| 200109052(PDF, 90K) |
3/28/2001 |
| This letter is in response to your request, dated February 3, 2000, for rulings on behalf of Company R that include rulings that Plan 2 is a qualified replacement plan as described in � 4980(d)(2) of the Internal Revenue Code (Code), and that the rate of excise tax imposed under � 4980 on the reversion to Company R resulting corn the termination of Plan 1 is 20 percent. |
| 200109051(PDF, 88K) |
3/28/2001 |
| This is in response to the ruling request dated February 2000, as supplemented by letters dated April 25, 2000, September 23, 2000, and October 31, 2000, in which your authorized representative has requested rulings on your behalf concerning the calculations of the minimum distributions as required by � 401(a)(9) of the Internal Revenue Code and the proposed trustee to trustee transfer of Individual A's Individual Retirement Account ("IRA"). |
| 200109050(PDF, 28K) |
3/28/2001 |
| This is in response to a request submitted on your behalf by your authorized representative on January 17, 2000, for a private ruling letter concerning the federal income tax treatment of certain contributions to Plan X under � 414(h) (2) of the Internal Revenue Code . |
| 200109049(PDF, 57K) |
3/28/2001 |
| This letter is in response to your request, dated April 24, 2000, for rulings on behalf of Plan T related to the creation of an excess benefit plan and its effect on Plan T. |
| 200109048(PDF, 21K) |
3/28/2001 |
| This letter constitutes notice that with respect to the above-named defined benefit pension plan we have granted a waiver of a portion of the minimum funding standard for the plan year ending December 31, 1999. |
| 200109047(PDF, 38K) |
3/2/2001 |
| Issues: (1) With respect to a TEFRA partnership, how should reasonable notice in advance be provided to the taxpayer under � 7602(c)(1)? (2) With respect to a TEFRA partnership, what contacts must be reported under � 7602(c)(2). (3) With respect to a non-TEFRA partnership or an S corporation, how should reasonable notice in advance be provided to the taxpayer under � 7602(c)(1)? (4) With respect to a non-TEFRA partnership or an S corporation, what contacts must be reported under � 7602(c)(2). |
| 200109046(PDF, 48K) |
3/2/2001 |
| For our review of your proposed advice to your local Collection Technical Support Group (CTSG) on a number of issues regarding their future handling of taxpayer claims for refund/abatement of Trust Fund Recovery Penalty (TFRP) assessments, pursuant to Internal Revenue Code § 6672. |
| 200109045(PDF, 14K) |
3/2/2001 |
| Requesting on behalf of the taxpayer a supplemental ruling to PLR-64726-95, a ruling letter issued on September 10, 1996 ("Prior Ruling Letter") regarding certain federal income tax consequences of a series of transactions, which included the distribution of all of the outstanding capital stock of Controlled owned by Distributing pro rata to Distributing's shareholders. |
| 200109044(PDF, 10K) |
3/2/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's anticipated loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200109043(PDF, 9.0K) |
3/2/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200109042(PDF, 9.1K) |
3/2/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200109041(PDF, 21K) |
3/2/2001 |
| Requesting a ruling regarding the federal gift tax consequences of a proposed disclaimer. Under paragraph 5 of Decedent's Will, the residuary estate passed to a trust. |
| 200109040(PDF, 6.2K) |
3/2/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. The information submitted discloses that Company was incorporated on a in State and began doing business on b. |
| 200109039(PDF, 27K) |
3/2/2001 |
| Requesting rulings as to the federal income tax consequences of a proposed transaction. Parent wishes to convert to a State X for-profit stock corporation as part of a larger integrated transaction ("Reorganization"). |
| 200109038(PDF, 7.6K) |
3/2/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. The information submitted discloses that Company was incorporated on a in State. |
| 200109037(PDF, 9.5K) |
3/2/2001 |
| Requested rulings on the federal income tax consequences of a completed transaction and a proposed transaction under � 368(a)(1)(A). The Acquisition Merger, viewed independently of the proposed Upstream Merger, qualified as a reorganization under � 368(a)(1)(A) by reason of � 368(a)(2)(E). |
| 200109036(PDF, 9.9K) |
3/2/2001 |
| Requesting a ruling that X be given an extension of time to elect under § 301.7701-3(c) of the Procedure and Administration Regulations to be classified for federal tax purposes other than as an association described in § 301.7701-2(b)(2). |
| 200109035(PDF, 7.0K) |
3/2/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200109034(PDF, 6.7K) |
3/2/2001 |
| Requesting a ruling that X be granted an extension of time under � 301.9100-3 of the Procedure and Administration Regulations to file an election under � 301.7701-3(c) to be treated as a partnership for federal tax purposes. |
| 200109033(PDF, 10K) |
3/2/2001 |
| Requesting a ruling that Z be given an extension of time under � 301.9100-3(a) of the Procedure and Administration Regulations to file an election to be disregarded as an entity separate from its owner for federal tax purposes under � 301.7701-3(c). |
| 200109032(PDF, 8.6K) |
3/2/2001 |
| Requesting a ruling that Z be given an extension of time under � 301.9100-3(a) of the Procedure and Administration Regulations to file an election to be disregarded as an entity separate from its owner for federal tax purposes under � 301.7701-3(c). |
| 200109031(PDF, 15K) |
3/2/2001 |
| For rulings concerning the federal income tax consequences of a proposed transaction. Distributing, a State Z corporation, is a holding company and the common parent of a consolidated group. |
| 200109030(PDF, 7.0K) |
3/2/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200109029(PDF, 7.4K) |
3/2/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200109028(PDF, 7.4K) |
3/2/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. |
| 200109027(PDF, 47K) |
3/2/2001 |
| Request for rulings on certain federal income tax consequences of a proposed transaction. Closely held Distributing is the common parent of a corporate group the includible affiliates of which join in filing a consolidated federal income tax return. |
| 200109026(PDF, 7.4K) |
3/2/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200109025(PDF, 22K) |
3/2/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on August 18, 1997. |
| 200109024(PDF, 6.4K) |
3/2/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1 and began doing business on Date 2. |
| 200109023(PDF, 20K) |
3/2/2001 |
| Request for rulings about the federal income tax consequences of a proposed transaction. First, Corp 4 will merge with and into Distributing 1 with Distributing 1 surviving (the "Merger"). In the Merger, Distributing 2 as the sole shareholder of Corp 4 will receive solely stock of Distributing 1. |
| 200109022(PDF, 56K) |
3/2/2001 |
