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–105067–14, page 391. This proposed regulation, which cross-references a temporary regulation under Section 382 of the Code, modifies the effective date of earlier regulations under section 382 (TD 9638, published October 22, 2013) to prevent an adverse effect on certain corporations whose stock was or is owned by the Department of the Treasury and then is sold by Treasury to a public group.

Announcement 2014–28, page 391. Guidance is provided to individuals who fail to meet the eligibility requirements of section 911(d)(1) of the Internal Revenue Code because adverse conditions in a foreign country preclude the individual from meeting those requirements. Rev. Proc. 2014–25 provides a current list of countries for tax year 2013 and the dates those countries are subject to the section 911(d)(4) waiver is provided. That list is incomplete. South Sudan and its departure date have been added.

Notice 2014–45, page 388. This Notice supplements Notice 2014–44 providing guidance concerning section 901(m), particularly with regard to entity classification elections.

Rev. Proc. 2014–45, page 388. This revenue procedure describes the circumstances in which the IRS will not treat a redemption of a money market fund share as part of a wash sale under section 1091 of the Internal Revenue Code.

T.D. 9685, page 379. This temporary regulation under Section 382 modifies the effective date of earlier regulations under section 382 (TD 9638, published October 22, 2013) to prevent an adverse effect on certain corporations whose stock was or is owned by the Department of the Treasury and then is sold by Treasury to a public group.

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