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[Federal Register Volume 63, Number 145 (Wednesday, July 29, 1998)]
[Rules and Regulations]
[Pages 40366-40369]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 98-20023]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 8776]
RIN 1545-AW34

Conversion to the Euro

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations.

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SUMMARY: This document contains temporary Income Tax Regulations 
relating to U.S. taxpayers operating, investing or otherwise conducting 
business in the currencies of certain European countries that are 
replacing their national currencies with a single, multinational 
currency called the euro. These regulations provide rules relating to 
adjustments required for qualified business units operating in such 
currencies and rules relating to the tax effect of holding such 
currencies or financial instruments or contracts denominated in such 
currencies. The text of these temporary regulations also serves as the 
text of proposed regulations published elsewhere in this issue of the 
Federal Register.

DATES: These regulations are effective July 29, 1998.

FOR FURTHER INFORMATION CONTACT: Howard Wiener of the Office of 
Associate Chief Counsel (International), (202) 622-3870, regarding the 
change in functional currency rules and Thomas Preston of the Office of 
Assistant Chief Counsel (Financial Institutions and Products), (202) 
622-3930, regarding section 1001 (not toll free calls).

SUPPLEMENTARY INFORMATION:

Background

    On March 9, 1998, the IRS issued Announcement 98-18 (1998-9 IRB 44) 
requesting comments relating to the tax issues for U.S. taxpayers 
operating, investing or otherwise conducting business in a currency 
that is converting to the euro. Numerous comments were received. After 
consideration of these comments, these regulations are adopted as a 
temporary Treasury decision to provide immediate guidance to taxpayers.

Explanation of Provisions

I. Background

    The Treaty on European Union signed February 7, 1992, (31 I.L.M. 
247) (entered into force November 1, 1993), sets forth a plan to 
replace the national currencies of participating members (legacy 
currencies) that meet certain economic criteria with a single European 
currency (euro). Pursuant to directives of the European Council, the 
process of converting the legacy currencies into the euro will take 
place in three phases.
    On January 1, 1999, the currency of participating member states of 
the European Union shall be the euro. At that time, the euro will be 
substituted for the currency of each state at a conversion rate 
established pursuant to the Treaty on European Union. Thereafter, the 
bills and coins of each of the legacy currencies will remain in 
circulation but will cease to have independent value apart from the 
euro. On January 1, 2002, euro bills and coins will be introduced into 
circulation. From January 1, 1999, until June 30, 2002 (transition 
period), the legacy currencies will remain in circulation as subunits 
of the euro. The transition period is referred to as the ``no 
prohibition, no compulsion'' period because during this time amounts 
may generally be denominated in the legacy currencies and/or the euro 
at the option of individuals and businesses. Finally, by July 1, 2002, 
the legacy currencies will no longer be accepted as legal tender.
    On May 3, 1998, the European Union announced the eleven countries 
that would initially participate in the conversion and the expected 
rates at which the respective currencies would convert to the euro. The 
eleven countries are Austria, Belgium, Finland, France, Germany, 
Ireland, Italy, Luxembourg, Netherlands, Portugal, and Spain. Four 
current members of the European Union (Denmark, Greece, Sweden, and the 
United Kingdom) will not participate in the initial conversion to the 
euro. These countries, along with other countries that later join the 
European Union, however, may convert their currencies to the euro at 
some future time.

II. Temporary Regulations

1. In General
    These temporary regulations provide guidance regarding certain of 
the federal income tax consequences arising from the introduction of 
the euro. Consistent with comments received from taxpayers, the 
regulations generally minimize the tax consequences that arise by 
reason of the euro conversion. In a limited number of circumstances, 
however, the Treasury and IRS determined that considerations, such as 
administrative feasibility, made a different result more appropriate.
    The regulations provide guidance with respect to two issues: (i) 
the circumstances under which the euro conversion creates a realization 
event with respect to instruments and contracts denominated in a legacy 
currency, and (ii) the circumstances under which the euro conversion 
constitutes a change in functional currency for a qualified business 
unit (QBU) whose functional currency is a legacy currency, and certain 
consequences thereof.
2. Realization
    The temporary regulations provide that the conversion of legacy 
currencies to the euro does not result in a realization event under 
section 1001. This rule is broadly applicable to all situations where 
the rights and obligations of a taxpayer are altered solely by reason 
of the euro conversion. Thus, conversion to the euro of legacy

