In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.The Bulletin is divided into four parts as follows: To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. This procedure provides a simplified alternate method for certain taxpayers to obtain an extension of time under section 301.9100-3 of the regulations to make an allocation of the generation-skipping transfer exemption in accordance with section 2642(b)(1) of the Code. Proposed regulations provide guidance for making the election under section 2632(c) of the Code to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption apply with regard to certain transfers to a GST trust.
On January 1, Year 3, S distributes all of the P indebtedness it holds to P.S, a domestic corporation, has only one class of stock outstanding, all of which is owned by P.On January 1, Year 2, S purchases all of the P indebtedness from A, an individual not related to S under § 1.108-2(d)(2), for cash in the amount of ,500,000.This document establishes an optional procedure for payors who make payments in the course of their trade or business through payment cards to determine whether the payments are reportable under sections 60A of the Code and the regulations thereunder.This procedure classifies businesses by Merchant Category Codes (MCCs), or other similar codes, according to whether they predominantly furnish services or predominantly provide goods.