Internal Revenue Bulletin 1999-48 (PDF rendition): IRS Revenue Procedures

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INCOME TAX
T.D. 8841, page 593.
Final regulations under section 6031 of the Code relate to
the filing of partnership tax returns.
T.D. 8843, page 590.
Final regulations under section 6011(e) of the Code gener-
ally require partnerships with more than 100 partners to file
their partnership tax returns on magnetic media for tax
years ending on or after December 31, 2000. However,
electing large partnerships and partnerships using foreign
addresses on their series 1065 forms are not required to
file their returns on magnetic media for tax years ending be-
fore January 1, 2001.
EMPLOYEE PLANS
Rev. Rul. 99–47, page 588.
Covered compensation tables for 2000.The covered
compensation tables for the year 2000 used for determining
contributions to defined benefit plans and permitted dispar-
ity are set forth.
Rev. Proc. 99–44, page 598.
Insurance companies; annuity contracts.This procedure
sets forth conditions under which the Service will treat a con-
tract as an annuity contract described in sections 403(a),
403(b), or 408(b) of the Code, notwithstanding that contract
premiums are invested at the direction of the contract holder
in publicly available securities. Rev. Rul. 81–225 modified.
Internal Revenue
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Bulletin No. 1999–48
November 29, 1999
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.

The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly and may be obtained
from the Superintendent of Documents on a subscription
basis. Bulletin contents are consolidated semiannually into
Cumulative Bulletins, which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of in-
ternal management are not published; however, statements
of internal practices and procedures that affect the rights
and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings
to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature
are deleted to prevent unwarranted invasions of privacy and
to comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have
the force and effect of Treasury Department Regulations,
but they may be used as precedents. Unpublished rulings
will not be relied on, used, or cited as precedents by Service
personnel in the disposition of other cases. In applying pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions in other cases unless the facts and circumstances
are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions, and Subpart B, Legislation and Related
Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to
these subjects are contained in the other Parts and Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative Rulings. Bank Secrecy Act Administrative Rulings
are issued by the Department of the Treasury’s Office of the
Assistant Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The first Bulletin for each month includes a cumulative index
for the matters published during the preceding months.
These monthly indexes are cumulated on a semiannual basis,
and are published in the first Bulletin of the succeeding semi-
annual period, respectively.
The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
Introduction
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402.

INSERT PHOTO HERE

Section 61.—Gross Income
Defined
26 CFR 1.61–1: Gross income.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), and 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
Section 401.—Qualified
Pension, Profit-Sharing, and
Stock Bonus Plans
26 CFR 1.401(1)–1: Permitted disparity in
employer-provided contributions or benefits.
Covered compensation tables for
2000. The covered compensation tables
for the year 2000 used for determining
contributions to defined benefit plans and
permitted disparity are set forth.
Rev. Rul. 99–47
This revenue ruling provides tables of
covered compensation under § 401(l)-
(5)(E) of the Internal Revenue Code (the
“Code”) and the Income Tax Regulations,
thereunder, for the 2000 plan year.
Section 401(l)(5)(E)(i) defines covered
compensation with respect to an em-
ployee, as the average of the contribution
and benefit bases in effect under section
230 of the Social Security Act (the “Act”)
for each year in the 35-year period ending
with the year in which the employee at-
tains social security retirement age.
Section 401(l)(5)(E)(ii) of the Code
states that the determination for any year
preceding the year in which the employee
attains social security retirement age shall
be made by assuming that there is no in-
crease in covered compensation after the
determination year and before the em-
ployee attains social security retirement
age.
Section 1.401(l)–1(c)(34) defines the
taxable wage base as the contribution and
benefit base under section 230 of the Act.
Section 1.401(l)–1(c)(7)(i) defines cov-
ered compensation for an employee as the
average (without indexing) of the taxable
wage bases in effect for each calendar
year during the 35-year period ending
with the last day of the calendar year in
which the employee attains (or will attain)
social security retirement age. A 35-year
period is used for all individuals regard-
less of the year of birth of the individual.
In determining an employee’s covered
compensation for a plan year, the taxable
wage base for all calendar years begin-
ning after the first day of the plan year is
assumed to be the same as the taxable
wage base in effect as of the beginning of
the plan year. An employee’s covered
compensation for a plan year beginning
after the 35-year period applicable under
§1.401(l)–1(c)(7)(i) is the employee’s
covered compensation for a plan year dur-
ing which the 35-year period ends. An
employee’s covered compensation for a
plan year beginning before the 35-year
period applicable under §1.401(l)–
1(c)(7)(i) is the taxable wage base in ef-
fect as of the beginning of the plan year.
Section 1.401(l)–1(c)(7)(ii) provides
that, for purposes of determining the
amount of an employee’s covered com-
pensation under § 1.401(l)–1(c)(7)(i), a
plan may use tables, provided by the
Commissioner, that are developed by
rounding the actual amounts of covered
compensation for different years of birth.
For purposes of determining covered
compensation for the 2000 year the tax-
able wage base is $76,200.
The following tables provide covered
compensation for 2000:
November 29, 19995881999–48 I.R.B.
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986
2000 COVERED COMPENSATION TABLE
CALENDARCALENDAR YEAR OF
YEAR OFSOCIAL SECURITY2000 COVERED
BIRTHRETIREMENT AGECOMPENSATION
19071972$4,488
190819734,704
190919745,004
191019755,316
191119765,664
191219776,060
191319786,480
191419797,044
191519807,692
191619818,460
191719829,300
1918198310,236
1919198411,232
1920198512,276
1921198613,368
1922198714,520
1923198815,708
1924198916,968
1925199018,312

2000 COVERED COMPENSATION TABLE—Continued
CALENDARCALENDAR YEAR OF
YEAR OFSOCIAL SECURITY2000 COVERED
BIRTHRETIREMENT AGECOMPENSATION
1926199119,728
1927199221,192
1928199322,716
1929199424,312
1930199525,920
1931199627,576
1932199729,304
1933199831,128
1934199933,060
1935200035,100
1936200137,092
1937200239,072
1938200442,984
1939200544,940
1940200646,896
1941200748,816
1942200850,688
1943200952,488
1944201054,252
1945201155,992
1946201257,708
1947201359,376
1948201460,900
1949201562,340
1950201663,660
1951201764,920
1952201866,072
1953201967,164
1954202068,220
1955202270,116
1956202371,004
1957202471,820
1958202572,528
1959202673,176
1960202773,764
1961202874,304
1962202974,748
1963203075,180
1964203175,564
1965203275,864
1966203376,092
1967 or later203476,200
1999–48 I.R.B.589November 29, 1999

2000 Rounded Covered
Compensation Table
Covered
Year of BirthCompensation
1934$33,000
1935 – 193636,000
193739,000
193842,000
193945,000
1940 – 194148,000
1942 – 194351,000
194454,000
1945 – 194657,000
1947 – 194860,000
1949 – 195063,000
1951 – 195366,000
1954 – 195569,000
1956 – 195972,000
1960 – 196475,000
1965 or later76,200
The principal author of this revenue rul-
ing is Todd Newman of the Employee
Plans Division. For further information
regarding this revenue ruling, call (202)
622-6076 between 2:30 and 3:30 Eastern
time (not a toll free number) Monday thru
Thursday. Mr. Newman’s number is (202)
622-8458 (also not a toll free number).
Section 403.—Taxation of
Employee Annuities
26 CFR 1.403(a)–1: Taxability of beneficiary under
a qualified annuity plan.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), or 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
26 CFR 1.403(b)–1: Taxability of beneficiary under
annuity purchased by section 501(c)(3)
organization or public school.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), or 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
Section 408.—Individual
Retirement Accounts
26 CFR 1.408–1: General rules.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), or 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
Section 817.—Treatment of
Variable Contracts
26 CFR 1.817–5: Diversification requirements for
variable annuity, endowment, and life insurance
contracts.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), or 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
Section 818.—Other Definitions
and Special Rules
26 CFR 1.818–2: Accounting provisions.
The circumstances are set forth under which the
Internal Revenue Service will treat a contract as an
annuity contract described in sections 403(a),
403(b), or 408(b) of the Internal Revenue Code
notwithstanding that contract premiums are invested
at the direction of the contract holder in publicly
available securities. See Rev. Proc. 99–44, page 598.
Section 6011.—General
Requirement of Return,
Statement, or List
26 CFR 301.6011–3: Required use of magnetic
media for partnership returns.
T.D. 8843
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 301
Partnership Returns Required
on Magnetic Media
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations relating to the require-
ments for filing partnership returns on
magnetic media. These regulations re-
flect changes to the law made by the Tax-
payer Relief Act of 1997. These regula-
tions affect partnerships with more than
100 partners.
DATES: Effective Date:These regula-
tions are effective January 1, 2000.
Applicability Date:These regulations
apply to partnership returns for taxable
years ending on or after December 31,
2000. However, the regulations will not
apply to electing large partnership returns
under section 775 or partnership returns
with foreign addresses for taxable years
ending before January 1, 2001.
FOR FURTHER INFORMATION CON-
TACT: Bridget E. Finkenaur, (202) 622-
4940 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments to
the Regulations on Procedure and Admin-
istration (26 CFR part 301) relating to fil-
ing partnership returns on magnetic media
under section 6011(e)(2). In addition, this
document contains conforming amend-
ments to the Regulations on Procedure
and Administration (26 CFR part 301) re-
lating to information reporting penalties
under section 6721.
A notice of proposed rulemaking
(REG–102023–98, 1998–48 I.R.B. 6) was
published in the Federal Register(63
F.R. 56878) on October 23, 1998. The
public hearing scheduled for January 13,
1999, was canceled in the Federal Regis-
ter(64 F.R. 1148) on January 8, 1998.
No public hearing was requested or held.
Two written comments were received.
After consideration of the comments, the
proposed regulations are adopted as mod-
ified by this Treasury decision. The com-
ments are discussed below.
Explanation of Revisions and Summary
of Comments
Both commentators requested that the
IRS and the Treasury Department post-
November 29, 19995901999–48 I.R.B.

