INCOME TAX

Rev. Rul. 2002–41, page 75. Health reimbursement arrangements (HRAs). This ruling describes an employer-provided medical care expense reimbursement plan called a health reimbursement arrangement (HRA), in which reimbursements for medical care expenses made from the plan are excludable from employee gross income. Among other things, the HRA described retains favorable tax treatment because it only reimburses employees or former employees for medical care expenses of the employee or former employee and their spouses and dependents; is solely employer-funded and not paid for directly or indirectly from salary reduction; and although it allows participants to carry forward unused amounts for use in later coverage periods, these amounts may never be used for anything but reimbursements for qualified medical care expenses.

Rev. Rul. 2002–44, page 84. Short sale of stock. This ruling provides guidance on the timing of recognition of gain or loss on a short sale when stock is purchased to close the short sale using a regular-way sale.

T.D. 8999, page 78. Final regulations under section 894 of the Code relate to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. laws, but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (domestic reverse hybrid entities).