INCOME TAX—Cont.

26 CFR 301.7701–2, –2T, amended; classification of definitions (TD 9235) 4, 338 26 CFR 301.7701–3T, added; deemed election to be an association taxable as a corporation for a qualified electing S corporation, correction to TD 9203 (Ann 12) 6, 421 Reporting requirements for widely held fixed investment trusts

(TD 9241) 7, 427 Revocations, exempt organizations (Ann 3) 3, 327 ; (Ann 9) 5,

392 ; (Ann 13) 7, 462 ; (Ann 17) 12, 653 Section 1503(d) filings, adoption of reasonable cause standard

(Notice 13) 8, 496 Standard Industry Fare Level (SIFL) formula (RR 13) 13, 656 Stocks:

Cross border section 304 transactions, application of section

367 (TD 9250) 11, 588 Determination of basis of stock and securities received in cer tain transactions (TD 9244) 8, 463 Outstanding stock rights, application of section 409A (Notice

4. 3, 307 Treatment of excess loss accounts (TD 9244) 8, 463 ;

(REG–138879–05) 8, 503 Substitute for return, Internal Revenue officer or employee, hear ing on REG–131739–03 (Ann 10) 5, 393 Substitute Forms W-2c and W-3c, general rules and specifica tions (RP 19) 13, 677 Tax conventions:

Superseding U.S.-Mexico LLC mutual agreement procedure

(MAP) (Ann 8) 4, 344 U.S.-Canada Appeals memorandum of understanding (MOU)

(Ann 7) 4, 342 U.S.-Ireland Common Contractual Funds MAP (Ann 19) 13,

674 U.S.-Japan Investment Bank MOU (Ann 6) 4, 340 ; self-certi fication of resident investment banks (Ann 20) 13, 675 Tax returns and return information, administrative review if re cipient failed to safeguard information (TD 9252) 12, 633 ; (REG–157271–05) 12, 652 Technical Advice Memoranda (TAMs) and Technical Expedited

Advice Memoranda (TEAMs) (RP 2) 1, 89 Waiver of penalties for failure to report loan origination fees and

capitalized interest (Notice 5) 4, 348