Issue

Date

Subject

2003-370

December 31, 2003

IRS Identifies Certain Roth IRA Transactions as "Listed Transactions"

2003-369

December 31, 2003

Final INDOPCO Regulations Are Filed for Publication; Effective Date Is December 31, 2003

2003-368

December 31, 2003

Final Research Credit Regulations Are Released for Publication; Effective Date Is Established

2003-367

December 31, 2003

Beginning 2004, Certain U.S. Persons Must Report to the IRS Information on Foreign Disregarded Entities; Comments on Proposed Form 8858 Are Due March 1, 2004

2003-366

December 30, 2003

Temporary Regulations Specify When Changes to the Depreciation Treatment of an Asset Are Accounting Method Changes

2003-365

December 30, 2003

Final Regulations Revise the Definition of Income for Trust Purposes

2003-364

December 30, 2003

Ohio: Legislation Revises Sales Factor Computation

2003-363

December 29, 2003

Regulations Requiring Information Reporting Relating to Corporate Inversions

2003-362

December 29, 2003

Final Regulations, Other Guidance Concerning Tax Avoidance Transactions

2003-361

December 24, 2003

Final Regulations Reflect 2003 Act Changes on Information Reporting for "Substitute Payments"

2003-360

December 23, 2003

Final Research Credit Regulations Are Issued; Advanced Notice of Proposed Rulemaking for Internal-Use Software

2003-359

December 23, 2003

Proposed Rules Relating to Estate's Election to Value Property on Alternative Valuation Date

2003-358

December 22, 2003

Final INDOPCO Regulations Are Released; Proposed Regulations Are Expected to Address Repairs, Improvements to Tangible Property

2003-357

December 22, 2003

IRS Notice Addresses Charitable Contributions of Patents or Other Intellectual Property

2003-356

December 22, 2003

IRS Issues "Q&As" on Health Savings Accounts

2003-355

December 16, 2003

Final Regulations Establish Content Requirements for Qualified Joint and Survivor Annuities Explanations

2003-354

December 12, 2003

Treasury to Revise Regulations on Inversion Transaction Reporting

2003-353

December 11, 2003

Wisconsin: Tax Appeals Commission Rules Software Is Not Subject to Tax

2003-352

December 11, 2003

Legislative Update: Description of Tax Provisions in Energy Policy Act of 2003

2003-351

December 10, 2003

Treasury, IRS Amend Temporary Regulations Governing Section 108 Attribute Reduction by Members of a Consolidated Group

2003-350

December 10, 2003

Legislative Update: Congress Adjourns; No Action on Expiring Measures; Senate to Consider Pension Fix in January

2003-349

December 9, 2003

Legislative Update: Consensus Technical Corrections Bill Introduced

2003-348

December 9, 2003

Revenue Ruling Describes When Worthless Stock Deduction Allowed as Result of Change in Entity Classification of Corporation to Disregarded Entity

2003-347

December 8, 2003

Treasury Fact Sheet on Health Savings Accounts

2003-346

December 8, 2003

Third Circuit Rejects Taxpayer Assertion of Non-Recognition of Income Under Claim of Right Doctrine

2003-345

December 4, 2003

IRS Adds Transactions Involving Options on Foreign Currencies to "Listed Transactions"

2003-344

December 4, 2003

South Africa: Recent Tax Amendments

2003-343

December 2, 2003

D.C. Circuit Holds Portions of Regulations Invalid in Tax-Exemption Disclosure Litigation

2003-342

December 1, 2003

IRS Revises "Listed Transaction" Guidance Concerning Contested Liabilities

Issue

Date

Subject

2003-341

November 26, 2003

Information Reporting for Dividends Paid by Foreign Corporations

2003-340

November 26, 2003

Guidance on Reporting Rules for U.S. Persons with Interests in Canadian Retirement Plans

2003-339

November 26, 2003

Legislative Update: Energy Legislation Unlikely This Year

2003-338

November 25, 2003

Analysis of Recently Signed United States-Japan Income Tax Treaty

2003-337

November 25, 2003

IRS Guidance on Defined Contribution Plans Maintained by Professional Employer Organizations

2003-336

November 25, 2003

Legislative Update: Senate Approves Medicare Legislation

2003-335

November 21, 2003

United States, Aruba Sign Tax Information Exchange Agreement

2003-334

November 21, 2003

Legislative Update: House to Consider Medicare Conference Report

2003-333

November 21, 2003

Proposed Regulations Address Treatment of Installment Obligations, Contributed Contracts Under Sections 704(c) and 737

2003-332

November 21, 2003

Legislative Update: Energy Conference Report Stalled in Senate

2003-331

November 20, 2003

Legislative Update: Taxwriters Introduce Extenders Bills

2003-330

November 19, 2003

Proposed Ordering Rules for Charitable Remainder Trusts

2003-329

November 19, 2003

Treasury, IRS Amend Regulations Under Section 461(f) to Address Contested Liabilities

2003-328

November 19, 2003

Legislative Update: JCT Description of Tax Provisions in Energy Bill

2003-327

November 19, 2003

IRS Announces Inflation Adjustments for 2004

2003-326

November 18, 2003

Legislative Update: House Approves Energy Bill With Tax Incentives

2003-325

November 17, 2003

Severance Payments Were Not Deferred Compensation; Hence, Were Subject to Employment Taxes When Paid

2003-324

November 17, 2003

Court of Federal Claims: Interest Deduction Calculation for U.S. Branch of U.K. Bank Under 1975 Treaty