[[Page 40367]]

currency held by a taxpayer and conversion of legacy currency 
denominated contractual relationships, financial instruments, and other 
claims or obligations are not realization events solely as a result of 
the conversion. In addition, as a result of this rule, exchange gains 
and losses on section 988 transactions denominated in a legacy currency 
will not be taken into account until a subsequent realization event 
with respect to the underlying instrument. For example, when the Dutch 
guilder is converted into the euro, a U.S. dollar functional currency 
taxpayer will not recognize either market gain or loss or exchange gain 
or loss on a fixed interest rate Dutch guilder debt instrument.
    Other aspects of the euro conversion may result in taxable events. 
For example, if an unscheduled fractional principal payment is made on 
a debt instrument in order to facilitate a rounding convention, this 
payment is accounted for under the rules governing payments on debt 
instruments (such as Secs. 1.446-2 and 1.1275-2) and under section 988 
(in the case of a section 988 transaction). Other changes may or may 
not constitute realization events depending on the terms of the 
changes. For example, accrual periods, holiday conventions or indices 
on a floating rate instrument may be altered. Whether these changes are 
realization events must be determined under existing law. See, e.g., 
Sec. 1.1001-3.
    Limitations that under otherwise applicable principles prevent or 
defer the recognition of realized gains and losses continue to apply. 
Thus, for example, recognition of losses between related parties under 
section 267 and Sec. 1.988-1(a)(10) remain subject to the limitations 
set forth in those sections.
3. Change in Functional Currency
    The regulations provide that QBUs with a legacy functional currency 
will be deemed to have automatically changed their functional currency 
to the euro at the beginning of the year they are required to make such 
change. Because of the significant administrative burdens that will be 
imposed on QBUs when they are required to change their internal systems 
to accommodate the introduction of the euro, the regulations provide 
that a QBU that currently uses a legacy functional currency is deemed 
to automatically change its functional currency to the euro in the year 
the QBU changes its books and records to the euro. That change, 
however, must be made no later than the last taxable year beginning on 
or before the first day such legacy currency is no longer valid legal 
tender.
    The euro conversion implicates the policy concerns underlying 
Sec. 1.985-5, namely, the preservation of built-in exchange gains and 
losses arising from the fact that positions that had once been 
denominated in a nonfunctional currency will now be made or received in 
a QBU's functional currency.
    In the context of the euro conversion, two items are of particular 
concern in properly accounting for exchange gains and losses: (1) 
section 988 transactions denominated in a legacy currency other than 
the QBU's legacy functional currency, and (2) unremitted earnings of a 
branch with a legacy functional currency different from the home 
office's legacy functional currency. In both these instances, positions 
that had previously been accounted for in a nonfunctional currency 
(against which exchange gains and loses would be computed) will, after 
the conversion, be accounted for in euros (against which exchange gains 
and losses would not be computed when a QBU's functional currency is 
also the euro).
    Rather than requiring immediate recognition, as would be required 
under Sec. 1.985-5, the temporary regulations provide special rules for 
the euro conversion. These rules provide that for affected section 988 
transactions (other than transactions in or holdings of nonfunctional 
currency cash), exchange gains and losses that would have been 
recognized immediately if the Sec. 1.985-5 change in functional 
currency rules applied will be deferred until otherwise realized. This 
is accomplished by providing that section 988 transactions continue to 
be treated as nonfunctional currency transactions under the principles 
of section 988 even though the remaining payments on the asset or 
liability will be made in the QBU's new functional currency (i.e., the 
euro).
    In response to comments by taxpayers, an election is provided for 
QBUs to realize exchange gain or loss on accounts receivable and 
payable immediately prior to the year of change. A QBU making this 
election must realize exchange gains and losses on all of its accounts 
receivable and payable that are legacy currency denominated section 988 
transactions. The election responds to the administrative burdens 
associated with tracking exchange gains and losses on large quantities 
of accounts receivable and payable. Taxpayers not making the election 
will continue to treat these positions as section 988 transactions 
under the general rule described above.
    Exchange gains and losses on transactions in, or holdings of, 
nonfunctional currency cash are recognized immediately because cash 
accounts are generally turned over rapidly and the administrative 
burdens in tracking exchange gains and losses outweigh the benefits of 
deferral.
    The regulations also provide special rules for taking into account 
exchange gain or loss when the taxpayer and a branch of the taxpayer 
change their functional currencies to the euro. The rules provide that 
exchange gains and losses on unremitted earnings of affected branches 
be recognized ratably over a four-year period beginning in the year of 
change. Some commentators recommended that the principles of section 
987 continue to be applied after the conversion. As in the case with 
cash, however, the Treasury and IRS believe that the administrative 
burdens for taxpayers and the government as well as the potential for 
abuse, outweigh the benefit of extended deferral.
    These temporary regulations also provide rules for the proper 
translation of a QBU's balance sheet accounts in a manner that 
preserves any accrued but unrecognized currency gain or loss. These 
rules are consistent with the existing Sec. 1.985-5, change in 
functional currency rules.

