| Files of Interest to Tax Professionals |
Date |
 |
| Announcement 2001-112(PDF, 5K) |
11/5/2001 |
| This announcement clarifies that the IRS will permit the
redesignation of estimated income tax payments |
| Announcement 2001-109(PDF, 13K) |
11/5/2001 |
| Revision of Forms 5300, 5307, 5309, 6406, and Schedule Q (Form 5300). The 2001 revisions of application forms used to request certain determination letters are now available on the IRS Web Site. |
| Announcement 2001-106(PDF, 26K) |
10/29/2001 |
| Saver's credit; employee plans and individual retirement arrangements. This announcement sets forth frequently asked questions and the related answers about the Saver's Credit described in section 25B of the Code. It also contains examples and a table regarding eligibility for this new nonrefundable credit. |
| Announcement 2001-104(PDF, 10K) |
10/22/2001 |
| GUST approved opinion letters and advisory letters. This announcement describes the issuance of GUST approved opinion letters and advisory letters in the instance of master & prototype and volume submitter specimen plans and reminds employers of the need to timely adopt their GUST approved plans. |
| Announcement 2001-103(PDF, 12K) |
10/22/2001 |
| Filing of certain schedules of Form 5500 due October 15, 2001. As a result of the disruption in financial markets caused by the events of September 11, 2001, this announcement provides limited relief from the penalties for failure to file a complete and accurate Schedule B and Schedule R of a Form 5500 that is due on or before October 15, 2001. |
| Announcement 2001-101(PDF, 9K) |
10/22/2001 |
| The purpose of this Announcement is to inform issuers of tax-exempt bonds that, effective immediately, the Internal Revenue Service will put into effect procedures to provide relief to issuers affected by the September 11, 2001, Terrorist Attack. |
| Announcement 2001-99(PDF, 9K) |
10/15/2001 |
| For purposes of the Archer MSA pilot program under section 220(j)(2) of the Code, 2001 is not a cut-off year. |
| Announcement 2001-98(PDF, 10K) |
10/9/2001 |
| This announcement advises taxpayers who file Form 720, Quarterly Federal Excise Tax Return, of the revised filing and deposit requirements effective for calendar quarters beginning after September 30, 2001. |
| Announcement 2001-93(PDF, 6K) |
10/29/2001 |
| The Service announces new reporting requirements for employee elective deferral "catch-up" contributions on the 2002 Form W-2. Similar reporting requirements will be addressed in the 2002 Instructions for Forms 1099-R and 5498. |
| Announcement 2001-92(PDF, 11K) |
9/24/2001 |
| This document announces that the reporting of an employee's income arising from the exercise of nonstatutory stock options on Form W-2 in box 12, using Code V, is optional for 2002 Forms W-2. This announcement also requests comments and suggestions as to alternative methods of collecting the information that employers would report in box 12 using Code V. |
| Announcement 2001-91(PDF, 12K) |
9/4/2001 |
| A payer may rely on a Form W-9, Request for Taxpayer Identification Number and Certification, received from an investment advisor or introducing broker authorized to transmit that form (or an electronic version) as the payee's agent, provided certain conditions are met. |
| Announcement 2001-83(PDF, 12K) |
8/27/2001 |
| Employee Plans (EP) determination letters; future of program. The Service invites the public to participate in a dialogue on the long-term future of the EP determination letter program and gives an Internet address to download a white paper that is available to begin that dialogue. |
| Announcement 2001-82(PDF, 9K) |
8/6/2001 |
| This announcement provides an alternative model amendment for proposed regulations (REG-130477-00 and REG-130481-00, 2001-11 I.R.B. 865) under section 401 of the Code, which certain qualified plan sponsors may adopt if they began making required minimum distributions for 2001 based on proposed regulations published in 1987. |
| Announcement 2001-77(PDF, 53K) |
7/23/2001 |
| Qualified plans; determination letters. This announcement describes steps the Service is taking to simplify the application procedures for determination letters on the qualification of pension, profit-sharing, stock bonus, and annuity plans under sections 401(a) and 403(a) of the Code. |
| Announcement 2001-63(PDF, 7K) |
6/18/2001 |
| The Service has revised the Defined Benefit Listing of Required Modifications and Information Package to allow additional options for master and prototype and volume submitter plans with respect to sections 415 and 417 of the Code. |
| Announcement 2001-58(PDF, 15K) |
5/29/2001 |
| FOIA administrative appeals. Authority to respond to FOIA administrative appeals has been transferred to the Chief, Appeals, from the Assistant Chief Counsel (Disclosure & Privacy Law). All FOIA administrative appeals must be filed with the Chief, Appeals, at the address provided in this announcement. |
| Announcement 2001-38(PDF, 35K) |
4/23/2001 |
| This document contains the annual report concerning pre-filing agreements under the Pre-Filing Agreement Program of the Large and Mid-Size Business Division for calendar year 2000. |
| Announcement 2001-34(PDF, 6K) |
4/19/2001 |
