December 2002

Issue

Date

Subject

2002-306

December 31, 2002

IRS Confirms Costa Rican "Soak-Up" Taxes Are Not Creditable Under Section 901 or 903

2002-305

December 30, 2002

Proposed Regulations Limiting Taxpayer Defenses to Accuracy-Related Penalty

2002-304

December 23, 2002

Final Regulations for Revocable Trusts Electing to Be Treated as Part of Estate; Reporting Rules Clarified

2002-303

December 23, 2002

Final Regulations on Exclusion of Gain on Sale of a Principal Residence

2002-302

December 23, 2002

Analysis: Proposed INDOPCO Regulations Regarding Capitalization of Certain Expenditures

2002-301

December 20, 2002

Treasury Clarifies 2003 Foreign Tax Credit Changes for Dividends Paid by 10/50 Corporations

2002-300

December 20, 2002

IRS Releases Guidance on Retirement Plans

2002-299

December 20, 2002

Return Filing Guidance for U.S. Partners of Foreign Partnerships

2002-298

December 19, 2002

Tax Court: AMT Book Income Adjustment of Life-Nonlife Consolidated Return Uses Single Adjustment for the Group

2002-297

December 18, 2002

Texas: Comptroller's Office Clarifies LP/LLC Eligibility for Intercorporate Services Exemption

2002-296

December 18, 2002

Text of Proposed INDOPCO Regulations: Guidance Concerning Expenditures Deduction and Capitalization

2002-295

December 18, 2002

Corporate Integration: Taxing Business Income Once – New Life in an Old Issue?

2002-294

December 17, 2002

Certain ESOP Arrangements Cannot Benefit From Section 409(p) Delayed Effective Date

2002-293

December 17, 2002

Final Regulations on Third-Party Contacts

2002-292

December 17, 2002

Legislative Update: Retroactive Technical Correction To Bonus Depreciation Provisions, Limited Window of Opportunity for Relief

2002-291

December 17, 2002

Proposed Regulations Authorize IRS's Rules Relating to Inclusion of Advance Rentals in Gross Income in Year Other Than Year of Receipt

2002-290

December 16, 2002

Outline of Proposed Anti-Loss-Duplication Rules for Consolidated Groups

2002-289

December 13, 2002

Seventh Circuit Denies Research Credit for Software Development Activities

2002-288

December 11, 2002

Leave-Based Donation Programs Are Taxable in 2003

2002-287

December 11, 2002

IRS Ruling Addresses When Accrual Method Taxpayer Includes State or Local Tax Refund in Income

2002-286

December 11, 2002

Section 338 Election Form Is Revised

2002-285

December 10, 2002

Webcast Video Discussions of Proposed Regulations Relating to Cash Balance Plans 

2002-284

December 10, 2002

IRS Guidance Addresses Whether "Group Captive" Is an Insurance Company, What Amounts Are Deductible Insurance Premiums

2002-283

December 10, 2002

Proposed Regulations for Cash Balance Pension Plans Are Released

2002-282

December 9, 2002

IRS Expands Situations in Which Taxpayers Can Qualify for Tax-Free Reorganization; Thus, Regulations Are to Be Amended

2002-281

December 6, 2002

Symposium to Examine "Nexus": International, National, State and Local Issues

2002-280

December 4, 2002

IRS Implements New Limited Issue Focused Examination (LIFE) Process

2002-279

December 4, 2002

Treasury Issues Interim Guidance on Terrorism Insurance Act

2002-278

December 4, 2002

IRS Releases Guidance on Viatical Settlement Providers

2002-277

December 4, 2002

IRS Offers Alternative Methods for Computing Discounted Unpaid Losses of Insurance Companies

2002-276

December 3, 2002

Ninth Circuit Reverses Tax Court, Holds Regulations Invalid in Computer Software Licensing FSC Case

2002-275

December 2, 2002

IRS Extends Deadline for Electing Tax Shelter Settlement Initiative

2002-274

December 2, 2002

IRS Issues Proposed Revenue Procedure Regarding Deferral Of Advance Payments

2002-273

December 2, 2002

Final Regulations Released on Loans from Qualified Plans

November 2002

Issue

Date

Subject

2002-272

November 27, 2002

IRS Releases Guidance on the Effect of Overpayments of Benefits from a Qualified Retirement Plan

2002-271

November 27, 2002

United States, Mexico Sign Second Protocol to Income Tax Treaty Providing Zero Withholding on Some Dividends, and More Double Tax Relief

2002-270

November 27, 2002

Missouri Supreme Court Reverses Acme/Gore Decisions; Concludes That PICs Were Not Subject to Tax

2002-269

November 26, 2002

IRS Issues Final Regulations Relating to Insurance Premium Excise Tax

2002-268

November 25, 2002

IRS Releases Guidance on Like-Kind Exchanges 

2002-267

November 22, 2002

Compensation From Nonqualified Stock Options Must Be Reported in Box 12 on 2003 Form W-2