2003-323

November 17, 2003

Legislative Update: Conference Agreement to Energy Bill Includes Tax Incentives

2003-322

November 14, 2003

Legislative Update: Energy Conference Agreement to be Posted on Web

2003-321

November 12, 2003

Guidance Expected Before Year's End to Address Accounting Method Changes for Depreciation Recovery Periods

2003-320

November 10, 2003

Proposed Lease-Stripping Regulations Are Withdrawn

2003-319

November 7, 2003

IRS Updates, Restates the List of "Listed Transactions"

2003-318

November 6, 2003

United States, Japan Sign New Income Tax Treaty

2003-317

November 6, 2003

IRS Guidance for Partnerships With Tax-Exempt Investments

2003-316

November 5, 2003

Guidance Offers Return-Filing Exceptions for Certain Partnerships

2003-315

November 3, 2003

Treasury, IRS Release First Quarterly Update of 2003-2004 Priority Guidance Plan

Issue

Date

Subject

2003-314

October 31, 2003

Legislative Update: Status of Legislation to Replace FSC/ETI Regime

2003-313

October 29, 2003

IRS Announcement on Section 29 and Synthetic Fuels Produced From Coal

2003-312

October 28, 2003

Legislative Update: Ways and Means Approves FSC/ETI Replacement

2003-311

October 28, 2003

IRS Offers Tax Relief for California Wildfire Victims

2003-310

October 27, 2003

New York: Changes to Expense Disallowance Statute

2003-309

October 27, 2003

New Jersey: Court Holds Physical Presence Required for Income Tax Nexus

2003-308

October 24, 2003

Legislative Update: Statutory Language of "American Jobs Creation Act of 2003" Released, to Be Considered by Ways and Means on October 28

2003-307

October 23, 2003

Analysis of Proposed Regulations Under Section 482: Addressing Controlled Services Transactions and Allocation of Income From Intangibles

2003-306

October 22, 2003

Legislative Update: More Details of Proposed Ways and Means Mark of International Tax Bill, Scheduled for October 28 Markup

2003-305

October 21, 2003

Final Foreign Entity Classification Regulations on Grandfathered Foreign Entities and Relevance of Foreign Entities; "Extraordinary Transaction" Rule Formally Withdrawn

2003-304

October 21, 2003

California: Recent Tax Legislation

2003-303

October 21, 2003

Legislative Update: Summary of Provisions in the Senate Finance Committee's JOBS Bill (Not Related to International Tax, Domestic Production Deduction, or Tax Shelters)

2003-302

October 20, 2003

Sixth Circuit Follows Second and Ninth Circuits Concerning Recapture of Investment Tax Credits

2003-301

October 20, 2003

IRS Procedures on Use of Electronic Receipts and Expense Reports Under Expense Reimbursement Arrangements

2003-300

October 16, 2003

IRS Releases 2004 Pension Plan Limitations

2003-299

October 16, 2003

Legislative Update: Revisions to Proposed Ways and Means Mark of International Tax Bill

2003-298

October 15, 2003

IRS Acquiescence to Tax Court Decision, Holding Example in the Gift Tax Regulations Is Invalid

2003-297

October 15, 2003

Standard Mileage Allowance Increases to 37.5 Cents Per Mile for 2004

2003-296

October 10, 2003

Election for Partners and S Corporation Shareholders to "Ratably Spread" Income Where Accounting Period Change Is Required

2003-295

October 9, 2003

Legislative Update: Proposed Mark of International Tax Bill by Ways and Means

2003-294

October 8, 2003

Legislative Update: House Passes Temporary Solution for Calculating Defined Benefit Plan Contributions

2003-293

October 7, 2003

United States, the Netherlands Agree to New Administrative Arrangements for Mutual Agreement Procedure

2003-292

October 3, 2003

IRS Defines "Established Securities Market" Test for "Qualified Foreign Corporations" That Can Pay Dividends Eligible for 15% Tax Rate

2003-291

October 2, 2003

IRS Announces Luxury Automobile Depreciation Deduction Limitations for 2003

2003-290

October 1, 2003

Legislative Update: Finance Committee Approves International Tax Bill Replacing FSC/ETI With Manufacturing Deduction

Issue

Date

Subject

2003-289

September 30, 2003

Treaty List for "Qualified Foreign Corporations" That Can Pay Dividends Eligible for 15% Individual Tax Rate Under 2003 Act

2003-288

September 30, 2003

IRS Guidance on Deductible Convention Expenses in "North American Area"

2003-287

September 30, 2003

Legislative Update: Finance Committee to Mark Up International Tax Reform Bill

2003-286

September 29, 2003

Tax Court: Below-Market Financing May Be an Intangible Asset That Can Be Amortized

2003-285

September 26, 2003

Tax Court: Taxpayer Entitled to Amortize Loan Commitment and Legal Fees Associated with Reverse Subsidiary Merger

2003-284

September 26, 2003

Legislative Update: Finance Committee Leaders Add Revenue Raisers to FSC/ETI Repeal Bill

2003-283

September 24, 2003

IRS Grants Special Tax Relief for Victims of Hurricane Isabel

2003-282

September 19, 2003

Legislative Update: Chairman Grassley, Senator Baucus Release FSC-ETI Replacement Bill Text

2003-281

September 17, 2003

Legislative Update: Finance Committee Approves Pension Reforms with Executive Compensation, COLI Provisions

2003-280

September 15, 2003

IRS Guidance for Brokers, Individuals on Information Reporting for Substitute Payments

2003-279

September 16, 2003

IRS, State Tax Officials Form Partnership to Combat Abusive Tax Avoidance Transactions

2003-278

September 15, 2003

Eighth Circuit Holds for Taxpayer on Canadian Fishing Trip Expenses, Reverses District Court