| This announcement sets forth the mutual agreement pursuant to Article 27 of the U.S.-Republic of Korea Income Tax Convention regarding gains from the disposition of shares of certain Korean real property corporations by U.S. persons. |
| Announcement 2001-33(PDF, 13K) |
4/23/2001 |
| Request for comments regarding the instructions for Form 990, Return of Organization Exempt From Income Tax, Form 990-EZ, Short Form Return of Organization Exempt From Income Tax, and Form 990vPF, Return of Private Foundation or Section 4947(a)(1) Nonexempt Charitable Trust Treated as a Private Foundation. |
| Announcement 2001-32(PDF, 169K) |
4/23/2001 |
| This announcement concerns Advance Pricing Agreements (APAs) and the experience of the APA Program during calendar year 2000. |
| Announcement 2001-22(PDF, 4K) |
3/12/2001 |
| Advance valuation of art. This announcement informs taxpayers who wish to request from the Service a Statement of Value under Rev. Proc. 96-15, 1996-1 C.B. 627, for use in substantiating the value of art for income, estate, and gift tax purposes of a change of address for submission of such requests. Rev. Proc. 96-15 modified. |
| Announcement 2001-21(PDF, 10K) |
2/26/2001 |
| This announcement advises trustees and custodians of medical savings accounts of the extension of the requirement to file Form 8851, Summary of Archer MSAs, and changes for magnetic and electronic filing. |
| Announcement 2001-19(PDF, 4K) |
3/5/2001 |
| This announcement corrects a numerical error in Rev. Rul. 2000-56, 2000-52 I.R.B. 597, relating to the inflation-adjusted amounts a taxpayer may lend a qualified continuing care facility without incurring imputed interest under section 7872(g) of the Code. |
| Announcement 2001-18(PDF, 9K) |
3/2/2001 |
| Model amendment; minimum distributions under section 401(a)(9).This announcement sets forth a corrected model amendment for qualified plan sponsors to adopt if they wish to follow the proposed regulations under section 401(a)(9) of the Code when making required minimum distributions for 2001 and subsequent calendar years. |
| Announcement 2001-16(PDF, 13K) |
2/20/2001 |
| This announcement provides guidance to federally recognized Indian tribal governments about their Federal Unemployment Tax Act (FUTA) obligations for 2000. Recent legislation changed how FUTA applies to Indian tribal governments. As of December 21, 2000, federally recognized Indian tribal governments are exempt from FUTA. The new law contains a transition rule which eliminates an Indian tribal government's 2000 liability for FUTA taxes for services performed before December 21, 2000, if certain requirements are met. Because the due date for the 2000 Form 940 used to report FUTA tax liability is January 31, 2001, this announcement is made to provide Indian tribal governments options in filing their Forms 940. |
| Announcement 2001-15(PDF, 5K) |
2/20/2001 |
| This announcement advises persons required to file information returns that the mandatory use of Form W-9, Request for Taxpayer Identification Number and Certification, (Rev. December 2000) by U.S. persons has been delayed until July 1, 2001. However, foreign persons may not use a Form W-9 after December 31, 2000. |
| Announcement 2001-14(PDF, 10K) |
2/12/2001 |
| This announcement requests comments and suggestions from the public for topics for Exempt Organizations plain-language publications and voluntary compliance programs. |
| Announcement 2001-6(PDF, 34K) |
1/16/2001 |
| This announcement provides a general summary of the rules for determining the GUST remedial amendment period for employers who use master and prototype (M&P) plans or volume submitter specimen plans. |
| Notice 2001-70(PDF, 8K) |
11/5/2001 |
| Additional disaster relief for taxpayers on account of the September 11, 2001, terrorist attack; depreciation, mid-quarter convention relief. This notice announces that the Treasury Department and the IRS intend to issue regulations permitting taxpayers to elect not to apply the mid-quarter convention rules contained in section 168(d)(3) of the Code to certain property placed in service in the tax year that includes September 11, 2001. This notice also provides guidance on making the election before regulations are issued. |
| Notice 2001-69(PDF, 11K) |
10/25/2001 |
| Tax issues related to employer's leave-based donations programs. |
| Notice 2001-66(PDF, 163K) |
10/29/2001 |
| This notice requests comments on and contains proposed audit guidelines for qualified intermediaries (Qls). These Qls are a key component of the withholding and reporting regulations that became effective on January 1, 2001 (T.D. 8734, 1997-2 C.B. 109 and T.D. 8881, 2000-23 I.R.B. 1158). |
| Notice 2001-63(PDF, 6K) |
10/1/2001 |
| This notice provides additional tax relief under sections 6081, 6161, and 7508A of the Code for taxpayers, regardless of their location, on account of events related to the September 11, 2001, terrorist attack. |
| Notice 2001-62(PDF, 10K) |
10/1/2001 |
