Internal Revenue Bulletins  

August 26, 1991

Internal Revenue Bulletin No. 1991-34

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SPECIAL ANNOUNCEMENT

Announcement 91-123
A public hearing will be held on November 7, 1991, on proposed regulations relating to the treatment of certain stripped bonds and stripped coupons.


INCOME TAX

Rev. Rul. 91-46
Stripped bonds and stripped coupons; mortgages. Section 1286 of the Code is applied to certain sales of mortgages. Rev. Rul. 66-314 obsoleted.

T.D. 8358
FI 19-85

Temporary and proposed regulations under section 1286 of the Code relate to the treatment of certain stripped bonds and stripped coupons.


EMPLOYEE PLANS

Announcement 91-124
Form 5310, Application for Determination Upon Termination, and Form 6088, Distributable Benefits from Employee Pension Benefit Plans, have been revised and will be available for use on August 26, 1991. New Form 5310-A, Notice of Merger, Consolidation or Transfer of Plan Assets or Liabilities, will be available on October 1, 1991.


ADMINISTRATIVE

Rev. Proc. 91-21A
Insurance companies; discounting unpaid losses on claims-made basis. Rev. Proc. 91-21 is clarified and modified for insurance companies that qualify to elect to apply "Composite Schedule P" discount factors to unpaid losses under section 846 of the Code.

Rev. Proc. 91-47
Partnership cash or deferred arrangements. Limited relief is provided to certain partnership plans that failed to make the election provided in Notice 88-127 (section II), 1988-2 C.B. 538. Under certain conditions, the plan will be treated as containing a qualified cash or deferred arrangement under section 401(k) of the Code.

Rev. Proc. 91-48
Insurance companies; salvage recoverable; discounting. For purposes of section 832(b)(5)(A) of the Code, set forth are a series of discount factors and salvage recovery patterns that property and casualty insurance companies must use to discount estimated salvage recoverable for 1990 and prior accident years, as required by the Revenue Reconciliation Act of 1990. Guidance is also provided with respect to the section 481 adjustment, the special deduction, the special rule for overestimates and changes in estimates of salvage recoverable.

Rev. Proc. 91-49
Stripped bonds; mortgages; original issue discount. Simplified tax treatment is provided for certain mortgages that are stripped bonds under section 1286 of the Code.

Rev. Proc. 91-50
Stripped bonds and stripped coupons; mortgages; safe harbor. An elective safe harbor is provided for applying section 1286 of the Code to certain sales of mortgages. When elected, this safe harbor determines reasonable compensation for servicing mortgages.

Rev. Proc. 91-51
Stripped bonds and stripped coupons; mortgages; change in method of accounting. An exclusive procedure applies to taxpayers required to change their method of accounting for certain sales of mortgages to a method that complies with section 1286 of the Code.

Notice 91-27
This notice clarifies the proposed rules under sections 1.1502-21 and 1.1502-90 through -99 of the regulations concerning the use of losses and deductions by consolidated groups between January 1, 1987, and January 29, 1991.


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