us-irs-revenue-rulings-irb-2011-13-pdf•Internal Revenue Bulletin 2011-13 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2011-13 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2011-13-pdfInternal Revenue Bulletin 2011-13 (PDF rendition): IRS Revenue RulingsGuidance
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Bulletin No. 201 1-13 March 28, 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 Rev. Rul. 2011–5, page 577. Interest rates; underpayments and overpayments.The rates for interest determined under section 6621 of the Code for the calendar quarter beginning April 1, 2011, will be 4 per- cent for overpayments (3 percent in the case of a corporation), 4 percent for underpayments, and 6 percent for large corpo- rate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 1.5 per- cent. EXEMPT ORGANIZATIONS REG–140108–08, page 591. Proposed regulations under section 6104(c) of the Code amend existing regulations to reflect changes made by the Pension Protection Act of 2006 (PPA) by providing guidance to states regarding the process by which they may obtain or inspect certain returns and return information (including information about final and proposed denials and revocations of tax-exempt status) for the purpose of administering state laws governing certain tax-exempt organizations and their activities. Notice 2011–23, page 588. This notice addresses the requirements for tax exemption for qualified nonprofit health insurance issuers described in sec- tion 501(c)(29) of the Code by providing guidance on the an- nual filing requirement for organizations that intend to apply for recognition of exempt status as well as on the effective date of exempt status for certain applicants. The notice also includes a request for public comments. ADMINISTRATIVE T.D. 9516, page 575. Final regulations under section 6103 of the Code describe the circumstances by which officers and employees of the Treasury Department may disclose return information to whistleblowers and, if applicable, their legal representatives in connection with written contracts for services relating to the detection of vio- lations of the internal revenue laws or related statutes by the IRS. Fi nding Lists begin on page ii. Index for January through March begins on page v. 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. March 28, 20112011–13 I.R.B. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 6103. —Confi- dentiality an dDisclosure of Returns and Return Information 26 CFR 301.6103(n)–2: Disclosure of return infor- mation in connection with written contracts among the IRS, whistleblowers, and legal representatives of whistleblowers. T.D. 9516 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 301 Disclosure of Return InformationinConnection with Written Contracts Among the IRS, Whistleblowers, and Legal Representatives of Whistleblowers AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations and removal of temporary regulations. SUMMARY: This document contains final regulati ons relating to the disclosure of re- turn inf ormation by an officer or employee of the Tr easury Department, to a whistle- blower a nd, if applicable, the legal repre- sentati ve of the whistleblower, to the ex- tent nec essary in connection with a writ- ten con tract among the IRS, the whistle- blower and, if applicable, the legal rep- resent ative of the whistleblower, for ser- vices r elating to the detection of viola- tions o f the internal revenue laws or re- lated s tatutes. The final regulations will affec t officers and employees of the Trea- sury D epartment who disclose return in- forma tion to whistleblowers or their legal repre sentatives in connection with written contr acts among the IRS, whistleblowers and, if applicable, their legal representa- tive s, for services relating to the detection of vi olations of the internal revenue laws or re lated statutes. The final regulations will also affect any whistleblower or le- gal r epresentative of a whistleblower who receives retu rn information in connection with a written contract among the IRS, the whistleblowe r and, if applicable, the le- gal represen tative of the whistleblower, for services rel ating to the detection of viola- tions of the i nternal revenue laws or related statutes. DATES:Effe ctive Date:These final regu- lations are effective on March 15, 2011. Applicabil ity Date:For dates of appli- cability, s ee §301.6103(n)–2(f). FOR FURTHE R INFORMATION CONTACT: H elene R. Newsome, 202–622–7 950 (not a toll-free number). SUPPLEMEN TARY INFORMATION: Backgrou nd This docu ment contains final regula- tions imp lementing amendments to the Procedu re and