| Timely filing or payment; private delivery services. An updated list of designated private delivery services (PDSs) is provided for purposes of section 7502 of the Code. Two new delivery services are added to the list. This notice also provides a new address for a PDS to use to submit its application for designation. The new address will also be used to request administrative review of a letter of denial of designation, appeal a letter confirming the denial of designation, provide written notification of any change in application information, and appeal a proposed revocation letter. Rev. Proc. 97-19 modified. Notice 99-41 modified and superseded. |
| Notice 2001-61(PDF, 17K) |
10/1/2001 |
| This notice provides tax relief under sections 6081, 6161, and 7508A of the Code for taxpayers affected by the September 11, 2001, terrorist attack, which included the destruction of the two World Trade Center towers and other buildings in the World Trade Center complex, damage to the Pentagon, and the airplane crash in Pennsylvania on Tuesday, September 11, 2001. |
| Notice 2001-60(PDF, 21K) |
10/1/2001 |
| This notice provides information about a closing agreement program for tax-exempt bonds (TEB VCAP). TEB VCAP provides a mechanism whereby issuers of tax-exempt bonds who come forward on a voluntary basis can resolve violations of the Code by entering into closing agreements with the Service. Comments are requested on TEB VCAP and on how the Service can expand its efforts to encourage compliance with the Code. |
| Notice 2001-59(PDF, 15K) |
10/9/2001 |
| Interest allocation. The IRS and the Treasury Department are soliciting comments on the appropriate method for allocating interest to certain types of financial positions that may constitute integrated financial transactions. |
| Notice 2001-57(PDF, 109K) |
9/17/2001 |
| Qualified plans; sample EGTRRA plan amendments. This notice sets forth various sample amendments that may be adopted by qualified plan sponsors as "good faith" plan amendments to reflect certain changes made by the Economic Growth Tax Relief and Reconciliation Act of 2001 (EGTRRA). Notice 2001-42 modified. |
| Notice 2001-56(PDF, 28K) |
9/17/2001 |
| EGTRRA effective dates; compensation limit; top-heavy determination date; section 401(k) hardship distribution. This notice provides guidance relating to the effective dates for sections of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) relating to (1) the increase in the compensation limit of section 401(a)(17) of the Code, (2) the modification to the top-heavy rules of section 416 of the Code, and (3) the suspension period for hard-ship distributions from a section 401(k) plan. Notice 98-52 modified. |
| Notice 2001-55(PDF, 10K) |
8/20/2001 |
| This notice provides guidance to section 529 qualified tuition programs and to program participants regarding the restriction on investment direction described in section 529(b)(5) of the Code. |
| Notice 2001-51(PDF, 12K) |
8/20/2001 |
| Listed transactions. This notice updates a listing of certain transactions that the Service has determined are tax avoidance transactions and identifies them as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T(b)(2) of the temporary regulations. Notice 2000-15 supplemented and superseded. |
| Notice 2001-50(PDF, 12K) |
8/20/2001 |
| This notice provides guidance regarding requests for an extension of time to make an allocation of generation-skipping transfer (GST) exemption under sections 2642(b)(1) and (2) of the Code. It also provides guidance regarding requests for an extension of time to make GST elections under sections 2632(b)(3) and 2632(c)(5). |
| Notice 2001-49(PDF, 15K) |
8/20/2001 |
| This notice proposes a revenue procedure that sets forth a safe harbor under which an issue of tax or revenue anticipation bonds will not be treated as outstanding longer than is reasonably necessary to accomplish the governmental purposes of the bonds under section 1.148-10(a)(4) of the regulations. The proposed procedure will apply to bonds sold after the date the procedure is published in the Internal Revenue Bulletin in final form. However, issuers may rely on the proposed procedure with respect to any issue of tax or revenue anticipation bonds that is sold before the effective date of the proposed revenue procedure and on or after August 3, 2001. |
| Notice 2001-47(PDF, 11K) |
6/25/2001 |
| Frivolous filing position based on section 861 of the Code. There is no basis in law for the view that U.S. citizens and residents are not subject to tax on wages and other U.S. source income because the Code only taxes foreign-based activities. |
| Notice 2001-46(PDF, 12K) |
8/6/2001 |
| Nonapplication of nondiscrimination rules; certain church and governmental plans. This notice extends the relief relating to the application of nondiscrimination rules for certain church and governmental retirement plans. Notice 2001-9 modified. |
| Notice 2001-45(PDF, 15K) |
8/13/2001 |
| Basis shifting tax shelter. The Service will challenge certain basis shifting tax avoidance transactions and intends to disallow losses claimed or increase taxable income or gains. Such transactions are designated as "listed transactions" for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations. |
| Notice 2001-44(PDF, 36K) |
7/23/2001 |
| Notional principal contract (NPC). The IRS and the Treasury Department are soliciting comments on the appropriate method for including in income or deducting contingent nonperiodic payments made pursuant to a notional principal contract and the treatment of such inclusions or deductions. |