III. Other Issues

    Finally, these regulations do not address certain issues that 
taxpayers have commented upon that are not unique to the euro 
conversion. In particular, these regulations do not address the 
deductibility of costs associated with the euro conversion and foreign 
tax credit mismatches that can occur as a result of tax accounting 
differences between the United States and other countries.

Special Analysis

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in Executive Order 12866. 
Therefore, a regulatory assessment is not required. It has also been 
determined that section 553(b) of the Administrative Procedures Act (5 
U.S.C. chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 
6) do not apply to these regulations, and therefore, a Regulatory 
Flexibility Analysis is not required. Pursuant to section 7805(f) of 
the Internal Revenue Code, these temporary regulations will be 
submitted to the Chief Counsel for Advocacy of the Small Business 
Administration for comment on their impact on small business.
    Drafting Information: The principal authors of these regulations 
are Howard A. Wiener of the Office of the Associate Chief Counsel 
(International) and Thomas Preston of the Office of Associate Chief 
Counsel (Domestic).

[[Page 40368]]

Other personnel from the IRS and Treasury Department also participated 
in their development.

List of Subjects in 26 CFR Part 1

    Income taxes, Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations

    Accordingly, 26 CFR part 1 is amended as follows:

PART 1--INCOME TAXES

    Paragraph 1. The authority citation for part 1 continues to read in 
part as follows:

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

    Par. 2. In Sec. 1.985-1, paragraph (c)(6) is amended by adding a 
sentence at the end to read as follows:

Sec. 1.985-1  Functional currency.

* * * * *
    (c) * * *
    (6) * * * For special rules relating to the conversion to the euro, 
see Sec. 1.985-8T.
* * * * *

Sec. 1.985-4  [Amended]

    Par. 3. In Sec. 1.985-4, the last sentence of paragraph (a) is 
amended by removing the reference ``Sec. 1.985-2'' and adding 
``Sec. 1.985-2 or 1.985-8T'' in its place.
    Par. 4. Section 1.985-8T is added to read as follows:

Sec. 1.985-8T  Special rules applicable to the European Monetary Union 
(conversion to the euro) (temporary).