2003-277

September 12, 2003

IRS Releases Guidance Regarding Identification of Built-in Gains and Losses under Section 382

2003-276

September 12, 2003

Analysis: Treasury Issues Temporary Regulations on the Application of Section 108 to Members of a Consolidated Group

2003-275

September 11, 2003

Final Regulations Issued on Split-Dollar Life Insurance Arrangements

2003-274

September 11, 2003

Massachusetts: Filing Deadline For Taxpayers Subject to Anti-PIC Addback Provisions is Extended

2003-273

September 9, 2003

Legislative Update: Ways and Means Panel To Mark Up Charitable Bill

2003-272

September 9, 2003

Proposed Regulations under Section 482 Address Controlled Services Transactions

2003-271

September 9, 2003

Reminder: Application for Tentative Refund May be Filed with Form 1120

2003-270

September 5, 2003

Proposed Regulations Issued under Section 482 Provide Guidance on Income from Intangibles, Services

2003-269

September 5, 2003

Temporary Regulations Issued On Bonus Depreciation Deduction

2003-268

September 5, 2003

Analysis of Final Regulations Concerning the Treatment of Stock-Based Compensation Under Section 482

2003-267

September 3, 2003

Over-the-Counter Drugs to be Covered by Health Care Flexible Spending Accounts

2003-266

September 3, 2003

Temporary Regulations Provide Guidance on the Nonaccrual Experience Method of Accounting

2003-265

September 2, 2003

Proposed Section 1446 Regulations Provide Guidance for Withholding by Partnerships Engaged in a U.S. Trade or Business

2003-264

September 2, 2003

Reminder: 25% of September 2003 Corporate Estimated Tax Payments Are Deferred Until October 1, 2003

Issue

Date

Subject

2003-263

August 29, 2003

Treasury Issues Regulations on Consolidated Attributes

2003-262

August 28, 2003

IRS Reminds Corporations of Postponement of September 2003 Estimated Tax Installment

2003-261

August 28, 2003

IRS Extends Deadline for Determination Letter Applications for Pre-Approved Qualified Retirement Plans

2003-260

August 28, 2003

Proposed Regulations on Contingent Payment Debt Instruments with Payment(s) Denominated in Nonfunctional Currency

2003-259

August 27, 2003

U.S., Austria Reach Agreement on Taxing Deferred Payments to U.S. Citizens Residing in Austria

2003-258

August 27, 2003

Analysis: U.S., Swiss Competent Authorities Provide Guidance on Treaty Benefits

2003-257

August 26, 2003

Legislative Update: Congress to Consider Energy and International Tax Provisions After Labor Day

2003-256

August 25, 2003

Final Regulations on Income from the International Operation of Ships and Aircraft

2003-255

August 25, 2003

Final Regulations Concerning the Treatment of Stock-Based Compensation Under Section 482

2003-254

August 22, 2003

U.S., Swiss Competent Authorities Provide Guidance on Treaty Benefits

2003-253

August 20, 2003

Connecticut: Statutory Expense Disallowance Provision Is Expanded

2003-252

August 15, 2003

IRS Grants Filing and Other Relief to Power Blackout Victims

2003-251

August 14, 2003

Legislative Update: Joint Committee Explains Proposed American Jobs Creation Act of 2003; Bill Includes Significant U.S. Tax Reductions Under Subpart F Regime

2003-250

August 13, 2003

IRS Allows Taxpayers to Apply Automatic Consent Procedures to Change Method of Accounting for Self-Constructed Assets

2003-249

August 12, 2003

Legislative Update: Congress Considers Repatriation Incentives

2003-248

August 5, 2003

Proposed Regulations Address Accounting Rules for Partnership Transactions Involving Long-Term Contracts

2003-247

August 4, 2003

Final Regulations Under Sections 897 and 1445 (FIRPTA): Foreign Persons Should Obtain U.S. TINs Before Transferring U.S. Real Property Interests

2003-246

August 1, 2003

Additional Reporting Relief for Canadian Retirement Trusts

2003-245

August 1, 2003

IRS Explains Trade Act Health Coverage Tax Credit to Health Plan Administrators

2003-244

August 1, 2003

Final Regulations, IRS Guidance for Golden Parachute Payments Under Section 280G

2003-243

August 1, 2003

Legislative Update: Senate Approves Energy Tax Incentives, With No Revenue Offsets

Issue

Date

Subject

2003-242

July 30, 2003

Analysis: New Proposed Research Credit Regulations

2003-241

July 29, 2003

Final Regulations Relating to Dual Consolidated Loss Recapture Rules

2003-240

July 28, 2003

Text of New Proposed Research Credit Regulations

2003-239

July 25, 2003

Legislative Update: Chairman Thomas Introduces American Jobs Creation Act of 2003; Senator Hatch Introduces FSC/ETI Repeal Bill

2003-238

July 24, 2003

Treasury, IRS Release 2003-2004 Priority Guidance Plan; Five Issues Are Selected for Industry Issue Resolution Program

2003-237

July 23, 2003

IRS Issues Revenue Ruling on Forward Contract/Note Units

2003-236

July 22, 2003

Customs Union Formed by Persian Gulf States

2003-235

July 22, 2003

Section 269B Guidance Changed – “Stapled” Foreign Corporation Will Be Treated as Includible Domestic Corporation for Foreign Tax Credit Limitation and Interest Allocation Rules

2003-234

July 21, 2003

IRS Rules Section 482 Cannot Be Used to Allocate Income, Deductions From Lease Stripping Transactions

2003-233

July 21, 2003

IRS Identifies Lease Stripping Transactions as "Listed Transactions"

