Internal Revenue Bulletins  

July 13, 1992

Internal Revenue Bulletin No. 1992-28

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SPECIAL ANNOUNCEMENT

Announcement 92-96
A public hearing will be held on September 14, 1992, on proposed regulations relating to adjustments to basis of stock and indebtedness of S corporations and treatment of distributions by S corporations to shareholders.


INCOME TAX

Rev. Rul. 92-56
Regulated investment companies; qualifying gross income. If, in the normal course of its business, a regulated investment company (RIC) receives a reimbursement from its investment advisor and the reimbursement is includible in the RIC's gross income, the reimbursement is qualifying income under section 851(b)(2) of the Code. Rev. Ruls. 64-247 and 74-248 obsoleted in part.

T.D. 8420
Final regulations under section 42 of the Code relate to low-income housing credit.

PS-264-82
Proposed regulations under sections 1367 and 1368 of the Code relate to adjustments to basis of stock and indebtedness to shareholders of S corporations and treatment of distributions by S corporations to shareholders.


EXEMPT ORGANIZATIONS

Announcement 92-98
A list is given of organizations now classified as private foundations.


ADMINISTRATIVE

Rev. Proc. 92-56
Allocation and apportionment of research and development expenditures. Guidance is provided regarding the allocation and apportionment of research and development expenditures incurred 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. 92-57
Insurance companies; modification or restructuring of contracts. If the modification or restructuring of an annuity, life insurance, or endowment contract issued or assumed (through reinsurance) by a financially trouble insurance company satisfies specified conditions, the Service will treat the modification as not having an effect on the date that the affected contract was issued, entered into, or purchased for purposes of sections 72, 101(f), 264, 7702, and 7702A of the Code and also as not resulting in retesting or the start of a new test period under sections 7702(f)(7)(B)-(E) and 7702A(c).

Announcement 92-95
When finalized, the regulations relating to the alternate method for computing the amount of deposits of taxes under section 6302 of the Code will apply prospectively.

Announcement 92-97
T.D. 8405, 1992-19 I.R.B. 4, relating to limitations on corporate net operation loss carryforwards, is corrected.


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