Internal Revenue Bulletin 2011-20 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 201
1-20
May 16, 2011
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
T.D. 9522, page 780.
Final regulations under section 1563 of the Code, that apply to
a controlled group of corporations, clarify that a corporation
that satisfies the controlled group rules for stock ownership
and qualification is a member of such group, without regard to
itsstatusasacomponentmember.
Notice 2011–37, page 785.
This notice extends to taxable years that begin before the date
that final regulations under regulations section 1.67–4 are pub-
lished in the Federal Register, the interim guidance provided
in Notice 2010–32, 2010–16 I.R.B. 594, Notice 2008–166,
2008–52 I.R.B. 1372, and Notice 2008–32, 2008–11 I.R.B
593, on the treatment under section 67 of the Code of invest-
ment advisory costs and other costs subject to the 2-percent
floor under section 67(a) that are integrated as part of one
commission or fee paid to the trustee or executor and are in-
curred by a trust other than a grantor trust or an estate. Notice
2010–32 modified and superseded.
Announcement 2011–30, page 791.
This announcement contains a rescheduled notice of public
hearing on proposed regulations (REG–146097–09, 2011–8
I.R.B. 516) providing guidance on the reporting requirements
for interest on deposits maintained at U.S. offices of certain fi-
nancial institutions and paid to nonresident alien individuals. A
public hearing is rescheduled for May 18, 2011.
EXCISE TAX
Rev. Proc. 2011–24, page 787.
This revenue procedure establishes a dispute resolution
process for the preliminary fee calculation for the 2011 annual
fee imposed on covered entities engaged in the business of
manufacturing or importing branded prescription drugs. The
fee was enacted by section 9008 of the Patient Protection
and Affordable Care Act, as amended by section 1404 of the
Health Care and Reconciliation Act of 2010. The procedure
describes the information necessary to assert a fee error, de-
scribes how the information must be formatted and submitted,
identifies who may submit the information, and provides the
date by which the information must be provided.
ADMINISTRATIVE
T.D. 9523, page 781.
Final regulations under Part 300 of the Code amend the regula-
tions relating to the imposition of user fees for enrolled agents
and enrolled retirement plan agents.
Notice 2011–38, page 785.
This notice announces an extension to calendar years 2011
and 2012 and modification of the pilot program announced in
Notice 2009–93, 2009–51 I.R.B. 863. Notice 2009–93 au-
thorized filers of certain information returns to truncate an indi-
vidual payee’s nine-digit identifying number on specified paper
payee statements furnished for calendar years 2009–2010, if
the filers met certain requirements. Notice 2009–93 modified.
(Continued on the next page)
Finding Lists begin on page ii.

Notice 2011–39, page 786.
The Department of Treasury and the Service invite public com-
ment on recommendations for items that should be included
on the 2011-2012 Guidance Priority List. Taxpayers may sub-
mit recommendations for guidance at any time during the year.
Please submit recommendations by June 1, 2011, for possible
inclusion on the original 2011-2012 Guidance Priority List. Rec-
ommendations received after June 1, 2011, will be reviewed
for inclusion in the next periodic update.
May 16, 20112011–20 I.R.B.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th 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.
2011–20 I.R.B.May 16, 2011

May 16, 20112011–20 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 1563.
—Definitions
and Special Ru
les
26 CFR 1.1563–
1: Definition of controlled group of
corporations
and component members and related
concepts.
T.D. 9522
DEPARTMENT O
FTHE
TREASURY
Internal Re
venue Service
26 CFR Part 1
Clarificat
ion of Controlled
Group Qual
ification Rules
AGENCY: In
ternal Revenue Service
(IRS), Tre
asury.
ACTION: Fi
nal regulation.
SUMMARY: T
his document contains a fi-
nal regul
ation that applies to a controlled
group of c
orporations. The regulation clar-
ifies tha
t a corporation that satisfies the
controll
ed group rules for stock owner-
ship and q
ualification is a member of such
group, w
ithout regard to its status as a com-
ponent m
ember.
DATES:E
ffective Date:This regulation is
effecti
ve on April 11, 2011.
Applica
bility Date:For date of applica-
bility,
see §1.1563–1(e).
FOR FURT
HER INFORMATION
CONTACT
: Grid Glyer (202) 622–7930
(not a t
oll-free number).
SUPPLE
MENTARY INFORMATION:
Backgr
ound and Explanation of
Provis
ions
This do
cument contains an amendment
to 26 CF
R Part 1. On September 29, 2009,
a notic
e of proposed rulemaking
(NPRM
) regarding the controlled group
quali
fication rules under §1.1563–1
was pu
blished in theFederal Register
(REG–
135005–07, 2009–47 I.R.B. 681
[74 FR
49829]). The NPRM proposed
to am
end §1.1563–1 to clarify that a
corporation d
escribed in section 1563(b)
as an excluded
member of a controlled
group of corpo
rations is nevertheless a
member of the
group. The NPRM further
proposed to a
dd an example demonstrating
that a contro
lled group of corporations can
consist sole
ly of excluded members.
One comment w
as received and no
public heari
ng was requested or held. The
public comm
ent concerned the treatment
of gross rec
eipts between members of
a controlle
d group of corporations for
purposes of
section 41, which provides
a tax credi
t to taxpayers for increasing
their rese
arch activities. In particular,
the commen
t refers to CCA 200233011,
dated May 1
, 2002. In that CCA, the IRS
Office of C
hief Counsel concluded first
that a dom
estic corporation and its major-
ity-owne
d foreign subsidiaries should be
treated a
s a single taxpayer for purposes
of sectio
ns 41(f)(1)(A)(i), 41(f)(5) and
1563(a) b
ecause they were members of
the same
controlled group of corporations
even tho
ugh the foreign subsidiaries were
treated
as excluded members of the group.
Second,
the IRS Office of Chief Coun-
sel conc
luded that, given the particular
facts an
d circumstances of that case, the
taxpay
er should exclude sales to its ma-
jority
-owned foreign subsidiaries when
comput
ing gross receipts for purposes of
determ
ining its base amount under section
41(c).
The commenter requested guidance
on the
facts and circumstances that caused
the IR
S Office of Chief Counsel to exclude
such s
ales in computing gross receipts.
The IR
S and the Treasury Department
belie
ve that the requested guidance is out-
side
the scope of the NPRM, which only
invo
lves the first issue addressed in the
CCA,
and is consistent with the conclu-
sion
of the CCA on that issue.
Howe
ver, the final regulation makes
one c
larifying change. Paragraph (a)(1)(ii)
of th
e proposed regulation states that
in de
termining whether a corporation is
inc
ludedinacontrolledgroupofcor-
por
ations, section 1563(b) shall not be
tak
en into account. Section 1563(b) de-
fin
es a component member, including an
exc
luded member and an additional mem-
be
r. Paragraph (a)(1)(ii) as now revised
will also prov
ide that the underlying reg-
ulation, §1.1
563–1(b), which defines a
component mem
ber, shall not be taken
into account
in determining the members
of a controll
ed group.
Special Analyses
It has been determined that this regu-
lation is not a significant regulatory ac-
tion as defined in Executive Order 12866.
Therefore, a regulatory assessment is not
required. It also has been determined that
section 553(b) of the Administrative Pro-
cedure Act (5 U.S.C. chapter 5) does not
apply to this regulation and because this
regulation does not impose a collection of
information on small entities, the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Pursuant to section 7805(f)
this regulation has been submitted to the
Chief Counsel for Advocacy of the Small
Business Administration for comment on
its impact on small business.
Draftin
g Information
The principal author of this regulation is
Grid Glyer of the Office of Associate Chief
Counsel (Corporate). However, other per-
sonnel from the IRS and the Treasury De-
partment participated in its development.
*****
Adopt
ion of Amendments to the
Regu
lations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Par
agraph 1. The authority citation for
par
t 1 continues to read in part as follows:
Aut
hority:26U.S.C.7805***
Par.
2. Section 1.1563–1 is amended
by:
1. Re
designating paragraph (a)(1)(ii) as
par
agraph (a)(1)(iii) and adding new para-
gra
ph (a)(1)(ii).
2. A
ddingExample 4to paragraph
(b)
(4).
3. A
dding a sentence at the end of para-
gra
ph (e).
2011–20 I.R.B.780May 16, 2011

