INCOME TAX

Rev. Rul. 2004–46, page 915. Royalties; information reporting. This ruling provides guidance concerning the reporting requirements of sections 6041 and 6050N of the Code for payments by publishers to literary agents on behalf of an author.

T.D. 9121, page 903. REG–139792–02, page 926. Final, temporary, and proposed regulations under section 704(b) of the Code provide guidance on the proper allocation of certain foreign tax expenditures of a partnership. A public hearing on the proposed regulations is scheduled for September 14, 2004.

T.D. 9123, page 907. Final regulations under section 1296 of the Code provide procedures for certain U.S. persons holding marketable stock in a passive foreign investment company (PFIC) to elect mark to market treatment for that stock under section 1296 and related provisions of sections 1291 and 1295.

T.D. 9124, page 901. Final regulations provide that all activities are subject to the rule under section 465 of the Code that amounts borrowed from a person who has an interest in an activity other than that of a creditor or from a person related to a person (other than the borrower) with such an interest do not increase the amount at risk in the activity.

REG–116564–03, page 927. Proposed regulations under section 358 of the Code adopt a tracing approach in determining the basis of stock and securities received in transactions under sections 355, 368, and certain transactions that qualify under both section 351 and section 368.

Finding Lists begin on page ii.