| Requesting rulings on issues concerning its establishment of a like-kind exchange program arising under § 1031 of the Internal Revenue Code. |
| 200109021(PDF, 7.9K) |
3/2/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1. |
| 200109020(PDF, 9.8K) |
3/2/2001 |
| Request for a supplement to your prior letter ruling dated August 3, 2000 (PLR-107629-00) (the "Prior Letter Ruling"). The Prior Letter Ruling addresses certain federal income tax consequences of a proposed 355 split-off transaction. |
| 200109019(PDF, 7.4K) |
3/2/2001 |
| Requesting a ruling that the conversion of X from a corporation to a limited liability company (LLC) will not cause X or LLC to be classified as an entity other than a corporation for federal tax purposes. |
| 200109018(PDF, 15K) |
3/2/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code that Company's S corporation election was inadvertently invalid. |
| 200109017(PDF, 25K) |
3/2/2001 |
| Requesting rulings regarding application of the rules for a qualified personal residence trust in § 2702 of the Internal Revenue Code. |
| 200109016(PDF, 25K) |
3/2/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on June 16, 1992. |
| 200109015(PDF, 14K) |
3/2/2001 |
| Request a ruling on the application of the generation-skipping transfer tax provisions of Chapter 13 of the Internal Revenue Code to the proposed modification to Trust. |
| 200109014(PDF, 12K) |
3/2/2001 |
| Requesting a private letter ruling concerning the low-income housing tax credit under � 42 of the Internal Revenue Code. |
| 200109013(PDF, 12K) |
3/2/2001 |
| Requesting a private letter ruling concerning the low-income housing tax credit under � 42 of the Internal Revenue Code. |
| 200109012(PDF, 12K) |
3/2/2001 |
| Requesting a private letter ruling concerning the low-income housing tax credit under � 42 of the Internal Revenue Code. |
| 200109011(PDF, 11K) |
3/2/2001 |
| Requesting a private letter ruling concerning the low-income housing tax credit under � 42 of the Internal Revenue Code. |
| 200109010(PDF, 55K) |
3/2/2001 |
| Issues: For purposes of determining whether a plan is an "employee stock ownership plan" as defined in ERISA §407(d)(6), and exempt from the prohibited transaction provisions of Internal Revenue Code §4975(c)(1)(A) pursuant to I.R.C. §4975(d)(13). |
| 200109009(PDF, 10K) |
3/2/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200109008(PDF, 8.8K) |
3/2/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of long-term resident status did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200109007(PDF, 14K) |
3/2/2001 |
| Requesting an extension of time under § 301.9100-1 of the Procedure and Administration Regulations to sever a trust under § 26.2654-1(b) of the Generation-Skipping Transfer Tax Regulations and to make a reverse qualified terminable interest property election under § 2652(a)(3) of the Internal Revenue Code. |
| 200109006(PDF, 6.1K) |
3/2/2001 |
| The trustees of Trust requested a ruling that the proposed division of Trust, a charitable remainder unitrust, into two separate trusts, each of which also will comply the requirements under § 664 of the Internal Revenue Code, will not cause either Trust or the resultant trusts, Trust A and Trust B, to fail to qualify under § 664. |
| 200109005(PDF, 9.5K) |
3/2/2001 |
| Taxpayer owned and operated a retail hardware store at Address (1) Taxpayer also leased a retail hardware store at Address (2) The lease contained an option to purchase the leased premises at market value, to be determined by appraisers selected by Taxpayer and the lessor. |
| 200109004(PDF, 11K) |
3/2/2001 |
| Issue: Whether a co-obligor agreement is required in accepting an offer in compromise of a trust fund recovery penalty from a responsible officer when another responsible officer also has been assessed a trust fund recovery penalty. |
| 200109003(PDF, 4.7K) |
3/2/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending, effective. |
| 200109002(PDF, 9.8K) |
3/2/2001 |
| Requesting a ruling that the income of Authority is excludable from gross income under § 115 of the Internal Revenue Code. |
| 200109001(PDF, 121K) |
3/2/2001 |
| Issue: Whether expenditures incurred by Corporation A for acquiring loans should be capitalized rather than deducted in the year incurred? |
| 200108042(PDF, 7.2K) |
2/23/2001 |
| Requested the Office of Assistant Chief Counsel's opinion on whether non-monetary recognition awards having a fair market value of $100 qualify as de minimis fringes. |
| 200108041(PDF, 20K) |
2/23/2001 |
| Issues: (1) Whether the original return included a valid refund claim. |
| 200108040(PDF, 18K) |
2/23/2001 |
| Issues: With regard to the claim for refund of an Indian ward, is the period of limitations established by � 6511 of the Internal Revenue Code tolled until such Indian ward has the restrictions removed from his or her Indian trust lands? |
| 200108039(PDF, 23K) |
2/23/2001 |
| Issues: With regard to the claim for refund of an Indian ward, is the period of limitations established by � 6511 of the Internal Revenue Code tolled until such Indian ward has the restrictions removed from his or her Indian trust lands? |
| 200108038(PDF, 11K) |
2/23/2001 |
| Requesting rulings relating to whether the proposed transaction meets the diversification requirements of § 817(h) of the Internal Revenue Code. Fund A is operated as a separate series of Trust 1, which is an open-ended management investment company organized as a State 1 business trust. |
| 200108037(PDF, 9.8K) |
2/23/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. lawful permanent residence did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200108036(PDF, 10K) |
2/23/2001 |
| Requesting a ruling under � 877(c) of the Internal Revenue Code of 1986 that A's loss of U.S. lawful permanent residence will not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200108035(PDF, 17K) |
2/23/2001 |
| Requesting various rulings regarding a proposed charitable remainder unitrust. |
| 200108034(PDF, 7.1K) |
2/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200108033(PDF, 6.8K) |
2/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200108032(PDF, 24K) |
2/23/2001 |
| Requesting rulings concerning the federal income, gift, and estate tax consequences of the creation of a proposed charitable lead annuity trust. |
| 200108031(PDF, 8.2K) |
2/23/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1, pursuant to the laws of State. |
| 200108030(PDF, 7.5K) |
2/23/2001 |
| X incorporated under State law on D1. The shareholder of X intended that X elect to be treated as an S corporation effective D1. However, the election to be treated as an S corporation was not timely filed. |
| 200108029(PDF, 33K) |
2/23/2001 |
| Request dated January 12, 2000 under Rev. Proc. 98-17, 1998-1 C.B. 405. In Year 1, Owner 1 and Owner 2 purchased property from Seller know as parcels #2 and #3. |
| 200108028(PDF, 20K) |
2/23/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as the common parent of the consolidated group of which Sub 3, the United States shareholder of Purchaser, the foreign "purchasing corporation," is a member). |