2003-232

July 18, 2003

Proposed Regulations on Computing Depreciation Following a Change in Use

2003-231

July 18, 2003

Legislative Update: Ways and Means Approves Pension Bill

2003-230

July 18, 2003

Proposed Accounting Rules for REMIC Inducement Fees

2003-229

July 18, 2003

Regulations Under Section 409(p) on ESOPs Holding Stock of S Corporations

2003-228

July 17, 2003

Regulations Relating to Reduction of Tax Attributes Due to Discharge of Indebtedness

2003-227

July 16, 2003

IRS Targets Certain Common Trust Fund Straddle Transactions

2003-226

July 16, 2003

Section 419A Regulations Regarding 10-or-More Employer Plans Are Finalized

2003-225

July 16, 2003

New Proposed Regulations Under Sections 401(k) and 401(m)

2003-224

July 16, 2003

Final Regulations on Subchapter S Trust Elections for Testamentary Trusts

2003-223

July 16, 2003

IRS Issues Guidance for REITs and Taxable REIT Subsidiaries

2003-222

July 15, 2003

IRS Rules When Accrual Method Taxpayer Incurs Liability of California Franchise Tax for Federal Tax Purposes

2003-221

July 15, 2003

Final Regulations Under Section 417(a)(17) on Qualified Joint-and-Survivor Annuity

2003-220

July 11, 2003

Legislative Update: Tax Issues for the July Session

2003-219

July 11, 2003

IRS Establishes Safe Harbor for Loan by REIT to Be Treated as Real Estate Asset

2003-218

July 10, 2003

Final Regulations Under Section 457 for State and Local Governments and Tax-Exempt Entities

2003-217

July 10, 2003

Final IRS Guidance on Withholding Rules for Foreign Partnerships and Foreign Trusts

2003-216

July 9, 2003

Safe-Harbor Depreciation Method for Certain Cable Television Fiber Optic Communications Services Under the IRS Industry Issue Resolution Program

2003-215

July 8, 2003

Legislative Update: Finance Committee Urged to Replace FSC/ETI with Manufacturing Credit

2003-214

July 8, 2003

New Regulations Governing Section 338(h)(10) Elections and Multi-Step Transactions – A Brave New World

2003-213

July 7, 2003

KPMG Transfer Pricing Seminars, on West Coast in Mid-July 2003

2003-212

July 7, 2003

Proposed Regulations on Elimination of Forms of Benefit From Defined Contribution Plan

2003-211

July 7, 2003

Guidance for Individuals Seeking to Change From Fiscal Year to Calendar Year

2003-210

July 7, 2003

IRS Proposes Modifications to the Proposed Regulations Under Section 465

2003-209

July 7, 2003

IRS Guidance on Statute of Limitations on Excise Tax for Failure to Satisfy Pension Plan Minimum Funding Requirements

2003-208

July 7, 2003

Final Regulations on Catch-Up Contributions for Individuals Age 50 Years or Older

2003-207

July 3, 2003

Vans and Light Trucks Are Provided Higher Luxury Automobile Deprecation Limitation in 2003 Than for Other Vehicles; Certain Vans and Trucks Will Be Exempt From the Limitation

2003-206

July 3, 2003

Final Regulations on Tax Treatment of Guaranteed Annuity and Unitrust Interests

2003-205

July 2, 2003

Tax Amnesty: Florida, Illinois, New York City, Arizona, Kansas, and North Dakota

2003-204

July 2, 2003

Saudi Arabia: Tax, Business, and Accounting News

2003-203

July 1, 2003

IRS Guidance on Transfer of Excess Assets to Qualified Replacement Plan After Termination of Defined Benefit Plan

2003-202

July 1, 2003

IRS Guidance on COBRA Coverage After Acquisition

2003-201

July 1, 2003

Revenue Ruling Addresses Spin-Off and Acquisition of Newly Formed Controlled Corporation

2003-200

July 1, 2003

Proposed Regulations Would Allow Partnerships to Revalue Property on Issuance of Profits Interests to Service Partners

2003-199

July 1, 2003

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

2003-198

July 1, 2003

Guidance on Transfers of Stock Options to Related Parties Under Section 83

Issue

Date

Subject

2003-197

June 30, 2003

Final Regulations on Substantiation of "Incidental Expenses"

2003-196

June 30, 2003

Final Regulations Provide Filing Guidance for U.S. Partners of Certain Controlled Foreign Partnerships

2003-195

June 27, 2003

IRS Establishes Asset Guideline Class for a Utility's Assets Used in General Business Operations

2003-194

June 27, 2003

IRS Corrects Form 8873 (Extraterritorial Income Exclusion)

2003-193

June 27, 2003

IRS Issues Ruling on Reasonable Funding Methods Under Section 412(c)(3)

2003-192

June 27, 2003

Legislative Update: Congress Takes Recess After Passing Medicare Bills

2003-191

June 27, 2003

IRS Announces Suspension of Section 29 Rulings

2003-190

June 26, 2003

IRS Extends Time to Elect Midquarter Convention Relief Under Notice 2001-70 and Notice 2001-74

2003-189

June 26, 2003

IRS Extends 30% Bonus Depreciation Procedures, Allows More Time for Selection of Section 179 Property

2003-188

June 26, 2003

Regulations Address Ownership Change of Loss Corporation on Distribution by Section 401(a) Trust to Plan Participants

2003-187

June 26, 2003

Treasury and IRS to Withdraw "Extraordinary Transaction" Rule From Proposed Regulations on Foreign Entity Classification, but Will Challenge Unintended Results of Electing Entity Classification

