Internal Revenue Bulletins  

May 29, 2001

Internal Revenue Bulletin No. 2001-22

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INCOME TAX

Rev. Rul. 2001-24(PDF, 33K)
Forward triangular merger. A controlling corporation's transfer of the acquiring corporation's stock to another controlled subsidiary as part of the plan of reorganization, following the merger of the acquired corporation with and into the acquiring corporation, will not cause the transaction to fail to qualify as a reorganization under sections 368(a)(1)(A) and 368(a)(2)(D) of the Code.

Rev. Rul. 2001-25(PDF, 32K)
Reverse triangular merger. A reverse triangular merger qualifies as a tax-free reorganization under sections 368(a)(1)(A) and 368(a)(2)(E) of the Code, notwithstanding that immediately after the merger, and as part of a plan that includes the merger, the surviving corporation sells a portion of its assets to an unrelated party for cash that it retains.

EXEMPT ORGANIZATIONS

Announcement 2001-61(PDF, 31K)
Excess benefit transactions. This document contains notice of a public hearing and submission of outlines of oral comments on proposed regulations (REG-246256-96, 2001-8 I.R.B. 713) relating to excess benefit transactions. The hearing is scheduled for July 31, 2001. Comments must be received by July 10, 2001.

ADMINISTRATIVE

Announcement 2001-58(PDF, 36K)
FOIA administrative appeals. Authority to respond to FOIA administrative appeals has been transferred to the Chief, Appeals, from the Assistant Chief Counsel (Disclosure & Privacy Law). All FOIA administrative appeals must be filed with the Chief, Appeals, at the address provided in this announcement.

Rev. Proc. 2001-34(PDF, 30K)
Qualified fuel under section 29(c)(1)(C). This procedure modifies Rev. Proc. 2001-30 (2001-19 I.R.B. 1163) regarding the circumstances under which the Service will issue private letter rulings regarding solid synthetic fuels produced from coal. Rev. Proc. 2001-30 modified.

Rev Proc. 2001-35(PDF, 33K)
Qualified mortgage bonds; mortgage credit certificates; national median gross income. Guidance is provided concerning the use of the national and area median gross income figures by issuers of qualified mortgage bonds and mortgage credit certificates in determing the housing cost/income ratio described in section 143(f) of the Code. Rev. Proc. 2000-21 obsoleted except as provided in section 5.02 of this revenue procedure.

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