SECTION 6. AMPLIFICATION OF

REV. PROC. 2003–3

.01 This revenue procedure amplifies section 4.01 of Rev. Proc. 2003–3, 2003–1 I.R.B. 113, relating to areas in which ruling letters or determination letters will not ordinarily be issued, by adding the following new paragraphs:

Section 451.—General Rule for Taxable Year of Inclusion—The income tax consequences as a result of being a beneficiary of a trust that an Indian tribe (as defined in 25 U.S.C. § 2703(5)) establishes to receive and invest per capita payments for its members who are minors or legal incompetents under the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701–2721), if the trust meets the requirements of section 5.02 of Rev. Proc. 2003–14.

Sections 671 through 679.—Grantors and Others Treated as Substantial Owners– Whether an Indian tribe (as defined in 25 U.S.C. § 2703(5)) that establishes a trust to receive and invest per capita payments for its members who are minors or legal incompetents under the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701–2721) is the grantor and owner of the trust, if the trust meets the requirements of section 5.02 of Rev. Proc. 2003–14. .02 This revenue procedure also amplifies section 5 of Rev. Proc. 2003–3, relating to areas in which rulings or

ing body of the Indian tribe; and (D) the per capita payments are subject to federal taxation and the Indian tribe notifies members of that tax liability when payments are made. Section 11(b)(3) and (d)(1)(A) of IGRA, 25 U.S.C. § 2710(b)(3) and (d)(1)(A).