Internal Revenue Bulletins  

November 13, 1990

Internal Revenue Bulletin No. 1990-46

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.


SPECIAL ANNOUNCEMENT

Announcement 90-123
A public hearing will be held on December 3, 1990, on proposed regulations relating to acquisitions made to evade or avoid income tax and to the use of pre-change corporate tax attributes following an ownership change.


INCOME TAX

Rev. Rul. 90-94
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 1991, will remain at 10 percent for overpayments and 11 percent for underpayments.

Rev. Rul. 90-95
QSP; reverse subsidiary cash merger. Circumstances are set forth under which a reverse subsidiary cash merger will be treated as a section 338 qualified stock purchase of a target. In situation 1, the target remains a subsidiary after the purchase. In situation 2, the target is immediately liquidated after the purchase.

Rev. Rul. 90-96
Taxation of DISC income to shareholder. The "base" period T-bill rate" for the period ending September 30, 1990, is published, as required by section 995(f)(4) of the Code.

T.D. 8317
EE-86-90

Temporary and proposed regulations under section 412 of the Code relate to minimum funding requirements for qualified plans.

Notice 90-67
This notice provides the domestic asset/liability percentages and domestic investment yields under section 842(b) of the Code and provides guidance on making estimated payments.

Notice 90-68
Countries that require participation in, or cooperation with, an international boycott are listed.

Notice 90-69
The applicability interest rate on the amount of additional tax attributable to any nonqualified withdrawals from a capital construction fund established under section 607 of the Merchant Marine Act is 9.28 percent with respect to nonqualified withdrawals made in the taxable year beginning in 1990.


TAX CONVENTIONS

The bilateral agreements between the U.S. and India, Malaysia, Marshall Islands, and Singapore providing for the reciprocal tax exemption of income from international operation of ships and/or aircraft are set forth.


ADMINISTRATIVE

Del. Order 42
This order clarifies the authority to execute consent agreements for fixing the period of limitations involving partnerships and S corporations, and eliminates the delegated authority for certain job positions phased out due to reorganization of the function. Del. Order 42 (Rev. 22) superseded.

Del. Order 209 (Rev. 4)
This order extends the authority to execute settlement agreements involving partnership and S corporation affected items to appeals officers at service centers and the Austin Compliance Center. Del. Order 209 (Rev. 3) superseded.

Announcement 90-124
The Service clarifies the 1990 "instructions for Forms W-2 and W-2P", as they relate to employer reporting of "golden parachute" payments on Form W-2.


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