Rev. Rul. 2003-97 provides guidance on whether
SECTION 3. APPLICATION ESTIMATED TAXES
Internal Revenue Bulletin 2003-34 · 2026-10-03 edition · updated 2026-10-04 · United States
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To compute estimated tax and the installment payments of estimated tax due for taxable years beginning after December 31, 2001, a foreign insurance company must compute its estimated tax payments by adding to its income other than net investment income the greater of (i) its net investment income as determined under section 842(b)(5), that is actually effectively connected with the conduct of a trade or business within the United States for the relevant period, or (ii) the minimum effectively connected net investment income under section 842(b) that would result from using the most recently available domestic asset/liability percentage and domestic investment yield. Thus, for installment payments due after the publication of this revenue procedure, the domestic asset/liability percentages and the domestic investment yields provided in this revenue
August 25, 2003 407 2003-34 I.R.B.
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