SECTION 4. DEFINITIONS

The following definitions apply for purposes of this revenue procedure.

.01 Foreign-born child . An eligible child (within the meaning of § 23(d)(2)) who is not a citizen or resident of the United States at the time the adoption process commences.

.02 Orphan . A foreign-born child who is under the age of 16 at the time an immigration petition is filed on the child’s behalf, and

(1) who has suffered the death or disappearance of, or abandonment or desertion

CHANGES TO PROPOSED SECTION 10.39 UNDER CONSIDERATION

The Treasury Department and the IRS also are considering other modifications to the requirements for State or local bond opinions in the Proposed Regulations, including, but not limited to: adding a provision that would permit a practitioner under certain circumstances to render an opinion that addresses less than all the significant Federal tax issues raised by a State or local bond issue; and permitting exclusions from the requirements of section 10.39 for opinions that would otherwise be State or local bond opinions if the opinion is a preliminary, post-filing, or negative opinion, or is in-house counsel advice, similar to the exclusions for these opinions from the requirements for covered opinions in section 10.35.

DRAFTING INFORMATION

The principal authors of this notice are Heather L. Dostaler of the Office of Associate Chief Counsel (Procedure & Administration) and Vicki Tsilas of the Office of Associate Chief Counsel (Tax Exempt/Government Entities). For further information regarding this notice, contact Heather L. Dostaler at (202) 622–4940 or Vicki Tsilas at (202) 622–3980 (not tollfree numbers).

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also Part 1, §§ 23, 137.)

Rev. Proc. 2005–31