Part IV. Applicable Federal Interest Rates.

TABLE OF APPLICABLE FEDERAL INTEREST RATES

FOR PURPOSES OF § 807

Year Interest Rate

2000 6.09 2001 6.00

Sources: Rev. Rul. 99-48, 1999-2 C.B. 600 for the 2000 rate and Rev. Rul. 2000-54, 2000-49 I.R.B. 566 for the 2001 rate.

EFFECT ON OTHER REVENUE RULINGS

Rev. Rul. 92–19 is supplemented by the addition to Part III of that ruling of prevailing state assumed interest rates under § 807 for certain insurance products issued in 2000 and 2001 and is further supplemented by an addition to the table

in Part IV of Rev. Rul. 92–19 listing applicable federal interest rates. Parts I and II of Rev. Rul. 92–19 are not affected by this ruling.

DRAFTING INFORMATION

The principal author of this revenue ruling is Ann H. Logan of the Office of

Assistant Chief Counsel (Financial Institutions and Products). For further information regarding this revenue ruling contact her at (202) 622-3970 (not a tollfree call).

2001–10 I.R.B. 783 March 5, 2001

On January 3, 2001, the Treasury Department published final regulations (T.D. 8930, 2001–5 I.R.B. 433) relating to the computation of the research credit under § 41(c) and the definition of qualified research under § 41(d) in the Federal Register (66 F.R. 280). These regulations reflect changes to § 41 made by the Tax Reform Act of 1986, the Revenue Reconciliation Act of 1989, the Small Business Job Protection Act of 1996, the Taxpayer Relief Act of 1997, the Tax and Trade Relief Extension Act of 1998, and the Tax Relief Extension Act of 1999.

The Treasury Department and the Internal Revenue Service will review these final regulations. Comments are requested on all aspects of the final regulations with specific comments requested on whether modifications should be made to the documentation requirement contained in § 1.41–4(d). As part of this review, the Treasury Department and the Service will reconsider all comments previously submitted in connection with the finalization of T.D. 8930. Comments should be submitted by April 2, 2001, and sent to: CC:M&SP:RU (T.D. 8930), room 5226, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Comments may be hand delivered Monday through Friday between the hours of 8 a.m. and 5 p.m. to CC:M&SP:RU (T.D. 8930), room 5226, Internal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC 20044. Alternatively, taxpayers may submit comments electronically via the Internet by selecting the “Tax Regs” option on the IRS Home Page or by submitting comments directly to the IRS Internet site at http://www.irs.ustreas.gov/tax_regs/regsli st.html. All submissions will be open to public inspection.

Upon the completion of this review, the Treasury Department and the Service will announce changes to the regulations, if any, in the form of proposed regulations. In addition, T.D. 8930 will be revised so that the provisions of the regulations,

including any changes to T.D. 8930, will be effective no earlier than the date when the completion of this review is announced, except that the provisions related to internal-use computer software (including any revisions) generally will be applicable for taxable years beginning after December 31, 1985.

Taxpayers may continue to rely on T.D. 8930 during the pendency of this review. For further information regarding this notice, contact Lisa Shuman of the Office of the Associate Chief Counsel (Passthroughs and Special Industries) at (202) 622-3120 (not a toll-free call).

26 CFR 601.204: Changes in accounting periods and in methods of accounting. (Also Part I, §§ 446, 472; 1.446–1, 1.472–1.)

Rev. Proc. 2001–23

Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to de- scribe 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 Contributions 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.

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.

P —Parent Corporation. 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 Procedural 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.

March 5, 2001 i 2001–10 I.R.B.