The additions read as follows:
§1.1563–1 Definition of controlled group
of corporations and component members
and related concepts.
(a) * * *
(1) * * *
(ii)Special rules. In determining
whether a corporation is included in a
controlled group of corporations, section
1563(b) and paragraph (b) of this section
shall not be taken into account. For rules
defining a component member of a con-
trolled group of corporations, including
rulesdefininganexcludedmemberand
an additional member, see section 1563(b)
and paragraph (b) of this section.
*****
(b) * * *
(4) * * *
Example 4. Individual A owns all of the stock of
corporations X, Y and Z. Each of these corporations
is an S corporation. X, Y, and Z are each members of
a brother-sister controlled group, even though each
such corporation is treated as an excluded member of
such group. See §1.1563–1(b)(2)(ii)(C).
*****
(e)Effective/Applicability date. ***
Paragraph (a)(1)(ii) of this section applies
to taxable years beginning on or after
April 11, 2011.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved April 4, 2011.
Michael F. Mundaca,
Assistant Secretary of
theTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on April 8, 2011,
8:45 a.m., and published in the issue of the Federal Register
for April 11, 2011, 76 F.R. 19907)
Section 9701.—Definitions
of General Applicability
26 CFR 300.0: User fees; in general.
T.D. 9523
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 300
User Fees Relating to
Enrolled Agents and Enrolled
Retirement Plan Agents
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
amendments to the regulations relating to
theimpositionofuserfeesforenrolled
agents and enrolled retirement plan agents.
The final regulations lower the initial en-
rollment and renewal of enrollment user
fees for enrolled agents and enrolled retire-
ment plan agents and separate the enrolled
retirement plan agent user fees from the
enrolled agent user fees. The final regula-
tions affect individuals who are, or apply
to become, enrolled agents or enrolled
retirement plan agents.
DATES:Effective Date:These regulations
are effective on April 19, 2011.
Applicability Date:For dates of ap-
plicability, see §§300.5(d), 300.6(d),
300.9(d), 300.10(d), and 300.11(d).
FOR FURTHER INFORMATION
CONTACT: Concerning the final reg-
ulations, Emily M. Lesniak at (202)
622–4570, or concerning cost methodol-
ogy, Eva J. Williams at (202) 435–5514
(not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
This document contains final regula-
tions relating to the initial enrollment and
renewal of enrollment for enrolled agents
and enrolled retirement plan agents. The
Independent Offices Appropriations Act
of 1952, which is codified at 31 U.S.C.
9701, authorizes agencies to prescribe reg-
ulations establishing user fees for services
provided by the agency. Regulations pre-
scribing user fees are subject to the poli-
cies of the President, which are currently
set forth in the Office of Management and
Budget Circular A–25 (the OMB Circu-
lar), 58 FR 38142 (July 15, 1993). The
OMB Circular requires agencies seeking
to impose user fees for providing special
benefits to identifiable recipients to calcu-
late the full cost of providing those bene-
fits.
Section 330 of title 31 of the United
States Code authorizes the Secretary
of the Treasury to regulate the practice
of representatives before the Treasury
Department. Pursuant to section 330
of title 31, the Secretary has published
regulations governing practice before the
IRS in 31 CFR part 10 and reprinted
the regulations as Treasury Department
Circular No. 230 (Circular 230). Section
10.4 of Circular 230 authorizes the
Commissioner of Internal Revenue to
grant status as an enrolled agent or enrolled
retirement plan agent to applicants who
demonstrate special competence in tax
matters.
To become an enrolled agent or enrolled
retirement plan agent, an applicant gener-
ally must pass a special enrollment exam-
ination and file an application for enroll-
ment with the IRS. An individual granted
status as an enrolled agent or enrolled re-
tirement plan agent as provided in §10.6(d)
of Circular 230 must renew enrollment ev-
ery three years to maintain active enroll-
mentandbeabletopracticebeforethe
IRS.
On December 10, 2010, the Treasury
Department and the IRS published in the
Federal Register(75 FR 76940) a notice
of proposed rulemaking proposing amend-
ments to part 300 of title 26 of the Code
of Federal Regulations. The regulations
proposed to reduce the initial enrollment
and renewal of enrollment user fees for en-
rolled agents and enrolled retirement plan
agents to $30 from $125. The reduction
in user fees is necessary to account for
the reallocation of portions of the enrolled
agent and enrolled retirement plan agent
renewal processes to the preparer tax iden-
tification number (PTIN) application and
renewal process. The costs to the govern-
ment for the reallocated portions of the en-
rolled agent and enrolled retirement plan
May 16, 20117812011–20 I.R.B.

agents initial enrollment and renewal of
enrollment processes are now recovered
by the user fee to apply for or renew a
PTIN (T.D. 9503, 2010–47 I.R.B. 706 [75
FR 60316]). Additionally, these regula-
tions proposed to separate the enrolled re-
tirement plan agent user fees from the en-
rolled agent user fees.
A public hearing was scheduled for Jan-
uary 14, 2011. The IRS did not receive any
requests to testify at the public hearing, and
the hearing was cancelled.
The IRS received written comments in
response to the proposed regulations. Af-
ter careful consideration of the public com-
ments, the Treasury Department and the
IRS decided to adopt without substantive
modification the proposed regulations re-
ducing the enrolled agent and enrolled re-
tirement plan agent initial enrollment and
renewal of enrollment user fees to $30
and separating the enrolled retirement plan
agent user fees from the enrolled agent
user fees.
Summary of Comments
The IRS received five comments in
response to the notice of proposed rule-
making. The comments were considered
and are available forpublic inspection at
www.regulations.govor upon request. The
comments related to the reduced enrolled
agent user fees; Announcement 2010–81,
2010–45 I.R.B. 638, which delayed the
renewal period for enrolled agents whose
social security or tax identification number
ends in 4, 5, or 6; the recently published
final regulations under section 6109 (T.D.
9501, 2010–46 I.R.B. 651 [75 FR 60309]),
which require tax return preparers who
prepare all or substantially all of a tax
return or claim for refund for compensa-
tion to have a PTIN; the final regulations
implementing a $50 user fee to the IRS
to apply for or renew a PTIN; and the
proposed amendments to Circular 230
(75 FR 51713). The IRS did not receive
any comments regarding the separation
of the enrolled retirement plan agent user
fees from the enrolled agent user fees.
The comments relating to the proposed
regulations reducing the enrolled agent
and enrolled retirement plan agent user
fees are summarized in this preamble. To
the extent that the comments raised is-
sues regarding other Treasury Department
guidance, the Treasury Department and
the IRS have considered or will consider
the comments in connection with the rele-
vant guidance.
The IRS received two comments re-
garding the amount of the user fees in the
proposed regulations. One comment sup-
ported reducing the initial enrollment and
renewal of enrollment user fees for en-
rolled agents to $30. Another comment re-
quested that the reduction in the user fee to
renew enrollment as an enrolled agent be
made retroactive.
The Treasury Department and the IRS
took steps to prevent duplication of costs
for enrolled agents whose enrollment re-
newal period was scheduled to begin after
the effective date of the user fee to ap-
ply for or renew of PTIN, but before the
enrolled agent user fees are reduced. As
previously discussed, the enrolled agent
and enrolled retirement plan agent user
fees are being reduced to account for
the reallocation of part of the enrollment
processes to the PTIN application and
renewal process. On October 14, 2010,
the Treasury Department and the IRS
issued Announcement 2010–81, which
delayed the renewal period for enrolled
agents who were scheduled to renew
their enrollment between November 1,
2010, and January 31, 2011. Thus, the
announcement delayed the renewal period
for those enrolled agents required to
both renew their enrollment and obtain a
PTIN between September 28, 2010 and
January 31, 2011 until guidance reducing
the renewal of enrollment user fees could
be finalized.
Further, the OMB Circular provides
that Federal agencies should recover the
full cost of providing a special benefit to
an identifiable recipient. Designation as
an enrolled agent is a special benefit that is
conferred upon a specific individual, and
under the OMB Circular, the IRS should
recover the full cost of providing this ben-
efit. Prior to the implementation of the
user fee to apply for or renew a PTIN, the
cost to the government to process an initial
enrollment or renewal of enrollment ap-
plication for an enrolled agent or enrolled
retirement plan agent was $125. Thus, the
reduced $30 user fee would not recover the
entire cost to the government to process
applications submitted before the effective
date of the regulations implementing the
user fee to apply for or renew a PTIN.
After considering the public comments,
the Treasury Department and the IRS have
decided to adopt the proposed regulations
without substantive modification.
Effective/Applicability Date
The Administrative Procedure Act pro-
vides that substantive rules will not be ef-
fective until thirty days after the final reg-
ulations are published in theFederal Reg-
ister(5 U.S.C. 553(d)). Final regulations
may be effective prior to thirty days after
publication if the publishing agency finds
that there is good cause for an earlier ef-
fective date.
The Treasury Department and the IRS
finalized regulations that require all tax re-
turn preparers who prepare all or substan-
tially all of a tax return or claim for refund
for compensation to use a PTIN as their
identifying number and to pay a $64.25
fee, which includes the amount paid to the
vendor, to apply for or renew a PTIN. Tax
return preparers who prepare all or sub-
stantially all of a tax return or claim for re-
fund must obtain or renew their PTIN for
the 2011 tax season.
Circular 230 requires that, to maintain
active enrollment to practice before the
IRS, enrolled agentsmust renew enroll-
ment every third yearafter initial enroll-
ment is granted. Under Circular 230, en-
rolled agents with social security numbers
or tax identification numbers ending in 4,
5, or 6 were scheduled to renew their en-
rollment between November 1, 2010 and
January 31, 2011. To enable these enrolled
agents to renew their enrollment at the
reduced fee, the IRS issued Announcement
2010–81 on October 14, 2010, which
delayed the renewal period for enrolled
agents with social security numbers or
tax identification numbers ending in 4,
5, or 6. The renewal process cannot
be reinstated until these regulations are
finalized; otherwise, these enrolled agents
will pay twice for the IRS to perform
compliance and suitability checks. To
minimize the disruption to the enrolled
agent program caused by the delay of
renewal, the renewal process must be
reinstated as quickly as possible. Thus, the
Treasury Department and the IRS find that
there is good cause for these regulations
to be effective upon the publication of a
Treasury decision adopting these rules as
final regulations in theFederal Register.
2011–20 I.R.B.782May 16, 2011

