Bulletin No. 2000–10

Internal Revenue

bulletin

Bulletin No. 2000–10

March 6, 2000

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

Rev. Rul. 2000–11, page 734.

Federal rates; adjusted federal rates; adjusted federal

long-term rate, and the long-term exempt rate. For

purposes of section 1274, 1288, 382, and other sections

of the Code, tables set forth the rates for March 2000.

EMPLOYEE PLANS

Notice 2000–14, page 737.

Cross-testing; comparability. This notice states that the

Service is undertaking a review of issues posed by “new comparability” retirement plans and invites public comments.

Finding Lists begin on page ii.

Index for January and February begins on page iv.

Department of the Treasury

Internal Revenue Service

ADMINISTRATIVE

Announcement 2000–11, page 739.

The United States recently exchanged instruments of ratification for four new income tax treaties effective January 1,

2000. This information was not included in Publication 515,

Withholding of Tax on Nonresident Aliens and Foreign Corporations (For Withholding in 2000). This announcement provides supplemental tables of income rates and exempt personal service income for Estonia, Latvia, Lithuania, and

Venezuela. It also includes corrected tables for Austria, Ireland, and South Africa.

The IRS Mission

Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities

and by applying the tax law with integrity and fairness to

all.

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 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 proce-

dures 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.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The first Bulletin for each month includes a cumulative index

for the matters published during the preceding months.

These monthly indexes are cumulated on a semiannual basis,

and are published in the first Bulletin of the succeeding semiannual 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, DC 20402.

March 6, 2000

2000–10 I.R.B.

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

Section 42.—Low-Income

Housing Credit

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

Section 280G.—Golden

Parachute Payments

Federal short-term, mid-term, and long-term

rates are set forth for the month of March 2000. See

Rev. Rul. 2000–11, page 734.

Section 382.—Limitation on Net

Operating Loss Carryforwards

and Certain Built-in Losses

Following Ownership Change

The adjusted applicable federal long-term rate is

set forth for the month of March 2000. See Rev. Rul.

2000–11, page 734.

Section 412.—Minimum Funding

Standards

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

Section 467.—Certain Payments

for the Use of Property or

Services

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

Section 468.—Special Rules for

Mining and Solid Waste

Reclamation and Closing Costs

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

March 6, 2000

Section 482.—Allocation of

Income and Deductions Among

Taxpayers

Federal short-term, mid-term, and long-term

rates are set forth for the month of March 2000. See

Rev. Rul. 2000–11, page 734.

Section 483.—Interest on

Certain Deferred Payments

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

Section 642.—Special Rules for

Credits and Deductions

Federal short-term, mid-term, and long-term

rates are set forth for the month of March 2000. See

Rev. Rul. 2000–11, page 734.

Section 807.—Rules for Certain

Reserves

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

the long-term exempt rate. For purposes

of section 1274, 1288, 382, and other sections of the Code, tables set forth the rates

for March 2000.

Rev. Rul. 2000–11

This revenue ruling provides various

prescribed rates for federal income tax

purposes for March 2000 (the current

month.) Table 1 contains the short-term,

mid-term, and long-term applicable federal rates (AFR) for the current month for

purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the

short-term, mid-term, and long-term adjusted applicable federal rates (adjusted

AFR) for the current month for purposes

of section 1288(b). Table 3 sets forth the

adjusted federal long-term rate and the

long-term tax-exempt rate described in

section 382(f). Table 4 contains the appropriate percentages for determining the

low-income housing credit described in

section 42(b)(2) for buildings placed in

service during the current month. Finally,

Table 5 contains the federal rate for determining the present value of an annuity, an

interest for life or for a term of years, or a

remainder or a reversionary interest for

purposes of section 7520.

Section 846.—Discounted

Unpaid Losses Defined

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

Section 1274.—Determination

of Issue Price in the Case of

Certain Debt Instruments Issued

for Property

(Also sections 42, 280G, 382, 412, 467, 468, 482,

483, 642, 807, 846, 1288, 7520, 7872.)

Federal rates; adjusted federal rates;

adjusted federal long-term rate, and

734

2000–10 I.R.B.

REV. RUL. 2000–11 TABLE 1

Applicable Federal Rates (AFR) for March 2000

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

6.45%

7.11%

7.77%

8.43%

6.35%

6.99%

7.62%

8.26%

6.30%

6.93%

7.55%

8.18%

6.27%

6.89%

7.50%

8.12%

6.80%

7.50%

8.19%

8.89%

10.29%

12.05%

6.69%

7.36%

8.03%

8.70%

10.04%

11.71%

6.63%

7.29%

7.95%

8.61%

9.92%

11.54%

6.60%

7.25%

7.90%

8.55%

9.84%

11.43%

6.75%

7.43%

8.13%

8.82%

6.64%

7.30%

7.97%

8.63%

6.59%

7.23%

7.89%

8.54%

6.55%

7.19%

7.84%

8.48%

Short-Term

AFR

110% AFR

120% AFR

130% AFR

Mid-Term

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

Long-Term

AFR

110% AFR

120% AFR

130% AFR

REV. RUL. 2000–11 TABLE 2

Adjusted AFR for March 2000

Period for Compounding

Annual

Semiannual

Quarterly

Monthly

Short-term

adjusted AFR

4.34%

4.29%

4.27%

4.25%

Mid-term

adjusted AFR

4.97%

4.91%

4.88%

4.86%

Long-term

adjusted AFR

5.84%

5.76%

5.72%

5.69%

REV. RUL. 2000–11 TABLE 3

Rates Under Section 382 for March 2000

Adjusted federal long-term rate for the current month

5.84%

Long-term tax-exempt rate for ownership changes during the current month (the highest of

the adjusted federal long-term rates for the current month and the prior two months.)

