INCOME TAX

Rev. Rul. 2003–105, page 696. Split-dollar life insurance arrangements. Certain previously published revenue rulings are obsoleted to the extent described in this ruling. The previously published rulings are obsoleted in light of T.D. 9092, which provides comprehensive final regulations regarding the federal income, gift, and employment taxation of split-dollar life insurance arrangements. Rev. Ruls. 78–420 and 79–50 obsoleted. Rev. Rul. 66–610 partially obsoleted.

T.D. 9080, page 696. REG–113112–03, page 760. Final, temporary, and proposed regulations under section 108 of the Code clarify that, in the case of a transaction described in section 381(a) that ends a year in which the distributor or transferor corporation excludes COD income from gross income under section 108(a), any tax attributes to which the acquiring corporation succeeds under section 381, and the basis of property acquired by the acquiring corporation in the transaction, shall reflect the reductions required by sections 108 and 1017.

T.D. 9083, page 700. Final regulations under section 280G of the Code provide rules for the treatment of golden parachute payments. A golden parachute payment includes certain compensation payments made to certain individuals in connection with a change in ownership or control of a corporation. These rules are effective for payments made on a change in control if the change in control occurs on or after January 1, 2004.

Finding Lists begin on page ii. Index for July through September begins on page ix.