FROM THE OFFICE OF PUBLIC AFFAIRS

Rev.Proc.2001-37

Treasury and the Internal Revenue Service today have issued a Revenue Procedure providing guidance with respect to the recently enacted FSC Repeal and Extraterritorial Income Exclusion Act of 2000. Revenue Procedure 2001-37 contains guidance on certain taxpayer elections under the new extraterritorial income exclusion regime. Specific issues covered include the application of the extraterritorial income exclusion regime to foreign corporations and the election to apply the new regime to transactions during the transition period. The Treasury and IRS are continuing to work on further guidance with respect to the operation of the new regime.