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Bulletin No. 1996–22

May 28, 1996

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.

SPECIAL ANNOUNCEMENTS

TAX CONVENTIONS

Announcement 96–48, page 10.

A public hearing will be held on June 24, 1996, on

proposed regulations relating to when amounts deferred

or paid from certain retirement plans are taken into

account as ‘‘wages’’ for FICA and FUTA purposes.

Notice 96–31, page 7.

This notice clarifies the application of the U.S.-Canada

Income Tax Convention, as revised by the Protocol

dated March 17, 1995, to Canadian Registered

Retirement Savings Plans, Canadian Registered Retirement Income Funds and the beneficiaries of both.

Announcement 96–49, page 10.

A public hearing will be held on June 28, 1996, on

proposed regulations relating to loans made from a

qualified employer plan to plan participants or

beneficiaries.

ADMINISTRATIVE

Notice 96–33, page 8.

T.D. 8618, 1995–40 I.R.B. 4, relating to final

regulations governing the definitions of a controlled

foreign corporation, foreign base company income, and

foreign personal holding company income of a controlled foreign corporation, is corrected.

INCOME TAX

T.D. 8668, page 4.

Final regulations under section 7701 of the Code relate

to the classification of certain organizations as trusts

for federal tax purposes.

Rev. Proc. 96–33, page 8.

Section 911(d)(4) waiver Rev. Proc. Guidance is

provided to individuals who fail to meet the eligibility

requirements of section 911(d)(1) of the Code because

adverse conditions in the foreign country preclude the

individual from meeting those requirements. A current

list of countries and the dates those countries are

subject to the section 911(d)(4) waiver is provided.

EMPLOYEE PLANS

Notice 96–32, page 7.

Guidelines are set forth for determining for May 1996,

the weighted average interest rate and the resulting

permissible range of interest rates used to calculate

current liability for purposes of the full funding

limitation of section 412(c)(7) of the Code as amended

by the Omnibus Budget Reconciliation Act of 1987 and

by the Uruguay Round Agreements Act (GATT).

Announcement 96–47, page 10.

Form 3115, Application for Change in Accounting

Method, and its instructions are approved by the Office

of Management and Budget through May 31, 1999,

and are available.

EXEMPT ORGANIZATIONS

Announcement 96–50, page 11.

T.D. 8658, 1996–13 I.R.B. 9, providing guidance on

the imposition of the accuracy-related penalty, is

corrected.

Announcement 96–52, page 12.

A list is provided of organizations that no longer qualify

as organizations to which contributions are deductible

under section 170 of the Code.

Announcement 96–51, page 11.

T.D. 8657, 1996–14 I.R.B. 4, final regulations relating

to the determination of effectively connected income;

and final and temporary regulations relating to the

branch-level interest tax, is corrected.

Finding Lists begin on page 16.

Announcement of Disbarments and Suspensions begins on page 13.

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Mission of the Service

The purpose of the Internal Revenue Service is to

collect the proper amount of tax revenue at the least

cost; serve the public by continually improving the

quality of our products and services; and perform in a

manner warranting the highest degree of public

confidence in our integrity, efficiency and fairness.

Statement of Principles

of Internal Revenue

Tax Administration

The function of the Internal Revenue Service is to

administer the Internal Revenue Code. Tax policy

for raising revenue is determined by Congress.

With this in mind, it is the duty of the Service to

carry out that policy by correctly applying the laws

enacted by Congress; to determine the reasonable

meaning of various Code provisions in light of the

Congressional purpose in enacting them; and to

perform this work in a fair and impartial manner,

with neither a government nor a taxpayer point of

view.

At the heart of administration is interpretation of the

Code. It is the responsibility of each person in the

Service, charged with the duty of interpreting the

law, to try to find the true meaning of the statutory

provision and not to adopt a strained construction in

the belief that he or she is ‘‘protecting the revenue.’’

The revenue is properly protected only when we ascertain and apply the true meaning of the statute.

The Service also has the responsibility of applying

and administering the law in a reasonable,

practical manner. Issues should only be raised by

examining officers when they have merit, never

arbitrarily or for trading purposes. At the same

time, the examining officer should never hesitate

to raise a meritorious issue. It is also important

that care be exercised not to raise an issue or to

ask a court to adopt a position inconsistent with

an established Service position.

Administration should be both reasonable and

vigorous. It should be conducted with as little

delay as possible and with great courtesy and

considerateness. It should never try to overreach,

and should be reasonable within the bounds of law

and sound administration. It should, however, be

vigorous in requiring compliance with law and it

should be relentless in its attack on unreal tax

devices and fraud.

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Introduction

The Internal Revenue Bulletin is the authoritative

instrument of the Commissioner of Internal Revenue for

announcing official rulings and procedures of the

Internal Revenue Service and for publishing Treasury

Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general

interest. It is published weekly and may be obtained

from the Superintendent of Documents on a subscription basis. Bulletin contents of a permanent nature are

consolidated semiannually into Cumulative Bulletins,

which are sold on a single-copy basis.

It is the policy of the Service to publish in the Bulletin

all substantive rulings necessary to promote a uniform

application of the tax laws, including all rulings that

supersede, revoke, modify, or amend any of those

previously published in the Bulletin. All published

rulings apply retroactively unless otherwise indicated.

Procedures relating solely to matters of internal

management are not published; however, statements of

internal practices and procedures that affect the rights

and duties of taxpayers are published.

Revenue rulings represent the conclusions of the

Service on the application of the law to the pivotal facts

stated in the revenue ruling. In those based on

positions taken in rulings to taxpayers or technical

advice to Service field offices, identifying details and

information of a confidential nature are deleted to

prevent unwarranted invasions of privacy and to comply

with statutory requirements.

Rulings and procedures reported in the Bulletin do not

have the force and effect of Treasury Department

Regulations, but they may be used as precedents.

Unpublished rulings will not be relied on, used, or cited

as precedents by Service personnel in the disposition of

other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be

considered, and Service personnel and others concerned are cautioned against reaching the same

conclusions in other cases unless the facts and

circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on

provisions of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows:

Subpart A, Tax Conventions, and Subpart B, Legislation

and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to

these subjects are contained in the other Parts and

Subparts. Also included in this part are Bank Secrecy

Act Administrative Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the

Treasury’s Office of the Assistant Secretary

(Enforcement).

Part IV.—Items of General Interest.

With the exception of the Notice of Proposed Rulemaking and the disbarment and suspension list included in

this part, none of these announcements are consolidated in the Cumulative Bulletins.

The first Bulletin for each month includes an index for

the matters published during the preceding month.

These monthly indexes are cumulated on a quarterly

and semiannual basis, and are published in the first

Bulletin of the succeeding quarterly and semi-annual

period, respectively.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

For sale by the Superintendent of Documents U.S. Government Printing Office, Washington, D.C. 20402.

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Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Section 911.—Citizens or Residents

of the United States Living Abroad

26 CFR 1.911–1: Partial exclusion for earned

income from sources within a foreign country

and foreign housing costs.

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.

A current list of countries and the dates those

countries are subject to the section 911(d)(4)

waiver is provided. See Rev. Proc. 96–33, page

Section 1441.—Withholding of Tax

on Nonresident Aliens

Notice 96–31 clarifies the application of the

U.S.-Canada Income Tax Convention, as revised

by the Protocol dated March 17, 1995 (‘‘Protocol’’), to Canadian Register Retirement Savings Plans, Canadian Registered Retirement

Income Funds and the beneficiaries of both.

Section 7701.—Definitions

26 CFR 301.7701–4: Trusts.

T.D. 8668

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1, 301, and 602

Environmental Settlement FundsClassification

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Final Regulations.

SUMMARY: This document contains

final regulations relating to the classification of certain organizations as

trusts for federal tax purposes. The

final regulations provide guidance to

taxpayers on the proper classification

of trusts formed to collect and disburse

amounts for environmental remediation

of an existing waste site to discharge

taxpayers’ liability or potential liability

under applicable environmental laws.

DATES: These regulations are effective

May 1, 1996.

For dates of applicability, see

§301.7701–4(e)(5).

FOR FURTHER INFORMATION

CONTACT: James A. Quinn, (202)

622-3060 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Paperwork Reduction Act

The collection of information contained in these final regulations has been

reviewed and approved by the Office of

Management and Budget in accordance

with the Paperwork Reduction Act (44

U.S.C. 3507) under control number

1545–1465. This information is required

by the IRS to ensure the proper

reporting of items of income and

expense of an environmental remediation trust in which a portion of the trust

is treated as owned by a grantor.

An agency may not conduct or

sponsor, and a person is not required to

respond to, a collection of information

unless the collection of information

displays a valid control number.

