Internal Revenue Bulletins  

November 9, 1992

Internal Revenue Bulletin No. 1992-45

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SPECIAL ANNOUNCEMENTS

Announcement 92-153
The Service has announced its decision to eliminate the Direct Deposit Indicator from the Acknowledgement process on the electronic returns Tax Filing Season '94. The decision was made to safeguard the growing electronic filing program from use for fraudulent purposes.

Announcement 92-154
A public hearing will be held on January 15, 1993, on proposed regulations relating to eligible rollover distributions from tax-qualified retirement plans and section 403(b) annuities.

Announcement 92-155
A public hearing will be held on November 23, 1992, on proposed regulations relating to the treatment of shareholders of certain passive foreign investment companies.

Announcement 92-156
The Fifth Annual Institute on Current Issues in International Taxation, cosponsored with The George Washington University, will be held December 14 and 15 at the J.W. Marriott Hotel in Washington, D.C.


INCOME TAX

Rev. Rul. 92-92
Discharge of indebtedness. Income from discharge of indebtedness is generally characterized as income from a passive activity for purposes of section 469 of the Code to the extent that, at the time the indebtedness is discharged, the debt is allocated to passive activity expenditures.

Rev. Rul. 92-93
Insurance subsidiary insuring its parent corporation's employees. Except for the cost of $50,000 of insurance coverage, each employee of a parent corporation must include in gross income under section 79 of the Code an amount equal to the cost of group-term life insurance on the employee's life purchased by the parent from its wholly owned insurance subsidiary. Parent may deduct the premiums paid to the insurance subsidiary for the group-term life insurance on an employee of the parent. Rev. Ruls. 77-316 and 88-72 distinguished.

Rev. Rul. 92-94
Nonlife insurance company insuring its own employees. A nonlife insurance company's gross premiums written on insurance contracts during the taxable year under section 832(b)(4) of the Code includes the amounts representing premiums that the company charges itself with respect to liability for insurance and annuity benefits for its employees.

Rev. Rul. 92-95
Penalty tax for annuities. For purposes of sections 72(q)(2)(I) and 72(u)(4) of the Code, the "date of purchase" of an annuity contract acquired in a section 1035 exchange for another annuity contract is the date of purchase of the annuity contract that was exchanged for the new annuity contract.

Rev. Rul. 92-96
Information reporting of commissions paid by state lotteries. Amounts retained by licensed lottery ticket sales agents from the sale proceeds of state lottery tickets are treated as commissions paid by the state lottery for purposes of information reporting under section 6041 of the Code.

T.D. 8443
EE-43-92

Temporary and proposed regulations under sections 401, 402, 403, and 3405 of the Code relate to eligible rollover distributions from tax-qualified retirement plans and section 403(b) annuities.

Notice 92-49
Countries that require participation in, or cooperation with, an international boycott are listed.


EMPLOYEE PLANS

Notice 92-48
Pursuant to section 521(d) of the Unemployment Compensation Amendments Act of 1992, the notice requirements of section 402(f) of the Code are revised to provide a safe harbor explanation of the rollover and tax treatment of an eligible rollover distribution. Notice 87-2 superseded.

Notice 92-50
Guidelines are set forth for determining for October 1992, the weighted average interest rate and the resulting permissible range of interest rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code as amended by the Omnibus Budget Reconciliation Act of 1987.


ADMINISTRATIVE

Notice 92-51
CO-5-90, 1990-2 C.B. 686, concerning returns relating to certain changes in corporate control or capital structure, is withdrawn.


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