2002-266

November 22, 2002

IRS News Releases: Arbitration for Tax Shelter Cases, Arbitrage for Tax-Exempt Bonds, Tornado and Storm Relief Granted

2002-265

November 21, 2002

Final Regulations Provide ITIN Rules Where Foreign Individuals, Receiving an Unexpected Payment, Claim a Treaty Rate

2002-264

November 19, 2002

IRS Extends Time for Making Various Amendments to Qualified Retirement Plans

2002-263

November 19, 2002

Proposed Regulations Limit Anti-Abuse Rule to Outbound Liquidations, Not to Foreign-to-Foreign Liquidations

2002-262

November 13, 2002

Legislative Update: Tax Technical Corrections Bill Introduced

2002-261

November 12, 2002

Treasury to Release Regulations to Address Reporting Requirements Relating to Corporate Inversions

2002-260

November 08, 2002

Temporary Regulations Allow New Guidance on Substantiation of "Incidental Expenses"

2002-259

November 07, 2002

Massachusetts' Highest Court Upholds Deductions for Trademark Licensing; Reverses Sherwin-Williams

2002-258

November 06, 2002

Legislative Update: Grassley to Reassume Finance Chair in GOP Senate

2002-257

November 06, 2002

IRS Proposes Revenue Procedure for Individual Taxpayers Seeking to Change From Fiscal to Calendar Year; Issues Guidance on Charitable Donations of Automobiles

2002-256

November 04, 2002

Year-End Employment Tax Issues

October 2002

Issue

Date

Subject

2002-255

October 28, 2002

IRS Clarifies Guidance for Accounting Period Changes

2002-254

October 25, 2002

Tax Court Determines 15-Year Asset Class for Natural Gas Pipelines and Gathering Systems

2002-253

October 25, 2002

Webcast: Discussion of Proposed Loss Duplication Regulations

2002-252

October 18, 2002

Proposed Loss Disallowance Regulations Are Released

2002-251

October 17, 2002

Amended Disclosure and List-Maintenance "Tax Shelter" Regulations Are Officially Released

2002-250

October 17, 2002

Proposed Regulations Issued on "Basis-Shifting" Transactions

2002-249

October 17, 2002

IRS Revises Settlement Initiative Guidelines for Contingent Liability Transactions

2002-248

October 17, 2002

Legislative Update: House Shelves Tax Action, Recesses for Elections

2002-247

October 16, 2002

IRS Provides Guidance on Timing of Gain or Loss on Certain Swap Termination Payments

2002-246

October 16, 2002

Legislative Update: Chairman Thomas Unveils Tax Bill for Immediate Action

2002-245

October 16, 2002

IRS Limits Time for Change in Method of Accounting Related to 401(k) Matching Contributions

2002-244

October 15, 2002

IRS Identifies Transactions Using Certain Reinsurance Arrangements as "Listed Transactions"

2002-243

October 15, 2002

October 31 Deadline Approaches for Taxpayers to Finalize Decisions About 5-Year NOL Carrybacks for Earlier-Filed 2001 and 2002 Tax Returns

2002-242

October 14, 2002

EU Consultative Process to Determine U.S. Products on the ETI Sanctions List

2002-241

October 11, 2002

IRS Reaffirms Earlier Treatment of "LILO" Transactions

2002-240

October 11, 2002

Legislative Update: Tax Bills Hang by Threads in Session's Final Days

2002-239

October 11, 2002

IRS Offers Tax Relief to Victims of Recent Tropical Storms

2002-238

October 9, 2002

Revenue Procedure Offers Guidance on Classification of Entity Owned Solely by Husband and Wife

2002-237

October 8, 2002

IRS Interim Guidance for Determining Interest Rates and Foreign Loss Payment Patterns for CFC Calculations of Qualified Insurance Income

2002-236

October 8, 2002

Sixth Circuit Affirms Tax Court Decision on Entertainment Expenses Under Section 274

2002-235

October 7, 2002

IRS Issues Guidance On Airline Sales Of Mileage Awards To Other Airlines

2002-234

October 7, 2002

Revenue Procedure Allows All Partners of an Eligible Partnership to Effect Monthly Closing Consent Statements

2002-233

October 4, 2002

IRS Offers Limited Time for Tax Shelter Settlements

2002-232

October 4, 2002

Proposed Regulations Set Forth Content Requirements for Qualified Joint and Survivor Annuities Explanations

2002-231

October 3, 2002

IRS Allows Modifications to "Substantially Equal Period Payments" from IRAs and Pension Plans

2002-230

October 2, 2002

IRS Guidance on Effect of Collar Transactions on Exemption Treatment for Qualified Covered Calls

