Internal Revenue Bulletin 2000-18 (PDF rendition): IRS Announcements

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

INCOME TAX
Rev. Proc. 2000–14, page 960.
Section 911(d)(4) waiver.Guidance is provided to individu-
als who fail to meet the eligibility requirements of section
911(d)(1) of the Code because adverse conditions in a foreign
country preclude the individual from meeting those require-
ments. A current list of countries with the dates those coun-
tries are subject to the section 911(d)(4) waiver is provided.
Rev. Proc. 99–20 supplemented.
ADMINISTRATIVE
Announcement 2000–45, page 962.
This announcement changes the date and location of the
public hearing and provides notice of an extension of time
for submitting comments with respect to proposed regula-
tions (REG–208280–86, 2000–8 I.R.B. 654) relating to ex-
clusions from gross income of foreign corporations under
section 883 of the Code. The hearing is now scheduled for
June 8, 2000.
Internal Revenue
bbuulllleettiinn
Bulletin No. 2000–18
May 1, 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.
Department of the Treasury
Internal Revenue Service
Finding Lists begin on page ii.
Index for January through April begins on page v.

May 1, 20002000–18 I.R.B.
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial 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 sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of in-
ternal 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 pub-
lished rulings and procedures, the effect of subsequent leg-
islation, regulations, court decisions, rulings, and proce-
dures must be considered, and Service personnel and oth-
ers concerned are cautioned against reaching the same con-
clusions 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 Sub-
parts. Also included in this part are Bank Secrecy Act Admin-
istrative 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, disbar-
ment 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 semi-
annual period, respectively.
The IRS Mission
Provide America’s taxpayers top quality service by help-
ing them understand and meet their tax responsibilities
and by applying the tax law with integrity and fairness to
all.
Introduction
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.

Section 911.—Citizens or
Residents of the United States
Living Abroad
26 CFR 1.911–1: Partial exclusion for earned
income from sources within a foreign country and
foreign housing costs.
Guidance is provided to individuals who fail to
meet the eligibility requirements of section
911(d)(1) of the Internal Revenue Code because ad-
verse conditions in a foreign country preclude the
individual from meeting those requirements. A cur-
rent list of countries with the dates those countries
are subject to the section 911(d)(4) waiver is pro-
vided. See Rev. Proc. 2000–14, page 960.
2000–18 I.R.B.959May 1, 2000
Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement;
determination of correct tax liability. (Also Part I, §
911, 1.911–1)
Rev. Proc. 2000–14
SECTION 1. PURPOSE
01. This revenue procedure provides
information to any individual who failed
to meet the eligibility requirements of §
911(d)(1) of the Internal Revenue Code
because adverse conditions in a foreign
country precluded the individual from
meeting those requirements for taxable
year 1999.
02. The Internal Revenue Service has
previously listed countries for which the el-
igibility requirements of § 911(d)(1) of the
Code are waived under § 911(d)(4) because
of adverse conditions in those countries on
and after the date stated. See Rev. Proc.
99–20, 1999–14 I.R.B. 7, Rev. Proc. 98–38,
1998–2 C.B. 28, and Rev. Proc. 97–51,
1997–2 C.B. 526. This revenue procedure
lists countries added to the list in 1999, for
which the eligibility requirements of §
911(d)(1) are waived. Rev. Proc. 99–20,
Rev. Proc. 98–38, and Rev. Proc. 97–51 re-
main in full force and effect.
SEC. 2. BACKGROUND
01. Section 911(a) of the Code allows
a “qualified individual,” as defined in §
911(d)(1), to exclude foreign earned in-
come and housing cost amounts from
gross income. Section 911(c)(3) of the
Code allows a qualified individual to
deduct housing cost amounts from gross
income.
02. Section 911(d)(1) of the Code de-
fines the term “qualified individual” as an
individual whose tax home is in a foreign
country and who is (A) a citizen of the
United States and establishes to the satis-
faction of the Secretary of the Treasury
that the individual has been a bona fide
resident of a foreign country or countries
for an uninterrupted period that includes
an entire taxable year, or (B) a citizen or
resident of the United States who, during
any period of 12 consecutive months, is
present in a foreign country or countries
during at least 330 full days.
03. Section 911(d)(4) of the Code pro-
vides an exception to the eligibility re-
quirements of § 911(d)(1). An individual
will be treated as a qualified individual
with respect to a period in which the indi-
vidual was a bona fide resident of, or was
present in, a foreign country if the indi-
vidual left the country during a period for
which the Secretary of the Treasury, after
consultation with the Secretary of State,
determines that individuals were required
to leave because of war, civil unrest, or
similar adverse conditions that precluded
the normal conduct of business. An indi-
vidual must establish that but for those
conditions the individual could reason-
ably have been expected to meet the eligi-
bility requirements.
04. For 1999, the Secretary of the Trea-
sury in consultation with the Secretary of
State, has determined that war, civil unrest,
or similar adverse conditions that precluded
the normal conduct of business existed in
the following countries beginning on or
after the specified dates:
Date of Departure
CountryOn or After
EritreaFebruary 12, 1999
EthiopiaFebruary 12, 1999
Serbia-MontenegroMarch 20, 1999
05. Accordingly, for purposes of § 911
of the Code, an individual who left one of
the foregoing countries on or after the
specified departure date shall be treated as
a qualified individual with respect to the
period during which that individual was
present in, or was a bona fide resident of,
such foreign country if the individual es-
tablishes a reasonable expectation of
meeting the requirements of § 911(d) but
for those conditions.
06. To qualify for relief under §
911(d)(4) of the Code, an individual must
have established residency or have been
physically present in the foreign country
on or prior to the date that the Secretary of
the Treasury determines that individuals
were required to leave the foreign coun-
try. Individuals who establish residency
or are first physically present in the for-
eign country after the date that the Secre-
tary prescribes, shall not be treated as
qualified individuals under § 911(d)(4) of
the Code pursuant to § 911(d)(4)(C). For
example, individuals who are first physi-
cally present in Eritrea after February 12,
1999, are not eligible to qualify for the
exemption prescribed in § 911(d)(4) of
the Code for taxable year 1999.
07. In order to assist those individuals
who are filing prior year or amended tax
returns, the Internal Revenue Service is
republishing the countries listed for tax
years 1996, 1997 and 1998, for which the
eligibility requirements of § 911(d)(1) of
the Code are waived under § 911(d)(4):
May 1, 20009602000–18 I.R.B.
Part III. Administrative, Procedural, and Miscellaneous
Tax Year 1996 –
Date of Departure
CountryOn or AfterOn or Before
Central African
RepublicMay 21, 1996September 12, 1996