Numerical Finding List ¹

Bulletins 2001–1 through 2001–9

Announcements: 2001–1, 2001–2 I.R.B. 277 2001–2, 2001–2 I.R.B. 277 2001–3, 2001–2 I.R.B. 278 2001–4, 2001–2 I.R.B. 286 2001–5, 2001–2 I.R.B. 286 2001–6, 2001–3 I.R.B. 357 2001–7, 2001–3 I.R.B. 357 2001–8, 2001–3 I.R.B. 357 2001–9, 2001–3 I.R.B. 357 2001–10, 2001–4 I.R.B. 431 2001–11, 2001–4 I.R.B. 432 2001–12, 2001–6 I.R.B. 526 2001–13, 2001–9 I.R.B. 752 2001–14, 2001–7 I.R.B. 648 2001–15, 2001–8 I.R.B. 715 2001–16, 2001–8 I.R.B. 715 2001–17, 2001–8 I.R.B. 716 2001–20, 2001–8 I.R.B. 716 2001–21, 2001–9 I.R.B. 752

Notices: 2001–1, 2001–2 I.R.B. 261 2001–2, 2001–2 I.R.B. 265 2001–3, 2001–2 I.R.B. 267 2001–4, 2001–2 I.R.B. 267 2001–5, 2001–3 I.R.B. 327 2001–6, 2001–3 I.R.B. 327 2001–7, 2001–4 I.R.B. 374 2001–8, 2001–4 I.R.B. 374 2001–9, 2001–4 I.R.B. 375 2001–10, 2001–5 I.R.B. 459 2001–11, 2001–5 I.R.B. 464 2001–12, 2001–3 I.R.B. 328 2001–13, 2001–6 I.R.B. 514 2001–14, 2001–6 I.R.B. 516 2001–15, 2001–7 I.R.B. 589 2001–16, 2001–9 I.R.B. 730 2001–17, 2001–9 I.R.B. 730 2001–18, 2001–9 I.R.B. 731

Proposed Regulations: REG–209461–79, 2001–8, I.R.B. 712 REG–246256–96, 2001–8, I.R.B. 713 REG–251701–96, 2001–4, I.R.B. 396 REG–106542–98, 2001–5, I.R.B. 473 REG–121928–98, 2001–6, I.R.B. 520 REG–103320–00, 2001–8, I.R.B. 714 REG–104683–00, 2001–4, I.R.B. 407 REG–106702–00, 2001–4, I.R.B. 424 REG–106791–00, 2001–6, I.R.B. 521 REG–107176–00, 2001–4, I.R.B. 428 REG–107566–00, 2001–3, I.R.B. 346 REG–114082–00, 2001–7, I.R.B. 629 REG–114083–00, 2001–7, I.R.B. 630 REG–114084–00, 2001–7, I.R.B. 633 REG–116468–00, 2001–6, I.R.B. 522 REG–119352–00, 2001–6, I.R.B. 525

Railroad Retirement Quarterly Rates: 2001–2, I.R.B. 258

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2000–27 through 2000–52 is in Internal Revenue Bulletin 2001–1, dated January 2, 2001.

Revenue Procedures: 2001–1, 2001–1 I.R.B. 1 2001–2, 2001–1 I.R.B. 79 2001–3, 2001–1 I.R.B. 111 2001–4, 2001–1 I.R.B. 121 2001–5, 2001–1 I.R.B. 164 2001–6, 2001–1 I.R.B. 194 2001–7, 2001–1 I.R.B. 236 2001–8, 2001–1 I.R.B. 239 2001–9, 2001–3 I.R.B. 328 2001–10, 2001–2 I.R.B. 272 2001–11, 2001–2 I.R.B. 275 2001–12, 2001–3 I.R.B. 335 2001–13, 2001–3 I.R.B. 337 2001–14, 2001–3 I.R.B. 343 2001–15, 2001–5 I.R.B. 465 2001–16, 2001–4 I.R.B. 376 2001–17, 2001–7 I.R.B. 589 2001–18, 2001–8 I.R.B. 708 2001–19, 2001–9 I.R.B. 732 2001–20, 2001–9 I.R.B. 738 2001–21, 2001–9 I.R.B. 742 2001–22, 2001–9 I.R.B. 745

Revenue Rulings: 2001–1, 2001–9 I.R.B. 726 2001–2, 2001–2 I.R.B. 255 2001–3, 2001–3 I.R.B. 319 2001–4, 2001–3 I.R.B. 295 2001–5, 2001–5 I.R.B. 451 2001–6, 2001–6 I.R.B. 491 2001–7, 2001–7 I.R.B. 541 2001–8, 2001–9 I.R.B. 726 2001–9, 2001–8 I.R.B. 652