pone the effective date of the regulations.
The commentators were concerned that,
given the various manners and formats
that nominees use to submit partner infor-
mation to publicly traded partnerships,
these partnerships would be unable to cre-
ate computer programs that would refor-
mat the partner information in time to file
their 1999 tax returns on magnetic media.
In addition, partnerships required to file
their returns on magnetic media begin-
ning in 2000 will be focusing their com-
puter resources on ensuring that their
computer systems are year 2000 compli-
ant. The commentators suggested that the
effective date of the regulations be post-
poned to take into account these program-
ming considerations.
In considering these comments, the
IRS and the Treasury Department have
decided to postpone the general effective
date of the regulations for one year. This
will allow partnerships additional time to
develop systems that accommodate IRS
processing requirements and integrate
third party information while not interfer-
ing with efforts to ensure year 2000 com-
pliance. Therefore, the final regulations
are generally effective for taxable years
ending on or after December 31, 2000.
However, the effective date for electing
large partnerships and partnerships using
foreign addresses on their Series 1065
forms remains the same as the proposed
regulations. Accordingly, electing large
partnerships and partnerships using for-
eign addresses will not be required to file
their returns on magnetic media for tax-
able years ending before January 1, 2001.
Although the general effective date of
the regulations has been postponed, on
March 15, 2000, the IRS will begin ac-
cepting partnership returns for taxable
years ending on or after December 31,
1999, on magnetic media. The magnetic
media filing of partnership returns for tax-
able years ending before December 31,
2000, is voluntary; partnerships will not
be penalized for submitting a partnership
return on paper for taxable years ending
before this date. However, partnerships
with the capability of submitting their
partnership tax returns on magnetic media
are encouraged to do so.
Partnerships with 100 or fewer partners
also may voluntarily submit partnership
returns on magnetic media beginning on
March 15, 2000. These regulations do not
require partnerships with 100 or fewer
partners to file their returns on magnetic
media; therefore, such partnerships will
not be penalized for their failure to do so.
In addition, partnerships with 100 or
fewer partners participating in the mag-
netic media filing program may discon-
tinue their participation at any time.
One commentator suggested that the
IRS and the Treasury Department publish
regulations under section 6031(c) to re-
quire nominees holding partnership inter-
ests to submit partner information to part-
nerships in the same manner and format
that the IRS requires partnerships to file
their returns under §301.6011-3 of the
regulations. However, by postponing the
effective date, it is anticipated that part-
nerships and nominees will have adequate
time to establish satisfactory guidelines
for sharing information. Accordingly, this
comment has not been adopted by the
final regulations.
Finally, one commentator asked
whether fiscal year and short year returns
will be required to be filed on magnetic
media by the general effective date.
Again, because the IRS and the Treasury
Department have postponed the general
effective date for one year, it is anticipated
that partnerships will be able to meet the
systems requirements set forth in IRS rev-
enue procedures and other published guid-
ance by the effective date. However, due
to issues relating to creation of the system
for accepting returns on magnetic media,
the IRS will not be able to accept fiscal
and short year returns prior to the general
effective date. Therefore, partnerships
that use a fiscal year and partnerships that
must file a short year return may not vol-
untarily file their returns on magnetic
media before January 1, 2001.
As indicated in the preamble to the pro-
posed regulations, although the regulations
define magnetic media broadly, the Service
currently plans, in prescribed procedures
for participation in the mandatory mag-
netic media filing program, to require part-
nerships with more than 100 partners to
file their partnership returns electronically.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions, and because these regulations do
not impose a collection of information on
small entities, the Regulatory Flexibility
Act (5 U.S.C. chapter 6) does not apply.
Pursuant to section 7805(f) of the Internal
Revenue Code, the notice of proposed
rulemaking that preceded these regula-
tions was submitted to the Chief Counsel
for Advocacy of the Small Business Ad-
ministration for comment on its impact on
small business.
Drafting Information
The principal author of these regula-
tions is Bridget E. Finkenaur, Office of
the Assistant Chief Counsel (Income Tax
and Accounting). However, other person-
nel from the IRS and Treasury Depart-
ment participated in the development of
these regulations.
* * * * *
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 301 is
amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 301.6011–3 also issued under
26 U.S.C. 6011; * * *
Par. 2. Section 301.6011–3 is added to
read as follows:
§301.6011–3 Required use of magnetic
media for partnership returns.
(a) Partnership returns required on
magnetic media.If a partnership with
more than 100 partners is required to file
a partnership return pursuant to
§1.6031(a)–1 of this chapter, the informa-
tion required by the applicable forms and
schedules must be filed on magnetic
media, except as otherwise provided in
paragraph (b) of this section. Returns
filed on magnetic media must be made in
accordance with applicable revenue pro-
cedures or publications. In prescribing
1999–48 I.R.B.591November 29, 1999

