ADMINISTRATIVE

Notice 2003–34, page 990. This notice identifies arrangements involving an investment in a purported insurance company organized offshore which invests in hedge funds or investments in which hedge funds typically invest. This notice alerts taxpayers to the fact that some of the arrangements may not qualify as insurance, some of the entities may not qualify as insurance companies, and the stakeholders involved may be subject to sections 1291–1298 of the Code (the passive foreign investment company rules).

Notice 2003–35, page 992. This notice reminds taxpayers that an entity must be an insurance company for federal income tax purposes in order to qualify as exempt from tax under section 501(c)(15) of the Code.

Notice 2003–36, page 992. Uniform capitalization; simplified service cost and sim- plified production methods. The Service and Treasury intend to publish guidance to clarify the types of property that qualify as eligible property for purposes of the simplified service cost and simplified production methods under the regulations under section 263A. Comments are requested. Also, taxpayers are informed of changes in the procedures for requesting approval of a change in method of accounting to one of these methods. Rev. Proc. 2002–9 suspended in part.

Rev. Proc. 2003–43, page 998. This procedure concerns relief for late S corporation elections, Electing Small Business Trust (ESBT) elections, Qualified Subchapter S Trust (QSST) elections, and Qualified Subchapter S Subsidiary (QSub) elections. Rev. Proc. 98–55 superseded.

June 9, 2003 2003–23 I.R.B.