Announcement 2002-100

Ann 2002-100.pdf

TD 9084/REG-106879-00-- Consolidated Loss Recapture Events

Announcement 2002-100

OMB: 1545-1796

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Age 55 Commencement
Optional Form
Life Annuity
QJSA (joint and 75% survivor annuity)
Joint and 100% survivor annuity
Lump sum

Amount of distribution per $1,000 of immediate Relative Value
single life annuity
$1,000 per month
approximately the same value as the QJSA
$956 per month
n/a
$886 per month
approximately the same value as the QJSA
$165,959
approximately the same value as the QJSA

Age 60 Commencement
Optional Form
Life Annuity
QJSA (joint and 75% survivor annuity)
Joint and 100% survivor annuity
Lump sum

Amount of distribution per $1,000 of immediate Relative Value
single life annuity
$1,000 per month
approximately 94% of the value of the QJSA
$945 per month
n/a
$859 per month
approximately 94% of the value of the QJSA
$151,691
approximately the same value as the QJSA

Age 65 Commencement
Optional Form
Life Annuity
QJSA (joint and 75% survivor annuity)
Joint and 100% survivor annuity
Lump sum

(iii) The chart disclosing the financial effect
and relative value of the optional forms specifies
that the calculations were prepared assuming that
the spouse is three years younger than the
participant, that the calculations relating to the
single-sum distribution were prepared using 5.5%
interest and average life expectancy, that the other
calculations were prepared using a 6% interest rate,
and that the relative value of actual payments for
an individual can vary depending on how long the
individual and spouse live. The explanation states
that the relative value comparison converts the
QJSA, the single life annuity, the joint and 100%
survivor annuity, and the single-sum options to an
equivalent present value and that this conversion
uses interest and life expectancy assumptions. The
explanation notes that the calculation of the QJSA
depends on the actual age of the spouse (for
example, annuity payments will be significantly
lower if the spouse is significantly younger than
the participant), and that the amount of the singlesum payment will depend on the interest rates that
apply when the participant actually takes a
distribution. The explanation also includes an offer
to provide a calculation specific to the participant
upon request.
(iv) Participant M requests information regarding the amounts payable under the QJSA, the joint and
100% survivor annuity, and the single sum.
(v) Based on the information about the age of Participant M’s spouse, Plan A determines that M’s QJSA
is $2,856.30 per month, the joint and 100% survivor annuity is $2,628.60 per month, and the single sum
is $497,876. The actuarial present value of the QJSA
(determined using the 5.5% interest and the section
417(e)(3) applicable mortality table, the actuarial assumptions required under section 417) is $525,091.
Accordingly, the value of the single-sum distribution available to M at January 1, 2004, is 94.8% of
the actuarial present value of the QJSA. In addition,
the actuarial present value of the life annuity and the
100% joint and survivor annuity are 95.0% of the actuarial present value of the QJSA.

2002–44 I.R.B.

Amount of distribution per $1,000 of immediate Relative Value
single life annuity
$1,000 per month
approximately 93% of the value of the QJSA
$932 per month
n/a
$828 per month
approximately 93% of the value of the QJSA
$135,759
approximately 93% of the value of the QJSA

(vi) Plan A provides M with a QJSA explanation that incorporates these more precise calculations of the financial effect and relative value of the
optional forms for which M requested information.

(f) Effective date. This section applies to
QJSA explanations provided with respect
to distributions with annuity starting dates
on or after January 1, 2004, and to QPSA
explanations provided on or after January
1, 2004.
§ 1.417(e)–1 [Amended]
Par. 5. In § 1.417(e)–1, paragraph (b)(2)
is amended by removing the language
“§ 1.401(a)–20 Q&A–36” and adding
“§ 1.417(a)(3)–1” in its place.
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
(Filed by the Office of the Federal Register on October 4,
2002, 8:45 a.m., and published in the issue of the Federal Register for October 7, 2002, 67 F.R. 62417)

799

Dual Consolidated Loss
Recapture Events; Correction
Announcement 2002–100
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed
rulemaking and notice of public hearing.
SUMMARY: This document contains corrections to proposed regulations (REG–
106879–00, 2002–34 I.R.B. 402) as
published in the Internal Revenue Bulletin. These regulations under section 1503(d)
relate to the events that require the recapture of dual consolidated losses.
DATES: These corrections are effective
August 26, 2002.
FOR
FURTHER
INFORMATION
CONTACT: Kenneth D. Allison or
Kathryn T. Holman at (202) 622–3860 (not
a toll-free number).

November 4, 2002

Request for Applications to
Participate in the 2003 IRS
Background
Individual e-file Partnership
The notice of proposed rulemaking that Program

web site (www.irs.gov) for a complete listing of accepted forms and schedules.

is the subject of these corrections is under section 1503(d).