revenue procedures or publications, the
Commissioner may determine that part-
nerships will be required to use any one
form of magnetic media filing. For exam-
ple, the Commissioner may determine
that partnerships with more than 100 part-
ners must file their partnership returns
electronically. In filing its return, a part-
nership must register to participate in the
magnetic media filing program in the
manner prescribed by the Internal Rev-
enue Service in applicable revenue proce-
dures or publications.
(b) Waiver.The Commissioner may
waive the requirements of this section if
hardship is shown in a request for waiver
filed in accordance with this paragraph
(b). A determination of hardship will be
based upon all of the facts and circum-
stances. One factor in determining hard-
ship will be the reasonableness of the in-
cremental cost to the partnership of
complying with the magnetic media filing
requirements. Other factors, such as
equipment breakdowns or destruction of
magnetic media filing equipment, also
may be considered. A request for waiver
must be made in accordance with applica-
ble revenue procedures or publications.
The waiver will specify the type of part-
nership return and the period to which it
applies. The waiver will also be subject
to such terms and conditions regarding
the method of filing as may be prescribed
by the Commissioner.
(c) Failure to file.If a partnership fails
to file a partnership return on magnetic
media in the manner required and when
required to do so by this section, the part-
nership will be deemed to have failed to
file the return in the manner prescribed
for purposes of the information return
penalty under section 6721. See
§301.6724–1(c)(3) for rules regarding the
waiver of penalties for undue economic
hardship relating to filing returns on mag-
netic media.
(d) Meaning of terms.The following
definitions apply for purposes of this sec-
tion:
(1) Magnetic media.The term mag-
netic media means any magnetic media
permitted under applicable regulations,
revenue procedures, or publications.
These generally include magnetic tape,
tape cartridge, and diskette, as well as
other media (such as electronic filing)
specifically permitted under the applica-
ble regulations, procedures, or publica-
tions.
(2) Partnership.The term partnership
means a partnership as defined in §1.761–
1(a) of this chapter.
(3) Partner.The term partnermeans a
member of a partnership as defined in
section 7701(a)(2).
(4) Partnership return.The term part-
nership return means a form in Series
1065 (including Form 1065, U.S. Partner-
ship Return of Income, and Form 1065-B,
U.S. Return of Income for Electing Large
Partnerships), along with the correspond-
ing Schedules K-1 and all other related
forms and schedules that are required to
be attached to the Series 1065 form.
(5) Partnerships with more than 100
partners.A partnership has more than
100 partners if, over the course of the
partnership’s taxable year, the partnership
had more than 100 partners, regardless of
whether a partner was a partner for the en-
tire year or whether the partnership had
over 100 partners on any particular day in
the year. For purposes of this paragraph
(d)(5), however, only those persons hav-
ing a direct interest in the partnership
must be considered partners for purposes
of determining the number of partners
during the partnership’s taxable year.
(e) Examples.The following examples
illustrate the provisions of paragraph
(d)(5) of this section. In the examples, the
partnerships utilize the calendar year, and
the taxable year in question is 2000:
Example 1.Partnership P had five general part-
ners and 90 limited partners on January 1, 2000. On
March 15, 2000, 10 more limited partners acquired
an interest in P. On September 29, 2000, the 10
newest partners sold their individual partnership in-
terests to C, a corporation which was one of the orig-
inal 90 limited partners. On December 31, 2000, P
had the same five general partners and 90 limited
partners it had on January 1, 2000. P had a total of
105 partners over the course of partnership taxable
year 2000. Therefore, P must file its 2000 partner-
ship return on magnetic media.
Example 2.Partnership Q is a general partner-
ship that had 95 partners on January 1, 2000. On
March 15, 2000, 10 partners sold their individual
partnership interests to corporation D, which was
not previously a partner in Q. On September 29,
2000, corporation D sold one-half of its partnership
interest in equal shares to five individuals, who were
not previously partners in Q. On December 31,
2000, Q had a total of 91 partners, and on no date in
the year did Q have more than 100 partners. Over
the course of the year, however, Q had 101 partners.
Therefore, Q must file its 2000 partnership return on
magnetic media.
Example 3.Partnership G is a general partnership
with 100 partners on January 1, 2000. There are no
new partners added to G in 2000. One of G’s part-
ners, A, is a partnership with 53 partners. A is one
partner, regardless of the number of partners A has.
Therefore, G has 100 partners and is not required to
file its 2000 partnership return on magnetic media.
(f) Effective date.In general, this sec-
tion applies to partnership returns for tax-
able years ending on or after December
31, 2000. However, electing large part-
nerships under section 775 and partner-
ships using foreign addresses on their Se-
ries 1065 forms are not required to file
using magnetic media for taxable years
ending before January 1, 2001.
Par. 3. Section 301.6721–1 is amended
by removing the third, fourth, and fifth
sentences of paragraph (a)(2)(ii) and
adding four sentences in their place to
read as follows:
§301.6721–1 Failure to file correct
information returns.
(a) * * *
(2) * * *
(ii) * * * However, no penalty is im-
posed under paragraph (a)(1) of this sec-
tion solely by reason of any failure to
comply with the requirements of section
6011(e)(2), except to the extent that such
a failure occurs with respect to more than
250 information returns (the 250-thresh-
old requirement) or in the case of a part-
nership with more than 100 partners,
more than 100 information returns (the
100-threshold requirement) (collectively,
the threshold requirements). Each Sched-
ule K-1 considered in applying the 100-
threshold requirement will be treated as a
separate information return. These
threshold requirements apply separately
to each type of information return re-
quired to be filed. Further, these thresh-
old requirements apply separately to orig-
inal and corrected returns. * * *
* * * * *
Robert E. Wenzel,
Deputy Commissioner of
Internal Revenue.
Approved October 29, 1999.
Joseph Mikrut,
Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on No-
vember 10, 1999, 8:45 a.m., and published in the
November 29, 19995921999–48 I.R.B.

issue of the Federal Register for November 12,
1999, 64 F.R. 61502)
Section 6031.—Return of
Partnership Income
26 CFR 1.6031(a)–1: Return of partnership income.
T.D. 8841
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Parts 1, 301, and 602
Return of Partnership Income
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations revising the partnership
filing requirement. These regulations re-
flect changes to the law made by the Tax-
payer Relief Act of 1997 (TRA). All part-
nerships required to file partnership
returns, including certain foreign partner-
ships, are affected by these regulations.
DATES: Effective Dates:These regula-
tions are effective January 1, 2000, except
that §1.6031(a)–1(b)(3) is effective Janu-
ary 1, 2001.
Applicability Dates:For dates of ap-
plicability, see §§1.6031(a)–1(f) and
1.6063–1(c)(2).
FOR FURTHER INFORMATION CON-
TACT: Concerning the regulations, Mar-
tin Schäffer, 202-622-3070; concerning
foreign partnerships, Guy A. Bracuti,
202-622-3860 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in these final regulations has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act of
1995 (44 U.S.C. 3507(d)) under control
number 1545-1583.
The collection of information in these
final regulations is in §1.6031(a)–1. This
information is required to enable the IRS
to verify that a taxpayer is reporting the
correct amount of income or gain or
claiming the correct amount of losses, de-
ductions, or credits from that taxpayer’s
interest in the partnership.
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless it dis-
plays a valid control number.
The burden is reflected in the burden
estimate of Form 1065.
Comments concerning the accuracy of
this burden estimate and suggestions for
reducing this burden should be sent to the
Internal Revenue Service,Attn: IRS Re-
ports Clearance Officer, T:FS:FP, Wash-
ington, DC 20224, and to the Office of
Management and Budget,Attn: Desk
Officer for the Department of the Trea-
sury, Office of Information and Regula-
tory Affairs, Washington, DC 20503.
Books or records relating to a collec-
tion of information must be retained as
long as their contents might become ma-
terial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. 6103.
Background
On January 26, 1998, the IRS and Trea-
sury published in the Federal Register
(63 F.R. 3677) proposed amendments to
the regulations (REG–209322–82,
1998–15 I.R.B. 26) under sections 6031
and 6063 of the Internal Revenue Code
(Code). These amendments were de-
signed, in part, to reflect changes made to
section 6031 of the Code by section 1141
of TRA, Public Law 105-34 (111 Stat.
788). Written comments responding to
these proposed regulations were received.
No public hearing was requested or held.
After consideration of all the comments,
the proposed regulations under sections
6031 and 6063 of the Code are adopted as
revised by this Treasury decision, and the
current final regulations under section
6031 of the Code are removed.
Explanation of Revisions and Summary
of Comments
A. General Filing Requirements for
Foreign Partnerships
Section 6031(a) of the Code requires
every partnership to file a partnership re-
turn. However, section 6031(e) of the
Code provides that a foreign partnership
is not required to file a return for a taxable
year unless during that year it derives
gross income from sources within the
United States (U.S.-source income) or has
gross income that is effectively connected
with the conduct of a trade or business
within the United States (ECI).
Consistent with section 6031(e) of the
Code, the proposed regulations generally
required a foreign partnership to file a re-
turn under section 6031 of the Code if it
had either U.S.-source income or ECI.
This general rule is adopted without
change in the final regulations.
B. Exceptions to General Filing
Requirements
Under the proposed regulations, a for-
eign partnership that had no ECI, and that
otherwise was required to file a partner-
ship return only because it had U.S.-
source income, was exempt from the re-
quirement to file a partnership return if (i)
no United States person had a direct or in-
direct interest in the partnership; (ii) the
U.S.-source income was either fixed or
determinable annual or periodical income
described in §1.1441–2(b) or other
amounts subject to withholding described
in §1.1441–2(c); (iii) Forms 1042 and
1042-S were filed with respect to all such
gross income by the partnership, or by an-
other withholding agent (or agents) if the
partnership was not required to file such
forms; and (iv) the tax liability of the part-
ners with respect to such gross income
was fully satisfied by the withholding of
tax at source. Most of the written com-
ments received with respect to the pro-
posed regulations requested that the IRS
and Treasury modify this proposed excep-
tion to the foreign partnership filing re-
quirement.
In response to these comments, the final
regulations liberalize the exceptions in
certain instances for foreign partnerships
that have U.S.-source income but no ECI.
The changes are designed to reduce du-
plicative filing requirements where other
information reporting and withholding re-
quirements provide adequate protection
for the tax system and to recognize that
where there is de minimis ownership in a
foreign partnership by U.S. partners, the
return filing requirements should not be
invoked merely because the partnership
earns any amount of U.S.-source income.
The final regulations contain three
rules that modify the reporting obligations
1999–48 I.R.B.593November 29, 1999

