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

T.D. 9650, page 394. These temporary and final regulations provide guidance on determining the ownership of a passive foreign investment company, the annual filing requirements for shareholders of PFICs, and an exclusion from certain filing requirements for shareholders that constructively own interests in certain foreign corporations.

REG–140974–11, page 438. This is a notice of proposed rulemaking by cross-reference to temporary regulations. The cross-referenced temporary regulations provide guidance on determining the ownership of a passive foreign investment company, the annual filing requirements for shareholders of PFICs, and an exclusion from certain filing requirements for shareholders that constructively own interests in certain foreign corporations. Comments requested by March 31, 2014.

REG–113350–13, page 440. This document withdraws a portion of proposed regulations issued under section 1291 on April 1, 1992. The withdrawn portion relates to the definitions of the terms pedigreed QEF, section 1291 fund, shareholder, indirect shareholder, and to annual information reporting requirements applicable to certain shareholders of passive foreign investment companies. A portion of REG–209054–87 withdrawn.

Rev. Proc. 2014–12, page 415. This revenue procedure establishes the requirements under which the Internal Revenue Service will not challenge partnership allocations of section 47 credits by a partnership to its partners.

Finding Lists begin on page ii. Index for July through January begins on page iv.