Tax Year 1997 –
Date of Departure
CountryOn or After
AlbaniaMarch 12,1997
CambodiaJuly 9, 1997
Central African
RepublicMarch 28, 1997
Democratic
Republic
of the CongoMay 3, 1997
Republic of the
CongoJune 7, 1997
Sierra LeoneMay 28, 1997
TajikistanNovember 26, 1997
Tax Year 1998 –
Date of Departure
CountryOn or After
AlbaniaAugust 14, 1998
Democratic
Republic
of the CongoAugust 5, 1998
EritreaJune 5, 1998
Guinea-BissauJune 10, 1998
IndonesiaMay 15, 1998
PakistanAugust 16, 1998
Sierra LeoneDecember 23, 1998
Serbia-Montenegro October 11, 1998
SEC. 3. INQUIRES
A taxpayer who needs assistance on
how to claim this exclusion, or on how to
file an amended return, should contact a
local IRS Office or, for a taxpayer resid-
ing or traveling outside the United States,
the nearest overseas IRS office.
SEC. 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 99–20, 1999–14 I.R.B. 7, is
supplemented.
DRAFTING INFORMATION
The principal author of this revenue
procedure is Kate Y. Hwa of the Office of
Associate Chief Counsel (International).
For further information regarding this
revenue procedure contact Ms. Hwa at
(202) 622-3840 (not a toll-free call).
2000–18 I.R.B.961May 1, 2000

May 1, 20009622000–18 I.R.B.
Exclusions From Gross Income
of Foreign Corporations
Announcement 2000–45
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Proposed rule; change of date
and location of the public hearing; and ex-
tension of time for public comments.
SUMMARY: This document changes the
date and location of the public hearing
and provides notice of an extension of
time for submitting comments with re-
spect to a notice of proposed rulemaking
and notice of public hearing (REG–
208280–86, 2000–8 I.R.B. 654) relating
to exclusions from gross income of for-
eign corporations under section 883 of the
Internal Revenue Code.
DATES: Written and electronically gener-
ated comments must be received by May
19, 2000. The public hearing is being
held on Thursday, June 8, 2000, at 10 a.m.
Requests to speak and outlines of topics
to be discussed at the public hearing must
be received by May 19, 2000.
ADDRESSES: Send submissions to:
CC:DOM:CORP:R (REG–208280–86),
room 5226, Internal Revenue Service,
POB 7604, Ben Franklin Station, Wash-
ington, DC 20044. Submissions may be
hand delivered between the hours of 8
a.m. and 5 p.m. to: CC:DOM:CORP:R
(REG–208280–86), Courier’s Desk, In-
ternal Revenue Service, 1111 Constitution
Avenue, NW., Washington, DC. Alter-
nately, taxpayers may submit comments
electronically via the Internet by selecting
the “Tax Regs” option on the IRS Home
Page, or by submitting comments directly
to the IRS internet site at
http://www.irs.ustreas.gov/tax_regs/regsli
st.html. The public hearing originally
scheduled in the Internal Revenue Build-
ing, room 2615, 1111 Constitution Av-
enue, NW., Washington, DC, is changed
to room 4718, in the Internal Revenue
Building, 1111 Constitution Avenue, NW.,
Washington, DC, beginning at 10 a.m.
FOR FURTHER INFORMATION CON-
TACT: Concerning the regulations, Patri-
cia A. Bray, (202) 622-3880; concerning
submissions of comments, the hearing,
and/or to be placed on the building access
list to attend the hearing, contact Guy R.
Traynor (202) 622-7180 (not toll-free
numbers).
SUPPLEMENTARY INFORMATION:
A notice of proposed rulemaking and no-
tice of public hearing appearing in the
Federal Registeron Tuesday, February
8, 2000 (65 FR 6065), announced that a
public hearing on proposed regulations
relating to exclusions from gross income
of foreign corporations under section 883,
would be held on Thursday, April 27,
2000, beginning at 10 a.m. in room 2615
of the Internal Revenue Building, 1111
Constitution Avenue, NW., Washington,
DC, and that requests to speak and out-
lines of oral comments should be received
by Wednesday, April 5, 2000.
The date and location of the public
hearing has changed, and the deadline for
submitting written comments, requests to
speak with outlines of topics to be dis-
cussed at the hearing, has been extended.
The hearing is scheduled for Thursday,
June 8, 2000, beginning at 10 a.m. in
room 4718 of the Internal Revenue Build-
ing, 1111 Constitution Avenue, NW.,
Washington, DC. The date by which writ-
ten comments on proposed rules, and re-
quests to speak with outlines of topics to
be discussed at the hearing must be deliv-
ered or mailed, is hereby extended to May
19, 2000.
The IRS will prepare an agenda show-
ing the scheduling of speakers after the
outlines are received from the persons tes-
tifying and make copies available free of
charge at the hearing, or in the Freedom
of Information Reading Room (Room
1621), approximately one week prior to
the hearing.
Cynthia E. Grigsby,
Chief, Regulations Unit,
Assistant Chief Counsel (Corporate).
(Filed by the Office of the Federal Register on
March 28, 2000, 8:45 a.m., and published in the
issue of the Federal Register for March 29, 2000, 65
F.R. 16554)
Part IV. Items of General Interest

