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. 9653, page 460. Final regulation that provide guidance on the tax treatment of a debt instrument with a bond premium carryforward in the holder’s final accrual period, including a Treasury bill acquired at a premium.

T.D. 9654, page 461. This regulation identifies certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of whether it is a surrogate foreign corporation under section 7874 and provides guidance under section 7874 with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of a domestic corporation or of trade or business of a domestic partnership. Notice 2009–78 (2009–40 IRB 452) superseded.

REG–121534–12, page 473. Notice of proposed rulemaking by cross-reference to temporary regulations that identify certain stock of a foreign corporation that is disregarded in calculating ownership of the foreign corporation for purposes of whether it is a surrogate foreign corporation under section 7874 and provide guidance under section 7874 with respect to the effect of transfers of stock of a foreign corporation after the foreign corporation has acquired substantially all of the properties of domestic corporation or of a trade of business of a domestic partnership. Comments and requests for a public hearing must be received by April 17, 2014.

REG–154890–03, page 504. This notice of proposed rulemaking (NPRM) provides rules for determining a taxable beneficiary’s basis in a term interest in a charitable remainder trust upon a sale or other disposition of all

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