Administration Regula- tions (2 6 CFR part 301) under section 6103(n) relating to the disclosure of return informa tion in connection with written contra cts among the IRS, whistleblowers and, if applicable, their legal representa- tives. The Tax Relief and Health Care Act of 2006 , Public Law 109–432 (120 Stat. 2958), (the Act) was enacted on Decem- ber 20, 2006. Section 406 of the Act amend s section 7623, concerning the pay- ment o f awards to whistleblowers, and es- tabli shes a Whistleblower Office within the IR S that has responsibility for the ad- minis tration of a whistleblower program. In co nnection with analyzing information prov ided by a whistleblower, or investigat- ing a matter, the IRS may determine that it re quires the assistance of the whistle- blow er, or the legal representative of the whis tleblower. The Joint Committee on Tax ation (the JCT) has noted that “[t]o the ext ent the disclosure of returns or return inf ormation is required [for the whistle- blo wer or his or her legal representative] to r ender such assistance, the disclosure mu st be pursuant to an IRS tax adminis- tr ation contract.” Joint Committee on Tax- at ion,Technical Explanation of H.R. 6408, Th e “Tax Relief and Health Care Act of 2006,”as Intr oduced in the House on De- cember 7, 2006 , at 89 (JCX–50–06), De- cember 7, 2006 . The JCT has further noted that “[i]t is expected that such disclosures will be infre quent and will be made only when the assi gned task cannot be properly or timely com pleted without the return in- formation t o be disclosed.”Id. Under sectio n 6103(a), returns and re- turn inform ation are confidential unless the Interna l Revenue Code authorizes dis- closure. Se ction 6103(n) is the authority by which ret urns and return information may be disc losedpursuanttoataxad- ministrat ion contract. Section 6103(n) authorize s, pursuant to regulations pre- scribed by the Secretary, returns and return informati on to be disclosed to any per- son, for p urposes of tax administration, to the exten t necessary in connection with: (1) the pr ocessing, storage, transmission, and repro duction of returns and return informat ion; (2) the programming, main- tenance , repair, testing, and procurement of equip ment; and (3) the providing of other se rvices. On March 25, 2008, temporary reg- ulation s (T.D. 9389, 2008–1 C.B. 863) under se ction 6103(n) were published in theFed eral Register(73 FR 15668) de- scribi ng the circumstances under which office rs and employees of the Treasury Depart ment may disclose return informa- tion to whistleblowers and, if applicable, their legal representatives, in connec- tion w ith written contracts for services relat ingtothedetectionofviolations of the internal revenue laws or related statu tes. A notice of proposed rulemak- ing ( REG–114942–07, 2008–1 C.B. 901) cros s-referencing the temporary regula- tion s was published in theFederal Regis- terf or the same day (73 FR 15687). One w ritten comment responding to the n otice of proposed rulemaking was rece ived. No public hearing was requested or he ld. After consideration of the com- men t, the regulations are adopted as pro- pos ed with only minor technical changes mad e. The limitations applicable to section 610 3(n) contracts as outlined in these reg- ula tions are not a limitation on the use of ret urn information that may be disclosed 2011–13 I.R.B.575March 28, 2011 to a whistleblower or the legal represen- tative of a whistleblower during an award determination administrative proceeding andinanawarddeterminationappealto the U.S. Tax Court. Summary of Comment The commentator recommended that §301.6103(n)–2(b)(3) of the proposed regulations be revised to eliminate any requirement that a written contract be in place for a whistleblower to be provided with basic status information about the whistleblower’s claim for award under section 7623. The commentator drew a comparison with whistleblower claims under the False Claims Act and argued that the standard for the IRS to share status information with a whistleblower should not be the same as that required to share information from the actual returns of tax- payers. Unlike other statutory schemes, however, information regarding the sta- tus of a whistleblower’s claim with the IRS is “return information” as defined in section 6103(b)(2). Like returns (defined in section 6103(b)(1)), return information is confidential under section 6103(a) and may only be disclosed if authorized by a specific provision of the Code. In order to disclose status information to a whistle- blower, an exception to section 6103 must be applicable. Section 6103(n) provides