| 200108027(PDF, 7.9K) |
2/23/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date 1. |
| 200108026(PDF, 8.2K) |
2/23/2001 |
| Requests relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1 under the laws of State. |
| 200108025(PDF, 7.3K) |
2/23/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. |
| 200108024(PDF, 13K) |
2/23/2001 |
| Requested an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested for Parent (as common parent of the consolidated group) to file an election statement under § 1.1502-13(f)(5)(ii)(E) of the Income Tax Regulations (regarding a transaction described in § 1.1502-13(f)(5)(ii)(C)) ("the Election"). |
| 200108023(PDF, 12K) |
2/23/2001 |
| Requesting a ruling under § 1362(g) of the Internal Revenue Code that Company may file an S corporation election within five years of the termination of an earlier election. |
| 200108022(PDF, 17K) |
2/23/2001 |
| Issue: Whether, after executing a Form 870-P, a taxpayer may file a request for administrative adjustment. |
| 200108021(PDF, 12K) |
2/23/2001 |
| Requesting rulings regarding the tax consequences of a proposed transaction. Distributing is a State corporation engaged in Business. Distributing is an S corporation that utilizes the cash method of accounting and has a December 31 taxable year end. |
| 200108020(PDF, 6.9K) |
2/23/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. X issued stock and began doing business on D1. A, the sole shareholder of X represents that A intended X to be an S corporation effective D1 and that a Form 2553, Election by a Small Business Corporation, was mailed to a service center. |
| 200108019(PDF, 12K) |
2/23/2001 |
| Requesting rulings regarding the tax consequences of a proposed transaction. (a) The fair market value of the Controlled stock received by Shareholder B will be approximately equal to the fair market value of the Distributing stock surrendered by Shareholder B in the exchange. |
| 200108018(PDF, 7.9K) |
2/23/2001 |
| Requesting an extension of time under § 301.9100 of the Procedure and Administration Regulations to elect to be treated as a corporation for federal tax purposes. |
| 200108017(PDF, 29K) |
2/23/2001 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Taxpayer and its qualified nuclear decommissioning fund as well as rulings regarding the tax treatment of |
| 200108016(PDF, 17K) |
2/23/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i)(1)(iii) of the Income Tax Regulations. Commission A decreased the amount of decommissioning costs included in Taxpayer's cost of service. |
| 200108015(PDF, 15K) |
2/23/2001 |
| Requested a ruling concerning the generation-skipping transfer tax consequences of the modification of a trust. |
| 200108014(PDF, 13K) |
2/23/2001 |
| Issue: Is Taxpayer's contribution of Company stock to a § 170(c) organization deductible under § 170? |
| 200108013(PDF, 13K) |
2/23/2001 |
| Issue: Is Taxpayer's contribution of Company stock to a § 170(c) organization deductible under § 170? |
| 200108012(PDF, 13K) |
2/23/2001 |
| Issue: Is Taxpayer's contribution of Company stock to a § 170(c) organization deductible under § 170? |
| 200108011(PDF, 14K) |
2/23/2001 |
| The facts submitted and representations made are as follows: Grantors executed an irrevocable trust (Trust) prior to September 25, 1985. |
| 200108010(PDF, 38K) |
2/23/2001 |
| The Fund is structured as a voluntary employees' beneficiary association (VEBA), as defined by � 501(c)(9) of the Internal Revenue Code (Code). |
| 200108009(PDF, 47K) |
2/23/2001 |
| Issues: (1) Whether losses recognized, if any, on the sale of the Target Parent stock would be disallowed pursuant to the anti-avoidance provisions under Treasury Regulation � 1.1502-20(e). (2) When Ultimate Sub received a distribution of property, namely the Target Sub 2 stock, from Target Parent prior to Target Parent leaving the Ultimate Parent consolidated group, and Ultimate Sub reduced its investment adjustment basis in the stock of Target Parent by the fair market value of the property distributed under Treas. Reg. � 1.1502-32, must Target Parent recognize gain where the property distributed has a fair market value greater |
| 200108008(PDF, 17K) |
2/23/2001 |
| Requesting rulings under � 280G of the Internal Revenue Code. Specifically you requested a ruling whether, under the facts outlined below, there will be a change in the ownership or effective control of Corporation X, or in the change in the ownership of a substantial portion of the assets of Corporation X within the meaning of � 280G(b)(2) of the Code. |
| 200108007(PDF, 7.7K) |
2/23/2001 |
| Concerning the federal income tax treatment of payments received as disability retirement. |
| 200108006(PDF, 7.9K) |
2/23/2001 |
| Requests relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. X intended to be treated as an S corporation for federal income tax purposes effective on D1, but the S election was not timely filed. |
| 200108005(PDF, 21K) |
2/23/2001 |
| Request for rulings under §368(a)(1)(C) of the Internal Revenue Code on behalf of the above-captioned taxpayers. Acquiring is organized under the laws of State X and registered under the Investment Company Act of 1940 (the "1940 Act") as a diversified, open-end management investment company. |
| 200108004(PDF, 34K) |
2/23/2001 |
| Issue: Whether Forms 1065, U.S. Partnership Return of Income, filed constitute valid returns. |
| 200108003(PDF, 208K) |
2/23/2001 |
| Issues: (1) Should this transaction be characterized as a sham for tax purposes and disregarded? (2) Is this a valid partnership for tax purposes? |
| 200108002(PDF, 29K) |
2/23/2001 |
| Issue: Whether Taxpayer may compute the tax reserves under § 807(d)(2) of the Internal Revenue Code for certain structured settlement annuities issued in 1983 through 1987 using graded valuation interest factors, consistent with the interest rates assumed in computing the statutory reserves for the contracts, rather than the prevailing State assumed interest rates under § 807(d)(4) for single premium immediate annuities issued in each of those years? |
| 200108001(PDF, 28K) |
2/23/2001 |
| Issues: (1) Whether Taxpayer is entitled to deduct a $c repayment made by Taxpayer of a portion of a tax sharing payment received by Taxpayer in connection with the "sale" of its losses. (2) Whether Taxpayer is entitled to deduct a $d payment of interest made by Taxpayer in connection with the "sale" of its losses. |
| 200107035(PDF, 64K) |
2/16/2001 |
| Issues: (1) Whether a Form 1040 on which the taxpayer has altered certain official line titles or has altered the jurat constitutes a valid income tax return. (2) Whether a taxpayer's "homemade" income tax form constitutes a valid income tax return. |
| 200107034(PDF, 19K) |
2/16/2001 |
| Issue: Whether � 3707 of the Internal Revenue Service Restructuring and Reform Act of 1998 prohibits the maintenance of the Frivolous Return Program database which tracks taxpayers who file returns containing potentially frivolous arguments within the meaning of � 6702. |
