Internal Revenue Bulletin 2010-21 (PDF rendition): IRS Announcements

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Bulletin No. 201
0-21
May 24, 2010
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.
INCOME TAX
Rev. Rul. 2010–13, page 691.
Section 45R — Average premium for small group mar-
ket for determining the small employer health insurance
credit.Section 45R provides a federal income tax credit to
eligible small employers, including tax-exempt organizations,
that make nonelective contributions towards their employees’
health insurance premiums under an arrangement that meets
certain requirements. The amount of an employer’s premiums
that are taken into consideration for purposes of calculating
the credit cannot exceed the average premium for the small
group market in the state in which the employer offers cover-
age. This ruling publishes the average premium rates for the
small group market. These rates are determined by the De-
partment of Health and Human Services.
EMPLOYEE PLANS
Notice 2010–40, page 693.
Weighted average interest rate update; corporate bond
indices; 30–year Treasury securities; segment rates.
This notice contains updates for the corporate bond weighted
average interest rate for plan years beginning in May 2010;
the 24-month average segment rates; the funding transitional
segment rates applicable for May 2010; and the minimum
present value transitional rates for April 2010.
EXEMPT ORGANIZATIONS
Announcement 2010–36, page 696.
A list is provided of organizations now classified as private foun-
dations.
ADMINISTRATIVE
Announcement 2010–38, page 696.
This document contains a correction to final regulations
(T.D. 9350, 2007–2 C.B. 607) that modify the rules relating to
the disclosure of reportable transactions under section 6011
of the Code.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top quality service by helping them
understand an
d meet their tax responsibilities and by applying
the tax law with
integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, 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 compiled 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, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement 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 published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation 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 Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last 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 last Bulletin of each semiannual period.
The c
ontents 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.
May 24, 20102010–21 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 45R.—
Average
Premium for Small Group
Market for Determining
the Small Employer Health
Insurance Credit
(Also Section 38(b).)
Section 45R — Average premium for
small group market for determining the
small employer health insurance credit.
Section 45R provides a federal income
tax credit to eligible small employers,
including tax-exempt organizations, that
make nonelective contributions towards
their employees’ health insurance pre-
miums under an arrangement that meets
certain requirements. The amount of an
employer’s premiums that are taken into
consideration for purposes of calculating
the credit cannot exceed the average pre-
mium for the small group market in the
state in which the employer offers cov-
erage. This ruling publishes the average
premium rates for the small group market.
These rates are determined by the Depart-
ment of Health and Human Services.
Rev. Rul. 2010
–13
Section 45R wa
s added to the Internal
Revenue Code b
ysection1421ofthePa-
tient Protect
ion and Affordable Care Act
(the Afforda
bleCareAct),Pub. L.No.
111-148. The
Affordable Care Act was
signed by the
President on March 23, 2010.
Section 45R i
s effective for taxable years
beginning a
fter December 31, 2009.
Section 45R p
rovides a Federal income
tax credit t
o eligible small employers,
including t
ax-exempt organizations, that
make nonele
ctive contributions towards
their emplo
yees’ health insurance pre-
miums unde
r an arrangement that meets
certain re
quirements. For taxable years
beginning
before 2014, the amount of
the credit
is based on a percentage of the
lesser of:
1) the amount of nonelective
contribu
tions paid by the eligible small
employer
on behalf of employees under
the arran
gement during the taxable year,
and 2) the
amount of nonelective contribu-
tions the
employer would have paid under
the arra
ngement if each such employee
were enr
olled in a plan that had a pre-
mium equ
al to the average premium for
the small grou
pmarketintheState(orin
an area in the S
tate) in which the employer
is offering he
alth insurance coverage. The
Secretary of
Health and Human Services
(HHS) determ
ines whether separate aver-
age premiums
will apply for areas within
aState(“sub
-State areas”) and also deter-
mines the av
erage premium for a State or
sub-State a
rea. The chart below sets forth
the average
premium for the small group
market in ea
ch State for the 2010 taxable
year, as det
erminedbyHHS.
HHS recogni
zes that there may be areas
in some Sta
tes with meaningfully higher
premium ra
tes. For the 2010 taxable year,
HHS may pro
vide additional average pre-
mium rates
for the small group market in
certain ar
eas within States. However, in
no case wi
ll any such additional sub-State
rates be l
ower than the applicable rate for
each Stat
e that is set forth in this Revenue
Ruling.