The estimated annual burden per

respondent is 4 hours.

Comments concerning the accuracy of

this burden estimate and suggestions for

reducing this burden should be sent to

the Internal Revenue Service, Attn: IRS

Reports Clearance Officer, T:FP, Washington, DC 20224, and to the Office of

Management and Budget, Attn: Desk

Officer for the Department of the Treasury, Office of Information and Regulatory Affairs, Washington, DC 20503.

Books or records relating to this collection of information must be retained

as long as their contents may become

material in the administration of any

internal revenue law. Generally, tax

returns and tax return information are

confidential, as required by 26 U.S.C.

6103.

Background

On August 4, 1995, the IRS published in the Federal Register a notice

of proposed rulemaking (60 FR 39903

[PS–54–94, 1995–37 I.R.B. 48]) to

provide guidance on the classification

of certain organizations as trusts for

federal tax purposes. Written comments

responding to the notice were received,

and a public hearing was held on

October 26, 1995. After consideration

of the comments received, the proposed

regulations are adopted as revised by

this Treasury decision.

Summary of Significant Comments

and Revisions

The proposed regulations provide

that an environmental remediation trust

is considered a trust for purposes of the

Internal Revenue Code. Under the

proposed regulations, a trust is an

environmental remediation trust if the

primary purpose of the trust is collecting and disbursing amounts for environmental remediation of an existing

waste site. One commentator suggested

that ‘‘response costs’’ should be considered amounts incurred for environmental remediation. To address this

concern, the final regulations clarify

that environmental remediation includes

the costs of remedying and removing

environmental contamination. One

commentator also suggested that the

final regulations define the term existing waste site. The final regulations do

not adopt this comment. The term

existing waste site should be sufficiently specific to allow taxpayers to

establish an environmental remediation

trust for any contaminated site that

currently requires remediation under

environmental laws.

The proposed regulations provide

that all contributors to an environmental remediation trust must have potential liability or a reasonable expectation

of liability under federal, state, or local

environmental laws for environmental

remediation of the waste site. A commentator suggested that the final regulations be clarified to provide that

eligible contributors include contributors with ‘‘actual’’ as well as potential

liability and contributors who are released from liability upon their contribution to the trust. The final regulations clarify that contributors having

‘‘actual’’ liability are eligible contributors. The final regulations do not

address the treatment of contributors

that are released from liability by the

governmental authority upon contribution to the trust; the regulations are

intended only to address the tax treatment of environmental remediation

trusts in which contributors continue to

have actual or potential liability (and

thus are treated as owners of the trust

under section 677). In situations where

one or more contributors are released

from liability by the governmental

authority upon contribution to the trust,

the rules for qualified settlement funds

may apply to the entire trust. See

§1.468B–1(c) and (h)(2). If such contributors contribute amounts to a trust

that is separate from the environmental

remediation trust, however, the classi-

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fication of the environmental remediation trust as a trust will not be affected.

One commentator suggested that a

cross-reference to these regulations be

inserted in §1.671–4(a) and §1.677(a)–

1(d) because the proposed regulations

address reporting and grantor trust

issues. The final regulations include the

suggested cross-references.

Other commentators suggested that

the final regulations address the timing

of deductions for contributions to the

trust, the treatment of interest earned

by the trust, and other federal tax

consequences of the trust. The final

regulations do not adopt these suggestions. The regulations are limited to the

classification of an environmental remediation trust as a trust for purposes

of section 7701 and do not address or

affect the timing or amount of a

deduction for environmental remediation costs. Amounts contributed to an

environmental remediation trust and

interest earned on those amounts must

be taken into account under the appropriate federal tax accounting rules,

including the economic performance

rules of section 461(h). Under those

rules, taxpayers generally cannot deduct contributions to the trust at the

time of contribution or deduct earnings

at the time they are received by the

trust.

The proposed regulations provide

that the regulations will apply to trusts

formed on or after the date of publication of final regulations. One commentator suggested that the final regulations should be effective, at the

trustee’s option, to trusts meeting the

requirements of an environmental remediation trust established prior to

such date, effective as of any date

designated by the trustee. The commentator further suggested that, with respect to amounts held in a fund,

account, or trust meeting the requirements of an environmental remediation

trust prior to the date of publication of

the final regulations, the IRS should

not challenge the classification of the

fund, account, or trust as a trust for

federal tax purposes.

The final regulations are effective for

trusts meeting the definition of an

environmental remediation trust that are

formed on or after May 1, 1996. The

final regulations may be relied on by

trusts formed before May 1, 1996, if

the trust has at all times met all

requirements of the final regulations

and the grantors reported items of

income and deduction consistent with

the final regulations on original or

amended returns. This provision allows

a trust and grantors that have met all of

the requirements of the final regulations throughout the existence of the

trust to treat the trust as an environmental remediation trust. The final

regulations also provide that, for trusts

formed before May 1, 1996, that are

not described by the preceding rule, the

Commissioner may permit by letter

ruling, in appropriate circumstances,

the final regulations to be applied

subject to appropriate terms and

conditions.

Special Analyses

It has been determined that this

Treasury decision is not a significant

regulatory action as defined in EO

12866. Therefore, a regulatory assessment is not required. It has also been

determined that section 553(b) of the

Administrative Procedure Act (5 U.S.C.

chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not

apply to these regulations, and, therefore, a Regulatory Flexibility Analysis

is not required. Pursuant to section

7805(f) of the Code, the notice of

proposed rulemaking preceding these

regulations was submitted to the Small

Business Administration for comment

on its impact on small business.

Drafting Information

The principal author of these regulations is James A. Quinn of the Office

of Assistant Chief Counsel (Passthroughs and Special Industries). However, other personnel from the IRS and

Treasury Department participated in

their development.

Amendments to the Regulations

Accordingly, 26 CFR parts 1, 301,

and 602 are amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as

follows:

Authority: 26 U.S.C. 7805 * * *

Par. 2. Section 1.671–4 is amended

by adding a sentence at the end of

paragraph (a) to read as follows:

§1.671–4 Method of reporting.

(a) * * * Section 301.7701–4(e)(2)

of this chapter provides guidance on

how these reporting rules apply to an

environmental remediation trust.

Par. 3. Section 1.677(a)–1 is

amended by adding a sentence at the

end of paragraph (d) to read as follows:

§1.677(a)–1 Income for benefit of

grantor; general rule.

(d) * * * See §301.7701–4(e) of this

chapter for rules on the classification of

and application of section 677 to an

environmental remediation trust.

PART 301—PROCEDURE AND

ADMINISTRATION

Par. 4. The authority citation for part

301 continues to read as follows:

Authority: 26 U.S.C. 7805 * * *

Par. 5. Section 301.7701–4(e) is

added to read as follows:

§301.7701-4 Trusts.

(e) Environmental remediation

trusts. (1) An environmental remediation trust is considered a trust for

purposes of the Internal Revenue Code.

For purposes of this paragraph (e), an

organization is an environmental remediation trust if the organization is

organized under state law as a trust; the

primary purpose of the trust is collecting and disbursing amounts for environmental remediation of an existing

waste site to resolve, satisfy, mitigate,

address, or prevent the liability or

potential liability of persons imposed

by federal, state, or local environmental

laws; all contributors to the trust have

(at the time of contribution and thereafter) actual or potential liability or a

reasonable expectation of liability under federal, state, or local environmental laws for environmental remediation

of the waste site; and the trust is not a

qualified settlement fund within the

meaning of §1.468B–1(a) of this chapter. An environmental remediation trust

is classified as a trust because its

primary purpose is environmental remediation of an existing waste site and

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not the carrying on of a profit-making

business that normally would be conducted through business organizations

classified as corporations or partnerships. However, if the remedial

purpose is altered or becomes so

obscured by business or investment

activities that the declared remedial

purpose is no longer controlling, the

organization will no longer be classified as a trust. For purposes of this

paragraph (e), environmental remediation includes the costs of assessing

environmental conditions, remedying

and removing environmental contamination, monitoring remedial activities and the release of substances,

preventing future releases of substances, and collecting amounts from

persons liable or potentially liable for

the costs of these activities. For purposes of this paragraph (e), persons

have potential liability or a reasonable

expectation of liability under federal,

state, or local environmental laws for

remediation of the existing waste site if

there is authority under a federal, state,

or local law that requires or could

reasonably be expected to require such

persons to satisfy all or a portion of the

costs of the environmental remediation.

(2) Each contributor (grantor) to the

trust is treated as the owner of the

portion of the trust contributed by that

grantor under rules provided in section

677 and §1.677(a)–1(d) of this chapter.

