieu of a qualified joint and survivor annuity. A public hearing is scheduled for January 14, 2003.

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