Internal Revenue Bulletins  

October 4, 1993

Internal Revenue Bulletin No. 1993-30

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Rev. Rul. 93-61
Corporate reorganizations; stock exchanged for note and stock; dividend equivalency. Rev. Rul. 75-83 is revoked as a result of the Supreme Court's decision in Commissioner v. Clark which determined whether the receipt of boot in an acquisitive reorganization has the effect of a dividend distribution under section 356(a)(2) of the Code.

Rev. Rul. 93-62
Corporate reorganizations. Effect of the Supreme Court's decision in Commissioner v. Clark, 489 U.S. 726 (1989), 1989-2 C.B. 68, on the analysis of whether gain recognized on the receipt of cash in an exchange of stock that otherwise qualifies under section 355 of the Code is treated as a dividend distribution under section 356(a)(2). Rev. Rul. 74-516 superseded .

Rev. Rul. 93-63
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 1993, will be 6 percent for overpayments, 7 percent for underpayments, and 9 percent for large corporate underpayments.

Rev. Rul. 93-64
Federal rates; adjusted federal rates; adjusted federal longterm 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 1993.

T.D. 8484

Temporary and proposed regulations under section 809 of the Code provide guidance to life insurance companies in determining the equity base for purposes of computing the differential earnings amount and recomputed differential earnings amount. A public hearing will be held on December 3, 1993.

T.D. 8486
Final regulations under section 401 of the Code relate to permitted disparity with respect to benefits and contributions.

T.D. 8487
Final regulations under sections 401 and 410 of the Code relate to minimum coverage requirements.

T.D. 8488
Final regulations under section 414 of the Code relate to the definition of compensation for qualified plans.

T.D. 8489
Final regulations under section 112 of the Code relate to combat zone compensation of members of the Armed Forces.

Notice 93-47
Resident populations of the various states for purposes of determining the 1993 calendar year (1) state housing credit ceiling under section 42(h) of the Code, and (2) private activity bond volume cap under section 146 are reproduced.

Proposed regulations under sections 410 and 414 of the Code relate to qualified separate lines of business. A public hearing will be held on November 10, 1993.


Notice 93-49
Guidelines are set forth for determining for September 1993, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation,Act of 1987.


Announcement 93-128
This announcement informs filers of Form CT-1, Employer's Annual Railroad Retirement and Unemployment Repayment Tax Return, that payments of the quarterly Repayment Tax are no longer necessary. The Railroad Retirement Board has paid off the loan which made these payments necessary.


Rev. Proc. 93-38
Mortgage revenue bonds; mortgage credit certificates, qualified census tracts. The qualified census tracts for each state and the District of Columbia are set forth for use in determining the portion of loans required to be placed in targeted areas under section 143(h) of the Code. Rev. Proc. 83-51 obsoleted in part.

Notice 93-48
Recent tax law changes affect the tax treatment of educational assistance provided under employer-provided educational assistance plans.

Announcement 93-129
Form 5307, Application of Determination for Adopters of Master or Prototype, Regional Prototype or Volume Submitter Plans, has been revised; Form 5302, Employee Census, has been obsoleted.

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