of certain foreign partnerships that have
no ECI. These modified reporting rules,
with the exception of the de minimis ex-
ception, are applicable for partnership
taxable years beginning after December
31, 2000, because they are dependent on
rules contained in §§1.1441–5(c) and
1.1461–1, which will be applicable only
after December 31, 2000. See Notice 99–
27 (1999–20 I.R.B. 75). The de minimis
exception, however, will be effective for
partnership taxable years beginning after
December 31, 1999, the general effective
date of these regulations.
The modified reporting rules contain
some common requirements. None of
these rules will apply to a withholding
foreign partnership (as defined in
§1.1441–5(c)(2)(i)). Also, with the ex-
ception of the de minimis rule, the modi-
fied reporting rules will apply only when
one or more withholding agents file the
required Forms 1042 and 1042-S and pay
the associated withholding tax.
The first modified reporting rule is the
de minimisexception. This rule provides
that a foreign partnership (other than a
withholding foreign partnership, as de-
fined in §1.1441–5(c)(2)(i)) with $20,000
or less of U.S.-source income and no ECI
is required to file a partnership return only
if one percent or more of any item of part-
nership gain, loss, deduction, or credit is
allocable in the aggregate to direct U.S.
partners.
The second modified reporting rule,
which also was contained in the proposed
regulations, provides that a foreign part-
nership with U.S.-source income but no
ECI and no U.S. partners is not required
to file a partnership return. Under the
third rule, a foreign partnership with U.S.-
source income and one or more U.S. part-
ners but no ECI must file a partnership re-
turn. However, such a partnership need
file Schedules K-1 only for its direct U.S.
partners and for its passthrough partners
through which U.S. partners hold an inter-
est in the foreign partnership.
The final regulations do not require a
foreign partnership to provide Schedules
K-1 for foreign partners deriving U.S.-
source income that is not ECI, because the
foreign partners are subject to information
reporting on Forms 1042-S under the rules
contained in §§1.1441–5(c) and 1.1461–1
of the regulations. These rules generally
subject the foreign partners, and not the
partnership, to an information reporting
regime with respect to U.S.-source income
(that is not ECI) paid to a foreign partner-
ship. To the extent that information re-
turns are not required for foreign partners
under section 1461 of the Code, the IRS
and Treasury have determined that report-
ing under section 6031 of the Code is un-
necessary as long as the foreign partner-
ship has no ECI. Accordingly, a foreign
partnership with no ECI need not report
on a Schedule K-1 a foreign partner’s allo-
cable share of items of income, including
U.S.-source gains that are not subject to
Form 1042-S reporting, deposit interest
under section 871(i) of the Code, and in-
terest or OID on short-term obligations
under section 871(g) of the Code.
In contrast to the rule for U.S.-source
income, the exception to Schedule K-1 re-
porting does not apply to a foreign part-
ner’s allocable share of ECI. Under the
information reporting rules in §§1.1441–
5(c)(1)(ii)(B) and 1.1461–1(c) of the regu-
lations, ECI must be reported to a foreign
partnership rather than to the foreign part-
ners directly. In addition, because ECI is
subject to tax on a net basis, a foreign part-
nership must provide a foreign partner’s
allocable share of other items of partner-
ship income, gain, loss, or deduction to
properly calculate the net taxable income.
Therefore, if a foreign partnership has
ECI, it must file a complete partnership re-
turn (with Schedules K-1 for all partners)
reflecting all items of partnership income,
gain, loss, deduction, and credit.
C. Partners That are Controlled Foreign
Corporations
One commentator suggested that a for-
eign partnership should not have to file
under section 6031 of the Code if it has no
direct U.S. partners and its only U.S.-
source income is bank deposit interest
under section 871(i) of the Code. The ex-
ception to the filing requirement in
§1.6031(a)–1(b)(2) of the proposed regu-
lations did not apply to foreign partner-
ships with direct or indirect U.S. partners.
Thus, according to the commentator, this
exception did not apply to a common,
nonabusive situation in which a con-
trolled foreign corporation (CFC) is a
partner in a foreign partnership whose
only U.S.-source income is interest
earned on a U.S. bank account. (Foreign
partners do not owe U.S. tax on this inter-
est income; see section 871(i) of the Code
and §1.1441–2(a) of the regulations (final
sentence). In addition, a U.S. person who
controls a CFC must report such income
on Form 5471; see §1.6038–2.)
The term indirect interest was not de-
fined in the proposed regulations. Thus,
whether a U.S. shareholder of a CFC part-
ner held an indirect interest in the foreign
partnership was not clear. These final
regulations define the term United States
partneras any U.S. person owning a di-
rect or indirect interest in the foreign part-
nership. An indirect interest is defined as
any interest held through one or more
passthrough partners (as defined in sec-
tion 6231(a)(9) of the Code). A pass-
through partner is a partnership, estate,
trust, S corporation, nominee, or other
similar person. Because a CFC is not a
passthrough partner, the U.S. shareholder
of a CFC has no indirect interest in the
foreign partnership under these final regu-
lations. Accordingly, a partnership with
no ECI need not file a return solely as a
result of having a CFC partner.
D. Responsibility to Ensure Filing of
Forms 1042 and 1042-S and Payment
of Associated Tax
As stated above, a foreign partnership
may avail itself of the modified filing re-
quirements in §1.6031(a)–1(b)(3) of these
regulations, for partnership taxable years
beginning after December 31, 2000, only
if it or another withholding agent actually
files the Forms 1042 and 1042-S and pays
the associated tax. A commentator sug-
gested that a foreign partnership with no
withholding responsibility should not
have the burden of ensuring that another
withholding agent has properly filed
Forms 1042-S in order to invoke the mod-
ified filing requirements.
Where a withholding agent fails to
withhold (and to file the requisite forms)
with respect to a partner in a foreign part-
nership, the Service might be unable to
assess and collect the proper tax without
information from a partnership return. A
partnership return provides the Service
with the name of the foreign partner and
the amount subject to withholding. Ac-
cordingly, these final regulations do not
adopt the comment.
While this comment is not adopted,
certain relief still may be available. Each
November 29, 19995941999–48 I.R.B.

person who has control, receipt, custody,
or payment of an amount subject to with-
holding is a withholding agent and is re-
sponsible for withholding tax and filing
Forms 1042 and 1042-S. Generally, a for-
eign partnership is a withholding agent
and must withhold tax and file the requi-
site forms. Under §1.1461–1(b) and (c),
one withholding agent among several
may be relieved of its responsibility to
withhold if another withholding agent
withholds tax and files the proper returns.
However, §1.1441–5(c)(3)(v) augments
this rule by deeming a foreign partnership
(other than a withholding foreign partner-
ship as defined in §1.1441–5(c)(2)(i)) to
have satisfied its withholding responsibil-
ities for an amount with respect to a part-
ner to the extent that the partner’s distrib-
utive share of the payment can be reliably
associated with a withholding certificate
described in §1.1441–5(c)(3)(iii) pertain-
ing to the partner that the partnership has
furnished to a withholding agent, and the
partnership does not know or has no rea-
son to know that the correct amount has
not been withheld. These final regula-
tions do not alter the result under
§1.1441–5(c)(3)(v). In addition, if a for-
eign partnership reasonably relies on a
modified filing requirement under these
regulations, but the modification is inap-
plicable because no party has satisfied
withholding responsibilities, the partner-
ship should be able to show that its failure
to file a partnership return was due to rea-
sonable cause for purposes of section
6698 of the Code if the foreign partner-
ship is deemed to have satisfied its with-
holding responsibilities under §1.1441–
5(c)(3)(v).
E. Partnership Level Elections under
Section 703 of the Code
A commentator suggested that an ab-
breviated return should be permitted
where a foreign partnership would be ex-
empt from the filing requirement but for a
partnership level election under section
703 of the Code. These final regulations
clarify that a return filed solely to make
an election under section 703 of the Code
need contain only information identifying
the partnership and the type of election.
In general, such a return is not considered
to be a return filed under section 6031(a)
of the Code. Therefore, a return filed
solely to make an election is not a partner-
ship return for purposes of section 6501
(regarding the statute of limitations) and
sections 6231(a)(1)(A) and 6233 (regard-
ing the partnership audit rules) of the
Code.
Section 1.6031(a)–1(b)(3)(ii) of the pro-
posed regulations provided that a return
filed by or for a foreign partnership to
make a section 703 election must be
signed by each partner who was a partner
at the time of election or by any partner
who was authorized (under local law or
the partnership’s organizational docu-
ments) to make the election and who rep-
resented having such authority under
penalties of perjury. A commentator sug-
gested that the signature requirement for
returns filed solely to make a partnership
level election should be restricted to part-
ners who are U.S. persons or are owned di-
rectly or indirectly by U.S. persons. These
final regulations do not adopt this com-
ment but maintain the signature require-
ment as proposed. Cf. §301.7701–3(c)(2)
setting forth the same signature require-
ment for entity classification elections.
F. Electing Out of Subchapter K under
Section 761 of the Code
A commentator suggested that the final
regulations should provide a default rule
under which a foreign partnership with no
direct U.S. partners that is eligible to elect
out of subchapter K of the Code would be
deemed to have elected exclusion. Under
§1.6031(a)–1(c)(2) of the proposed regu-
lations, a partnership that was deemed to
have elected exclusion from subchapter
K, as specified in §1.761–2(b)(2)(ii),
would be exempt from the partnership fil-
ing requirement. According to the com-
mentator, for joint ventures in which all
the direct owners are foreign, it is often
difficult to clearly demonstrate an inten-
tion to exclude the entity from U.S. part-
nership treatment, as required by the
section 761 regulations. To avoid incon-
sistency with the requirements for
deemed exclusion under section 761 of
the Code, these final regulations maintain
the rule as proposed.
Special Analyses
It has been determined that these regu-
lations are not a significant regulatory ac-
tion as defined in Executive Order 12866.
Therefore, a regulatory assessment is not
required. It also has been determined that
section 553(b) of the Administrative Pro-
cedure Act (5 U.S.C. chapter 5) does not
apply to these regulations. It is hereby
certified that the collection of information
contained in these regulations will not
have a significant economic impact on a
substantial number of small entities. This
certification is based on the fact that the
regulations would reduce (rather than in-
crease) the number of small entities that
are required to file a partnership return.
Specifically, the regulations eliminate the
filing requirements for certain foreign
partnerships that are fully subject to with-
holding in order to prevent duplicative fil-
ing requirements. In addition to eliminat-
ing the filing requirements in these
circumstances, for ease of reference, the
regulations update and restate the general
requirements to file a partnership return
as set forth in existing regulations. Be-
cause these regulations do not impose any
new reporting requirements that are not
imposed by the existing regulations, and
the only significant modification of the
existing regulations is to eliminate the fil-
ing requirement for certain foreign part-
nerships, the regulations will not have a
significant economic impact on a substan-
tial number of small entities. Accord-
ingly, a Regulatory Flexibility Analysis
under the Regulatory Flexibility Act (5
U.S.C. chapter 6) is not required. Pur-
suant to section 7805(f) of the Code, the
proposed regulations preceding these reg-
ulations were submitted to the Chief
Counsel for Advocacy of the Small Busi-
ness Administration for comment on its
impact on small business.
Drafting Information
The principal authors of these regula-
tions are Martin Schäffer, Office of Assis-
tant Chief Counsel (Passthroughs and
Special Industries), and Guy A. Bracuti,
Office of Associate Chief Counsel (Inter-
national). However, other personnel from
the IRS and Treasury Department partici-
pated in their development.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 1, 301, and
602 are amended as follows:
1999–48 I.R.B.595November 29, 1999

PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by adding an entry in
numerical order to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Section 1.6031(a)-1 also issued under
26 U.S.C. 6031. * * *
§1.6031–1 [Removed]
Par. 2. Section 1.6031–1 is removed.
Par. 3. Section 1.6031(a)–1 is added to
read as follows:
§1.6031(a)–1 Return of partnership
income.
(a) Domestic partnerships—(1) Return
required.Except as provided in para-
graphs (a)(3) and (c) of this section, every
domestic partnership must file a return of
partnership income under section 6031
(partnership return) for each taxable year
on the form prescribed for the partnership
return. The partnership return must be
filed for the taxable year of the partner-
ship regardless of the taxable years of the
partners. For taxable years of a partner-
ship and of a partner, see section 706 and
§1.706–1. For the rules governing part-
nership statements to partners and nomi-
nees, see §1.6031(b)–1T.
(2) Content of return. The partnership
return must contain the information re-
quired by the prescribed form and the ac-
companying instructions.
(3) Special rule.A partnership that has
no income, deductions, or credits for fed-
eral income tax purposes for a taxable
year is not required to file a partnership
return for that year.
(4) Failure to file.For the conse-
quences of a failure to comply with the re-
quirements of section 6031(a) and this
paragraph (a), see sections 6229(a),
6231(f), 6698, and 7203.
(b) Foreign partnerships—(1) General
rule.A foreign partnership is not required
to file a partnership return, if the foreign
partnership does not have gross income
that is (or is treated as) effectively con-
nected with the conduct of a trade or busi-
ness within the United States (ECI) and
does not have gross income (including
gains) derived from sources within the
United States (U.S.-source income). Ex-
cept as provided in paragraphs (b)(2) and
(3) of this section, a foreign partnership
that has ECI or has U.S.-source income
that is not ECI must file a partnership re-
turn for its taxable year in accordance
with the rules for domestic partnerships in
paragraph (a) of this section.
(2) Foreign partnerships with de min-
imis U.S.-source income and de minimis
U.S. partners.A foreign partnership
(other than a withholding foreign partner-
ship, as defined in §1.1441–5(c)(2)(i))
that has $20,000 or less of U.S.-source in-
come and has no ECI during its taxable
year is not required to file a partnership
return if, at no time during the partnership
taxable year, one percent or more of any
item of partnership income, gain, loss, de-
duction, or credit is allocable in the aggre-
gate to direct United States partners. The
United States partners must directly re-
port their shares of the allocable items of
partnership income, gain, loss, deduction,
and credit.
(3) Filing obligations for certain other
foreign partnerships with no ECI—(i)
General requirements for modified filing
obligations.A foreign partnership will be
subject to the modified filing obligations
in paragraphs (b)(3)(ii) and (iii) of this
section if, in addition to satisfying the re-
quirements contained in paragraph
(b)(3)(ii) and (iii) of this section—
(A) The partnership is not a withholding
foreign partnership as defined in
§1.1441–5(c)(2)(i);
(B) Forms 1042 and 1042-S are filed by
the partnership with respect to the
amounts subject to reporting under
§1.1461–1(b) and (c), unless the partner-
ship is not required to file such returns
under §1.1461–1(b)(2) and (c)(4), in
which case Forms 1042 and 1042-S must
be filed by another withholding agent or
agents; and
(C) The tax liability of the partners with
respect to such amounts has been fully sat-
isfied by the withholding of tax at the
source, if applicable, under chapter 3 of
the Internal Revenue Code.
(ii) Foreign partnerships with U.S.-
source income but no U.S. partners.A
foreign partnership that has U.S.-source
income is not required to file a partnership
return if the partnership has no ECI and no
United States partners at any time during
the partnership’s taxable year.
(iii) Foreign partnerships with U.S.-
source income and U.S. partners. Except
as provided in paragraph (b)(2) of this sec-
tion, a foreign partnership with one or
more United States partners that has U.S.-
source income but no ECI must file a part-
nership return. However, such a foreign
partnership need not file Statements of
Partner’s Share of Income, Credit, Deduc-
tion, Etc. (Schedules K-1) for any partners
other than its direct United States partners
and its passthrough partners (whether U.S.
or foreign) through which United States
partners hold an interest in the foreign
partnership. Schedules K-1 that are not
excepted from filing under this paragraph
(b)(3)(iii) must contain the same informa-
tion required of a domestic partnership fil-
ing under paragraph (a) of this section.
(4) Information or returns required of
partners who are United States persons—
(i) In general.If a United States person is
a partner in a partnership that is not re-
quired to file a partnership return, the dis-
trict director or director of the relevant ser-
vice center may require that person to
render the statements or provide the infor-
mation necessary to verify the accuracy of
the reporting by that person of any items
of partnership income, gain, loss, deduc-
tion, or credit.
(ii) Controlled foreign partnerships.
Certain United States persons who are
partners in a foreign partnership con-
trolled (within the meaning of section
6038(e)(1)) by United States persons may
be required to provide information with
respect to the partnership under section
6038.
(5) Certain partnership elections. For
a partnership that is not otherwise re-
quired to file a partnership return, if an
election that can only be made by the
partnership under section 703 (affecting
the computation of taxable income de-
rived from a partnership) is to be made by
or for the partnership, a return on the form
prescribed for the partnership return must
be filed for the partnership. Unless other-
wise provided in the form or the accom-
panying instructions, a return filed solely
to make an election need only contain a
written statement citing paragraph
(b)(5)(ii) of this section, listing the name
and address of the partnership making the
election, and clearly identifying the spe-
cific election being made. A return filed
under paragraph (b)(5)(ii) of this section
solely to make an election is not a partner-
ship return. Thus, such a return is not a
return filed under section 6031(a) for pur-
November 29, 19995961999–48 I.R.B.