authority for the IRS to make status in- formation disclosures to a whistleblower. Because disclosures pursuant to section 6103(n) require a written tax administra- tion contract, the final regulations do not adopt the commentator’s recommenda- tion. The commentator also recommended that §301.6103(n)–2(d)(3) of the proposed regulations be revised to eliminate the inspection requirement. The commentator asserted that, by contrast, §301.6103(n)–1, “Disclosure of returnsand return informa- tion in connection with written contracts or agreements for the acquisition of prop- erty or services for tax administration purposes,” does not include such a re- quirement and argued that the requirement is unnecessary in that the regulations al- ready provide for severe sanctions for any failure to comply with the terms of written contracts for services. In fact, §301.6103(n)–1(e)(1) does indeed contain an inspection requirement. The final regu- lations retain the inspection requirement as consistent with the longstanding safeguard procedures that incorporate inspection as an integral part of the contracting process under section 6103(n). Special Analyses It has been determined that this Trea- sury decision is not a significant regula- tory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not required. It also has been deter- mined that section 553(b) of the Admin- istrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because the regulations do not impose a collection of information on small entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to sec- tion 7805(f) of the Code, the proposed reg- ulations preceding these regulations were submitted to the Chief Counsel for Advo- cacy of the Small Business Administration for comment on their impact on small busi- ness. Drafting Information The principal author of these regula- tions is Helene R. Newsome, Office of the Associate Chief Counsel (Procedure & Administration). ***** Adoption of Amendments to the Regulations Accordingly, 26 CFR part 301 is amended as follows: PART 301—PROCEDURE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 is amended by adding an entry in numerical order to read as follows: Authority: 26 U.S.C. 7805 * * * Section 301.6103(n)–2 also issued un- der 26 U.S.C. 6103(n). * * * Section 301.6103(n)–2 also issued un- der 26 U.S.C. 6103(q). * * * Par. 2. Section 301.6103(n)–2 is added to read as follows: §301.6103(n)–2 Disclosure of return information in connection with written contracts among the IRS, whistleblowers, and legal representatives of whistleblowers. (a)General rule. (1) Pursuant to the provisions of sections 6103(n) and 7623 of the Internal Revenue Code and subject to the conditions of this section, an offi- cer or employee of the Treasury Depart- ment is authorized to disclose return infor- mation (as defined in section 6103(b)(2)) to a whistleblower and, if applicable, the legal representative of the whistleblower, to the extent necessary in connection with a written contract among the Internal Rev- enue Service (IRS), the whistleblower and, if applicable, the legal representative of the whistleblower, for services relating to the detection of violations of the internal rev- enue laws or related statutes. (2) The IRS shall have the discretion to determine whether to enter into a writ- ten contract pursuant to section 7623 with the whistleblower and, if applicable, the legal representative of the whistleblower, for services described in paragraph (a)(1) of this section. (b)Limitations. (1) Disclosure of re- turn information in connection with a writ- ten contract for services described in para- graph (a)(1) of this section shall be made only to the extent the IRS deems it neces- sary in connection with the reasonable or proper performance of the contract. Dis- closures may include, but are not limited to, disclosures to accomplish properly any purpose or activity ofthe nature described in section 6103(k)(6) and the regulations thereunder. (2) If the IRS determines that the ser- vices of a whistleblower and, if applica- ble, the legal representative of the whistle- blower, as described in paragraph (a)(1) of this section, can be performed reasonably or properly by disclosure of only parts or portions of return information, then only the parts or portions of the return informa- tion shall be disclosed. (3) Upon written request by a whistle- blower, or a legal representative of a whistleblower, with whom the IRS has entered into a written contract for ser- vices as described in paragraph (a)(1) of this section, the Director of the Whistle- blower Office, or designee of the Director, may inform the whistleblower and, if