Internal Revenue Bulletin: 2004-33
August 16, 2004
Table of Contents
Effect of mergers on qualified subchapter S subsidiary (QSub) elections. This ruling discusses the effect certain interest transfers have on QSub and entity classification elections.
Classification of Delaware statutory trust. This ruling explains how a Delaware statutory trust described in the ruling will be classified for federal tax purposes and whether a taxpayer may acquire an interest in the Delaware statutory trust without recognition of gain or loss under section 1031 of the Code. Rev. Ruls. 78-371 and 92-105 distinguished.
This notice consists of 88 questions and answers on Health Savings Accounts (HSAs) that have not been previously addressed. This notice also provides transition relief for months before January 1, 2005, for health plans, which would otherwise qualify as high deductible health plans (HDHPs) except for the absence of an express limit on out-of-pocket expenses. It also provides transition relief for months before January 1, 2006, for health plans which allow deductibles to be satisfied over a period of more than 12 months. Notice 2004-2 modified.
Requests for comments concerning the application of section 761. This notice requests comments regarding the application of section 761 of the Code and whether section 1.761-2(a)(2) of the regulations should be revised, modified, or clarified.
This notice provides that paid preparers will be permitted to sign original returns, amended returns, or requests for filing extensions by rubber stamp, mechanical device (such as signature pen), or computer software program.
This procedure grants relief to S corporations that had a QSub election of a subsidiary terminate as a result of a transfer described in Situation 2 of Rev. Rul. 2004-85.
Like-kind exchanges using qualified exchange accommodation arrangements. This procedure modifies Rev. Proc. 2000-37, 2000-2 C.B. 308, to provide that the safe harbor of Rev. Proc. 2000-37 does not apply to replacement property held in a qualified exchange accommodation arrangement if the property is owned by a taxpayer within the 180-day period ending on the date of transfer of qualified indicia of ownership of the property to an exchange accommodation titleholder. Rev. Proc. 2000-37 modified.
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