2000–18 I.R.B.iMay 1, 2000
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 pub-
lished 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously
published ruling and points out an essen-
tial 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 pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. 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 sub-
stance has been included in regulations
subsequently adopted.
Revoked describes situations where the
position in the previously published rul-
ing 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 pe-
riod 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 pub-
lished 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 super-
seded.
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 pub-
lished 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
The following abbreviations in current use and for-
merly 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.
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.
Definition of Terms

May 1, 2000ii2000–18 I.R.B.
Numerical Finding List
1
Bulletins 2000–1 through 2000–17
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
2000–11, 2000–10 I.R.B. 739
2000–12, 2000–12 I.R.B. 835
2000–13, 2000–11 I.R.B. 771
2000–14, 2000–11 I.R.B. 772
2000–15, 2000–12 I.R.B. 837
2000–16, 2000–12 I.R.B. 837
2000–17, 2000–13 I.R.B. 846
2000–18, 2000–13 I.R.B. 846
2000–24, 2000–14 I.R.B. 855
2000–25, 2000–14 I.R.B. 855
2000–26, 2000–15 I.R.B. 876
2000–27, 2000–15 I.R.B. 876
2000–28, 2000–15 I.R.B. 876
2000–29, 2000–15 I.R.B. 877
2000–30, 2000–15 I.R.B. 877
2000–31, 2000–15 I.R.B. 877
2000–32, 2000–15 I.R.B. 879
2000–33, 2000–15 I.R.B. 878
2000–34, 2000–15 I.R.B. 879
2000–35, 2000–16 I.R.B. 922
2000–36, 2000–16 I.R.B. 947
2000–37, 2000–16 I.R.B. 947
2000–38, 2000–16 I.R.B. 948
2000–39, 2000–16 I.R.B. 948
2000–40, 2000–16 I.R.B. 948
2000–41, 2000–16 I.R.B. 949
2000–42, 2000–16 I.R.B. 949
2000–43, 2000–17 I.R.B. 957
2000–44, 2000–17 I.R.B. 958
Court Decisions:
2066, 2000–15 I.R.B. 867
2067, 2000–15 I.R.B. 863
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
2000–14, 2000–10 I.R.B. 737
2000–15, 2000–12 I.R.B. 826
2000–16, 2000–12 I.R.B. 826
Notices—continued:
2000–17, 2000–12 I.R.B. 827
2000–18, 2000–13 I.R.B. 845
2000–19, 2000–13 I.R.B. 845
2000–20, 2000–14 I.R.B. 851
2000–22, 2000–16 I.R.B. 902
2000–23, 2000–17 I.R.B. 952
2000–24, 2000–17 I.R.B. 952
2000–25, 2000–17 I.R.B. 954
2000–26, 2000–17 I.R.B. 954
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–209601–92, 2000–12 I.R.B. 829
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–109101–98, 2000–16 I.R.B. 903
REG–110311–98, 2000–11 I.R.B. 767
REG–103831–99, 2000–5 I.R.B. 452
REG–103882–99, 2000–8 I.R.B. 706
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–107872–99, 2000–16 I.R.B. 911
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–117162–99, 2000–15 I.R.B. 871
REG–100163–00, 2000–7 I.R.B. 633
REG–100291–00, 2000–16 I.R.B. 917
REG–103735–00, 2000–11 I.R.B. 770
REG–103736–00, 2000–11 I.R.B. 768
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
2000–15, 2000–5 I.R.B. 447
2000–16, 2000–6 I.R.B. 518
2000–17, 2000–11 I.R.B. 766
2000–18, 2000–9 I.R.B. 722
2000–19, 2000–12 I.R.B. 785
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
Revenue Rulings—continued:
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
2000–11, 2000–10 I.R.B. 734
2000–12, 2000–11 I.R.B. 744
2000–13, 2000–12 I.R.B. 774
2000–14, 2000–12 I.R.B. 779
2000–15, 2000–12 I.R.B. 774
2000–16, 2000–12 I.R.B. 780
2000–17, 2000–13 I.R.B. 842
2000–18, 2000–14 I.R.B. 847
2000–19, 2000–14 I.R.B. 849
2000–20, 2000–16 I.R.B. 880
2000–21, 2000–16 I.R.B. 881
2000–22, 2000–16 I.R.B. 880
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
8875, 2000–11 I.R.B.761
8876, 2000–11 I.R.B.753
8877, 2000–11 I.R.B.747
8878, 2000–15 I.R.B.857
8879, 2000–16 I.R.B.882
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.