The follo
wing chart sets forth the aver-
age premi
um for the small group market in
each Stat
e for the 2010 taxable year. Fam-
ily cove
rage includes any coverage other
than emp
loyee-only (or single) coverage.
State
Employee-only
Coverage
Family Coverage
Alaska
$ 6,204$ 13,723
Alabama4,441
11,275
Arkansa
s
4,3299,677
Arizona
4,495
10,239
California4,628
10,957
Colora
do
4,97211,437
Connecticut
5,419
13,484
District of Columbia
5,355
12,823
Delaw
are
5,60212,513
Florida
5,16112,453
Georgia4,612
10,5
98
Hawa
ii
4,22
8
10,508
Iowa
4,65210,503
Idaho
4,2
15
9,3
65
Ill
inois
5,198
12,
309
Indiana
4,775
11,222
Kansas4,60311,462
Ken
tucky
4,2
87
10,
434
Louisiana4,82911,074
Massachusetts
5,
700
14,138
Ma
ryland
4,
837
11
,939
Maine
5,215
11,887
Michigan
5
,098
12,364
2010–21 I.R.B.691May 24, 2010

Minnesota4,70411,938
Missouri4,66310,681
Mississippi
4,53310,501
Montana4,77210,212
North Carolina4,920
11,583
North Dakota4,469
10,506
Nebraska
4,715
11,169
New Hampshire
5,519
13,624
New Jersey
5,60713,521
New Mexico
4,754
11,404
Nevada
4,553
10,297
New York
5,442
12,867
Ohio4,66711,293
Oklahoma4,83811,002
Oregon4,68110,890
Pennsylvania
5,039
12,471
Rhode Island
5,887
13,786
South Carolina4,89911,780
South Dakota4,49711,483
Tennessee4,61110,369
Texas
5,140
11,972
Utah4,238
10,935
Virginia4,89011,338
Vermont
5,244
11,748
Washington
4,54310,725
Wisconsin
5,222
12,819
West Virginia4,98611,611
Wyoming
5,266
12,163
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Mireille Khoury of the Office of the
Division Counsel/Associate Chief Coun-
sel (Tax Exempt & Government Entities).
For further information regarding this rev-
enue ruling, contact Mireille Khoury at
(202) 622–6080 (not a toll-free call). For
questions regarding the data contained
in the table of average State premiums,
contact Tara Oakman of the Department
of Health and Human Services at (202)
690–6870 (not a toll-free call).
May 24, 20106922010–21 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2010–40
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code as in ef-
fect for plan years beginning before 2008.
It also provides guidance on the corpo-
rate bond monthly yield curve (and the
corresponding spot segment rates), the
24-month average segment rates, and
the funding transitional segment rates
under § 430(h)(2). In addition, this no-
tice provides guidance as to the interest
rate on 30-year Treasury securities un-
der § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008, the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I), and the min-
imum present value segment rates under
§ 417(e)(3)(D) as in effect for plan years
beginning after 2007.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004 and by
the Pension Protection Act of 2006 (PPA),
provide that the interest rates used to cal-
culate current liability and to determine
the required contribution under § 412(l)
for plan years beginning in 2004 through
2007 must be within a permissible range
based on the weighted average of the rates
of interest on amounts invested conser-
vatively in long term investment grade
corporate bonds during the 4-year period
ending on the last day before the beginning
of the plan year.
Notice 2004–34, 2004–1 C.B. 848, pro-
vides guidelines for determining the cor-
porate bond weighted average interest rate
and the resulting permissible range of in-
terest rates used to calculate current liabil-
ity. That notice establishes that the corpo-
rate bond weighted average is based on the
monthly composite corporate bond rate de-
rived from designated corporate bond in-
dices. The methodology for determining
the monthly composite corporate bond rate
as set forth in Notice 2004–34 continues to
apply in determining that rate. See Notice
2006–75, 2006–2 C.B. 366.
