Internal Revenue Bulletins  

February 26, 2001

Internal Revenue Bulletin No. 2001-09

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. Rul. 2001-1(PDF, 11K)
E & P adjustments on exercise of option. The earnings and profits of a corporate employer are reduced to reflect the deduction the corporation takes when an employee receives stock upon exercise of a nonstatutory stock option.

Rev. Rul. 2001-8(PDF, 19K)
Inventories; floor stocks payments. Payments made or received with respect to floor stocks must be accounted for as adjustments to the invoice price or production cost of the goods physically held on the floor stocks date to which the payments relate, rather than as an adjustment to the tax basis (carrying value) of those goods. This ruling provides, for costing purposes, an optional simplifying assumption for LIFO taxpayers regarding identification of the goods physically held on the floor stocks date to which the floor stocks payments relate. Rev. Ruls. 85-30 and 88-95 clarified. Rev. Proc. 99-49 modified and amplified.

EXEMPT ORGANIZATIONS

Rev. Proc. 2001-20(PDF, 26K)
This procedure describes the Voluntary Compliance on Alien Withholding Program (VCAP), which is available to certain public and other not-for-profit colleges and universities and their charitable affiliates to resolve issues arising from the payment, withholding, and reporting of certain taxes due on payments made to alien individuals.

ADMINISTRATIVE

Announcement 2001-13(PDF, 11K)
New Schedule N (Form 1120), Foreign Operations of U.S. Corporations, is now available. This form is used by corporations that have assets in, or operate a business in, a foreign country or U.S. possession.

Announcement 2001-21(PDF, 6K)
This announcement advises trustees and custodians of medical savings accounts of the extension of the requirement to file Form 8851, Summary of Archer MSAs, and changes for magnetic and electronic filing.

Notice 2001-16(PDF, 11K)
Intermediary transactions tax shelter. The Service may challenge certain transactions in which the assets of a corporation are sold following the purported sale of the corporation's stock to an intermediary. Such transactions are designated as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations.

Notice 2001-17(PDF, 11K)
Contingent liability tax shelter. The Service may challenge certain transactions in which a taxpayer transfers assets to a corporation and the transferee assumes a liability that the transferor has not yet taken into account for federal income tax purposes. Such transactions are designated as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations.

Notice 2001-18(PDF, 15K)
This notice provides an exception from the registration requirements under section 6111(d) of the Code and the list maintenance requirements under section 6112 for certain leasing transactions, except as may be provided in subsequent guidance.

Rev. Proc. 2001-19(PDF, 26K)
Automobile owners and lessees. This procedure provides owners and lessees of passenger automobiles (including electric automobiles) with tables detailing the limitations on depreciation deductions for automobiles first placed in service during calendar year 2001 and the amounts to be included in income for automobiles first leased during calendar year 2001. In addition, this procedure provides the maximum allowable value of employer-provided automobiles first made available to employees for personal use in calendar year 2001 for which the vehicle cents-per-mile valuation rule provided under section 1.61-21(e) of the regulations may be applicable.

Rev. Proc. 2001-21(PDF, 24K)
Election to treat certain debt substitutions as realization events. The procedure provides for an election that allows taxpayers to treat a debt substitution, in certain circumstances, as a realization event even though it does not result in a significant modification under section 1.1001-3 of the regulations. Rev. Proc. 99-18 modified and superseded.

Rev. Proc. 2001-22(PDF, 36K)
Pre-filing agreement program. This procedure permits a taxpayer subject to the jurisdiction of the Large and Mid-Size Business Division (LMSB) of the Service to request the examination of specific issues relating to a tax return before the return is timely filed. If the taxpayer and the Service are able to resolve the examined issues prior to the filing of the return, this procedure authorizes the taxpayer and the Service to finalize their resolution by executing an LMSB Pre-Filing Agreement.

T.D. 8936(PDF, 35K)
Final regulations under section 118(c) of the Code relate to the exclusion from gross income for a contribution in aid of construction (CIAC) from any person (whether or not a shareholder) to a regulated public utility that provides water or sewerage disposal services. The regulations define what property constitutes a CIAC for purposes of the exclusion from gross income and provide rules for adjusting the basis of water or sewerage disposal facilities acquired as, or acquired or constructed with any money received as, a CIAC. The regulations also provide the time and manner for taxpayers to notify the Secretary of amounts treated as a contribution to capital under this provision.

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