Section 677 and §1.677(a)–1(d) of this

chapter provide rules regarding the

treatment of a grantor as the owner of a

portion of a trust applied in discharge

of the grantor’s legal obligation. Items

of income, deduction, and credit attributable to an environmental remediation trust are not reported by the trust

on Form 1041, but are shown on a

separate statement to be attached to

that form. See §1.671–4(a) of this

chapter. The trustee must also furnish

to each grantor a statement that shows

all items of income, deduction, and

credit of the trust for the grantor’s

taxable year attributable to the portion

of the trust treated as owned by the

grantor. The statement must provide the

grantor with the information necessary

to take the items into account in

computing the grantor’s taxable income, including information necessary

to determine the federal tax treatment

of the items (for example, whether an

item is a deductible expense under

section 162(a) or a capital expenditure

under section 263(a)) and how the item

should be taken into account under the

economic performance rules of section

461(h) and the regulations thereunder.

See §1.461–4 of this chapter for rules

relating to economic performance.

(3) All amounts contributed to an

environmental remediation trust by a

grantor (cash-out grantor) who, pursuant to an agreement with the other

grantors, contributes a fixed amount to

the trust and is relieved by the other

grantors of any further obligation to

make contributions to the trust, but

remains liable or potentially liable

under the applicable environmental

laws, will be considered amounts contributed for remediation. An environmental remediation trust agreement

may direct the trustee to expend

amounts contributed by a cash-out

grantor (and the earnings thereon)

before expending amounts contributed

by other grantors (and the earnings

thereon). A cash-out grantor will cease

to be treated as an owner of a portion

of the trust when the grantor’s portion

is fully expended by the trust.

(4) The provisions of this paragraph

(e) may be illustrated by the following

example:

Example. (a) X, Y, and Z are calendar year

corporations that are liable for the remediation of

an existing waste site under applicable federal

environmental laws. On June 1, 1996, pursuant

to an agreement with the governing federal

agency, X, Y, and Z create an environmental

remediation trust within the meaning of paragraph (e)(1) of this section to collect funds

contributed to the trust by X, Y, and Z and to

carry out the remediation of the waste site to the

satisfaction of the federal agency. X, Y, and Z are

jointly and severally liable under the federal

environmental laws for the remediation of the

waste site, and the federal agency will not

release X, Y, or Z from liability until the waste

site is remediated to the satisfaction of the

agency.

(b) The estimated cost of the remediation is

$20,000,000. X, Y, and Z agree that, if Z

contributes $1,000,000 to the trust, Z will not be

required to make any additional contributions to

the trust, and X and Y will complete the

remediation of the waste site and make additional contributions if necessary.

contribute $1,000,000 to the trust. The trust

agreement directs the trustee to spend

Z’s

contributions to the trust and the income

allocable to Z’s portion before spending X’s and

Y’s portions. On November 30, 1996, the trustee

disburses $2,000,000 for remediation work performed from June 1, 1996, through September

30, 1996. For the six-month period ending

November 30, 1996, the interest earned on the

funds in the trust was $75,000, which is

allocated in equal shares of $25,000 to X’s, Y’s,

and Z’s portions of the trust.

(d) Z made no further contributions to the

trust. Pursuant to the trust agreement, the trustee

expended Z’s portion of the trust before expend-

ing X’s and Y’s portion. Therefore, Z’s share of

the remediation disbursement made in 1996 is

$1,025,000 ($1,000,000 contribution by Z plus

$25,000 of interest allocated to Z’s portion of the

trust). Z takes the $1,025,000 disbursement into

account under the appropriate federal tax accounting rules. In addition, X’s share of the

remediation disbursement made in 1996 is

$487,500, and Y’s share of the remediation

disbursement made in 1996 is $487,500. X and Y

take their respective shares of the disbursement

into account under the appropriate federal tax

accounting rules.

(e) The trustee made no further remediation

disbursements in 1996, and X and Y made no

further contributions in 1996. From December 1,

1996, to December 31, 1996, the interest earned

on the funds remaining in the trust was $5,000,

which is allocated $2,500 to X’s portion and

$2,500 to Y’s portion. Accordingly, for 1996, X

and Y each had interest income of $27,500 from

the trust and Z had interest income of $25,000

from the trust.

(5) This paragraph (e) is applicable

to trusts meeting the requirements of

paragraph (e)(1) of this section that are

formed on or after May 1, 1996. This

paragraph (e) may be relied on by

trusts formed before May 1, 1996, if

the trust has at all times met all

requirements of this paragraph (e) and

the grantors have reported items of

income and deduction consistent with

this paragraph (e) on original or

amended returns. For trusts formed

before May 1, 1996, that are not

described in the preceding sentence, the

Commissioner may permit by letter

ruling, in appropriate circumstances,

this paragraph (e) to be applied subject

to appropriate terms and conditions.

PART 602—OMB CONTROL

NUMBERS UNDER THE

PAPERWORK REDUCTION ACT

Par. 6. The authority citation for part

602 continues to read as follows:

Authority: 26 U.S.C. 7805.

Par. 7. In §602.101, paragraph (c) is

amended by adding the entry

‘‘301.7701–4(e) . . . . 1545–1465’’ in

numerical order to the table.

Margaret Milner Richardson,

Commissioner of Internal Revenue.

Approved April 5, 1996.

Leslie Samuels,

Assistant Secretary of the Treasury.

(Filed by the Office of the Federal Register on

April 30, 1996, 8:45 a.m., and published in the

issue of the Federal Register for May 1, 1996,

61 F.R. 19189)

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Part III. Administrative, Procedural, and Miscellaneous

RRSPs and RRIFs Under 1995

Protocol to U.S.-Canada Income Tax

Treaty

Notice 96–31

This notice clarifies the application

of the Convention Between the United

States of America and Canada with

Respect to Taxes on Income and on

Capital, dated September 26, 1980, as

amended by the Protocols dated June

14, 1983, March 28, 1984, and March

17, 1995 (the ‘‘Convention’’) to dividends and interest derived by, distributions from, and income accrued in

Canadian Registered Retirement Savings Plans (‘‘RRSPs’’) and Registered

Retirement Income Funds (‘‘RRIFs’’).

Article 9(1) of the Protocol of March

17, 1995 (the ‘‘Protocol’’), amended

paragraph 3 of Article XVIII (Pensions

and Annuities) of the Convention to

expand the definition of ‘‘pensions’’ to

include a retirement ‘‘arrangement.’’

Article 9(3) of the Protocol added

paragraph 7 to Article XVIII of the

Convention, allowing a citizen or resident of one state to defer taxation in

that state on income accrued as the

beneficiary of a trust, company, organization or other arrangement that is a

resident of, and generally exempt from

income taxation in the other state, until

the income is distributed from the plan,

or any plan substituted therefor,

provided that the arrangement is operated exclusively to provide pension,

retirement or employee benefits. Under

Article 21(2)(a) of the Protocol, these

revisions of Article XVIII apply to

amounts paid or credited on or after

January 1, 1996.

Article 10(1) of the Protocol

amended paragraph 2 of Article XXI

(Exempt Organizations) of the Convention to provide an exemption from

taxation for dividends and interest

derived from one Contracting State by

certain trusts, companies, organizations

or other arrangements resident in the

other Contracting State. The trust,

company, organization or other arrangement generally must be exempt

from income taxation in the taxable

year in the resident Contracting State,

and be operated exclusively either to

administer or provide pension, retirement or employee benefits, or to earn

income for the benefit of an exempt

trust, company, organization or other

retirement arrangement providing such

benefits. The exemption does not apply

to income from carrying on a trade or

business or from certain related persons. Under Article 21(2)(b) of the

Protocol, the revision of Article XXI

applies to taxable years of RRSPs or

RRIFs beginning on or after January 1.

1996.

The Treasury Department Technical

Explanation of the Protocol (‘‘Technical Explanation’’) states that RRSPs

and RRIFs, for example, are eligible

for benefits under paragraph 7 of

Article XVIII and paragraph 2 of

Article XXI provided that they are

‘‘operated exclusively to provide’’ or

‘‘administer,’’ in the case of Article

XXI(2), ‘‘pension, retirement, or

employee benefits.’’

The Technical Explanation was not

intended to imply that, under current

Canadian law, RRIFs and RRSPs might

not be eligible for benefits under

Articles XVIII(3) and (7) and XXI(2)

Month

Year

Weighted

Average

May

1996

6.93

of the Convention because they might

not be operated exclusively to provide

pension, retirement or employee benefits. It is the position of the Internal

Revenue Service that, under current

Canadian law, RRSPs and RRIFs are

examples of arrangements that meet the

conditions stated in the Protocol. Thus,

RRSPs and RRIFs qualify for the

benefits of Article XVIII of the Convention, and paragraph 2 of Article

XXI of the Convention, as amended by

Articles 9(1) and 9(3), and Article

10(1) of the Protocol, respectively.

