Internal Revenue Bulletin: 2003-43
October 27, 2003
Temporary and proposed regulations under section 1502 of the Code provide guidance concerning how a corporation that is a member of a consolidated group reduces its tax attributes when that member realizes discharge of indebtedness income that is excluded from gross income under section 108.
Temporary and proposed regulations under section 448(d)(5) of the Code provide guidance regarding the use of a nonaccrual-experience method by taxpayers using an accrual method of accounting and performing services. A public hearing on the proposed regulations is scheduled for December 10, 2003. Notice 2003-12 obsoleted. Rev. Proc. 2002-9 modified.
Section 1(h) of the Code provides that certain dividends paid to an individual shareholder from either a domestic corporation or a “qualified foreign corporation” are subject to tax at the reduced rates applicable to certain capital gains. The term “qualified foreign corporation” is defined to include possessions corporations and certain foreign corporations that are eligible for benefits of certain United States income tax treaties. A foreign corporation that is not otherwise treated as a qualified foreign corporation will be so treated with respect to any dividend it pays if the stock with respect to which the dividend is paid is readily tradable on an established securities market in the United States. This notice defines, for dividends received on or after January 1, 2003, what it means to be readily tradable on an established securities market in the United States.
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