INCOME TAX

T.D. 8944, page 1067. Final regulations and amendments to temporary regulations under section 925 of the Code provide guidance to taxpayers that have made an election to be treated as a foreign sales corporation (FSC). These regulations permit the grouping of transactions for purposes of applying the administrative pricing (including marginal costing) rules to determine FSC transfer prices and provide a time for filing for the election to group transactions.

REG–105946–00, page 1069. Proposed regulations under section 460 of the Code provide guidance regarding changes in the taxpayer accounting for a long-term contract that has been accounted for under a long-term contract method. A public hearing is scheduled for June 13, 2001.

REG–106513–00, page 1076. Proposed regulations under section 643 of the Code and related sections relate to the definition of income for trust purposes. A public hearing is scheduled for June 8, 2001.

REG–107101–00, page 1083. Proposed regulations under section 894 of the Code relate to the eligibility for treaty benefits of items of income paid by domestic entities that are not fiscally transparent under U.S. law but are fiscally transparent under the laws of the jurisdiction of the person claiming treaty benefits (a domestic reverse hybrid entity). This is the corrected version of what was published in the Federal Register on February 27, 2001. A public hearing is scheduled for June 26, 2001.

Finding Lists begin on page ii.

Department of the Treasury Internal Revenue Service