The principal author of this notice is

Kenneth Allison of the Office of the

Associate Chief Counsel (International). For further information regarding this notice contact Mr. Allison at

(202)-622-3860 (not a toll-free call).

Weighted Average Interest Rate

Update

Notice 96–32

Notice 88–73 provides guidelines for

determining the weighted average interest rate and the resulting permissible

range of interest rates used to calculate

current liability for the purpose of the

full funding limitation of § 412(c)(7) of

the Internal Revenue Code as amended

by the Omnibus Budget Reconciliation

Act of 1987 and as further amended by

the Uruguay Round Agreements Act,

Pub. L. 103–465 (GATT).

The average yield on the 30-year

Treasury Constant Maturities for April

1996 is 6.79 percent.

The following rates were determined

for the plan years beginning in the

month shown below.

90% to 108%

Permissible

Range

90% to 110%

Permissible

Range

6.24 to 7.49

6.24 to 7.63

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Drafting Information

Correction of Publication

The principal author of this notice is

Donna Prestia of the Employee Plans

Division. For further information regarding this notice, call (202) 622-6076

between 2:30 and 4:00 p.m. Eastern

time (not a toll-free number). Ms.

Prestia’s number is (202) 622-7377

(also not a toll-free number).

Accordingly, the publication of the

final regulations which are the subject

of FR Doc. 95–21838 is corrected as

follows:

Definition of a Controlled Foreign

Corporation, Foreign Base Company

Income and Foreign Personal Holding

Company Income of a Controlled

Foreign Corporation; Correction

Notice 96–33

AGENCY: Internal Revenue Service,

Treasury.

ACTION:

regulations.

Correction

DATE:

On page 46530, column 3, under

amendatory instruction 1. of ‘‘Par.

11.’’, §602.101(c) is corrected in the

table by removing the entry for

‘‘§1.954A–2’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

March 29, 1996, 8:45 a.m., and published in

the issue of the Federal Register for April 1,

1996, 61 F.R. 14248)

final

SUMMARY: This document contains a

correction to final regulations (TD

8618 [1995–40 I.R.B. 4]) which were

published in the Federal Register for

Thursday, September 7, 1995 (60 FR

46500). The final regulations govern

the definition of a controlled foreign

corporation and the definitions of foreign base company income and foreign

personal holding company income of a

controlled foreign corporation.

EFFECTIVE

1995.

§602.101 [Corrected]

September

FOR FURTHER INFORMATION

CONTACT: Valerie Mark, (202)

622-3840 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations which are the

subject of this correction are under

sections 954 and 957 of the Internal

Revenue Code.

Need for Correction

As published, TD 8618 contains an

error that is in need of clarification.

26 CFR 601.105: Examination of returns and

claims for refund, credit, or abatement;

determination of correct tax liability.

(Also Part I, § 911, 1.911–1)

Rev. Proc. 96–33

SECTION 1. PURPOSE

01. This revenue procedure provides

information to any individual who

failed to meet the eligibility requirements of § 911(d)(1) of the Internal

Revenue Code because adverse conditions in a foreign country precluded the

individual from meeting those requirements for taxable year 1995.

02. The Internal Revenue Service

previously has listed countries for

which the eligibility requirements of

§ 911(d)(1) of the Code are waived

under § 911(d)(4) because of adverse

conditions in those countries during the

time periods stated. See Rev. Proc. 95–

45, 1995–44 I.R.B. 22, Rev. Proc. 94–

31, 1994–1 C.B. 625, Rev. Proc. 94–

15, 1994–1 C.B. 575, and Rev. Proc.

92–63, 1992–2 C.B. 421. This revenue

procedure relists countries where the

adverse conditions are still in effect.

Rev. Proc. 95–45, Rev. Proc. 94–31,

Rev. Proc. 94–15, and Rev. Proc. 92–

63 remain in full force and effect; the

older periods listed therein are omitted

from this revenue procedure solely for

brevity.

SEC. 2. BACKGROUND

01. Section 911(a) of the Code

allows a ‘‘qualified individual,’’ as

defined in § 911(d)(1), to exclude

foreign earned income and housing cost

amounts from gross income. Section

911(c)(3) allows a qualified individual

to deduct housing cost amounts from

gross income.

02. Section 911(d)(1) of the Code

defines the term ‘‘qualified individual’’

as an individual whose tax home is in a

foreign country and who is (A) a citizen

of the United States and establishes to

the satisfaction of the Secretary of the

Treasury that the individual has been a

bona fide resident of a foreign country

or countries for an uninterrupted period

that includes an entire taxable year, or

(B) a citizen or resident of the United

States who, during any period of 12

consecutive months, is present in a

foreign country or countries during at

least 330 full days.

03. Section 911(d)(4) of the Code

provides an exception to the eligibility

requirements of § 911(d)(1). An individual will be treated as a qualified

individual with respect to a period in

which the individual was a bona fide

resident of, or was present in, a foreign

country if the individual left the

country during a period for which the

Secretary of the Treasury, after consultation with the Secretary of State,

determines that individuals were required to leave because of war, civil

unrest, or similar adverse conditions

that precluded the normal conduct of

business. An individual must establish

that but for those conditions the individual could reasonably have been

expected to meet the eligibility

requirements.

04. For purposes of § 911(d)(4) of

the Code, the Secretary of the Treasury

in consultation with the Secretary of

State, has determined that war, civil

unrest, or similar adverse conditions

that precluded the normal conduct of

business existed in the following countries during the specified periods:

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Date of Departure

Country

On or After

On or Before

Afghanistan

Bosnia and Herzegovina

Croatia

Iran

Lebanon

The Former Yugoslav Republic of Macedonia

1) Montenegro

1) Serbia

Somalia

April 23, 1979

April 7, 1992

September 1, 1978

August 31, 1979

June 13, 1992

December 21, 1990

(still in effect)

1) Montenegro and Serbia, formerly part of the Socialist Federal Republic of Yugoslavia, have asserted the formation

of a joint independent state, but this entity has not been formally recognized as a state by the United States.

.05 Accordingly, for purposes of

§ 911 of the Code, an individual who

left one of the foregoing countries

during the specified period shall be

treated as a qualified individual with

respect to the period during which that

individual was a bona fide resident of,

or present in, that foreign country if the

individual establishes a reasonable expectation of meeting the requirements

of § 911(d) but for those conditions.

.06 To qualify for relief under

§ 911(d)(4), an individual must have

established residency or have been

physically present in the foreign country on or prior to the date that the

Secretary of the Treasury determines

that individuals were required to leave

the foreign country. Individuals who

establish residency or are first physically present in the foreign country

after the date that the Secretary prescribes, but during the period for which

the Secretary determines that individuals were required to leave the foreign

country, shall not be treated as

qualified individuals under § 911(d)(4)

pursuant to § 911(d)(4)(C). For example, individuals who establish residency

or are first physically present in Iran

after September 1, 1978, are not

eligible to qualify for the exemption

prescribed in § 911(d)(4). The same

holds true with respect to individuals

who move to Afghanistan after April

23, 1979, or Lebanon after August 31,

1979.

SEC. 3. INQUIRIES

A taxpayer who needs assistance on

how to claim this exclusion, or on how

to file an amended return, should

contact a local IRS Office or, for a

taxpayer residing or traveling outside

the United States, the nearest overseas

IRS office.

SEC. 4. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 91–29, 1991–1 C.B. 562

is obsoleted.

DRAFTING INFORMATION

The principal author of this revenue

procedure is Leslie B. van der Wal of

the Office of Associate Chief Counsel

(International). For further information

regarding this revenue procedure contact Ms. van der Wal on (202)

622-3880 (not a toll-free call).

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Part IV. Items of General Interest

OMB Approval of Form 3115

the Federal Insurance Contributions

Act.

Announcement 96–47

Form 3115, Application for Change

in Accounting Method, and the separate

Instructions for Form 3115, were

revised and have been approved by the

Office of Management and Budget

(OMB) through May 31, 1999. This

February 1996 revision is the current

Form 3115 and replaces the November

1992 version. Copies of the revised

form and instructions are available at

most IRS offices.

Applicants may order Form 3115 by

telephone or they may use other IRS

electronic information services to get

copies.