Treasury Decisions: 8910, 2001–2 I.R.B. 258 8911, 2001–3 I.R.B. 321 8912, 2001–5 I.R.B. 452 8913, 2001–3 I.R.B. 300 8914, 2001–8 I.R.B. 653 8915, 2001–4 I.R.B. 359 8916, 2001–4 I.R.B. 360 8917, 2001–7 I.R.B. 538 8918, 2001–4 I.R.B. 372 8919, 2001–6 I.R.B. 505 8920, 2001–8 I.R.B. 654 8921, 2001–7 I.R.B. 532 8922, 2001–6 I.R.B. 508 8923, 2001–6 I.R.B. 485 8924, 2001–6 I.R.B. 489 8925, 2001–6 I.R.B. 496 8926, 2001–6 I.R.B. 492 8928, 2001–8 I.R.B. 685 8930, 2001–5 I.R.B. 433 8931, 2001–7 I.R.B. 542 8935, 2001–8 I.R.B. 702 8936, 2001–9 I.R.B. 720

2001–10 I.R.B. ii March 5, 2001

Treasury Decisions:

8889 Corrected by Ann. 2001–14, 2001–2 I.R.B. 286

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2001–1 through 2001–9

Announcement:

98–99 Modified by Ann. 2001–9, 2001–3 I.R.B. 357

99–79 Superseded by Ann. 2001–3, 2001–2 I.R.B. 278

2000–97 Corrected by Ann. 2001–7, 2001–3 I.R.B. 357

Cumulative Bulletin:

1998–2 Corrected by Ann. 2001–5, 2001–2 I.R.B. 286

Notices:

98–39 Modified by Notice 2001–9, 2001–4 I.R.B. 375

98–40 Modified by Notice 2001–9, 2001–4 I.R.B. 375

99–53 Modified and superseded by Notice 2001–7, 2001–4 I.R.B. 374

2000–21 Superseded by Notice 2001–1, 2001–2 I.R.B. 261

2000–22 Modified and superseded by Notice 2001–8, 2001–4 I.R.B. 374

2000–43 Extended by Notice 2001–13, 2001–6 I.R.B. 514

Proposed Regulations:

EE–130–86 Partially withdrawn by REG–209461–79, 2001–8 I.R.B. 712

REG–116733–98 Withdrawn by Ann. 2001–11, 2001–4 I.R.B. 432

Revenue Procedures:

83–87 Superseded by Rev. Proc. 2001–15, 2001–5 I.R.B. 465

90–18 Amplified and superseded by Rev. Proc. 2001–18, 2001–8 I.R.B. 708

92–19 Superseded by Rev. Proc. 2001–15, 2001–5 I.R.B. 465

96–17 Modified by Rev. Proc. 2001–9, 2001–3 I.R.B. 328

1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2000–27 through 2000–52 is in Internal Revenue Bulletin 2001–1, dated January 2, 2001.

Revenue Procedures–continued:

99–18 Modified and superseded by Rev. Proc. 2001–21, 2001–9 I.R.B. 742

99–47 Superseded by Rev. Proc. 2001–16, 2001–4 I.R.B. 376

99–49 Modified and amplified by Rev. Proc. 2001–10, 2001–2 I.R.B. 272 Rev. Rul. 2001–8, 2001–9 I.R.B. 762

2000–1 Superseded by Rev. Proc. 2001–1, 2001–1 I.R.B. 1

2000–2 Superseded by Rev. Proc. 2001–2, 2001–1 I.R.B. 79

2000–3 Superseded by Rev. Proc. 2001–3, 2001–1 I.R.B. 111

2000–4 Superseded by Rev. Proc. 2001–4, 2001–1 I.R.B. 121

2000–5 Superseded by Rev. Proc. 2001–5, 2001–1 I.R.B. 164

2000–6 Superseded by Rev. Proc. 2001–6, 2001–1 I.R.B. 194

2000–7 Superseded by Rev. Proc. 2001–7, 2001–1 I.R.B. 236

2000–8 Superseded by Rev. Proc. 2001–8, 2001–1 I.R.B. 239

2000–16 Modified and superseded by Rev. Proc. 2001–17, 2001–7 I.R.B. 589

2000–22 Modified and superseded by Rev. Proc. 2001–10, 2001–2 I.R.B. 272

2001–13 Clarified by Notice 2001–12, 2001–3 I.R.B. 328

Revenue Rulings:

64–328 Modified by Notice 2001–10, 2001–5 I.R.B. 459

66–110 Modified by Notice 2001–10, 2001–5 I.R.B. 459

85–30 Clarified by Rev. Rul. 2001–8, 2001–9 I.R.B. 762

88–95 Clarified by Rev. Rul. 2001–8, 2001–9 I.R.B. 762

March 5, 2001 iii 2001–10 I.R.B.

Internal Revenue Bulletins 2001-1 through 2001-9

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

Key to Abbreviations: Ann Announcement CD Court Decision DO Delegation Order EO Executive Order PL Public Law PTE Prohibited Transaction

Exemption

RP Revenue Procedure RR Revenue Ruling SPR Statement of Procedural

Rules TC Tax Convention TD Treasury Decision TDO Treasury Department Order

Advance letter rulings and determination

Group health plans:

Continuation coverage requirements

(TD 8928) 8, 685 HIPAA nondiscrimination:

Bona fide wellness programs

(REG–114084–00) 7, 633 Certain grandfathered church plans,

exception (REG–114083–00) 7, 630 Eligibility not limited by certain

26 CFR 54.4980B–0 through –8, amended; 54.4980B–9, –10, added; group health plans, continuation coverage requirements (TD 8928) 8, 685 26 CFR 54.9802–1, added; 54.9802–1T, removed; group health plans, HIPAA nondiscrimination requirements, eligibility not limited by certain health factors (TD 8931) 7, 452 Technical advice to:

health factors (TD 8931) 7, 452 ; (REG– 114082–00) 7, 629 GUST remedial amendment period, M&P

plans and volume submitter plans (Ann 12) 6, 526 Letter rulings:

Directors and chiefs, appeals offices,

Determination letters, and information

from Associates Chief Counsel & Division Counsel/Associate Chief Counsel (TE/GE) (RP 2) 1, 79 IRS employees (RP 5) 1, 164 User fees, request for letter rulings (RP 8)

1, 239

Electronic filing, Form 940 (RP 9) 3, 328 Forms:

940, electronic filing (RP 9) 3, 328 W-2, new code (Ann 7) 3, 357 Indian tribal governments under FUTA,

letters, areas which will not be issued from:

treatment of (Ann 16) 8, 715 Proposed Regulations:

Associates Chief Counsel & Division

Counsel/Associate Chief Counsel

(TE/GE) (RP 3) 1, 111 Associate Chief Counsel International

letters issued by Associates Chief Counsel (RP 1) 1, 1 Information letters, etc. (RP 4) 1, 121 Life insurance contracts, “split-dollar”

arrangements (Notice 10) 5, 459 Nondiscrimination rules, governmental

and church plans, relief from (Notice 9) 4, 375 Proposed Regulations:

26 CFR 1.125–1 Q&A–8, amended; 1.125–2 Q&A–6(a), amended; 1.125–2 Q&A–6(b), (c), and (d), withdrawn; 1.125–2 Q&A–6(e), redignated as (b); tax treatment of cafeteria plans (REG–209461–79) 8, 712 26 CFR 1.420–1, added; defined benefit pension plan, transfer of excess assets (REG–116468–00) 6, 522 26 CFR 54.9802–1, amended; group health plans, HIPAA nondiscrimination requirements, eligibility not limited by certain health factors (REG–114082–00) 7, 629 26 CFR 54.9802–1(f), amended; group health plans, HIPAA nondiscrimination requirements, bona fide wellness programs (REG–114084–00) 7, 633 26 CFR 54.9802–2, added; group health plans, HIPAA nondiscrimination requirements for certain grandfathered church plans, exception (REG–114083–00) 7, 630 Regulations:

