Internal Revenue Bulletins  

May 9, 1994

Internal Revenue Bulletin No. 1994-19

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Rev. Rul. 94-28
Dividends-received deduction. Section 246(c)(4) of the Code applies to an instrument that affords the holder the rights of a creditor and is not stock for corporate law purposes but is stock for federal income tax purposes. Rev. Rul. 90-27 distinguished.

Rev. Rul. 94-30
Classification of Kansas limited liability company. Because of the flexibility accorded by the Kansas Limited Liability Company Act, a Kansas 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.

Notice 94-43
This notice announces the calendar year 1994 inflation adjustment factor and reference prices for the renew able electricity production credit under section 45(a) of the Code.

Notice 94-47
This notice provides that the Service will scrutinize certain instruments to determine whether their purported status as debt for federal income tax purposes is appropriate. Of concern are instruments that are designed to be treated as debt for federal income tax purposes but that either are mandatorily redeemable with stock or have unreasonably long maturities.

Notice 94-48
This notice provides that the Service will scrutinize certain proposed transactions that are intended to give an issuing corporation the tax benefits of issuing debt even though the corporation actually issues stock.

Notice 94-50
This notice provides references to guidance published by the Service with respect to the time and manner for making seven of the elections provided by the Omnibus Budget Reconciliation Act of 1993.

Notice 94-51
Countries that require participation in, or cooperation with, an international boycott are listed.


Proposed regulations under section 3402 of the Code relate to electronic filing of Form W-4. A public hearing will be held on July 15, 1994.


Rev. Proc. 94-35
Reproduction of forms; Forms 1096, 1098, 1099 series, 5498, and W-2G. Requirements are set forth for reproducing paper substitutes for Forms 1096, 1098, 1099 series, and W-2G, and for furnishing substitute statements to form recipients. Rev. Proc. 93-24 superseded.

Notice 94-52
T.D. 8487, 1993-30 I.R.B. 20, relating to minimum coverage requirements, is corrected.

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