2003-186

June 25, 2003

IRS Guidelines for Determining Inventory Valuations in Corporate Acquisitions

2003-185

June 25, 2003

Rev. Proc. 2003-48 Limits Issues for Consideration in PLR Requests Under Section 355

2003-184

June 24, 2003

IRS Issues Guidance for Ruling Requests Under Section 355

2003-183

June 24, 2003

Revenue Ruling Addresses Business Purpose Requirement in "Access-to-Capital/Fit-and-Focus" Spin-off

2003-182

June 24, 2003

IRS Addresses Business Purpose Requirement in "Fit-and-Focus" Spin-off

2003-181

June 23, 2003

Texas: Refund Limitation, Other Measures Are Enacted

2003-180

June 23, 2003

Regulations Address Assumption of Certain Liabilities by Partnerships

2003-179

June 18, 2003

Legislative Update: House Passes Permanent Estate Tax Repeal

2003-178

June 18, 2003

Revenue Procedure Waives 5-Year Prior Change Scope Limitation for Accounting Method Changes

2003-177

June 17, 2003

D.C. Circuit Affirms That Rent Stripping Transactions Should Be Disregarded

2003-176

June 17, 2003

Compliance Initiative for Nonresident Aliens and Foreign Corporations That Have Not Filed Timely Returns for a U.S. Trade or Business: Deductions and Credits Not Disallowed

2003-175

June 17, 2003

Eighth Circuit Holds Two Depreciation Issues Against IRS, Agrees with Fifth Circuit That Certain MACRS Depreciation Changes Are Not Accounting Method Changes

2003-174

June 16, 2003

IRS Releases Third Annual Report on Pre-Filing Agreement Program

2003-173

June 13, 2003

Maryland: Court of Appeals Overturns Taxpayer-Favorable Decision for Certain Delaware Holding Companies

2003-172

June 13, 2003

New York: Tax Tribunal Reverses Sherwin-Williams

2003-171

June 12, 2003

Legislative Update: House Approves Child Tax Credit Bill

2003-170

June 11, 2003

United States, Japan Initial New Income Tax Treaty

2003-169

June 11, 2003

Individual Taxpayers Can Use Lower Rates in Upcoming 2003 Second Quarterly Estimated Income Tax Payments

2003-168

June 10, 2003

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

2003-167

June 10, 2003

Temporary Regulations on Automatic Extension of Time to File Information Returns

2003-166

June 9, 2003

IRS Guidance When Qualified Retirement Plan Accruals Are Frozen and Later Thawed

2003-165

June 6, 2003

IRS Issues Final Regulations Relating to the Allocation of Basis Adjustments Among Partnership Assets Under Section 755

2003-164

June 6, 2003

Proposed Regulations Offer Guidance Concerning ISOs and ESPPs

2003-163

June 5, 2003

Legislative Update: Revenue Offsets Reappear in New Tax Bills

2003-162

June 4, 2003

IRS Updates Employee Plans Compliance Resolution System

2003-161

June 3, 2003

IRS Finalizes Alternative Dispute Resolution Programs, Introduces New ADR Measures for Tax-Exempt Bonds

2003-160

June 3, 2003

Legislative Update: Bill Related to Refundability of Child Tax Credit for Low-Income Workers Includes "Enron-Related" Revenue Offsets

Issue

Date

Subject

2003-159

May 28, 2003

Ninth Circuit Affirms, Covenant Not to Compete in Connection With Stock Redemption Subject to 15-Year Amortization Under Section 197

2003-158

May 28, 2003

New Withholding Tables Reflect Changes in Tax Law

2003-157

May 28, 2003

IRS Issues Guidance on Advance Child Tax Credit Payments

2003-156

May 28, 2003

Legislative Update: President Bush Signs the Jobs and Growth Tax Relief Reconciliation Act of 2003

2003-155

May 23, 2003

Sixth Circuit Addresses VEBA's Unrelated Business Income

2003-154

May 23, 2003

Legislative Update: Congress Puts Off Foreign Earnings Repatriation Legislation

2003-153

May 23, 2003

Legislative Update: Congress Clears Tax Bill for President's Signature

2003-152

May 22, 2003

Legislative Update: Statutory Language and Summary of Tax Relief Bill

2003-151

May 20, 2003

New U.K./U.S. Income Tax Treaty: Little IRS Guidance on Claiming the New Treaty's Benefits, or Electing to Delay the New Treaty's Entry Date, for U.S. Withholding Taxes

2003-150

May 19, 2003

New York: Anti-PIC Provision Is Enacted

2003-149

May 19, 2003

Analysis: The Final Factor – Temp Reg. 1.1502-35T Takes a New Approach to Barring Duplicated Losses

2003-148

May 19, 2003

Proposed Regulations on Deemed IRAs in Qualified Plans

2003-147

May 16, 2003

Legislative Update: Conferees to Meet Next Week on Tax Bill

2003-146

May 15, 2003

IRS Clarifies Tax Treatment of Certain Medical Expenses

2003-145

May 14, 2003

Legislative Update: Senate Takes Up Modified Tax Bill

2003-144

May 13, 2003

2001 Protocol to 1982 U.S.-Australia Income Tax Convention: Effective Dates

2003-143

May 12, 2003

Protocol to U.S.-Australia Tax Treaty; Exchange of Instruments of Ratification

2003-142

May 12, 2003

Business Purpose Requirement Is Satisfied, Even Though Thwarted by Unexpected Change in Circumstances

2003-141

May 12, 2003

Business Purpose Is Satisfied in "Going Your Own Way" Split-Off of Family Business