September 2002

Issue

Date

Subject

2002-229

September 30, 2002

Transition Relief for Foreign Partnerships and U.S. Withholding Agents Extended Through 2002

2002-228

September 30, 2002

Revenue Procedure Provides Safe Harbor Method of Accounting for Track Repair and Maintenance Expense For Class II and Class III Railroads

2002-227

September 25, 2002

United States and India Suspend Tax Collection During Mutual Agreement Procedure Negotiations

2002-226

September 25, 2002

IRS Identifies Passthrough Entity Straddle Tax Shelter as a "Listed Transaction"

2002-225

September 17, 2002

Standard Mileage Allowance Will Drop to 36 Cents Per Mile for 2003

2002-224

September 17, 2002

Legislative Update: Senate Finance to Vote on Expanded Tax Shelters in Small Business Bill

2002-223

September 16, 2002

Federal Circuit Reverses Claims Court Decision Concerning Insurance Company's Foreign Tax Credit and Foreign Currency Translation Issues

2002-222

September 12, 2002

IRS Updates Domestic Asset/Liability Percentages and Domestic Investment Yields for Foreign Insurance Companies

2002-221

September 12, 2002

Legislative Update: Energy Conferees Make Little Progress; Senate Panel Approves Expatriate Provision

2002-220

September 9, 2002

Federal Circuit Affirms, No Interest on Overpayments Applied to Later Tax Years After Due Dates of Those Returns

2002-219

September 3, 2002

Appeals Court Narrows "Qualified Research" Under Section 41

August 2002

Issue

Date

Subject

2002-218

August 30, 2002

IRS Issues Rulings on Two Matters Concerning Utility Cooperatives

2002-217

August 30, 2002

WTO Arbitration Panel Authorizes $4 Billion in Countermeasures

2002-216

August 27, 2002

Eight Circuit Affirms Employee Stock Ownership Plans Could not be Aggregated

2002-215

August 22, 2002

IRS Guidance Allows Home-Sale Relief to Taxpayers Affected by September 11th Terrorist Attacks

2002-214

August 20, 2002

Final Section 469 Regulations Address Treatment of Self-Charged Items of Income and Expense When Taxpayer Engages in Lending Transaction with Partnership or S Corporation

2002-213

August 19, 2002

Third Circuit Affirms Leveraged COLI Transactions Lacked Economic Substance

2002-212

August 16, 2002

IRS Notice Provides Valuation Guidance for Split-Dollar Life Insurance Arrangements

2002-211

August 16, 2002

IRS Issues Final Audit Guidance for External Auditors of Qualified Intermediaries

2002-210

August 16, 2002

Legislative Update: Thomas' "Competitiveness" Bill Also Includes Revenue Raisers

2002-209

August 15, 2002

Ninth Circuit Affirms Tax Court's Finding That Relining and Replacement Expenditures Must Be Capitalized

2002-208

August 14, 2002

Revenue Procedure Clarifies Earlier Change in Method of Accounting Guidance

2002-207

August 12, 2002

Election to Include in Gross Income Gain on Assets Held on January 1, 2001

2002-206

August 9, 2002

Israel: Reform of the Tax System

2002-205

August 8, 2002

Legislative Update: What Is the Effect of a "Sense of the Senate" Resolution That CEOs Should Sign Corporations' Tax Returns?

2002-204

August 5, 2002

Focus on Proposed Rules Relating to Income from International Operations of Ships and Aircraft

2002-203

August 1, 2002

Provisions in Sarbanes-Oxley Act of 2002 Affecting Compensation or Benefits

July 2002

Issue

Date

Subject

2002-202

July 31, 2002

New Proposed Rules on Income from International Operations of Ships and Aircraft; Earlier Proposed Regulations Are Withdrawn

2002-201

July 31, 2002

Proposed Regulations Relating to Dual Consolidated Loss Recapture Rules

2002-200

July 31, 2002

Final Regulations Clarify Check-the-Box Rules for Business Entities Owned by Foreign Governments and Foreign Banks

2002-199

July 30, 2002

Regulations Are Proposed for Electing Section 1296 Mark-to-Market Treatment for Marketable Stock of a PFIC

2002-198

July 30, 2002

Treasury, IRS Propose Regulations on Reporting of Deposit Interest Paid to Nonresident Aliens; Previously Proposed Regulations Are Withdrawn

2002-197

July 29, 2002

Tax Court: Fuel Assemblies Failed to Qualify Under Transition Rules for the Investment Tax Credit

2002-196

July 26, 2002

Proposed Regulations Address the Treatment of Stock-Based Compensation Under Section 482

2002-195

July 25, 2002

Sections 897 and 1445 (FIRPTA): Proposed Rules Address TIN and Withholding Requirements on Transfers of U.S. Real Property Interests