    (a) Definitions--(1) Legacy currency. A legacy currency is the 
national currency of a participating member state of the European Union 
used prior to the substitution of the euro for the national currency of 
that state in accordance with the Treaty on European Union signed 
February 7, 1992. The term legacy currency shall also include the 
European Currency Unit.
    (2) Conversion rate. The conversion rate is the rate at which the 
euro is substituted for a legacy currency.
    (b) Operative rules--(1) Initial adoption. A QBU (as defined in 
Sec. 1.989(a)-1(b)) whose first taxable year begins after the euro has 
been substituted for a legacy currency may not adopt that legacy 
currency as its functional currency.
    (2) QBU with a legacy functional currency--(i) Required change. A 
QBU with a legacy currency as its functional currency is required to 
change its functional currency to the euro beginning the first day of 
the first taxable year:
    (A) That begins on or after the day that the euro is substituted 
for that legacy currency (in accordance with the Treaty on European 
Union); and
    (B) In which the QBU begins to maintain its books and records (as 
described in Sec. 1.989(a)-1(d)) in the euro.
    (ii) Notwithstanding paragraph (b)(2)(i) of this section, a QBU 
with a legacy currency as its functional currency is required to change 
its functional currency to the euro no later than the last taxable year 
beginning on or before the first day such legacy currency is no longer 
valid legal tender.
    (iii) Consent of Commissioner. A change made pursuant to paragraph 
(b)(2)(i) of this section shall be deemed to be made with the consent 
of the Commissioner for purposes of Sec. 1.985-4. A QBU changing its 
functional currency to the euro pursuant to this paragraph (b)(2) must 
make adjustments as provided in paragraph (c) of this section.
    (3) Statement to file upon change. With respect to a QBU that 
changes its functional currency to the euro under paragraph (b)(2) of 
this section, an affected taxpayer shall attach to its return for the 
taxable year of change a statement that includes the following: 
``TAXPAYER CERTIFIES THAT A QBU OF THE TAXPAYER HAS CHANGED ITS 
FUNCTIONAL CURRENCY TO THE EURO PURSUANT TO TREAS. REG. Sec. 1.985-
8T.'' For purposes of this paragraph (b)(3), an affected taxpayer shall 
be in the case where the QBU is: a QBU of an individual U.S. resident 
(as a result of the activities of such individual), the individual; a 
QBU branch of a U.S. corporation, the corporation; a controlled foreign 
corporation (as described in section 957)(or QBU branch thereof), each 
United States shareholder (as described in section 951(b)); a 
partnership, each partner separately; a noncontrolled section 902 
corporation (as described in section 904(d)(2)(E)) (or branch thereof), 
each domestic shareholder as described in Sec. 1.902-1(a)(1); or a 
trust or estate, the fiduciary of such trust or estate.
    (c) Adjustments required--(1) In general. A QBU that changes its 
functional currency to the euro pursuant to paragraph (b) of this 
section must make the adjustments described in paragraphs (c)(2) 
through (5) of this section. Section 1.985-5 shall not apply.
    (2) Determining the euro basis of property and the euro amount of 
liabilities and other relevant items. The euro basis in property and 
the euro amount of liabilities and other relevant items shall equal the 
product of the legacy functional currency adjusted basis or amount of 
liabilities multiplied by the applicable conversion rate. 
    (3) Taking into account exchange gain or loss on legacy currency 
section 988 transactions--(i) In general. Except as provided in 
paragraphs (c)(3) (iii) and (iv) of this section, a legacy currency 
denominated section 988 transaction (determined after applying section 
988(d)) outstanding on the last day of the taxable year immediately 
prior to the year of change shall continue to be treated as a section 
988 transaction after the change and the principles of section 988 
shall apply.
    (ii) Examples. The application of this paragraph (c)(3) may be 
illustrated by the following examples:

    Example 1. X, a calendar year QBU on the cash method of 
accounting, uses the deutschmark as its functional currency. X is 
not described in section 1281(b). On July 1, 1998, X converts 10,000 
deutschmarks(DM) into Dutch guilders(fl) at the spot rate of fl1 = 
DM1 and loans the 10,000 guilders to Y (an unrelated party) for one 
year at a rate of 10% with principal and interest to be paid on June 
30, 1999. On January 1, 1999, X changes its functional currency to 
the euro pursuant to this section. The euro/deutschmark conversion 
rate is set by the European Council at =1= DM2. The euro/guilder 
conversion rate is set at =1 = fl2.25. Accordingly, under the terms 
of the note, on June 30, 1999, X will receive =4444.44 (f110,000/
2.25) of principal and =444.44 (fl1,000/2.25) of interest. Pursuant 
to this paragraph (c)(3), X will realize an exchange loss on the 
principal computed under the principles of Sec. 1.988-2(b)(5). For 
this purpose, the exchange rate used under Sec. 1.988-2(b)(5)(i) 
shall be the guilder/euro conversion rate. The amount under 
Sec. 1.988-2(b)(5)(ii) is determined by translating the fl10,000 at 
the guilder/deutschmark spot rate on July 1, 1998, and translating 
that deutschmark amount into euros at the deutschmark/euro 
conversion rate. Thus, X will compute an exchange loss for 1999 of 
=555.56 determined as follows: [=4444.44 (fl10,000/2.25)-=5000 
((fl10,000/1)/2) =-=555.56]. Pursuant to this paragraph (c)(3), the 
character and source of the loss are determined pursuant to section 
988 and regulations thereunder. Because X uses the cash method of 
accounting for the interest on this debt instrument, X does not 
realize exchange gain or loss on the receipt of that interest.
    Example 2. (i) X, a calendar year QBU on the accrual method of 
accounting, uses the deutschmark as its functional currency.
    On February 1, 1998, X converts 12,000 deutschmarks into Dutch 
guilders at the spot rate of fl1 = DM1 and loans the 12,000 guilders 
to Y (an unrelated party) for one year at a rate of 10% with 
principal and interest to be paid on January 31, 1999. In addition, 
assume the average rate (deutschmark/guilder) for the period from 
February 1, 1998, through December 31, 1998 is fl1.07 = DM1. 
Pursuant to Sec. 1.988-2(b)(2)(ii)(C), X will accrue eleven months 
of interest on the note

