Internal Revenue Bulletins  

February 18, 2003

Internal Revenue Bulletin No. 2003-07

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.


T.D. 9033(PDF, 28K)
REG-124069-02(PDF, 30K)
Final, temporary, and proposed regulations under section 6038 of the Code provide that a United States partner must follow the filing requirements that are specified in the instructions for Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships, when the United States partner must file Form 8865 and the foreign partnership completes and files Form 1065, U.S. Return of Partnership Income, or Form 1065-B, U.S. Return for Electing Large Partnerships. This amendment would facilitate revisions to the filing requirements such as electronic filing for Form 8865. A public hearing on the proposed regulations is scheduled for March 12, 2003.

Rev. Rul. 2003-18(PDF, 23K)
Section 355. This ruling discusses whether the acquisition by D, a brand X automobile dealer, of a brand Y automobile dealership constitutes an expansion of the brand X business or an acquisition of a new or different business under section 1.355-3(b)(3)(ii) of the regulations. Rev. Rul. 57-190 obsoleted.

Rev. Rul. 2003-19(PDF, 38K)
Insurance demutualization. This ruling provides guidance as to the tax consequences that occur when, as described in the facts set forth in this ruling, a mutual insurance company converts to a stock insurance company.

Rev. Rul. 2003-20(PDF, 32K)
New markets tax credit. This ruling holds that, for purposes of determining the new markets tax credit under the facts of the ruling, the amount of the qualified equity investment made by a limited liability company (LLC) classified as a partnership includes cash from a nonrecourse loan to the LLC that the LLC invests as equity in a qualified community development entity.

T.D. 9032(PDF, 99K)
These regulations also provide reporting rules for a trust that is treated as owned by the grantor, or another person under provisions of the Code for the taxable year ending with the death of the grantor or other person. Notice 2001-26 and Rev. Proc. 98-13 obsoleted.

T.D. 9034(PDF, 103K)
Final regulations under section 25A of the Code relate to the education tax credit for the payment of certain postsecondary educational expenses.


Announcement 2003-10(PDF, 29K)
A list is provided of organizations now classified as private foundations.


Announcement 2003-9(PDF, 17K)
This document contains corrections to proposed regulations (REG-150313-01, 2002-44 I.R.B. 777) under sections 302, 304, and other sections of the Code providing guidance regarding the treatment of the basis of redeemed stock when a distribution in redemption of such stock is treated as a dividend. February 18, 2003 2003-7 I.R.B.

REG-126016-01(PDF, 31K)
Proposed regulations under sections 6662 and 6664 of the Code limit the defenses available to the imposition of the accuracy-related penalty when taxpayers fail to disclose reportable transactions or that they have taken a position based upon a regulation being invalid. The regulations also clarify existing regulations with respect to the facts and circumstances that the IRS will consider in determining whether a taxpayer acted with reasonable cause and in good faith in relying on an opinion or advice.

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