2002-194

July 25, 2002

Middleman Information Reporting Rules Take Final Form

2002-193

July 24, 2002

Federal Circuit: No Interest on Refund of Harbor Maintenance Tax Refund

2002-192

July 23, 2002

United States, United Kingdom Sign Protocol to Income Tax Treaty

2002-191

July 22, 2002

"Brown Group" Regulations Are Finalized, Address Subpart F Consequences of CFC's Distributive Share of Partnership Income

2002-190

July 22, 2002

Final Regulations Address Taxable Years of Partnerships with Tax-Exempt or Foreign Partners

2002-189

July 22, 2002

Proposed Regulations Address Earnings Calculation for Returned or Recharacterized IRA Contributions

2002-188

July 22, 2002

Proposed Regulations Conform Existing Rules Concerning Tax Treatment of Guaranteed Annuity and Unitrust Interests

2002-187

July 19, 2002

Revenue Ruling Addresses Five-Year "Active Conduct of a Trade or Business" Requirement Under Section 355(b)

2002-186

July 19, 2002

IRS Issues Ruling on Commercial Aviation "Foreign Trade" Exemption from Federal Jet Fuel Tax

2002-185

July 19, 2002

Proposed Regulations Offer Guidance on Net Gift Treatment of Lifetime Transfers of Qualifying Income Interests

2002-184

July 19, 2002

Final Regulations: Return of Employer Contributions to Multiemployer Plans Due to Mistake of Fact or Law

2002-183

July 18, 2002

IRS Releases Statistics of Income Bulletin, Includes Statistics on Difference Between Corporation Book and Tax Net Income

2002-182

July 17, 2002

Tax Court Addresses the Calculation of Accumulated Earnings Tax Liability

2002-181

July 15, 2002

D.C. Circuit: Official Brazilian Tax Receipts Sufficient Evidence for Claiming Foreign Tax Credits

2002-180

July 15, 2002

South Africa: SARS Looks to International Transactions to Broaden the Tax Base

2002-179

July 12, 2002

IRS Modifies Competent Authority Guidance

2002-178

July 11, 2002

Legislative Update: Thomas Unveils International Tax, Inversions, Shelters Bill

2002-177

July 11, 2002

Legislative Update: Senate Finance Approves Pension Reforms, ESPP Exclusion

2002-176

July 10, 2002

First Circuit Affirms MedChem, Without Adopting Tax Court's Test for Section 936 "Active Conduct of Trade or Business" Within U.S. Possession

2002-175

July 10, 2002

Regulations Are Proposed Under Section 419A Addressing 10 or More Employer Plans

2002-174

July 10, 2002

Treasury, IRS Release 2002-2003 Priority Guidance Plan

2002-173

July 10, 2002

Seven Issues Are Selected for 2002 Industry Issue Resolution (IIR) Program

2002-172

July 3, 2002

Proposed Regulations Address Split-Dollar Life Insurance Arrangements

2002-171

July 2, 2002

Legislative Update: Finance Committee Releases Report, Statutory Language for Inversion and Shelter Legislation

2002-170

July 2, 2002

IRS Simplifies Broker Reporting Requirements for Stock Options Exercised and Sold on Same Day

2002-169

July 2, 2002

Proposed Regulations Address Backup Withholding, Solicitation Rules on IRS Notification of Incorrect TINs

June 2002

Issue

Date

Subject

2002-168

June 28, 2002

IRS Announces Enhanced Schedule K-1 Compliance Effort

2002-167

June 28, 2002

Instructions Relating to Determination of Substitute Agent to Act for a Consolidated Group

2002-166

June 28, 2002

Legislative Update: Thomas Outlines Proposals on Earnings Stripping, Tax Shelters, ETI Repeal

2002-165

June 28, 2002

IRS Guidance on Treatment of State Agency Financing by Electric Utility Company

2002-164

June 28, 2002

Final Regulations Address the Scope of the Common Parent’s Authority to Act for a Consolidated Group

2002-163

June 27, 2002

Final Regulations Establish Who Has Authority to Act for Consolidated Group

2002-162

June 27, 2002

IRS Guidance on Deductions for Contributions to 401(k) Plans and Defined Contribution Plans

2002-161

June 26, 2002

Revenue Ruling Provides Certain Payments to Defined Contribution Plans Are Not "Contributions"

2002-160

June 26, 2002

Revised EPCRS Program Guidelines Are Released

2002-159

June 26, 2002

Legislative Update: House Hearing Considers Anti-Inversions Legislation

2002-158

June 26, 2002

IRS Clarifies Tax Treatment and Rules Regarding Employer-Funded Health Reimbursement Accounts

2002-157

June 26, 2002

Fast-Track Mediation for Resolving Tax Disputes Is Expanded

2002-156

June 25, 2002

IRS Guidance on Calculation of Prohibited Transaction Excise Tax

2002-155

June 25, 2002

Comments Requested on Elimination of Optional Forms of Benefit Under Defined Benefit Plans