| Notice 2001-43(PDF, 35K) |
7/23/2001 |
| This notice provides transitional relief and guidance to certain U.S. withholding agents making payments to nonqualified intermediaries (NQIs) and foreign trusts for implementing the new withholding regulations under section 1441 of the Code. These regulations, which were published as T.D. 8734 (1997-2 C.B. 109) and T.D. 8881 (2000-23 I.R.B. 1158), apply to payments made after December 31, 2000. Announcement 2000-48 modified. Notice 2001-4 modified. |
| Notice 2001-42(PDF, 37K) |
7/23/2001 |
| Qualified plans; remedial amendment period. This notice provides a remedial amendment period under section 401(b) of the Code with respect to the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA). This remedial amendment period is conditioned on the timely adoption of "good faith" EGTRRA plan amendments. The GUST remedial amendment period for individually designed plans is not being extended. Rev. Procs. 2000-20 and 2001-6 modified. |
| Notice 2001-37(PDF, 21K) |
6/18/2001 |
| Definition of compensation; qualified transportation fringe benefits. This notice provides guidance to sponsors of qualified plans and tax-sheltered annuity plans concerning changes made to the definition of compensation by the Community Renewal Tax Relief Act of 2000. These changes generally expand the definition of compensation to reflect elective salary reductions for qualified transportation fringe benefits. |
| Notice 2001-35(PDF, 57K) |
6/4/2001 |
| Annual accounting periods; automatic approval. This notice provides a proposed revenue procedure that, when finalized, will provide the procedures for certain partnerships, S corporations, electing S corporations, and personal service corporations to obtain automatic approval of the Commissioner to adopt, change, or retain their annual accounting periods. |
| Notice 2001-34(PDF, 88K) |
6/4/2001 |
| Annual accounting periods; approval. This notice provides a proposed revenue procedure that, when finalized, will provide the procedures under section 442 of the Code to establish a business purpose and request the approval of the Commissioner to adopt, change, or retain a taxpayer's annual accounting period. |
| Notice 2001-30(PDF, 15K) |
4/9/2001 |
| This notice provides tax relief under sections 6081, 6161, 6404(h), 6654(e)(3), and 7508A of the Code for taxpayers affected by the Cerro Grande Fire. |
| Notice 2001-29(PDF, 11K) |
4/9/2001 |
| Research credit suspension period. This notice provides guidance to corporate taxpayers that file Form 7004 requesting an extension of time to file their income tax return for a taxable year that includes expired research credit suspension periods. |
| Notice 2001-25(PDF, 12k) |
3/26/2001 |
| This notice provides a method for transferring the estimated tax payments made by an electing small business trust (ESBT) to the account of the deemed owner of the ESBT. The estimated tax payments made by the trust will be treated as a payment of estimated tax made by the deemed owner of the ESBT on January 15, 2001. For purposes of the annualized income installment method of section 6654(d)(2)(B) of the Code, the deemed owner may take into account, as of the last day of the deemed owner's 2000 taxable year, all S corporation items allocable to stock held by the ESBT. |
| Notice 2001-24(PDF, 11K) |
3/19/2001 |
| The "differential earnings rate" under section 809 of the Code is tentatively determined for 2000 together with the "recomputed differential earnings rate" for 1999. |
| Notice 2001-23(PDF, 8K) |
3/19/2001 |
| Business expenses; changes in method of accounting. This notice modifies Rev. Rul. 2001-4, 2001-3 I.R.B. 295, which holds, in part, that costs incurred by a taxpayer to perform work on its aircraft airframe as part of a heavy maintenance visit generally are deductible as ordinary and necessary business expenses under section 162 of the Code. Rev. Rul. 2001-4 is modified by extending the application of the automatic consent for change in accounting method provisions of Rev. Proc. 99-49, 1999-2 C.B. 725, to the taxpayer's first or second taxable year ending after December 21, 2000. Rev. Proc. 99-49 and Rev. Rul. 2001-4 modified. |
| Notice 2001-22(PDF, 9K) |
3/19/2001 |
| Installment sales; changes in method of accounting. This notice provides that an accrual method taxpayer that entered into an installment sale on or after December 17, 1999, and filed a federal income tax return by April 16, 2001, reporting the sale on an accrual method has the consent of the Secretary to revoke its effective election out of the installment method. The taxpayer must file, within the applicable period of limitations, amended federal income tax returns for the taxable year in which the installment sale occurred, and for any other affected taxable year, reporting the gain on the installment method. Notice 2000-26 modified. |
| Notice 2001-19(PDF, 7K) |
3/5/2001 |