2000–18 I.R.B.iiiMay 1, 2000
Finding List of Current Actions on
Previously Published Items
1
Bulletins 2000–1 through 2000–17
Announcements:
99–40
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
99–50
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–18
Corrected by
Announcement 2000–32, 2000–15 I.R.B. 878
Notices:
88–125
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
92–48
Obsoleted by
Notice 2000–11, 2000–6 I.R.B. 572
97–19
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Obsoleted by
T.D. 8870, 2000–8 I.R.B. 647
98–52
Modified by
Notice 2000–3, 2000–4 I.R.B. 413
98–61
Modified and superseded by
Rev. Proc. 2000–15, 2000–5 I.R.B. 447
99–8
Obsoleted by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
2000–4
Corrected by
Announcement 2000–9, 2000–9 I.R.B. 733
Proposed Regulations:
REG–209601–92
Corrected by
Announcement 2000–40, 2000–16 I.R.B. 948
REG–100276–97
Corrected by
Announcement 2000–38, 2000–16 I.R.B. 948
REG–101492–98
Corrected by
Announcement 2000–16, 2000–12 I.R.B. 837
REG–113572–99
Corrected by
Announcement 2000–41, 2000–16 I.R.B. 949
REG–103736–00
Corrected by
Announcement 2000–44, 2000–17 I.R.B. 958
Revenue Procedures:
80–18
Modified by
Rev. Proc. 2000–13, 2000–6 I.R.B. 515
Revenue Procedures—Continued:
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
92–41
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–9
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
93–10
Superseded 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
95–42
Superseded by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
96–13
Modified by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
98–22
Modified and superseded by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
98–27
Superseded by
Rev. Proc. 2000–12, 2000–4 I.R.B. 387
98–64
Superseded by
Rev. Proc. 2000–9, 2000–2 I.R.B. 280
98–65
Superseded by
Rev. Proc. 2000–19, 2000–12 I.R.B. 785
99–1
Superseded by
Rev. Proc. 2000–1, 2000–1 I.R.B. 4
99–2
Superseded by
Rev. Proc. 2000–2, 2000–1 I.R.B. 73
99–3
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
99–4
Superseded by
Rev. Proc. 2000–4, 2000–1 I.R.B. 115
Revenue Procedures—Continued:
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
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
Notice 2000–4, 2000–3 I.R.B. 313
99–51
Superseded by
Rev. Proc. 2000–3, 2000–1 I.R.B. 103
2000–6
Modified by
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–8
Modified by
Rev. Proc. 2000–16, 2000–6 I.R.B. 518
Rev. Proc. 2000–20, 2000–6 I.R.B. 553
2000–16
Corrected by
Announcement 2000–17, 2000–13 I.R.B. 846
Revenue Rulings:
57–259
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
57–499
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
73–292
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
78–218
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
86–62
Obsoleted by
T.D. 8879, 2000–16 I.R.B. 882
88–36
Modified by
Rev. Rul. 2000–6, 2000–6 I.R.B. 512
89–89
Obsoleted by
Rev. Rul. 2000–2, 2000–3 I.R.B. 305
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.

May 1, 2000iv2000–18 I.R.B.
Revenue Rulings—continued:
92–19
Supplemented by
Rev. Rul. 2000–17, 2000–13 I.R.B. 842
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
8845
Corrected by
Announcement 2000–6, 2000–4 I.R.B. 428
8846
Corrected by
Announcement 2000–3, 2000–2 I.R.B. 296
8847
Corrected by
Announcement 2000–13, 2000–11 I.R.B. 771
8849
Corrected by
Announcement 2000–28, 2000–15 I.R.B. 876
8852
Corrected by
Announcement 2000–18, 2000–13 I.R.B. 846
8853
Corrected by
Announcement 2000–33, 2000–15 I.R.B. 878
8856
Corrected by
Announcement 2000–31, 2000–15 I.R.B. 877
8859
Corrected by
Announcement 2000–27, 2000–15 I.R.B. 876
8864
Corrected by
Announcement 2000–26, 2000–15 I.R.B. 876
8865
Corrected by
Announcement 2000–37, 2000–16 I.R.B. 947
8867
Corrected by
Announcement 2000–30, 2000–15 I.R.B. 877
8869
Corrected by
Announcement 2000–36, 2000–16 I.R.B. 947
8870
Corrected by
Announcement 2000–34, 2000–15 I.R.B. 879
8874
Corrected by
Announcement 2000–29, 2000–15 I.R.B. 877

