INCOME TAX

T.D. 8889, page 124. Final regulations under section 894 of the Code clarify the availability of treaty benefits with respect to an item of U.S. source income paid to an entity that is treated as fiscally transparent under the laws of one or more jurisdictions (including the United States) with respect to that item of income. These regulations provide rules for determining whether an entity is fiscally transparent under the laws of a jurisdiction and for determining whether such income is derived by persons entitled to treaty benefits.

T.D. 8890, page 122. Final regulations under section 671 of the Code define the term “grantor” for purposes of determining who is the grantor of a trust.

Notice 2000–39, page 132. Individual retirement accounts; net income calcula- tion. This notice provides a new method for calculating net income attributable to IRA contributions returned pursuant to section 408(d)(4) of the Code and to IRA contributions recharacterized pursuant to section 408A(d)(6).