Internal Revenue Bulletin 2000-10

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb00-10.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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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.

Rev. Rul. 2000–11, page 734. Federal rates; adjusted federal rates; adjusted federal long-term rate, and the long-term exempt rate. For purposes of section 1274, 1288, 382, and other sections of the Code, tables set forth the rates for March 2000.

Notice 2000–14, page 737. Cross-testing; comparability. This notice states that the Service is undertaking a review of issues posed by “new comparability” retirement plans and invites public comments.

Finding Lists begin on page ii. Index for January and February begins on page iv.

Department of the Treasury Internal Revenue Service

Announcement 2000–11, page 739. The United States recently exchanged instruments of ratification for four new income tax treaties effective January 1, 2000. This information was not included in Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Corporations (For Withholding in 2000). This announcement provides supplemental tables of income rates and exempt personal service income for Estonia, Latvia, Lithuania, and Venezuela. It also includes corrected tables for Austria, Ireland, and South Africa.

Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official 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 substantive 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 otherwise indicated. Procedures relating solely to matters of internal 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 published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and proce

and by applying the tax law with integrity and fairness to all.

dures 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:

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 Subparts. Also included in this part are Bank Secrecy Act Administrative 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, disbarment 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 semiannual period, respectively.

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.

March 6, 2000 2000–10 I.R.B.

Section 42.—Low-Income Housing Credit

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 280G.—Golden Parachute Payments

Federal short-term, mid-term, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-in Losses Following Ownership Change

The adjusted applicable federal long-term rate is set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 412.—Minimum Funding Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 467.—Certain Payments for the Use of Property or Services

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 482.—Allocation of Income and Deductions Among Taxpayers

Federal short-term, mid-term, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 483.—Interest on Certain Deferred Payments

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 642.—Special Rules for Credits and Deductions

Federal short-term, mid-term, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 807.—Rules for Certain Reserves

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 846.—Discounted Unpaid Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 1274.—Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property

(Also sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal rates; adjusted federal long-term rate, and

the long-term exempt rate. For purposes of section 1274, 1288, 382, and other sections of the Code, tables set forth the rates for March 2000.

Rev. Rul. 2000–11

This revenue ruling provides various prescribed rates for federal income tax purposes for March 2000 (the current month.) Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(2) for buildings placed in service during the current month. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520.

March 6, 2000 734 2000–10 I.R.B.

REV. RUL. 2000–11 TABLE 1

Applicable Federal Rates (AFR) for March 2000

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-Term

AFR 6.45% 6.35% 6.30% 6.27% 110% AFR 7.11% 6.99% 6.93% 6.89% 120% AFR 7.77% 7.62% 7.55% 7.50% 130% AFR 8.43% 8.26% 8.18% 8.12%

Mid-Term

AFR 6.80% 6.69% 6.63% 6.60% 110% AFR 7.50% 7.36% 7.29% 7.25% 120% AFR 8.19% 8.03% 7.95% 7.90% 130% AFR 8.89% 8.70% 8.61% 8.55% 150% AFR 10.29% 10.04% 9.92% 9.84% 175% AFR 12.05% 11.71% 11.54% 11.43%

Long-Term

AFR 6.75% 6.64% 6.59% 6.55% 110% AFR 7.43% 7.30% 7.23% 7.19% 120% AFR 8.13% 7.97% 7.89% 7.84% 130% AFR 8.82% 8.63% 8.54% 8.48%

REV. RUL. 2000–11 TABLE 2

Adjusted AFR for March 2000

Period for Compounding

Annual Semiannual Quarterly Monthly

Short-term adjusted AFR 4.34% 4.29% 4.27% 4.25%

Mid-term adjusted AFR 4.97% 4.91% 4.88% 4.86%

Long-term adjusted AFR 5.84% 5.76% 5.72% 5.69%

REV. RUL. 2000–11 TABLE 3

Rates Under Section 382 for March 2000

Adjusted federal long-term rate for the current month 5.84%

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 5.84%

REV. RUL. 2000–11 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for March 2000

Appropriate percentage for the 70% present value low-income housing credit 8.59%

Appropriate percentage for the 30% present value low-income housing credit 3.68%

2000–10 I.R.B. 735 March 6, 2000

REV. RUL. 2000–11 TABLE 5

Rate Under Section 7520 for March 2000

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 8.2%

Section 1288.—Treatment of Original Issue Discounts on Tax- Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

Section 7872.—Treatment of Loans With Below-Market Interest Rates

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of March 2000. See Rev. Rul. 2000–11, page 734.

March 6, 2000 736 2000–10 I.R.B.

plans, including existing plans, on a prospective basis only.

