Bulletin No. 2003-32 August 11, 2003

T.D. 9067, page 287. REG–116914–03, page 338. Temporary and proposed regulations under section 83 of the Code clarify and amend existing regulations to address the transfers of compensatory stock options to related persons. The regulations provide that the transfer of a compensatory stock option to a related person will not be treated as an armÊs length transaction for purposes of section 1.83–7 of the regulations.

Notice 2003–50, page 295. This notice announces that regulations issued under section 269B of the Code will provide that a foreign corporation that is stapled to a domestic corporation will be treated as a domestic corporation for purposes of the definition of an includible corporation under section 1504(b) when applying sections 1.904(i)–1 and 1.861–11T(d)(6). Notice 89–94 modified.

Notice 2003–52, page 296. This notice clarifies the application of section 911 of the Code to U.S. citizens and residents earning income in Iraq attributable to services performed by such individuals. As long as individuals whose activities in Iraq are permitted by a specific or general license issued by TreasuryÊs Office of Foreign Assets Control, those individuals are not subject to the limitations of section 911(d)(8)(A).

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Announcement of Declaratory Judgment Proceedings Under Section 7428 begins on page 345. Announcements of Disbarments and Suspensions begin on page 339. Finding Lists begin on page ii.

Rev. Proc. 2003–64, page 306. This procedure contains the final withholding foreign partnership (WP) and withholding foreign trust (WT) agreements. The WP and WT agreements are designed to simplify withholding and reporting obligations for payments of income made to foreign partnerships and foreign simple or grantor trusts. This procedure also contains rules regarding withholding and reporting on certain small or related foreign partnerships and foreign simple or grantor trusts that do not enter into WP or WT agreements. Section III.C. of Notice 2001–4 superseded for 2004 and subsequent calendar years. Rev. Proc. 2000–12 modified.