Internal Revenue Bulletin: 2004-45
November 8, 2004
Table of Contents
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for November 2004.
Modification of Rev. Rul. 95-63. Rev. Rul. 95-63, with respect to countries described in section 901(j)(2)(A) of the Code, is modified by providing that Iraq ceased to be described in that section on June 27, 2004. Rev. Rul. 95-63 modified.
Final regulations under section 6050P(c)(2)(D) of the Code provide guidance on the information reporting requirements for discharges of indebtedness by organizations that have a significant trade or business of lending money. These regulations provide that the lending of money is a significant trade or business if money is loaned on a regular and continuing basis.
Section 1(h)(11) 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. This notice provides guidance for persons required to make returns and provide statements under section 6042 of the Code (e.g., Form 1099-DIV) regarding distributions with respect to securities issued by a foreign corporation, and for individuals receiving such statements. The notice also describes when a security (or an American depositary receipt in respect of such security) issued by a foreign corporation that is other than ordinary or common stock (such as preferred stock) will satisfy the readily tradable test.
This announcement notifies Archer MSA trustees of their obligation to report the number of Archer MSAs established between January 1, 2004, and June 30, 2004.
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