2002-154

June 25, 2002

IRS Identifies Partnership Straddle Transaction as "Listed Transaction"

2002-153

June 25, 2002

IRS Delays Tax on ESPPs, ISOs for More Than Two Years

2002-152

June 24, 2002

IRS Notice Addresses Three Tax Benefits for New York Liberty Zone

2002-151

June 24, 2002

IRS Guidance on Timing of Realization of Gain or Loss on Short Sale of Stock

2002-150

June 20, 2002

IRS Releases Guidance on Safe Harbor Method of Accounting for Non-Life Insurance Companies

2002-149

June 18, 2002

Legislative Update: Senate Finance Panel Approves Shelters, Inversions, Charitable Package

2002-148

June 18, 2002

Eleventh Circuit: Holding Company Had No LIFO Inventory Requiring Recapture on Becoming an S Corporation

2002-147

June 17, 2002

Revenue Ruling Addresses Merger or Conversion of Money Purchase Pension Plans Into Profit-Sharing Plans

2002-146

June 17, 2002

IRS Policy Change Concerning Requests for Tax Accrual and Other Financial Audit Workpapers

2002-145

June 17, 2002

Supreme Court: IRS Has Authority to Use Aggregate Estimation Method to Determine Employer’s FICA Liability

2002-144

June 17, 2002

IRS Requests Comments on Proposal to Simplify Transfer Pricing Documentation

2002-143

June 14, 2002

New Regulations Modify the Tax Shelter Rules

2002-142

June 14, 2002

IRS Guidance on Filing Procedures for Research Credit Claims

2002-141

June 14, 2002

Tax Analysts v. IRS: Affirmed in Part, Reversed in Part, by D.C. Circuit

2002-140

June 14, 2002

IRS Requests Comments on Issues for "Phased Retirement" Arrangements Under a Defined Benefit Plan

2002-139

June 13, 2002

Legislative Update: Senate Finance Panel Delays Votes on Shelters, Inversions, Charitable Package

2002-138

June 13, 2002

Additional IRS Guidance on Valuation of Stock Options for Purposes of the Golden Parachute Rules

2002-137

June 12, 2002

Proposed Regulations Address Discharge-of-Indebtedness Reporting Requirements

2002-136

June 11, 2002

Legislative Update: Senate Finance to Mark Up Shelters, Inversions With Charity Bill

2002-135

June 11, 2002

Revenue Ruling Addresses Tax Treatment of Income From REIT Subsidiary's Provision of Noncustomary Services

2002-134

June 11, 2002

Final Section 894(c) Regulations Affecting Payments by Domestic (U.S.) Reverse Hybrids Are Issued

2002-133

June 10, 2002

Tax Court: Charitable Contribution Deductions Disallowed for Split-Dollar Life Insurance Contract

2002-132

June 7, 2002

IRS Expands Appeals Arbitration, Modifies and Formally Establishes Mediation Procedures

2002-131

June 6, 2002

Legislative Update: Thomas Calls for Careful Consideration of Inversions, Tax Competitiveness

2002-130

June 5, 2002

Regulations Propose Changes to Definition of "Highway Vehicle" for Excise Tax Purposes

2002-129

June 5, 2002

Australia: Simplified Imputation System Is Introduced

May 2002

Issue

Date

Subject

2002-128

May 31, 2002

Guidance for Insurance Companies Relating to Modified Guaranteed Contracts

2002-127

May 31, 2002

Legislative Update: Congress Returns from Memorial Day Recess Contemplating Tax Agenda

2002-126

May 30, 2002

New Consolidated Loss Disallowance Regulations and Carryback Rules Are Issued

2002-125

May 30, 2002

Proposed Regulations Relating to Cost Recovery Under Income Forecast Method Are Issued

2002-124

May 29, 2002

Final Regulations Broadening the "Qualified Covered Call" Exception for Options Are Suspended

2002-123

May 28, 2002

IRS Releases Model Plan Amendments for Required Minimum Distributions

2002-122

May 28, 2002

IRS Chief Counsel Tests New Procedures for Expediting Technical Advice

2002-121

May 23, 2002

IRS Releases Guidance on Employer Reimbursement of Employee-Provided Equipment

2002-120

May 22, 2002

IRS Notice Includes Proposed Guidance for Withholding Foreign Partnership and Withholding Foreign Trust Agreements

2002-119

May 22, 2002

IRS Issues Guidance Relating to New 5-Year NOL Carryback Period

2002-118

May 20, 2002

IRS Grants Interest and Penalty Relief to September 11th Victims and Affected Taxpayers

2002-117

May 20, 2002

Legislative Update: Side-by-Side Comparison of Tax Provisions in House and Senate Versions of Energy Bill