| 200107033(PDF, 124K) |
2/16/2001 |
| In United States v. Lindberg, 220 F.3d 1120 (9 th Cir. 2000), the Ninth CInternal Revenue Codeuit held the standard of review of a federal district court's denial of a criminal defendant's motion for attorney's fees and litigation costs pursuant to the Hyde Amendment, 18 U.S.C. § 3006A, is for abuse of discretion. Moreover, the court determined in order to recover expenses, a defendant must show more than the government's position was not "substantially justified," the standard for recovery under the Hyde Amendment's civil counterpart, the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d)(1)(A). |
| 200107032(PDF, 50K) |
2/16/2001 |
| Issues: 1) Constitutionally, may the U.S. Congress enact and may the U.S. federal courts enforce a statute that allows U.S. citizens in a foreign country to be served with an investigative summons or a subpoena that requires them to return to the United States to give testimony and/or to produce documents, irrespective of whether service of the investigative summons or subpoena abroad would conflict with applicable international law? 2) In Internal Revenue Code §§ 7603 or 7701(a)(39), did the U.S. Congress indicate an unmistakable intent to override applicable international law so as to permit the IRS to effect service of IRS administrative summonses as a general matter upon U.S. citizens abroad? 3) If the IRS may not properly serve administrative summonses outside the United States upon U.S. citizens abroad as a general matter, due to prohibitions on such service arising under international law, does that interpretation deny any practical impact to � 7701(a)(39)? |
| 200107031(PDF, 14K) |
2/16/2001 |
| Request for rulings on certain federal income tax consequences of the partially completed transaction described below. Distributing conducts Business A. B and C together own 50 percent of the Distributing stock, and D and E together own the remaining 50 percent. |
| 200107030(PDF, 17K) |
2/16/2001 |
| Requesting a ruling under § 1362(f) of the Internal Revenue Code. The information submitted states that X was incorporated on D1. X uses the cash method of accounting and its taxable year ends on December 31. |
| 200107029(PDF, 7.8K) |
2/16/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on Date (1) The shareholders of X desired that X elect S corporation treatment effective on Date 1, but the election to be treated as an S corporation was not timely filed. |
| 200107028(PDF, 10K) |
2/16/2001 |
| Requesting a ruling concerning the deferred compensation plan (the "Plan") which E intends to be an eligible deferred compensation plan under � 457(b) of the Internal Revenue Code of 1986. E is represented to be a state governmental instrumentality described in � 457(e)(1)(A) of the Code. |
| 200107027(PDF, 23K) |
2/16/2001 |
| Requested several rulings concerning the application of the backup withholding rules under � 3406 of the Internal Revenue Code for payees acquiring readily tradable instruments through a broker. |
| 200107026(PDF, 9.2K) |
2/16/2001 |
| Requests an extension of time under Treasury Regulation § 301.9100-3 to file the agreement described in § 1.1503-2(g)(2) with respect to the losses of Domestic Owners (2) and (3) for Year (3), and the loss of Domestic Owner (1) for Year (4); and to file the annual certifications described in § 1.1503-2(g)(2)(vi)(B) for Domestic Owners (2) and (3) for Years (4) and (5), and for Domestic Owner (1) for Year (5). |
| 200107025(PDF, 13K) |
2/16/2001 |
| Requesting a ruling that the proposed restructuring described below will not terminate X's subchapter S corporation status under § 1362(d)(2)(A) of the Internal Revenue Code. |
| 200107024(PDF, 6.9K) |
2/16/2001 |
| Requesting a time extension under § 301.9100-3 of the Procedure and Administration Regulations. X was validly formed under Country law on D1 and began operations on D2. Further, X and X's shareholders, Y and Z, intended from inception to elect to classify X as a partnership for federal tax purposes. |
| 200107023(PDF, 7.1K) |
2/16/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year 1. |
| 200107022(PDF, 9.2K) |
2/16/2001 |
| Requesting an extension of time to identify buildings as part of a multiple-building project under § 42(g)(3)(D) of the Internal Revenue Code pursuant to § 301.9100-1 of the Procedure and Administration Regulations. |
| 200107021(PDF, 12K) |
2/16/2001 |
| Requesting relief under � 1362(f) of the Internal Revenue Code. X incorporated under the laws of State on D1 and elected to be treated as a subchapter S corporation effective D2. |
| 200107020(PDF, 28K) |
2/16/2001 |
| Issue: Whether the Issuer is eligible for relief under § 7805(b) of the Internal Revenue Code (the "Code") from the retroactive revocation of the Organization's exempt status, the effect of which was analyzed in the previous technical advice memorandum in this case issued on October 22, 1999. The Issuer argues that it relied on the determination letter issued to the Organization, its conduit borrower. |
| 200107019(PDF, 61K) |
2/16/2001 |
| For rulings that you are not required to include in your income under the anticipatory assignment of income doctrine a $t punitive damages award paid from a judgment that you transferred to the Trust. |
| 200107018(PDF, 20K) |
2/16/2001 |
| Section 1361(b)(3)(B) of the Code and � 1.1361-2(a) of the Income Tax Regulations provide that the term qualified subchapter S subsidiary means any domestic corporation that is not an ineligible corporation (as defined in � 1361(b)(2) and the regulations thereunder). |
| 200107017(PDF, 21K) |
2/16/2001 |
| Issues: (1) Will the issuance of the financing order and the transfer of the securitization property to the Issuer result in gross income to the Company? (2) Will the issuance of the Bonds and the transfer of the proceeds of the Bonds to the Company result in gross income to the Company? (3) Will the Bonds constitute obligations of the Company? |
| 200107016(PDF, 60K) |
2/16/2001 |
| For rulings as to federal income tax consequences of a series of proposed transactions. The following transactions are proposed (or, as indicated, have been recently completed), as part of the plan of separation: (i) Sub 1 and Sub 10 recently contributed land and structures to Partnership in exchange for partnership interests. (ii) Partnership recently distributed the stock of N Corp to its partners, Subs 5A and 6, in reduction of their partnership interests in Partnership. |
| 200107015(PDF, 19K) |
2/16/2001 |
| A ruling is requested concerning the federal gift and generation-skipping transfer tax consequences of a proposed transaction regarding a testamentary trust. |
| 200107014(PDF, 7.4K) |
2/16/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year 1. |
| 200107013(PDF, 7.5K) |
2/16/2001 |
| Requesting a ruling on behalf of Company under § 1362(b)(5) of the Internal Revenue Code. |
| 200107012(PDF, 35K) |
2/16/2001 |