2003-140

May 12, 2003

Legislative Update: Statutory Language, Finance Committee Explanation of "Jobs and Growth Reconciliation Tax Act of 2003"

2003-139

May 9, 2003

Legislative Update: House Passes $550 Billion Tax Cut

2003-138

May 9, 2003

Proposed Regulations Address Private Activity Bond Restrictions to Refunding Issues

2003-137

May 9, 2003

Simplified Method to Request Relief for Late Elections Under Subchapter S

2003-136

May 9, 2003

IRS Releases Guidance on Tax Consequences of Like-Kind Exchanges That Straddle Two Tax Years

2003-135

May 9, 2003

Proposed Amendments to Adjustment Period Rules for Changes in Methods of Accounting

2003-134

May 9, 2003

Sample Trust Declaration for Qualified Personal Residence Trust (QPRT) for Gift Tax Valuations

2003-133

May 9, 2003

Certain Arrangements Using Offshore Entities Investing in Hedge Funds Not Entitled to Claimed Tax Benefits

2003-132

May 8, 2003

IRS Guidance on Treatment of Gasoline Station Pump Canopies

2003-131

May 8, 2003

IRS Intends to Address Uncertainty as to Accounting Methods for Self-Constructed Assets

2003-130

May 8, 2003

Legislative Update: Senate Finance Committee Considering $350 Billion Tax Cut

2003-129

May 8, 2003

Proposed Regulations Supplement Existing Guidance on Split-Dollar Life Insurance Arrangements

2003-128

May 7, 2003

IRS Provides Guidance on Substantiating Valuations Under the Fair Market Value Method of Interest Expense Apportionment

2003-127

May 7, 2003

IRS Provides Safe Harbors for Like-Kind Exchanges Under Section 1031 for LKE Programs

2003-126

May 7, 2003

Analysis: "New" Temporary and Proposed Regulations Define a Statutory Merger or Consolidation

2003-125

May 6, 2003

IRS Guidance on Use of Debit and Credit Cards in Medical Reimbursement Plans

2003-124

May 6, 2003

Legislative Update: House Tax Panel Starts Markup

2003-123

May 6, 2003

Insurance: Final Regulations Under Section 817A Concerning Modified Guaranteed Contracts

2003-122

May 5, 2003

Advance Notice of Proposed Rulemaking Regarding Assumed Liability

2003-121

May 5, 2003

IRS Rules on Section 351 Control Requirement in Successive Transfers

2003-120

May 5, 2003

Analysis: Proposed Safe Harbor for Satisfying Statutory Requirements for Valuation Under Section 475 for Certain Securities and Commodities

2003-119

May 2, 2003

Proposed Safe Harbor Framework for Valuation of Certain Securities and Commodities

2003-118

May 2, 2003

Final Regulations on Earnings Calculation for Returned or Recharacterized IRA Contributions

2003-117

May 2, 2003

Legislative Update: House, Senate Committees Move Toward Reporting Tax Bills

2003-116

May 1, 2003

IRS Guidance on Section 457(e) Length-of-Service Award Plans

2003-115

May 1, 2003

IRS Guidance on Reporting and Withholding Requirements for Section 457(b) Plans

2003-114

May 1, 2003

Court of Federal Claims: No Federal Excise Tax Refund, Despite Claims of Specialized Vehicles

2003-113

May 1, 2003

IRS Initiates Gaming Industry Tip Compliance Agreement Program

Issue

Date

Subject

2003-112

April 29, 2003

State Taxes: Amnesty Programs Enacted in Virginia, Colorado, and Maine

2003-111

April 28, 2003

Sixth Circuit Affirms COLI Judgment for Government

2003-110

April 28, 2003

Final Regulations for Backup Withholding, Solicitation Rules on IRS Notification of Incorrect TINs

2003-109

April 25, 2003

Legislative Update: Congress Returns with Tax Debate at Top of Agenda

2003-108

April 23, 2003

Supreme Court: Nevada Court Not Required to Extend Full Faith and Credit to California Statute Immunizing Its Tax Agency from Suit

2003-107

April 23, 2003

Analysis: Cinergy Corp. v. United States – Court of Federal Claims Finds That Asbestos Removal Costs Are Deductible

2003-106

April 22, 2003

IRS Finds "E" and "F" Reorganizations on Conversion of Mutual Savings Bank to Stock Savings Bank

2003-105

April 21, 2003

Outline: Temporary Anti-Loss-Duplication Rules for Consolidated Groups – Temp Reg. § 1.1502-35T

2003-104

April 17, 2003

IRS Solicits Comments on Business Plan Items for 2003-04

2003-103

April 17, 2003

IRS Revises Industry Issue Resolution Program Procedures

2003-102

April 11, 2003

Changes to Reporting Requirements for Canadian Retirement Trusts

2003-101

April 11, 2003

IRS Targets Certain Arrangements Attempting to Qualify as Collectively Bargained Welfare Benefits

2003-100

April 11, 2003

Legislative Update: Ways and Means Members Introduce Alternative FSC/ETI Repeal Bill

2003-99

April 9, 2003

Court of Federal Claims Refuses Refund Because Manufacturer Did Not Bear Economic Burden of Excise Tax

2003-98

April 8, 2003

Revenue Procedure Modifies Terms and Conditions Relating to Requests for Changes in Annual Accounting Periods

2003-97

April 8, 2003

Webcast: Global Interest Netting in Light of the Fannie Mae Case

2003-96

April 8, 2003

IRS Addresses Direct Liability of Air Carriers for Air Transportation Excise Tax in Certain Situations

2003-95

April 8, 2003

Final Regulations on Notices to Be Provided to Adversely Affected Plan Participants