The composite corporate bond rate for
April 2010 is 5.84 percent. Pursuant to No-
tice 2004–34, the Service has determined
this rate as the average of the monthly
yields for the included corporate bond in-
dices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
Corporate
Bond Weighted
Average90%to100%
May20106.37
5.73
6.37
YIELD CURVE AND SEGMENT
RATES
Generally for plan years beginning
after 2007 (except for delayed effective
dates for certain plans under sections 104,
105, and 106 of PPA), § 430 of the Code
specifies the minimum funding require-
ments that apply to single employer plans
pursuant to § 412. Section 430(h)(2) spec-
ifies the interest rates that must be used
to determine a plan’s target normal cost
and funding target. Under this provision,
present value is generally determined us-
ing three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods.
However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates. For
plan years beginning in 2008 and 2009, a
transitional rule under § 430(h)(2)(G) pro-
vides that the segment rates are blended
with the corporate bond weighted average
as specified above. An election may be
made under § 430(h)(2)(G)(iv) to use the
segment rates without applying the transi-
tional rule.
Notice 2007–81, 2007–2 C.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, the
24-month average corporate bond segment
rates, and the funding transitional segment
rates used to compute the target normal
cost and the funding target. Pursuant to
Notice 2007–81, the monthly corporate
bond yield curve derived from April 2010
data is in Table I at the end of this notice.
The spot first, second, and third segment
rates for the month of April 2010 are,
respectively, 2.30, 5.60, and 6.47. The
three 24-month average corporate bond
segment rates applicable for May 2010
under the election of § 430(h)(2)(G)(iv)
are as follows:
First
Segment
Second
Segment
Third
Segment
4.26
6.56
6.70
2010–21 I.R.B.693May 24, 2010

The transitional segment rates under
§ 430(h)(2)(G) applicable for May 2010,
taking into account the corporate bond
weighted average of 6.37 stated above, are
as follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20094.96
6.506.59
The transitional rule of § 430(h)(2)(G)
does not apply to plan years starting in
2010. Therefore, for a plan year starting in
2010 with a lookback month to May 2010,
the funding segment rates are the three
24-month average corporate bond segment
rates applicable for May 2010, listed above
without blending for the transitional pe-
riod.
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 417(e)(3)(A)(ii)(II) (prior to
amendment by PPA) defines the appli-
cable interest rate, which must be used
for purposes of determining the minimum
present value of a participant’s benefit
under § 417(e)(1) and (2), as the annual
rate of interest on 30-year Treasury se-
curities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
bleinterestrateforamonthistheannual
rate of interest on 30-year Treasury secu-
rities as specified by the Commissioner
for that month in revenue rulings, notices
or other guidance published in the Internal
Revenue Bulletin.
The rate of interest on 30-year Trea-
sury securities for April 2010 is 4.69 per-
cent. The Service has determined this rate
as the average of the daily determinations
of yield on the 30-year Treasury bond ma-
turing in February 2040.
Generally for plan years beginning
after 2007, § 431 specifies the mini-
mum funding requirements that apply to
multiemployer plans pursuant to § 412.
Section 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation
described in section 431(c)(6)(A), based
on the plan’s current liability. Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 percent
below the weighted average of the rates of
interest on 30-year Treasury securities dur-
ing the four-year period ending on the last
day before the beginning of the plan year.
Notice 88–73, 1988–2 C.B. 383, provides
guidelines for determining the weighted
average interest rate. The following rates
were determined for plan years beginning
in the month shown below.
For Plan Years
Beginning inPermissible Range
MonthYear
30-Year
Treasury
Weighted
Average90%to105%
May20104.403.964.62
MINIMUM PRESENT VALUE
SEGMENT RATES
Generally for plan years beginning af-
ter December 31, 2007, the applicable in-
terest rates under § 417(e)(3)(D) are seg-
ment rates computed without regard to a
24-month average. For plan years be-
ginning in 2008 through 2011, the appli-
cable interest rates are the monthly spot
segment rates blended with the applicable
rate under § 417(e)(3)(A)(ii)(II) as in ef-
fect for plan years beginning in 2007. No-
tice 2007–81 provides guidelines for de-
termining the minimum present value seg-
ment rates. Pursuant to that notice, the
minimum present value transitional seg-
ment rates determined for April 2010, tak-
ing into account theApril 2010 30-year
Treasury rate of 4.69 stated above, are as
follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20093.73
5.055.40
20103.26
5.245.76
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
May 24, 20106942010–21 I.R.B.

