Internal Revenue Bulletins  

August 13, 2001

Internal Revenue Bulletin No. 2001-33

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.

INCOME TAX

Notice 2001-45(PDF, 17K)
Basis shifting tax shelter. The Service will challenge certain basis shifting tax avoidance transactions and intends to disallow losses claimed or increase taxable income or gains. Such transactions are designated as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations.

Rev. Rul. 2001-38(PDF, 15K)
Insurance companies; prevailing mortality and morbidity tables. The prevailing mortality and morbidity tables for contracts issued on or after January 1, 1999, are set forth for use by insurance companies to compute their reserves. Rev. Rul. 92-19 supplemented.

Rev. Rul. 2001-39(PDF, 14K)
U.S. corporation; wholly-owned Mexican subsidiary treated as a domestic corporation. This ruling obsoletes Rev. Rul. 70-379 (1970-2 C.B. 179) relating to a U.S. corporation electing under section 1504(d) of the Code to treat its wholly-owned Mexican subsidiary as a domestic corporation for the purpose of filing consolidated returns. Rev. Rul. 70-379 obsoleted.

EMPLOYEE PLANS

Notice 2001-48(PDF, 10K)
Weighted average interest rate update. The weighted average interest rate for July 2001 and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth.

ESTATE TAX

T.D. 8957(PDF, 25K)
Final regulations under sections 6075 and 6081 of the Code provide the executor of a decedent's estate an automatic 6-month extension of time to file Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, beyond the 9 months provided for by section 6075(a).

EXEMPT ORGANIZATIONS

Announcement 2001-81(PDF, 9K)
WorldCare, Inc., of La Mesa, CA, no longer qualifies as an organization to which contributions are deductible under section 170 of the Code.

ADMINISTRATIVE

Rev. Proc. 2001-40(PDF, 160K)
This procedure provides specifications for filing Form 1042-S, Foreign Person's U.S. Source Income Subject to Withholding, magnetically or electronically. Rev. Proc. 98-44 superseded.

Rev. Proc. 2001-41(PDF, 14K)
Technical advice furnished by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions & Products), Associate Chief Counsel (Income Tax & Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs & Special Industries), Associate Chief Counsel (Procedure & Administration), and Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). This procedure modifies Rev. Proc. 2001-2 (2001-1 I.R.B. 79) to clarify that technical advice will not be issued on frivolous issues and to provide a procedure for expedited review of denials of technical advice when a taxpayer requests advice on frivolous issues. Rev. Proc. 2001-2 modified.

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