2003-94

April 7, 2003

Proposed Cash Balance Regulations Are Withdrawn

2003-93

April 4, 2003

IRS Targets Offshore Deferred Compensation Arrangements

2003-92

April 4, 2003

Ruling Addresses the Spinoff of New ".com" Business

2003-91

April 4, 2003

IRS Makes Permanent Fast Track Settlement Program

2003-90

April 4, 2003

Disaster Relief for Certain Taxpayers in Kentucky and Ohio

2003-89

April 4, 2003

Legislative Update: Ways and Means Committee Approves Energy, Taxpayer Rights Bills

2003-88

April 3, 2003

Court of Federal Claims: Global Interest Netting Applies As Long As One Limitations Period Is Open

2003-87

April 2, 2003

IRS to Allow Taxpayers to Exclude Certain Fuel Cost and Energy Conservation Costs Overrecoveries From Gross Income

2003-86

April 2, 2003

"Automatic" Extension of Time to File Section 338 Elections

2003-85

April 2, 2003

Legislative Update: Finance Committee Approves Energy Tax Incentives

2003-84

April 2, 2003

Federal District Court Allows Taxpayer's $22 Million Refund Claim Related to COLI Plans

2003-83

April 1, 2003

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

Issue

Date

Subject

2003-82

March 31, 2003

IRS Guidance for RICs Holding Partnership Interest; RIC Is Treated as Directly Invested in Partnership's Underlying Asset

2003-81

March 31, 2003

IRS Releases APA Program Report for 2002

2003-80

March 31, 2003

Exchange of Instruments of Ratification for U.S.-UK Income Tax Treaty

2003-79

March 31, 2003

Proposed Definition of "Toll Telephone Service" for Communications Excise Tax Purposes

2003-78

March 26, 2003

Fourth Circuit: Expenditures Are Not Deductible Under Section 174

2003-77

March 24, 2003

United States Court of Appeals for Federal Circuit Reverses Judgment of the Court of Federal Claims in "One-Claim Rule" Case

2003-76

March 24, 2003

Status of U.S.-UK Income Tax Treaty and Protocol

2003-75

March 24, 2003

IRS Releases Reportable Transaction Disclosure Form

2003-74

March 24, 2003

IRS Guidance on Tax Treatment of Rotable Spare Parts

2003-73

March 19, 2003

IRS Updates Filing Addresses for Certain Elections, Statements, and Other Documents

2003-72

March 19, 2003

IRS Guidance on Tax Treatment for Certain Grants to Businesses Located in World Trade Center Area

2003-71

March 17, 2003

Final Regulations Provide Amendments to the Special Rules for Determining a Partner's Interest

2003-70

March 14, 2003

U.S. Senate Approves Tax Treaty with United Kingdom, Protocols with Australia and Mexico

2003-69

March 14, 2003

Final Regulations on Corporate Transfers to RICs or REITs

2003-68

March 13, 2003

IRS Takes Steps to Combat Offshore Payment Card Arrangements

2003-67

March 13, 2003

Tax Shelter Regulations: Outline Presentation, Text of Final Regulations and Related Revenue Procedures

2003-66

March 12, 2003

Legislative Update: Budget Committees Begin Considering $726 Billion Tax Cut

2003-65

March 12, 2003

PATA Reaches Final Transfer Pricing Documentation Agreement

2003-64

March 11, 2003

Temporary and Proposed Loss Duplication Regulations Are Released

2003-63

March 11, 2003

Court of Federal Claims: Asbestos Removal Costs Are Deductible

2003-62

March 11, 2003

Interest/Penalty Relief Extended to Certain Estates of Taxpayers Affected by 2001 Terrorist Attack

2003-61

March 7, 2003

Final Regulations Provide Relief From Denial of Deductions and Credits for Foreign Corporations and Individuals That Failed to "Timely File" U.S. Tax Returns

2003-60

March 6, 2003

Massachusetts: Tax Legislation Is Enacted

2003-59

March 5, 2003

Connecticut: Corporate Tax Surcharge Is Enacted

2003-58

March 5, 2003

South Africa: Proposed Tax Amendments Included in 2003 Budget

2003-57

March 5, 2003

FSC/ETI: European Commission Submits Draft Sanctions List to EU Member States

2003-56

March 4, 2003

U.S. Supreme Court: DISC Regulations Upheld

2003-55

March 3, 2003

Proposed Regulations Allow Utilities to Flow Through Certain Reserves to Customers for Assets Ceasing to Be Public Utility Property

Issue

Date

Subject

2003-54

February 27, 2003

Final Tax Shelter Regulations, Related Revenue Procedures Are Released

2003-53

February 27, 2003

Legislative Update: Jobs and Growth Act of 2003 Is Introduced

2003-52

February 26, 2003

IRS Addresses Deductibility of Charitable Contribution of a Patent or License to Use a Patent

2003-51

February 26, 2003

Legislative Update: Senate Foreign Relations Committee Schedules Hearing on UK Tax Treaty and Protocols with Australia and Mexico

2003-50

February 25, 2003

Analysis: Ninth Circuit Review of NFL Team's Treatment of Loans and Settlement Proceeds

2003-49

February 21, 2003

Webcast: IRS Directive Launches New Transfer Pricing Compliance Initiative

2003-48

February 20, 2003

IRS Releases Guidance for ESOPs Owning Stock of an S Corporation

2003-47

February 18, 2003

Ninth Circuit: Two-Life Annuity Is "Qualified" Interest for GRATs

2003-46

February 13, 2003

Tax Court: VEBA Contributions for Retired Employees May Be Allocated "Up Front"

