INCOME TAX

T.D. 8981, page 496. REG–107100–00, page 529. Final, temporary and proposed regulations under sections 874 and 882 of the Code relate to the disallowance of deductions and credits for nonresident alien individuals and foreign corporations that fail to file a timely U.S. income tax return unless the Commissioner waives the filing deadlines. The temporary regulations revise the waiver standard. A public hearing on the proposed regulations is scheduled for June 3, 2002.

REG–115054–01, page 530. Proposed regulations under section 66 of the Code relate to the treatment of community income for certain married individuals in community property states who do not file joint individual federal income tax returns. The regulations also reflect changes in the law made by the Internal Revenue Service Restructuring and Reform Act of 1998.

Notice 2002–11, page 526. Loss disallowance. This notice sets forth the Service’s new position with regard to consolidated return loss disallowance rules.

Rev. Proc. 2002–11, page 526. Dealer in securities futures contracts. This procedure provides guidelines for an exchange to follow in order to obtain a letter ruling regarding whether certain persons trading on that exchange qualify as “dealers” in securities futures contracts (or options on such contracts) for purposes of section 1256(g)(9) of the Code. Also, after issuance of a specific letter ruling determining dealer status, the Service expects to publish the same conclusion in a revenue ruling.