ap- March 28, 20115762011–13 I.R.B. plicable, the legal representative of the whistleblower, of the status of the whistle- blower’s claim for award under section 7623, including whether the claim is be- ing evaluated for potential investigative action, or is pending due to an ongoing examination, appeal, collection action, or litigation. The information may be disclosed only if the IRS determines that the disclosure would not seriously impair Federal tax administration. (4) Return information disclosed to a whistleblower and, if applicable, a legal representative of a whistleblower, under this section, shall not be further disclosed or otherwise used by the whistleblower or a legal representative of a whistleblower, except as expressly authorized in writing by the IRS. (c)Penalties. Any whistleblower, or le- gal representative of a whistleblower, who receives return information under this sec- tion, is subject to the civil and criminal penalty provisions of sections 7431, 7213, and 7213A for the unauthorized inspection or disclosure of the return information. (d)Safeguards. (1) Any whistleblower, or the legal representative of a whistle- blower, who receives return information under this section, shall comply with all applicable conditions and requirements as the IRS may prescribe from time to time for the purposes of protecting the confi- dentiality of the return information and preventing any disclosure or inspection of the return information in a manner not authorized by this section (prescribed re- quirements). (2) Any written contract for services as described in paragraph (a)(1) of this sec- tion shall provide that any whistleblower and, if applicable, the legal representative of a whistleblower, who has access to re- turn information under this section, shall comply with the prescribed requirements. (3) Any whistleblower, or the legal representative of a whistleblower, who may receive return information under this section, shall agree in writing, be- fore any disclosure of return information is made, to permit an inspection of the whistleblower’s or the legal representa- tive’s premises by the IRS relative to the maintenance of the return information dis- closed under these regulations and, upon completion of services as described in the written contract with the IRS, to dispose of all return information by returning the return information, including any and all copies or notes made, to the IRS, or to the extent that it cannot be returned, by destroying the information in a manner consistent with prescribed requirements. (4) If the IRS determines that any whistleblower, or the legal representa- tive of a whistleblower, who has access to return information under this section, has failed to, or does not, satisfy the pre- scribed requirements, the IRS, using the procedures described in the regulations under section 6103(p)(7), may take any action it deems necessary to ensure that the prescribed requirements are or will be satisfied, including— (i) Suspension of further disclosures of return information by the IRS to the whistleblower and, if applicable, the legal representative of the whistleblower, until the IRS determines that the conditions and requirements have been or will be satis- fied; and (ii) Suspension or termination of any duty or obligation arising under the con- tract with the IRS. (e)Definitions. For purposes of this section— (1) The termTreasury Departmentin- cludes the IRS and the Office of the Chief Counsel for the IRS. (2) The termwhistleblowermeans an individual who provides information to the IRS regarding violations of the tax laws or related statutes and submits a claim for an award under section 7623 with respect to the information. (3) The termlegal representativemeans any individual who is a member in good standing in the bar of the highest court of any state, possession, territory, common- wealth, or the District of Columbia, and who has a written power of attorney exe- cutedbythewhistleblower. (f)Effective/applicability date.This section is applicable on March 15, 2011. Par. 3. Section 301.6103(n)–2T is re- moved. §301.6103(n)–2T [Removed]. Steven T. Miller, Deputy Commissioner for Services and Enforcement. Approved March 9, 2011. Michael F. Mundaca, Assistant Secretary of the Treasury for Tax Policy. (Filed by the Office of the Federal Register on March 14, 2011, 8:45 a.m., and published in the issue of the Federal Register for March 15, 2011, 76 F.R. 13880) Section 6621.