26 CFR 31.6302–1, amended; 31.6302(c)–3, amended; removal of Federal Reserve banks as federal depositaries (REG–107176–00) 4, 428 Railroad retirement, rate determination,

quarterly, January 1, 2001, 2, 258 Regulations:

(RP 7) 1, 236 Cafeteria plans, tax treatment of (TD

8921. 7, 532 ; (REG–209461–79) 8, 712 Defined benefit pension plan, transfer of

excess assets (REG–116468–00) 6, 522 Determination letters, issuing procedures

(RP 6) 1, 194 Employee Plans Compliance Resolution

System (EPCRS), update (RP 2001–17) 7, 589 Employee stock ownership plans, deductibility of redemption proceeds (RR 6) 6, 491 Full funding limitations:

26 CFR 1.125–4, amended; 1.125–4T, removed; tax treatment of cafeteria plans (TD 8921) 7, 532

26 CFR 31.6053–1,–4, amended; tips, tip reporting, employer established electronic systems (TD 8910) 2, 258 Statutory stock options (Notice 14) 6, 516 Tips:

Tips reporting:

Weighted average interest rate for:

Employer-designed tip reporting,

food and beverage industry (EmTRAC) programs (Notice 1) 2, 261 Employer established electronic sys tems (TD 8910) 2, 258 Voluntary tip reporting agreements

proformas (TRDA and TRAC) (Ann 1) 2, 277

December 2000 (Notice 3) 2, 267 January 2001 (Notice 15) 7, 589

2001–10 I.R.B. iv March 5, 2001

Charitable deductions, guaranteed annuity

and unitrust interest (TD 8923) 6, 485 Generation-skipping transfer tax and

retention of exempt status (TD 8912) 5, 452 Proposed Regulations:

26 CFR 1.641(b)–3, amended; 1.642(c)–1, revised; 1.645–1, added; 1.671–4, amended; 1.6072–1, amended; 301.6109–1, amended; election to treat trust as part of an estate (REG–106542–98) 5, 473 Regulations:

26 CFR 20.2055–2, amended; charitable deductions, guaranteed annuity and unitrust interest (TD 8923) 6, 485 26 CFR 26.2601–1, amended; generation-skipping transfer issues (TD 8912) 5, 452 Trusts, election to treat trust as part of an

estate (REG–106542–98) 5, 472

Directors and chiefs, appeals offices,

Indian tribal governments treated as

states, list (RP 15) 5, 465 Letter rulings, information letters, etc.

(RP 4) 1, 121 Plain language publications and voluntary

compliance programs (Ann 14) 7, 648 Proposed Regulations:

26 CFR 53.4958–0 through –8, added; excise taxes on excess benefit transactions (REG–246256–96) 8, 713 Regulations:

26 CFR 53.4958–0T through –8T, added; 53.4963–1, amended; 301.6213–1, amended; 301.6501 (e)–1, amended; 301.6501(n)–1, amended; 301.7422–1, amended; 301.7454–2, amended; 301.7611–1, amended; 602.101, amended; excise taxes on excess benefit transactions (TD 8920) 8, 654 Revocations (Ann 20) 8, 716 Technical advice to :

procedure (Ann 9) 3, 357 Archer MSA (Ann 21) 9, 752 Attorney’s fees, recovery of (TD 8922) 6,

508 ; (REG–121928–98) 6, 520 Automobile owners and lessees, determi nation of correct tax liability, 2001 inflation adjustment (RP 19) 9, 732 Case Resolution Pilot Program, extension

(Notice 13) 6, 514 Charitable deductions, transfers to chari table lead trust (TD 8923) 6, 485 Contribution in aid of construction

(CIAC), regulated public utilities, water or sewerage disposal (TD 8936) 9, 720 Corporations:

Assumed liabilities (TD 8924) 6, 489 ;