| Comments on research credit regulations. This notice announces that the Treasury Department and the IRS will review the research credit final regulations in T.D. 8930 (2001-5 I.R.B. 433), and that comments are requested on the final regulations. Upon completion of this review, Treasury and the IRS will announce changes to the regulations, if any, in the form of proposed regulations. In addition, T.D. 8930 will be revised so that the provisions of the regulations, including any changes, will be effective no earlier than the date the review is completed. However, the provisions related to internal-use computer software (including any revisions) generally will be applicable to taxable years beginning after December 31, 1985. Comments should be submitted by April 2, 2001. |
| Notice 2001-18(PDF, 11K) |
2/26/2001 |
| This notice provides an exception from the registration requirements under section 6111(d) of the Code and the list maintenance requirements under section 6112 for certain leasing transactions, except as may be provided in subsequent guidance. |
| Notice 2001-17(PDF, 17K) |
2/26/2001 |
| Contingent liability tax shelter. The Service may challenge certain transactions in which a taxpayer transfers assets to a corporation and the transferee assumes a liability that the transferor has not yet taken into account for federal income tax purposes. Such transactions are designated as (listed transactions� for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations. |
| Notice 2001-16(PDF, 10K) |
2/26/2001 |
| Intermediary transactions tax shelter. The Service may challenge certain transactions in which the assets of a corporation are sold following the purported sale of the corporation's stock to an intermediary. Such transactions are designated as (listed transactions for purposes of sections 1.6011-4T(b)(2) and 301.6111-2T of the regulations. |
| Notice 2001-14(PDF, 28K) |
2/5/2001 |
| Application of employment taxes to statutory options. This notice provides notice of intent to issue guidance regarding an employer's income tax withholding obligations upon a disposition of stock acquired by an individual pursuant to the exercise of a statutory option. This notice also provides notice of intent to issue administrative guidance clarifying cur-rent law as to the application of employment taxes upon an exercise of a statutory option. Public comments about the anticipated guidance must be submitted by May 7, 2001. Rev. Rul. 71-52 obsolete. Notice 87-49 modified. |
| Notice 2001-13(PDF, 26K) |
2/5/2001 |
| This notice announces the extension of the Comprehensive Case Resolution pilot program, which was announced in Notice 2000-43, 2000-35, I.R.B. 209, and under which large business taxpayers may request resolution of all years they have open under examination by the Large and Mid-Size Business Division, in Appeals, and in docketed status before the United States Tax Court, through an Internal Revenue Service team process. |
| Notice 2001-12(PDF, 7K) |
1/16/2001 |
| This notice clarifies Rev. Proc. 2001-13, 2001-3 I.R.B. (Jan. 16, 2001), to provide that the inflation-adjustment amounts set forth in Part I of section 3 of that revenue procedure are the applicable amounts for 2001 in light of recently enacted legislation. |
| Notice 2001-10(PDF, 57K) |
1/29/2001 |
| Split-dollar insurance arrangements. This notice clarifies prior rulings issued by the IRS regarding the taxation of split-dollar arrangements, provides taxpayers with interim guidance on the tax treatment of split-dollar arrangements pending publication of further guidance, and requests taxpayer comments on the interim guidance and a number of unresolved issues. Rev. Rul 55-747 revoked. Rev. Ruls. 64-32-8 and 66-110 modified. |
| Revenue Procedure 2001-51(PDF, 9K) |
10/22/2001 |
| Section 1374 rulings. This procedure modifies Rev. Proc. 2001-3 (2001-1 I.R.B. 111) by removing section 5.06 from the No-Rule list. This concerns the application of section 1374 of the Code to certain timber, coal, and domestic iron ore transactions. Rev. Proc. 2001-3 modified. |
| Revenue Procedure 2001-48(PDF, 7K) |
10/1/2001 |
| This procedure provides the domestic asset/liability percentages and domestic investment yield percentages needed by foreign companies conducting insurance business in the United States to compute their minimum effectively connected net investment income. |
| Revenue Procedure 2001-47(PDF, 61K) |
10/15/2001 |
| Per diem allowances. This procedure provides rules for deeming substantiated the amount of certain reimbursed traveling expenses of an employee as well as optional rules for determining the amount of deductible meals and incidental expenses while traveling away from home. Rev. Proc. 2000-39 superseded. |
| Revenue Procedure 2001-46(PDF, 66K) |
9/10/2001 |
| Business expenses, capital expenditures, railroad track maintenance costs. This procedure provides a safe harbor method of accounting for track structure expenditures paid or incurred by certain railroads, and procedures for a qualifying taxpayer to obtain automatic consent from the Commissioner to change to the track maintenance allowance method. In addition, this procedure provides an optional procedure for certain qualifying taxpayers to settle the issue of track structure expenditures for open taxable years using the track maintenance allowance method. Rev. Proc. 99-49 modified and amplified. |
| Revenue Procedure 2001-43(PDF, 9K) |
8/20/2001 |