Special Analyses
It has been determined that this final
rule is not a significant regulatory action
as defined in Executive Order 12866. It
is hereby certified that the regulations will
not have a significant economic impact on
a substantial number of small entities. Ac-
cordingly, a regulatory flexibility analy-
sis is not required. This certification is
based upon the information that follows.
The regulations do not place an additional
filing requirement on enrolled agents or
enrolled retirement plan agents and de-
crease the enrollment costs already in ef-
fect. Thus, the regulations should reduce
the economic impact imposed by the cur-
rent enrolled agent and enrolled retirement
plan agent user fees.
It also has been determined that sec-
tion 553(b) of the Administrative Proce-
dure Act (5 U.S.C. chapter 5) does not ap-
ply to these regulations, and because the
regulations do not impose a collection of
information on small entities, the Regula-
tory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Pursuant to section 7805(f)
of the Code, the notice of proposed rule-
making was submitted to the Chief Coun-
sel for Advocacy of the Small Business
Administration for comment on its impact
on small business. The Chief Counsel for
Advocacy did not submit comments on the
notice of proposed rulemaking.
Drafting Information
The principal author of these regula-
tions is Emily M. Lesniak, Office of the
Associate Chief Counsel (Procedure and
Administration).
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 300 is
amended as follows:
PART 300—USER FEES
Paragraph 1. The authority citation for
part 300 continues to read in part as fol-
lows:
Authority: 31 U.S.C. 9701.
Par. 2. Section 300.0 is amended by:
1. Redesignating paragraph (b)(9) as
paragraph (b)(12).
2. Adding new paragraph (b)(9).
3. Adding paragraphs (b)(10) and
(b)(11).
The additions and revisions read as fol-
lows.
§300.0 User fees; in general.
*****
(b) * * *
(9) Taking the special enrollment exam-
ination to become an enrolled retirement
plan agent.
(10) Enrolling an enrolled retirement
plan agent.
(11) Renewing the enrollment of an en-
rolled retirement plan agent.
*****
Par. 3. Section 300.4 is amended by
revising the heading to read as follows:
§300.4 Enrolled agent special enrollment
examination fee.
*****
Par. 4. Section 300.5 is amended by
revising paragraphs (b) and (d) to read as
follows:
§300.5 Enrollment of enrolled agent fee.
*****
(b)Fee. The fee for initially enrolling
as an enrolled agent with the IRS is $30.
*****
(d)Effective/applicability date.This
section is applicable beginning April 19,
2011.
Par. 5. Section 300.6 is amended by
revising paragraphs (b) and (d) to read as
follows:
§300.6 Renewal of enrollment of enrolled
agent fee.
*****
(b)Fee. The fee for renewal of enroll-
ment as an enrolled agent with the IRS is
$30.
*****
(d)Effective/applicability date.This
section is applicable beginning April 19,
2011.
Par. 6. Redesignate §300.9 as §300.12.
§300.9[Redesignated as §300.12]
Par. 7. Add new §300.9 to read as
follows:
§300.9 Enrolled retirement plan agent
special enrollment examination fee.
(a)Applicability. This section applies
to the special enrollment examination to
become an enrolled retirement plan agent
pursuant to 31 CFR 10.4(b).
(b)Fee. The fee for taking the enrolled
retirement plan agent special enrollment
examination is $11 per part, which is the
cost to the government for overseeing the
examination and does not include any fees
charged by the administrator of the exam-
ination.
(c)Person liable for the fee. The per-
son liable for the enrolled retirement plan
agent special enrollment examination fee
is the applicant taking the examination.
(d)Effective/applicability date.This
section is applicable beginning April 19,
2011.
Par. 8. Section 300.10 is added to read
as follows:
§300.10 Enrollment of enrolled retirement
plan agent fee.
(a)Applicability
. This section applies
to the initial enrollment of enrolled retire-
ment plan agents with the IRS pursuant to
31 CFR 10.5(b).
(b)Fee. The fee for initially enrolling
as an enrolled retirement plan agent with
the IRS is $30.
(c)Person liable for the fee. The per-
son liable for the enrollment fee is the ap-
plicant filing for enrollment as an enrolled
retirement plan agent with the IRS.
(d)Effective/applicability date.This
section is applicable beginning April 19,
2011.
Par. 9. Section 300.11 is added to read
as follows:
§300.11 Renewal of enrollment of enrolled
retirement plan agent fee.
(a)Applicability. This section applies
to the renewal of enrollment of enrolled re-
tirement plan agents with the IRS pursuant
to 31 CFR 10.5(b).
(b)Fee. The fee for renewal of enroll-
ment as an enrolled retirement plan agent
with the IRS is $30.
(c)Personliableforthefee. The person
liable for the renewal of enrollment fee is
the person renewing enrollment as an en-
rolled retirement plan agent with the IRS.
May 16, 20117832011–20 I.R.B.

(d)Effective/applicability date.This
section is applicable beginning April 19,
2011.
Steven T. Miller,
Deputy Commissioner for
Services and Enforcement.
Approved April 13, 2011.
Michael F. Mundaca,
Assistant Secretary of
theTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on April 14, 2011,
4:15 p.m., and published in the issue of the Federal Register
for April 19, 2011, 76 F.R. 21805)
2011–20 I.R.B.784May 16, 2011

