Internal Revenue Bulletins  

January 22, 2001

Internal Revenue Bulletin No. 2001-04

Links to Official IRS Bulletin Documents listed below are in the Adobe Acrobat PDF Format, and require the appropriate Acrobat Reader to view and/or print.


REG-104683-00(PDF, 91K)
Proposed regulations under section 902 of the Code provide that multi-year pooling of earnings and taxes will stop when a foreign corporation ceases to have a 10-percent domestic corporate shareholder. These regulations provide that the active rents and royalties exception from passive income treatment is no longer limited to payments from unrelated payors. The proposed regulations also include other clarifications regarding the application of section 904(d), guidance on the application of section 904(b), and guidance regarding section 904(j). A public hearing is scheduled for April 26, 2001.

REG-106702-00(PDF, 31K)
Proposed regulations under section 705 of the Code provide guidance for making basis adjustments necessary to coordinate sections 705 and 1032 of the Code in situations in which a corporation acquires an interest in a partnership that holds stock in that corporation. A public hearing is scheduled for May 3, 2001.

T.D. 8918(PDF, 15K)
REG-107176-00(PDF, 19K)
Temporary and proposed regulations relate to the deposit of federal taxes pursuant to section 6302 of the Code.

REG-251701-96(PDF, 72K)
Proposed regulations under sections 641 and 1361 of the Code relate to the taxation of electing small business trusts (ESBTs). A public hearing is scheduled for April 25, 2001.

T.D. 8915(PDF, 16K)
Temporary regulations under section 444 of the Code relate to the election of a taxable year other than the required taxable year. The regulations provide that solely with respect to an S corporation shareholder, an electing small business trust (ESBT) and a trust described in section 401(a) or section 501(c)(3) that is exempt from taxation under section 501(a) are not deferral entities for purposes of section 1.444-2T.

T.D. 8916(PDF, 70K)
Final regulations under section 864 of the Code provide guidance on the treatment of section 936 corporations for purposes of allocating expenses in order to calculate the alternative minimum tax foreign tax credit. Final regulations under section 904(d) relate to the application of the foreign tax credit separate categories, including the application of the look-through rules under section 904(d)(3).


Notice 2001-9(PDF, 14K)
This notice provides relief from the application of the Code's nondiscrimination requirements for certain governmental and church plans. Notices 98-39 and 99-40 modified.


Announcement 2001-10(PDF, 11K)
This document contains a notice of public hearing on proposed regulations (REG-105316-98, 2000-27 I.R.B. 98), regarding reporting for payments of qualified tuition and payments of interest on qualified education loans and magnetic media filing requirements for information returns. The hearing is scheduled for February 13, 2001.

Announcement 2001-11(PDF, 9K)
This document withdraws the notice of proposed rulemaking (REG-116733-98, 1999-36 I.R.B. 392) relating to recognition of gain on certain distributions of stock or securities of a controlled corporation in connection with an acquisition.

Notice 2001-7(PDF, 7K)
Information returns; payments to attorneys. The Service intends to further delay the effective date of the regulations proposed under section 6045(f) of the Code (relating to the reporting of payments of gross proceeds to attorneys). Under this extension, the rules in section 1.6045-5 will apply to payments made during the first calendar year that begins at least two months after the date of publication of the final regulations in the Federal Register. Notice 99-53 modified and superseded.

Notice 2001-8(PDF, 9K)
Information returns; discharge of indebtedness. The suspension of penalties under sections 6721 and 6722 of the Code provided by Notice 2000-22, 2000-16 I.R.B. 902, for certain organizations newly subject to section 6050P is being extended. Penalties will not be imposed on such organizations for failure to file information returns under section 6050P for any discharge of indebtedness that occurs prior to the first calendar year beginning at least two months after the date that appropriate guidance is issued. Notice 2000-22 modified and superseded.

Rev. Proc. 2001-16(PDF, 73K)
Publication 1245 (Rev. 1-2001) provides specifications for the filing of Forms W-4, Employee's Withholding Allowance Certificate, magnetically or electronically. Rev. Proc. 99-47 superseded.

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