| Issue: Whether, under Internal Revenue Code §404(a), Taxpayer X may deduct contributions made to Plan on the last day of Taxpayer X's taxable year if such contributions are attributable to compensation earned after the close of Taxpayer X's taxable year. |
| 200107011(PDF, 26K) |
2/16/2001 |
| For a revised schedule of ruling amounts in accordance with � 1.468A-3(i) of the Income Tax Regulations. Taxpayer was previously granted a revised schedule of ruling amounts on May 8, 1998. Information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200107010(PDF, 7.4K) |
2/16/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed. |
| 200107009(PDF, 10K) |
2/16/2001 |
| Funds request extensions of time pursuant to §301.9100-1(a) of the Procedure and Administration Regulations to elect under � 855(a) of the Internal Revenue Code. |
| 200107008(PDF, 20K) |
2/16/2001 |
| Requested rulings on the federal income tax treatment of the transactions described below. Specifically, you requested rulings under § 355 of the Internal Revenue Code and other related Code sections. |
| 200107007(PDF, 25K) |
2/16/2001 |
| Requested rulings regarding the tax consequences under � 468A of the Internal Revenue Code to the Taxpayer and its qualified nuclear decommissioning fund as well as rulings regarding the tax treatment of the transfer of nonqualified funds on the transfer of the Plants. |
| 200107006(PDF, 6.5K) |
2/16/2001 |
| This is in reference to a request that a Form 1128, Application to Adopt, Change, or Retain a Tax Year, be considered timely filed under the authority contained in § 301.9100-3 of the Procedure and Administration Regulations. |
| 200107005(PDF, 19K) |
2/16/2001 |
| The request is for a revised schedule of ruling amounts under � 1.468A-3(i)(2) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission |
| 200107004(PDF, 6.3K) |
2/16/2001 |
| The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200107003(PDF, 24K) |
2/16/2001 |
| Requesting a ruling that the proposed partition of Trust 2 into five separate trusts will not cause the five separate trusts to be subject to the Generation-Skipping Transfer tax imposed by § 2601 of the Internal Revenue Code. |
| 200107002(PDF, 15K) |
2/16/2001 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file an election. The extension is being requested by Parent (Parent is the common parent of the consolidated group of which Purchaser is a member, and Purchaser is the acquiring corporation of Target). |
| 200107001(PDF, 18K) |
2/16/2001 |
| Requesting an extension of time under §§ 301.9100-1 and 301.9100-3 of the Procedure and Administration Regulations to file elections. The extension is being requested by Parent (Parent is the common parent of the consolidated group of which Purchaser is a member; Purchaser is the acquiring corporation of Target and the United States shareholder of "new" Target, and "new" Target is the deemed foreign purchasing corporation of Target Affiliate #1 and Target Affiliate #2). |
| 200106036(PDF, 11K) |
2/12/2001 |
| Ruling be issued to A under § 301.9100-1(c) of the Procedure and Administration Regulations. A wishes to revise and supplement the Form 970, Application To Use LIFO Inventory Method, that it had previously filed for the tax year ended Date (1) This ruling request is being made under § 301.9100-3. |
| 200106035(PDF, 12K) |
2/12/2001 |
| For an extension of time under § 301.9100-1(c) of the Procedure and Administration Regulations. Specifically, A has requested an extension of time to file a Form 970, Application To Use LIFO Inventory Method, for the year ended Date (1) This ruling request is made in accordance with § 301.9100-3. |
| 200106034(PDF, 10K) |
2/12/2001 |
| A ruling that the rental income received by Company from the Properties is not passive investment income within the meaning of § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200106033(PDF, 10K) |
2/12/2001 |
| Fund requests a ruling granting permission for calendar year 2000 and subsequent calendar years to revoke an election under § 4982(e)(4)(A) of the Internal Revenue Code to use Fund's tax year (the calendar year) in lieu of the 1-year period ending October 31, for purposes of calculating the required distribution amount under § 4982(b)(1)(B), § 4982(e)(2), § 4982(e)(5), and § 4982(e)(6). |
| 200106032(PDF, 13K) |
2/12/2001 |
| Ruling on behalf of X as to the applicability of the reporting requirements under � 6041(a) of the Internal Revenue Code to certain cash advances made to third party service providers. |
| 200106031(PDF, 7.8K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. A, X's sole shareholder, represents that X elected to be treated as an S corporation for federal tax purposes effective as of D1 of Year 1, X's first taxable year, by filing a timely Form 2553, Election by a Small Business Corporation, for X. |
| 200106030(PDF, 13K) |
2/12/2001 |
| Requesting a ruling that the rental income received by Company from Properties will not be passive investment income under § 1362(d)(3)(C)(i) of the Internal Revenue Code. |
| 200106029(PDF, 24K) |
2/12/2001 |
| Requesting the following Federal gift tax rulings: (1) Trustee's distribution to Taxpayer of all but x$ of the Trust A Marital Share pursuant to the settlement agreement will not be treated as a disposition under Internal Revenue Code § 2519. (2) Taxpayer's nonqualified disclaimer of her interest in the Trust A Marital Share will be treated as a disposition of Taxpayer's qualifying income interest for life under � 2519. Accordingly, as a result of the disclaimer, Taxpayer is treated as making the following gifts for Federal gift tax purposes: (i) a gift under � 2511 of her qualifying income interest in the Trust A Marital Share that remains after Trustee's distribution of principal under the settlement agreement; and (ii) a gift under � 2519 of the fair market value of the entire property of the Trust A Marital Share that remains after the Trustee's distribution of principal under the settlement agreement, less the sum of (a) the value of her qualifying income interest (determined after the settlement agreement distribution to Taxpayer), and (b) the amount of gift tax that may be recovered by Taxpayer from the Trustee of the Trust A Marital Share under � 2207A(b). (3) Taxpayer's waiver of her right to recover the amount of gift tax that Taxpayer may be entitled to recover from the Trustee of the Trust A Marital Share under � 2207A(b) by reason of her disclaimer will constitute a gift under � 2511 by Taxpayer in the amount of the unrecovered gift taxes. |
| 200106028(PDF, 8.0K) |
2/12/2001 |
| Requests relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1. X intended to be treated as an S corporation for federal income tax purposes effective on D2, but the S election was not timely filed. |
| 200106027(PDF, 7.1K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A, the president of X, represents that X was intended to be an S corporation from its inception. |
| 200106026(PDF, 7.1K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A, the president of X, represents that X was intended to be an S corporation effective for the Year 1 taxable year. |