One possible approach to address the issues raised by new comparability plans would be to provide that, for purposes of determining whether a defined contribution plan satisfies

§ 1.401(a)(4)–8(b)(1) of the Income Tax Regulations (i.e., the rules governing the cross-testing of defined contribution plans), the right to receive each rate of nonelective employer contributions must be currently and effectively available on a nondiscriminatory basis, determined in a manner generally patterned after the approach under § 1.401(a)(4)–4 of the regulations. These regulations already contain a requirement that rates of the other three basic types of contributions — elective contributions, after-tax employee contributions, and employer matching contributions — be made currently and effectively available in a nondiscriminatory manner.

If such an approach were adopted, however, it is anticipated that, subject to certain conditions, a plan would be permitted to disregard differences in rates of nonelective contributions that result from differences in attained age or service for purposes of determining whether contribution rates are currently available in a nondiscriminatory manner. Accordingly, under such an approach, the Service and Treasury anticipate that cross-testing would continue to be a permissible testing alternative for generic age-weighted or service-based defined contribution plans (plans under which younger and shorterservice participants become entitled to higher allocation rates as they age and accumulate more service) and certain other appropriate plan designs.

Comments are invited on this and other possible approaches (including appropriate exceptions) to address the issues raised by new comparability plans. It is requested that comments be submitted by May 15, 2000, and that they refer to Notice 2000–14. Comments can be addressed to CC:DOM:CORP:R (Notice 2000–14), room 5226, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. In the alternative, comments may be hand delivered between the hours of 8 a.m. and 5 p.m. to CC:DOM:CORP:R

Review of Issues Raised By “New Comparability” Plans

I. PURPOSE

The Internal Revenue Service and the Treasury Department are undertaking a review of issues posed by “new comparability” plans and invite public comments. The Service and Treasury believe it is appropriate at this time to review the effect of these rapidly evolving plan designs with the benefit of comments from plan sponsors, plan participants, and other interested parties.

New comparability plans (and similar plan designs such as “super-integrated” plans) are defined contribution plans that generally restrict higher rates of employer contributions to highly compensated employees. The focus of this review is the nondiscrimination requirements applicable to these plans.

Section 401(a)(4) of the Internal Revenue Code provides that a plan is a qualified plan only if the contributions or the benefits provided under the plan do not discriminate in favor of highly compensated employees. For purposes of determining whether nonelective employer contributions under a defined contribution plan discriminate in favor of highly compensated employees, the regulations under § 401(a)(4) permit such contributions either to be tested on a present value basis or to be “cross-tested” on a future value basis. Under this cross-testing method, contributions are converted to and tested as equivalent benefits payable at normal retirement age; the conversion is done by making an actuarial projection of the benefits payable at normal retirement age that are attributable to such contributions. Thus, this cross-testing method effectively permits nonelective employer contributions under a defined contribution plan to be tested as the equivalent of employer-provided benefits under a defined benefit plan.

Notwithstanding the analytical underpinnings of cross-testing, the Service and Treasury are concerned whether crosstested plan designs that provide for built

in disparities in contribution rates between highly compensated and nonhighly compensated employees can be reconciled with the basic purpose of the nondiscrimination rules as applied to defined contribution plans. In this regard, the Service and Treasury are reviewing whether it is appropriate in all cases, without regard to the particular structure of a crosstested defined contribution plan, to allow the projected future value of employer contributions to be tested as the equivalent of employer-provided benefits under a defined benefit plan.

For example, in a typical new comparability plan, highly compensated employees (who tend to be older than a majority of nonhighly compensated employees) receive high allocation rates (often 18% to 20% of compensation), while nonhighly compensated employees, regardless of their age or years of service, receive comparatively low allocation rates (e.g., 3% of compensation). In the typical case, there is a sufficient number of young nonhighly compensated employees to enable the employer to demonstrate compliance with the nondiscrimination standards by comparing the actuarially projected value of the small allocations for those young nonhighly compensated employees with the actuarially projected value of the substantially larger allocations for older highly compensated employees. The Service and Treasury are concerned that, by plan design, nonhighly compensated employees never have an opportunity to earn the higher allocation rates as they work additional years for the employer and grow older. Further, when a sponsor replaces its existing defined contribution plan with a new comparability plan, rankand-file employees may suffer significant reductions in their allocation rates, while owners and executives may benefit from a significant increase in their allocation rates.

II. POSSIBLE APPROACHES

In their review of new comparability plans, the Service and Treasury are considering what modifications to the existing rules applicable to these plans might be appropriate. It is anticipated that any such modifications would be applied to

2000–10 I.R.B. 737 March 6, 2000

(Notice 2000–14), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC. Alternatively, taxpayers may transmit comments electronically via the IRS Internet site at: http://www.irs.gov/tax_regs/regslist.html.

