Internal Revenue Bulletins  

October 5, 1992

Internal Revenue Bulletin No. 1992-40

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SPECIAL ANNOUNCEMENT

Announcement 92-136
A public hearing will be held on November 9, 1992, on proposed regulations relating to real estate mortgage investment conduit (REMIC) reporting requirements.


INCOME TAX

Rev. Rul. 92-83
Fringe benefits; aircraft valuation formula. For purposes of section 1.61-21(g) of the regulations, relating to the rule for valuing noncommercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) cents-per-mile rates and the terminal charges in effect for 1992 are set forth. Rev. Rul. 92-35 modified.

Rev. Rul. 92-84
Gain or loss; sale of S stock by QSST. If a "qualified subchapter S trust" (QSST) sells all or part of its stock in an S corporation, the beneficiary rather than the trust is the taxpayer who recognizes gain or loss on the sale of th stock, even if under local trust law gain or loss on the sale is allocable to corpus rather than to income.

Rev. Rul. 92-85
Deemed dividend distribution to foreign corporation; subject to federal income tax and section 1442 withholding. A section 304 deemed dividend distribution to a foreign corporation by a domestic or foreign corporation is subject to federal income tax and therefore section 1442 withholding to the extent the distribution is from sources within the U.S. The 30 percent statutory withholding tax rate may be reduced under the appropriate income tax treaty to the treaty withholding tax rate for dividends paid to 10 percent or greater corporate shareholders.

Rev. Rul. 92-86
Indirect foreign tax credit and section 304. A domestic corporation may compute foreign taxes deemed paid on deemed dividend distributions from foreign corporations under section 304 of the Code if the domestic corporation owns, directly or by attribution, 10 percent of the voting stock of the distributing foreign corporation. Rev. Rul. 91-5 modified and amplified.

Rev. Rul. 92-87
Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for October 1992.

Rev. Rul. 92-88
Limited partnerships. The Connecticut Uniform Limited Partnership Act corresponds to the Uniform Limited Partnership Act (ULPA) for purposes of section 301.7701-2 of the regulation. Rev. Rul. 89-123 amplified.

T.D. 8426
Final regulations under section 458 of the Code relate to a method of accounting for certain returns of magazines, paperbacks, or records.

T.D. 8428
Final and temporary regulations under section 382 of the Code relate to issuance and redemption of stock by certain regulated investment companies.

T.D. 8429
Final regulations under section 451 of the Code relate to the election to include crop insurance proceeds in gross income in the taxable year following the taxable year of destruction or damage.

T.D. 8431
FI-61-91

Final and proposed regulations under sections 67, 1275, and 6049 of the Code relate to original issue discount reporting requirements and real estate mortgage investment conduit (REMIC) reporting requirements.

Notice 92-43
The Service is granting relief to taxpayers in the Florida counties of Dade, Broward, and Monroe, and the Louisiana parish of Terre Bonne, who, as a result of Hurricane Andrew, are unable to comply with certain requirements of the low-income housing credit under section 42 of the Code.

Announcement 92-139
A list of organizations is provided that no longer qualify as organizations, contributions to which are deductible under section 170 of the Code.


EXEMPT ORGANIZATIONS

Notice 92-45
This notice provides relief from certain provisions of the Code for organizations giving emergency assistance to victims of Hurricanes Andrew and Iniki. The relief is available until December 31, 1992, or later if an extension by the Service is determined to be necessary or appropriate.


EMPLOYMENT TAXES

Railroad retirement, rate determination; quarterly
The Railroad Retirement Board has determined that the rate of tax imposed by section 3221(c) of the Code shall be thirty-one cents for the quarter beginning October 1, 1992.


ADMINISTRATIVE

T.D. 8427
Final regulations under section 7216 of the Code relate to disclosure of tax return information for purposes of quality or peer reviews.

Notice 92-44
Certain relief is granted to taxpayers and tax practitioners who are unable to meet deadlines for filing returns and paying taxes due to the destruction caused by Hurricane Iniki.

Announcement 92-138
Form 2758, Application for Extension of Time to File Certain Excise, Income, Information, and Other Returns, has been revised and is now available.


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