Internal Revenue Bulletins  

August 31, 1992

Internal Revenue Bulletin No. 1992-35

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SPECIAL ANNOUNCEMENT

Announcement 92-119
A public hearing will be held on September 24, 1992, on proposed regulations relating to the allocation and apportionment of interest and other expenses within an affiliated group and the foreign tax credit limitation.


INCOME TAX

Rev. Rul. 92-65
Taxable year and tax rate of a personal service corporation. The portion of Rev. Rul. 91-30 that requires a corporation whose employees perform veterinary services to use the 34 percent corporate income tax rate pursuant to section 11(b)(2) of the Code will not be applied to taxable years beginning prior to May 13, 1991. A corporation whose employees perform veterinary services and is required to use a calendar year as its taxable year pursuant to section 441(i) will be permitted to defer any required change in taxable year under Rev. Rul. 91-30 until its first taxable year beginning after December 31, 1991. Rev. Rul. 91-30 modified.

T.D. 8423
Final regulations under section 509 and 512 of the Code relate to tax-exempt organizations' income from ordinary and routine investments.

T.D. 8424
Final regulations under section 79 of the Code relate to group term life insurance.


EMPLOYEE PLANS

Notice 92-36
The remedial amendment period under section 401(b) of the Code is extended until the end of the 1994 plan year, and generally, until the end of the 1996 plan year for plans maintained by tax-exempt organizations and governmental plans. Certain transition relief provided in Notice 91-38, including the availability of Alternative II D, is extended through the remedial amendment period. Notices 88-131, 89-23, 89-92, 90-73, 91-38 and Rev. Proc. 89-65 modified.


EXCISE TAXES

T.D. 8422
Final regulations under sections 4471 and 4472 of the Code relate to tax on transportation by water.

T.D. 8423
Final regulations under section 4940 of the Code relate to tax-exempt organizations' income from ordinary and routine investments.


ADMINISTRATIVE

Rev. Proc. 92-52A
Insurance companies; discounting estimated salvage recoverable. This procedure clarifies a sentence in Rev. Proc. 92-52, 1992-27 I.R.B. 22, to indicate that the tables in Rev. Proc. 92-52 are to be used only by taxpayers that discount salvage recoverable pursuant to Alternative 1 under section 4.04 of Rev. Proc. 91-48, 1991-2 C.B. 760. This procedure also corrects the discount factor for AY+4 in the Auto Liability table. Rev. Proc. 92-52 clarified.

Rev. Proc. 92-63
Waiver of section 911 time requirements. This procedure provides a current list of countries to which section 911(d)(4) of the Code applies.

Rev. Proc. 92-68
Puerto Rico and possessions tax credit; change of election. A possessions corporation is granted an extension of time to change its election from the cost sharing method to the profit split method or the method permitted under section 936(h)(1) to (h)(4). The period to change the method is extended to 120 days following the publication of final regulations under sections 1.482-2(d), (e) and (f) provided that taxpayer waives the statute of limitations for the section 936 corporation and its appropriate affiliates for a three-year period. Notices 87-27, 88-97, 89-82, and Rev. Procs. 89-61, 90-50, 91-53 modified.

Rev. Proc. 92-71
Proof of payment of an amount. An account statement prepared by a financial institution showing certain information may be used to prove payment of an amount by check, credit card, or electronic funds transfer for purposes of substantiating a deduction, credit, or basis.

Rev. Proc. 92-72
Insurance companies; discounting estimated salvage recoverable. Rev. Proc. 92-53, 1992-27 I.R.B. 24, prescribes the salvage discount factors for the 1992 accident year for each property and casualty line of business to be used in discounting estimated salvage recoverable as required by section 832(b)(5)(A) of the Code. An error was made in regrouping the data underlying three lines of business. This procedure corrects the discount factors for these lines of business. For administrative ease, correct discount factors are provided for all lines of business. Rev. Proc. 92-53 revoked.

Announcement 92-120
New Form 8275-R (July 1992), Regulation Disclosure Statement, and Form 8275 (Rev. July 1992), Disclosure Statement, are available from IRS Forms Distribution Centers.

Announcement 92-121
Application packages for the 1993 Tax Counseling for the Elderly (TCE) Program are available.


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