DRAFTING INFORMATION

The principal author of this notice is James Flannery of the Tax Exempt and Government Entities Division. For further information regarding this notice, please

contact the Employee Plans’taxpayer assistance telephone service at (202) 6226074/6075 (not toll-free numbers) between the hours of 1:30 and 3:30 p.m. Eastern Time, Monday through Thursday.

March 6, 2000 738 2000–10 I.R.B.

Announcement 2000–11

Changes to Publication 515

Changes apply to Tables 1 and 2 in Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Corpora- tions (For Withholding in 2000) . These changes are needed to reflect the new income tax treaties with Estonia, Latvia, Lithuania, and Venezuela that became effective on January 1, 2000. In addition, this announcement contains corrections to Table 2 to provide the current provisions of the tax treaties with Austria, Ireland, and South Africa.

Rosalie La Plante, Acting National Director,

Tax Forms and Publications Division.

2000–10 I.R.B. 739 March 6, 2000

March 6, 2000 740 2000–10 I.R.B.

2000–10 I.R.B. 741 March 6, 2000

March 6, 2000 742 2000–10 I.R.B.

2000–10 I.R.B. 743 March 6, 2000

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 published 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 confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential 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

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.

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 published ruling that is not considered determinative with respect to future transactions. 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 substance has been included in regulations subsequently adopted.

Revoked describes situations where the position in the previously published ruling 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 period of time in separate rulings. If the

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.

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 published 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 superseded.

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 published 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.

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.

March 6, 2000 i 2000–10 I.R.B.

Numerical Finding List ¹

Bulletins 2000–1 through 2000–9

Announcements: 2000–1, 2000–2 I.R.B. 294 2000–2, 2000–2 I.R.B. 295 2000–3, 2000–2 I.R.B. 296 2000–4, 2000–3 I.R.B. 317 2000–5, 2000–4 I.R.B. 427 2000–6, 2000–4 I.R.B. 428 2000–7, 2000–6 I.R.B. 586 2000–8, 2000–6 I.R.B. 586 2000–9, 2000–9 I.R.B. 733 2000–10, 2000–9 I.R.B. 733

Notices: 2000–1, 2000–2 I.R.B. 288 2000–2, 2000–9 I.R.B. 727 2000–3, 2000–4 I.R.B. 413 2000–4, 2000–3 I.R.B. 313 2000–5, 2000–3 I.R.B. 314 2000–6, 2000–3 I.R.B. 315 2000–7, 2000–4 I.R.B. 419 2000–8, 2000–4 I.R.B. 420 2000–9, 2000–5 I.R.B. 449 2000–10, 2000–5 I.R.B. 451 2000–11, 2000–6 I.R.B. 572 2000–12, 2000–9 I.R.B. 727 2000–13, 2000–9 I.R.B. 732

Proposed Regulations: REG–208280–86, 2000–8 I.R.B. 654 REG–209135–88, 2000–8 I.R.B. 681 REG–208254–90, 2000–6 I.R.B. 577 REG–100276–97, 2000–8 I.R.B. 682 REG–101492–98, 2000–3 I.R.B. 326 REG–106012–98, 2000–2 I.R.B. 290 REG–103831–99, 2000–5 I.R.B. 452 REG–103882–99, 2000–8 I.R.B. 702 REG–105089–99, 2000–6 I.R.B. 580 REG–105279–99, 2000–8 I.R.B. 707 REG–105606–99, 2000–4 I.R.B. 421 REG–111119–99, 2000–5 I.R.B. 455 REG–113572–99, 2000–7 I.R.B. 624 REG–116048–99, 2000–6 I.R.B. 584 REG–116567–99, 2000–5 I.R.B. 463 REG–116704–99, 2000–3 I.R.B. 325 REG–100163–00, 2000–7 I.R.B. 633

Railroad Retirement Quarterly Rate: 2000–9, I.R.B. 721

Revenue Procedures: 2000–1, 2000–1 I.R.B. 4 2000–2, 2000–1 I.R.B. 73 2000–3, 2000–1 I.R.B. 103 2000–4, 2000–1 I.R.B. 115 2000–5, 2000–1 I.R.B. 158 2000–6, 2000–1 I.R.B. 187 2000–7, 2000–1 I.R.B. 227 2000–8, 2000–1 I.R.B. 230 2000–9, 2000–2 I.R.B. 280 2000–10, 2000–2 I.R.B. 287 2000–11, 2000–3 I.R.B. 309 2000–12, 2000–4 I.R.B. 387 2000–13, 2000–6 I.R.B. 515

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000.

