SECTION 12. — Internal Revenue Bulletin 2001-47

	Statute or Regulation	Act Postponed
19.	Sec. 927 and Treas. Reg. § 1.927(f)- 1(a) (Q&A 4)	A transferee or other recipient of shares in the corporation (other than a shareholder that previously consented to the election) must consent to be bound by the prior election within 90 days of the first day of the FSC’s taxable year to preserve the status of a corporation that previously qualified as a FSC or as a small FSC.
20.	Sec. 936 and Treas. Reg. § 1.936-10(c)	If a “qualified investment” in a Caribbean Basin country ceases to meet the qualification requirements, the taxpayer may correct any disqualifying events within a reasonable period of time, which is defined as not more than 60 days from the date that such events came to the attention of the taxpayer (or should have come to its attention by the exercise of reason- able diligence).
21.	Sec. 936 and Treas. Reg. § 1.936-11	A taxpayer that elects retroactive application of the temporary regulation regarding sepa- rate lines of business for taxable years beginning after December 31, 1995, must elect to do so prior to the expiration of the statute of limitations for the year in question.
22.	Treas. Reg. §§ 1.964 - 1(c)(3)(ii) and -1T(g)(2).	An election of, or an adoption of or change in a method of accounting of a CFC (controlled foreign corporation) requires the filing of a written statement jointly executed by the con- trolling U.S. shareholders of the CFC within 180 days after the close of the taxable year of the CFC.
23.	Sec. 982(c)(2)(A)	Any person to whom a formal document request is mailed shall have the right to bring a proceeding to quash such request not later than the 90th day after the day such request was mailed.
24.	Treas. Reg. § 1.988- 1(a)(7)(ii).	An election to have Treas. Reg. § 1.988-1(a)(2)(iii) apply to regulated futures contracts and nonequity options must be made on or before the first day of the taxable year, or if later, on or before the first day during such taxable year on which the taxpayer holds a contract described in section 988(c)(1)(D)(ii) and Treas. Reg. § 1.988-1(a)(7)(ii). A late election may be made within 30 days after the time prescribed for the election.
25.	Sec. 988(c)(1)(E) (iii)(V) (qualified fund) and Treas. Reg. § 1.988- 1(a)(8)(i)(E).	A qualified fund election must be made on or before the first day of the taxable year, or if later, on or before the first day during such taxable year on which the partnership holds an instrument described in section 988(c)(1)(E)(i).
26.	Treas. Reg. § 1.988-3(b)	An election to treat (under certain circumstances) any gain or loss recognized on a contract described in Treas. Reg. § 1.988-2(d)(1) as capital gain or loss must be made by clearly identifying such transaction on taxpayer's books and records on the date the transaction is entered into.
27.	Treas. Reg. § 1.988- 5(a)(8)(i)	Taxpayer must establish a record, and before the close of the date the hedge is entered into, the taxpayer must enter into the record for each qualified hedging transaction the informa- tion contained in Treas. Reg. §§ 1.988-5(a)(8)(i)(A) through (E).
28.	Treas. Reg. § 1.988- 5(b)(3)(i)	Taxpayer must establish a record and before the close of the date the hedge is entered into, the taxpayer must enter into the record a clear description of the executory contract and the hedge.
29.	Treas. Reg. § 1.988- 5(c)(2)	Taxpayer must identify a hedge and underlying stock or security under the rules of Treas. Reg. § 1.988-5(b)(3).
30.	Sec. 991	A corporation that elects IC-DISC treatment (other than in the corporation's first taxable year) must file Form 4876-A, Election To Be Treated as an Interest Charge DISC, with the regional service center during the 90-day period prior to the beginning of the tax year in which the election is to take effect.

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