Part III. Administrative, Procedural, and Miscellaneous
Extension of Interim Guidance
on Section 67 Limitations on
Estates or Trusts
Notice 2011–37
PURPOSE
This notice extends to taxable years that
begin before the date that final regulations
under § 1.67–4 of the Income Tax Regula-
tions are published in theFederal Regis-
ter, the interim guidance provided in No-
tice 2010–32, 2010–16 I.R.B. 594, Notice
2008–116, 2008–52 I.R.B. 1372, and No-
tice 2008–32, 2008–11 I.R.B. 593, on the
treatment under § 67 of the Internal Rev-
enue Code of investment advisory costs
and other costs subject to the 2-percent
floor under § 67(a) that are integrated as
part of one commission or fee paid to a
trustee or executor (“Bundled Fiduciary
Fee”) and are incurred by a trust other than
a grantor trust (nongrantor trust) or an es-
tate. Notice 2010–32 is modified and su-
perseded.
BACKGROUND
On January 16, 2008, the Supreme
Court of the United States issued its de-
cision inMichael J. Knight, Trustee of
William L. Rudkin Testamentary Trust
v. Commissioner, 552 U.S. 181, 128 S.
Ct. 782 (2008), holding that costs paid
to an investment advisor by a nongrantor
trust or estate generally are subject to the
2-percent floor for miscellaneous itemized
deductions under § 67(a). The IRS and
the Treasury Department expect to issue
regulations under § 1.67–4 consistent with
the Supreme Court’s holding inKnight.
The regulations also will address the issue
raised when a nongrantor trust or estate
pays a Bundled Fiduciary Fee for costs
incurred in-house by the fiduciary, some
of which are subject to the 2-percent floor
and some of which are fully deductible
without regard to the 2-percent floor. The
IRS and Treasury Department intend that
final regulations will not be applicable to
taxable years that begin before the date
that final regulations are published in the
Federal Register.
Notice 2008–32 provided interim guid-
ance that specificallyaddressed the treat-
ment of a Bundled Fiduciary Fee. In short,
Notice 2008–32 provided that taxpayers
would not be required to determine the
portion of a Bundled Fiduciary Fee that is
subject to the 2-percent floor under § 67
for any taxable year beginning before Jan-
uary 1, 2008. Notice 2008–116 extended
the interim guidance provided in Notice
2008–32 to any taxable years begin-
ning before January 1, 2009, and Notice
2010–32 extended the interim guidance
provided in Notice 2008–116 and Notice
2008–32 to taxable years beginning before
January 1, 2010.
EXTENSION OF INTERIM GUIDANCE
Taxpayers will not be required to deter-
mine the portion of a Bundled Fiduciary
Fee that is subject to the 2-percent floor
under § 67 for any taxable year beginning
before the date that final regulations are
published in theFederal Register.In-
stead, for each such taxable year, taxpay-
ers may deduct the full amount of the Bun-
dled Fiduciary Fee without regard to the
2-percent floor. Payments by the fiduciary
to third parties for expenses subject to the
2-percent floor are readily identifiable and
must be treated separately from the other-
wise Bundled Fiduciary Fee.
EFFECT ON OTHER DOCUMENTS
Notice 2010–32 is modified and super-
seded.
CONTACT INFORMATION
The principal author of this notice
isJenniferN.KeeneyoftheOfficeof
Associate Chief Counsel (Passthroughs
& Special Industries). For further in-
formation regarding this notice, contact
Jennifer N. Keeney at (202) 622–3060.
Truncating Social Security
Numbers on Paper Payee
Statements
Notice 2011–38
SECTION 1. PURPOSE
This notice announces an extension
and modification of the pilot program
announced in Notice 2009–93, 2009–51
I.R.B. 863, which authorized filers of
certain information returns to truncate
an individual payee’s nine-digit identi-
fying number on specified paper payee
statements furnished for calendar years
2009 and 2010, if the filers met certain re-
quirements. This notice extends the pilot
program as to paper payee statements fur-
nished for calendar years 2011 and 2012,
in order to allow more time for the IRS
and taxpayers to evaluate the program.
This notice also modifies the requirements
announced in Notice 2009–93 by exclud-
ing Form 1098–C,Contributions of Motor
Vehicles, Boats, and Airplanes,fromthe
pilot program as it is an “acknowledge-
ment” required by section 170(f)(12),
rather than a payee statement. Therefore
it is not included in the scope of this pilot
program.
SECTION 2. BACKGROUND
An information return is a return, state-
ment, form, or other document that must
be filed with the IRS to report certain
payments or distributions to a payee or
amounts received from a payee in a cal-
endar year. See section 6724(d)(1); Treas.
Reg. § 301.6721–1(g)(1). A filer is any
person required to file an information re-
turn. See Treas. Reg. § 301.6721–1(g)(6).
A payee is any person who is required
to receive a copy of the information set
forthonaninformationreturnbythe
filer of the return. See Treas. Reg.
§ 301.6721–1(g)(5). A filer generally
must also furnish a payee statement to
each payee that contains the same infor-
mation as the information return for that
payee. See section 6724(d)(2); Treas.
Reg. § 301.6722–1(d)(2). Generally, filers
are required to furnish payee statements
to payees on or before January 31
st
of the
year following the calendar year for which
the information return is made. See,e.g.,
sections 6041(d) and 6042(c). Filers may
be subject to penalties for failure to file
correct information returns or furnish cor-
rect payee statements. See sections 6721
and 6722.
Regulations, forms, or instructions to
forms typically require that the payee
statement include the identifying number
of the payee. The three types of identi-
May 16, 20117852011–20 I.R.B.

fying numbers applicable to individuals
are social security numbers, IRS indi-
vidual taxpayer identification numbers,
and IRS adoption taxpayer identification
numbers. All three of these identifying
numbers are nine-digit numbers taking
the form 000–00–0000. Treas. Reg.
§ 301.6109–1(a)(1)(i).
A person’s identifying number is sen-
sitive personal information. A risk exists
that this information could be misappro-
priated from a paper payee statement and
misused in various ways, such as to facili-
tate identity theft.
SECTION 3. SCOPE
This notice applies only to paper payee
statements in the Form 1098 series (ex-
cluding Form 1098–C,Contributions of
Motor Vehicles, Boats, and Airplanes),
Form 1099 series, and Form 5498 series.
Substitute and composite substitute state-
ments (within the meaning of Treas. Reg.
§ 301.6722–1(a)(1)) that meet the require-
ments of this notice are also included. See
Rev. Proc. 2009–49, 2009–51 I.R.B. 879.
This notice does not apply to any infor-
mation return filed with the IRS, any payee
statement furnished electronically, or any
payee statement not specified in this no-
tice.
During this extended pilot program,
truncation will be permitted only for indi-
vidual identifying numbers on the paper
payee statements specified in this section.
Truncation of payee employer identifica-
tion numbers (EINs) or filer identifying
numbers is not permitted. Truncation of
identifying numbers is not permitted on
information returns filed with the IRS or
on any payee statements furnished elec-
tronically.
SECTION 4. REQUIREMENTS
A filer must satisfy the requirements
set forth in this section to be authorized
to truncate identifying numbers for indi-
viduals on the paper payee statements for
calendar years 2011 and 2012. The IRS
will treat a filer as having satisfied any re-
quirement in Treasury and IRS guidance,
whether in a regulation, form, or form in-
structions, to include a payee’s identifying
number on a paper payee statement if the
following requirements are met:
.01 The identifying number is a social
security number, IRS individual taxpayer
identification number, or IRS adoption
taxpayer identification number;
.02 The identifying number is trun-
cated by replacing the first five digits of
the nine-digit number with asterisks or
Xs (for example, a social security number
123–45–6789 would appear on the pa-
per payee statement as ***–**–6789 or
XXX–XX–6789); and
.03 The truncated identifying number
appears on a paper payee statement (in-
cluding substitute and composite substi-
tute statements) in the Form 1098 series
(excluding Form 1098–C,Contributions
of Motor Vehicles, Boats, and Airplanes),
Form 1099 series, or Form 5498 series for
calendar years 2011 and 2012.
Truncation of an identifying number on
a paper payee statement in the manner
set forth in this Section 4 is authorized
notwithstanding calendar year 2011 form
instructions that state that the pilot pro-
gram announced in Notice 2009–93 has
expired.
SECTION 5. EFFECTIVE DATE
This notice is effective upon release.
SECTION 6. REQUEST FOR
COMMENTS
The IRS invites the public to submit
comments on this notice by July 29, 2011,
and is particularly interested in com-
ments from payors that furnished paper
payee statements with truncated identi-
fying numbers under the original pilot
program as well as comments from payees
that received paper payee statements with
truncated identifying numbers for either
calendar year 2009 or 2010. The IRS is
interested in learning about issues encoun-
tered by payors and payees alike. The
IRS also welcomes comments on whether
payors should be allowed to truncate a
payee’s EIN, whether truncation should
be permitted on additional types of payee
statements, and whether payors should be
allowed to truncate a payee’s identifying
number on electronically furnished payee
statements.
Comments should be submitted to: In-
ternal Revenue Service, CC:PA:LPD:PR
(Notice 2011–38), Room 5203, P.O. Box
7604, Ben Franklin Station, N.W., Wash-
ington, D.C. 20044. Alternatively, com-
ments may be hand delivered between the
hours of 8:00 a.m. and 4:00 p.m., Mon-
day through Friday, to CC:PA:LPD:PR
(Notice 2011–38), Courier’s Desk, Inter-
nal Revenue Service, 1111 Constitution
Avenue, N.W., Washington, D.C. Com-
ments may also be transmitted electron-
ically via the following e-mail address:
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2011–38” in the
subject line of any electronic communica-
tions. All comments will be available for
public inspection and copying.
SECTION 7. DRAFTING
INFORMATION
The principal author of this notice is
TammieA.GeieroftheOfficeofthe
Associate Chief Counsel (Procedure and
Administration). For further informa-
tion regarding this notice, please contact
Tammie A. Geier at (202) 622–4940 (not
a toll-free call).
Public Comment Invited
on Recommendations for
2011–2012 Guidance Priority
List
Notice 2011–39
The Department of Treasury and Inter-
nal Revenue Service invite public com-
ment on recommendations for items that
should be included on the 2011–2012
Guidance Priority List.
The Treasury Department’s Office of
Tax Policy and the Service use the Guid-
ance Priority List each year to identify
and prioritize the tax issues that should
be addressed through regulations, revenue
rulings, revenue procedures, notices, and
other published administrative guidance.
The 2011–2012 Guidance Priority List
will establish the guidance that the Trea-
sury Department and the Service intend to
issue from July 1, 2011, through June 30,
2012. The Treasury Department and the
Service recognize the importance of pub-
lic input to formulate a Guidance Priority
List that focuses resources on guidance
items that are most important to taxpayers
and tax administration. Published guid-
ance plays an important role in increasing
voluntary compliance by helping to clarify
ambiguous areas of the tax law.
2011–20 I.R.B.786May 16, 2011