Revenue Procedures—continued: 2000–15, 2000–5 I.R.B. 447 2000–16, 2000–6 I.R.B. 518 2000–18, 2000–9 I.R.B. 722 2000–20, 2000–6 I.R.B. 553

Revenue Rulings: 2000–1, 2000–2 I.R.B. 250 2000–2, 2000–3 I.R.B. 305 2000–3, 2000–3 I.R.B. 297 2000–4, 2000–4 I.R.B. 331 2000–5, 2000–5 I.R.B. 436 2000–6, 2000–6 I.R.B. 512 2000–7, 2000–9 I.R.B. 712 2000–8, 2000–7 I.R.B. 617 2000–9, 2000–6 I.R.B. 497 2000–10, 2000–8 I.R.B. 643

Treasury Decisions: 8849, 2000–2 I.R.B. 245 8850, 2000–2 I.R.B. 265 8851, 2000–2 I.R.B. 275 8852, 2000–2 I.R.B. 253 8853, 2000–4 I.R.B. 377 8854, 2000–3 I.R.B. 306 8855, 2000–4 I.R.B. 374 8856, 2000–3 I.R.B. 298 8857, 2000–4 I.R.B. 365 8858, 2000–4 I.R.B. 332 8859, 2000–5 I.R.B. 429 8860, 2000–5 I.R.B. 437 8861, 2000–5 I.R.B. 441 8862, 2000–6 I.R.B. 466 8863, 2000–6 I.R.B. 488 8864, 2000–7 I.R.B. 614 8865, 2000–7 I.R.B. 589 8866, 2000–6 I.R.B. 495 8867, 2000–7 I.R.B. 620 8868, 2000–6 I.R.B. 491 8869, 2000–6 I.R.B. 498 8870, 2000–8 I.R.B. 647 8871, 2000–8 I.R.B. 641 8872, 2000–8 I.R.B. 639 8873, 2000–9 I.R.B. 713 8874, 2000–8 I.R.B. 644

2000–10 I.R.B. ii March 6, 2000

Revenue Procedures—Continued:

2000–6 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

2000–8 Modified by both Rev. Proc. 2000–16, 2000–6 I.R.B. 518 and Rev. Proc. 2000–20, 2000–6 I.R.B. 553

Revenue Rulings:

88–36 Modified by Rev. Proc. 2000–6, 2000–6 I.R.B. 512

98–30 Amplified and superseded by Rev. Rul. 2000–8, 2000–7, I.R.B. 617

Treasury Decisions:

8734 Modified by T.D. 8856, 2000–3, I.R.B. 298

8804 Modified by T.D. 8856, 2000–3, I.R.B. 298

Finding List of Current Action on Previously Published Items ¹

Bulletins 2000–1 through 2000–9

Announcements:

99–50 Modified by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

Notices:

88–125 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647

92–48 Obsoleted by Notice 2000–11, 2000–6 I.R.B. 572

97–19 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4

98–22 Obsoleted by T.D. 8870, 2000–8 I.R.B. 647

98–52 Modified by Notice 2000–3, 2000–4 I.R.B. 413

98–61 Modified and superseded by Rev. Proc. 2000–15, 2000–5 I.R.B. 447

99–8 Obsoleted by Rev. Proc. 2000–12, 2000–4 I.R.B. 387

Revenue Procedures:

80–18 Modified by Rev. Proc. 2000–13, 2000–6 I.R.B. 515

89–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

89–13 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

90–21 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

91–66 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

92–13 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309

92–13A Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309

92–41 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

93–9 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 1999–27 through 1999–52 is in Internal Revenue Bulletin 2000–1, dated January 3, 2000.

Revenue Procedures—Continued:

93–10 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

94–12 Modified, amplified, and superseded by Rev. Proc. 2000–11, 2000–3 I.R.B. 309

94–42 Superseded by Rev. Proc. 2000–20, 2000–6 I.R.B. 553

96–13 Modified by Rev. Proc. 2000–1, 2000–1 I.R.B. 4

98–22 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518

98–27 Superseded by Rev. Proc. 2000–12, 2000–4 I.R.B. 387

98–64 Superseded by Rev. Proc. 2000–9, 2000–2 I.R.B. 280

99–1 Superseded by Rev. Proc. 2000–1, 2000–1 I.R.B. 4

99–2 Superseded by Rev. Proc. 2000–2, 2000–1 I.R.B. 73

99–3 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103

99–4 Superseded by Rev. Proc. 2000–4, 2000–1 I.R.B. 115

99–5 Superseded by Rev. Proc. 2000–5, 2000–1 I.R.B. 158

99–6 Superseded by Rev. Proc. 2000–6, 2000–1 I.R.B. 187

99–7 Superseded by Rev. Proc. 2000–7, 2000–1 I.R.B. 227

99–8 Superseded by Rev. Proc. 2000–8, 2000–1 I.R.B. 230

99–13 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518

99–31 Modified and superseded by Rev. Proc. 2000–16, 2000–6 I.R.B. 518

99–49 Modified and amplified by Rev. Rul. 2000–4, 2000–4 I.R.B. 331; Rev. Rul. 2000–7, 2000–9 I.R.B. 712, and Notice 2000–4, 2000–3 I.R.B. 313

99–51 Superseded by Rev. Proc. 2000–3, 2000–1 I.R.B. 103

March 6, 2000 iii 2000–10 I.R.B.

