Internal Revenue Bulletins  

December 27, 1993

Internal Revenue Bulletin No. 1993-42

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INCOME TAX

Rev. Rul. 93-92
Classification of Oklahoma limited liability company. Because of the flexibility accorded by the Oklahoma Limited Liability Company Act, an Oklahoma limited liability company may be classified as a partnership or as an association taxable as a corporation depending upon the provisions adopted in the limited liability company's articles of organization or operating agreement.

Rev. Rul. 93-93
Classification of Arizona limited liability company. Because the flexibility accorded by the Arizona Limited Liability Company Act, an Arizona limited liability company may be classified as a partnership or as an association taxable as a corporation depending upon the provisions adopted in the limited liability company's articles of organization or operating agreement.

Rev. Rul. 93-94
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 1994, will be 6 percent for overpayments, 7 percent for underpayments, and 9 percent for large corporate underpayments.

T.D. 8499
Final regulations under section 809 of the Code relate to differential earnings rate and the recomputed differential earnings rate of a mutual life insurance company.


EMPLOYEE PLANS

Notice 93-60
Guidelines are set forth for determining for December 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 limitations of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987.


EXEMPT ORGANIZATIONS

Announcement 93-150
A list is given of organizations now classified as private foundations.


EXCISE TAXES

Announcement 93-148
New registration activity for diesel fuel ultimate vendors will appear on the next revision of Form 637 and the Instructions for Form 637.


ADMINISTRATIVE

Rev. Proc. 93-48
Change in accounting method for notional principal contracts. Rules are provided by which a taxpayer may change its method of accounting for notional principal contracts as required by section 446 of the Code and the regulations thereunder.

Rev. Proc. 93-49
Income tax cost-of-living adjustments for tax years beginning in 1994. The Service provides cost-of-living adjustments factors and their application to the tax rate tables for individuals and for estates and trusts, the standard deduction amounts, the personal exemption, and several other items. Rev. Proc. 92-102 modified.

Rev. Proc. 93-50
Per diem allowances. This procedure provides rules under which the amount of ordinary and necessary business expenses of an employee for lodging, meals, and/or incidental expenses incurred while away from home will be deemed substantiated when a payor provides a reimbursement or other expense allowance to pay for such expenses. It also provides an optional method for employees and self-employed individuals to use in computing the deductible costs of business meal and incidental expenses paid or incurred while traveling away from home. Rev. Proc. 93-21 superseded.

Rev. Proc. 93-51
Optional standard mileage rates. This procedure announces 29 cents a mile as the optional rate for deducting or accounting for expenses for business use of an automobile for 1994, and provides rules for substantiating the deductible expenses of using an automobile for business, moving, medical, or charitable purposes. Rev. Proc. 92-104 superseded.

GL-708-88
Proposed regulations under section 6159 of the Code relate to agreements for the payment of tax liabilities in installments.

Announcement 93-149
Payors and recipients of qualified residence interest on any seller-provided financing are required to furnish certain identifying information.


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