# Bulletin No. 2000–10

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A1c2a69e6713b5b13

## Record

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- **Document type:** Agency decision

## Text

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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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A1c2a69e6713b5b13. Public record. Not legal advice.