| Partnership profits interests. This procedure clarifies Rev. Proc. 93-27 (1993-2 C.B. 343) by providing guidance on the treatment of the grant of a partnership profits interest that is substantially nonvested for the provision of services to or for the benefit of the partnership. Rev. Proc. 93-27 clarified. |
| Revenue Procedure 2001-42(PDF, 58K) |
9/4/2001 |
| Insurance companies; modified endowment contracts; uniform closing agreement. This revenue procedure provides procedures by which an issuer may remedy an inadvertent non-egregious failure to comply with the modified endowment contract rules under section 7702A of the Code. Rev. Proc. 99-27 superseded. |
| Revenue Procedure 2001-41(PDF, 10K) |
8/13/2001 |
| Technical advice furnished by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Financial Institutions & Products), Associate Chief Counsel (Income Tax & Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs & Special Industries), Associate Chief Counsel (Procedure & Administration), and Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). This procedure modifies Rev. Proc. 2001-2 (2001-1 I.R.B. 79) to clarify that technical advice will not be issued on frivolous issues and to provide a procedure for expedited review of denials of technical advice when a taxpayer requests advice on frivolous issues. Rev. Proc. 2001-2 modified. |
| Revenue Procedure 2001-39(PDF, 9K) |
7/9/2001 |
| This procedure modifies the definitions of capitation fee and per-unit fee in Rev. Proc. 97-13 (1997-1 C.B. 632) to permit automatic increases of those fees according to a specified, objective, and external standard such as the Consumer Price Index. Rev. Proc. 97-13 modified. |
| Revenue Procedure 2001-37(PDF, 20K) |
6/4/2001 |
| This procedure provides guidance to taxpayers regarding certain elections made pursuant to the FSC Repeal and Extraterritorial Income Exclusion Act of 2000 ("the Act"). Specifically, this revenue procedure includes guidance with respect to the election to exclude gross receipts from foreign trading gross receipts under section 942(a)(3) of the Code, the election (and revocation of such election) by a foreign corporation to be treated as a domestic corporation under section 943(e)(1) of the Code, and the election (and revocation of such election) by a taxpayer to apply the extraterritorial income exclusion in lieu of the foreign sales corporation ("FSC") provisions to certain transactions under section 5(c)(2) of the Act. |
| Revenue Procedure 2001-36(PDF, 15K) |
6/4/2001 |
| This procedure grants automatic permission for certain securities partnerships to aggregate the built-in gains and losses from contributed property for purposes of making allocations under section 704(c) of the Code. |
| Revenue Procedure 2001-34(PDF, 9K) |
5/29/2001 |
| Qualified fuel under section 29(c)(1)(C). This procedure modifies Rev. Proc. 2001-30 (2001-19 I.R.B. 1163) regarding the circumstances under which the Service will issue private letter rulings regarding solid synthetic fuels produced from coal. Rev. Proc. 2001-30 modified. |
| Revenue Procedure 2001-30(PDF, 12K) |
3/7/2001 |
| Qualified fuel under section 29(c)(1)(C). This procedure informs the public of the Service's decision to issue private letter rulings, under specified circumstances, regarding whether a solid fuel produced from coal is a qualified fuel under section 29(c)(1)(C) of the Code. Section 5.01 of Rev. Proc. 2001-3 revoked. |
| Revenue Procedure 2001-27(PDF, 13K) |
3/7/2001 |
| Section 911(d)(4) waiver. Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries and the dates those countries are subject to the section 911(d)(4) waiver is provided. Rev. Proc. 2000-14 supplemented. |
| Revenue Procedure 2001-25(PDF, 11K) |
3/19/2001 |
| Automatic accounting method change for stated interest on short-term loans. This procedure modifies section 13.02 of the Appendix to Rev. Proc. 99-49, 1999-2 C.B. 725, 757, to allow any bank that uses the cash receipts and disbursements method of accounting to change automatically its method of accounting for stated interest on short-term loans made in the ordinary course of its business. Rev. Proc. 99-49 modified. |
| Revenue Procedure 2001-24(PDF, 17K) |
3/5/2001 |
| Change in method of accounting. This procedure allows an insurance company to obtain automatic consent to change its method of accounting for cash advances on commissions paid to its agents, from deducting cash advances in the taxable year paid to an agent to deducting cash advances in the taxable year earned by the agent. Rev. Proc. 99-49 modified and amplified. |
| Revenue Procedure 2001-23(PDF, 39K) |
3/5/2001 |
| Dollar-value LIFO; used vehicles. This procedure provides an optional LIFO inventory computation method for taxpayers who sell used automobiles or used light-duty trucks. The link-chain, dollar-value LIFO inventory method is designed to simplify the dollar-value LIFO computations of used vehicle dealers. Rev. Proc. 99-49 modified and amplified. |
| Revenue Procedure 2001-22(PDF, 50K) |
2/26/2001 |
| Pre-filing agreement program. This procedure permits a taxpayer subject to the jurisdiction of the Large and Mid-Size Business Division (LMSB) of the Service to request the examination of specific issues relating to a tax return before the return is timely filed. If the taxpayer and the Service are able to resolve the examined issues prior to the filing of the return, this procedure authorizes the taxpayer and the Service to finalize their resolution by executing an LMSB Pre-Filing Agreement. |