2002-116

May 16, 2002

Regulations on Reporting of Gross Proceeds Payments to Attorneys Are Amended and Re-Proposed

2002-115

May 16, 2002

Regulations Are Finalized for Adoptions, Changes, and Retentions of Annual Accounting Periods

2002-114

May 15, 2002

IRS Releases Second Annual Report on Pre-Filing Agreement Program

2002-113

May 15, 2002

Proposed Regulations Take Aim at Certain "Abusive" Blended Taxable Fuel Transactions

2002-112

May 14, 2002

Australia: Business Tax Reform Initiatives Included in Budget 2002

2002-111

May 14, 2002

Regulations Are Finalized Concerning Mid-Contract Change in Taxpayer Under Long-Term Contract Method of Accounting

2002-110

May 13, 2002

Regulations Relating to Electing Small Business Trusts Are Finalized

2002-109

May 10, 2002

Legislative Update: Senate Finance Committee Leaders Introduce Tax Shelter Bill

2002-108

May 10, 2002

IRS Updates and Finalizes New Automatic Approval Procedures Relating to Annual Accounting Periods for Corporations, Partnerships, and Personal Service Corporations

2002-107

May 10, 2002

Proposed Regulations Address Treatment of Hedging Transaction Gains or Losses Relating to Foreign Personal Holding Company

2002-106

May 10, 2002

Australia: Government Releases Draft Reference Manual in Advance of Tax Consolidation Regime

2002-105

May 9, 2002

IRS Makes Technical Changes to Guidance Concerning 60-Month Rule on Reconsolidation Following Disaffiliation

2002-104

May 8, 2002

IRS Issues Guidance Relating to Transfers of Certain Stock Options and Deferred Compensation Incident to Divorce, and Requests Comments Concerning Employment Tax Issues Related to Such Transfers

2002-103

May 7, 2002

Regulations Under Section 457 Are Proposed for State and Local Governments, Tax-Exempt Entities

2002-102

May 7, 2002

Analysis: Tax Court Holds Rent Stripping Transaction Should Be Disregarded

2002-101

May 6, 2002

IRS Addresses Contingent Convertible Debt Instruments, Requests Comments

2002-100

May 6, 2002

Notional Principal Contracts: IRS Addresses Payments with Noncontingent and Contingent Components; Certain Type Is "Listed" Transaction

2002-99

May 6, 2002

Final Regulations, IRS Notice Provide Guidance for Insurance Companies

2002-98

May 3, 2002

Revenue Procedure Addresses Proper Tax Treatment of "CCR Payments" Made by Purchasers of Leased Vehicles

2002-97

May 2, 2002

Internal IRS Memorandum Revises Prior Guidance to Examiners Concerning Capitalization of Certain Transaction Costs Related to Intangible Assets

2002-96

May 1, 2002

Revenue Ruling Provides Guidance to Private Foundations

April 2002

Issue

Date

Subject

2002-95

April 30, 2002

IRS Releases Guidance to Clarify 60-Month Rule on Reconsolidation Following Disaffiliation

2002-94

April 29, 2002

IRS Tells Taxpayers How to Deduct, or Elect Not to Deduct, Additional First Year Depreciation

2002-93

April 26, 2002

Final Regulations Broaden the "Qualified Covered Call" Exception for Options

2002-92

April 26, 2002

Regulations Address Information Reporting for Payments of Interest on Qualified Education Loans

2002-91

April 25, 2002

Legislative Update: Senate Moves to Pass Energy Bill

2002-90

April 24, 2002

Final "Qualified Sponsorship Payment" Regulations Are Issued

2002-89

April 24, 2002

IRS Issues Revenue Procedure on Defined Contribution Retirement Plans Maintained by Professional Employer Organizations

2002-88

April 23, 2002

New Section 355(e) Temporary Regulations Are Issued

2002-87

April 23, 2002

Tax Court Finds Abuse of Discretion in Requiring Taxpayer to Change Method of Accounting

2002-86

April 22, 2002

Regulations Propose Rules for Notices to Be Provided to Adversely Affected Plan Participants

2002-85

April 18, 2002

Refund of Overpaid Deficiency Interest Is Denied, as Not Being Timely Claimed

2002-84

April 18, 2002

Legislative Update: Stock Options Gets Spotlight; House Passes Tax Cut Extension

2002-83

April 17, 2002

U.S. Supreme Court: One Spouse’s Interest in Tenancy by the Entirety Property May Be Attached by Federal Tax Lien for His Separate Tax Liability

2002-82

April 17, 2002

Analysis: Temporary and Proposed Regulations on Corporate Transfers to RICs or REITs

