Internal Revenue Bulletins  

September 16, 1991

Internal Revenue Bulletin No. 1991-37

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Announcement 91-136
A public hearing will be held on October 16, 1991, on proposed regulations relating to a method of accounting for certain returns of magazines, paperbacks, or records.

Announcement 91-137
A public hearing will be held on November 20, 1991, on proposed regulations relating to the capitalization of interest.


Rev. Rul. 91-50
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 1991, will remain at 9 percent for overpayments, 10 percent for underpayments, and 12 percent for large corporate underpayments.

Proposed regulations under sections 263A and 266 of the Code relate to capitalization of interest.


Rev. Proc. 91-53
Puerto Rico and possession tax credit; change of election. Procedures are provided for changing from the cost sharing method to the profit split method or the method permitted under section 936(h)(1) through (h)(4) of the Code for all applicable taxable years beginning after December 31, 1986. Notices 87-27, 88-97, 89-82 and Rev. Procs. 89-61, 90-50 modified.

Rev. Proc. 91-54
Areas in which advance rulings will be issued. The Service has the discretion to issue advance rulings on significant subissues that must be resolved to determine whether section 351 or 368(a)(1)(B) of the Code apply to certain holding company formations and whether a transaction is a reorganization under section 368(a)(1)(F). Rev. Proc. 91-3 modified.

Announcement 91-138
A typographical error in Announcement 91-124, 1991-34 I.R.B. 36, is corrected.

Announcement 91-139
Errors in T.D. 8353, 1991-28 I.R.B. 7, relating to information that must be reported and records that must be maintained by certain corporations, are corrected.

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