Request by—

Number or Address

Telephone

800-TAX-FORM

(800-829-3676)

Computer and

modem

703-321-8020

(modem settings are

N, 8, 1)

Internet:

World Wide

Web

www.irs.ustreas.gov

FTP

ftp.irs.ustreas.gov

Telnet

iris.irs.ustreas.gov

FUTA Taxation of Amounts Under

Employee Benefits Plans; FICA

Taxation of Amounts Under Employee

Benefits Plans; Hearing

Announcement 96–48

AGENCY: Internal Revenue Service,

Treasury.

ACTION: Notice of public hearing on

proposed regulations.

SUMMARY: This document provides

notice of a public hearing on proposed

Income Tax Regulations relating to

when amounts deferred under or paid

from certain nonqualified deferred

compensation plans are taken into

account as ‘‘wages’’ for purposes of

the employment taxes imposed by the

Federal Unemployment Tax Act and

1996– 27 I.R.B.

DATES: The public hearing will be

held on Monday, June 24, 1996,

beginning at 10:00 a.m. Requests to

speak and outlines of oral comments

must be received by Monday, June 3,

1996.

ADDRESSES: The public hearing will

be held in the Internal Revenue Service

Auditorium, Seventh Floor, 7400 Corridor, Internal Revenue Building, 1111

Constitution Avenue, NW, Washington,

DC. Requests to speak and outlines of

oral comments should be submitted to

the Internal Revenue Service, P.O. Box

7604, Ben Franklin Station, Attn:

CC:DOM:CORP:R [EE–55–95]; [EE–

142–87] Room 5228, Washington, DC

20044.

FOR FURTHER INFORMATION

CONTACT: Mike Slaughter of the

Regulations Unit, Assistant Chief

Counsel (Corporate), (202) 622-7190,

(not a toll-free number).

SUPPLEMENTARY INFORMATION:

The subject of the public hearing is

proposed amendments to the Income

Tax Regulations under sections 3306

and 3121 of the Internal Revenue Code

of 1986. These proposed regulations

(EE–55–95, 1996–12 I.R.B. 12; EE–

142–87, 1996–12 I.R.B. 13) appeared

in the Federal Register for Thursday,

January 25, 1996 (61 FR 2194; 2214).

The rules of § 601.601 (a)(3) of the

‘‘Statement of Procedural Rules’’ (26

CFR part 601) shall apply with respect

to the public hearing. Persons who

have submitted written comments within the time prescribed in the notice of

proposed rulemaking and who also

desire to present oral comments at the

hearing on the proposed regulations

should submit not later than Monday,

June 3, 1996, an outline of the oral

comments/testimony to be presented at

the hearing and the time they wish to

devote to each subject.

Each speaker (or group of speakers

representing a single entity) will be

limited to 10 minutes for an oral

presentation exclusive of the time

consumed by the questions from the

panel for the government and answers

to these questions.

Because of controlled access restrictions, attendees cannot be admitted

beyond the lobby of the Internal

Revenue Building until 9:45 a.m.

An agenda showing the scheduling

of the speakers will be made after

outlines are received from the persons

testifying. Copies of the agenda will be

available free of charge at the hearing.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

May 7, 1996, 8:45 a.m., and published in the

issue of the Federal Register for May 8, 1996,

61 F.R. 20767)

Loans to Plan Participants; Hearing

Announcement 96–49

AGENCY: Internal Revenue Service,

Treasury.

ACTION Notice of public hearing on

proposed rulemaking.

SUMMARY: This document provides

notice of a public hearing on proposed

regulations relating to loans made from

a qualified employer plan to plan

participants or beneficiaries.

DATES: The public hearing will be

held on Friday, June 28, 1996, beginning at 10:00 a.m. Requests to speak

and outlines or oral comments must be

received by Friday, May 31, 1996.

ADDRESSES: The public hearing will

be held in the Internal Revenue Service

Auditorium, Seventh Floor, 7400 Corridor, Internal Revenue Building, 1111

Constitution Avenue NW, Washington,

DC. Requests to speak and outlines of

oral comments should be mailed to the

Internal Revenue Service, P.O. Box

7604, Ben Franklin Station, Attn:

CC:DOM:CORP:R [EE 106–82], Room

5226, Washington, DC 20044.

FOR FURTHER INFORMATION

CONTACT: Christina Vasquez of Regulations Unit, Assistant Chief Counsel

(Corporate), (202) 622-6803 (not a tollfree number).

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SUPPLEMENTARY INFORMATION:

The subject of the public hearing is

proposed amendments to the Income

Tax Regulations under section 72 of

the Internal Revenue Code of 1986.

The proposed regulations (EE–106–82,

1996–10 I.R.B. 31) appeared in the

Federal Register for Thursday, December 21, 1995 (60 FR 66233).

The rules of §601.601(a)(3) of the

‘‘Statement of Procedural Rules’’ (26

CFR Part 601) shall apply with respect

to the public hearing. Persons who

have submitted written comments within the time prescribed in the notice of

proposed rulemaking and who also

desire to present oral comments at the

hearing on the proposed regulations

should submit not later than Friday,

May 31, 1996, an outline of the oral

comments/testimony to be presented at

the hearing and the time they wish to

devote to each subject.

Each speaker (or group of speakers

representing a single entity) will be

limited to 10 minutes for an oral

presentation exclusive of the time

consumed by the questions from the

panel for the government and answer

thereto.

Because of controlled access restrictions, attenders cannot be admitted

beyond the lobby of the Internal

Revenue Building until 9:45 a.m.

An agenda showing the scheduling

of the speakers will be make after

outlines are received from the persons

testifying. Copies of the agenda will be

available free of charge at eh hearing.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

May 7, 1996, 8:45 a.m., and published in the

issue of the Federal Register for May 8, 1996,

61 F.R. 20766)

Section 6662—Imposition of the

Accuracy-Related Penalty; Correction

regulations [TD 8656 [1996–13 I.R.B.

9]] which were published in the Federal Register for Friday, February 9,

1996 (61 FR 4876). The regulations

provide guidance on the imposition of

the accuracy related penalty.

EFFECTIVE DATE: February 9, 1996.

FOR FURTHER INFORMATION

CONTACT: Carolyn D. Fanaroff of the

Office of Associate Chief Counsel

(International), (202) 622-3880 (not a

toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations

that are the subject of these corrections

are under section 6662 of the Internal

Revenue Code.

Need for Correction

As published, TD 8656 contains

errors that are in need of clarification.

Correction of Publication

Accordingly, the publication of final

and temporary regulations which are

the subject of FR Doc. 96–2171 is

corrected as follows:

1. On page 4878, column 1, in the

preamble following the paragraph heading ‘‘Reasonably Thorough Search for

Data’’, third full paragraph, line 8, the

language ‘‘expense a search for data

against (i) the’’ is corrected to read

‘‘expense of a search for data against

(i) the’’.

§1.6662–0 [Corrected]

§1.6662–5T [Corrected]

3. On page 4880, column 1,

§1.6662–5T, paragraph (e)(4)(iii), lines

5 through 9, the language ‘‘such as

land, buildings, fixtures and inventory.

Intangible property includes property

such as goodwill. Covenants not to

compete, leaseholds, patents, contract

rights, debts and choses in’’ is corrected to read ‘‘such as money, land,

buildings, fixtures and inventory. Intangible property includes property such

as goodwill, covenants not to compete,

leaseholds, patents, contract rights,

debts, choses in’’.

§1.6662–6 [Corrected]

4. On page 4882, column 3,

§1.6662–6, paragraph (d)(2)(iii)(A),

line 10, the language ‘‘provided the

most accurate measure of’’ is corrected

to read ‘‘provided the most reliable

measure of’’.

5. On page 4883, column 1,

§1.6662–6, paragraph (d)(2)(iii)(C),

line 2 from the bottom of the page, the

language ‘‘provided the most accurate

measure of’’ is corrected to read

‘‘provided the most reliable measure

of’’.

6. On page 4884, column 2,

§1.6662–6, paragraph (e), in the Example., line 7, the language ‘‘which was

carried to taxpayer’s year 2 year’’ is

corrected to read ‘‘which was carried

to taxpayer’s year 2’’.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

§1.6662–0 Table of contents.

Regulations on Effectively Connected

Income and the Branch Profits Tax;

Correction

§1.6662–5T Substantial and gross

valuation misstatements under chapter

1 (Temporary).

SUMMARY: This document contains

corrections to final and temporary

(Filed by the Office of the Federal Register on

March 29, 1996, 8:45 a.m., and published in

the issue of the Federal Register for April 1,

1996, 61 F.R. 14248)

ACTION: Correction to final and temporary regulations.

2. On page 4879, column 2,

§1.6662–0, the entry for §1.6662–

5T(e)(4) and (e)(4)(i) are corrected to

read as follows:

Announcement 96–50

AGENCY: Internal Revenue Service,

Treasury.