[[Page 40369]]

and recognize interest income of DM1028.04 (fl1100/1.07) in the 1998 
taxable year.
    (ii) On January 1, 1999, the euro will replace the deutschmark 
as the national currency of Germany pursuant to the Treaty on 
European Union signed February 7, 1992. Assume that on January 1, 
1999, X changes its functional currency to the euro pursuant to this 
section. The euro/deutschmark conversion rate is set by the European 
Council at =1 = DM2. The euro/guilder conversion rate is set at =1 = 
fl2.25. In 1999, X will accrue one month of interest equal to =44.44 
(fl100/2.25). On January 31, 1999, pursuant to the note, X will 
receive interest denominated in euros of =533.33 (fl1200/2.25). 
Pursuant to this paragraph (c)(3), X will realize an exchange loss 
in the 1999 taxable year with respect to accrued interest computed 
under the principles of Sec. 1.988-2(b)(3). For this purpose, the 
exchange rate used under Sec. 1.988-2(b)(3)(i) is the guilder/euro 
conversion rate and the exchange rate used under Sec. 1.988-
2(b)(3)(ii) is the deutschmark/euro conversion rate. Thus, with 
respect to the interest accrued in 1998, X will realize exchange 
loss of =25.13 under Sec. 1.988-2(b)(3) as follows: [=488.89 
(fl1100/2.25)-=514.02 (DM1028.04/2) = -=25.13]. With respect to the 
one month of interest accrued in 1999, X will realize no exchange 
gain or loss since the exchange rate when the interest accrued and 
the spot rate on the payment date are the same.
    (iii) X will realize exchange loss of =666.67 on repayment of 
the loan principal computed in the same manner as in Example 1 
[=5333.33 (fl12,000/2.25)-=6000 fl12,000/1)/2)]. The losses with 
respect to accrued interest and principal are characterized and 
sourced under the rules of section 988.

