Internal Revenue Bulletins  

June 25, 2001

Internal Revenue Bulletin No. 2001-26

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.


Notice 2001-40(PDF, 13K)
Frivolous filing position based on section 861 of the Code. There is no basis in law for the view that U.S. citizens and residents are not subject to tax on wages and other U.S. source income because the Code only taxes foreign-based activities.

Rev. Rul. 2001-29(PDF, 19K)
REIT and section 355(b) active conduct of a trade or business. A REIT can be engaged in the active conduct of a trade or business within the meaning of section 355(b) of the Code solely by virtue of functions with respect to rental activity that produces income qualifying as rents from real property within the meaning of section 856(d) of the Code. Rev. Rul. 73-236 obsoleted.

Rev. Rul. 2001-31(PDF, 15K)
Captive insurance transactions. This ruling explains that the Service will no longer raise the "economic family theory," set forth in Rev. Rul. 77-316 (1977-2 C.B. 53), in addressing whether captive insurance transactions constitute valid insurance. Rather, the Service will address captive insurance transactions on a case-by-case basis. Rev. Ruls. 77-316, 78-277, 88-72, and 89-61 obsoleted. Rev. Ruls. 78-338, 80-120, 92-93, and 2000-3 modified.

Rev. Rul. 2001-32(PDF, 19K)
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning July 1, 2001, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.


Announcement 2001-67(PDF, 10K)
Wentworth Community Services of Chicago, IL, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

Announcement 2001-68(PDF, 19K)
A list is provided of organizations now classified as private foundations.


Announcement 2001-65(PDF, 14K)
The Service announces that an updated edition of Publication 954, Tax Incentives for Empowerment Zones and Other Distressed Communities (revised June 2001), is now available.

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