Internal Revenue Bulletins  

June 19, 1989

Internal Revenue Bulletin No. 1989-25

There are no links to the official documents for the years 1989 through 1995. The information below can only be used as help for further research, as there is not enough information here to rely on for official guidance. For that you need to obtain a copy of the complete document.


Rev. Rul. 89-76
Interest on certain loans used to acquire employer securities. A corporation's actions as an underwriter in the sale of notes evidencing a securities acquisition loan will not adversely affect the status, under section 133 of the Code, of interest received or accrued on such notes. A qualified lender will be entitled to the partial interest exclusion of section 133 without regard to whether each previous holder of the note was a qualified lender.

Rev. Rul. 89-78
Net operating loss deduction; carrybacks and carryovers. For purposes of section 172(b)(1)(L) of the Code, (1) a taxpayer must be an organization to which section 593 is incurred, and (2) the relevant version of section 593 is former section 593, as in effect during the loss year.

Rev. Rul. 89-79
Dividends paid deduction; preferential dividends; regulated investment companies. For purposes of applying the $10,000,000 initial investment requirement of section 562(c) of the Code, the term "shareholder" refers to the legal owner of a regulated investment company's shares rather than to the beneficial owner.

Rev. Rul. 89-80
Consolidated returns; carryback of consolidated net operating losses following the consolidation of two unrelated common parent corporations. Pursuant to the reverse acquisition rules of section 1.1502-75(d)(3) of the regulations, the portion of a consolidated net operating loss attributable to a newly formed common parent, following the consolidation of two unrelated common parents under section 368(a)(1)(A) of the Code, may be carried back to prior years of the affiliated group which is treated as continuing in existence. No portion of the consolidated net operating loss attributable to the newly formed common parent may be carried back to the prior years of the affiliated group which is treated as terminating.

Rev. Proc. 89-39
Areas in which advance rulings will not be issued; section 355. The Service will not rule on whether the corporate business requirement of section 1.355-2(b) of the regulations is satisfied in three situations. Rv. Proc. 89-3 amplified.

Proposed regulations under section 280G of the Code relate to golden parachute payments.


Notice 89-70
Additional guidance is provided concerning certain aspects of permitted disparity under section 401(1) of the Code.

Announcement 89-79
Changes will be made in the procedures for issuing opinion letters relating to master and prototype pension and profit- sharing plan, and for issuing notification letters relating to regional prototype plans. Rev. Procs. 89-9 and 89-13 will be modified.

Announcement 89-80
Further information is given regarding the appropriate user fee for applications for determination letters for adopters of volume submitter plans.

Announcement 89-81
In accordance with Section 12.02 of Rev. Proc. 84-23, set forth is a list of master or prototype plans closed by the National Office of the Internal Revenue Service between January 1, 1988 and March 31, 1988.

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