poses of sections 6501 (except regarding
the specific election issue), 6231(a)-
(1)(A), and 6233. The return must be
signed by—
(i) Each partner that is a partner in the
partnership at the time the election is
made; or
(ii) Any partner of the partnership who
is authorized (under local law or the part-
nership’s organizational documents) to
make the election and who represents to
having such authorization under penalties
of perjury.
(6) Exclusion for certain organizations.
The return requirement of section 6031
and this section does not apply to the In-
ternational Telecommunications Satellite
Organization, the International Maritime
Satellite Organization, or any organiza-
tion that is a successor of either.
(c) Partnerships excluded from the ap-
plication of subchapter K of the Internal
Revenue Code—(1) Wholly excluded—(i)
Year of election.An eligible partnership
as described in §1.761-2(a) that elects to
be excluded from all the provisions of
subchapter K of chapter 1 of the Internal
Revenue Code in the manner specified by
§1.761–2(b)(2)(i) must timely file the
form prescribed for the partnership return
for the taxable year for which the election
is made. In lieu of the information other-
wise required, the return must contain or
be accompanied by the information re-
quired by §1.761–2(b)(2)(i).
(ii) Subsequent years.Except as other-
wise provided in paragraph (c)(1)(i) of
this section, an eligible partnership that
elects to be wholly excluded from the ap-
plication of subchapter K is not required
to file a partnership return.
(2) Deemed excluded.An eligible part-
nership that is deemed to have elected ex-
clusion from the application of subchapter
K beginning with its first taxable year, as
specified in §1.761–2(b)(2)(ii), is not re-
quired to file a partnership return.
(d) Definitions—(1) Partnership. For
the meaning of the term partnership, see
§1.761–1(a).
(2) United States person.In applying
this section, a United States person is a
person described in section 7701(a)(30);
the government of the United States, a
State, or the District of Columbia (includ-
ing an agency or instrumentality thereof);
or a corporation created or organized in
Guam, the Commonwealth of Northern
Mariana Islands, the U.S. Virgin Islands,
and American Samoa, if the requirements
of section 881(b)(1)(A), (B), and (C) are
met for such corporation. The term does
not include an alien individual who is a
resident of Puerto Rico, Guam, the Com-
monwealth of Northern Mariana Islands,
the U.S. Virgin Islands, or American
Samoa, as determined under
§301.7701(b)–1(d) of this chapter.
(3) United States partner.In applying
this section, a United States partner is any
United States person who holds a direct or
indirect interest in the partnership.
(4) Indirect interest. An indirect inter-
est is any interest held through one or
more passthrough partners, as defined in
section 6231(a)(9).
(e) Procedural requirements—(1)
Place for filing.The return of a partner-
ship must be filed with the service center
prescribed in the relevant IRS revenue
procedure, publication, form, or instruc-
tions to the form (see §601.601(d)(2)).
(2) Time for filing.The return of a part-
nership must be filed on or before the fif-
teenth day of the fourth month following
the close of the taxable year of the part-
nership.
(3) Magnetic media filing.For mag-
netic media filing requirements with re-
spect to partnerships, see section
6011(e)(2) and the regulations thereunder.
(f) Effective dates. This section applies
to taxable years of a partnership begin-
ning after December 31, 1999, except that
paragraph (b)(3) of this section applies to
taxable years of a foreign partnership be-
ginning after December 31, 2000.
Par. 4. Section 1.6063–1 is amended
by adding paragraph (c) to read as fol-
lows:
§1.6063–1 Signing of returns,
statements, and other documents made by
partnerships.
* * * * *
(c) Certain partnership elections—(1)
In general.For rules regarding the au-
thority of a partner to sign a partnership
return filed solely for the purpose of mak-
ing certain partnership-level elections, see
§1.6031(a)–1(b)(5)(ii).
(2) Effective date.Paragraph (c) of this
section applies to taxable years of a part-
nership beginning after December 31,
1999.
PART 301—PROCEDURE AND
ADMINISTRATION
Par. 5. The authority citation for part
301 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
§301.6031–1 [Removed]
Par. 6. Section 301.6031–1 is removed.
Par. 7. Section 301.6031(a)–1 is added
to read as follows:
§301.6031(a)–1 Return of partnership
income.
For provisions relating to the require-
ment of returns of partnership income, see
§1.6031(a)–1 of this chapter.
PART 602—OMB CONTROL
NUMBERS UNDER THE
PAPERWORK REDUCTION ACT
Par. 8. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 9. In §602.101, paragraph (b) is
amended by removing the entry “1.6031–
1” from the table and adding the entry
“1.6031(a)–1 . . . . 1545–1583” in numer-
ical order to the table to read as follows:
§602.101 OMB Control numbers.
* * * * *
(b) * * *
CFR part or sectionCurrent OMB
where identifiedcontrol No.
and described
* * * * *
1.6031(a)–1 . . . . . . . . . . . . . 1545–1583
* * * * *
Robert E. Wenzel,
Deputy Commissioner
of Internal Revenue.
Approved October 29, 1999.
Jonathan Talisman,
Acting Assistant Secretary
of the Treasury.
(Filed by the Office of the Federal Register on No-
vember 10, 1999, 8:45 a.m., and published in the
issue of the Federal Register for November 12,
1999, 64 F.R. 61498)
1999–48 I.R.B.597November 29, 1999

26 CFR 601.201: Rulings and determination letters.
(Also sections 61, 403(a), 403(b), 408(b), 817(h),
818(a); 1.61–1, 1.403(a)–1, 1.403(b)–1, 1.408–1,
1.817–5, 1.818–2)
Rev. Proc. 99–44
SECTION 1. PURPOSE
This revenue procedure sets forth the
circumstances under which the Internal
Revenue Service will treat a contract as
an annuity contract described in
§§ 403(a), 403(b) or 408(b) of the Internal
Revenue Code (“Code”) notwithstanding
that contract premiums are invested at the
direction of the contract holder in publicly
available securities.
SECTION 2. BACKGROUND
Rev. Rul. 77–85, 1977–1 C.B. 12, con-
cludes that if a contract holder retains
control over the assets in a custodial ac-
count associated with a purported “annu-
ity” contract, then the contract holder is
the owner of those assets for federal in-
come tax purposes. The contract holder’s
gross income, therefore, includes any in-
terest, dividends, and other income gener-
ated by those assets. In the ruling, the
contract holder’s control over the assets in
the custodial account is manifested by the
ability to direct the custodian: (1) to in-
vest amounts in the account in any of an
approved list of investments, and (2) to
sell, purchase, or exchange securities or
other assets held in the account. Through
the interaction of the custodial agreement
and the annuity contract, the contract
holder enjoys any increase or suffers any
decrease in the value of the assets in the
account as well as any income from the
assets. The contract holder also has the
right to vote account securities either
through the custodian or personally. Rev.
Rul. 77–85 generally applies to contracts
entered into after March 9, 1977.
In Rev. Rul. 80–274, 1980–2 C.B. 27,
an insurance company and a savings and
loan association enter into a group annu-
ity contract under which the association’s
depositors are issued annuity certificates.
The certificate holders’ premiums (net of
sales and other expenses) are invested in
certificates of deposit issued by the sav-
ings and loan association, with maturity
dates designated by the certificate hold-
ers. When a certificate of deposit ma-
tures, the proceeds generally are invested
in another certificate of deposit with the
savings and loan association. Prior to the
annuity starting date, a holder of an annu-
ity certificate can withdraw part or all of
his or her investment (including the in-
vestment income thereon) by partially or
completely surrendering the certificate.
Due to fees imposed by the insurance
company, annuity certificate holders re-
ceive a lower rate of return than if they
were to invest directly in the certificates
of deposit. The ruling concludes, how-
ever, that, prior to the annuity starting
date, the position of holders of the annuity
certificates is substantially identical to
what their position would have been if in-
vestments were directly maintained or es-
tablished with the savings and loan asso-
ciation, with the insurance company
acting merely as a conduit.
Rev. Rul. 81–225, 1981–2 C.B. 12, an-
alyzes five situations involving purported
variable “annuity” contracts. In four of
the situations, the ruling concludes that
the contracts are not annuity contracts de-
scribed in §§ 403(a), 403(b), or 408(b)
and that prior to the annuity starting date
the contract holders are the owners of the
assets held by the insurance company
with regard to the contracts. In these situ-
ations, the insurance company holds
shares of mutual funds that are directly or
indirectly available to the public. In the
fifth situation, the contract holder can in-
vest only in a non-publicly-available mu-
tual fund managed by the insurance com-
pany or one of its affiliates. The shares in
that mutual fund are available only
through the purchase of an annuity con-
tract. In this situation, the ruling con-
cludes that the insurance company is
treated as the owner of the mutual fund
shares held by the company for the con-
tracts. Rev. Rul. 80–274 did not address
the treatment of contracts described in
§§ 403(a), 403(b) or 408(b). For that rea-
son, Rev. Rul. 81–225 contains a special
transition rule for such contracts. This
rule provides that any contract entered
into on or before September 25, 1981, is
treated as an annuity contract if the
arrangement would have met the require-
ments imposed by those sections without
taking the holding or rationale of Rev.
Rul. 81–225 into account, and no contri-
butions are made on behalf of any indi-
vidual who was not included under the
contract on or before September 25, 1981.
In Rev. Rul. 82–54, 1982–1 C.B. 11, a
variable annuity contract holder can direct
that the consideration paid for the con-
tracts be invested in any or all of three
non-publicly-available mutual funds man-
aged by the insurance company. Each of
the funds has a different general invest-
ment strategy. One fund invests primarily
in common stocks, another in bonds, and
the third in money market instruments. A
contract holder is free to allocate pay-
ments among the three funds and to real-
locate account values among the three
funds at any time before the annuity start-
ing date. The ruling concludes that the
contract holder’s ability to choose among
broad general investment strategies, ei-
ther at the time of the initial purchase of
the annuity contract or subsequent
thereto, does not constitute sufficient con-
trol over individual investment decisions
so as to cause the contract holder to be the
owner of the mutual fund shares.
Rev. Rul. 82–55, 1982–1 C.B. 12, clari-
fies that, if an annuity contract holder’s
premiums are invested in a separate ac-
count that holds mutual fund shares and
the mutual fund’s shares were originally
available to the public but are unavailable
to the public when the contract holder’s
premiums are invested, then the contract
holder is not treated as the owner of the
mutual fund shares.
In Christofferson v. United States,749
F.2d 513 (8th Cir. 1984), an individual
purchased a purported deferred “annuity”
contract that permitted the contract holder
to allocate the consideration paid for the
contract among various mutual funds.
The contract holder could reallocate funds
among the mutual funds at any time, and
could withdraw part or all of the funds
with seven days notice. The contract also
gave the contract holder an option to pur-
chase an immediate life annuity at guar-
anteed rates. The contract holder did not
have to exercise the option. The court
found that the contract holder had surren-
dered few of the rights of ownership or
control over the assets, and therefore con-
November 29, 19995981999–48 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous

