The NPRM will treat as a listed transaction under section 6011, cases where a Non-U.S. DISC Shareholder:  1) Receives a distribution of accumulated Domestic International Sales Corporation (DISC) income, including a deemed distribution, or derives gain referred to in section 995(c) (relating to disposition of stock of a DISC); and 2) Claims, notwithstanding section 996(g), that an income tax treaty to which the United States is a party exempts or reduces tax on the income.