| Revenue Procedure 2001-21(PDF, 23K) |
2/26/2001 |
| Election to treat certain debt substitutions as realization events. The procedure provides for an election that allows taxpayers to treat a debt substitution, in certain circumstances, as a realization event even though it does not result in a significant modification under section 1.1001-3 of the regulations. Rev. Proc. 99-18 modified and superseded. |
| Revenue Procedure 2001-20(PDF, 43K) |
2/26/2001 |
| This procedure describes the Voluntary Compliance on Alien Withholding Program (VCAP), which is available to certain public and other not-for-profit colleges and universities and their charitable affiliates to resolve issues arising from the payment, withholding, and reporting of certain taxes due on payments made to alien individuals. |
| Revenue Procedure 2001-18(PDF, 27K) |
2/20/2001 |
| Last known address. This procedure explains how a taxpayer is to inform the Service of a change of address. When so informed, the Service will update the taxpayer's address of record to the new address. The Service uses the taxpayer's address of record for the various notices that are required to be sent to a taxpayer's "last known address" under the Code and for refunds of overpayments of tax. Rev. Proc. 90-18 amplified and superseded. |
| Revenue Procedure 2001-17(PDF, 197K) |
2/12/2001 |
| Administrative programs; closing agreements. This procedure updates and expands upon the Service's correction programs for retirement programs within the jurisdiction of the Commissioner, Tax Exempt and Government Entities Division. Rev. Proc. 2000-16 modified and superseded. Rev. Proc. 2001-8 modified. |
| Revenue Procedure 2001-15(PDF, 53K) |
1/29/2001 |
| This procedure provides a modified and supplemented list of Indian tribal governments that are to be treated similarly to states for specified purposes under the Internal Revenue Code. Rev. Procs. 83v87 and 92v19 superseded. |
| Revenue Ruling 2001-57(PDF, 14K) |
10/19/2001 |
| If an individual elects under § 311(e) of the Taxpayer Relief Act of 1997 ("TRA 97"), 1997-4 (Vol. 1) C.B. 1, 49-50, to treat the individual's principal residence as being both sold and reacquired on January 1, 2001, for an amount equal to its fair market value on that date ("§ 311(e) election"), can the individual exclude from gross income under § 121 of the Internal Revenue Code any of the gain resulting from the deemed sale? |
| Revenue Ruling 2001-52(PDF, 5K) |
11/5/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for November 2001. |
| Revenue Ruling 2001-51(PDF, 48K) |
11/5/2001 |
| Limitations on benefits and contributions. This ruling provides guidance on the limitations under section 415 of the Code, as amended by the Economic Growth and Tax Relief Reconciliation Act of 2001. Rev. Rul. 98-1 modified. |
| Revenue Ruling 2001-50(PDF, 13K) |
10/22/2001 |
| Built-in gains tax. The built-in gains tax under section 1374 of the Code will not apply to the timber, coal, and domestic iron ore transactions described in the four situations in the ruling. |
| Revenue Ruling 2001-49(PDF, 5K) |
10/9/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for October 2001. |
| Revenue Ruling 2001-48(PDF, 28K) |
10/15/2001 |
| This ruling updates the list of countries that grant a reciprocal exemption for income from the international operation of ships or aircraft to U.S. persons for purposes of sections 872(b) and 883 of the Code. Rev. Ruls. 89-42 and 97-31 modified and superseded. |
| Revenue Ruling 2001-46(PDF, 22K) |
10/15/2001 |
| Step transaction. Under the facts presented, if, pursuant to an integrated plan, a newly formed wholly owned subsidiary of an acquiring corporation merges into a target corporation, followed by the merger of the target corporation into the acquiring corporation, the transaction is treated as a single statutory merger of the target corporation into the acquiring corporation that qualifies as a reorganization under section 368(a)(1)(A) of the Code. Rev. Rul. 67-274 amplified. Rev. Rul. 90-95 distinguished. |
| Revenue Ruling 2001-43(PDF, 6K) |
9/4/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for September 2001. |
| Revenue Ruling 2001-39(PDF, 7K) |
8/13/2001 |
| U.S. corporation; wholly-owned Mexican subsidiary treated as a domestic corporation. This ruling obsoletes Rev. Rul. 70-379 (1970-2 C.B. 179) relating to a U.S. corporation electing under section 1504(d) of the Code to treat its wholly-owned Mexican subsidiary as a domestic corporation for the purpose of filing consolidated returns. Rev. Rul. 70-379 obsoleted. |
| Revenue Ruling 2001-38(PDF, 7K) |
8/13/2001 |
| Insurance companies; prevailing mortality and morbidity tables. The prevailing mortality and morbidity tables for contracts issued on or after January 1, 1999, are set forth for use by insurance companies to compute their reserves. Rev. Rul. 92-19 supplemented. |
| Revenue Ruling 2001-36(PDF, 6K) |
8/6/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2001. |
| Revenue Ruling 2001-34(PDF, 6K) |