Internal Revenue Bulletins 2000–1 Through 2000–9

The abbreviation and number in parenthesis following the index entry refer to the specific item; numbers in roman and italic type following the parenthesis refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears.

Key to Abbreviations: RR Revenue Ruling RP Revenue Procedure TD Treasury Decision CD Court Decision PL Public Law EO Executive Order DO Delegation Order TDO Treasury Department Order TC Tax Convention SPR Statement of Procedural

Rules PTE Prohibited Transaction

Exemption

Areas in which advance letter rulings and

determination letters will not be issued from Associate Chief Counsel, Domestic (RP 3) 1, 103 Areas in which advance letter rulings and

determination letters will not be issued from Associate Chief Counsel, International (RP 7) 1, 227 Cash or deferred arrangements:

26 CFR 35.3405–1, redesignated as 35.3405–1T, revised; 35.3405–1, added; new technologies in retirement plans (TD 8873) 9, 713 New technologies in retirement plans,

amendment period (TD 8871) 8, 641 Regulations:

Railroad retirement:

26 CFR 1.401(b)–1T, removed; remedial amendment period (TD 8871) 8, 641 26 CFR 1.402(f)–1, amended; 1.411(a)–11, amended; new technologies in retirement plans (TD 8873) 9, 713 Reporting requirements, Section 457

Rate determination quarterly (January

1, 2000) 9, 721 Regulations:

26 CFR 49.4251–4, added; 602.101, amended; prepaid telephone cards (TD 8855) 4, 374 Return filing and deposits (Ann 5) 4, 427

plans (Ann 1) 2, 294 New technologies in retirement plans,

distribution notices and consents (TD 8873) 9, 713 Technical advice to district directors and

Areas in which advance letter rulings and

determination letters will not be issued from Associate Chief Counsel, Domestic (RP 3) 1, 103 Information letters available for public

chiefs, appeals office from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP

5. 1, 158 User fees, request for letter rulings (RP

(RP 4) 1, 115 List of organizations classified as private

inspection (Ann 2) 2, 295 Letter rulings, information letters, etc.

8. 1, 230

Electronically filed information returns,

foundations (Ann 8) 6, 586 Private foundation disclosure rules (TD

8861. 5, 442 Regulations:

due dates (REG–105279–99) 8, 707 Information reporting:

Election workers (RR 6) 6, 512 Proposed Regulations:

26 CFR 31.3402(q)–1, revised; 31.6053–3, revised; 31.6071(a)–1, revised; extension of due date for electronically filed information returns (REG–105279–99) 8, 707 Regulations:

Elective deferrals (RR 8) 7, 617 Nondiscrimination (Notice 3) 4, 413 Determination letter, issuing procedures

(RP 6) 1, 187 Eligible rollover distributions, safe har

26 CFR 1.513–7, added; travel and tour activities of tax-exempt organizations (TD 8874) 8, 644 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; private foundation disclosure rules (TD 8861) 5, 442 Technical advice to district directors and

chiefs, and appeals office from Associate Chief Counsel (RP 2) 1, 73 Technical advice to IRS employees (RP

bor explanations (Notice 11) 6, 572 EPCRS, closing agreements (RP 16) 6, 518 Full funding limitations, weighted aver

distribution notices and consents (TD 8873) 9, 713

age interest rate for: January (Notice 8) 4, 420; February

(Notice 2) 9, 727 Letter rulings, determination letters and

QTIP elections, individual retirement

5. 1, 158 Travel tours, taxation of (TD 8874) 8,

6. 1, 230

information letters issued by Associate Chief Counsel (RP 1) 1, 4 Letter rulings, information letters, etc.

accounts and testamentary trusts (RR 2) 3, 305 Marital / Charitable deduction, valuation

of property; administration expenses (Ann 3) 2, 296

644 User fees, request for letter rulings (RP

Accounting period change, automatic

(RP 4) 1, 115 Master and prototype plans, unified pro

Prepaid telephone cards (TD 8855) 4,

374

tributions (Ann 10) 9, 733

cedures (RP 20) 6, 553 Mortality tables (Ann 7) 6, 586 Qualified retirement plans, remedial

consent (RP 11) 3, 309 Acquisitions, recognition of gain on dis

2000–10 I.R.B. iv March 6, 2000

Adequate disclosure of gifts (Ann 6) 4,

Closely-held real estate investment

13. 9, 732 Nonqualified preferred stock, exchanges

Resident population estimates (Notice

428 Allocation of partnership debt, nonre

course liabilities (REG–103831–99) 5, 452 Amortization of intangible property (TD

trust, penalty relief (Notice 5) 3, 314 Equity options with flexible terms, spe

cial rules and definitions (TD 8866) 6, 495 Financial asset securitization investment

and distributions (REG–105089–99) 6, 580 Partnerships:

Allocation of nonrecourse liabilities

(REG–103831–99) 5, 452 Amortization of intangible property

8865. 7, 589 Appeals, test of arbitration procedure

(Ann 4) 3, 317 Areas in which advance letter rulings and

determination letters will not be issued, International (RP 7) 1, 227 Asset acquisitions, allocation of purchase

trusts, general (REG–100276–97; REG–122450–98) 8, 682 Foreign corporations:

(REG–208280–86) 8, 654 Information reporting (TD 8850) 3,

265 Stock transfer rules:

Exclusion of shipping income

(REG–111119–99) 5, 455 Passive foreign investment companies:

(REG–100163–00) 7, 633 Mergers and divisions

price (TD 8858) 4, 332 Automobile owners and lessees (RP 18)

9, 722 Barter exchanges, information reporting

(REG–116048–99) 6, 584 Foreign currency, hyperinflation; defini

General provisions (TD 8862) 6, 466 Nonrecognition (TD 8863) 6, 488

647 Postponement of tax-related deadlines;

service in combat zone or Presidentially declared disaster (REG–101492–98) 3, 326 Pre-filing agreement pilot program

Marketable stock (TD 8867) 7, 620 Qualified electing fund (TD 8870) 8,

(Notice 6) 3, 315 Business Expenses

ISO 9000 costs (RR 4) 4, 331 Traveling expenses, per diem

allowances (RP 9) 2, 280 Substantiation (TD 8864) 7, 614 Canadian banking legislation, repeal,

tion (REG–116567–99) 5, 463 ; (TD 8860) 5, 437 Foreign partnerships:

(Notice 12) 9, 727 Private foundations:

deferral of termination (Notice 7) 4, 419 Closely-held real estate investment trust,

estimated tax payments, penalty relief (Notice 5) 3, 314 Contribution in aid of construction, defi

inspection (Ann 2) 2, 295 Information reporting:

Information reporting (TD 8850) 3,

265 U.S. persons with reportable event,

reporting requirement (TD 8851) 2, 275 Guidance priority list (Notice 10) 5, 451 Information letters available for public

8. 6, 586 Proposed Regulations:

Disclosure rules (TD 8861) 5, 442 Organizations now classified as (Ann

nition (REG–106012–98) 2, 290 Credits:

Low-income housing credit:

Compliance monitoring (TD 8859)

Barter exchange (Notice 6) 3, 315 Foreign partnerships and foreign corporations (TD 8850) 3, 265 Innocent spouse, equitable relief (RP 15)

5, 429 Resident population estimates

(Notice 13) 9, 732 Puerto Rico and possession tax credit,

5, 447 Interest:

Investment:

Federal short-term, mid-term, and

termination of (TD 8868) 6, 491 Research credit, controlled group

long-term rates for: January 2000 (RR 1) 2, 250; February (RR 9) 6, 497 Installment agreements, limitation of fail

(REG–105606–99) 4, 421 Depletion, treatment of delay rental

(REG–103882–99) 8, 702 Depreciation:

MACRS property, involuntary conver

ure to pay penalty (REG–105279–99) 8, 707 Inventory:

sion or like-kind exchange (Notice 4) 3, 313; Correction (Ann 9) 9, 733 Determination of underwriting income,

non-life insurance companies (TD 8857) 4, 365 Disclosure of return information, Census

November 1999 (RR 3) 3, 297 December 1999 (RR 10) 8, 643 Letter rulings, determination letters and

LIFO:

Price indexes, department stores

of Agriculture (TD 8854) 3, 306 ; (REG–116704–99) 3, 325 Electronically filed information returns,

26 CFR 1.41–0, amended; 1.41–8, revised; credit for increasing research activities (REG–105606–99) 4, 421 26 CFR 1.118–2, added; contribution in aid of construction, definition (REG–106012–98) 2, 290 26 CFR 1.132–0, amended; 1.132–9, added; qualified transportation fringes (REG–113572–99) 7, 624 26 CFR 1.197–2, amended; amortization of intangible property (REG–100163–00) 7, 633 26 CFR 1.337(d)–5T, added, 1.852–12, added; 1.857–11, added; certain asset transfers to regulated investment companies and real estate investment trusts (REG–209135–88) 8, 681 26 CFR 1.354–1, amended; 1.355–1, amended; 1.356–7, added; 1.1036–1, amended; treatment of nonqualified perferred stock and other preferred stock in certain exchanges and distributions (REG–105089–99) 6, 580 26 CFR 1.367(b)–3, amended; stock transfer rules (REG–116048–99) 6, 584

due dates of (REG–105279–99) 8, 707 Estimated taxes:

information letters issued by Associate Chief Counsel (RP 1) 1, 4 Low-income housing credit:

Compliance monitoring (TD 8859) 5,

429

March 6, 2000 v 2000–10 I.R.B.