Index
Internal Revenue Bulletins
2000–1 Through 2000–17
The abbreviation and number in paren-
thesis 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:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction
Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural
Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
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
Cafeteria plans, treatment of (TD 8878)
15, 857; (REG-117162–99) 15, 871
Cash or deferred arrangements:
Elective deferrals (RR 8) 7, 617
Nondiscrimination (Notice 3) 4, 413
Determination letters, issuing procedures
(RP 6) 1, 187
Eligible rollover distributions, safe har-
bor explanations (Notice 11) 6, 572
EPCRS, closing agreements (RP 16) 6,518;
correction (Ann 17) 13,846
Full funding limitations, weighted aver-
age interest rate for:
January (Notice 8) 4, 420
February (Notice 2) 9,727
March (Notice 18) 13, 845
April (Notice 25) 17, 954
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 pro-
cedures (RP 20) 6, 553
Minimum funding standards:
Amortization bases (RR 20) 16, 880
Waiver of the 100 percent tax (RP 17)
11, 766
Mortality tables (Ann 7) 6, 586
New comparability plans, nondiscrimina-
tion (Notice 14) 10, 737
New technologies in retirement plans,
distribution notices and consents (TD
8873) 9, 713
Proposed Regulations:
26 CFR 1.125–1, amended; 1.125–2,
amended; 1.125–4, amended; tax
treatment of cafeteria plans
(REG–117162–99) 15, 871
26 CFR 1.411(d)–4, amended; special
rules regarding optional forms of
benefit under qualified retirement
plans (REG–109101–98) 16, 903
Qualified retirement plans:
Optional forms of benefit
(REG–109101–98) 16, 903
Remedial amendment period (TD
8871) 8, 641
Regulations:
26 CFR 1.125–4, added; 1.125–4T,
amended; tax treatment of cafeteria
plans (TD 8878) 15, 857
26 CFR 1.401(b)–1T, removed; reme-
dial amendment period (TD 8871)
8, 641
26 CFR 1.402(f)–1, amended;
1.411(a)–11, amended; new tech-
nologies in retirement plans (TD
8873) 9,713
Reporting requirements, section 457
plans (Ann 1) 2, 294
Technical advice to district directors and
chiefs, appeals offices, 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
EMPLOYMENT TAX
Electronically filed information returns,
due dates (REG–105279–99) 8, 707
EPCRS, closing agreements (RP 16) 6,
518; correction (Ann 17) 13, 846
Information reporting:
Election workers (RR 6) 6,512
New technologies in retirement plans,
distribution notices and consents (TD
8873) 9, 713
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
Railroad retirement, quarterly rate
beginning January 1, 2000, 9, 721
Regulations:
26 CFR 35.3405–1, redesignated as
35.3405–1T, revised; 35.3405–1,
added; new technologies in retire-
ment plans (TD 8873) 9, 713
ESTATE TAX
Guaranteed annuity interests and unitrust
interests (REG–100291–00) 16, 917
Marital / charitable deduction, valuation
of property; administration expenses
(Ann 3) 2, 296
Proposed Regulations:
26 CFR 1.170A–6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; guaranteed annuity inter-
ests and unitrust interests
(REG–100291–00) 16, 917
QTIP elections, individual retirement
accounts and testamentary trusts (RR
2) 3, 305
Valuation tables (Ann 25) 14, 855
EXCISE TAX
Gasoline and diesel fuel dye injection
systems, partial withdrawal of
REG–209735–95 (Ann 42) 16, 949
Imported substances, tax on (Ann 43) 17,
957
Kerosene tax; aviation fuel tax; taxable
fuel measurement and reporting; tax
on heavy trucks and trailers; highway
use tax (TD 8879) 16,882
Minimum funding standards, waiver of
(RP 17) 11, 766
Prepaid telephone cards (TD 8855) 4,
374
Regulations:
26 CFR 40.6011(a)–1, amended;
2000–18 I.R.B.vMay 1, 2000
EMPLOYEE PLANS—
cont.
EMPLOYMENT TAX—
cont.