Table I
Monthly Yield Curve for April 2010
Derived from April 2010 Data
Maturity YieldMaturity YieldMaturity YieldMaturity YieldMaturity Yield
0.5
0.80
20.5
6.24
40.5
6.49
60.5
6.59
80.5
6.63
1.01.1021.0
6.25
41.0
6.50
61.06.5981.06.63
1.51.4221.56.2641.56.5061.56.5981.56.63
2.01.7622.06.2742.0
6.50
62.06.5982.06.63
2.5
2.12
22.5
6.28
42.56.5162.5
6.59
82.5
6.64
3.0
2.49
23.0
6.29
43.0
6.51
63.06.5983.06.64
3.52.8523.5
6.30
43.56.5163.5
6.59
83.5
6.64
4.0
3.19
24.06.3144.0
6.52
64.06.6084.06.64
4.53.5024.56.3244.56.5264.56.6084.56.64
5.0
3.79
25.0
6.32
45.06.5265.0
6.60
85.0
6.64
5.54.0525.5
6.33
45.56.5265.5
6.60
85.5
6.64
6.04.2826.06.3446.0
6.53
66.06.6086.06.64
6.5
4.48
26.56.3546.56.5366.5
6.60
86.5
6.64
7.04.6727.06.3647.0
6.53
67.06.6087.06.64
7.54.8427.56.3647.56.5367.56.6087.56.64
8.04.9928.06.3748.0
6.54
68.06.6188.06.64
8.55.1228.5
6.38
48.56.5468.5
6.61
88.5
6.64
9.0
5.24
29.0
6.38
49.0
6.54
69.0
6.61
89.0
6.65
9.5
5.35
29.5
6.39
49.5
6.54
69.56.6189.5
6.65
10.0
5.45
30.06.40
50.06.55
70.06.61
90.0
6.65
10.55.5430.56.4050.56.5570.56.6190.56.65
11.0
5.62
31.06.41
51.06.55
71.06.6191.0
6.65
11.5
5.69
31.5
6.41
51.56.5571.5
6.6191.5
6.65
12.0
5.75
32.06.42
52.06.55
72.06.62
92.0
6.65
12.55.8132.5
6.42
52.56.5672.5
6.6292.5
6.65
13.0
5.86
33.06.43
53.06.56
73.06.62
93.0
6.65
13.55.9133.56.4453.56.5673.56.6293.56.65
14.05.9534.06.44
54.06.56
74.06.6294.0
6.65
14.5
5.99
34.56.4554.56.5674.5
6.6294.5
6.65
15.0
6.02
35.06.4555.06.5775.0
6.6295.0
6.65
15.56.0535.56.4555.56.5775.5
6.6295.5
6.65
16.06.0836.06.46
56.06.57
76.06.62
96.0
6.65
16.56.1036.56.4656.56.5776.56.6296.56.65
17.06.1237.06.47
57.06.57
77.06.6397.06.66
17.5
6.14
37.5
6.47
57.56.5877.5
6.6397.56.66
18.06.1638.06.48
58.06.58
78.06.63
98.0
6.66
18.5
6.18
38.5
6.48
58.56.5878.5
6.6398.56.66
19.0
6.20
39.0
6.4859.0
6.58
79.0
6.63
99.0
6.66
19.56.2139.5
6.49
59.56.5879.56.6399.56.66
20.06.2240.06.4960.0
6.58
80.06.63100.06.66
2010–21 I.R.B.695May 24, 2010

Part IV. Items o
fGeneralInterest
Foundations S
tatus of Certain
Organization
s
Announcement
2010–36
The following
organizations have failed
to establish o
r have been unable to main-
tain their st
atus as public charities or as op-
erating foun
dations. Accordingly, grantors
and contribu
tors may not, after this date,
rely on previ
ous rulings or designations
in the Cumul
ative List of Organizations
(Publicati
on 78), or on the presumption
arising fro
m the filing of notices under sec-
tion 508(b)
of the Code. This listing does
notindica
te that the organizations have lost
their stat
us as organizations described in
section 50
1(c)(3), eligible to receive de-
ductible c
ontributions.
