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SECTION 1. PURPOSE
Internal Revenue Bulletin 2001-23 · 2026-10-03 edition · updated 2026-10-04 · United States
T his revenue procedure provides guidance to taxpayers regarding certain elections made pursuant to the FSC Repeal
and Extraterritorial Income Exclusion Act
of 2000 (the “Act”). Pub. L. No.
106–519, 114 Stat. 2423 (Nov. 15, 2000).
Specifically, this revenue procedure includes guidance with respect to the election to exclude gross receipts from foreign trading gross receipts under
§ 942(a)(3) of the Internal Revenue Code
(“Code”), the election (and revocation of
such election) by a foreign corporation to
be treated as a domestic corporation under
§ 943(e)(1), and the election (and revocation of such election) by a taxpayer to
apply the extraterritorial income exclu
2001–23 I.R.B. 1327 June 4, 2001
sion (the “ETI exclusion”) in lieu of the foreign sales corporation (“FSC”) provisions to certain transactions under § 5(c)(2) of the Act.
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