As is the case whenever significant
legislation is enacted, the Treasury De-
partment and the Service have continued
to dedicate substantial resources during
the current plan year to published guid-
ance projects necessary to implement the
provisions of the multitude of tax Acts
that have been enacted over the past sev-
eral years including, but not limited to,
the American Recovery and Reinvestment
Tax Act of 2009, Pub. L. No. 111–5,
123 Stat. 115, which was enacted on
February 17, 2009; the Hiring Incentives
to Restore Employment Act, Pub. L.
No. 111–147, 124 Stat. 71, which was
enacted on March 18, 2010; the Patient
Protection and Affordable Care Act, Pub.
L. No. 111–148, 124 Stat. 119, which was
enacted on March 23, 2010; the Health
Care and Education Reconciliation Act,
Pub. L. 111–152, 124 Stat. 1029, which
was enacted on March 30, 2010; and
the Tax Relief, Unemployment Insurance
Reauthorization, and Job Creation Act of
2010, Pub. L. No. 111–312, 124 Stat.
3296, which was enacted on December 17,
2010. The Treasury Department and
the Service will continue to evaluate the
priority of each guidance project in light
of the above-mentioned tax legislation and
other developments occurring during the
2011–2012 plan year.
In reviewing recommendations and se-
lecting projects for inclusion on the 2011-
2012 Guidance Priority List, the Treasury
Department and the Service will consider
the following:
1. Whether the recommended guidance
resolves significant issues relevant to
many taxpayers;
2. Whether the recommended guidance
promotes sound tax administration;
3. Whether the recommended guidance
can be drafted in a manner that will
enable taxpayers to easily understand
and apply the guidance;
4. Whether the recommended guid-
ance involves regulations that are
outmoded, ineffective, insufficient,
or excessively burdensome and that
should be modified, streamlined, ex-
panded, or repealed;
5. Whether the Service can administer
the recommended guidance on a uni-
form basis; and
6. Whether the recommended guidance
reduces controversy and lessens the
burden on taxpayers or the Service.
Taxpayers may submit recommenda-
tions for guidance at any time during the
year. Please submit recommendations by
June 1, 2011, for possible inclusion on
the original 2011–2012 Guidance Priority
List. The Treasury Department and the
Service may update the 2011–2012 Guid-
ance Priority List periodically to reflect
additional guidancethat the Treasury De-
partment and the Service intend to publish
during the plan year. The periodic updates
allow the Treasury Department and the
Service to respond to the need for addi-
tional guidance that may arise during the
plan year. Recommendations for guidance
received after June 1, 2011, will be re-
viewed for inclusion in the next periodic
update.
Taxpayers are not required to submit
recommendations for guidance in any par-
ticular format. Taxpayers should, how-
ever, briefly describe the recommended
guidance and explain the need for the guid-
ance. In addition, taxpayers may include
an analysis of how the issue should be re-
solved. It would be helpful if taxpayers
suggesting more than one guidance project
prioritize the projects by order of impor-
tance. If a large number of projects are be-
ing suggested, it also would be helpful if
the projects were grouped in terms of high,
medium or low priority.
Taxpayers should send written com-
ments to:
Internal Revenue Service
Attn: CC:PA:LPD:PR
(Notice 2011–39)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
or hand deliver comments Monday
through Friday between the hours of
8 a.m. and 4 p.m. to:
Courier’s Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR
(Notice 2011–39)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
Alternatively, taxpayers may sub-
mit comments electronically via
e-mail to the following address:
Notice.Comments@irscounsel.treas.gov.
Taxpayers should include “Notice
2011–39” in the subject line. All
comments submitted by the public will
be available for public inspection and
copying in their entirety.
For further information regarding this
notice, contact Henry Schneiderman of
the Office of Associate Chief Counsel
(Procedure and Administration) at (202)
622–3400 (not a toll-free call).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
Rev. Proc. 2011–24
SECTION 1. PURPOSE
This revenue procedure establishes a
dispute resolution process for the prelim-
inary fee calculation for the 2011 annual
fee imposed on covered entities engaged
in the business of manufacturing or im-
porting branded prescription drugs. The
fee was enacted by section 9008 of the Pa-
tient Protection and Affordable Care Act
(ACA), Public Law 111–148 (124 Stat.
119 (2010)), as amended by section 1404
of the Health Care and Education Rec-
onciliation Act of 2010 (HCERA), Pub-
lic Law 111–152 (124 Stat. 1029 (2010)).
All references in this revenue procedure to
section 9008 are references to section 9008
of the ACA, as amended by section 1404
of HCERA.
SECTION 2. BACKGROUND
.01 Section 9008 imposes an annual
fee on each covered entity with gross re-
ceipts of over $5 million from branded pre-
scription drug sales to any specified gov-
ernment program or pursuant to coverage
under such program (branded prescription
drug sales). A covered entity is gener-
ally any manufacturer or importer with
gross receipts from branded prescription
drug sales. Multiple related manufactur-
ers or importers may be treated as a sin-
gle covered entity under certain circum-
stances. See §9008(d)(2) and Part 1 of No-
tice 2011–9, 2011–6 I.R.B. 459. The spec-
ified government programs are the Medi-
care Part D program, the Medicare Part B
May 16, 20117872011–20 I.R.B.

program, the Medicaid program, and any
program under which branded prescription
drugs are procured by the Department of
Veterans Affairs (VA), Department of De-
fense (DOD), and DOD’s TRICARE retail
pharmacy program (the Programs). Fees
collected under section 9008 are credited
to the Medicare Part B trust fund.
.02 Section 9008 sets the aggregate an-
nual fee for all covered entities. For 2011,
the aggregate fee is $2.5 billion. This
aggregate fee is apportioned among the
covered entities for each year based on
each covered entity’s proportionate share
of branded prescription drug sales that are
taken into account during the previous cal-
endar year. The Secretary of the Treasury
is to establish an annual payment date that
is no later than September 30 of each year.
.03 Special rules in section 9008 ex-
clude sales of certain orphan drugs from
“branded prescription drug sales”; provide
that a covered entity’s branded prescrip-
tion drug sales between $5 million and
$400 million will only partially be taken
into account in determining a covered en-
tity’s proportionate share of sales; and pro-
vide a controlled group rule so that all per-
sons that are treated as a single employer
under certain provisions of the Internal
Revenue Code (Code) will be treated as a
single covered entity.
.04 Section 9008 requires the Secretary
of Health and Human Services, the Sec-
retary of Veterans Affairs, and the Secre-
tary of Defense (the Agencies) to report
to the Secretary of the Treasury, at such
time and in such manner as the Secretary of
the Treasury prescribes, the total branded
prescription drug sales under each Secre-
tary’s jurisdiction. The provision includes
the detailed information to be included in
the reports by the respective Secretaries for
each specified government program.
.05 In Notice 2011–9, the Treasury De-
partment and the Internal Revenue Ser-
vice (IRS) described a proposed method-
ology for calculating the section 9008 fee
and the approach that the IRS will use
to perform a preliminary 2011 fee calcu-
lation for each covered entity. The IRS
will mail each covered entity notification
of its preliminary fee calculation for 2011
by May 16, 2011. (The IRS requested
that comments on this notice be submitted
by June 15, 2011.) Under that methodol-
ogy, the IRS will calculate each covered
entity’s fee for 2011 using data from the
2009 sales year. As set forth in Notice
2011–9, the IRS asked covered entities to
submit a Form 8947,Report of Branded
Prescription Drug Information,to the IRS
by February 11, 2011, to provide data on
branded prescription drugs, orphan drugs,
and rebates. In addition, any controlled
group treated as a single covered entity un-
der section 9008(d)(2) was asked to iden-
tify on Form 8947 a single person as the
“designated entity” toact for the controlled
group with respect to the section 9008 fee.
.06 From the data on the Forms 8947,
the IRS compiled a list of National Drug
Codes (NDCs) for branded prescription
drugs sold to the Programs and, after ap-
propriate due diligence, provided that list
to the Agencies. The Agencies provided
sales data to the IRS on the branded pre-
scription drug sales for the 2009 sales year
by Program and NDC.
.07 After receiving the sales data from
the Agencies, the IRS will make adjust-
ments for orphan drug sales and rebates,
and then calculate each covered entity’s
branded prescription drug sales taken into
account for purposes of the ratio set forth
in section 9008(b)(1). The IRS will then
provide a preliminary fee calculation for
2011 for each covered entity by dividing
each covered entity’s branded prescription
drug sales taken into account under sec-
tion 9008(b)(2) by the aggregate branded
prescription drug sales taken into account
for all covered entities and multiplying that
fraction by the applicable amount for the
year as set forth in section 9008(b)(4). The
IRS will mail each covered entity notifica-
tion of its preliminary fee calculation for
2011 by May 16, 2011.
.08 The notification of the preliminary
fee calculation for 2011 will include: (1)
the covered entity’s preliminary fee cal-
culation; (2) the covered entity’s branded
prescription drug sales for 2009, by NDC,
for each Program; (3) the covered entity’s
branded prescriptiondrugsalesfor2009
taken into account after application of
section 9008(b)(2); and (4) the aggregate
branded prescriptiondrugsalesfor2009
taken into account for all covered entities.
Covered entities will be able to review
this information before the June 15, 2011,
deadline for commenting on the method-
ology proposal in Notice 2011–9.
.09 The IRS will mail a final fee calcu-
lation for 2011 to each covered entity by
August 15, 2011, and payment of the fee
from each covered entity will be due no
later than September 30, 2011.
SECTION 3. SCOPE
This revenue procedure provides the
process a covered entity may use to dis-
pute what it believes are errors in its 2011
preliminary fee calculation. This is the
exclusive process available to covered
entities to dispute the preliminary fee cal-
culation and obtain any change to data that
would be reflected in the final fee calcula-
tion mailed by the IRS by August 15, 2011.
SECTION 4. PROCEDURES FOR
DISPUTING A 2011 PRELIMINARY
FEE CALCULATION
.01Submission of claimed error(s) to
the IRS
Upon receipt of the notification that
contains its 2011 preliminary fee calcula-
tion from the IRS, a covered entity should
review the data contained in the notifica-
tion. If the covered entity believes that
the notification contains one or more er-
rors in the mathematical calculation of
the fee, the orphan drug or rebate data,
the Program drug sales data, or any other
error, the covered entity must provide a
written error report to the IRS postmarked
by June 1, 2011, in order for a correction
to the claimed error(s) to be considered
by the IRS. If a designated entity filed a
Form 8947 on behalf of the covered entity,
the designated entity must also file any
error report for the covered entity.
.02Program drug sales data errors
If a covered entity asserts that there has
been one or more errors in drug sales data,
the entity must submit a separate error re-
port for each Program with its asserted er-
rors. Each report must include the follow-
ing information:
(1) Entity name, entity number (if appli-
cable, from Part I(a) of the Form 8947), ad-
dress, and Employer Identification Num-
ber (EIN) as previously reported on the
Form 8947.
(2) The name, telephone number, and
e-mail address (if available) of one or more
employees or representatives of the entity
with whom the Agencies may discuss the
claimed errors. If the representative is not
an employee of the entity, a Form 2848,
Power of Attorney and Declaration of Rep-
2011–20 I.R.B.788May 16, 2011