41.0–1, revised; 41.02–2, –3,
removed; 41.4481–1T, 1.4481–1,
–2, amended; 41.4481–1T, removed;
41.4482(a)–1, amended;
41.4482(b)–1, amended;
41.4482(b)–1T, removed;
41.4482(c)–1, amended; 41.4483–1,
revised; 41.4483–2, –3, amended;
41.4483–5, removed; 41.4484–1,
removed; 41.6001–1, –2, amended;
41–6011(a)–1, revised;
41.6071(a)–1, amended;
41.6081(a)–1, removed; 41.6091–1,
revised; 41–6101–1, revised;
41.6109–1, revised; 41.6151(a)–1,
revised; 41.6161(a)(1)–1, removed;
41.6302(b)–1, removed; 41.7805–1,
removed; Part 47, removed; 48.0–2,
amended; 48.4041–21, amended;
48.4052–1, added; 48.4081–1,
amended; 48.4081–1T, removed;
48.4081–2, –3, –6, –7, –8, amended;
48.4081–9, removed; 48.4082–1,
amended; 48.4082–2, –3, revised;
48.4082–4, –5, amended;
48.4082–6, –7, added; 48.4082–6T,
–7T, –8T, –9T, –10T, removed;
48.4083–1, amended; 48.4091–3T,
redesignated as 48.4091–3, amend-
ed; 48.4101–3T, removed;
48.4101–1, –2, amended;
48.4102–2T, removed; 48.4221–1,
amended; 48.4222(b)–1, amended;
48.6416(b)(2)–1, –2, amended;
48.6420–7, removed; 48.6420(c)–2,
removed; 48.6421–2, amended;
48.6427–8, –9, amended;
48.6427–10T, –11T, removed;
48.6427–10, –11, added; 48.6715–1,
amended; 145.4051–1, amended;
145.4052–1, amended; kerosene tax;
aviation fuel tax; taxable fuel mea-
surement and reporting; tax on
heavy trucks and trailers; highway
use tax (TD 8879) 16, 882
26 CFR 49.4251–4, added; 602.101,
amended; prepaid telephone cards
(TD 8855) 4, 374
Return filing and deposits (Ann 5) 4,
427
Areas in which advance letter rulings and
determination letters will not be issued
from Associate Chief Counsel,
Domestic (RP 3) 1, 103
Charitable split dollar insurance, report-
ing requirements (Notice 24) 17, 952
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, 441
Proposed Regulations:
26 CFR 1.170A–9(e)(6)(i), amended;
1.509(a)–3(f)(1), amended;
1.512(a)–1(e), amended; 1.513–4,
withdrawn; 1.513–4, added; taxation
of tax-exempt organizations’ income
from corporate sponsorship
(REG–209601–92) 12, 829; correc-
tion (Ann 40) 16, 948
Regulations:
26 CFR 1.513–7, added; travel and
tour activities of tax-exempt organi-
zations (TD 8874) 8, 644; correction
(Ann 29) 15, 877
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, 441
Revocations:
(Ann 15) 12, 837
(Ann 39) 16, 948
Sponsorship payments, taxation of
(REG–209601–92) 12, 829; correction
(Ann 40) 16, 948
Technical advice to district directors and
chiefs, appeals offices, 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; correction (Ann 29) 15, 877
User fees, request for letter rulings (RP
8) 1, 230
Guaranteed annuity interests and unitrust
interests (REG–100291–00) 16, 917
Proposed Regulations:
26 CFR 1.170A-6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; guaranteed annuity inter-
ests and unitrust interests
(REG–100291–00) 16, 917
INCOME TAX
Accounting period change, automatic
consent (RP 11) 3, 309
Acquisitions, recognition of gain on dis-
tributions (Ann 10) 9, 733
Adequate disclosure of gifts (Ann 6) 4,
428
Advance pricing agreements (Ann 35)
16, 922
Allocation of partnership debt, nonre-
course liabilities (REG–103831–99) 5,
452
Amortization of intangible property (TD
8865) 7, 589; correction (Ann 37) 16,
947
Appeals, test of arbitration procedure
(Ann 4) 3, 317
Areas in which advance letter rulings and
determination letters will not be issued
from Associate Chief Counsel,
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
Substantiation (TD 8864) 7,614; cor-
rection (Ann 26) 15,876
Traveling expenses, per diem
allowances (RP 9) 2, 280
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, defi-
nition (REG–106012–98) 2, 290
Credits:
Low-income housing credit:
Compliance monitoring (TD 8859)
May 1, 2000vi2000–18 I.R.B.
EXCISE TAX—cont.EXEMPT
ORGANIZATIONS
GIFT TAX