2003-45

February 11, 2003

IRS Aims for Stricter Enforcement of 30-Day Period for Transfer Pricing Reports

2003-44

February 11, 2003

Tax Court: Partnerships Not Organized or Operated for Nontax Business Purpose Are Disregarded

2003-43

February 10, 2003

Limited Opportunity for U.S. Taxpayers to Disclose Offshore Payment Card Arrangements

2003-42

February 6, 2003

Legislative Update: Senate Finance Committee Approves Bill Including Tax Shelters

2003-41

February 5, 2003

Court of Federal Claims Refuses Federal Excise Tax Refund, Despite Specialized Nature of Vehicles

2003-40

February 4, 2003

Massachusetts: Significant Tax Changes Proposed; Possible Retroactive Effect

2003-39

February 3, 2003

IRS Establishes Procedures for the Expanded TIN Matching Program and Proposes Procedures for Qualified Payment Card Agents

2003-38

February 3, 2003

Legislative Update: President's Budget Reiterates Three Revenue-Raising Proposals Among $1.46 Trillion in Tax Cuts

Issue

Date

Subject

2003-37

January 31, 2003

Legislative Update: Grassley Plans Senate Finance Session on Charitable Bill

2003-36

January 31, 2003

Legislative Update: Budget to Include Consolidated Retirement Savings Proposals

2003-35

January 30, 2003

Final Regulations on the Treatment of Hedging Transaction Gains or Losses Relating to Foreign Personal Holding Company Income

2003-34

January 30, 2003

Regulations Address TIN Matching Program and Propose Backup Withholding Rules for Certain Credit Card Transactions

2003-33

January 28, 2003

Legislative Update: Congress Returns with Taxes High on Agenda

2003-32

January 24, 2003

United States, Switzerland Agree to Exchange Tax Information

2003-31

January 24, 2003

Treasury Updates 2002-2003 Priority Guidance Plan

2003-30

January 24, 2003

Analysis: IRS Interim Guidance on Use of Nonaccrual Experience (NAE) Method

2003-29

January 23, 2003

Temporary Regulations Define "Statutory Merger or Consolidation"

2003-28

January 23, 2003

IRS Guidance for Foreign Companies with U.S. Life Insurance Business

2003-27

January 22, 2003

Rev. Rul. 2003-18 Addresses Section 355(b) Active Trade or Business Requirement

2003-26

January 22, 2003

IRS Issues Guidance on Tax Consequences of Converting Mutual Insurance Company to Stock Insurance Company

2003-25

January 22, 2003

IRS Releases Interim Guidance on Use of Nonaccrual Experience Method (NAE)

2003-24

January 22, 2003

Webcast: Discussion of Blue Book's Analysis of Dividend Exclusion Proposal

2003-23

January 22, 2003

IRS Offers Safe Harbor Inventory Valuation Method for Automotive Remanufacturing Industry

2003-22

January 22, 2003

IRS Provides Relief to Brokers and Corporations Required to File Form 1099-CAP for 2002 Corporate Inversion Transactions

2003-21

January 21, 2003

Proposed Regulations Address Tax Treatment of Noncompensatory Options and Convertible Instruments Issued by Partnerships

2003-20

January 21, 2003

Video/Audio Conference: Emerging Issues in State Taxation

2003-19

January 21, 2003

Legislative Update: Treasury Releases "Blue Book" Explanation of Dividend Exclusion Proposal

2003-18

January 17, 2003

IRS Notice Delays Effective Date of Disclosure and List Maintenance Regulations

2003-17

January 16, 2003

IRS Rules on Variable Share Prepaid Forward Contracts

2003-16

January 15, 2003

Annual IRS Guidance Revises Procedures for Ruling, Determination, and Information Letters; Changes in User Fees

2003-15

January 15, 2003

Tax Court: Section 304 "Cross-Chain" Sales Were Part of Integrated Plan to Terminate Target Corporations' Interest in Issuing Corporations

2003-14

January 14, 2003

Legislative Update: Treasury Releases Fact Sheets on Proposed Dividend Relief

2003-13

January 14, 2003

Legislative Update: Preliminary Report on Proposed Dividend Relief

2003-12

January 13, 2003

OMB Deputy Tapped to Be New IRS Commissioner

2003-11

January 13, 2003

Massachusetts: Amnesty Extended and Electronic Filing Requirements Expanded

2003-10

January 10, 2003

Treasury, IRS Intend to Propose Regulations Relating to Early Retirement Benefits and Retirement-Type Subsidies

2003-09

January 10, 2003

D.C. Circuit Holds for Government in Boca Investerings; District Court Is Reversed

2003-08

January 10, 2003

Final Regulations on When Spouse Will Be Taxed on Certain Stock Redemptions During Marriage or Incident to Divorce

2003-07

January 9, 2003

IRS Waives Certain Reporting Requirements for Securities Futures Contracts Until Further Notice

2003-06

January 8, 2003

Procedures for Obtaining Waiver of 60-Day Rollover Requirement Under Sections 402(C)(3)(A) and 408(D)(3); Automatic Waiver In Some Circumstances

2003-05

January 7, 2003

Bush Tax Proposal Launches Legislative Season

2003-04

January 6, 2003

IRS Addresses Application of Accrual Method to Disputes Between Vendors and Retailers

2003-03

January 6, 2003

Revenue Ruling Provides Guidance on Application of Section 1259 to Successive Short Sales of Appreciated Financial Position

2003-02

January 3, 2003

Webcast: Discussion of Proposed INDOPCO Regulations

2003-01

January 2, 2003

IRS Guidance on "Deemed IRAs" Implements Section 408(q)