resentative,mustbefiledwiththeerrorre-
port.
(3) The name of the Program that re-
ported the data, the NDC, the specific
amount of sales data disputed, the pro-
posed corrected amount, an explanation of
why the Agency should use the proposed
corrected data instead, and documentation
of any Program drug sales data or other
information used to establish the existence
of any errors.
.03Errors other than Program drug
sales errors
If a covered entity asserts that there has
been one or more errors in the mathemat-
ical calculation of the fee, the rebate data,
the listing of an NDC for an orphan drug,
or any other error (other than Program drug
sales data errors), the entity must submit
one error report, separated into sections by
type of error, and must include the follow-
ing information:
(1) Entity name, entity number (if appli-
cable, from Part I(a) of the Form 8947), ad-
dress, and Employer Identification Num-
ber (EIN) as previously reported on the
Form 8947.
(2) The name, telephone number, and
e-mail address (if available) of one or more
employees or representatives of the entity
with whom the IRS and/or the Agencies
may discuss the claimed errors. If the rep-
resentative is not an employee of the entity,
a Form 2848,Power of Attorney and Dec-
laration of Representative, must be filed
with the error report.
(3) For a mathematical calculation er-
ror, the specific calculation element(s) that
the entity disputes and its proposed cor-
rected calculation.
(4) For a rebate data error, the NDC for
the drug to which it relates; a discussion
of whether the data used in the prelimi-
nary fee calculation matches previously re-
ported Form 8947 data on rebates; and if
the data used in the preliminary fee cal-
culation does match the Form 8947 data,
an explanation of whythe Form 8947 data
was erroneous and why the IRS should use
the proposed corrected data instead.
(5) For the listing of an NDC for an
orphan drug, the name and NDC of the
orphan drug; a discussion of whether the
data used in the preliminary fee calcu-
lation matches previously reported Form
8947 data on orphan drugs; and if the
data used in the preliminary fee calculation
does match the Form 8947 data, an expla-
nation of why the Form 8947 data was er-
roneous and why the IRS should use the
proposed corrected data instead.
(6) For any other asserted error, an ex-
planation of the nature of the error, how the
error affects the fee calculation, an expla-
nation of how the entity established that an
error occurred, the proposed correction to
the error, and an explanation of why the
IRS or Agency should use the proposed
corrected data instead.
(7) If an entity is using data to establish
the existence of an error and that data was
not reported on Form 8947 or contained
in the notification of the preliminary fee
calculation, a description of what the data
is, how the entity acquired the data, and
who maintains it.
(8) Documentation of any rebate and or-
phan drug data, or other information used
to establish the existence of any errors.
.04Form and manner of submission
(1) Each covered entity must submit its
error report(s) in the following format and
manner:
(a) All error reports and the supporting
documentation must be submitted on a sin-
gle CD-ROM.
(b) A separate folder must be created
for each Program with asserted drug sales
data errors and the corresponding files
for each Program placed in the Program
folder. (For example, a Microsoft Excel
spreadsheet file with drug sales data er-
rors for the Medicaid program must be
separate from a Microsoft Excel spread-
sheet file with drug sales data errors for
the Medicare Part D program). The folder
and file names of the Microsoft Excel,
Word, or Adobe files must include the
name of the Program to which the asserted
errors will be communicated. Asserted
errors in Program drug sales data must
be presented in a Microsoft Excel spread-
sheet file (no version newer than 2007)
in a format consistent with the data for-
mat from Attachment 2 of the Preliminary
Fee Calculation Letter (the IRS will mail
these letters (Letter 4657) by May 16,
2011) showing the amount reported by the
Program and the corresponding amount
asserted by the covered entity, with the
difference between the two.
(c) Asserted errors in mathematical cal-
culations, rebate data, an NDC listing for
an orphan drug, or any other asserted errors
must be submitted on a separate Microsoft
Excel spreadsheet file (no version newer
than 2007). This spreadsheet file must be
placed in a folder separate from the Pro-
gram sales data folder(s). The folder and
file names must distinguish these items
from the Program sales data folder and
files. These folders must also contain the
corresponding files for the asserted errors.
(d) A separate narrative for each Mi-
crosoft Excel spreadsheet file must be sub-
mitted and must be in Microsoft Word for-
mat (no version newer than 2007).
(e) Supporting documentation for each
Microsoft Excel spreadsheet file must be
in Adobe Portable Document Format (no
version newer than 8.0), if not available in
Microsoft Word or Excel format.
(2) A covered entity must also provide
an additional copy of its error report(s)
and supporting documentation in a sepa-
rate folder labeled “IRS Comprehensive
Error Report.”
.05Alternative Formats
Formats for submission other than Mi-
crosoft Word or Excel, or Adobe Portable
Document format may be arranged on a
case-by-case basis, if necessary, by con-
tacting the first IRS representative listed in
Section 6 of this revenue procedure.
.06Address for submission
Error reports and all supporting docu-
mentation must be mailed to:
Department of the Treasury
Internal Revenue Service
1973 N. Rulon White Boulevard,
Mail Stop 4916
Ogden, UT 84404
SECTION 5. REVIEW OF CLAIMED
ERROR(S)
.01In general
If a claimed error involves a mathemat-
ical calculation or a correction to orphan
drug or rebate data, the IRS will review
the information and determine whether to
make a correction. If a claimed error in-
volves drug sales data provided by a Pro-
gram, the IRS will provide the information
sent by the covered entity to the Agency
with jurisdiction over the appropriate Pro-
gram to determine whether to make a cor-
rection. For any other claimed error, the
IRS will review the information and deter-
mine whether the IRS or an Agency should
determine whether to make a correction.
.02Period of review of error reports and
notification of final determinations
May 16, 20117892011–20 I.R.B.