5.84%

REV. RUL. 2000–11 TABLE 4

Appropriate Percentages Under Section 42(b)(2) for March 2000

Appropriate percentage for the 70% present value low-income housing credit

8.59%

Appropriate percentage for the 30% present value low-income housing credit

3.68%

2000–10 I.R.B.

735

March 6, 2000

REV. RUL. 2000–11 TABLE 5

Rate Under Section 7520 for March 2000

Applicable federal rate for determining the present value of an annuity, an interest for

life or a term of years, or a remainder or reversionary interest

Section 1288.—Treatment of

Original Issue Discounts on TaxExempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

March 6, 2000

Section 7520.—Valuation Tables

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

736

8.2%

Section 7872.—Treatment of

Loans With Below-Market

Interest Rates

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of March 2000. See Rev. Rul. 2000–11, page 734.

2000–10 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous

Review of Issues Raised By

“New Comparability” Plans

Notice 2000-14

I. PURPOSE

The Internal Revenue Service and the

Treasury Department are undertaking a

review of issues posed by “new comparability” plans and invite public comments.

The Service and Treasury believe it is appropriate at this time to review the effect

of these rapidly evolving plan designs

with the benefit of comments from plan

sponsors, plan participants, and other interested parties.

New comparability plans (and similar

plan designs such as “super-integrated”

plans) are defined contribution plans that

generally restrict higher rates of employer

contributions to highly compensated employees. The focus of this review is the

nondiscrimination requirements applicable to these plans.

Section 401(a)(4) of the Internal Revenue Code provides that a plan is a qualified plan only if the contributions or the

benefits provided under the plan do not

discriminate in favor of highly compensated employees. For purposes of determining whether nonelective employer

contributions under a defined contribution

plan discriminate in favor of highly compensated employees, the regulations

under § 401(a)(4) permit such contributions either to be tested on a present value

basis or to be “cross-tested” on a future

value basis. Under this cross-testing

method, contributions are converted to

and tested as equivalent benefits payable

at normal retirement age; the conversion

is done by making an actuarial projection

of the benefits payable at normal retirement age that are attributable to such contributions. Thus, this cross-testing

method effectively permits nonelective

employer contributions under a defined

contribution plan to be tested as the

equivalent of employer-provided benefits

under a defined benefit plan.

Notwithstanding the analytical underpinnings of cross-testing, the Service and

Treasury are concerned whether crosstested plan designs that provide for built-

2000–10 I.R.B.

in disparities in contribution rates between highly compensated and nonhighly

compensated employees can be reconciled with the basic purpose of the nondiscrimination rules as applied to defined

contribution plans. In this regard, the Service and Treasury are reviewing whether

it is appropriate in all cases, without regard to the particular structure of a crosstested defined contribution plan, to allow

the projected future value of employer

contributions to be tested as the equivalent of employer-provided benefits under

a defined benefit plan.

For example, in a typical new comparability plan, highly compensated employees (who tend to be older than a majority

of nonhighly compensated employees) receive high allocation rates (often 18% to

20% of compensation), while nonhighly

compensated employees, regardless of

their age or years of service, receive comparatively low allocation rates (e.g., 3%

of compensation). In the typical case,

there is a sufficient number of young nonhighly compensated employees to enable

the employer to demonstrate compliance

with the nondiscrimination standards by

comparing the actuarially projected value

of the small allocations for those young

nonhighly compensated employees with

the actuarially projected value of the substantially larger allocations for older

highly compensated employees. The Service and Treasury are concerned that, by

plan design, nonhighly compensated employees never have an opportunity to earn

the higher allocation rates as they work

additional years for the employer and

grow older. Further, when a sponsor replaces its existing defined contribution

plan with a new comparability plan, rankand-file employees may suffer significant

reductions in their allocation rates, while

owners and executives may benefit from a

significant increase in their allocation

rates.

II. POSSIBLE APPROACHES

In their review of new comparability

plans, the Service and Treasury are considering what modifications to the existing rules applicable to these plans might

be appropriate. It is anticipated that any

such modifications would be applied to

737

plans, including existing plans, on a

prospective basis only.

One possible approach to address the

issues raised by new comparability plans

would be to provide that, for purposes of

determining whether a defined contribution plan satisfies

§ 1.401(a)(4)–8(b)(1) of the Income

Tax Regulations (i.e., the rules governing

the cross-testing of defined contribution

plans), the right to receive each rate of

nonelective employer contributions must

be currently and effectively available on a

nondiscriminatory basis, determined in a

manner generally patterned after the approach under § 1.401(a)(4)–4 of the regulations. These regulations already contain

a requirement that rates of the other three

basic types of contributions — elective

contributions, after-tax employee contributions, and employer matching contributions — be made currently and effectively

available in a nondiscriminatory manner.

