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

REG–131239–13, page 1064. Proposed regulations under section 381 of the Internal Revenue Code modify the definition of an acquiring corporation for purposes of section 381 with regard to certain acquisitions of assets. Written or electronic comments and requests for a public hearing must be received by August 5, 2014.

Announcement 2014–22, page 1066. This document contains corrections to final and temporary regulations (TD 9650) that were published in the Federal Register on Tuesday, December 31, 2013 (78 FR 79602). The regulations provide guidance on determining ownership of a passive foreign investment company (“PFIC”) and on the annual filing requirements for shareholders of PFICs.

Announcement 2014–23, page 1067. This document contains corrections to a notice of proposed rulemaking by cross-reference to temporary regulations (REG– 140974–11) that was published in the Federal Register on Tuesday, December 31, 2013 (78 FR 79650). The proposed regulations provide guidance on determining the ownership of a passive foreign investment company (PFIC), 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.

Rev. Proc. 2014–33, page 1060. This revenue procedure provides the exclusive procedures for taxpayers to obtain the automatic consent of the Commissioner to change a method of accounting for sales-based royalties and sales-based vendor chargebacks to comply with final regulations under §§ 263A and 471 of the Code. The final regulations (TD 9652) were published in the Federal Register on January 13, 2014.

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