Internal Revenue Bulletins  

May 24, 1993

Internal Revenue Bulletin No. 1993-21

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SPECIAL ANNOUNCEMENT

Announcement 93-76
A public hearing will be held on October 5, 1993, on proposed regulations relating to deduction for certain foreign deferred compensation plans.


INCOME TAX

T.D. 8474
CO-53-92

Final regulations and withdrawal of proposed regulations that remove final and temporary regulations under 26 CFR parts 1, 5, 5c, 12, 54, and 602 relating primarily to provisions of prior law.

EE-14081
Proposed regulations under section 404A of the Code relate to deduction for certain foreign deferred compensation plans.

Announcement 93-77
A list of organizations is provided that no longer qualify as organizations, contributions to which are deductible under section 170 of the Code.


ADMINISTRATIVE

Rev. Rul. 93-38
Classification of Delaware limited liability company. The Delaware Limited Liability Company Act contains numerous provisions that can be modified by a limited liability company agreement; accordingly, depending on the provisions of the limited liability company agreement, a Delaware limited liability company can assume the characteristics either of a corporation or of a partnership for federal tax purposes.

Announcement 93-78
Errors in Instructions for Form 5472 (Revised March 1992), Information Return of a 25% Foreign-Owned U.S. Corporation or Foreign Corporation Engaged in a U.S. Trade or Business, are corrected.


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