Bulletin No. 2003-33 August 18, 2003

Rev. Rul. 2003–92, page 350. Variable contract holder. This ruling holds that a variable contract holder is the owner of interests in a nonregistered partnership where interests in the nonregistered partnership are not available exclusively through the purchase of a life insurance or annuity contract. Rev. Rul. 81–225 clarified and amplified.

Rev. Rul. 2003–93, page 346. Low-income housing credit; satisfactory bond; “bond fac- tor” amounts for the period July through September 2003. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period July through September 2003.

Rev. Rul. 2003–94, page 357. Federal rates; adjusted federal rates; adjusted federal long- term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2003.

Rev. Rul. 2003–95, page 358. Life insurance contracts; distributions made in connection with a change in benefits. This ruling describes the rules of section 7702(f)(7) of the Code regarding the tax treatment of a cash distribution made in connection with a reduction in the benefits of a life insurance contract.

REG–131997–02, page 366. Proposed regulations under section 42 of the Code concerning the low-income housing tax credit make amendments to existing regulations to reflect statutory changes made by the Community Renewal Tax Relief Act of 2000. A public hearing is scheduled for September 23, 2003.

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Notice 2003–51, page 361. This notice accompanies Rev. Rul. 2003–76. The notice requests comments on possible additional guidance prescribing the tax treatment of partial exchanges of annuity contracts and also provides interim guidance.

Notice 2003–54, page 363. This notice advises taxpayers and their representatives about a tax shelter that uses a common trust fund (CTF) to invest in offsetting gain and loss positions in foreign currencies for the purpose of creating losses for a high net worth taxpayer and notifies the taxpayers and their representatives that the claimed tax benefits purportedly generated by these transactions are not allowable for federal income tax purposes. The notice also states that this transaction is a „listed transaction‰ and warns of the potential penalties that may be imposed if taxpayers claim losses from such a transaction.

Rev. Proc. 2003–66, page 364. Rents paid to a real estate investment trust (REIT) by a joint venture partnership that includes a taxable REIT subsidiary (TRS) of the REIT. This procedure provides conditions under which payments to a REIT from a joint venture between a TRS and an unrelated third party for space at a property owned by the REIT will be treated as rents from real property under section 856(d) of the Code.