(i) Substantial valuation misstatement.

AGENCY: Internal Revenue Service,

Treasury.

(e)(4) Tests related to section 482.

Announcement 96–51

ACTION: Correction to final and temporary regulations.

1996– 27 I.R.B.

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SUMMARY: This document contains

corrections to final Income Tax Regulations (TD 8657 [1996–14 I.R.B. 4]),

which were published in the Federal

FR 9336), relating to the determination

of effectively connected income; and

final and temporary Income Tax Regulations relating to the branch-level

interest tax, respectively.

the first entry in the table is corrected

to read as follows:

Sentence

Remove

Add

First, third, and

fifth sentence.

* * * * *

1993 . . . . .

1997

§ 1.884–5 [Corrected]

EFFECTIVE DATE: June 6, 1996.

FOR FURTHER INFORMATION

CONTACT: Gwendolyn A. Stanley,

(202) 622-3860 (not a toll-free

number).

2. On page 9343, column 1,

§ 1.884–5 (e)(4)(ii) , line 7, the language ‘‘country in its country of

residence’’ is corrected to read ‘‘corporation in its country of residence’’.

SUPPLEMENTARY INFORMATION:

§ 1.897–1 [Corrected]

Background

3. On page 9343, column 1, amendatory instruction ‘‘Par. 10.’’ is corrected

by removing items 1. and 2. and

correcting ‘‘Par. 10.’’ to read as

follows:

Par. 10. Paragraph (f)(2)(i) in

§ 1.897–1 is revised to read as follows:

The final regulations that are the

subject of these corrections are under

sections 861, 864, 871, 884, and 897 of

the Internal Revenue Code.

Need for Correction

As published, the final regulations

(TD 8657) contain errors which may

prove to be misleading and are in need

of clarification.

Cynthia E. Grigsby,

Chief, Regulations Unit,

Assistant Chief Counsel (Corporate).

(Filed by the Office of the Federal Register on

March 29, 1996, 8:45 a.m., and published in

the issue of the Federal Register for April 1,

1996, 61 F.R. 14247)

Correction of Publication

Accordingly, the publication of the

final and temporary regulations (TD

8657) which are the subject of FR Doc.

96–5261 is corrected as follows:

Deletions from Cumulative List of

Organizations Contributions to Which

Are Deductible Under Section 170 of

the Code

§ 1.884–1 [Corrected]

Announcement 96–52

1. On page 9338, column 3, in

amendatory instruction 11.b. under

‘‘Par. 5.’’, § 1.884–1 (e)(5) Example 1.

The names of organizations that no

longer qualify as organizations described in section 170(c)(2) of the

1996– 27 I.R.B.

Internal Revenue Code of 1986 are

listed below.

Generally, the Service will not disallow deductions for contributions

made to a listed organization on or

before the date of announcement in the

Internal Revenue Bulletin that an organization no longer qualifies. However,

the Service is not precluded from disallowing a deduction for any contributions made after an organization ceases

to qualify under section 170(c)(2) if the

organization has not timely filed a suit

for declaratory judgment under section

7428 and if the contributor (1) had

knowledge of the revocation of the

ruling or determination letter, (2) was

aware that such revocation was imminent, or (3) was in part responsible for

or was aware of the activities or

omissions of the organization that

brought about this revocation.

If on the other hand a suit for

declaratory judgment has been timely

filed, contributions from individuals

and organizations described in section

170(c)(2) that are otherwise allowable

will continue to be deductible. Protection under section 7428(c) would begin

on May 28, 1996, and would end on

the date the court first determines that

the organization is not described in

section 170(c)(2) as more particularly

set forth in section 7428(c)(1). For

individual contributors, the maximum

deduction protected is $1,000, with a

husband and wife treated as one

contributor. This benefit is not extended to any individual who was

responsible, in whole or in part, for the

acts or omissions of the organization

that were the basis for revocation.

Evangelism Outreach, Inc.

Franklin Springs, GA

Market Street Mission

Louisville, KY

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Announcement of the Disbarment, Suspension, or Consent to Voluntary

Suspension of Attorneys, Certified Public Accountants, Enrolled Agents and

Enrolled Actuaries From Practice Before the Internal Revenue Service

Under 31 Code of Federal Regulations, Part 10, an attorney, certified

public accountant, enrolled agent or enrolled actuary, in order to avoid the institution or conclusion of a proceeding

for his disbarment or suspension from

practice before the Internal Revenue

Service, may offer his consent to

suspension from such practice. The

Director of Practice, in his discretion,

may suspend an attorney, certified

public accountant, enrolled agent or

enrolled actuary in accordance with the

consent offered.

Attorneys, certified public accountants, enrolled agents and enrolled actuaries are prohibited in any Internal

Revenue Service matter from directly

or indirectly employing, accepting

assistance from, being employed by,

or sharing fees with, any practitioner disbarred or suspended from

practice before the Internal Revenue

Service.

To enable attorneys, certified public

accountants, enrolled agents and enrolled actuaries to identify practitioners

under consent suspension from practice

before the Internal Revenue Service,

the Director of Practice will announce

in the Internal Revenue Bulletin the

names and addresses of practitioners

who have been suspended from such

practice, their designation as attor-

ney, certified public accountant, enrolled agent or enrolled actuary and

date or period of suspension. This announcement will appear in the weekly

Bulletin at the earliest practicable date

after such action and will continue to

appear in the weekly Bulletins for five

successive weeks or for as many weeks

as is practicable for each attorney,

certified public accountant, enrolled

agent or enrolled actuary so suspended

and will be consolidated and published

in the Cumulative Bulletin.

The following individuals have been

placed under consent suspension from

practice before the Internal Revenue

Service:

Name

Address

Designation

Date of Suspension

Behrens, William

Warter, J. Christopher

Leckie, Jerry B.

Retzlaff, Gene

Cahill, Donal

Guidera, George C.

Kirk, Gregg T.

Brock, Guy Charles

Mathews, Thomas

Farnsworth Jr., Harold

King, John C.

Kenosha, WI

South Bend, IN

Macon, GA

Hortonville, WI

Stratford, CT

Straford, CT

Dallas, TX

Spokane, WA

Cincinnati, OH

Starke, FL

Wichita, KS

Enrolled Agent

Attorney

Enrolled Agent

Attorney

CPA

Attorney

March 6, 1996 to May 5, 1996

Indefinite from March 8, 1996

March 9, 1996 to March 8, 1999

March 18, 1996 to July 17, 1996

April 4, 1996 to April 3, 1997

April 11, 1996 to October 10, 1996

Indefinite from May 1, 1996

May 1, 1996 to August 31, 1996

May 1, 1996 to April 30, 1998

May 1, 1996 to August 31, 1996

Announcement of the Expedited Suspension of Attorneys, Certified Public

Accountants, Enrolled Agents, and Enrolled Actuaries From Practice Before the

Internal Revenue Service

Under title 31 of the Code of Federal

Regulations, section 10.76, the Director

of Practice is authorized to immediately

suspend from practice before the Internal Revenue Service any practitioner

who, within five years, from the date

the expedited proceeding is instituted,

(1) has had a license to practice as an

attorney, certified public accountant, or

actuary suspended or revoked for

cause; or (2) has been convicted of any

crime under title 26 of the United

States Code or, of a felony under title

18 of the United States Code involving

dishonesty or breach of trust.

Attorneys, certified public accountants, enrolled agents, and enrolled actuaries are prohibited in any Internal

Revenue Service matter from directly

or indirectly employing, accepting assistance from, being employed by, or

sharing fees with, any practitioner

disbarred or suspended from practice

before the Internal Revenue Service.

To enable attorneys, certified public

accountants, enrolled agents, and enrolled actuaries to identify practitioners

under expedited suspension from practice before the Internal Revenue Service, the Director of Practice will announce in the Internal Revenue Bulletin

the names and addresses of practitioners who have been suspended from such

practice, their designation as attorney,

certified public accountant, enrolled

agent, or enrolled actuary, and date or

period of suspension. This announcement will appear in the weekly Bulletin

at the earliest practicable date after

such action and will continue to appear

in the weekly Bulletins for five successive weeks or for as many weeks as is

practicable for each attorney, certified

public accountant, enrolled agent, or

enrolled actuary so suspended and will

be consolidated and published in the

Cumulative Bulletin.

The following individuals have been

placed under suspension from practice

before the Internal Revenue Service by

virtue of the expedited proceeding

provisions of the applicable regulations:

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Name

Address

Designation

Date of Suspension

Noske, Joan M.

Wahl, Roger W.

Stojanov, Dragan

Gay, Randall D.

Sheffey, Ralph

Doyle, Robert

Singer, Michael G.