If such an approach were adopted,

however, it is anticipated that, subject to

certain conditions, a plan would be permitted to disregard differences in rates of

nonelective contributions that result from

differences in attained age or service for

purposes of determining whether contribution rates are currently available in a

nondiscriminatory manner. Accordingly,

under such an approach, the Service and

Treasury anticipate that cross-testing

would continue to be a permissible testing

alternative for generic age-weighted or

service-based defined contribution plans

(plans under which younger and shorterservice participants become entitled to

higher allocation rates as they age and accumulate more service) and certain other

appropriate plan designs.

Comments are invited on this and other

possible approaches (including appropriate

exceptions) to address the issues raised by

new comparability plans. It is requested

that comments be submitted by May 15,

2000, and that they refer to Notice

2000–14. Comments can be addressed to

CC:DOM:CORP:R (Notice 2000–14),

room 5226, Internal Revenue Service, POB

7604, Ben Franklin Station, Washington,

DC 20044. In the alternative, comments

may be hand delivered between the hours

of 8 a.m. and 5 p.m. to CC:DOM:CORP:R

March 6, 2000

(Notice 2000–14), Courier’s Desk, Internal

Revenue Service, 1111 Constitution Avenue NW, Washington, DC. Alternatively,

taxpayers may transmit comments electronically via the IRS Internet site at:

http://www.irs.gov/tax_regs/regslist.html.

March 6, 2000

DRAFTING INFORMATION

The principal author of this notice is

James Flannery of the Tax Exempt and

Government Entities Division. For further

information regarding this notice, please

738

contact the Employee Plans’ taxpayer assistance telephone service at (202) 6226074/6075 (not toll-free numbers) between

the hours of 1:30 and 3:30 p.m. Eastern

Time, Monday through Thursday.

2000–10 I.R.B.

Part IV. Items of General Interest

Announcement 2000–11

Changes to Publication 515

Changes apply to Tables 1 and 2 in

Publication 515, Withholding of Tax on

Nonresident Aliens and Foreign Corporations (For Withholding in 2000). These

changes are needed to reflect the new income tax treaties with Estonia, Latvia,

Lithuania, and Venezuela that became effective on January 1, 2000. In addition,

this announcement contains corrections to

Table 2 to provide the current provisions

of the tax treaties with Austria, Ireland,

and South Africa.

Rosalie La Plante,

Acting National Director,

Tax Forms and

Publications Division.

2000–10 I.R.B.

739

March 6, 2000

insert

new

table

here

March 6, 2000

740

2000–10 I.R.B.

insert

new

table

here

2000–10 I.R.B.

741

March 6, 2000

insert

new

table

here

March 6, 2000

742

2000–10 I.R.B.

insert

new

table

here

2000–10 I.R.B.

743

March 6, 2000

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 ap-

plies 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 Procedral 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.

March 6, 2000

i

2000–10 I.R.B.

Numerical Finding List1

Bulletins 2000–1 through 2000–9

Announcements:

2000–1, 2000–2 I.R.B. 294

2000–2, 2000–2 I.R.B. 295

2000–3, 2000–2 I.R.B. 296

2000–4, 2000–3 I.R.B. 317

2000–5, 2000–4 I.R.B. 427

2000–6, 2000–4 I.R.B. 428

2000–7, 2000–6 I.R.B. 586

2000–8, 2000–6 I.R.B. 586

2000–9, 2000–9 I.R.B. 733

2000–10, 2000–9 I.R.B. 733

Notices:

2000–1, 2000–2 I.R.B. 288

2000–2, 2000–9 I.R.B. 727

2000–3, 2000–4 I.R.B. 413

2000–4, 2000–3 I.R.B. 313

2000–5, 2000–3 I.R.B. 314

2000–6, 2000–3 I.R.B. 315

2000–7, 2000–4 I.R.B. 419

2000–8, 2000–4 I.R.B. 420

2000–9, 2000–5 I.R.B. 449

2000–10, 2000–5 I.R.B. 451

2000–11, 2000–6 I.R.B. 572

2000–12, 2000–9 I.R.B. 727

2000–13, 2000–9 I.R.B. 732

Proposed Regulations:

REG–208280–86, 2000–8 I.R.B. 654

REG–209135–88, 2000–8 I.R.B. 681

REG–208254–90, 2000–6 I.R.B. 577

REG–100276–97, 2000–8 I.R.B. 682

REG–101492–98, 2000–3 I.R.B. 326

REG–106012–98, 2000–2 I.R.B. 290

REG–103831–99, 2000–5 I.R.B. 452

REG–103882–99, 2000–8 I.R.B. 702

REG–105089–99, 2000–6 I.R.B. 580

REG–105279–99, 2000–8 I.R.B. 707

REG–105606–99, 2000–4 I.R.B. 421

REG–111119–99, 2000–5 I.R.B. 455

REG–113572–99, 2000–7 I.R.B. 624

REG–116048–99, 2000–6 I.R.B. 584

REG–116567–99, 2000–5 I.R.B. 463

REG–116704–99, 2000–3 I.R.B. 325

REG–100163–00, 2000–7 I.R.B. 633

Revenue Procedures—continued:

2000–15, 2000–5 I.R.B. 447

2000–16, 2000–6 I.R.B. 518

2000–18, 2000–9 I.R.B. 722

2000–20, 2000–6 I.R.B. 553

Revenue Rulings:

2000–1, 2000–2 I.R.B. 250

2000–2, 2000–3 I.R.B. 305

2000–3, 2000–3 I.R.B. 297

2000–4, 2000–4 I.R.B. 331

2000–5, 2000–5 I.R.B. 436

2000–6, 2000–6 I.R.B. 512

2000–7, 2000–9 I.R.B. 712

2000–8, 2000–7 I.R.B. 617

2000–9, 2000–6 I.R.B. 497

2000–10, 2000–8 I.R.B. 643

Treasury Decisions:

8849, 2000–2 I.R.B. 245

8850, 2000–2 I.R.B. 265

8851, 2000–2 I.R.B. 275

8852, 2000–2 I.R.B. 253

8853, 2000–4 I.R.B. 377

8854, 2000–3 I.R.B. 306

8855, 2000–4 I.R.B. 374

8856, 2000–3 I.R.B. 298

8857, 2000–4 I.R.B. 365

8858, 2000–4 I.R.B. 332

8859, 2000–5 I.R.B. 429

8860, 2000–5 I.R.B. 437

8861, 2000–5 I.R.B. 441

8862, 2000–6 I.R.B. 466

8863, 2000–6 I.R.B. 488

8864, 2000–7 I.R.B. 614

8865, 2000–7 I.R.B. 589

8866, 2000–6 I.R.B. 495

8867, 2000–7 I.R.B. 620

8868, 2000–6 I.R.B. 491

8869, 2000–6 I.R.B. 498

8870, 2000–8 I.R.B. 647

8871, 2000–8 I.R.B. 641

8872, 2000–8 I.R.B. 639

8873, 2000–9 I.R.B. 713

8874, 2000–8 I.R.B. 644

Railroad Retirement Quarterly Rate:

2000–9, I.R.B. 721

Revenue Procedures:

2000–1, 2000–1 I.R.B. 4

2000–2, 2000–1 I.R.B. 73

2000–3, 2000–1 I.R.B. 103

2000–4, 2000–1 I.R.B. 115

2000–5, 2000–1 I.R.B. 158

2000–6, 2000–1 I.R.B. 187

2000–7, 2000–1 I.R.B. 227

2000–8, 2000–1 I.R.B. 230

2000–9, 2000–2 I.R.B. 280

2000–10, 2000–2 I.R.B. 287

2000–11, 2000–3 I.R.B. 309

2000–12, 2000–4 I.R.B. 387

2000–13, 2000–6 I.R.B. 515

1 A cumulative list of all revenue rulings, revenue

procedures, Treasury decisions, etc., published in

Internal Revenue Bulletins 1999–27 through

1999–52 is in Internal Revenue Bulletin 2000–1,

dated January 3, 2000.

2000–10 I.R.B.

ii

March 6, 2000

Finding List of Current Action on

Previously Published Items1

Bulletins 2000–1 through 2000–9

Announcements:

99–50

Modified by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

Revenue Procedures—Continued:

Revenue Procedures—Continued:

93–10

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

2000–6

Modified by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

94–12

Modified, amplified, and superseded by

Rev. Proc. 2000–11, 2000–3 I.R.B. 309

2000–8

Modified by both

Rev. Proc. 2000–16, 2000–6 I.R.B. 518 and

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

Notices:

94–42

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

88–125

Obsoleted by

T.D. 8870, 2000–8 I.R.B. 647

96–13

Modified by

Rev. Proc. 2000–1, 2000–1 I.R.B. 4

92–48

Obsoleted by

Notice 2000–11, 2000–6 I.R.B. 572

98–22

Modified and superseded by

Rev. Proc. 2000–16, 2000–6 I.R.B. 518

97–19

Modified by

Rev. Proc. 2000–1, 2000–1 I.R.B. 4

98–27

Superseded by

Rev. Proc. 2000–12, 2000–4 I.R.B. 387

98–22

Obsoleted by

T.D. 8870, 2000–8 I.R.B. 647

98–64

Superseded by

Rev. Proc. 2000–9, 2000–2 I.R.B. 280

98–52

Modified by

Notice 2000–3, 2000–4 I.R.B. 413

99–1

Superseded by

Rev. Proc. 2000–1, 2000–1 I.R.B. 4

98–61

Modified and superseded by

Rev. Proc. 2000–15, 2000–5 I.R.B. 447

99–2

Superseded by

Rev. Proc. 2000–2, 2000–1 I.R.B. 73

99–8

Obsoleted by

Rev. Proc. 2000–12, 2000–4 I.R.B. 387

99–3

Superseded by

Rev. Proc. 2000–3, 2000–1 I.R.B. 103

Revenue Procedures:

99–4

Superseded by

Rev. Proc. 2000–4, 2000–1 I.R.B. 115

80–18

Modified by

Rev. Proc. 2000–13, 2000–6 I.R.B. 515

89–9

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

89–13

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

90–21

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

91–66

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

92–13

Modified, amplified, and superseded by

Rev. Proc. 2000–11, 2000–3 I.R.B. 309

92–13A

Modified, amplified, and superseded by

Rev. Proc. 2000–11, 2000–3 I.R.B. 309

Revenue Rulings:

88–36

Modified by

Rev. Proc. 2000–6, 2000–6 I.R.B. 512

98–30

Amplified and superseded by

Rev. Rul. 2000–8, 2000–7, I.R.B. 617

Treasury Decisions:

8734

Modified by

T.D. 8856, 2000–3, I.R.B. 298

8804

Modified by

T.D. 8856, 2000–3, I.R.B. 298

99–5

Superseded by

Rev. Proc. 2000–5, 2000–1 I.R.B. 158

99–6

Superseded by

Rev. Proc. 2000–6, 2000–1 I.R.B. 187

99–7

Superseded by

Rev. Proc. 2000–7, 2000–1 I.R.B. 227

99–8

Superseded by

Rev. Proc. 2000–8, 2000–1 I.R.B. 230

99–13

Modified and superseded by

Rev. Proc. 2000–16, 2000–6 I.R.B. 518

99–31

Modified and superseded by

Rev. Proc. 2000–16, 2000–6 I.R.B. 518

92–41

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

99–49

Modified and amplified by

Rev. Rul. 2000–4, 2000–4 I.R.B. 331;

Rev. Rul. 2000–7, 2000–9 I.R.B. 712, and

Notice 2000–4, 2000–3 I.R.B. 313

93–9

Superseded by

Rev. Proc. 2000–20, 2000–6 I.R.B. 553

99–51

Superseded by

Rev. Proc. 2000–3, 2000–1 I.R.B. 103

1 A cumulative list of current actions on previously

published items in Internal Revenue Bulletins

1999–27 through 1999–52 is in Internal Revenue

Bulletin 2000–1, dated January 3, 2000.

March 6, 2000

iii

2000–10 I.R.B.

Index

Internal Revenue Bulletins

2000–1 Through 2000–9

The abbreviation and number in parenthesis following the index entry refer to

the specific item; numbers in roman and

italic type following the parenthesis refer

to the Internal Revenue Bulletin in which

the item may be found and the page

number on which it appears.

Key to Abbreviations:

RR

Revenue Ruling

RP

Revenue Procedure

TD

Treasury Decision

CD

Court Decision

PL

Public Law

EO

Executive Order

DO

Delegation Order

TDO

Treasury Department Order

TC

Tax Convention

SPR

Statement of Procedural

Rules

PTE

Prohibited Transaction

Exemption

EMPLOYEE PLANS

Areas in which advance letter rulings and

determination letters will not be issued

from Associate Chief Counsel,

Domestic (RP 3) 1, 103

Areas in which advance letter rulings and

determination letters will not be issued

from Associate Chief Counsel,

International (RP 7) 1, 227

Cash or deferred arrangements:

Elective deferrals (RR 8) 7, 617

Nondiscrimination (Notice 3) 4, 413

Determination letter, issuing procedures

(RP 6) 1, 187

Eligible rollover distributions, safe harbor explanations (Notice 11) 6, 572

EPCRS, closing agreements (RP 16) 6, 518

Full funding limitations, weighted average interest rate for:

January (Notice 8) 4, 420; February

(Notice 2) 9, 727

Letter rulings, determination letters and

information letters issued by Associate

Chief Counsel (RP 1) 1, 4

Letter rulings, information letters, etc.

(RP 4) 1, 115

Master and prototype plans, unified procedures (RP 20) 6, 553

Mortality tables (Ann 7) 6, 586

Qualified retirement plans, remedial

2000–10 I.R.B.

EMPLOYEE PLANS

cont.

EXCISE TAX

cont.

amendment period (TD 8871) 8, 641

Regulations:

26 CFR 1.401(b)–1T, removed; remedial amendment period (TD 8871)

8, 641

26 CFR 1.402(f)–1, amended;

1.411(a)–11, amended; new technologies in retirement plans (TD

8873) 9, 713

Reporting requirements, Section 457

plans (Ann 1) 2, 294

New technologies in retirement plans,

distribution notices and consents (TD

8873) 9, 713

Technical advice to district directors and

chiefs, appeals office from Associate

Chief Counsel (RP 2) 1, 73

Technical advice to IRS employees (RP

5) 1, 158

User fees, request for letter rulings (RP

8) 1, 230

Railroad retirement:

Rate determination quarterly (January

1, 2000) 9, 721

Regulations:

26 CFR 49.4251–4, added; 602.101,

amended; prepaid telephone cards

(TD 8855) 4, 374

Return filing and deposits (Ann 5) 4, 427

EMPLOYMENT TAX

Electronically filed information returns,

due dates (REG–105279–99) 8, 707

Information reporting:

Election workers (RR 6) 6, 512

Proposed Regulations:

26 CFR 31.3402(q)–1, revised;

31.6053–3, revised; 31.6071(a)–1,

revised; extension of due date for

electronically filed information

returns (REG–105279–99) 8, 707

Regulations:

26 CFR 35.3405–1, redesignated as

35.3405–1T, revised; 35.3405–1,

added; new technologies in retirement plans (TD 8873) 9, 713

New technologies in retirement plans,

distribution notices and consents (TD

8873) 9, 713

ESTATE TAX

QTIP elections, individual retirement

accounts and testamentary trusts (RR

2) 3, 305

Marital / Charitable deduction, valuation

of property; administration expenses

(Ann 3) 2, 296

EXCISE TAX

Prepaid telephone cards (TD 8855) 4,

374

iv

EXEMPT

ORGANIZATIONS

Areas in which advance letter rulings and

determination letters will not be issued

from Associate Chief Counsel,

Domestic (RP 3) 1, 103

Information letters available for public

inspection (Ann 2) 2, 295

Letter rulings, information letters, etc.

