INCOME TAX—Cont. INCOME TAX—Cont. INCOME TAX—Cont.

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 ; correction (Ann 41) 18, 1147 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 1.925(a)–1, added; 1.925(a)–1T, amended; 1.925(b)–1T, amended; foreign sales corporation transfer pricing, grouping rules (TD 8944) 16, 1067 26 CFR 1.985–1, –4, amended; 1.985–8, added; 1.985–8T, removed; 1.1001–5, added; 1.1001–5T, removed; conversion to the euro (TD 8927) 11, 807 26 CFR 1.988–1, revised; hyperinflationary currency (TD 8914) 8, 653 26 CFR 1.1441–1, –5, –7, corrected; 1.1461–1, corrected; 1.6045–1, corrected; 1.6049–5, corrected; U.S. source income paid to foreign persons; reporting and recordkeeping requirements (Ann 55) 21, 1284 26 CFR 1.1502–78T, added; corporations, consolidated groups, tentative carryback adjustments (TD 8919) 6, 505 26 CFR 1.6041–2T, added; 1.6050S– 1T, –2T, added; 301.6724–1T, added; 602.101, amended; electronic payee statements, voluntary (TD 8942) 13, 929 26 CFR 7.367(c)–1, –2, removed; requirements relating to certain exchanges involving a foreign corporation (TD 8938) 13, 929 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 301.6103(j)(1)(1)–1T, added; disclosure of return information to the Bureau of the Census (TD 8943) 15, 1054 26 CFR 301.6302–1T, added; removal of Federal Reserve banks as depositaries (TD 8918) 4, 372

51. 20, 1185 Supplemental rules (Ann 27) 11, 897 Transition rules (TD 8937) 11, 806 Straddles; capitalization of interest and

26 CFR 301.7430–7T, added; attorney’s fees, recovery of (TD 8922) 6, 508 26 CFR 301.7502–1, revised; 301.7502–1T, removed; 301.7502 –2, added; timely mailing treated as timely filing (TD 8932) 11, 813 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 Reopenings, debt instruments, Treasury

securities, original issue discount (TD 8934) 12, 904 Reporting requirements for interest on

deposits paid to nonresident aliens (REG–126100–00) 11, 862 Revocations, exempt organizations (Ann

20. 8, 716 ; (Ann 36) 16, 1089 ; (Ann
21. 19, 1165 ; (Ann 67) 26, 1357 Ruling guidelines, leveraged leasing

transactions (RP 28) 19, 1156 ; (RP 29) 19, 1160 S Corporations, pass-through items, dis charge of indebtedness (CD 2069) 21, 1191 Section 911(d)(4) waiver, 2000 update

(RP 27) 19, 1155 Short-term leases, qualified lessee con struction allowances for (RR 20) 18, 1144 Short-term loans, stated interest, cash

method banks, automatic change (RP 25) 12, 913 Source of income from space and ocean

activities, communications activities (REG–106030–98) 11, 820 ; correction (Ann 30) 15, 1065 Specifications for filing Form 8851,

Summary of Archer MSAs magnetically or electronically (RP 31) 20, 1170 Standard Industry Fare Level (SIFL) for mula (RR 13) 12, 898 States and political subdivisions, obliga tions of (TD 8941) 14, 977 ; (REG–114998–99) 14, 992 Stock transfer rules:

carrying charges (REG–105801–00) 13, 965 Substantial understatement penalty, ade quate disclosure (RP 11) 2, 275 Substitute forms, W-2 and W-3, specifica tions for private printing (RP 26) 17, 1093 Tax convention, claims for benefits (Ann

4. 2, 286 Tax shelters:

Leasing transactions, exceptions (Notice 18) 9, 731 New address for filing application for

registration (Ann 62) 24, 1337 Technical advice to directors and chiefs,

appeals offices, from Associates Chief Counsel and Division Counsel/ Associate Chief Counsel (TE/GE) (RP 2) 1, 79 Timely mailing treated as timely filing

(TD 8932) 11, 813 Treaty benefits, eligibility of items of

income paid by a domestic reverse hybrid entity (REG–107101–00) 16, 1083 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, 473 ; correction (Ann 24) 10, 793 ESBTs, electing small business trusts,

estimated tax payments (Notice 25) 13, 941 Qualified revocable trust treated as part

of an estate (Notice 26) 13, 942 U.S.-source income:

Frivolous filing position based on sec tion 861 (Notice 40) 26, 1355 Paid to foreign persons, reporting and

recordkeeping requirements (Ann 55) 21, 1284 Valuation of art requests, change of

address for submissions (Ann 22) 11, 895 Withholdings:

Carryover of earnings and taxes (Ann

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

2001–27 I.R.B. xiii July 2, 2001