Internal Revenue Bulletins  

July 11, 1994

Internal Revenue Bulletin No. 1994-28

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. 94-45
Insurance companies; transfer to corporation controlled by transferor. An assumption reinsurance transaction that is used to effectuate a transfer of insurance and annuity contracts as part of a section 351 exchange is not subject to the provision of sections 803 and 805 of the Code, and sections 1.817-4(d) and 1.848-2 of the regulations. Rev. Rul. 75-382 revoked.

Announcement 94-91
Chicago Divorce Association for Men, Itasca, IL, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.


Rev. Proc. 94-44
Estate and gift tax consequences resulting from the enactment of Florida Statutes Annotated section 737.402(4). The enactment of F.S.A. & 737.402(4) will not cause a lapse of a trustee-beneficiary's power of appointment for purposes of sections 2041 and 2514 of the Code. Any party in interests who elects not to be subject to the statute under F.A.A.&737-402(4)(b)(3) will not be treated as making a gift for purposes of section 2511.


Notice 94-72
Until further guidance is issued, the Service will not change the treatment of kerosene or require the use of dye injection systems, colorless markers, or visual inspection devices, or the making of information reports.


Rev. Proc. 94-45
Liquidating trust letter rulings; issuance procedures. Procedures are provided for furnishing ruling letters classifying entitles created pursuant to bankruptcy liquidating trusts under section 301.7701-4 of the regulations. Rev. Procs 82-58 and 91-15 modified and amplified.

Rev. Proc. 94-46
Majority in interest. This procedure provides a safe harbor that may be used to determine a "majority in interest" for purposes of section 301.7701-2(b)(1) of the regulations. Rev. Procs. 89-12 and 92-35 amplified.

T.D. 8540
Final regulations relating to the valuation of annuities, interests for life or terms of years, and remainder or reversionary interests.

T.D. 8541
Final regulations under section 7426 of the Code relate to civil actions by persons other than taxpayers.

Proposed regulations relating to exceptions to the use of standard valuation tables for valuating annuities, interests for life or a term of years, and remainder or reversionary interests.

Announcement 94-90
Annual Information Reporting Program seminars will be held. The schedule of cities, dates, and contact telephone numbers is shown.

Announcement 94-92
The Service invites written comments on issues that may be addressed in proposed regulations under section 197 of the Code relating to the amortization of goodwill and certain other intangibles.

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