| 200106025(PDF, 6.9K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) The sole shareholder of X is A. |
| 200106024(PDF, 7.6K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A and B are the shareholders of X. |
| 200106023(PDF, 7.1K) |
2/12/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A and B, as the shareholders of X, represent that X was intended to be an S corporation beginning Year 1. |
| 200106022(PDF, 7.7K) |
2/12/2001 |
| Regarding the late filing of a Form 8716, Election To Have a Tax Year Other Than a Required Tax Year. The information submitted indicates that the taxpayer was incorporated on September 14, 1998, and has elected S corporation status effective as of that date. |
| 200106021(PDF, 23K) |
2/12/2001 |
| Correspondence concerning the federal income tax consequences of amounts paid pursuant to the settlement of a class action, including state intangible property tax refunds and interest thereon, administration costs, and attorneys' fees. |
| 200106020(PDF, 26K) |
2/12/2001 |
| Accordance with � 8.07(2)(a) of Rev. Proc. 2000-1, 2000-1 I.R.B. 4, 33, this memorandum advises you that a taxpayer within your district has withdrawn one of the issues set forth in its Form 3115, Application for Change in Accounting Method. |
| 200106019(PDF, 65K) |
2/12/2001 |
| Issue: Whether Taxpayer, the corporate parent of alleged purchasers/lessors engaged in a purported sale/leaseback of transponders located on a communications satellite, is entitled to depreciation deductions on the transponders. |
| 200106018(PDF, 16K) |
2/12/2001 |
| Issues: (1) Whether Decedent's interest in a passive activity was transferred by reason of his death pursuant to Internal Revenue Code § 469(g)(2). (2) Whether certain S Corporation stock is includible in Decedent's estate. |
| 200106017(PDF, 11K) |
2/12/2001 |
| Requesting a ruling that Trust will be eligible to be a Qualified Subchapter S Trust (QSST) under � 1361(d) of the Internal Revenue Code. |
| 200106016(PDF, 12K) |
2/12/2001 |
| Ruling relating to the Company's status as a real estate investment trust ("REIT") under � 856 of the Internal Revenue Code. |
| 200106015(PDF, 14K) |
2/12/2001 |
| Concerning the status of X as a "religious order" for purposes of � 1402(c)(4), 3121(b)(8), and 3401(a)(9) of the Internal Revenue Code. X is a nonprofit corporation organized under the laws of State. |
| 200106014(PDF, 7.2K) |
2/12/2001 |
| Requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(i)(1)(iii) and (iv) of the Income Tax Regulations. |
| 200106013(PDF, 7.2K) |
2/12/2001 |
| Requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(i)(1)(iii) and (iv) of the Income Tax Regulations. |
| 200106012(PDF, 7.1K) |
2/12/2001 |
| Requesting under §301.9100-3 of the Procedure and Administration Regulations an extension of time to file a request for a revised schedule of ruling amounts for Plant under §1.468A-3(i)(1)(iii) and (iv) of the Income Tax Regulations. |
| 200106011(PDF, 8.1K) |
2/12/2001 |
| Concerning the federal income tax treatment of payments received as disability retirement. |
| 200106010(PDF, 21K) |
2/12/2001 |
| Issues: 1) Whether Internal Revenue Code � 6501(c)(4)(B) applies to the facts of this case? 2) If � 6501(c)(4)(B) applies to this case, whether the Service complied with this code provision? 3) If the Service did not comply with � 6501(c)(4)(B), whether Form 2750, Waiver Extending Statutory Period for Assessment of Trust Fund Recovery Penalty, secured in this case is valid? |
| 200106009(PDF, 23K) |
2/12/2001 |
| Ruling concerning the proper timing of adjustments to the basis of shareholders' stock in Company under § 1367 of the Internal Revenue Code. |
| 200106008(PDF, 16K) |
2/12/2001 |
| Ruling that Surviving Spouse has a qualifying income interest for life in the marital trust under � 2056 of the Internal Revenue Code, provided a State court of competent jurisdiction reforms Decedent's will in accordance with applicable State law as it would be applied in the highest court of State. |
| 200106007(PDF, 27K) |
2/12/2001 |
| Issue: Whether A received gross income under § 61 of the Internal Revenue Code when the Tribe funded the Trust with payments for the benefit of A. |
| 200106006(PDF, 33K) |
2/12/2001 |
| Issue: Whether payments made by a corporation to former shareholders pursuant to an agreement for the sale of goodwill and a covenant not to compete may be deducted by the corporation as wages and consulting expenses. |
| 200106005(PDF, 115K) |
2/12/2001 |
| Issues: (1) Whether Petitioners may deduct losses from foreign currency trading in Year 3, when the foreign currency transactions matured, or in Year 5, when Petitioners paid to their broker the amounts owed on the foreign currency losses. (2) Whether Petitioners may deduct losses from foreign currency trading in Year 4 pursuant to Internal Revenue Code § 461(f). |
| 200106004(PDF, 39K) |
2/12/2001 |
| This Field Service Advice is issued pursuant to � 8.07(2)(b) of Revenue Procedure 2000-1, 2001-1 I.R.B. 4, 33. This Field Service Advice is not binding on Examination or Appeals and is not a final case determination. |
| 200106003(PDF, 28K) |
2/12/2001 |
| Issue: Tax Evasion - Interest and Penalties This is to apprize you of a recent decision which appears to be the first criminal tax case to specifically hold, albeit dicta,1 that interest and penalties are not included within the meaning of the term "tax deficiency" for purposes of 7201 violations. |
| 200106002(PDF, 31K) |
2/12/2001 |
| The purpose of this memorandum is to summarize the proposed amendments to the Federal Rules of Criminal Procedure, the Federal Rules of Civil Procedure, and the Federal Rules of Evidence. |
| 200106001(PDF, 54K) |
2/12/2001 |
| On April 25, 2000, President Clinton signed into law the Civil Asset Forfeiture Reform Act of 2000, 1 (hereinafter referred to as "CAFRA"). CAFRA represents the culmination of a seven year effort to reform the United States' civil asset forfeiture laws to make the procedures fair and more equitable. The intent is to strike an appropriate balance between the needs of law enforcement and the rights of individuals to not have their property forfeited without proper safeguards. |
| 200105062(PDF, 11K) |
2/3/2001 |
| Issue: May the Service abate the individual estimated tax penalty in cases in which the penalty is based upon the additional income reported for the taxable year pursuant to a roll-over from a traditional IRA to a Roth IRA? |
| 200105061(PDF, 19K) |
2/3/2001 |
| Issues: (1) Whether Taxpayer constructively received $A in Year 1 from the sale of property as provided by � 451 and 453 of the Internal Revenue Code? (2) Alternatively, whether Taxpayer constructively received $B in Year 1 and $C in Year 2? (3) Alternatively, whether Taxpayer constructively received $A in Year 2? |
| 200105060(PDF, 18K) |
2/3/2001 |
