INCOME TAX

REG–103033–11, page 325. This document contains proposed regulations that provide guidance regarding the amount of the penalty under section 6707A of the Internal Revenue Code (Code) for failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction.

REG–109813–11, page 330. These proposed regulations would make it easier for individuals to satisfy the presence test for qualifying as a bona fide resident of a U.S. possession or territory under section 937(a). In counting days of presence in the possession under the presence test, the proposed regulations generally would allow an individual to include up to 30 days that the individual was outside the possession and the United States, provided that the individual was present for more days in the possession than in the United States.

REG–136459–09, page 332. The proposed regulations provide guidance to taxpayers on the amendments made to section 199 by the Energy Improvement and Extension Act of 2008 and the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, involving oil related qualified production activities income and qualified films, and the American Taxpayer Relief Act of 2012, involving activities in Puerto Rico. The proposed regulations also provide guidance on (1) determining domestic production gross receipts, (2) the terms manufactured, produced, grown, or extracted, (3) contract manufacturing, (4) hedging transactions, (5) construction activities, (6) allocating cost of goods sold, and (7) agricultural and horticultural cooperatives.

Finding Lists begin on page ii.