INCOME TAX

Rev. Rul. 2003–1, page 291. Constructive sales; reestablished positions. This ruling provides guidance on the interaction between section 1259(c)(3)(A) of the Code (exception for certain closed transactions) and section 1259(c)(3)(B) (treatment of positions which are reestablished).

Rev. Rul. 2003–8, page 290. Costa Rican income tax law; withholding taxes. This ruling holds that certain Costa Rican taxes are noncreditable soak-up taxes under sections 901 and 903 of the Code. The ruling also serves as an official confirmation to the Costa Rican Tax Administration that these taxes are noncreditable in the United States.

Rev. Rul. 2003–10, page 288. Accrual of income. This ruling addresses the accrual of gross income when a taxpayer’s customer disputes its liability to the taxpayer because of (1) a clerical mistake in a sales invoice, (2) the shipment of the wrong goods, or (3) the shipment of more items than the customer ordered.

Rev. Rul. 2003–12, page 283. Gross income; general welfare; gifts; disaster relief pay- ments. This ruling holds that amounts paid to an individual by a state agency, a charity, or an employer to reimburse the individual for certain expenses the individual incurs as a result of a Presidentially declared disaster are excluded from the individual’s gross income under the administrative general welfare exclusion, sections 102 and 139 of the Code, respectively. Rev. Rul. 53–131 modified.

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