| Rulings were requested as to the federal income tax consequences of a proposed transaction. According to taxpayer's submission, along with supporting documentation, the separation of Business T from Business R would positively affect the operations of each business, which are disparate on several levels. Distributing has experienced significant management and systemic problems by operating Business R and Business T in the same affiliated group. |
| 200105059(PDF, 21K) |
2/3/2001 |
| Requested rulings under § 2055 of the Internal Revenue Code. Specifically, you requested the following rulings: (1) The interest passing to the charitable organizations under the Paragraph B Trust is a "reformable interest" as defined in § 2055(e)(3)(C). (2) The petition for reformation, when granted, will result in a "qualified reformation" as defined in § 2055(e)(3)(B). (3) An estate tax charitable deduction will be allowed under § 2055(a) for the present value of the remainder interest of the Paragraph B Trust, as reformed. |
| 200105058(PDF, 33K) |
2/3/2001 |
| Requesting a ruling concerning proposed disclaimers with respect to interests in Decedent's retirement plan, and a trust established by Decedent. |
| 200105057(PDF, 7.0K) |
2/3/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A is the sole shareholder of X. A, the president of X, represents that it was intended for X to be an S corporation beginning in Year 1, its first taxable year. A relied on X's attorney to take care of the necessary requirements for X to be an S corporation. X's attorney prepared a Form 2553, Election by a Small Business Corporation, and forward it to X. However, due to a miscommunication, A failed to file the Form 2553 timely for X for Year 1. |
| 200105056(PDF, 7.1K) |
2/3/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A, as the president of X, represents that X was intended to be an S corporation beginning Year 1, its first taxable year. |
| 200105055(PDF, 7.0K) |
2/3/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 of Year (1) A and B are the shareholders of X. A, the president of X, represents that it was intended for X to be an S corporation since inception. |
| 200105054(PDF, 8.7K) |
2/3/2001 |
| Requesting a ruling that A's surrender of his U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200105053(PDF, 7.2K) |
2/3/2001 |
| Requesting, dated October 29, 1999, that we rule on certain tax consequences under � 468A of the Internal Revenue Code of the transfer of the Plants in the context of a tax-free reorganization intended to qualify under � 368(a)(1)(D) and 355. As set forth below, you have requested rulings regarding the tax consequences to the Taxpayer and its qualified nuclear decommissioning funds. |
| 200105052(PDF, 20K) |
2/3/2001 |
| Requesting, dated October 29, 1999, that we rule on certain tax consequences under � 468A of the Internal Revenue Code of the transfer of the Plants in the context of a tax-free reorganization intended to qualify under � 368(a)(1)(D) and 355. As set forth below, you have requested rulings regarding the tax consequences to the Taxpayer and its qualified nuclear decommissioning funds. |
| 200105051(PDF, 8.7K) |
2/3/2001 |
| Requesting a ruling that A's surrender of her U.S. Alien Registration Card (Green Card) did not have for one of its principal purposes the avoidance of U.S. taxes under subtitle A or subtitle B of the Code. |
| 200105050(PDF, 19K) |
2/3/2001 |
| Requesting rulings on the federal income tax consequences of proposed transactions. Taxpayer intends to convert the members' Equity Interests into stock interests and convert from a not-for-profit corporation into a for-profit corporation. |
| 200105049(PDF, 12K) |
2/3/2001 |
| Requesting a ruling that Taxpayer's disclaimer of his remainder interest in Trust within nine months of Date 3 will not constitute a taxable gift under § 2501 of the Internal Revenue Code. |
| 200105048(PDF, 8.3K) |
2/3/2001 |
| Requesting a ruling on whether A will be treated as a "nonresident not a citizen of the United States" for purposes of U.S. estate and gift taxation. A is a U.S. citizen, and a resident of Puerto Rico. A proposes to transfer property with a value in excess of $10,000 to A's children. |
| 200105047(PDF, 19K) |
2/3/2001 |
| Requesting is for a revised schedule of ruling amounts under � 1.468A-3(i)(2) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. The required information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200105046(PDF, 6.7K) |
2/3/2001 |
| Requesting a ruling under § 1362(b)(5) of the Internal Revenue Code. The information submitted states that X was incorporated on D1 in Year (1) A, as the president of X, represents that X was intended to be an S corporation effective D1, Year 1. X's Form SS-4, Application for Employer Identification Number, evidences this intent. However, a completed Form 2553, Election by a Small Business Corporation, was not timely filed for X. |
| 200105045(PDF, 28K) |
2/3/2001 |
| Issue: Whether employment tax assessments in the name and employer identification number (EIN) of a single member limited liability company are valid assessments against the company's sole owner under the cInternal Revenue Codeumstances described below. |
| 200105044(PDF, 40K) |
2/3/2001 |
| Requesting rulings regarding the effect of the division of trust assets and the judicial construction and modification of the trust instrument for federal income, estate, gift, and generation-skipping transfer tax purposes. |
| 200105043(PDF, 21K) |
2/3/2001 |
| Requesting an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. Parent (as common parent of the consolidated group of which Sub X, the United States shareholder of Sub Z, the foreign purchasing company is a member) is requesting an extension to file an election under § 338(g) of the Internal Revenue Code with respect to the acquisition of Target 1 and Target 2. |
| 200105042(PDF, 4.6K) |
2/3/2001 |
| Requesting permission to change its accounting period, for federal income tax purposes, from a taxable year ending, to a taxable year ending, effective. The taxpayer has requested that the Form 1128 be considered timely filed under the authority contained in §301.9100-3 of the Procedure and Administration Regulations. |
| 200105041(PDF, 7.6K) |
2/3/2001 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. X began doing business under State law on D1. The shareholders of X intended that X elect to be treated as an S corporation effective D1. However, the election to be treated as an S corporation was not timely filed. |
| 200105040(PDF, 14K) |
2/3/2001 |
| Requested rulings on the federal income tax consequences of certain completed and proposed transactions under � 368(a)(1)(A). Pursuant to � 3.01(23) of Rev. Proc. 2000-3, 2000-1 I.R.B. 103,105, the Internal Revenue Service will not rule as to whether a proposed transaction qualifies under � 368(a)(1)(A). However, the Service has discretion to rule on significant sub issues that must be resolved to determine whether a transaction qualifies under � 368(a)(1)(A). |
| 200105039(PDF, 33K) |
2/3/2001 |
| Requesting rulings regarding the generation-skipping transfer tax (GSTT) consequences and income tax consequences of a division of trust assets as described below. |
