Internal Revenue Bulletins  

August 28, 1989

Internal Revenue Bulletin No. 1989-35

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.


INCOME TAX

Rev. Rul. 89-99
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 1989, will decrease to 10 percent for overpayments and 11 percent for underpayments.

Rev. Rul. 89-100
LIFO; price indexes; department stores. The May 1989 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, May 31, 1989.

Rev. Rul. 89-101
Controlled corporation; stock distribution; business purpose. The business purpose requirement under section 355 of the Code is met if a first-tier foreign subsidiary distributes to its domestic parent all of the stock of a second-tier foreign subsidiary in order to reduce the amount of foreign withholding tax imposed on distributions by the second-tier corporation.

Rev. Rul. 89-102
Basis of property; Countertrade II - sales made at a price in excess of fair market value (FMV). If property is purchased from an unrelated third party at a price in excess of an arm's length price, and as part of the same transaction a party related to the buyer sells property to the original seller or another third party at a price in excess of an arm's length price, the prices are reduced to reflect an arm's length price.

Rev. Rul. 89-103
Stapled stock domestication. The deemed conversion of a foreign corporation to a domestic corporation pursuant to the stapled stock provisions of section 269B of the Code qualifies as a reorganization under section 368(a)(1)(F) of the Code.

Rev. Rul. 89-104
GOSI; benefit cancellation payments. Guidance is provided for taxpayers to determine the taxability of benefit cancellation payments received from the Saudi Arabian social security system.


ADMINISTRATIVE

Rev. Proc. 89-50
Rulings; retention of corporate charters in "C" and "D" reorganizations. Conditions are set forth under which the Service ordinarily will waive the distribution requirement of section 368(a)2(G)(i) of the Code in "C: reorganizations or will treat the distribution requirement of section 354(b)(1)(B) as satisfied in "D" reorganizations. Rev. Proc. 77-37, as amplified by Rev. Proc. 86-42, is further amplified.

Notice 89-94
Guidance is provided concerning a domestic corporation and a foreign corporation that are stapled entities.

Notice 89-96
Guidance is provided for computing a foreign insurance company's minimum effectively connected net investment income under section 842(b) of the Code.

Announcement 89-104
The Service will postpone the effective date of Rev. Proc. 89-34 until February 5, 1990, and also requests comments on private letter rulings policy.

Announcement 89-105
The Service answers questions concerning Rev. Proc. 89-34.

Announcement 89-106
A correction is made to the Application Packages for the 1990 Tax Counseling for the Elderly (TCE) Program.

An amendment to the regulations under Part 103 of Title 31 of the Code of Federal Regulations relates to an administrative ruling.


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