5, 429; correction (Ann 27) 15,
876
Resident population estimates
(Notice 13) 9, 732
Satisfactory bond; “bond factor”
amounts for the period January
through March 2000 (RR 22) 16,
880
Puerto Rico and possession tax credit,
termination of (TD 8868) 6, 491
Research credit, controlled group
(REG–105606–99) 4, 421
Debt instrument (RR 12) 11, 744
Depletion, treatment of delay rental
(REG–103882–99) 8, 706
Depreciation:
MACRS property, involuntary conver-
sion 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
Equity options with flexible terms, special
rules and definitions (TD 8866) 6, 495
Estimated taxes:
Closely-held real estate investment
trust, penalty relief (Notice 5) 3,
314
Date deemed paid (CD 2066) 15, 867
Filing requirements:
Northeastern taxpayers, due dates
(Notice 17) 12, 827
Financial asset securitization investment
trusts, general (REG–100276–97;
REG–122450–98) 8, 682; correction
(Ann 38) 16, 948
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:
Gains and losses, qualified business
units (Notice 20) 14, 851
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
Foreign persons, distributions to (Ann
24) 14, 855
Form SS-4, interim waiver of signature
(Notice 19) 13, 845
Fringe benefits:
Aircraft valuation (RR 13) 12, 774
Qualified transportation
(REG–113572–99) 7,624; correc-
tion (Ann 41) 61,949
Guaranteed annuity interests and unitrust
interests, definition of (REG–100291–
00) 16, 917
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
Discharges of indebtedness, penalties
for (Notice 22) 16, 902
Foreign partnerships and foreign cor-
porations (TD 8850) 3, 265
Innocent spouse, equitable relief (RP 15)
5, 447
Installment agreements, limitation of fail-
ure to pay penalty (REG–105279–99)
8, 707
Installment sales (Notice 26) 17, 954
Insurance companies:
Differential earnings rate, tentative
(Notice 16) 12, 826
Prevailing state assumed interest
rates (RR 17) 13, 842
Interest:
Investment:
Federal short-term, mid-term, and
long-term rates for:
January 2000 (RR 1) 2, 250
February 2000 (RR 9) 6,497
March 2000 (RR 11) 10, 734
April 2000 (RR 19) 14, 849
Rates:
Underpayment and overpayment,
quarter beginning April 1, 2000
(RR 16) 12, 780
Inventory:
LIFO:
Price indexes, department stores:
November 1999 (RR 3) 3, 297
December 1999 (RR 10) 8,643
January 2000 (RR 14) 12,779
February 2000 (RR 21) 16, 881
Letter rulings, determination letters and
information letters issued by Associate
Chief Counsel (RP 1) 1, 4
Major disaster and emergency areas,
losses (RR 15 ) 12, 774
Nonconventional source fuel credit,
inflation adjustment factor and refer-
ence price (Notice 23) 17, 952
Nonqualified preferred stock, exchanges
and distributions (REG–105089–99) 6,
580
Partnerships:
Adjustments following sales (Ann 13)
11, 771
Allocation of basis adjustments among
partnership assets
(REG–107872–99) 16, 911
Allocation of nonrecourse liabilities
(REG–103831–99) 5,452
Amortization of intangible property
(REG–100163–00) 7, 633
Basis adjustments, residual method,
valuation of partnership assets
including goodwill
(REG–107872–99) 16, 911
Mergers and divisions
(REG–111119–99) 5, 455
Qualified replacement property, trans-
fer to (RR 18) 14, 847
Passive foreign investment companies:
Marketable stock (TD 8867) 7, 620;
correction (Ann 30) 15,877
Qualified electing fund (TD 8870) 8,
647; correction (Ann 34) 15, 879
Pre-filing agreement pilot program
(Notice 12) 9, 727
Presidentially declared disaster and com-
bat zone, relief (REG–101492–98) 3,
326; correction (Ann 16) 12, 837
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
2000–18 I.R.B.viiMay 1, 2000
INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont.

in aid of construction, definition
(REG–106012–98) 2, 290
26 CFR 1.132–0, amended; 1.132–9,
added; qualified transportation
fringe benefits (REG–113572–99) 7,
624; correction (Ann 41) 16, 949
26 CFR 1.170A–6, amended;
20.2055–2, amended; 25.2522(c)–3,
amended; lifetime charitable lead
trusts (REG–100291–00) 16, 917
26 CFR 1.197–2, amended; amortiza-
tion 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
26 CFR 1.612–3, amended; depletion,
treatment of delay rental
(REG–103882–99) 8, 706
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 1.755–2, added; 1.755–2T,
removed; allocation of basis adjust-
ments among partnership assets
(REG–107872–99) 16, 911
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; correction
(Ann 38) 16,948
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; hyperinfla-
tionary currencies, definition
(REG–116567–99) 5, 463
26 CFR 1.6011–4, added; tax shelter
disclosure statements
(REG–103735–00) 11, 770
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 peri-
od of installment agreement
(REG–105279–99) 8, 707
26 CFR 301.6103(j)(5)–1, added; dis-
closure of return information;
Census of Agriculture
(REG–116704–99) 3, 325
26 CFR 301.6111–2, added; corporate
tax shelter registration
(REG–110311–98) 11, 767
26 CFR 301.6112–1, amended;
requirements to maintain list of
investors in potentially abusive tax
shelters (REG–103736–00) 11, 768;
correction (Ann 44) 17, 958
26 CFR 301.7508–1, added;
301.7508A–1, added; relief for ser-
vice in combat zone and for
Presidentially declared disaster
(REG–101492–98) 3, 326; correc-
tion (Ann 16) 12, 837
Publications:
515, changes to Tables 1 and 2 (Ann
11) 10, 739
1167, substitute forms, general
requirements (RP 19) 12, 785
1212, supplemental information (Ann
14) 11, 772
Qualified Zone Academy Bonds (RP 10)
2, 287
Real estate investment trusts, asset trans-
fers to (TD 8872) 8, 639;
(REG–209135–88) 8, 681
Real estate mortgage investment con-
duits, safe harbor (REG–100276–97;
REG–122450–98) 8, 682; correction
(Ann 38) 16,948
Recharacterizing financing arrangements,
fast-pay stock (TD 8853) 4, 377; cor-
rection (Ann 33) 15, 878
Regulated investment companies, asset
transfers to (TD 8872) 8, 639;
(REG–209135–88) 8, 681
Regulations:
26 CFR 1.42–5, –6, amended; 1.42
–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; correction (Ann 26) 15, 876
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;
correction (Ann 37) 16, 947
26 CFR 1.337(d)–5, added, certain
asset transfers to regulated invest-
ment 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;
May 1, 2000viii2000–18 I.R.B.
INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont.