(RP 4) 1, 115

List of organizations classified as private

foundations (Ann 8) 6, 586

Private foundation disclosure rules (TD

8861) 5, 442

Regulations:

26 CFR 1.513–7, added; travel and

tour activities of tax-exempt organizations (TD 8874) 8, 644

26 CFR 301.6104(d)–1, removed;

301.6104(d)–2, redesignated as

301.6104(d)–0, revised;

301.6104(d)–3, redesignated as

301.6104(d)–1, amended;

301.6104(d)–4, redesignated as

301.6104(d)–2, amended;

301.6104(d)–5, redesignated as

301.6104(d)–3, amended; private

foundation disclosure rules (TD

8861) 5, 442

Technical advice to district directors and

chiefs, and appeals office from

Associate Chief Counsel (RP 2) 1, 73

Technical advice to IRS employees (RP

5) 1, 158

Travel tours, taxation of (TD 8874) 8,

644

User fees, request for letter rulings (RP

8) 1, 230

INCOME TAX

Accounting period change, automatic

consent (RP 11) 3, 309

Acquisitions, recognition of gain on distributions (Ann 10) 9, 733

March 6, 2000

INCOME TAX cont.

INCOME TAX cont.

INCOME TAX cont.

Adequate disclosure of gifts (Ann 6) 4,

428

Allocation of partnership debt, nonrecourse liabilities (REG–103831–99) 5,

452

Amortization of intangible property (TD

8865) 7, 589

Appeals, test of arbitration procedure

(Ann 4) 3, 317

Areas in which advance letter rulings and

determination letters will not be

issued, International (RP 7) 1, 227

Asset acquisitions, allocation of purchase

price (TD 8858) 4, 332

Automobile owners and lessees (RP 18)

9, 722

Barter exchanges, information reporting

(Notice 6) 3, 315

Business Expenses

ISO 9000 costs (RR 4) 4, 331

Traveling expenses, per diem

allowances (RP 9) 2, 280

Substantiation (TD 8864) 7, 614

Canadian banking legislation, repeal,

deferral of termination (Notice 7) 4,

419

Closely-held real estate investment trust,

estimated tax payments, penalty relief

(Notice 5) 3, 314

Contribution in aid of construction, definition (REG–106012–98) 2, 290

Credits:

Low-income housing credit:

Compliance monitoring (TD 8859)

5, 429

Resident population estimates

(Notice 13) 9, 732

Puerto Rico and possession tax credit,

termination of (TD 8868) 6, 491

Research credit, controlled group

(REG–105606–99) 4, 421

Depletion, treatment of delay rental

(REG–103882–99) 8, 702

Depreciation:

MACRS property, involuntary conversion or like-kind exchange (Notice

4) 3, 313; Correction (Ann 9) 9, 733

Determination of underwriting income,

non-life insurance companies (TD

8857) 4, 365

Disclosure of return information, Census

of Agriculture (TD 8854) 3, 306;

(REG–116704–99) 3, 325

Electronically filed information returns,

due dates of (REG–105279–99) 8, 707

Estimated taxes:

Closely-held real estate investment

trust, penalty relief (Notice 5) 3,

314

Equity options with flexible terms, special rules and definitions (TD 8866) 6,

495

Financial asset securitization investment

trusts, general (REG–100276–97;

REG–122450–98) 8, 682

Foreign corporations:

Exclusion of shipping income

(REG–208280–86) 8, 654

Information reporting (TD 8850) 3,

265

Stock transfer rules:

General provisions (TD 8862) 6, 466

Nonrecognition (TD 8863) 6, 488

(REG–116048–99) 6, 584

Foreign currency, hyperinflation; definition (REG–116567–99) 5, 463; (TD

8860) 5, 437

Foreign partnerships:

Information reporting (TD 8850) 3,

265

U.S. persons with reportable event,

reporting requirement (TD 8851) 2,

275

Guidance priority list (Notice 10) 5, 451

Information letters available for public

inspection (Ann 2) 2, 295

Information reporting:

Barter exchange (Notice 6) 3, 315

Foreign partnerships and foreign corporations (TD 8850) 3, 265

Innocent spouse, equitable relief (RP 15)

5, 447

Interest:

Investment:

Federal short-term, mid-term, and

long-term rates for:

January 2000 (RR 1) 2, 250;

February (RR 9) 6, 497

Installment agreements, limitation of failure to pay penalty (REG–105279–99)

8, 707

Inventory:

LIFO:

Price indexes, department stores

November 1999 (RR 3) 3, 297

December 1999 (RR 10) 8, 643

Letter rulings, determination letters and

information letters issued by Associate

Chief Counsel (RP 1) 1, 4

Low-income housing credit:

Compliance monitoring (TD 8859) 5,

429

Resident population estimates (Notice

13) 9, 732

Nonqualified preferred stock, exchanges

and distributions (REG–105089–99) 6,

580

Partnerships:

Allocation of nonrecourse liabilities

(REG–103831–99) 5, 452

Amortization of intangible property

(REG–100163–00) 7, 633

Mergers and divisions

(REG–111119–99) 5, 455

Passive foreign investment companies:

Marketable stock (TD 8867) 7, 620

Qualified electing fund (TD 8870) 8,

647

Postponement of tax-related deadlines;

service in combat zone or

Presidentially declared disaster

(REG–101492–98) 3, 326

Pre-filing agreement pilot program

(Notice 12) 9, 727

Private foundations:

Disclosure rules (TD 8861) 5, 442

Organizations now classified as (Ann

8) 6, 586

Proposed Regulations:

26 CFR 1.41–0, amended; 1.41–8,

revised; credit for increasing

research activities

(REG–105606–99) 4, 421

26 CFR 1.118–2, added; contribution

in aid of construction, definition

(REG–106012–98) 2, 290

26 CFR 1.132–0, amended; 1.132–9,

added; qualified transportation

fringes (REG–113572–99) 7, 624

26 CFR 1.197–2, amended; amortization of intangible property

(REG–100163–00) 7, 633

26 CFR 1.337(d)–5T, added,

1.852–12, added; 1.857–11, added;

certain asset transfers to regulated

investment companies and real

estate investment trusts

(REG–209135–88) 8, 681

26 CFR 1.354–1, amended; 1.355–1,

amended; 1.356–7, added;

1.1036–1, amended; treatment of

nonqualified perferred stock and

other preferred stock in certain

exchanges and distributions

(REG–105089–99) 6, 580

26 CFR 1.367(b)–3, amended; stock

transfer rules (REG–116048–99) 6,

584

March 6, 2000

v

2000–10 I.R.B.

INCOME TAX cont.

26 CFR 1.612–3, amended; depletion,

treatment of delay rental

(REG–103882–99) 8, 702

26 CFR 1.708–1, amended; 1.743–1,

amended; treatment of partnership

mergers and divisions

(REG–111119–99) 5, 455

26 CFR 1.752–3, amended; 1.752–5,

revised; allocation of nonrecourse

liabilities by a partnership

(REG–103831–99) 5, 452

26 CFR 1.860E–1, amended;

1.860H–0, –1, –2, –3, –4, –5, –6,

added; 1.860I–1, –2, added;

1.860J–1, added; 1.860L–1, –2, –3,

–4, added; 1.861–9T, amended;

1.861–10T, amended; financial asset

securitization investment trusts; real

estate mortgage investment conduits

(REG–100276–97;

REG–122450–98) 8, 682

26 CFR 1.861–4, amended; source of

compensation for labor or personal

services (REG–208254–90) 6, 577

26 CFR 1.883–0, added; 1.883–1,

revised; 1.883–2, –3, –4, –5, added;

exclusions from gross income of

foreign corporations

(REG–208280–86) 8, 654

26 CFR 1.988–1, revised; hyperinflationary currencies, definition

(REG–116567–99) 5, 463

26 CFR 1.6041–2, revised; 1.6041–6,

revised; 1.6042–2, revised;

1.6043–2, revised; 1.6044–2,

revised; 1.6045–1, added; 1.6045–2,

revised; 1.6045–4, revised;

1.6047–1, revised; 1.6049–4,

revised; 1.6049–7, revised;

1.6050A–1, revised; 1.6050D–1,

revised; 1.6050E–1, revised;

1.6050H–2, revised; 1.6050J–1T,

revised; 1.6050P–1, revised;

1.6052–1, revised; 301.6651–1,

amended; extension of due date for

electronically filed information

returns; limitation of failure to pay

penalty for individuals during period of installment agreement

(REG–105279–99) 8, 707

26 CFR 301.6103(j)(5)–1, added; disclosure of return information;

Census of Agriculture

(REG–116704–99) 3, 325

26 CFR 301.7508–1, added;

301.7508A–1, added; relief for ser-

2000–10 I.R.B.

INCOME TAX cont.

vice in combat zone and for

Presidentially declared disaster

(REG–101492–98) 3, 326

Qualified transportation fringe benefits

(REG–113572–99) 7, 624

Qualified Zone Academy Bonds (RP 10)

2, 287

Real estate investment trusts, asset transfers to (TD 8872) 8, 639;

(REG–209135–88) 8, 681

Real estate mortgage investment conduits, safe harbor (REG–100276–97;

REG–122450–98) 8, 682

Regulated investment companies, asset

transfers to (TD 8872) 8, 639;

(REG–209135–88) 8, 681

Recharacterizing financing arrangements;

fast-pay stock (TD 8853) 4, 377

Regulations:

26 CFR 1.42–5, –6, –11, –12, –13,

amended; 1.42–17, added; compliance monitoring and miscellaneous

issues relating to the low-income

housing credit (TD 8859) 5, 429

26 CFR 1.62–2, amended; 1.62–2T,

removed; 1.274–5, added;

1.274–5T, amended; substantiation

of business expenses (TD 8864) 7,

614

26 CFR 1.162–11, amended;

1.167(a)–3, amended; 1.167(a)–6,

amended; 1.167(a)–14, added;

1.197–0, added; 1.197–2, added;

amortization of goodwill and certain

other intangibles (TD 8865) 7, 589

26 CFR 1.337(d)–5, added, certain

asset transfers to regulated investment companies and real estate

investment trusts (TD 8872) 8, 639

26 CFR 1.338–0, –1, –2, –3, removed;

1.338–4, redesignated as 1.338–8;

1.338–5, redesignated as 1.338–9;

1.338–4T, –5T, –6T, –7T, –10T,

added; 1.338(b)–1, added;

1.338(b)–2T, –3T, removed;

1.338(h)(10)–1, removed;

1.338(i)–1, removed; 1.338(i)–1T,

added; 1.1060–1T, revised; purchase

price allocations in deemed and

actual asset acquisitions (TD 8858)

4, 332

26 CFR 1.367(a)–3, amended;

1.367(b)–0, added; 1.367(b)–1, –2,

revised; 1.367(b)–3, added;

1.367(b)–4, revised; 1.367(b)–5, –6,

added; 1.367(b)–7, –8, –9, removed;

vi

INCOME TAX cont.

