Bulletin No. 2000–49 December 4, 2000

Notice 2000–61, page 569. This notice clarifies that section 935 of the Code applies only to individuals and, therefore, does not relieve a trust from any obligation it may have to file an income tax return for the taxable year with the United States. The notice also provides that transactions entered into by taxpayers who claim that section 935 applies to trusts as part of a scheme to avoid both U.S. and Guamanian tax liability are designated as “listed transactions” for purposes of sections 6011, 6111, and 6112 of the Code.