Internal Revenue Bulletins  

August 20, 2001

Internal Revenue Bulletin No. 2001-34

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

Rev. Proc. 2001-43(PDF, 14K)
Partnership profits interests. This procedure clarifies Rev. Proc. 93-27 (1993-2 C.B. 343) by providing guidance on the treatment of the grant of a partnership profits interest that is substantially nonvested for the provision of services to or for the benefit of the partnership. Rev. Proc. 93-27 clarified.

T.D. 8960(PDF, 47K)
Temporary regulations under section 355(e) of the Code generally require corporations to recognize gain on certain distributions of stock or securities of a subsidiary corporation if the distribution is part of a plan that also involves one or more persons acquiring a 50-percent or greater interest in the distributing corporation or any controlled corporation.

GIFT TAX

Notice 2001-50(PDF, 18K)
This notice provides guidance regarding requests for an extension of time to make an allocation of generation-skipping transfer (GST) exemption under sections 2642(b)(1) and (2) of the Code. It also provides guidance regarding requests for an extension of time to make GST elections under sections 2632(b)(3) and 2632(c)(5).

ESTATE TAX

Notice 2001-50(PDF, 18K)
This notice provides guidance regarding requests for an extension of time to make an allocation of generation-skipping transfer (GST) exemption under sections 2642(b)(1) and (2) of the Code. It also provides guidance regarding requests for an extension of time to make GST elections under sections 2632(b)(3) and 2632(c)(5).

EMPLOYMENT TAX

T.D. 8959(PDF, 22K)
Final regulations under section 6205 of the Code provide guidance on interest-free adjustments of certain underpayments of employment taxes.

ADMINISTRATIVE

Notice 2001-49(PDF, 18K)
This notice proposes a revenue procedure that sets forth a safe harbor under which an issue of tax or revenue anticipation bonds will not be treated as outstanding longer than is reasonably necessary to accomplish the governmental purposes of the bonds under section 1.148-10(a)(4) of the regulations. The proposed procedure will apply to bonds sold after the date the procedure is published in the Internal Revenue Bulletin in final form. However, issuers may rely on the proposed procedure with respect to any issue of tax or revenue anticipation bonds that is sold before the effective date of the proposed revenue procedure and on or after August 3, 2001.

Notice 2001-51(PDF, 19K)
Listed transactions. This notice updates a listing of certain transactions that the Service has determined are tax avoidance transactions and identifies them as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T(b)(2) of the temporary regulations. Notice 2000-15 supplemented and superseded.

T.D. 8958(PDF, 22K)
Final regulations under section 6103 of the Code authorize the Service to disclose return information to the Department of Agriculture to structure, prepare, and conduct the Census of Agriculture.

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