Internal Revenue Bulletins  

September 8, 1992

Internal Revenue Bulletin No. 1992-36

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SPECIAL ANNOUNCEMENT

Announcement 92-123
A public hearing will be held on October 29, 1992, on proposed regulations relating to an ownership change of a corporation under the jurisdiction of a court in a title II case to which section 382(l)(5) of the Code does not apply.


INCOME TAX

Rev.Rul. 92-63A
Foreign tax credit. This ruling corrects the typographical error in Rev. Rul. 92-63, 1992-33 I.R.B., by substituting South Africa for South Korea in the list of countries subject to section 901(j) of the Code for the periods listed.

Rev. Rul. 92-67
Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 1274, 1288, 382, and other sections of the Code, tables set forth the rates for September 1992.

Rev. Rul. 92-69
Employer-provided outplacement counseling. The Service has ruled on the income tax and employment tax treatment in three situations where an employer provides outplacement services to its employees based on their individual needs and each affected employee is seeking new employment within the employee's same trade or business.

T.D. 8425
Final and temporary regulations under section 149 of the Code relate to information reporting requirements for tax-exempt bond issues.

CO-88-90
Proposed regulations under section 382 of the Code relate to an ownership change of a corporation under the jurisdiction of a court in a title 11 case to which section 382(l)(5) does not apply.

EE-6-92
Proposed regulations under sections 401 and 410 of the Code relate to nondiscrimination requirements for qualified plans.

EE-23-92
Proposed regulations under section 501 of the Code relate to the qualification of voluntary employees' beneficiary associations (VEBAs). A public hearing will be held on December 3, 1992.


EMPLOYEE PLANS

Rev. Rul. 92-66
Early retirement window benefit. Where a defined benefit pension plan is repeatedly amended so that an early retirement window benefit is available to certain employees for substantially consecutive, limited periods of time, the benefit is not required to be provided permanently if the facts and circumstances so warrant.

Notice 92-37
This notice describes certain proposed changes to the general test in the final regulations under section 401(a)(4) of the Code. Public comments on the proposal are requested.

Notice 92-38
Guidelines are set forth for determining for August 1992, the weighted average interest rate 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 as amended by the Omnibus budget Reconciliation Act of 1987.


GIFT TAX

Rev. Rul. 92-68
Revocation of Rev. Rul. 81-31. In view of Tax Court's opinion in "Estate of DiMarco v Commissioner," 87 T.C. 653 (1986), "acq. in result," 1980-2 C.B. 1, the Service has reconsidered Rev. Rul. 81-31. Rev. Rul. 81-31 revoked.


ADMINISTRATIVE

Rev. Proc. 92-69
Allocation and apportionment of research and development expenditures. Guidance is provided concerning the allocation and apportionment of research and development expenditures during the last six months of a taxpayer's first taxable year beginning after August 1, 1991, and during the immediately succeeding taxable year. Rev. Proc. 92-56 amplified.

Announcement 92-124
This announcement solicits written comments concerning issues that the Service should address in proposed regulations relating to the excise tax on amounts paid for communications services under sections 4251, 4252, 4253, and 4254 of the Code.

Announcement 92-125
T.D. 8394, 1992-10 I.R.B 4, relating to reimbursements of previously paid expenditures with tax exempt bond proceeds, is corrected.


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