Former Pub
lic Charities. The follow-
ing organi
zations (which have been treated
as organi
zations that are not private foun-
dations d
escribed in section 509(a) of the
Code) are
now classified as private foun-
dations:
ABC Music
, Jonesborough, TN
Access He
alth Services, Redford, MI
After Tha
t, Inc., Lehigh Acres, FL
Ann Jean C
ommunity Service, Inc.,
Culver Ci
ty, CA
Atlantic
Coast Junior Golf Association,
Myrtle Be
ach, SC
Barbara’
s Touch of Love Daycare and
Learning
Center, Greenwood, MS
Changing
Minds, Inc., New Orleans, LA
Communit
y Care Instructional Academy,
Catalpa,
CA
Fair Have
n Rehab Corporation,
New Haven
,CT
Friends o
f Ujima, Inc., Mount Vernon, NY
Godschil
Resurrecting Senior Citizen
Ministri
es, Jamaica, NY
Healing H
eart Ministries, Inc.,
Benson, N
C
Home, Aus
tin, TX
Horse Mou
ntain R & R, Inc., Rayville, MO
Institut
e for Human Development,
Canton, M
I
Just Beca
use Foundation, Smithtown, NY
Koblah Fou
ndation, Inc., Brookeville, MD
Lighthous
e Community Development
Corporat
ion, Little Rock, AR
Moriah Min
istry, Appleton, WI
Mount Mori
ah Missionary Baptist Church
WRS, Aberd
een, MS
National Asso
ciation of Preventive
Kidney Care an
d Counseling, Inc.,
Annapolis, MD
Prevailing Wi
nds Group Home
Corporation,
Oakley, CA
Primary Care S
olutions Community
Based Program
s, Charlotte, NC
Princess Thea
ter Foundation,
Harriman, TN
Professional
Providers Training Institute,
Perris, CA
Redeemer Barn
abas Community Center,
Inc., Downey,
CA
Redemption Mi
nistries,Arvin,CA
Shabach Minis
tries Help-Outreach,
Long Beach, CA
Smith Airfiel
d Forever, Inc.,
Fort Wayne, IN
Solano Stingr
ays Baseball Club,
Vacaville, CA
Sudan Family E
ducation and Enrichment
Center, Wood
bury, MN
Tarrant Net, F
ort Worth, TX
Teen Nubi, Inc
., Fairburn, GA
True Love Yout
h and Community
Empowerment I
nc., Lithonia, GA
Worship and Pr
aise Child Development
Center, Rich
mond, VA
YASU, Reading
,PA
Yoshida Young
’s Youth Foundation,
Gardena, CA
If an organiza
tion listed above submits
information
that warrants the renewal of
its classifi
cation as a public charity or as
a private ope
rating foundation, the Inter-
nal Revenue S
ervice will issue a ruling or
determinati
on letter with the revised clas-
sification
as to foundation status. Grantors
and contrib
utors may thereafter rely upon
such ruling
or determination letter as pro-
videdinsec
tion 1.509(a)–7 of the Income
Tax Regula
tions. It is not the practice of
the Servic
e to announce such revised clas-
sificatio
n of foundation status in the Inter-
nal Revenu
e Bulletin.
AJCA Modifica
tions to the
Section 6011 R
egulations;
Correction
Announcement 2010–38
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Correction to final regulations.
SUMMARY: This document contains a
correction to final regulations (T.D. 9350,
2007–2 C.B. 607) which were published in
theFederal Registeron Friday, August 3,
2007 (72 FR 43146) that modify the rules
relating to the disclosure of reportable
transactions under section 6011.
DATES: This correction is effective on
May 11, 2010, and is applicable on
August 3, 2007.
FOR FURTHER INFORMATION
CONTACT: Charles D. Wien or
Michael H. Beker, (202) 622–3070 (not a
toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (T.D. 9350) that
are the subject of this document are under
section 6011 of the Internal Revenue Code.
Need for Correction
As published, the final regulations
(T.D. 9350) contain an error that may
prove to be misleading and is in need of
clarification.
Correction of Publication
Accordingl
y, the publication of the fi-
nal regulat
ions (T.D. 9350) which were the
subject of F
R Doc. 07–3786, is corrected
as follows
:
On page 4314
6, column 2, in the
preamble,
under the caption heading
“FOR FURTH
ER INFORMATION CON-
TACT:”, th
e language “Charles D. Wien,
Michael H.