(REG–106791–00) 6, 521 Consolidated groups, tentative carry back adjustments (TD 8919) 6, 505 ; (REG–119352–00) 6, 525 Distributions of stock or securities in

connection with an acquisition:

Purchase of 50% or greater interest

in the corporation making the distribution or being distributed (REG–107566–00) 3, 346 Withdrawal of REG–116733–98

Air transportation, mileage awards (Notice

6. 3, 327 Excess benefit transactions (TD 8920) 8,

654 ; (REG–246256–96) 8, 713 Proposed Regulations:

26 CFR 53.4958–0 through –8, added; excise taxes on excess benefit transactions (REG–246256–96) 8, 713 Regulations:

from Associates Chief Counsel & Division Counsel/Associate Chief Counsel (TE/GE) (RP 2) 1, 79 IRS employees (RP 5) 1, 164 User fees, request for letter rulings (RP 8)

1, 239 Withholding, Voluntary Compliance on

Alien Withholding Program (VCAP) (RP 20) 9, 738

(Ann 11) 4, 432 Recognition of gain on certain distribu tions of stock or securities (TD 8913) 3, 300 Tax shelter:

Contingent liability (Notice 17) 9, 730 Intermediary transactions (Notice

26 CFR 53.4958–0T through –8T, added; 53.4963–1, amended; 301.6213–1, amended; 301.6501(e) –1, amended; 301.6501 (n)–1, amended; 301.7422–1, amended; 301.7454–2, amended; 301.7611–1, amended; 602.101, amended; excise taxes on excess benefit transactions (TD 8920) 8, 654

Charitable deductions, transfers to chari

table lead trust (TD 8923) 6, 485 Regulations:

26 CFR 25.2522(c)–3, amended; charitable deductions, lifetime charitable lead trust (TD 8923) 6, 485

16. 9, 730 Cost-of-living adjustments for inflation,

2001 (RP 13) 3, 337 ; clarified (Notice 12) 3, 328 Credits:

Deemed-paid credit computations (REG–104683–00) 4, 407 Foreign tax credit limitations:

Advance letter rulings and determination

Affiliated groups and interest expense

allocations (TD 8916) 4, 360 Income subject to separate limita

Advance letter rulings and determination

letters, areas which will not be issued from Associates Chief Counsel & Division Counsel/Associate Chief Counsel (TE/GE) (RP 3) 1, 111 Excise taxes on excess benefit transactions

(TD 8920) 8, 654 ; (REG–246256–96) 8, 713

(RP 7) 1, 236 Aircraft maintenance costs (RR 4) 3, 295 Appeals, extension of test of mediation

letters, areas which will not be issued from:

Associates Chief Counsel & Division

Counsel/Associate Chief Counsel

(TE/GE) (RP 3) 1, 111 Associate Chief Counsel International

tions (REG–104683–00) 4, 407 Increasing research activities, defini tion of qualified research (TD 8930) 5, 433 Low-income housing credit:

Satisfactory bond; “bond factor”

amounts for the period October through December 2000 (RR 2) 2, 255

March 5, 2001 v 2001–10 I.R.B.

Research credit (Notice 2) 2, 265 Cumulative Bulletin 1998-2, numerical

finding list, finding list of current actions on previously published items and index; corrections (Ann 5) 2, 286 Debt substitution, election to treat as real ization event (RP 21) 9, 742 Disclosure of returns or return informa tion to designee of taxpayer (TD 8935) 8, 702 ; (REG–103320–00) 8, 714 Earnings and profits adjustments, exercise

Interest:

Investment:

Federal short-term, mid-term, and

long-term rates for:

January 2001 (RR 3) 3, 319 February 2001 (RR 7) 7, 541 Inventory:

Floor stocks payments (RR 8) 9, 726 LIFO:

Price indexes, department stores for:

revised; 1.904(b)–1, –2, revised; 1.904(b)–3, –4, removed; 1.904(j)–1, added; application of section 904 to income subject to separate limitations and computations of deemed paid credit under section 902 (REG–104683–00) 4, 407 26 CFR 1.1502–78, amended; corporations, consolidated groups, tentative carryback adjustments (REG–119352–00) 6, 525 26 CFR 1.6302–1, –2, amended; 31.6302–1, amended; 31.6302(c)–3, amended; removal of Federal Reserve banks as federal depositaries (REG–107176–00) 4, 428 26 CFR 301.6103(c)–1, added; disclosure of return and return information to designee of taxpayer (REG–103320–00) 8, 714 26 CFR 301.7430–0, removed; 301.7430–7, added; attorney’s fees, recovery of (REG–121928–98) 6, 520 Publications:

547, Casualties, Disasters, and Thefts, revised (Ann 6) 3, 357 551, Basis of Assets, revised 2000 (Ann 2) 2, 277 583, Starting a Businesss and Keeping Records, revised (Ann 8) 3, 357 1245, Specifications for Filing Forms W-4, Employee’s Withholding Allowance Certificate, magnetically or electronically (RP 6) 4, 376 Qualified zone academy bonds, limitation

for 2001 (RP 14) 3, 343 Real estate mortgage investment conduits

(REMICs), safe harbor (RP 12) 3, 335 Regulations:

26 CFR 1.41–0, –1, –4, revised; 1.41–2, amended; 1.41–3, redesignated as 1.41–3A; 1.41–3, added; 1.41–5, redesignated as 1.41–4A, amended; 1.41–6, redesignated as 1.41–5, amended; 1.41–7, redesignated as 1.41–5A, amended; 1.41–8, redesignated as 1.41–6, amended; 1.41–9, redesignated as 1.41–7; 1.41–8, added; 1.41–0A through –8A, removed; 1.41–0A, added; 1.218–0, removed; 1.482–7, amended; credit for increasing research activities (TD 8930) 5, 433

of stock option (RR 1) 9, 726 Electing small business trusts; ESBT:

Qualifications and treatments (REG–

November 2000 (RR 5) 5, 451 December 2000 (RR 9) 8, 652 Last known address (RP 18) 8, 708 Letter rulings, determination letters, and

information letters issued by Associates Chief Counsel (RP 1) 1, 1 Life insurance contracts, “split-dollar”

arrangements (Notice 10) 5, 459 Methods of accounting, inventories, small

251701–96) 4, 396 Tiered structures (TD 8915) 4, 359 Electronic filing; magnetic media, Form

W-4, Employee’s Withholding Allowance Certificate, specifications (RP 16) 4, 376 Employee stock ownership plans, deduc tibility of redemption proceeds (RR 6) 6, 491 Federal tax deposits, removal of Federal

Reserve banks as depositaries (TD 8918) 4, 372 ; (REG–107176–00) 4, 428 Financial asset securitization investment

Corporate partner’s stock, partnership

termination (REG–106702–00) 4, 424 Final short-year tax return, determina tion of basis (Notice 5) 3, 327 Mergers and divisions (TD 8925) 6,

taxpayers (RP 10) 2, 272 Partnerships:

trusts (FASITs) (RP 12) 3, 335 Forms:

W-2, new code (Ann 7) 3, 357 W-4, Employee’s Withholding Allow

496 Pre-filing agreement program (RP 22) 9,

745 Presidentially declared disaster and com bat zone, tax related deadlines (TD 8911) 3, 321 Proposed Regulations:

ance Certificate, specifications (RP 6) 4, 376 W-9, Request for Taxpayer Identification Number and Certification (Ann 15) 8, 715 1042S, specifications for filing magnetically or electronically (Ann 3) 2, 278 1120, Schedule N, Foreign Operations of U.S. Corporations (Ann 13) 9, 752 8875, Taxable REIT Subsidiary Election, revised (Ann 17) 8, 716 Hyperinflationary currency, definition of

(TD 8914) 8, 653 Information reporting:

Discharges of indebtedness (Notice 8)

4, 374 Payments to attorneys (Notice 7) 4, 374 Payments of qualified tuition and pay

ments of interest on qualified education loans, magnetic media filing requirements (Ann 10) 4, 431

