INCOME TAX

Rev. Rul. 2002–31, page 1023. Contingent convertible debt instruments . This ruling provides guidance on the tax treatment of a debt instrument that is convertible into stock of the issuer and that also provides for one or more cash contingent payments.

T.D. 8993, page 1026. Final regulations under section 1275 of the Code provide guidance on the treatment of annuity contracts issued by an insurance company subject to tax under subchapter L.

REG–154920–01, page 1060. Proposed regulations under section 954 of the Code provide that gain or loss arising from certain commodities hedging transactions and currency gain or loss arising from certain interest-bearing liabilities do not constitute (or are not netted against) foreign personal holding company income.