Beker, or Tolsun N. Waddle,
202–622–3
070 (not a toll-free number).”
is remove
d and replaced with the language
“Charles
D. Wien or Michael H. Beker,
202–622–
3070 (not a toll-free number).”.
May 24, 20106962010–21 I.R.B.

LaNita Van Dyke,
Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on May 10, 2010,
8:45 a.m., and published in the issue of the Federal Register
for May 11, 2010, 75 F.R. 26061)
2010–21 I.R.B.697May 24, 2010

Definition of Terms
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 ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis 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 applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes 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 rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published 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 pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
May 24, 2010i2010–21 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–21
Announcements:
2010-1, 2010-4 I.R.B.333
2010-2, 2010-2 I.R.B.271
2010-3, 2010-4 I.R.B.333
2010-4, 2010-5 I.R.B.384
2010-5, 2010-6 I.R.B.402
2010-6, 2010-6 I.R.B.402
2010-7, 2010-6 I.R.B.403
2010-8, 2010-7 I.R.B.408
2010-9, 2010-7 I.R.B.408
2010-10, 2010-7 I.R.B.410
2010-11, 2010-10 I.R.B.438
2010-12, 2010-7 I.R.B.410
2010-13, 2010-8 I.R.B.426
2010-14, 2010-11 I.R.B.449
2010-15, 2010-10 I.R.B.438
2010-16, 2010-11 I.R.B.450
2010-17, 2010-13 I.R.B.515
2010-18, 2010-12 I.R.B.460
2010-19, 2010-14 I.R.B.529
2010-20, 2010-15 I.R.B.551
2010-21, 2010-15 I.R.B.551
2010-22, 2010-16 I.R.B.602
2010-23, 2010-16 I.R.B.602
2010-24, 2010-15 I.R.B.587
2010-25, 2010-15 I.R.B.588
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
2010-28, 2010-17 I.R.B.616
2010-29, 2010-17 I.R.B.616
2010-30, 2010-19 I.R.B.668
2010-31, 2010-19 I.R.B.681
2010-32, 2010-19 I.R.B.681
2010-33, 2010-18 I.R.B.658
2010-34, 2010-20 I.R.B.685
2010-35, 2010-20 I.R.B.685
2010-36, 2010-21 I.R.B.696
2010-37, 2010-20 I.R.B.685
2010-38, 2010-21 I.R.B.696
Notices:
2010-1, 2010-2 I.R.B.251
2010-2, 2010-2 I.R.B.251
2010-3, 2010-2 I.R.B.253
2010-4, 2010-2 I.R.B.253
2010-5, 2010-2 I.R.B.256
2010-6, 2010-3 I.R.B.275
2010-7, 2010-3 I.R.B.296
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
Notices— Continued:
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-17, 2010-14 I.R.B.519
2010-18, 2010-14 I.R.B.525
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-21, 2010-12 I.R.B.451
2010-22, 2010-10 I.R.B.435
2010-23, 2010-11 I.R.B.441
2010-24, 2010-12 I.R.B.452
2010-25, 2010-14 I.R.B.527
2010-26, 2010-14 I.R.B.527
2010-27, 2010-15 I.R.B.531
2010-28, 2010-15 I.R.B.541
2010-29, 2010-15 I.R.B.547
2010-30, 2010-18 I.R.B.650
2010-31, 2010-16 I.R.B.594
2010-32, 2010-16 I.R.B.594
2010-33, 2010-17 I.R.B.609
2010-34, 2010-17 I.R.B.612
2010-35, 2010-19 I.R.B.660
2010-36, 2010-17 I.R.B.612
2010-37, 2010-18 I.R.B.654
2010-38, 2010-20 I.R.B.682
2010-40, 2010-21 I.R.B.693
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-134235-08, 2010-16 I.R.B.596
REG-137036-08, 2010-6 I.R.B.398
REG-101896-09, 2010-5 I.R.B.347
REG-117501-09, 2010-11 I.R.B.442
REG-131028-09, 2010-4 I.R.B.332
REG-148681-09, 2010-11 I.R.B.443
Revenue Procedures:
2010-1, 2010-1 I.R.B.1
2010-2, 2010-1 I.R.B.90
2010-3, 2010-1 I.R.B.110
2010-4, 2010-1 I.R.B.122
2010-5, 2010-1 I.R.B.165
2010-6, 2010-1 I.R.B.193
2010-7, 2010-1 I.R.B.231
2010-8, 2010-1 I.R.B.234
2010-9, 2010-2 I.R.B.258
2010-10, 2010-3 I.R.B.300
2010-11, 2010-2 I.R.B.269
2010-12, 2010-3 I.R.B.302
2010-13, 2010-4 I.R.B.329
2010-14, 2010-12 I.R.B.456
2010-15, 2010-7 I.R.B.404