Mohme, Robert H.

Vogelei, George Mac

Gaskins, Oscar N.

Gawel, Michael S.

Richmond, MN

Martinez, GA

Detroit, MI

Honolulu, HI

LaCrosse, WI

Sacramento, CA

Minnetonka, MN

St. Louis, MO

Novato, CA

Cherry Hill, NJ

Niagara Falls, NY

CPA

Attorney

CPA

Attorney

CPA

Attorney

Indefinite from March 1, 1996

Indefinite from March 13, 1996

Indefinite from March 19, 1996

Indefinite from March 20, 1996

Indefinite from March 26, 1996

Indefinite from March 29, 1996

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Definition of Terms

Revenue rulings and revenue procedures (hereinafter referred to as ‘‘rulings’’) that have an effect on previous

rulings use the following defined terms

to describe the effect:

Amplified describes a situation where

no change is being made in a prior

published position, but the prior position is being extended to apply to a

variation of the fact situation set forth

therein. Thus, if an earlier ruling held

that a principle applied to A, and the

new ruling holds that the same principle also applies to B, the earlier ruling

is amplified. (Compare with modified,

below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in

a prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously

published ruling and points out an

essential difference between them.

Modified is used where the substance

of a previously published position is

being changed. Thus, if a prior ruling

held that a principle applied to A but

not to B, and the new ruling holds that

it applies to both A and B, the prior

ruling is modified because it corrects a

published position. (Compare with amplified and clarified, above).

Obsoleted describes a previously

published ruling that is not considered

determinative with respect to future

transactions. This term is most commonly used in a ruling that lists

previously published rulings that are

obsoleted because of changes in law or

regulations. A ruling may also be

obsoleted because the substance has

been included in regulations subsequently adopted.

Revoked describes situations where

the position in the previously published

ruling is not correct and the correct

position is being stated in the new

ruling.

Superseded describes a situation

where the new ruling does nothing

more than restate the substance and

situation of a previously published

ruling (or rulings). Thus, the term is

used to republish under the 1986 Code

and regulations the same position published under the 1939 Code and regulations. The term is also used when it is

desired to republish in a single ruling a

series of situations, names, etc., that

were previously published over a

period of time in separate rulings.

If the new ruling does more than

restate the substance of a prior ruling, a

combination of terms is used. For

example, modified and superseded describes a situation where the substance

of a previously published ruling is

being changed in part and is continued

without change in part and it is desired

to restate the valid portion of the

previously published ruling in a new

ruling that is self contained. In this

case the previously published ruling is

first modified and then, as modified, is

superseded.

Supplemented is used in situations in

which a list, such as a list of the names

of countries, is published in a ruling

and that list is expanded by adding

further names in subsequent rulings.

After the original ruling has been

supplemented several times, a new

ruling may be published that includes

the list in the original ruling and the

additions, and supersedes all prior

rulings in the series.

Suspended is used in rare situations

to show that the previous published

rulings will not be applied pending

some future action such as the issuance

of new or amended regulations, the

outcome of cases in litigation, or the

outcome of a Service study.

Abbreviations

E.O.—Executive Order.

ER—Employer.

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contribution Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign Corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statements of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

The following abbreviations in current use and

formerly used will appear in material published

in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C.—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

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Numerical Finding List1

Bulletins 1996–1 through 1996–21

Announcements:

96–1, 1996–2 I.R.B. 57

96–2, 1996–2 I.R.B. 57

96–3, 1996–2 I.R.B. 57

96–4, 1996–3 I.R.B. 50

96–5, 1996–4 I.R.B. 99

96–6, 1996–5 I.R.B. 43

96–7, 1996–5 I.R.B. 44

96–8, 1996–7 I.R.B. 56

96–9, 1996–8 I.R.B. 30

96–10, 1996–8 I.R.B. 30

96–11, 1996–9 I.R.B. 11

96–12, 1996–11 I.R.B. 30

96–13, 1996–12 I.R.B. 33

96–14, 1996–12 I.R.B. 35

96–15, 1996–11 I.R.B. 9

96–16, 1996–13 I.R.B. 22

96–17, 1996–13 I.R.B. 22

96–18, 1996–15 I.R.B. 15

96–19, 1996–15 I.R.B. 15

96–20, 1996–15 I.R.B. 15

96–21, 1996–15 I.R.B. 15

96–22, 1996–15 I.R.B. 16

96–23, 1996–18 I.R.B. 7

96–24, 1996–16 I.R.B. 35

96–25, 1996–17 I.R.B. 13

96–26, 1996–17 I.R.B. 13

96–27, 1996–17 I.R.B. 16

96–28, 1996–17 I.R.B. 16

96–29, 1996–17 I.R.B. 17

96–30, 1996–17 I.R.B. 17

96–31, 1996–17 I.R.B. 18

96–32, 1996–17 I.R.B. 18

96–33, 1996–18 I.R.B. 12

96–34, 1996–18 I.R.B. 13

96–35, 1996–18 I.R.B. 13

96–36, 1996–18 I.R.B. 13

96–37, 1996–18 I.R.B. 14

96–38, 1996–19 I.R.B. 84

96–39, 1996–19 I.R.B. 84

96–40, 1996–19 I.R.B. 85

96–41, 1996–20 I.R.B. 18

96–42, 1996–20 I.R.B. 18

96–43, 1996–20 I.R.B. 18

96–44, 1996–21 I.R.B. 10

96–45, 1996–21 I.R.B. 10

96–46, 1996–21 I.R.B. 10

Delegations Orders:

232 (Rev. 2), 1996–7 I.R.B. 49

236 (Rev. 2), 1996–21 I.R.B. 7

239 (Rev. 1), 1996–7 I.R.B. 49

247, 1996–21 I.R.B. 7

Notices:

96–2, 1996–2 I.R.B. 15

96–1, 1996–3 I.R.B. 30

Notices—Continued

Revenue Procedures—Continued

96–4, 1996–4 I.R.B. 69

96–5, 1996–6 I.R.B. 22

96–6, 1996–5 I.R.B. 27

96–7, 1996–6 I.R.B. 22

96–8, 1996–6 I.R.B. 23

96–9, 1996–6 I.R.B. 26

96–10, 1996–7 I.R.B. 47

96–11, 1996–8 I.R.B. 19

96–12, 1996–10 I.R.B. 29

96–13, 1996–10 I.R.B. 29

96–14, 1996–12 I.R.B. 11

96–15, 1996–13 I.R.B. 19

96–16, 1996–13 I.R.B. 20

96–17, 1996–13 I.R.B. 20

96–18, 1996–14 I.R.B. 27

96–19, 1996–14 I.R.B. 28

96–20, 1996–14 I.R.B. 30

96–21, 1996–14 I.R.B. 30

96–22, 1996–14 I.R.B. 30

96–23, 1996–16 I.R.B. 23

96–24, 1996–16 I.R.B. 23

96–25, 1996–17 I.R.B. 11

96–26, 1996–18 I.R.B. 4

96–27, 1996–18 I.R.B. 4

96–28, 1996–19 I.R.B. 7

96–29, 1996–19 I.R.B. 7

96–30, 1996–20 I.R.B. 11

96–8, 1996–1 I.R.B. 187

96–8A, 1996–9 I.R.B. 10

96–9, 1996–2 I.R.B. 15

96–10, 1996–2 I.R.B. 17

96–11, 1996–2 I.R.B. 18

96–12, 1996–3 I.R.B. 30

96–13, 1996–3 I.R.B. 31

96–14, 1996–3 I.R.B. 41

96–15, 1996–3 I.R.B. 41

96–16, 1996–3 I.R.B. 45

96–17, 1996–4 I.R.B. 69

96–18, 1996–4 I.R.B. 73

96–19, 1996–4 I.R.B. 80

96–20, 1996–4 I.R.B. 88

96–21, 1996–4 I.R.B. 96

96–22, 1996–5 I.R.B. 27

96–23, 1996–5 I.R.B. 27

96–24, 1996–5 I.R.B. 28

96–24A, 1996–15 I.R.B. 12

96–25, 1996–8 I.R.B. 19

96–26, 1996–8 I.R.B. 22

96–27, 1996–11 I.R.B. 27

96–28, 1996–14 I.R.B. 31

96–29, 1996–16 I.R.B. 24

96–30, 1996–19 I.R.B. 8

96–31, 1996–20 I.R.B. 11

96–32, 1996–20 I.R.B. 14

Proposed Regulations:

Revenue Rulings:

DL–1–95, 1996–6 I.R.B. 28

EE–20–95, 1996–5 I.R.B. 15

EE–34–95, 1996–3 I.R.B. 49

EE–35–95, 1996–5 I.R.B. 19

EE–53–95, 1996–5 I.R.B. 23

EE–55–95, 1996–12 I.R.B. 12

EE–106–82, 1996–10 I.R.B. 31

EE–142–87, 1996–12 I.R.B. 13

EE–148–81, 1996–11 I.R.B. 29

GL–1–96, 1996–21 I.R.B. 7

IA–3–94, 1996–17 I.R.B. 12

IA–33–95, 1996–4 I.R.B. 99

IA–41–93, 1996–11 I.R.B. 29

INTL–3–95, 1996–6 I.R.B. 29

INTL–9–95, 1996–5 I.R.B. 25

INTL–54–95, 1996–14 I.R.B. 39

INTL–62–90; INTL–32–93;

INTL–52–86; INTL–52–94,

1996–19 I.R.B. 26

PS–2–95, 1996–7 I.R.B. 50

PS–4–96, 1996–18 I.R.B. 5

PS–6–95, 1996–16 I.R.B. 27

96–1, 1996–1 I.R.B. 7

96–2, 1996–2 I.R.B. 5

96–3, 1996–2 I.R.B. 14

96–6, 1996–2 I.R.B. 8

96–4, 1996–3 I.R.B. 16

96–5, 1996–3 I.R.B. 29

96–7, 1996–3 I.R.B. 12

96–8, 1996–4 I.R.B. 62

96–9, 1996–4 I.R.B. 5

96–10, 1996–4 I.R.B. 27

96–11, 1996–4 I.R.B. 28

96–12, 1996–9 I.R.B. 4

96–13, 1996–10 I.R.B. 19

96–14, 1996–6 I.R.B. 20

96–15, 1996–11 I.R.B. 9

96–16, 1996–11 I.R.B. 4

96–17, 1996–13 I.R.B. 5

96–18, 1996–13 I.R.B. 4

96–19, 1996–14 I.R.B. 24

96–20, 1996–15 I.R.B. 5

96–21, 1996–15 I.R.B. 7

96–22, 1996–15 I.R.B. 9

96–23, 1996–15 I.R.B. 11

96–24, 1996–19 I.R.B. 5

96–25, 1996–19 I.R.B. 4

96–26, 1996–21 I.R.B. 9

Revenue Procedures:

96–1, 1996–1 I.R.B. 8

96–2, 1996–1 I.R.B. 60

96–3, 1996–1 I.R.B. 82

96–4, 1996–1 I.R.B. 94

96–5, 1996–1 I.R.B. 129

96–6, 1996–1 I.R.B. 151

96–7, 1996–1 I.R.B. 185

See footnote at the end of list.

Treasury Decisions:

8630, 1996–3 I.R.B. 19

8631, 1996–3 I.R.B. 7

8632, 1996–4 I.R.B. 6

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Numerical Finding List1—Continued

Bulletins 1996–1 through 1996–21

Treasury Decisions—Continued

8633, 1996–4 I.R.B. 20

8634, 1996–3 I.R.B. 17

8635, 1996–3 I.R.B. 5

8636, 1996–4 I.R.B. 64

8637, 1996–4 I.R.B. 29

8638, 1996–5 I.R.B. 5

8639, 1996–5 I.R.B. 12

8640, 1996–2 I.R.B. 10

8641, 1996–6 I.R.B. 4

8642, 1996–7 I.R.B. 4

8643, 1996–11 I.R.B. 4

8644, 1996–7 I.R.B. 16

8645, 1996–8 I.R.B. 4

8646, 1996–8 I.R.B. 10

8647, 1996–9 I.R.B. 7

8648, 1996–10 I.R.B. 23

8649, 1996–9 I.R.B. 5

8650, 1996–10 I.R.B. 5

8651, 1996–11 I.R.B. 24

8652, 1996–11 I.R.B. 11

8653, 1996–12 I.R.B. 4

8654, 1996–11 I.R.B. 14

8655, 1996–12 I.R.B. 9

8656, 1996–13 I.R.B. 9

8657, 1996–14 I.R.B. 4

8658, 1996–14 I.R.B. 13

8659, 1996–16 I.R.B. 4

8660, 1996–17 I.R.B. 4

8661, 1996–17 I.R.B. 7

8664, 1996–20 I.R.B. 7

8665, 1996–21 I.R.B. 4

8667, 1996–20 I.R.B. 4

1A cumulative list of all Revenue Rulings,

Revenue Procedures, Treasury Decisions, etc.,

published in Internal Revenue Bulletins 1995–

27 through 1995–52 will be found in Internal

Revenue Bulletin 1996–1, dated January 2,

1996.

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Finding List of Current Action on

Previously Published Items1

Revenue Procedures—Continued

96–31, 1996–20 I.R.B. 11

Bulletins 1996–1 through 1996–21

92–85

Modified by

96–1, 1996–1 I.R.B. 8

95–66

Modified by

96–25, 1996–19 I.R.B. 4

*Denotes entry since last publication

Delegation Orders:

232 (Rev. 1)

Superseded by

232 (Rev. 2), 1996–7 I.R.B. 49

236 (Rev. 1)

Superseded by

236 (Rev. 2), 1996–21 I.R.B. 7*

239

Amended by

239 (Rev. 1), 1996–7 I.R.B. 49

93–16

Superseded by

96–11, 1996–2 I.R.B. 18

93–46

Superseded in part by

96–17, 1996–4 I.R.B. 69

Superseded by

96–18, 1996–4 I.R.B. 73

Revenue Procedures:

94–16

Modified by

96–29, 1996–16 I.R.B. 24

65–17

Modified by

96–14, 1996–3 I.R.B. 41

94–18

Superseded in part by

96–17, 1996–4 I.R.B. 69

66–49

Modified by

96–15, 1996–3 I.R.B. 41

Superseded by

96–18, 1996–4 I.R.B. 73

88–32

Obsoleted by

96–15, 1996–3 I.R.B. 41

88–33

Obsoleted by

96–15, 1996–3 I.R.B. 41

89–19

Superseded by

96–17, 1996–4 I.R.B. 69

89–48

Superseded in part by

96–17, 1996–4 I.R.B. 69

91–22

Modified by

96–1, 1996–1 I.R.B. 8

91–22

Amplified by

96–13, 1996–3 I.R.B. 31

95–7

Superseded by

96–7, 1996–1 I.R.B. 185

95–8

Superseded by

96–8, 1996–1 I.R.B. 187

95–13

Superseded by

96–20, 1996–4 I.R.B. 88

95–20

Superseded by

96–24, 1996–5 I.R.B. 28

95–50

Superseded by

96–3, 1996–1 I.R.B. 82

96–3

Amplified by

96–12, 1996–3 I.R.B. 30

Revenue Rulings:

94–59

Superseded in part by

96–17, 1996–4 I.R.B. 69

66–307

Obsoleted by

96–3, 1996–2 I.R.B. 14

Superseded by

96–18, 1996–4 I.R.B. 73

72–437

Modified by

96–13, 1996–3 I.R.B. 31

94–62

Modified by

96–29, 1996–16 I.R.B. 24

94–77

Superseded by

96–28, 1996–14 I.R.B. 31

95–1

Superseded by

96–1, 1996–1 I.R.B. 8

95–2

Superseded by

96–2, 1996–1 I.R.B. 60

78–294

Obsoleted by

8665, 1996–21 I.R.B. 4

80–80

Obsoleted by

96–3, 1996–2 I.R.B. 14

82–80

Modified by

96–14, 1996–3 I.R.B. 41

92–19

Supplemented in part

96–2, 1996–2 I.R.B. 5

95–3

Superseded by

96–3, 1996–1 I.R.B. 82

92–75

Clarified by

96–13, 1996–3 I.R.B. 31

91–24

Superseded by

96–14, 1996–3 I.R.B. 41

95–4

Superseded by

96–4, 1996–1 I.R.B. 94

95–10

Supplemented and superseded by

96–4, 1996–3 I.R.B. 16

91–26

Superseded by

96–13, 1996–3 I.R.B. 31

95–5

Superseded by

96–5, 1996–1 I.R.B. 129

95–11

Supplemented and superseded by

96–5, 1996–3 I.R.B. 29

92–20

Modified by

96–1, 1996–1 I.R.B. 8

95–6

Superseded by

96–6, 1996–1 I.R.B. 151

96–24

Modified and amplified by

96–24A, 1996–15 I.R.B. 12

91–23

Superseded by

96–13, 1996–3 I.R.B. 31

1A cumulative finding list for previously

published items mentioned in Internal Revenue

Bulletins 1995–27 through 1995–52 will be

found in Internal Revenue Bulletin 1996–1, dated

January 2, 1996.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.