cluded that the contract holder was the
owner of the mutual fund shares for tax
purposes. As the contract holder could
surrender the contract for cash prior to an-
nuitization, the possibility that the mutual
fund shares could be converted into an
immediate annuity at rates guaranteed in
the contract did not cause the contract
holder to lack ownership or control.
Section 817(h) of the Internal Revenue
Code was added by §211(a) of the Tax
Reform Act of 1984, 1984–3 (Vol. 1) C.B.
259–60, effective for taxable years begin-
ning after December 31, 1983. Section
817(h) provides that a variable contract
(other than a pension plan contract de-
scribed in § 818(a)) is not treated as a life
insurance, endowment, or annuity con-
tract if the investments of a segregated
asset account upon which the contract is
based are not adequately diversified in ac-
cordance with regulations prescribed by
the Secretary. Pension plan contracts de-
scribed in § 818(a) are subject to a variety
of statutory limits, including limits on an-
nual contributions, that do not apply to
other variable contracts.
The legislative history explains the pur-
pose underlying the § 817(h) diversifica-
tion requirement as follows:
In authorizing Treasury to prescribe
diversification standards, the confer-
ees intend that standards be designed
to deny annuity or life insurance
treatment for investments that are
publicly available to investors and
investments that are made, in effect,
at the direction of the investor.
H.R. Conf. Rep. No. 861, 98th Cong., 2d
Sess. 1055, 1984–3 (Vol. 2) C.B. 309.
Section 1.817–5 of the Income Tax
Regulations provides guidance related to
the minimum level of diversification ap-
plicable to the investments underlying
variable annuity and life insurance con-
tracts. Satisfying the diversification re-
quirements, however, does not prevent a
contract holder’s control of the invest-
ments of a segregated asset account from
causing the contract holder, rather than
the insurance company, to be treated as
the owner of the assets in the account.
SECTION 3. SCOPE
This revenue procedure applies to a
contract that otherwise would qualify as
an annuity contract for purposes of
§§ 403(a) or 403(b), or as an individual re-
tirement annuity for purposes of § 408(b),
but for the fact that contract premiums are
invested at the direction of the contract
holder in publicly available securities.
SECTION 4. APPLICATION
Notwithstanding that contract premi-
ums are invested at the contract holder’s
direction in publicly available securities,
the Service will treat a contract described
in section 3 of this revenue procedure as
an annuity contract and will not treat the
contract holder as owning the assets asso-
ciated with the contract, provided the fol-
lowing conditions are met:
1. For a contract that is intended to
qualify as an annuity contract for pur-
poses of §§ 403(a) or 403(b), no addi-
tional federal tax liability would have
been incurred if the employer of the con-
tract holder had instead paid an amount
into a trust or a custodial account in an ar-
rangement that satisfied the requirements
of §§ 401(a) or 403(b)(7)(A), respec-
tively; or
2. For a contract that is intended to
qualify as an individual retirement annu-
ity for purposes of § 408(b), no additional
federal tax liability would have been in-
curred if consideration for the contract
had instead been held as part of a trust
that would satisfy the requirements of
§ 408(a), except that the general account
of an insurance company shall be treated
as a common investment fund for pur-
poses of satisfying § 408(a)(5).
EFFECTIVE DATE
This revenue procedure is effective on
November 16,1999, with respect to all
taxable years.
Under the authority of § 7805(b) of the
Code, this revenue procedure will not be
applied adversely to an issuer or holder of
a contract issued before November 16,
1999.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 81–225 is modified.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Katherine Hossofsky of the
Office of Assistant Chief Counsel (Finan-
cial Institutions & Products). For further
information regarding this revenue proce-
dure, contract Ms. Hossofsky on (202)
622-3477 (not a toll-free call).
1999–48 I.R.B.599November 29, 1999

November 29, 1999i1999–48 I.R.B.
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds
that the same principle also applies to B,
the earlier ruling is amplified. (Compare
with modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial difference between them.
Modified is used where the substance
of a previously published position is
being changed. Thus, if a prior ruling
held that a principle applied to A but not
to B, and the new ruling holds that it ap-
plies to both A and B, the prior ruling is
modified because it corrects a published
position. (Compare with amplified and
clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used
in a ruling that lists previously published
rulings that are obsoleted because of
changes in law or regulations. A ruling
may also be obsoleted because the sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing is not correct and the correct position
is being stated in the new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the
new ruling does more than restate the
substance of a prior ruling, a combination
of terms is used. For example, modified
and superseded describes a situation
where the substance of a previously pub-
lished ruling is being changed in part and
is continued without change in part and it
is desired to restate the valid portion of
the previously published ruling in a new
ruling that is self contained. In this case
the previously published ruling is first
modified and then, as modified, is super-
seded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and
that list is expanded by adding further
names in subsequent rulings. After the
original ruling has been supplemented
several times, a new ruling may be pub-
lished that includes the list in the original
ruling and the additions, and supersedes
all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current use and for-
merly used will appear in material published in the
Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C.—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contribution Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign Corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statements of Procedral Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Definition of Terms