    (iii) Special rule for legacy nonfunctional currency. The QBU shall 
realize or otherwise take into account for all purposes of the Internal 
Revenue Code the amount of any unrealized exchange gain or loss 
attributable to nonfunctional currency (as described in section 
988(c)(1)(C)(ii)) that is denominated in a legacy currency as if the 
currency were disposed of on the last day of the taxable year 
immediately prior to the year of change. The character and source of 
the gain or loss are determined under section 988.
    (iv) Legacy currency denominated accounts receivable and payable--
(A) In general. A QBU may elect to realize or otherwise take into 
account for all purposes of the Internal Revenue Code the amount of any 
unrealized exchange gain or loss attributable to a legacy currency 
denominated item described in section 988(c)(1)(B)(ii) as if the item 
were terminated on the last day of the taxable year ending prior to the 
year of change.
    (B) Time and manner of election. With respect to a QBU that makes 
an election described in paragraph (c)(3)(iv)(A) of this section, an 
affected taxpayer (as described in paragraph (b)(3) of this section) 
shall attach a statement to its tax return for the taxable year of 
change which includes the following: ``TAXPAYER CERTIFIES THAT A QBU OF 
THE TAXPAYER HAS ELECTED TO REALIZE CURRENCY GAIN OR LOSS ON LEGACY 
CURRENCY DENOMINATED ACCOUNTS RECEIVABLE AND PAYABLE UPON CHANGE OF 
FUNCTIONAL CURRENCY TO THE EURO.'' A QBU making the election must do so 
for all legacy currency denominated items described in section 
988(c)(1)(B)(ii).
    (4) Adjustments when a branch changes its functional currency to 
the euro--(i) Branch changing from a legacy currency to the euro in a 
taxable year during which taxpayer's functional currency is other than 
the euro. If a branch changes its functional currency from a legacy 
currency to the euro for a taxable year during which the taxpayer's 
functional currency is other than the euro, the branch's euro equity 
pool shall equal the product of the legacy currency amount of the 
equity pool multiplied by the applicable conversion rate. No adjustment 
to the basis pool is required.
    (ii) Branch changing from a legacy currency to the euro in a 
taxable year during which taxpayer's functional currency is the euro. 
If a branch changes its functional currency from a legacy currency to 
the euro for a taxable year during which the taxpayer's functional 
currency is the euro, the taxpayer shall realize gain or loss 
attributable to the branch's equity pool under the principles of 
section 987, computed as if the branch terminated on the last day prior 
to the year of change. Adjustments under this paragraph (c)(4)(ii) 
shall be taken into account by the taxpayer ratably over four taxable 
years beginning with the taxable year of change.
    (5) Adjustments to a branch's accounts when a taxpayer changes to 
the euro--(i) Taxpayer changing from a legacy currency to the euro in a 
taxable year during which a branch's functional currency is other than 
the euro. If a taxpayer changes its functional currency to the euro for 
a taxable year during which the functional currency of a branch of the 
taxpayer is other than the euro, the basis pool shall equal the product 
of the legacy currency amount of the basis pool multiplied by the 
applicable conversion rate. No adjustment to the equity pool is 
required.
    (ii) Taxpayer changing from a legacy currency to the euro in a 
taxable year during which a branch's functional currency is the euro. 
If a taxpayer changes its functional currency from a legacy currency to 
the euro for a taxable year during which the functional currency of a 
branch of the taxpayer is the euro, the taxpayer shall take into 
account gain or loss as determined under paragraph (c)(4)(ii) of this 
section.
    (6) Additional adjustments that are necessary when a corporation 
changes its functional currency to the euro. The amount of a 
corporation's euro currency earnings and profits and the amount of its 
euro paid-in capital shall equal the product of the legacy currency 
amounts of these items multiplied by the applicable conversion rate. 
The foreign income taxes and accumulated profits or deficits in 
accumulated profits of a foreign corporation that were maintained in 
foreign currency for purposes of section 902 and that are attributable 
to taxable years of the foreign corporation beginning before January 1, 
1987, also shall be translated into the euro at the conversion rate.
    (d) Effective date. This section applies to tax years ending after 
July 29, 1998.
    Par. 5. Section 1.1001-5T is added to read as follows:

Sec. 1.1001-5T  European Monetary Union (conversion to the 
euro)(temporary).

    (a) Conversion of currencies. For purposes of Sec. 1.1001-1(a), the 
conversion to the euro of legacy currencies (as defined in Sec. 1.985-
8T(a)(1)) is not the exchange of property for other property differing 
materially in kind or extent.
    (b) Effect of currency conversion on other rights and obligations. 
For purposes of Sec. 1.1001-1(a), if, solely as the result of the 
conversion of legacy currencies to the euro, rights or obligations 
denominated in a legacy currency become rights or obligations 
denominated in the euro, that event is not the exchange of property for 
other property differing materially in kind or extent. Thus, for 
example, when a debt instrument that requires payments of amounts 
denominated in a legacy currency becomes a debt instrument requiring 
payments of euros, that alteration is not a modification within the 
meaning of Sec. 1.1001-3(c).
    (c) Effective date. This section applies to tax years ending after 
July 29, 1998.
Michael P. Dolan,
Deputy Commissioner of Internal Revenue.

    Approved: July 17, 1998.
Donald C. Lubick,
Assistant Secretary of the Treasury.
[FR Doc. 98-20023 Filed 7-28-98; 8:45 am]
BILLING CODE 4830-01-U
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