INCOME TAX

T.D. 8915, page 359. Temporary regulations under section 444 of the Code relate to the election of a taxable year other than the required taxable year. The regulations provide that solely with respect to an S corporation shareholder, an electing small business trust (ESBT) and a trust described in section 401(a) or section 501(c)(3) that is exempt from taxation under section 501(a) are not deferral entities for purposes of section 1.444–2T.

T.D. 8916, page 360. Final regulations under section 864 of the Code provide guidance on the treatment of section 936 corporations for purposes of allocating expenses in order to calculate the alternative minimum tax foreign tax credit. Final regulations under section 904(d) relate to the application of the foreign tax credit separate categories, including the application of the look-through rules under section 904(d)(3).

T.D. 8918, page 372. REG–107176–00, page 428. Temporary and proposed regulations relate to the deposit of federal taxes pursuant to section 6302 of the Code.

REG–104683–00, page 407. Proposed regulations under section 902 of the Code provide that multi-year pooling of earnings and taxes will stop when a foreign corporation ceases to have a 10-percent domestic corporate shareholder. These regulations provide that the active rents and royalties exception from passive income treatment is no longer limited to payments from unrelated payors. The proposed regulations also include other clarifications regarding the application of section 904(d), guidance on the application of section 904(b), and guidance

Finding Lists begin on page ii.

Department of the Treasury Internal Revenue Service