For Filing Season 2003, the IRS will focus on the 1040 series income tax returns
covering “IRS e-file Using a Tax Preparer”
and “IRS e-file Using a Personal Computer.” Additional emphasis is being placed
on the following features: “Self-Select Personal Identification Number (PIN) for e-file;
“Using e-file for Federal/State Returns”, and
“Electronic Payment Options” for balance
due and estimated payment options.
Emphasis should also be placed on the
first-time filer population. IRS research indicates that this segment of the population continues to lag behind other segments
of the population that e-file. In addition, research indicates that e-file is still lagging
in the self-prepared simple segment. Another area of emphasis is to reach those taxpayers who continue to file computer
prepared paper returns (v-code). Research
indicates that the number of v-code returns continues to increase (76% of all
v-code returns are prepared by paid preparers). Emphasis should be placed on encouraging v-code filers to electronically file
their returns through the marketing and promotion of the benefits of e-file.
The IRS expects all accepted partners to
aggressively market, promote and offer e-file
services through October 15, 2003. The IRS
will supply the partners with the Filing Season and post April 15 e-file campaign message(s), if available, to target additional
qualified taxpayers, i.e., extensions, military returns, etc. Pending the passage of legislation, Participants are encouraged to offer
the April 30 due date extension for e-file.
For additional information on the various e-file programs, features, and market research, visit our web site at www.irs.gov.
For a listing of our current partners and the
services they offer, refer to the IRS e-file
Partners Page at www.irs.gov.
Participants will receive hyperlinks from
the IRS web site to the Participant’s web
site. Potential Participants may request links
for the following categories: IRS e-file
Partners for Taxpayers, IRS e-file Partners for Tax Professionals, IRS e-file
Partners for Financial Institutions/
Employers, and IRS e-file Partners for
Credit Card Payment Options.

SUPPLEMENTARY INFORMATION:

Need for Correction
As published in the Internal Revenue
Bulletin, this notice of proposed rulemaking contains errors which may prove to be
misleading and are in need of clarification.
Correction of Publication
Accordingly, the notice of proposed rulemaking (REG–106879–00) as published in
the Internal Revenue Bulletin is corrected
as follows:
1. On page 404 of the Internal Revenue Bulletin (I.R.B.), column 1, under
“Proposed Effective Date”, the language
“These regulations amending the dual consolidated loss rules under § 1.1503–2 are
proposed to apply to transactions otherwise constituting triggering events occurring on or after August 1, 2002.” is
corrected to read “These regulations amending the dual consolidated loss rules under
§ 1.1503–2 are proposed to apply to transactions otherwise constituting triggering
events occurring on or after [DATE THE
FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER].”
2. On page 405 of the I.R.B., column
2, the language “Paragraphs (g)(2)(iv)(A)(4)
and (5) of this section, and paragraphs
(g)(2)(iv)(B)(l)(ii) and (iii) of this section, shall apply with respect to transactions otherwise constituting triggering events
occurring on or after August 1, 2002.” is
corrected
to
read
“Paragraphs
(g)(2)(iv)(A)(4) and (5) of this section, and
paragraphs (g)(2)(iv)(B)(l)(ii) and (iii) of this
section, shall apply with respect to transactions otherwise constituting triggering
events occurring on or after [DATE THE
FINAL REGULATIONS ARE PUBLISHED IN THE FEDERAL REGISTER].”
The corrections made herein will be reflected in the notice of proposed rulemaking published in the Cumulative Bulletin.

November 4, 2002

Announcement 2002–101
The Stakeholder Partnerships, Education and Communication (SPEC) function within the Internal Revenue Service
(IRS) is continuing its efforts to establish
IRS e-file partnerships with various entities. The IRS is seeking non-monetary e-file
partnerships for Filing Season 2003. No applications for funding (monetary compensation) will be considered. Applications may
be submitted by a commercial business,
non-profit organization, state government
or local government. Applications are not
solicited from other Federal government
agencies. The program is an annual program and covers the period January 2003
through October 15, 2003. All prior year
partners must reapply for Filing Season 2003.
BACKGROUND
The IRS Restructuring and Reform Act
of 1998 (RRA 98) requires the IRS to receive 80 percent of all returns electronically by 2007. RRA 98 authorized the IRS
Commissioner to promote the benefits of
and encourage the use of e-file services. As
a result of RRA 98, the IRS enters into nonmonetary partnerships with businesses to offer low cost income tax preparation and
electronic filing for qualified taxpayers.
Continued opportunities for growth in
electronic tax administration are evident. For
Filing Season 2002, the IRS received over
46 million electronically filed returns, an increase of 16% over the previous year. Visit
the IRS web site, www.irs.gov, “IRS e-file
for Tax Professionals, Software Developers, and Transmitters” for the most current results from market research on
individual taxpayers: demographic data and
psychographic studies. This includes attitudinal surveys, customer satisfaction surveys, Public Service Announcements
(PSAs)/Paid Advertising Tracking Studies and any focus group results.
The IRS currently accepts 115 forms and
schedules for electronic filing. Visit the IRS

800

FILING SEASON 2003

2002–44 I.R.B.


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