Internal Revenue Bulletins  

June 1, 1992

Internal Revenue Bulletin No. 1992-22

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Announcement 92-82
A public hearing will be held on July 8, 1992, on proposed regulations relating to the exhaustion of administrative remedies limitation on awards of reasonable litigation costs.


Rev. Rul. 92-39
Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for June 1992.

T.D. 8412
Final regulations under section 904 of the Code relate to income subject to the foreign tax credit separate limitations.

Notice 92-24
Countries that require participation in, or cooperation with, an international boycott are listed.

Proposed regulations under sections 861 and 904 of the Code relate to the allocation and apportionment of interest and other expenses within an affiliated group and the foreign tax credit limitation.


Rev. Proc. 92-42
Limitations on benefits; changes in benefit structure. A change in benefit structure under a plan adopted on or after August 3, 1992, will not be subject to the 10-year-phase-in limitation of section 415(b)(5)(D) of the Code. Guidance is provided on the application of section 415(b)(5)(D) for amendments adopted before that date. Notice 89-45 modified and revoked.

Notice 92-25
Guidelines are set forth for determining, for May 1992, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987.

Announcement 92-81
This announcement sets forth proposed substantiation guidelines for purposes of nondiscrimination testing for qualified plans under sections 401(a)(4) and 410(b) of the Code and certain related provisions. The Service invites comments with respect to the proposed guidelines.


Announcement 92-83
Guidelines developed for use by IRS agents in the exempt organizations examination program are reproduced. The guidelines will be used in the examination of tax-exempt hospitals.


T.D. 8411
Final regulations under sections 871, 904, 953, 1303, 1441, 3121, 3306, 6013, and 7701 of the Code relate to the definition of a resident alien.

Proposed regulations under section 7430 of the Code relate to the exhaustion of administrative remedies limitation on awards of reasonable litigation costs.

Proposed regulations under sections 6114 and 7701 of the Code relate to treaty-based return positions.

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