INCOME TAX

Rev. Rul. 2003–109, page 839. Disallowance of convention expenses; North American geo- graphical area. All geographical areas included in the North American area for purposes of section 274 of the Code are listed. Rev. Ruls. 87–95 and 94–56 superseded.

T.D. 9088, page 841. Final regulations under section 482 of the Code clarify that stock-based compensation is taken into account in determining the intangible development costs of a controlled participant in a qualified cost sharing arrangement. The regulations also provide rules for measuring the cost associated with stockbased compensation; clarify that stock-based compensation is appropriately taken into account as a comparability factor for purposes of the comparable profits method; and provide rules that coordinate the cost sharing rules with the armÊs length standard.

REG–106486–98, page 853. Proposed regulations under section 1275 of the Code provide for the treatment of contingent payment debt instruments for which one or more payments are denominated in, or determined by reference to, a currency other than the taxpayerÊs