Internal Revenue Bulletin: 2003-36
September 8, 2003
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2003.
Temporary and proposed regulations under section 382 of the Code affect loss corporations and provide guidance on whether a loss corporation has an ownership change where a qualified trust described in section 401(a) distributes an ownership interest in an entity.
Substantiation of incidental expenses. Final and temporary regulations under section 274 of the Code authorize the Commissioner to establish a method under which a taxpayer may substantiate the amount of incidental expenses paid or incurred while traveling away from home by means of an allowance in lieu of substantiating the actual cost.
Final regulations under section 6038 of the Code amend regulations sections 1.6038-3 to 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 of Income for Electing Large Partnerships.
Final regulations under section 367 of the Code amend the anti-abuse rule of regulations section 1.367(e)-2(d) by narrowing the scope of the rule to apply only to outbound transfers to a foreign corporation in a complete liquidation of a domestic corporation to which a principal purpose of the liquidation is the avoidance of U.S. tax.
Proposed regulations, for purposes of the at-risk limitations under section 465 of the Code, relate to the treatment of amounts borrowed from a person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest. The proposed amendments provide that all activities are subject to the rule that these borrowed amounts do not increase the amount at risk in the activity.
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