Annuity payments. This ruling addresses the taxation of income received by residents of Puerto Rico and nonresident aliens under life insurance and annuity contracts issued by a foreign branch of a U.S. life insurance company. The ruling holds that income received by nonresident aliens under life insurance and annuity contracts issued by a foreign branch of a U.S. life insurance company is U.S.-source FDAP income. The ruling also holds that income received by bona fide residents of Puerto Rico under life insurance or annuity contracts issued by a Puerto Rican branch of a U.S. life insurance company is U.S.-source income.

Dual resident company. This ruling concludes that a dual resident company, resident in both Country Y and Country X under the domestic laws of those countries, is not entitled to claim benefits under the U.S. income tax convention with Country X if it is treated as a resident of Country Y and not of Country X for purposes of the income tax convention between Country X and Country Y and, as a result, is not liable to tax in Country X by reason of its residence. Rev. Rul. 73-354 obsoleted.

Corporate reorganizations; exchange of debt instruments. This ruling discusses the exchange of a debt security for a debt instrument in a reorganization.

Corporate distributions of property. This ruling addresses the tax consequences of the distribution by a subsidiary to its parent of parent indebtedness that the subsidiary previously purchased from a party unrelated to the parent.

This procedure provides alternative disclosure procedures that are deemed to satisfy a taxpayer’s disclosure obligations under section 1.6011-4 of the regulations for transactions with a significant book-tax difference under section 1.6011-4(b)(6). Taxpayers also may continue to follow the disclosure procedures provided in section 1.6011-4 for disclosing transactions described in section 1.6011-4(b)(6).