2010-16, 2010-19 I.R.B.664
Revenue Procedures— Continued:
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.427
2010-19, 2010-13 I.R.B.469
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
Revenue Rulings:
2010-1, 2010-2 I.R.B.248
2010-2, 2010-3 I.R.B.272
2010-3, 2010-3 I.R.B.272
2010-4, 2010-4 I.R.B.309
2010-5, 2010-4 I.R.B.312
2010-6, 2010-6 I.R.B.387
2010-7, 2010-8 I.R.B.417
2010-8, 2010-10 I.R.B.432
2010-9, 2010-13 I.R.B.461
2010-10, 2010-13 I.R.B.461
2010-11, 2010-14 I.R.B.516
2010-12, 2010-18 I.R.B.617
2010-13, 2010-21 I.R.B.691
Tax Conventions:
2010-2, 2010-2 I.R.B.271
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
Treasury Decisions:
9474, 2010-4 I.R.B.322
9475, 2010-4 I.R.B.304
9476, 2010-5 I.R.B.336
9477, 2010-6 I.R.B.385
9478, 2010-4 I.R.B.315
9479, 2010-18 I.R.B.618
9480, 2010-11 I.R.B.439
9481, 2010-17 I.R.B.605
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin
2009–52, dated December 28, 2009.
2010–21 I.R.B.iiMay 24, 2010

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–21
Announcements:
2009-23
Corrected by
Ann. 2010-29, 2010-17 I.R.B.616
2009-51
Supplemented and superseded by
Ann. 2010-16, 2010-11 I.R.B.450
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
2010-22
Corrected by
Ann. 2010-34, 2010-20 I.R.B.685
Notices:
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2006-87
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-25
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-77
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-14
Modified and superseded by
Notice 2010-33, 2010-17 I.R.B.609
2008-41
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-55
Modified by
Notice 2010-3, 2010-2 I.R.B.253
2008-88
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-107
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
Notices— Continued:
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-116
Modified and superseded by
Notice 2010-32, 2010-16 I.R.B.594
2009-11
Amplified by
Notice 2010-9, 2010-3 I.R.B.298
2009-13
Obsoleted by
T.D. 9478, 2010-4 I.R.B.315
REG-131028-09, 2010-4 I.R.B.332
2009-35
Supplemented by
Notice 2010-17, 2010-14 I.R.B.519
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
2009-62
Modified and supplemented by
Notice 2010-23, 2010-11 I.R.B.441
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
REG-134235-08
Hearing scheduled by
Ann. 2010-33, 2010-18 I.R.B.658
Revenue Procedures:
80-59
Modified and superseded by
Rev. Proc. 2010-11, 2010-2 I.R.B.269
87-35
Obsoleted by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2001-18
Superseded by
Rev. Proc. 2010-16, 2010-19 I.R.B.664
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
2009-1
Superseded by
Rev. Proc. 2010-1, 2010-1 I.R.B.1
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
Revenue Procedures— Continued:
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-17
Superseded by
Rev. Proc. 2010-21, 2010-13 I.R.B.473
2009-25
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-55
Corrected by
Ann. 2010-11, 2010-10 I.R.B.438
2010-1
Corrected by
Ann. 2010-5, 2010-6 I.R.B.402
Revenue Rulings:
67-436
Obsoleted by
REG-101896-09, 2010-5 I.R.B.347
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin 2009–52, dated December 28,
2009.
May 24, 2010iii2010–21 I.R.B.

Treasury Decisions:
9350
Corrected by by
Ann. 2010-38, 2010-21 I.R.B.696
9424
Corrected by
Ann. 2010-18, 2010-12 I.R.B.460
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
2010–21 I.R.B.ivMay 24, 2010

May 24, 20102010–21 I.R.B.

INTERNAL REVENUE BULLETIN
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