26 CFR 1.301–1, amended; liabilities assumed in certain corporate transactions (REG–106791–00) 6, 521 26 CFR 1.355–0, amended; 1.355–7, added; recognition of gain on certain distributions of stock or securities in connection with an acquisition (REG–107566–00) 3, 346 26 CFR 1.444–4, added; 1.641(c)–0, –1, added; 1.1361–0, –1, amended; 1.1362–6, –7, amended; 1.1377–1, –3, amended; electing small business trusts (REG–251701–96) 4, 396 26 CFR 1.705–1, amended; 1.705–2, added; basis adjustments upon the sale of a corporate partner’s stock (REG–106702–00) 4, 424 26 CFR 1.902–0, –1, amended; 1.904–0, –4, –5, –6, amended; 1.904–5,

2001–10 I.R.B. vi March 5, 2001

26 CFR 1.118–2, added; contribution in aid of construction (CIAC), regulated public utilities, water or sewerage disposal (TD 8936) 9, 720 26 CFR 1.170A–6, amended; lifetime charitable lead trust (TD 8923) 6, 485 26 CFR 1.301–1, amended; 1.301–1T, added; assumed liabilities (TD 8924) 6, 489 26 CFR 1.355–0, amended; 1.355–6, revised; recognition of gain on certain distributions of stock or securities (TD 8913) 3, 300 26 CFR 1.444–4T, added; ESBT, electing small business trusts, tiered structures (TD 8915) 4, 359 26 CFR 1.467–0, –1, amended; 1.467–2, added; 1.467–3, revised; rental agreements involving payments of $2,000,000 or less (TD 8917) 7, 538 26 CFR 1.643(a)–8, added; 1.664–1, –2, –3, amended; charitable remainder trusts, deemed sale, trust distributions, abusive transactions (TD 8926) 6, 492 26 CFR 1.708–1, amended; 1.752–1, –5, amended; partnership mergers and divisions (TD 8925) 6, 496 26 CFR 1.861–9, –11, –14, added; 1.861–9T, –11T, –14T, revised;

1.902–1, amended; 1.904–0, –4, –5, amended; application of section 904 to income subject to separate limitations and section 864(e) affiliated group expense allocation and apportionment rules (TD 8916) 4, 360 26 CFR 1.894–1, amended; 1.894–1T, removed; guidance regarding claims for certain income tax convention benefits (Ann 4) 2, 286 26 CFR 1.988–1, revised; hyperinflationary currency (TD 8914) 8, 653 26 CFR 1.1502–78T, added; corporations, consolidated groups, tentative carryback adjustments (TD 8919) 6, 505 26 CFR 301.6103(c)–1, removed; 301.6103(c)–1T, added; disclosure of returns or return information to designee of taxpayer (TD 8935) 8, 702 26 CFR 301.6302–1T, added; removal of Federal Reserve banks as depositaries (TD 8918) 4, 372 26 CFR 301.7430–7T, added; attorney’s fees, recovery of (TD 8922) 6, 508 26 CFR 301.7508–1, added; 301.7508 A–1, added; for combat zone service or Presidentially declared disasters,

tax related deadlines (TD 8911) 3, 321 Rental agreements (TD 8917) 7, 538 Substantial understatement penalty, ade quate disclosure (RP 11) 2, 275 Tax convention, claims for benefits (Ann 4)

2, 286 Tax shelters, leasing transactions, excep tions (Notice 18) 9, 731 Technical advice to directors and chiefs,

appeals offices, from Associates Chief Counsel and Division Counsel/ Associate Chief Counsel (TE/GE) (RP 2) 1, 79 Trusts:

Charitable remainder trusts, deemed

sale, trust distributions, abusive transactions (TD 8926) 6, 492 Election to treat trust as part of an

estate (REG–106542–98) 5, 472 Withholdings:

Payments to financial institutions in

U.S. possessions (Notice 11) 5, 464 Qualified intermediary agreements,

clarifications (Notice 4) 2, 267 Voluntary Compliance on Alien Withholding Program (VCAP) (RP 20) 9, 738

March 5, 2001 vii 2001–10 I.R.B.

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