Internal Revenue Bulletins  

April 18, 1994

Internal Revenue Bulletin No. 1994-16

There are no links to the official documents for the years 1989 through 1995. The information below can only be used as help for further research, as there is not enough information here to rely on for official guidance. For that you need to obtain a copy of the complete document.


INCOME TAX

T.D. 8528
PS-55-93

Temporary and proposed regulations under sections 167 and 168 of the Code relate to certain elections for intangible property.

T.D. 8529
Final regulations under section 382 of the Code relate to limitations on corporate net operating loss carryforwards.

T.D. 8530
Final and temporary regulations under section 382 of the Code provide guidance on determining the value of a loss corporation following an ownership change to which section 382(1)(6) applies.


ADMINISTRATIVE

Rev. Proc. 94-28
Accounting method change; original issue discount; points. This procedure explains how taxpayers may change their methods of accounting to comply with the final regulations dealing with original issue discount and other related matters (T.D. 8517, 1994-9 I.R.B. 4). Taxpayers using this procedure change their method of accounting for debt instruments issued on or after a "cut-off date."

Rev. Proc. 94-29
Principal-reduction method; de minimis original issue discount; points. This procedure allows use of the principal-reduction method, which is an aggregate method of accounting for de minimis original issue discount, including de minimis original issue discount attributable to points. Taxpayers using this procedure change their methods of accounting for loans originated on or after a "cut-off date." This procedure also describes how eligible taxpayers may change to this method. Rev. Ruls. 216, 54-367, 64-278, and 74-607 obsoleted; Rev. Rul. 70-540 obsoleted to the extent of the lender's treatment of points.

Rev. Proc. 94-30
Revised loan liquidation method; points; "old loans." Because the method changes permitted by Rev. Procs. 94-28 and 94-29 cover only loans originated on or after a "cut-off date," this procedure explains how taxpayers may change their method of accounting for loans acquired before that date.

Notice 94-37
Payors will not be subject to penalties for calendar year 1993 and earlier years if they failed to file and furnish correct Forms 1099 as required by Rev. Rul. 93-70. This rule does not apply to payors that were notified of the Form 1099 requirement in a letter signed by a District Director.

Announcement 94-55
The Service is considering a major change to Form 8582, Passive Activity Loss Limitations. Drafts of the proposed revision and of the current version are provided for comments.


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