Internal Revenue Bulletins  

January 10, 1994

Internal Revenue Bulletin No. 1994-2

There are no links to the official documents for the years 1989 through 1995. The information below can only be used as help for further research, as there is not enough information here to rely on for official guidance. For that you need to obtain a copy of the complete document.


Announcement 94-5
Guidance is provided for partnerships and S corporations that have elected under section 444 of the Code to have a tax year other than that of their owners on how to effect a valid termination of their elections.


Rev. Rul. 94-3
LIF0; price indexes; department stores. The October 1993 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, October 31, 1993.

Rev. Rul. 94-4
Recognition of gain on deemed distributions of money. A deemed distribution of money under section 752(b) of the Code resulting from a decrease in a partner's share of liabilities is treated as an advance or drawing of money under section 1.731-1(a)(1)(ii) of the regulations to the extent of the partner's distributive share of income for the partnership taxable year.

Rev. Rul. 94-5
Classification of Louisiana limited liability company. Because of the flexibility accorded by the Louisiana Limited Liability Act, a Louisiana 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.

T.D. 8500
Final and temporary regulations under section 704 of the Code relate to allocations reflecting built-in gain or loss on property contributed to a partnership.

T.D. 8501

Temporary and proposed regulations under section 704 of the Code relate to (1) the remedial allocation method with respect to property contributed by a partner to a partnership, and (2) allocations with respect to securities and similar investments owned by a partnership. A public hearing will be held on April 4, 1994.

T.D. 8502

Temporary and proposed regulations under section 25 of the Code relate to the reissuance of mortgage credit certificates.

Notice 94-2
This notice provides transition relief for taxpayers who are subject to section 162(m) of the Code and who wish to base performance goals on services and performance results for periods beginning January 1, 1994.


Announcement 94-3
The Omnibus Budget Reconciliation Act of 1993 reinstated the vaccine excise tax, effective August 11, 1993.

Announcement 941
The Service intends to amend the temporary fuel floor stocks regulations (T.D. 8498) and the temporary diesel fuel regulations (T.D. 8496) to provide an exception from floor stocks tax for diesel fuel that is destined for an exempt use and that is dyed at any point in the chain of distribution and modify the description and concentration of dyes used to identify nontaxable diesel fuel.


Notice 9-1
Guidance is provided on several procedural issues relating to the new Netherlands Convention entering into force January 1, 1994.


Rev. Proc. 94-9
Low-income housing credit; election for rent; number of bedrooms method. How an owner of a qualified low income building that received an allocation of a low income housing credit dollar amount before 1990 can elect to use the number of bedrooms method to determine the gross rent limitation.

Rev. Proc. 94-10
Low-income housing credit; election for deep-rent skewed projects; gross rent. How an owner of a qualified low income building that received an allocation of a lonesome housing credit dollar amount before 1990 can elect to meet the 200% rent restriction requirement for market rate units in a deep-rent skewed building.

Rev. Proc. 94-11
Electronic filing; Form 1040. Participants in the electronic filing program for Form 1040, U.S. Individual Income Tax Return, are informed of their obligations to the Service, the taxpayers, and other participants. Rev. Proc. 93-8 superseded.

Rev. Proc. 94-12
Changes in annual accounting periods. This procedure prohibits the use of the automatic provisions of Rev. Proc. 92-13 by corporations that have an election in effect under section 936 of the Code. Rev. Proc. 9213 modified.

Announcement 94-1
New Form 1099-C, Cancellation of Debt, is provided for your information.

Announcement 94-2
New rules are explained on reporting moving expense reimbursements on 1994 Form W-2.

Announcement 94-6
The 1993 instructions for filing Form 1098, contained in the 1993 Instructions for Forms 1099, 1098, 5498, and W-2G, with regard to reporting the reimbursement of overpaid interest, are modified.

Announcement 94-7
The Office of Management and Budget has extended the expiration date of Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations.

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