(1) The IRS and the Agencies will
review the error reports to determine
whether to make the proposed corrections
to the covered entity’s preliminary fee
calculation for 2011. The IRS will rely
exclusively on the Agencies to make de-
terminations with respect to any proposed
corrections to the Program drug sales data.
The IRS will notify the covered entity in
writing of the final determination with re-
spect to error reports when the IRS sends
the covered entity the final fee calculation
no later than August 15, 2011.
(2) The IRS will base a covered entity’s
final fee determination solely on the data
used for the preliminary fee calculation to-
gether with any adjustments to that data
made as a result of the dispute resolution
process described inthis revenue proce-
dure. To the extent any covered entity’s
preliminary fee calculation is changed as a
result of the dispute resolution process, the
final fee calculation for one or more cov-
ered entities may differ from the prelimi-
nary fee calculations those entities previ-
ously received. Any such changes will be
reflected in the covered entity’s final fee
calculation for 2011.
SECTION 6. CONTACT
INFORMATION
For questions regarding this dispute
resolution process, contact Lou Milano at
(908) 301–2118 (not a toll-free call). For
all other questions regarding this revenue
procedure, contact Celia Gabrysh at (202)
622–3130 (not a toll-free call).
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective
May 2, 2011.
SECTION 8. PAPERWORK
REDUCTION ACT
The collections of information con-
tained in this revenue procedure have
been reviewed and approved by the Office
of Management and Budget in accor-
dance with the Paperwork Reduction Act
(44 U.S.C. § 3507) under control number
1545–2209.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
control number.
The collections of information in this
revenue procedure are in section 4.
This information is required to evaluate
whether an error report regarding a prelim-
inary fee calculation is valid and justifies
an adjustment to the preliminary fee cal-
culation. The likely respondents are busi-
nesses.
The estimated total annual reporting
and/or recordkeeping burden of this rev-
enue procedure is 4,760 hours.
The estimated annual burden per re-
spondent/recordkeeper varies from 8 hours
to 64 hours, depending on individual cir-
cumstances, with an estimated average
burden of 40 hours. The estimated number
of respondents and/or record keepers is
119.
The estimated frequency of responses is
annual.
Books or records relating to a collection
of information must be retained as long as
their contents may become material in the
administration of the branded prescription
drug fee and any related internal revenue
law. Generally, this information is confi-
dential, as required by 26 U.S.C. § 6103.
2011–20 I.R.B.790May 16, 2011

Part IV. Items o
fGeneralInterest
Guidance on Re
porting
Interest Paid
to Nonresident
Aliens; Heari
ng
Announcemen
t 2011–30
AGENCY: Inter
nal Revenue Service
(IRS), Treas
ury.
ACTION: Noti
ce of public hearing on pro-
posed rulema
king.
SUMMARY: Thi
s document contains
a reschedule
d notice of public hear-
ingonanotic
e of proposed rulemaking
(REG–14609
7–09, 2011–8 I.R.B. 516)
that was pub
lished in theFederal Reg-
isteron Fri
day, January 7, 2011 (76 FR
1105) provi
ding guidance on the reporting
requiremen
ts for interest on deposits main-
tained at U
.S. offices of certain financial
instituti
ons and paid to nonresident alien
individua
ls.
DATES: The
public hearing is being
reschedul
ed from Monday, April 25, 2011
to Wednesd
ay, May 18, 2011, at 10 a.m.
ADDRESSE
S: The public hearing is being
held in th
e auditorium, Internal Revenue
Building
, 1111 Constitution Avenue, NW,
Washingt
on, DC. Send submissions to:
CC:PA:LP
D:PR (REG–146097–09), room
5203, In
ternal Revenue Service, P.O. Box
7604, Ben Fran
klin Station, Washing-
ton, DC 20044.
Submissions may be
hand-deliver
ed Monday through Friday
between the ho
urs of 8 a.m. and 4 p.m.
to CC:PA:LPD:
PR (REG–146097–09),
Courier’s De
sk, Internal Revenue
Service, 111
1 Constitution Avenue, NW,
Washington,
DC.
Alternative
ly, taxpayers may submit
electronic o
utlines of oral comments
via the Feder
al eRulemaking Portal at
http://www
.regulations.gov.
FOR FURTHER
INFORMATION
CONTACT: Co
ncerning the proposed
regulation
s, Kathryn Holman at (202)
622–3840; c
oncerning submissions of
comments,
the hearing, and/or to be
placed on t
he building access list to at-
tend the he
aring, Richard A. Hurst at
Richard.A
.Hurst@irscounsel.treas.govor
(202) 622
–7180 (not toll-free numbers).
SUPPLEME
NTARY INFORMATION:
The subjec
t of the public hearing
is in the n
otice of proposed rulemak-
ing (REG–
146097–09) that was pub-
lished in
theFederal Registeron Friday,
January 7
, 2011 (76 FR 1105).
Persons,
whowishtopresentoralcom-
ments at t
he hearing that submitted written
comment
s, must have submitted an out-
line of t
he topics to be discussed and the
amount of time
to be devoted to each topic
(signed origi
nal and eight (8) copies) by
Friday, April
8, 2011.
Aperiodof10m
inutes is allotted to
each person fo
r presenting oral comments.
After the dead
line for receiving out-
lines has pass
ed, the IRS will prepare an
agenda conta
ining the schedule of speak-
ers. Copies o
f the agenda will be made
available, f
ree of charge, at the hearing or
in the Freedo
m of Information Reading
Room (FOIA R
R) (Room 1621) which
is located a
tthe11
th
and Pennsylvania
Avenue NW en
trance, 1111 Constitution
Avenue, NW,
Washington, DC.
Because of a
ccess restrictions, the IRS
will not adm
it visitors beyond the imme-
diate entr
ance area more than 30 minutes
before the
hearing starts. For informa-
tion about
having your name placed on the
building a
ccess list to attend the hearing,
see the FO
R FURTHER INFORMATION
CONTACT s
ection of this document.
LaNita Va
n Dyke,
Chief, Pu
blications and
Regulati
ons Branch,
Legal Pro
cessing Division,
Associa
te Chief Counsel
(Proced
ure and Administration).
(Filed by the Office of the Federal Register on April 19, 2011,
8:45 a.m., and published in the issue of the Federal Register
for Apri
l 20, 2011, 76 F.R. 22064)
May 16, 20117912011–20 I.R.B.

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.
2011–20 I.R.B.iMay 16, 2011