2002-81

April 16, 2002

Final Regulations, IRS Notice Provide Guidance on Required Minimum Distributions

2002-80

April 15, 2002

Supreme Court Denies Certiorari in COLI Case

2002-79

April 15, 2002

Eighth Circuit Affirms Tax Court in Insurance Loss Estimates

2002-78

April 12, 2002

Certain Layoff Payments May Be Excluded From FICA Requirements

2002-77

April 11, 2002

Sixth Circuit Reverses Tax Court, Holds Credit Card Subsidiary Was Carrying on "the Banking Business" Under Section 956

2002-76

April 11, 2002

Ninth Circuit Affirms in Part, Reverses in Part the Tax Court’s Opinion in DHL Corp. v. Commissioner

2002-75

April 11, 2002

Legislative Update: Congress Addresses Tax Smorgasbord

2002-74

April 11, 2002

Japan: Overview of Changes in 2002 Tax Reform

2002-73

April 10, 2002

IRS Expands and Makes Permanent Industry Issue Resolution Program

2002-72

April 9, 2002

IRS Permits Electronic Submission of Certification Requests for Work Opportunity, Welfare-to-Work Credits

2002-71

April 4, 2002

IRS Suspends Form 5500 Schedule F Filing Requirement

2002-70

April 3, 2002

Revenue Procedure Provides Safe Harbor Method of Accounting for Cost of Tires Used in Business Activities

2002-69

April 2, 2002

Revenue Ruling Addresses When Weight-Loss Programs May Be Tax-Deductible

March 2002

Issue

Date

Subject

2002-68

March 29, 2002

IRS Releases Annual Report on APA Program

2002-67

March 29, 2002

Revenue Ruling Addresses Dutch Investment Yield Tax Credits

2002-66

March 28, 2002

Regulations Providing Special Rules for Determining Basis of Partner's Interest Are Finalized

2002-65

March 27, 2002

Tax Court Upholds Validity of Reg. Section 1.267(a)-3

2002-64

March 27, 2002

IRS Releases Guidance Regarding Penalty Relief in Coordination with DOL's DFVC and VFC Programs

2002-63

March 27, 2002

RS Provides Relief on Documentation of Donations

2002-62

March 22, 2002

IRS Solicits Comments on Business Plan Items for 2002-03

2002-61

March 21, 2002

Legislative Update: Baucus Says Shelter Legislation to Be Introduced After Easter

2002-60

March 20, 2002

Legislative Update: Ways and Means Approves Taxpayer Rights

2002-59

March 20, 2002

IRS Revises 2001 Depreciation Forms; Changes to NOL Instructions Are Expected

2002-58

March 20, 2002

Treasury Proposes New Initiatives to Curb Abusive Tax Avoidance Transactions

2002-57

March 20, 2002

IRS Chief Counsel Changes Litigation Position Concerning Capitalization of Certain Intangible Costs

2002-56

March 19, 2002

JCT Releases Analysis of President's Tax Proposals

2002-55

March 19, 2002

Revenue Procedure Establishes Guidelines for Ruling Requests on Undivided Fractional Interests in Rental Real Property

2002-54

March 19, 2002

Analysis: Final Regulations Regarding Hedging Transactions

2002-53

March 18, 2002

Analysis: Revenue Procedure Eliminates Four-Year Spread Period For All Favorable Accounting Method Change Adjustments, Permitting Full Deduction in Year of Change

2002-52

March 18, 2002

Analysis: IRS Issues Procedures for Involuntary Accounting Method Changes

2002-51

March 18, 2002

IRS Notice Addresses Tax Avoidance Using Inflated Basis

2002-50

March 15, 2002

Tax Court: Netting of Interest Expense and Interest Income Not Allowed for Purposes of Computing Non-U.S. Source Income

2002-49

March 15, 2002

Hedging Transaction Regulations Are Finalized

2002-48

March 14, 2002

Legislative Update: Ways and Means Committee Approves Enron-Related Pension Reforms

2002-47

March 14, 2002

IRS Issues Revenue Procedures Relating to Changes in Method of Accounting

2002-46

March 13, 2002

Filing Extension Granted for Form 1042-S, but Not for Form 1042

2002-45

March 12, 2002

Revenue Procedure Offers Automobile Dealers a Safe Harbor Method of Accounting for Vehicle Parts Inventory

2002-44

March 11, 2002

Analysis: New Loss Disallowance Rule Adopts Tracing and Appraisal Regime for Post-March 6, 2002 Consolidated Group Subsidiary Dispositions

2002-43

March 11, 2002

President Bush Signs the Job Creation and Worker Assistance Act of 2002

2002-42

March 8, 2002

Analysis: Job Creation and Worker Assistance Act of 2002

2002-41

March 8, 2002

Senate Approves Economic Stimulus Bill

2002-40

March 7, 2002

Treasury, IRS Issue Loss Disallowance Regulations and Announce Future Regulations to Prevent Duplication of Losses within a Consolidated Group