1.381(b)–1, amended; 7.367(b)–1,

–2, –3, –4, –5, –6, –7, –8, –9, –10,

–11, removed; 7.367(b)–12, amended; 7.367(b)–13, removed; stock

transfers rules (TD 8862) 6, 466

26 CFR 1.367(b)–3T, added; stock

transfer rules, (TD 8863) 6, 488

26 CFR 1.401(b)–1, amended;

1.401(b)–1T, removed; remedial

amendment period (TD 8871) 8, 641

26 CFR 1.513–7, added; travel and

tour activities of tax-exempt organizations (TD 8874) 8, 644

26 CFR 1.663(a)–1, amended;

1.663(c)–1, amended; 1.663(c)–2,

revised; 1.663(c)–3, amended;

1.663(c)–4, redesignated as

1.663(c)–5, amended; 1.663(c)–4,

added; 1.663(c)–6, added; separate

shares rule applicable to estates (TD

8849) 2, 245

26 CFR 1.871–14, revised; 1.1441–1,

–4, –5, –6, –8, –9, revised;

1.1443–1, revised; 1.6042–3,

revised; 1.6045–1, revised;

1.6049–5, revised; withholding of

tax on certain U.S. source income

paid to foreign persons; delay of

effective date (TD 8856) 3, 298

26 CFR 1.936–11T, removed;

1.936–11, added; termination of

Puerto Rico and possession tax

credit (TD 8868) 6, 491

26 CFR 1.988–0, amended; 1.988–2,

amended; treatment of income and

expenses from certain hyperinflationary currencies; nonperiodic payments (TD 8860) 5, 437

26 CFR 1.1092(c)–1, added; equity

options with flexible terms (TD

8866) 6, 495

26 CFR 1.1291–1T, redesignated as

1.1291–1, revised; 1.1293–1T,

redesignated as 1.1293–1, revised;

1.1295–0, amended; 1.1295–1T,

redesignated as 1.1295–1, amended;

1.1295–3T, redesignated as

1.1295–3, amended; general rules

for making and maintaining qualified electing fund elections (TD

8870) 8, 647

26 CFR 1.1296(e)–1, added; passive

foreign investment companies, marketable stock (TD 8867) 7, 620

26 CFR 1.1361–0, –1; amended;

1.1361–2, –3, –4, –5, –6, added;

March 6, 2000

INCOME TAX cont.

1.1362–0, amended; 1.1362–2,

amended; 1.1362–8, added;

1,1368–0, amended; 1.1368–2,

amended; 1.1374–8, amended;

301.6109–1, amended; subchapter S

subsidiaries (TD 8869) 6, 498

26 CFR 1.1366–0, –1, added;

1.1366–2, revised; 1.1366–3, –4, –5,

added; 1.1367–0, –1, amended;

1.1367–3, revised; 1.1368–0, –1, –2,

–3, amended; 1.1368–4, revised;

passthrough of items of an S corporation to its shareholders (TD 8852)

2, 253

26 CFR 1.1441–10, added;

1.7701(1)–0, added; 1.7701(1)–3,

added; 602.101(b), amended;

recharacterizing financing arrangements involving fast–pay stock (TD

8853) 4, 377

26 CFR 1.6038–3, added; 1.6038–2,

amended; 1.6038B–1, amended;

1.6038B–2, amended; information

reporting with respect to certain foreign partnerships and certain foreign

corporations (TD 8850) 2, 265

26 CFR 1.6046A–1, added; return

March 6, 2000

INCOME TAX cont.

INCOME TAX cont.

requirement for U.S. persons acquiring or disposing of an interest in a

foreign partnership (TD 8851) 2,

275

26 CFR 301.6103(j)(5)–1T, added;

disclosure of return information;

Census of Agriculture (TD 8854) 3,

306

26 CFR 301.6104(d)–1, removed;

301.6104(d)–2, redesignated as

301.6104(d)–0, revised;

301.6104(d)–3, redesignated as

301.6104(d)–1, amended;

301.6104(d)–4, redesignated as

301.6104(d)–2, amended;

301.6104(d)–5, redesignated as

301.6104(d)–3, amended;

602.101(b), amended; private foundation disclosure rules (TD 8861) 5,

442

Removal costs, capital expenditures (RR

7) 9, 712

Reorganizations:

Solely for voting stock requirement

(Notice 1) 2, 288

Divisive mergers, definition (RR 5) 5,

436

Research credit, controlled group

(REG–105606–99) 4, 421

S corporation passthrough items (TD

8852) 2, 253

Separate shares rules (TD 8849) 2, 245

Sources of income, compensation for

labor or services (REG–208254–90) 6,

577

Subchapter S subsidiaries (TD 8869) 6,

498

Technical advice to district directors and

chiefs, and appeals office from

Associate Chief Counsel (RP 2) 1, 73

United States — United Kingdom Tax

Convention, repeal of advance corporation tax (RP 13) 6, 515

Variable annuity contracts, closing agreements (Notice 9) 5, 449

Withholdings

U.S. source income payments to foreign persons, delay of effective date

(TD 8856) 3, 298

Qualified intermediary withholding

agreements (RP 12) 4, 387

vii

2000–10 I.R.B.

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