Internal Revenue Bulletins  

January 18, 1994

Internal Revenue Bulletin No. 1994-3

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.


Rev. Rul. 91-6
Classification of Alabama limited liability company. Because of the flexibility accorded by the Alabama Limited Liability Company Act, an Alabama 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. 94-7
Meaning of security held for investment under section 475 mark-to-market rules. This ruling provides guidance concerning the identification of securities as "held for investment" for purposes of section 475 of the Code, by providing that the term "held for investment" has the same meaning for purposes of section 475 that it has for purposes of section 1236. Rev. Rul. 93-76 modified and clarified.

T.D. 8503

Temporary and proposed regulations under section 45B of the Code relate to credit for employer social security taxes paid on employee tips. A public hearing will be held on March 29, 1994.

Announcement 94-9
The Falls City Community Art Gallery, Inc., Louisviile, KY, no longer qualifies as an organization, contributions to which are deductible under section 170 of the Code.


Notice 94-3
Guidance is provided on employer-provided parking and transit passes under section 132(f) of the Code as amended by the Energy Policy Act of 1992. In addition to providing general guidance, this notice provides that taxpayers may use any reasonable good faith method in complying with section 132(f) during 1993 and the first quarter of 1994. Finally, the Service solicits comments and has scheduled a public hearing on these issues on February 1, 1994.


Announcement 94-8
The Service is considering issuing a revenue procedure that will set forth circumstances indicating that an organization is excepted from the lobbying expenditure reporting requirements of section 6033(e) of the Code.


T.D. 8504
Final regulations under sections 6011, 6071, and 6302 of the Code relate to reporting and depositing of Federal employment taxes.


Rev. Proc. 94-3
Section 401(a)(17) amendment procedures. This procedure provides guidance for certain sponsors of qualified plans and SEPs on amending their plans to reflect the modifications made by section 13212 of the Omnibus Budget Reconciliation Act of 1993 to section 401(a)(17) of the Code. Notice 92-36 and Rev. Procs. 89-9, 89-13, and 94-6 modified.

Rev. Proc. 94-14
Domestic asset/liability percentages and domestic investment yields. This procedure provides the domestic asset/liability percentages and domestic investment yields necessary for foreign insurance companies doing business in the U.S. to compute their minimum effectively connected net investment income under section 842(b) of the Code, for 1993 tax year.

Rev. Proc. 94-15
Waiver of section 911 time requirements. This procedure provides a current list of countries to which section 911(d)(4) of the Code applies.

Proposed regulations under section 7426 of the Code relate to civil actions by persons other than taxpayers.

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