SEC. 2. CHANGES FROM REV. PROC.

99–41

The following will no longer constitute adequate disclosure for purposes of re

ducing the understatement of income tax under § 6662(d) and avoiding the preparer penalty under § 6694(a): The completion of Schedule M (Form 5471), Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons, lines 19 and 20, and Form 5472, Part IV, Monetary Transactions Between Reporting Corporations and Foreign Related Party, lines 7 and 18. Additionally, minor editorial changes have been made in updating Rev. Proc. 99–41.