Internal Revenue Bulletin: 2003-40
October 6, 2003
Split-dollar life insurance arrangements. Certain previously published revenue rulings are obsoleted to the extent described in this ruling. The previously published rulings are obsoleted in light of T.D. 9092, which provides comprehensive final regulations regarding the federal income, gift, and employment taxation of split-dollar life insurance arrangements. Rev. Ruls. 78-420 and 79-50 obsoleted. Rev. Rul. 66-610 partially obsoleted.
Final, temporary, and proposed regulations under section 108 of the Code clarify that, in the case of a transaction described in section 381(a) that ends a year in which the distributor or transferor corporation excludes COD income from gross income under section 108(a), any tax attributes to which the acquiring corporation succeeds under section 381, and the basis of property acquired by the acquiring corporation in the transaction, shall reflect the reductions required by sections 108 and 1017.
Final regulations under section 280G of the Code provide rules for the treatment of golden parachute payments. A golden parachute payment includes certain compensation payments made to certain individuals in connection with a change in ownership or control of a corporation. These rules are effective for payments made on a change in control if the change in control occurs on or after January 1, 2004.
Final regulations under section 1503(d) of the Code provide guidance regarding the events that require the recapture of dual consolidated losses. The regulations will facilitate compliance by taxpayers with the dual consolidated loss provisions. The regulations generally provide that certain events will not trigger recapture of a dual consolidated loss or payment of the associated interest charge. The regulations provide for the filing of certain agreements in such cases. This document also makes clarifying and conforming changes to the current regulations.
This notice provides guidance to brokers and individuals for information reporting of payments in lieu of dividends.
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