Internal Revenue Bulletin: 2003-49
December 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 December 2003.
Final, temporary, and proposed regulations under section 461 of the Code clarify that the transfer of a taxpayer's note or promise to provide property or services in the future is not a transfer for the satisfaction of a contested liability under section 461(f). A transfer of a taxpayer's stock or the stock or note of a related party also is not a transfer for the satisfaction of a contested liability under section 461(f). The temporary regulations further provide that, in general, economic performance does not occur when a taxpayer transfers money or other property to a trust, escrow account, or court to provide for the satisfaction of a contested workers compensation, tort, or other payment liability. A public hearing on the proposed regulations is scheduled for March 23, 2004.
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