26 CFR 1.612–3, amended; depletion, treatment of delay rental (REG–103882–99) 8, 702 26 CFR 1.708–1, amended; 1.743–1, amended; treatment of partnership mergers and divisions (REG–111119–99) 5, 455 26 CFR 1.752–3, amended; 1.752–5, revised; allocation of nonrecourse liabilities by a partnership (REG–103831–99) 5, 452 26 CFR 1.860E–1, amended; 1.860H–0, –1, –2, –3, –4, –5, –6, added; 1.860I–1, –2, added; 1.860J–1, added; 1.860L–1, –2, –3, –4, added; 1.861–9T, amended; 1.861–10T, amended; financial asset securitization investment trusts; real estate mortgage investment conduits (REG–100276–97; REG–122450–98) 8, 682 26 CFR 1.861–4, amended; source of compensation for labor or personal services (REG–208254–90) 6, 577 26 CFR 1.883–0, added; 1.883–1, revised; 1.883–2, –3, –4, –5, added; exclusions from gross income of foreign corporations (REG–208280–86) 8, 654 26 CFR 1.988–1, revised; hyperinflationary currencies, definition (REG–116567–99) 5, 463 26 CFR 1.6041–2, revised; 1.6041–6, revised; 1.6042–2, revised; 1.6043–2, revised; 1.6044–2, revised; 1.6045–1, added; 1.6045–2, revised; 1.6045–4, revised; 1.6047–1, revised; 1.6049–4, revised; 1.6049–7, revised; 1.6050A–1, revised; 1.6050D–1, revised; 1.6050E–1, revised; 1.6050H–2, revised; 1.6050J–1T, revised; 1.6050P–1, revised; 1.6052–1, revised; 301.6651–1, amended; extension of due date for electronically filed information returns; limitation of failure to pay penalty for individuals during period of installment agreement (REG–105279–99) 8, 707 26 CFR 301.6103(j)(5)–1, added; disclosure of return information; Census of Agriculture (REG–116704–99) 3, 325 26 CFR 301.7508–1, added; 301.7508A–1, added; relief for ser

vice in combat zone and for Presidentially declared disaster (REG–101492–98) 3, 326 Qualified transportation fringe benefits amended; 1.42–17, added; compliance monitoring and miscellaneous issues relating to the low-income housing credit (TD 8859) 5, 429 26 CFR 1.62–2, amended; 1.62–2T, removed; 1.274–5, added; 1.274–5T, amended; substantiation of business expenses (TD 8864) 7, 614 26 CFR 1.162–11, amended; 1.167(a)–3, amended; 1.167(a)–6, amended; 1.167(a)–14, added; 1.197–0, added; 1.197–2, added; amortization of goodwill and certain other intangibles (TD 8865) 7, 589 26 CFR 1.337(d)–5, added, certain asset transfers to regulated investment companies and real estate investment trusts (TD 8872) 8, 639 26 CFR 1.338–0, –1, –2, –3, removed; 1.338–4, redesignated as 1.338–8; 1.338–5, redesignated as 1.338–9; 1.338–4T, –5T, –6T, –7T, –10T, added; 1.338(b)–1, added; 1.338(b)–2T, –3T, removed; 1.338(h)(10)–1, removed; 1.338(i)–1, removed; 1.338(i)–1T, added; 1.1060–1T, revised; purchase price allocations in deemed and actual asset acquisitions (TD 8858) 4, 332 26 CFR 1.367(a)–3, amended; 1.367(b)–0, added; 1.367(b)–1, –2, revised; 1.367(b)–3, added; 1.367(b)–4, revised; 1.367(b)–5, –6, added; 1.367(b)–7, –8, –9, removed;

(REG–113572–99) 7, 624 Qualified Zone Academy Bonds (RP 10)

2, 287 Real estate investment trusts, asset trans

fers to (TD 8872) 8, 639 ; (REG–209135–88) 8, 681 Real estate mortgage investment con

duits, safe harbor (REG–100276–97; REG–122450–98) 8, 682 Regulated investment companies, asset

transfers to (TD 8872) 8, 639; (REG–209135–88) 8, 681 Recharacterizing financing arrangements;

fast-pay stock (TD 8853) 4, 377 Regulations:

1.381(b)–1, amended; 7.367(b)–1, –2, –3, –4, –5, –6, –7, –8, –9, –10, –11, removed; 7.367(b)–12, amended; 7.367(b)–13, removed; stock transfers rules (TD 8862) 6, 466 26 CFR 1.367(b)–3T, added; stock transfer rules, (TD 8863) 6, 488 26 CFR 1.401(b)–1, amended; 1.401(b)–1T, removed; remedial amendment period (TD 8871) 8, 641 26 CFR 1.513–7, added; travel and tour activities of tax-exempt organizations (TD 8874) 8, 644 26 CFR 1.663(a)–1, amended; 1.663(c)–1, amended; 1.663(c)–2, revised; 1.663(c)–3, amended; 1.663(c)–4, redesignated as 1.663(c)–5, amended; 1.663(c)–4, added; 1.663(c)–6, added; separate shares rule applicable to estates (TD 8849) 2, 245 26 CFR 1.871–14, revised; 1.1441–1, –4, –5, –6, –8, –9, revised; 1.1443–1, revised; 1.6042–3, revised; 1.6045–1, revised; 1.6049–5, revised; withholding of tax on certain U.S. source income paid to foreign persons; delay of effective date (TD 8856) 3, 298 26 CFR 1.936–11T, removed; 1.936–11, added; termination of Puerto Rico and possession tax credit (TD 8868) 6, 491 26 CFR 1.988–0, amended; 1.988–2, amended; treatment of income and expenses from certain hyperinflationary currencies; nonperiodic payments (TD 8860) 5, 437 26 CFR 1.1092(c)–1, added; equity options with flexible terms (TD 8866) 6, 495 26 CFR 1.1291–1T, redesignated as 1.1291–1, revised; 1.1293–1T, redesignated as 1.1293–1, revised; 1.1295–0, amended; 1.1295–1T, redesignated as 1.1295–1, amended; 1.1295–3T, redesignated as 1.1295–3, amended; general rules for making and maintaining qualified electing fund elections (TD 8870) 8, 647 26 CFR 1.1296(e)–1, added; passive foreign investment companies, marketable stock (TD 8867) 7, 620 26 CFR 1.1361–0, –1; amended; 1.1361–2, –3, –4, –5, –6, added;

2000–10 I.R.B. vi March 6, 2000

1.1362–0, amended; 1.1362–2, amended; 1.1362–8, added; 1,1368–0, amended; 1.1368–2, amended; 1.1374–8, amended; 301.6109–1, amended; subchapter S subsidiaries (TD 8869) 6, 498 26 CFR 1.1366–0, –1, added; 1.1366–2, revised; 1.1366–3, –4, –5, added; 1.1367–0, –1, amended; 1.1367–3, revised; 1.1368–0, –1, –2, –3, amended; 1.1368–4, revised; passthrough of items of an S corporation to its shareholders (TD 8852) 2, 253 26 CFR 1.1441–10, added; 1.7701(1)–0, added; 1.7701(1)–3, added; 602.101(b), amended; recharacterizing financing arrangements involving fast–pay stock (TD 8853) 4, 377 26 CFR 1.6038–3, added; 1.6038–2, amended; 1.6038B–1, amended; 1.6038B–2, amended; information reporting with respect to certain foreign partnerships and certain foreign corporations (TD 8850) 2, 265 26 CFR 1.6046A–1, added; return

requirement for U.S. persons acquiring or disposing of an interest in a foreign partnership (TD 8851) 2, 275 26 CFR 301.6103(j)(5)–1T, added; disclosure of return information; Census of Agriculture (TD 8854) 3, 306 26 CFR 301.6104(d)–1, removed; 301.6104(d)–2, redesignated as 301.6104(d)–0, revised; 301.6104(d)–3, redesignated as 301.6104(d)–1, amended; 301.6104(d)–4, redesignated as 301.6104(d)–2, amended; 301.6104(d)–5, redesignated as 301.6104(d)–3, amended; 602.101(b), amended; private foundation disclosure rules (TD 8861) 5, 442 Removal costs, capital expenditures (RR

Research credit, controlled group

eign persons, delay of effective date (TD 8856) 3, 298 Qualified intermediary withholding

(REG–105606–99) 4, 421 S corporation passthrough items (TD

8852. 2, 253 Separate shares rules (TD 8849) 2, 245 Sources of income, compensation for

labor or services (REG–208254–90) 6, 577 Subchapter S subsidiaries (TD 8869) 6,

498 Technical advice to district directors and

chiefs, and appeals office from Associate Chief Counsel (RP 2) 1, 73 United States — United Kingdom Tax

Convention, repeal of advance corporation tax (RP 13) 6, 515 Variable annuity contracts, closing agree

ments (Notice 9) 5, 449 Withholdings

U.S. source income payments to for

7. 9, 712 Reorganizations:

Solely for voting stock requirement

(Notice 1) 2, 288 Divisive mergers, definition (RR 5) 5,

agreements (RP 12) 4, 387

436

March 6, 2000 vii 2000–10 I.R.B.

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