Numerical Finding List
1
Bulletin 2011–1 through 2011–20
Announcements:
2011-1, 2011-2 I.R.B.304
2011-2, 2011-3 I.R.B.324
2011-3, 2011-3 I.R.B.324
2011-4, 2011-4 I.R.B.424
2011-5, 2011-4 I.R.B.430
2011-6, 2011-4 I.R.B.433
2011-7, 2011-5 I.R.B.446
2011-8, 2011-5 I.R.B.446
2011-9, 2011-7 I.R.B.499
2011-10, 2011-7 I.R.B.499
2011-11, 2011-7 I.R.B.500
2011-12, 2011-9 I.R.B.532
2011-13, 2011-8 I.R.B.525
2011-14, 2011-9 I.R.B.532
2011-15, 2011-8 I.R.B.526
2011-16, 2011-7 I.R.B.500
2011-17, 2011-9 I.R.B.532
2011-18, 2011-12 I.R.B.567
2011-19, 2011-11 I.R.B.553
2011-20, 2011-10 I.R.B.542
2011-21, 2011-12 I.R.B.567
2011-22, 2011-16 I.R.B.672
2011-23, 2011-12 I.R.B.568
2011-24, 2011-12 I.R.B.569
2011-25, 2011-14 I.R.B.608
2011-26, 2011-14 I.R.B.608
2011-27, 2011-15 I.R.B.651
2011-28, 2011-18 I.R.B.748
2011-29, 2011-18 I.R.B.748
2011-30, 2011-20 I.R.B.791
Notices:
2011-1, 2011-2 I.R.B.259
2011-2, 2011-2 I.R.B.260
2011-3, 2011-2 I.R.B.263
2011-4, 2011-2 I.R.B.282
2011-5, 2011-3 I.R.B.314
2011-6, 2011-3 I.R.B.315
2011-7, 2011-5 I.R.B.437
2011-8, 2011-8 I.R.B.503
2011-9, 2011-6 I.R.B.459
2011-10, 2011-6 I.R.B.463
2011-11, 2011-7 I.R.B.497
2011-12, 2011-8 I.R.B.514
2011-13, 2011-9 I.R.B.529
2011-14, 2011-11 I.R.B.544
2011-15, 2011-10 I.R.B.539
2011-16, 2011-17 I.R.B.720
2011-17, 2011-10 I.R.B.540
2011-18, 2011-11 I.R.B.549
2011-19, 2011-11 I.R.B.550
Notices— Continued:
2011-20, 2011-16 I.R.B.652
2011-21, 2011-19 I.R.B.761
2011-22, 2011-12 I.R.B.557
2011-23, 2011-13 I.R.B.588
2011-24, 2011-14 I.R.B.603
2011-25, 2011-14 I.R.B.604
2011-26, 2011-17 I.R.B.720
2011-27, 2011-17 I.R.B.723
2011-28, 2011-16 I.R.B.656
2011-29, 2011-16 I.R.B.663
2011-30, 2011-17 I.R.B.724
2011-31, 2011-17 I.R.B.724
2011-32, 2011-18 I.R.B.737
2011-33, 2011-19 I.R.B.761
2011-34, 2011-19 I.R.B.765
2011-37, 2011-20 I.R.B.785
2011-38, 2011-20 I.R.B.785
2011-39, 2011-20 I.R.B.786
Proposed Regulations:
REG-140108-08, 2011-13 I.R.B.591
REG-149335-08, 2011-6 I.R.B.468
REG-146097-09, 2011-8 I.R.B.516
REG-153338-09, 2011-14 I.R.B.606
REG-154159-09, 2011-19 I.R.B.777
REG-124018-10, 2011-2 I.R.B.301
REG-131151-10, 2011-8 I.R.B.519
REG-131947-10, 2011-8 I.R.B.521
REG-132724-10, 2011-7 I.R.B.498
Revenue Procedures:
2011-1, 2011-1 I.R.B.1
2011-2, 2011-1 I.R.B.90
2011-3, 2011-1 I.R.B.111
2011-4, 2011-1 I.R.B.123
2011-5, 2011-1 I.R.B.167
2011-6, 2011-1 I.R.B.195
2011-7, 2011-1 I.R.B.233
2011-8, 2011-1 I.R.B.237
2011-9, 2011-2 I.R.B.283
2011-10, 2011-2 I.R.B.294
2011-11, 2011-4 I.R.B.329
2011-12, 2011-2 I.R.B.297
2011-13, 2011-3 I.R.B.318
2011-14, 2011-4 I.R.B.330
2011-15, 2011-3 I.R.B.322
2011-16, 2011-5 I.R.B.440
2011-17, 2011-5 I.R.B.441
2011-18, 2011-5 I.R.B.443
2011-19, 2011-6 I.R.B.465
2011-20, 2011-11 I.R.B.551
2011-21, 2011-12 I.R.B.560
2011-22, 2011-18 I.R.B.737
2011-23, 2011-15 I.R.B.626
2011-24, 2011-20 I.R.B.787
Revenue Procedures— Continued:
2011-25, 2011-17 I.R.B.725
2011-26, 2011-16 I.R.B.664
2011-27, 2011-18 I.R.B.740
2011-28, 2011-18 I.R.B.743
2011-29, 2011-18 I.R.B.746
Revenue Rulings:
2011-1, 2011-2 I.R.B.251
2011-2, 2011-2 I.R.B.256
2011-3, 2011-4 I.R.B.326
2011-4, 2011-6 I.R.B.448
2011-5, 2011-13 I.R.B.577
2011-6, 2011-10 I.R.B.537
2011-7, 2011-10 I.R.B.534
2011-8, 2011-12 I.R.B.554
2011-9, 2011-12 I.R.B.554
2011-10, 2011-14 I.R.B.597
2011-11, 2011-19 I.R.B.758
Treasury Decisions:
9507, 2011-3 I.R.B.305
9508, 2011-7 I.R.B.495
9509, 2011-6 I.R.B.450
9510, 2011-6 I.R.B.453
9511, 2011-6 I.R.B.455
9512, 2011-7 I.R.B.473
9513, 2011-8 I.R.B.501
9514, 2011-9 I.R.B.527
9515, 2011-14 I.R.B.599
9516, 2011-13 I.R.B.575
9517, 2011-15 I.R.B.610
9518, 2011-17 I.R.B.710
9519, 2011-18 I.R.B.734
9520, 2011-18 I.R.B.730
9521, 2011-19 I.R.B.750
9522, 2011-20 I.R.B.780
9523, 2011-20 I.R.B.781
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin
2010–52, dated December 27, 2010.
May 16, 2011ii2011–20 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2011–1 through 2011–20
Announcements:
85-88
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
2008-11
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2009-62
Obsoleted by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
Notices:
2006-87
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-25
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2007-77
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2008-107
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2009-23
Modified by
Notice 2011-24, 2011-14 I.R.B.603
2009-24
Modified by
Notice 2011-24, 2011-14 I.R.B.603
2009-83
Modified by
Notice 2011-25, 2011-14 I.R.B.604
2009-93
Modified by
Notice 2011-38, 2011-20 I.R.B.785
2010-27
Superseded by
Notice 2011-8, 2011-8 I.R.B.503
2010-32
Modified and superseded by
Notice 2011-37, 2011-20 I.R.B.785
2010-59
Modified by
Notice 2011-5, 2011-3 I.R.B.314
Notices— Continued:
2010-60
Supplemented and superseded by
Notice 2011-34, 2011-19 I.R.B.765
2010-71
Modified and superseded by
Notice 2011-9, 2011-6 I.R.B.459
2010-79
Clarified and modified by
Notice 2011-4, 2011-2 I.R.B.282
Proposed Regulations:
REG-132554-08
Corrected by
Ann. 2011-11, 2011-7 I.R.B.500
REG-149335-08
Hearing scheduled by
Ann. 2011-26, 2011-14 I.R.B.608
REG-146097-09
Hearing rescheduled by
Ann. 2011-30, 2011-20 I.R.B.791
Revenue Procedures:
72-50
Modified and superseded by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
76-34
Modified and supersed by
Rev. Proc. 2011-10, 2011-2 I.R.B.294
83-23
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
94-17
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
97-27
Clarified and modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2001-10
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2002-28
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2003-21
Modified and superseded by
Rev. Proc. 2011-15, 2011-3 I.R.B.322
2004-34
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
Modified and clarified by
Rev. Proc. 2011-18, 2011-5 I.R.B.443
Revenue Procedures— Continued:
2006-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2006-56
Modified by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2008-52
Modified by
Notice 2011-4, 2011-2 I.R.B.282
Rev. Proc. 2011-17, 2011-5 I.R.B.441
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2009-39
Superseded in part by
Rev. Proc. 2011-14, 2011-4 I.R.B.330
2009-44
Modified by
Ann. 2011-6, 2011-4 I.R.B.433
2010-1
Superseded by
Rev. Proc. 2011-1, 2011-1 I.R.B.1
2010-2
Superseded by
Rev. Proc. 2011-2, 2011-1 I.R.B.90
2010-3
Superseded by
Rev. Proc. 2011-3, 2011-1 I.R.B.111
2010-4
Superseded by
Rev. Proc. 2011-4, 2011-1 I.R.B.123
2010-5
Superseded by
Rev. Proc. 2011-5, 2011-1 I.R.B.167
2010-6
Superseded by
Rev. Proc. 2011-6, 2011-1 I.R.B.195
2010-7
Superseded by
Rev. Proc. 2011-7, 2011-1 I.R.B.233
2010-8
Superseded by
Rev. Proc. 2011-8, 2011-1 I.R.B.237
2010-9
Superseded by
Rev. Proc. 2011-9, 2011-2 I.R.B.283
2010-15
Updated by
Rev. Proc. 2011-13, 2011-3 I.R.B.318
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin 2010–52, dated December 27,
2010.
2011–20 I.R.B.iiiMay 16, 2011

Revenue Procedures— Continued:
2010-18
Amplified and modified by
Rev. Proc. 2011-21, 2011-12 I.R.B.560
2010-25
Obsoleted in part by
Rev. Proc. 2011-23, 2011-15 I.R.B.626
2011-1
Corrected by
Ann. 2011-7, 2011-5 I.R.B.446
2011-8
Corrected by
Ann. 2011-8, 2011-5 I.R.B.446
2011-11
Corrected by
Ann. 2011-9, 2011-7 I.R.B.499
2011-14
Modified by
Rev. Proc. 2011-27, 2011-18 I.R.B.740
Rev. Proc. 2011-28, 2011-18 I.R.B.743
Modified and amplified by
Rev. Proc. 2011-22, 2011-18 I.R.B.737
2011-21
Amplified by
Rev. Proc. 2011-26, 2011-16 I.R.B.664
Revenue Rulings:
81-100
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2004-67
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2008-40
Modified by
Rev. Rul. 2011-1, 2011-2 I.R.B.251
2011-3
Corrected by
Ann. 2011-16, 2011-7 I.R.B.500
Treasury Decisions:
9391
Corrected by
Ann. 2011-12, 2011-9 I.R.B.532
9505
Corrected by
Ann. 2011-10, 2011-7 I.R.B.499
May 16, 2011iv2011–20 I.R.B.

2011–20 I.R.B.May 16, 2011

May 16, 20112011–20 I.R.B.

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