| 200105038(PDF, 16K) |
2/3/2001 |
| Requesting a ruling that will waive for Project buildings the 10-year holding period requirement for existing buildings of § 42(d)(2)(B)(ii) of the Internal Revenue Code, under authority of the exception for the acquisition of certain federally-assisted buildings provided in § 42(d)(6)(A). |
| 200105037(PDF, 19K) |
2/3/2001 |
| Request is for a revised schedule of ruling amounts under � 1.468A-3(i)(2) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. The required information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200105036(PDF, 19K) |
2/3/2001 |
| Request is for a revised schedule of ruling amounts under � 1.468A-3(i)(2) of the Income Tax Regulations for the Taxpayer's nuclear decommissioning fund (the "Fund") under the jurisdiction of Commission A. The required information for the schedule of ruling amounts was submitted on behalf of the Taxpayer pursuant to � 1.468A-3(h)(2). |
| 200105035(PDF, 15K) |
2/3/2001 |
| Requested as to certain federal income tax consequences of a proposed transaction. Target 1 and Target 2 are each closely held, and there is significant overlap in their shareholders. |
| 200105034(PDF, 15K) |
2/3/2001 |
| Requested as to certain federal income tax consequences of a proposed transaction. Target 1 and Target 2 are each closely held, and there is significant overlap in their shareholders. |
| 200105033(PDF, 8.1K) |
2/3/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated on D1, pursuant to the laws of State. X intended to be treated as an S corporation effective D2, but the S election was not timely filed. |
| 200105032(PDF, 31K) |
2/3/2001 |
| Requesting an extension of time, under §§ 301.9100-1 and -3 of the Procedure and Administration Regulations, for Taxpayers to make consent dividend elections pursuant to § 565 of the Internal Revenue Code. |
| 200105031(PDF, 28K) |
2/3/2001 |
| Requested as to the federal income tax consequences of a proposed transaction. Accordingly, the following transaction is proposed: (i) Holding will contribute 100 percent of the stock of DSub1 to DSub 2 (the "First Contribution"). (ii) Holding will contribute 100 percent of the stock of FSub 1 to DSub 2 (the "Second Contribution"). |
| 200105030(PDF, 12K) |
2/3/2001 |
| Requesting relief under � 1362(b)(5) of the Internal Revenue Code. X incorporated under State law on D1. The shareholder of X intended that X elect to be treated as an S corporation effective D1. However, the election to be treated as an S corporation was not timely filed. |
| 200105029(PDF, 7.2K) |
2/3/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed. |
| 200105028(PDF, 9.0K) |
2/3/2001 |
| Requesting that X be given an extension of time in which to elect to treat each of Y1, Y2, and Y3 as a qualified subchapter S subsidiary under § 1361(b)(3)(B) of the Internal Revenue Code. |
| 200105027(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105026(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105025(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105024(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105023(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105022(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105021(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105020(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105019(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105018(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105017(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105016(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105015(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105014(PDF, 52K) |
2/3/2001 |
| Issue: Whether Taxpayer and its operating subsidiaries are entitled to deductions for "insurance" premiums paid to C. |
| 200105013(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105012(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105011(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105010(PDF, 24K) |
2/3/2001 |
| Requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. Portfolio is a sub-trust of Trust, which was organized as a business trust under the laws of State 1 pursuant to Declaration. Trust is registered as an investment company under the Investment Company Act of 1940 (1940 Act). |
| 200105009(PDF, 24K) |
2/3/2001 |
| This letter responds to your submission of April 28, 2000, together with subsequent correspondence, in which you requested certain rulings under §§ 704, 721, and 7704 of the Internal Revenue Code. |
| 200105008(PDF, 21K) |
2/3/2001 |
| Requesting, on behalf Parent and Seller, an extension of time under §§ 301.9100-1 through 301.9100-3 of the Procedure and Administration Regulations to file an election. |
| 200105007(PDF, 14K) |
2/3/2001 |
| Issue: Whether reimbursement provided to for parking costs incurred at nontemporary work locations is excludable from wages for income and employment tax purposes. |
| 200105006(PDF, 7.2K) |
2/3/2001 |
| Requesting relief under § 1362(b)(5) of the Internal Revenue Code. X was incorporated under State law. X's shareholders intended that X be a subchapter S corporation, effective D1; however, an S corporation election under § 1362 was not timely filed. |
| 200105005(PDF, 5.3K) |
2/3/2001 |
| Issue: Whether a U.S. citizen may exclude his pension income from gross income under � 871(f)(1) if he was a nonresident alien when he performed the services that entitled him to the pension and when he began to receive annuity payments, and those services were performed outside the United States. |
| 200105004(PDF, 14K) |
2/3/2001 |
| Issues: (1) Whether P exchanged the installment obligation, resulting in capital gain income of $C in D8 and $H in D7, under the provisions of � 1031 of the Internal Revenue Code. (2) Whether P exchanged the installment obligation, resulting in capital gain income of $A in D7 under the provisions of � 1031 of the Internal Revenue Code. (3) Whether P constructively received $A in D9 from collection of the installment obligation, as provided by � 451 of the Internal Revenue Code. |
| 200105003(PDF, 54K) |
2/3/2001 |
| Issue: Whether the lease-in/lease-out transaction lacks economic substance. |
| 200105002(PDF, 29K) |
2/3/2001 |
| Issue: When does the period of eligibility begin for a life insurance company to be included as a member of the consolidated return? |
| 200105001(PDF, 37K) |
2/3/2001 |
| Issues: A. For purposes of the U.S.-U.K. income tax treaty , will the shareholder and recipient of certain cash dividends to be distributed with respect to American Depositary Shares ("ADSs") held by the Plan be the participants in the Plan ("Participants") or the trust that holds the assets of the Plan ("Trust")? B. If the Trust is the shareholder and recipient of the dividends and it elects benefits under the Treaty, will the taxes of the Trust that are eligible for the foreign tax credit pass through to the Participants under � 901(b)(5) of the Internal Revenue Code? |
