Internal Revenue Bulletins  

September 21, 1992

Internal Revenue Bulletin No. 1992-38

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SPECIAL ANNOUNCEMENT

Announcement 92-129
A public hearing will be held on November 4, 1992, on proposed regulations relating to the general asset accounts under the accelerated cost recovery system.


INCOME TAX

Rev. Rul. 92-74
Elections under section 882(d). This ruling explains the income tax consequences of an election under section 882(d) of the Code by a foreign corporation.

Rev. Rul. 92-75
Foreign tax credit; income allocation to domestic parent. The allocation of income from a foreign subsidiary, in a country with which the U.S. has an income tax convention, to its domestic parent under section 482 of the Code reduces the amount of the foreign tax paid by the subsidiary to be used in computing the parent's deemed paid foreign tax credit under section 902 in the absence of efforts by the subsidiary and the domestic parent, including competent authority consideration, to reduce the subsidiary's foreign income tax liability. Rev. Rul. 76-508 superseded; Rev. Rul. 80-231 modified.

Rev. Rul. 92-77
Interest rates; underpayments and overpayments. The rate of interest determined under section 6621 of the Code for the calendar quarter beginning October 1, 1992, will be 6 percent for overpayments, 7 percent for underpayments, and 9 percent for large corporate underpayments.

PS-55-89
Proposed regulations under section 168 of the Code relate to general asset accounts under the accelerated cost recovery system.

Announcement 92-132
A list of organizations is provided that no longer qualify as organizations, contributions to which are deductible under section 170 of the Code.


EMPLOYEE PLAN

Rev. Rul. 92-76
Pre-termination restrictions; plan qualifications. Guidance is provided to implement section 1.401(a)(4)-5(b) of the regulations which replaces section 1.401-4(c) pertaining to the early termination restrictions and the 25 most highly compensated employees (including former employees) of an employer. Rev. Rul. 81-135 obsoleted.


EXEMPT ORGANIZATIONS

Announcement 92-131
A list is given of organizations now classified as private foundations and an organization that is not a private operating foundation.


ADMINISTRATIVE

Rev. Proc. 92-74
Change; cash to accrual with inventories. This procedure provides that certain taxpayers that are required to use inventories in order to clearly determine income may obtain expeditious consent to change their method of accounting to an overall accrual method, or to an accrual method of accounting in conjunction with a request to change to a special method of accounting. Rev. Proc. 85-36 modified and superseded.

Rev. Proc. 92-75
Change; cash to accrual. This procedure provides that certain taxpayers (other than those required to use inventories) may obtain expeditious consent to change their method of accounting to an overall accrual method, or to an accrual method of accounting in conjunction with a request to change to a special method of accounting. Rev. Proc. 85-37 modified and superseded.

Rev. Proc. 92-76
Insurance companies; historical payment pattern. An administrative procedure is provided by which a property and casualty insurance company determines whether a line of business is an eligible line of business for purposes of computing discounted unpaid losses based on the taxpayer's historical payment pattern.

Rev. Proc. 92-77
Insurance companies; estimated salvage recoverable; unpaid losses. Administrative guidance is provided concerning the proper amount of deduction for property and casualty insurance companies that, pursuant to regulations, increase unpaid losses by the amount of estimated salvage recoverable take into account on a company's annual statement.

Rev. Proc. 92-78
Insurance companies; estimated salvage recoverable; insurance pools. Guidance is provided on the treatment of estimated salvage recoverable relating to insurance pools. In addition, the date is extended for property and casualty insurance companies to disclose the extent to which estimated salvage recoverable relating to certain insurance pools was taken into account as a reduction to unpaid losses shown on the company's annual statement.

Notice 92-40
Certain relief is granted to taxpayers and tax practitioners who are unable to meet deadlines for filing returns and paying taxes due to the destruction caused by Hurricane Andrew.

IA-55-90
Proposed regulations under section 6611 of the Code relating to the clarification of the period during which interest is allowed on certain overpayments.

IA-4-92
Proposed regulations under section 6109 of the Code relate to the authority of the Federal Crop Insurance Corporation (FCIC) to require employer identification numbers.

Announcement 92-127
The Service announces that it plans to offer a settlement to certain taxpayers under exam regarding their method of accounting for multi-year insurance policies purchased in conjunction with the sale of multi-year service warranty contracts.

Announcement 92-128
This announcement discusses deductibility of contributions to organizations for Hurricane Andrew Relief, and explains how newly formed organizations may expedite consideration of their applications for recognition of exempt status.

Announcement 92-130
New Form 1120-W(FY), Fiscal Year Corporation Estimated Tax, has been developed for use by corporations with tax years beginning after June 30, 1992, and before January 1, 1993, and is now available from the IRS Forms Distribution Centers.


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