HIGHLIGHTS OF THIS ISSUE

These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations.

INCOME TAX

Rev. Rul. 2011–26, page 803. Geographical areas included in North American area. This ruling contains an updated list of all geographical areas included in the North American area for purposes of section 274 of the Code. Rev. Rul. 2007–28 superseded.

Rev. Rul. 2011–27, page 805. Section 1274A – inflation adjusted numbers for 2012. This ruling provides the dollar amounts, increased by the 2012 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2010–30 supplemented and superseded.

REG–146537–06, page 813. Proposed regulations under section 892 of the Code relate to the taxation of certain investment income earned by foreign governments in the United States.

REG–114749–09, page 819. Proposed regulations under section 964 of the Code clarify and add examples illustrating the application of final regulations relating to the procedures for U.S. shareholders of foreign corporations to make tax accounting elections on behalf of the foreign corporations for purposes of computing the foreign corporation’s earnings and profits for U.S. tax purposes. The regulations also update the rules relating to required book-to-tax adjustments in respect of depreciation and amortization and contain a rule related to mandated changes in methods of accounting in connection with an audit or audits of a foreign corporation’s controlling domestic shareholders.

Announcement 2011–73, page 822. This announcement notifies taxpayers that the Service has withdrawn Weld Rite, Inc.’s right to certify its hydronic outdoor

Finding Lists begin on page ii. Index for July through November begins on page v.