INCOME TAX

T.D. 9614, page 947. Final and temporary regulations provide an exception to the general rule under section 367(a)(5) of the Code, which generally causes gain to be recognized on transfers otherwise not taxable under section 361(a) or (b), if certain conditions are satisfied. Section 1248(f) causes an inclusion to domestic corporations that transfer the stock of certain foreign corporations in transfers that would otherwise be tax free under sections 337, 355 or 361(c). Section 1248(f) allows taxpayers to elect out of taxation under regulations and the final regulations provide such an election. Notice 87–64 obsoleted.

Notice 2013–25, page 978. 2012 nonconventional source fuel credit, section 45K inflation adjustment factor, and section 45K reference price. The notice announces the inflation adjustment factor, the reference price, and the credit amount for the nonconventional source fuel credit for coke or coke gas (other than from petroleum based products) for the 2012 calendar year.

Rev. Proc. 2013–23, page 978. Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. A current list of countries for tax year 2012 and the dates those countries are subject to the section 911(d)(4) waiver is provided.

Announcement 2013–27, page 981. This document contains corrections to a notice of proposed rulemaking and notice of public hearing (REG–148500–12, 2013–13 I.R.B. 716) that was published in the Federal Register on Friday, February 1, 2013 (78 FR 7314). The proposed

Finding Lists begin on page ii.