INCOME TAX

Rev. Rul. 2003–74, page 77. Section 355 management ruling. Where two different businesses operate within the same corporate group, and senior management wishes to focus on only one, the separation of the businesses to enable the management of each to concentrate on its own business satisfies the business purpose requirement of section 1.355–2(b) of the regulations.

Rev. Rul. 2003–75, page 79. Section 355 capital allocation ruling. Where two different businesses within the same corporate group are competing for limited capital, the separation of these businesses to resolve the capital allocation problem satisfies the business purpose requirement of section 1.355–2(b) of the regulations.

Rev. Rul. 2003–77, page 75. Community service facility. This ruling describes the type of facility that qualifies as a community service facility under section 42(d)(4)(C)(iii) of the Code.

Rev. Rul. 2003–78, page 76. Advance refunding bonds. This ruling concludes that tax-exempt bonds are advance refunding bonds within the meaning of section 149(d)(5) of the Code if proceeds of the bonds are loaned to a governmental unit (the conduit borrower) that uses the proceeds to redeem an outstanding tax-exempt obligation on which the conduit borrower is the obligor (the prior obligation) more than 90 days after the issue date of the bonds.

Finding Lists begin on page ii.