IRS Bulletin 89-40. Does anyone have its exact language? The PR tax incentives seem to hinge on this one bulletin, but it's not available online

IRC Sec.865(g)(2) does not allow US citizens to treat personal property sales as foreign source (or PR-source) income unless a tax of at least 10% of the gain is actually paid to the foreign jurisdiction. The Treasury is authorized to prescribe regulations to waive the 10% tax rule for BFR-PR, but it hasn’t done so. In researching this potential pitfall, I’ve read that the IRS did publish a notice (Bulletin 89-40) which announced that the regulations would exempt BFR-PR from the 10% tax rule. However, this bulletin is too old (from 1989) to be found online.
Does anyone have the text of this bulletin? Also, given that the Treasury hasn’t actually prescribed regulations exempting BFR-PR from the 10% tax rule, is it possible for the IRS to simply nullify the tax benefits of Act 60 Resident Individual Investors by assessing US tax on capital gains not taxed by PR?

Thanks so much for looking into this. The document you link is a US General Accounting Office document. It does have the same number (89-40) and does reference the IRS, but after reading through it, I find no reference to IRC Sec.865(g)(2) or Puerto Rico. I’m looking for the actual Internal Revenue Bulletin 89-40. It’s an IRS publication. The IRS has some of its Bulletin archives on its website at this link, but they don’t go back to 1989:

Internal Revenue Bulletin 89-40 is referenced in the below article authored by Douglas Borg, CPA, J.D., LL.M., in the 4th paragraph under the section heading “Income derived from sources in Puerto Rico with respect to capital gains”

The specific Bulletin seems to be a critical piece in ensuring PR’s Act 60 incentives would actually be recognized by the IRS. I wanted to read the language of the original Bulletin and find out if anyone in this forum has the legal knowledge to know whether the Bulletin’s contents would be legally enforceable.