INCOME TAX—Cont.

Per diem allowances, 2004 (RP 80) 45,

1037 California franchise tax, accrual of liabil ities (RR 90) 33, 353 Capital gain reporting for 2002–2003 fis cal year entities (Ann 56) 39, 694 Charitable guaranteed annuity and uni trust interests, requirements for qualification (TD 9068) 37, 538 Charitable remainder annuity trusts:

Inter vivos:

For a term of years (RP 54) 31, 236 For one measuring life (RP 53) 31,

230 With concurrent and consecutive in terests for two measuring lives (RP 56) 31, 249 With consecutive interests for two

measuring lives (RP 55) 31, 242 Testamentary:

For a term of years (RP 58) 31, 262 For one measuring life (RP 57) 31,

257 With concurrent and consecutive in terests for two measuring lives (RP 60) 31, 274 With consecutive interests for two

measuring lives (RP 59) 31, 268 Child’s attainment of an age (RR 72) 33,

346 Common trust fund, listed transaction,

straddle, tax shelter (Notice 54) 33, 363 Compliance initiative, nonresident aliens

and foreign corporations (Notice 38) 27, 9 Consumer Price Index (CPI) adjustments:

Below-market loans under section 7872(g) for 2004 (RR 118) 47, 1095 Certain loans under section 1274A for

2004 (RR 119) 47, 1094 Controlled foreign corporations, insur ance business treated as a domestic corporation (RP 47) 28, 55 Corporations:

Distributions of interests in a loss cor poration from qualified trusts (TD 9063) 36, 510 ; (REG–108676–03) 36, 523 Effect of section 338(h)(10) elec tions in certain multi-step transactions (TD 9071) 38, 560 ; (REG–143679–02) 38, 592 Outbound liquidations to foreign cor porations (TD 9066) 36, 509

2003-47 I.R.B. xii November 24, 2003