7/9/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for July 2001. |
| Revenue Ruling 2001-33(PDF, 15K) |
8/6/2001 |
| Mutual life insurance companies; differential earnings rate. The differential earnings rate for 2000 and the recomputed differential earnings rate for 1999 are set forth for use by mutual life insurance companies to compute their income tax liabilities for 2000. |
| Revenue Ruling 2001-31(PDF, 7K) |
6/25/2001 |
| Captive insurance transactions. This ruling explains that the Service will no longer raise the "economic family theory," set forth in Rev. Rul. 77-316 (1977-2 C.B. 53), in addressing whether captive insurance transactions constitute valid insurance. Rather, the Service will address captive insurance transactions on a case-by-case basis. Rev. Ruls. 77-316, 78-277, 88-72, and 89-61 obsoleted. Rev. Ruls. 78-338, 80-120, 92-93, and 2000-3 modified. |
| Revenue Ruling 2001-30(PDF, 14K) |
7/16/2001 |
| Nondiscrimination; cross-testing. This ruling describes specific conditions that a defined contribution plan allocation must meet to be treated as a defined benefit replacement allocation under section 1.401(a)(4)-8(b) of the regulations. |
| Revenue Ruling 2001-29(PDF, 11K) |
6/25/2001 |
| REIT and section 355(b) active conduct of a trade or business. A REIT can be engaged in the active conduct of a trade or business within the meaning of section 355(b) of the Code solely by virtue of functions with respect to rental activity that produces income qualifying as rents from real property within the meaning of section 856(d) of the Code. Rev. Rul. 73-236 obsoleted. |
| Revenue Ruling 2001-27(PDF, 4K) |
6/4/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for June 2001. |
| Revenue Ruling 2001-25(PDF, 10K) |
5/29/2001 |
| Reverse triangular merger. A reverse triangular merger qualifies as a tax-free reorganization under sections 368(a)(1)(A) and 368(a)(2)(E) of the Code, notwithstanding that immediately after the merger, and as part of a plan that includes the merger, the surviving corporation sells a portion of its assets to an unrelated party for cash that it retains. |
| Revenue Ruling 2001-24(PDF, 15K) |
5/29/2001 |
| Forward triangular merger. A controlling corporation's transfer of the acquiring corporation's stock to another controlled subsidiary as part of the plan of reorganization, following the merger of the acquired corporation with and into the acquiring corporation, will not cause the transaction to fail to qualify as a reorganization under sections 368(a)(1)(A) and 368(a)(2)(D) of the Code. |
| Revenue Ruling 2001-22(PDF, 6K) |
5/7/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2001. |
| Revenue Ruling 2001-20(PDF, 12K) |
4/30/2001 |
| Qualified lessee construction allowances for short-term leases. The purpose requirement under section 1.110-1(b)(3) of the regulations does not require a lease agreement to provide that the entire construction allowance is for the purpose of constructing or improving qualified long-term real property. However, only the portion of the construction allowance actually expended on qualified long-term real property for use in the lessee's trade or business at the retail space may qualify as a qualified lessee construction allowance. |
| Revenue Ruling 2001-17(PDF, 6K) |
4/19/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for April 2001. |
| Revenue Ruling 2001-15(PDF, 26K) |
3/26/2001 |
| Election in respect of losses attributable to a disaster. This ruling lists the areas declared by the President to qualify as major disaster or emergency areas during 2000 under the Disaster Relief and Emergency Assistance Act. |
| Revenue Ruling 2001-12(PDF, 6K) |
3/12/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate; and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2001. |
| Revenue Ruling 2001-8(PDF, 30K) |
2/26/2001 |
| Inventories; floor stocks payments. Payments made or received with respect to floor stocks must be accounted for as adjustments to the invoice price or production cost of the goods physically held on the floor stocks date to which the payments relate, rather than as an adjustment to the tax basis (carrying value) of those goods. This ruling provides, for costing purposes, an optional simplifying assumption for LIFO taxpayers regarding identification of the goods physically held on the floor stocks date to which the floor stocks payments relate. Rev. Ruls. 85-30 and 88-95 clarified. Rev. Proc. 99-49 modified and amplified. |
| Revenue Ruling 2001-7(PDF, 6K) |
2/12/2001 |
| Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2001. |
| Revenue Ruling 2001-6(PDF, 12K) |
2/5/2001 |
| Deductibility of payments in redemption of stock held by an employee stock ownership plan (ESOP). Payments in redemption of stock held by an ESOP that are used to make distributions to terminating ESOP participants are not deductible and do not constitute (applicable dividends under section 404(k)(1) of the Code. |
| Revenue Ruling 2001-1(PDF, 5K) |
2/26/2001 |
| E & P adjustments on exercise of option. The earnings and profits of a corporate employer are reduced to reflect the deduction the corporation takes when an employee receives stock upon exercise of a nonstatutory stock option. |