2002-39

March 7, 2002

Fifth Time’s a Charm: House Stimulus Package Draws Encouraging Words from Senate

2002-38

March 7, 2002

Proposed Regulations Under Sections 338 and 1060 Apply to Deemed Sale or Acquisition of Insurance Company’s Assets

2002-37

March 4, 2002

Webcast Video: Recent IRS Memorandum on Capitalization of Expenditures Raises Concerns

February 2002

Issue

Date

Subject

2002-36

February 28, 2002

IRS Memorandum Provides Guidance to Examiners Concerning Capitalization of Expenditures Relating to Intangible Assets or Benefits

2002-35

February 20, 2002

IRS Affirms Practice of Not Taxing Frequent Flyer Benefits

2002-34

February 20, 2002

Draft Text of Agreement Concerning Privileges for Taxpayers Making Disclosures Pursuant to Announcement 2002-2

2002-33

February 19, 2002

Proposed Regulations for Golden Parachute Payments Under Section 280G Are Released

2002-32

February 15, 2002

IRS Rules Favorably That Real Estate Development Impact Fees Are Properly Capitalized to the Basis of the Building, Rather Than to an Intangible Asset

2002-31

February 14, 2002

Legislative Update: House Approves Another Tax Stimulus Package

2002-30

February 14, 2002

Senate Finance Committee Approves Energy Tax Incentives

2002-29

February 12, 2002

Senate Finance Committee to Consider Energy Tax Incentives

2002-28

February 11, 2002

Ninth Circuit Affirms Tax Court in “Unpaid Losses” Case

2002-27

February 4, 2002

IRS Issues Procedures for Exchanges to Use in Requesting a Ruling Regarding Which Traders Qualify as "Dealers"

2002-26

February 4, 2002

Taxpayers Affected by September 11th Terrorist Attack Allowed Additional Time for Tentative Carryback Adjustments

2002-25

February 4, 2002

President Bush Proposes Changes to 401(k) Plans

2002-24

February 4, 2002

Economic Analysis: Overview of President’s 2003 Budget

2002-23

February 4, 2002

Legislative Update: Bush Administration Sends FY 2003 Budget, Tax Proposals to Congress

January 2002

Issue

Date

Subject

2002-22

January 31, 2002

Treasury, IRS Will Not Appeal Federal Circuit’s Decision in Rite Aid

2002-21

January 31, 2002

Legislative Update: Senate Finance Leaders State Their Intentions to Extend Expired Tax Provisions

2002-20

January 30, 2002

Legislative Update: Bush Delivers State of the Union

2002-19

January 28, 2002

Tax Court: Purported Tax-Free Reorganization Held Taxable, as Device to Distribute Earnings and Profits

2002-18

January 28, 2002

Temporary Regulations Expand Possibility of Relief From Denial of Deductions for Foreign Persons Missing the Filing Deadline for U.S. Tax Returns

2002-17

January 24, 2002

Legislative Update: Senate Resurrects Stimulus Package

2002-16

January 23, 2002

Legislative Update: CBO Presents 10-year Forecast to Congress

2002-15

January 23, 2002

President Bush Signs the Victims of Terrorism Tax Relief Act

2002-14

January 22, 2002

Final Intermediate Sanctions Regulations Are Issued

2002-13

January 18, 2002

Web Cast Video: Update on FSC/EIE

2002-12

January 17, 2002

Proposed Guidance Regarding the Deduction and Capitalization of Certain Expenditures

2002-11

January 17, 2002

Japan: Changes to Corporate Tax and Cross-Border Transactions Included in 2002 Tax Reform

2002-10

January 16, 2002

Tax Court: Controlled Foreign Corporation Not Found, Transfer of Assets Was Constructive Dividend and Subject to Withholding

2002-09

January 16, 2002

Regulations Address TIN Rules Where Foreign Individuals, Receiving an Unexpected Payment, Claim a Treaty Rate

2002-08

January 14, 2002

WTO Appellate Body Denies U.S. Appeal on FSC Replacement Legislation

2002-07

January 8, 2002

IRS Releases Safe Harbor Revenue Procedure for Restaurants and Taverns to Account for "Smallwares"

2002-06

January 8, 2002

IRS Updates Procedures for Automatic Changes in Methods of Accounting

2002-05

January 8, 2002

IRS Issues Final Regulations on LIFO Method

2002-04

January 7, 2002

IRS Issues Revenue Procedure on Automatic Changes in Methods of Accounting

2002-03

January 4, 2002

IRS Issues Proposed Regulations Relating to Insurance Premium Excise Tax

2002-02

January 4, 2002

Guidance Issued on Treatment of Split Dollar Life Insurance Arrangements

2002-01

January 3, 2002

IRS Issues Notice on Split-Dollar Life Insurance Arrangements

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