Internal Revenue Bulletins  

March 23, 1992

Internal Revenue Bulletin No. 1992-12

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SPECIAL ANNOUNCEMENT

Announcement 92-48
A public hearing will be held on April 14, 1992, on proposed regulations relating to the treatment of warrants, options, obligations convertible into stock, and similar interests as exercised for purposes of determining whether a corporation is a member of an affiliated group.


INCOME TAX

Rev. Rul. 92-15
Tiered partnership distributions; basis adjustments. The Service has ruled on two situations in which there are distributions of property to a partner from a partnership that owns an interest in another partnership and both entities have optional basis adjustment elections under section 754 of the Code in effect.

Rev. Rul. 92-16
Issuance of emission allowances. Gross income does not include issuance of an emission allowance by the Environmental Protection Agency pursuant to 42 U.S.C. section 7651b(a).

Rev. Rul. 92-17
Managing a partnership. A corporation that is a general partner in a limited partnership is engaged in the active conduct of a trade or business for purposes of section 355(b) of the Code if officers of the corporation perform active and substantial management functions for the partnership.

CO-152-84
Proposed regulations under section 1504 of the Code relate to the treatment of warrants, options, obligations convertible into stock, and similar interests as exercised for purposes of determining whether a corporation is a member of an affiliated group.


EXCISE TAXES

Rev. Rul. 92-18
Obsolete revenue rulings. Certain revenue rulings involving the tax on the sale of tires and related articles are declared obsolete.


ADMINISTRATIVE

Rev. Proc. 92-20
Change in method of accounting. New procedures are provided for taxpayers to request a change in method of accounting under section 446 of the Code. Rev. Proc. 84-74 modified and superseded.

Rev. Proc. 92-22
Construction issue elections. Procedures are set forth for electing under section 148(f)(4)(C) of the Code to pay a penalty in lieu of rebating arbitrage, for terminating the penalty, and for paying the penalty. Announcement 90-133 modified and superseded.

Rev. Proc. 92-27
Foreign insurance companies; effectively connected net investment income. This procedure provides the domestic asset/liability percentages and domestic investment yields under section 842(b) of the Code and provides guidance on making estimated payments.


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