Internal Revenue Bulletins  

January 31, 2000

Internal Revenue Bulletin No. 2000-05

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. 2000-5(PDF, 23K)
Application of section 368(a)(1)(A) to divisive mergers. This ruling holds that a state law merger will not qualify as a reorganization under section 368(a)(1)(A) of the Code if the merger does not result in one corporation acquiring the assets of a target corporation and the target corporation ceasing to exist.

T.D. 8859(PDF, 55K)
Final regulations under section 42 of the Code amend various low-income housing tax credit regulations including the procedures for compliance monitoring by the state and local housing agencies, the requirements for making carryover allocations, and the rules for the agencies' correction of administrative errors or omissions. In addition, the regulations require the independent verification of information on sources and uses of funds submitted by tax-payers to the agencies.

T.D. 8860(PDF, 38K)
Final regulations under section 988 of the Code relate to the treatment of income and expenses from certain hyperinflationary, nonfunctional currency transactions and certain notional principal contracts.

EXEMPT ORGANIZATIONS

T.D. 8861(PDF, 38K)
Final regulations under section 6104(d) of the Code relate to the disclosure requirements of private foundations.

ADMINISTRATIVE

Notice 2000-9(PDF, 25K)
Insurance companies; treatment of variable contracts, closing agreements. This notice reminds issuers of variable contracts that diversification rules for investments in U.S. Treasury securities by separate accounts are different for variable annuity contracts than for variable life insurance contracts. For a limited time, the notice permits issuers of variable annuity contracts that did not satisfy the diversification requirements under section 817(h) of the Code, but which would have satisfied the more lenient diversification requirements for variable life insurance contracts, to obtain a closing agreement through a reduced payment amount.

Notice 2000-10(PDF, 15K)
Guidance Priority List. Public comments are requested about items that should be included in the Guidance Priority List for 2000. All comments should be submitted by February 14, 2000.

REG-103831-99(PDF, 43K)
Proposed regulations under section 752 of the Code relate to the allocation of non-recourse liabilities by a partnership. A public hearing is scheduled for May 3, 2000.

REG-111119-99(PDF, 63K)
Proposed regulations under section 708 of the Code clarify the tax consequences of partnership mergers and divisions. A public hearing is scheduled for May 4, 2000.

REG-116567-99(PDF, 25K)
Proposed regulations address when a currency will be considered hyperinflationary under section 988 of the Code. These regulations are intended to prevent distortions associated with the computation of income and expenses arising from section 988 transactions denominated in hyperinflationary currencies. A public hearing is scheduled for May 17, 2000.

Rev. Proc. 2000-15(PDF, 31K)
Innocent spouse; equitable relief. Guidance is provided for taxpayers seeking relief from federal tax liability under section 6015(f) or 66(c) of the Code. Notice 98-61 modified and superseded.

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