Internal Revenue Bulletins  

February 18, 1997

Internal Revenue Bulletin No. 1997-07

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

REG-209040-88(PDF, 64K)
Proposed regulations under section 1295 permit certain shareholders to make a special election, in lieu of the election currently provided for under that section, for certain preferred shares of a passive foreign investment company (PFIC). A public hearing will be held on May 8, 1997.

REG-209817-96(PDF, 85K)
Proposed regulations under section 7701 of the Code relate to the treatment of certain multiple-party financing transactions in which one party realizes income from leases or similar agreements and another party claims deductions related to that income. A public hearing will be held on April 29, 1997.

REG-249819-96(PDF, 39K)
Proposed regulations under sections 354, 355, and 356 of the Code relate to exchanges of stock and securities in certain reorganizations. A public hearing will be held on March 25, 1997.

REG-252231-96(PDF, 37K)
Proposed regulations under section 368 of the Code provide that the continuity of shareholder interest requirement for corporate reorganizations is satisfied if the acquiring corporation furnishes consideration which represents a proprietary interest in the affairs of the acquiring corporation and such consideration represents a substantial part of the value of the stock or properties transferred. A public hearing will be held on May 7, 1997.

Rev. Rul. 97-8(PDF, 36K)
LIFO; price indexes; department stores. The December 1996 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, December 31, 1996.

T.D. 8700(PDF, 89K)
Final regulations under section 475 of the Code provide guidance to enable taxpayers to comply with the mark-to-market requirements applicable to dealers in securities.

T.D. 8701(PDF, 57K)
Final regulations provide rules for making the deemed sale and deemed dividend elections under section 1291 of the Code.

T.D. 8707(PDF, 53K)
Final regulations under section 731 of the Code provide rules for partnership distributions of marketable securities and for determining when those distributions are taxable to the distributee partner.

EXEMPT ORGANIZATIONS

Announcement 97-12(PDF, 22K)
A list is given of organizations now classified as private foundations.

ADMINISTRATIVE

T.D. 8698(PDF, 41K)
Final regulations under section 6231 of the Code provide guidance necessary for the designation or selection of a tax matters partner for partnerships, including limited liability companies classified as partnerships.

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