IRS Announces 'No Rule' Areas

The Internal Revenue Service has issued a packet of revenue procedures designed to clarify areas on which the service will not provide guidance to taxpayers in the form of letter rulings or determination letters. The complete packet, presented in Internal Revenue Bulletin 2003-1, explains the various types of taxpayer guidance available and provides details as to which types of guidance apply to which types of problems.

In particular, according to Revenue Procedure 2003-3, the IRS has designated several issues relating to employment and employee benefit plans as "no rule" areas, topics on which private letters rulings and determination letters will not be issued. Included on the no rule list are particular features of the following topics:

  • Group-term life insurance purchased for employees
  • Amounts paid to highly compensated individuals under discriminatory self-insured medical expense reimbursement plans
  • Rental value of parsonages
  • Qualified scholarships
  • Meals or lodging furnished for the convenience of the employer
  • Cafeteria plans
  • Medical, dental, etc., expenses
  • Substitution or assumption of incentive stock options
  • General rules for taxable year of inclusion regarding deferred compensation arrangements and deferred compensation plans of state and local governments and tax-exempt organizations
  • Definitions of employee vs. independent contractor
  • Failure to satisfy continuation coverage requirements of group health plans.

The specific features of these topics that may not be addressed in letter rulings and determination letters have been reprinted in Deloitte & Touche's Washington Bulletin.


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