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;
1.381(b)–1, amended; 7.367(b)–1,
–2, –3, –4, –5, –6, –7, –8, –9, –10,
–11, removed; 7.367(b)–12, amend-
ed; 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 1.367(e)–1, –2, corrected;
treatment of distributions to foreign
persons (Ann 24) 14, 855
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 organi-
zations (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; correction (Ann 28)
15,876
26 CFR 1.664–2, corrected; use of
actuarial tables in valuing annuities,
interests for life or term of years,
and remainder or reversionary inter-
ests (Ann 25) 14, 855
26 CFR 1.743–1, 1.754–1, 1.755–1,
corrected; adjustments following
sales of partnership interests (Ann
13) 11, 771
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;
correction (Ann 31) 15, 877
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 hyperinfla-
tionary currencies; nonperiodic pay-
ments (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 quali-
fied electing fund elections (TD
8870) 8, 647; correction (Ann 34)
15,879
26 CFR 1.1296(e)–1, added; passive
foreign investment companies, mar-
ketable stock (TD 8867) 7, 620; cor-
rection (Ann 30) 15,877
26 CFR 1.1361–0, –1; amended;
1.1361–2, –3, –4, –5, –6, added;
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; cor-
rection (Ann 36) 16,947
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 corpo-
ration to its shareholders (TD 8852)
2, 253; correction (Ann 18) 13,846;
correction (Ann 32) 15,878
26 CFR 1.1441–10, added; 1.7701(1)–0,
added; 1.7701(1)–3, added;
602.101(b), amended; recharacteriz-
ing financing arrangements involving
fast–pay stock (TD 8853) 4, 377; cor-
rection (Ann 33) 15,878
26 CFR 1.6011–4T, added; tax shelter
disclosure statements (TD 8877) 11,
747
26 CFR 1.6038–3, added; 1.6038–2,
amended; 1.6038B–1, amended;
1.6038B–2, amended; information
reporting with respect to certain for-
eign partnerships and certain foreign
corporations (TD 8850) 2, 265
26 CFR 1.6046A–1, added; return
requirement for U.S. persons acquir-
ing 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 foun-
dation disclosure rules (TD 8861) 5,
442
26 CFR 301.6111–2T, added; corpo-
rate tax shelter registration (TD
8876) 11, 753
26 CFR 301.6112–1T, amended;
requirements to maintain list of
investors in potentially abusive tax
shelters (TD 8875) 11, 761
Removal costs, capital expenditures (RR
7) 9, 712
Reorganizations:
Divisive mergers, definition (RR 5) 5,
436
Solely for voting stock requirement
(Notice 1) 2, 288
Research credit, controlled group
(REG–105606–99) 4, 421
S corporations:
Passthrough items (TD 8852) 2, 253;
correction (Ann 18) 13,846; correc-
tion (Ann 32) 15,878
Subsidiaries (TD 8869) 6, 498; correc-
tion (Ann 36) 16,947
Separate shares rules (TD 8849) 2, 245;
correction (Ann 28) 15,876
Short-term Treasury bills (Ann 14) 11,
772
Sources of income, compensation for
labor or services (REG–208254–90) 6,
577
Tax conventions:
New treaties with Estonia, Latvia,
Lithuania, Venezuela;
Publication 515 changes (Ann 11)
10, 739
2000–18 I.R.B.ixMay 1, 2000
INCOME TAX—cont.INCOME TAX—cont.INCOME TAX—cont.

Treaties with Austria, Ireland, South
Africa; Publication 515 changes (Ann
11) 10,
739
United Kingdom; repeal of advance
corporation tax (RP 13) 6, 515
Tax liens, determination of property or
rights to property (CD 2067) 15, 863
Tax shelters:
Confidential corporate, registration
(TD 8876) 11, 753;
(REG–110311–98) 11,753
Disclosure statements (TD 8877) 11,
747; (REG–103735–00) 11, 770
Listed transactions (Notice 15) 12, 826
Office of Tax Shelter Analysis (Ann
12) 12,835
Potentially abusive, list of investors
(TD 8875) 11, 761;
(REG–103736–00) 11, 768; correc-
tion (Ann 44) 17,958
Technical advice to district directors and
chiefs, appeals office, from Associate
Chief Counsel (RP 2) 1, 73
Valuation tables (Ann 25) 14, 855
Variable annuity contracts, closing agree-
ments (Notice 9) 5, 449
Withholdings:
Date deemed paid (CD 2066) 15, 867
Qualified intermediary withholding
agreements (RP 12) 4, 387
U.S. source income payments to for-
eign persons, delay of effective date
(TD 8856) 3, 298; correction (Ann
31) 15, 877
May 1, 2000x2000–18 I.R.B.
INCOME TAX—cont.

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