1999–48 I.R.B.iiNovember 29, 1999
Numerical Finding List
1
Bulletins 1999–27 through 1999–47
Announcements:
99–47, 1999–28 I.R.B. 29
99–64, 1999–27 I.R.B.7
99–65, 1999–27 I.R.B. 9
99–66, 1999–27 I.R.B. 9
99–67, 1999–28 I.R.B. 31
99–68, 1999–28 I.R.B. 31
99–69, 1999–28 I.R.B. 33
99–70, 1999–29 I.R.B. 118
99–71, 1999–31 I.R.B. 223
99–72, 1999–30 I.R.B. 132
99–73, 1999–30 I.R.B. 133
99–74, 1999–30 I.R.B. 133
99–75, 1999–30 I.R.B. 134
99–76, 1999–31 I.R.B. 223
99–77, 1999–32 I.R.B. 243
99–78, 1999–31 I.R.B. 229
99–79, 1999–31 I.R.B. 229
99–80, 1999–34 I.R.B. 310
99–81, 1999–32 I.R.B. 244
99–82, 1999–32 I.R.B. 244
99–83, 1999–32 I.R.B. 245
99–84, 1999–33 I.R.B. 248
99–85, 1999–33 I.R.B. 248
99–86, 1999–35 I.R.B. 332
99–87, 1999–35 I.R.B. 333
99–88, 1999–36 I.R.B. 407
99–89, 1999–36 I.R.B. 408
99–90, 1999–36 I.R.B. 409
99–91, 1999–37 I.R.B. 421
99–92, 1999–38 I.R.B. 433
99–93, 1999–36 I.R.B. 409
99–94, 1999–39 I.R.B. 437
99–95, 1999–42 I.R.B. 520
99–96, 1999–41 I.R.B. 504
99–97, 1999–41 I.R.B.505
99–98, 1999–42 I.R.B. 520
99–99, 1999–42 I.R.B. 522
99–100, 1999–42 I.R.B. 522
99–101, 1999–43 I.R.B. 544
99–102, 1999–43 I.R.B. 545
99–103, 1999–43 I.R.B. 546
99–104, 1999–44 I.R.B. 555
99–105, 1999–44 I.R.B. 555
99–106, 1999–45 I.R.B. 561
99–107, 1999–45 I.R.B. 561
99–108, 1999–46 I.R.B. 573
99–109, 1999–46 I.R.B. 573
99–110, 1999–46 I.R.B. 574
99–111, 1999–47 I.R.B. 587
Notices:
99–34, 1999–35 I.R.B. 323
99–35, 1999–28 I.R.B.26
99–37, 1999–30 I.R.B. 124
99–38, 1999–31 I.R.B. 138
99–39, 1999–34 I.R.B.313
99–40, 1999–35 I.R.B. 324
99–41, 1999–35 I.R.B. 325
99–42, 1999–35 I.R.B. 325
99–43, 1999–36 I.R.B. 344
99–44, 1999–35 I.R.B. 326
99–45, 1999–37 I.R.B. 415
99–46, 1999–37 I.R.B. 415
99–47, 1999–36 I.R.B. 391
Notices—Continued
99–48, 1999–38 I.R.B. 429
99–49, 1999–39 I.R.B. 436
99–50, 1999–40 I.R.B. 444
99–51, 1999–40 I.R.B. 447
99–52, 1999–43 I.R.B. 525
99–53, 1999–46 I.R.B.565
99–54, 1999–47 I.R.B.579
Proposed Regulations:
REG–252487–96, 1999–34 I.R.B. 303
REG–101519–97, 1999–29 I.R.B. 114
REG–107069–97, 1999–36 I.R.B. 346
REG–121063–97, 1999–43 I.R.B. 540
REG–106010–98, 1999–40 I.R.B. 493
REG–106527–98, 1999–34 I.R.B. 304
REG–108287–98, 1999–28 I.R.B.27
REG–113526–98, 1999–37 I.R.B. 417
REG–113909–98, 1999–30 I.R.B. 125
REG–116733–98, 1999–36 I.R.B. 392
REG–116991–98, 1999–32 I.R.B. 242
REG–121946–98, 1999–36 I.R.B. 403
REG–105237–99, 1999–35 I.R.B. 331
REG–105327–99, 1999–29 I.R.B. 117
REG–105565–99, 1999–37 I.R.B. 419
REG–115932–99, 1999–47 I.R.B. 583
REG–116125–99, 1999–44 I.R.B. 552
Railroad Retirement Quarterly Rate:
1999–45 I.R.B. 560
1999–46 I.R.B.563
Revenue Procedures:
99–28, 1999–29 I.R.B.109
99–29, 1999–31 I.R.B. 138
99–30, 1999–31 I.R.B. 221
99–31, 1999–34 I.R.B. 280
99–32, 1999–34 I.R.B. 296
99–33, 1999–34 I.R.B. 301
99–34, 1999–40 I.R.B. 450
99–35, 1999–41 I.R.B. 501
99–36, 1999–42 I.R.B. 509
99–37, 1999–42 I.R.B. 517
99–38, 1999–43 I.R.B. 525
99–39, 1999–43 I.R.B. 532
99–40, 1999–46 I.R.B. 565
99–41, 1999–46 I.R.B. 566
99–42, 1999–46 I.R.B. 568
99–43, 1999–47 I.R.B.579
Revenue Rulings:
99–29, 1999–27 I.R.B.3
99–30, 1999–28 I.R.B. 24
99–31, 1999–37 I.R.B. 410
99–32, 1999–31 I.R.B. 135
99–33, 1999–34 I.R.B. 251
99–34, 1999–33 I.R.B. 247
99–35, 1999–34 I.R.B. 278
99–36, 1999–35 I.R.B. 319
99–37, 1999–36 I.R.B. 336
99–38, 1999–36 I.R.B. 335
99–39, 1999–38 I.R.B. 424
99–40, 1999–40 I.R.B. 441
99–41, 1999–40 I.R.B. 439
99–42, 1999–41 I.R.B. 497
99–43, 1999–42 I.R.B. 506
99–44, 1999–44 I.R.B. 549
99–45, 1999–45 I.R.B. 558
Revenue Rulings—Continued
99–46, 1999–45 I.R.B. 557
Treasury Decisions:
8822, 1999–27 I.R.B.5
8823, 1999–29 I.R.B. 34
8824, 1999–29 I.R.B. 62
8825, 1999–28 I.R.B. 19
8826, 1999–29 I.R.B. 107
8827, 1999–30 I.R.B.120
8828, 1999–30 I.R.B.120
8829, 1999–32 I.R.B.235
8830, 1999–38 I.R.B. 430
8831, 1999–34 I.R.B.264
8832, 1999–35 I.R.B. 315
8833, 1999–36 I.R.B. 338
8834, 1999–34 I.R.B.251
8835, 1999–35 I.R.B.317
8836, 1999–37 I.R.B. 411
8837, 1999–38 I.R.B. 426
8838, 1999–38 I.R.B. 424
8839, 1999–41 I.R.B. 498
8840, 1999–47 I.R.B. 575
8842, 1999–47 I.R.B. 576
1
A cumulative list of all revenue rulings, revenue
procedures, Treasury decisions, etc., published in
Internal Revenue Bulletins 1999–1 through 1999–26
is in Internal Revenue Bulletin 1999–27, dated July
6, 1999.

November 29, 1999iii1999–48 I.R.B.
Finding List of Current Action on
Previously Published Items
1
Bulletins 1999–27 through 1999–47
Announcements:
99–5
Modified by
Ann. 99–106, 1999–45 I.R.B. 561
99–57
Modified by
Ann. 99–104, 1999–44 I.R.B. 555
99–59
Corrected by
Ann. 99–67, 1999–28 I.R.B. 31
Notices:
83–10
Modified by
Notice 99–44, 1999–35 I.R.B. 326
96–64
Modified by
Notice 99–40, 1999–35 I.R.B. 324
97–26
Modified by
Notice 99–41, 1999–35 I.R.B. 325
97–50
Modified and superseded by
Notice 99–41, 1999–35 I.R.B. 325
97–73
Modified by
Notice 99–37, 1999–30 I.R.B. 124
98–7
Modified by
Notice 99–37, 1999–30 I.R.B. 124
98–46
Modified by
Notice 99–37, 1999–30 I.R.B. 124
98–47
Modified and superseded by
Notice 99–41, 1999–35 I.R.B. 325
98–54
Modified by
Notice 99–37, 1999–30 I.R.B. 124
98–59
Modified by
Notice 99–37, 1999–30 I.R.B. 124
Proposed Regulations:
REG–208156–91
Corrected by
Ann. 99–65, 1999–27 I.R.B. 9
Revenue Procedures:
65–17
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
65–31
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
70–23
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
Revenue Procedures—Continued
71–35
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
72–22
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
72–46
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
72–48
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
72–53
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
89–48
Obsoleted (after Jan. 31, 2000) by
Notice 99–42, 1999–35 I.R.B. 325
89–49
Obsoleted (after Jan. 31, 2000) by
Notice 99–42, 1999–35 I.R.B. 325
96–9
Superseded by
Rev. Proc. 99–28, 1999–29 I.R.B. 109
96–17
Modified by
Rev. Proc. 99–39, 1999–43 I.R.B. 532
96–47
Amplified and superseded by
Rev. Proc. 99–40, 1999–46 I.R.B. 565
97–19
Modified by
Notice 99–41, 1999–35 I.R.B. 325
97–47
Amplified, clarified, modified, and superseded by
Rev. Proc. 99–39, 1999–43 I.R.B. 532
98–22
Clarified and supplemented by
Rev. Proc. 99–31, 1999–34 I.R.B. 280
98–35
Superseded by
Rev. Proc. 99–29, 1999–31 I.R.B. 138
98–37
Superseded by
Rev. Proc. 99–34, 1999–40 I.R.B. 450
98–63
Modified by Ann. 99–7 and superseded by
Rev. Proc. 99–38, 1999–43 I.R.B. 525
99–19
Modified and superseded by
Rev. Proc. 99–43, 1999–47 I.R.B. 579
Revenue Rulings:
77–475
Modified and superseded by
Rev. Rul. 99–40, 1999–40 I.R.B. 441
82–80
Superseded by
Rev. Proc. 99–32, 1999–34 I.R.B. 296
Revenue Rulings—Continued
84–58
Modified and superseded by
Rev. Rul. 99–40, 1999–40 I.R.B. 441
88–98
Modified and superseded by
Rev. Rul. 99–40, 1999–40 I.R.B. 441
99–23
Corrected by
Ann. 99–89, 1999–36 I.R.B. 408
Treasury Decisions:
8476
Corrected by
Ann. 99–74, 1999–30 I.R.B. 133
8742
Corrected by
Ann. 99–73, 1999–30 I.R.B. 133
8793
Corrected by
Ann. 99–75, 1999–30 I.R.B. 134
8805
Corrected by
Ann. 99–66, 1999–27 I.R.B. 9
8806
Corrected by
Ann. 99–84, 1999–33 I.R.B. 248
8819
Corrected by
Ann. 99–47, 1999–28 I.R.B. 29
8823
Corrected by
Ann. 99–86, 1999–35 I.R.B. 332
8825
Corrected by
Ann. 99–100, 1999–42 I.R.B. 522
8827
Corrected by
Ann. 99–111, 1999–47 I.R.B. 587
1
A cumulative finding list of actions published in
Internal Revenue Bulletins 1999–1 through 1999–26
is in Internal Revenue Bulletin 1999–27, dated July
6, 1999.

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