—Determina- tion of Rate of Interest 26 CFR 301.6621–1: Interest rate. Interest rates; underpayments and overpayments.The rates for interest de- termined under section 6621 of the Code for the calendar quarter beginning April 1, 2011, will be 4 percent for overpayments (3 percent in the case of a corporation), 4 percent for underpayments, and 6 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 1.5 percent. Rev. Rul. 2011–5 Section 6621 of the Internal Revenue Code establishes the rates for interest on tax overpayments and tax underpay- ments. Under section 6621(a)(1), the overpayment rate is the sum of the federal short-term rate plus 3 percentage points (2 percentage points in the case of a cor- poration), except the rate for the portion of a corporate overpayment of tax exceed- ing $10,000 for a taxable period is the sum of the federal short-term rate plus 0.5 of a percentage point. Under section 6621(a)(2), the underpayment rate is the sum of the federal short-term rate plus 3 percentage points. Section 6621(c) provides that for pur- poses of interest payable under section 6601 on any large corporate underpay- ment, the underpayment rate under section 6621(a)(2) is determined by substituting “5 percentage points” for “3 percentage points.” See section 6621(c) and section 301.6621–3 of the Regulations on Proce- dure and Administration for the definition of a large corporate underpayment and for the rules for determining the appli- cable date. Section 6621(c) and section 301.6621–3 are generally effective for periods after December 31, 1990. Section 6621(b)(1) provides that the Secretary will determine the federal 2011–13 I.R.B.577March 28, 2011 short-term rate for the first month in each calendar quarter. Section 6621(b)(2)(A) provides that the federal short-term rate determined under section 6621(b)(1) for any month applies during the first calen- dar quarter beginning after that month. Section 6621(b)(2)(B) provides that in de- termining the addition to tax under section 6654 for failure to pay estimated tax for any taxable year, the federal short-term rate that applies during the third month following the taxable year also applies during the first 15 days of the fourth month following the taxable year. Sec- tion 6621(b)(3) provides that the federal short-term rate for any month is the fed- eral short-term rate determined during that month by the Secretary in accordance with section 1274(d), rounded to the nearest full percent (or, if a multiple of 1/2 of 1 percent, the rate is increased to the next highest full percent). Notice 88–59, 1988–1 C.B. 546, an- nounced that, in determining the quarterly interest rates to be used for overpayments and underpayments of tax under section 6621, the Internal Revenue Service will use the federal short-term rate based on daily compounding because that rate is most consistent with section 6621 which, pursuant to section 6622, is subject to daily compounding. The federal short-term rate determined in accordance with section 1274(d) during January 2011 is the rate published in Rev- enue Ruling 2011–4, 2011–6 I.R.B. 448 to take effect beginning February 1, 2011. The federal short-term rate, rounded to the nearest full percent, based on daily com- pounding determined during the month of January 2011 is 1 percent. Accordingly, an overpayment rate of 4 percent (3 percent in the case of a corporation) and an under- payment rate of 4 percent are established for the calendar quarter beginning April 1, 2011. The overpayment rate for the por- tion of a corporate overpayment exceeding $10,000 for the calendar quarter beginning April 1, 2011, is 1.5 percent. The under- payment rate for large corporate underpay- ments for the calendar quarter beginning April 1, 2011, is 6 percent. These rates ap- ply to amounts bearing interest during that calendar quarter. Under section 6621(b)(2)(B), the 4 per- cent rate also applies to estimated tax un- derpayments for the first calendar quarter in 2011 and for the first 15 days in April 2011. Interest factors for daily compound in- terest for annual rates of 1.5 percent, 3 per- cent, 4 percent and 6 percent are published in Tables 8, 11, 13, and 17 of Rev. Proc. 95–17, 1995–1 C.B. 556, 562, 567, and 571. Interest factors for daily compound interest for an annual rate of 0.5 percent are published in Appendix A of Revenue Rul- ing 2010–31, 2010–52 I.R.B. 898, 899. Annual interest rates to be compounded daily pursuant to section 6622 that apply for prior periods are set forth in the tables accompanying this revenue ruling. DRAFTING INFORMATION The principal author of this revenue rul- ing is Deborah Colbert-James of the Office of Associate Chief Counsel (Procedure & Administration). For further information regarding this revenue ruling, contact Ms. Colbert-James at (202) 622–8143 (not a toll-free call). March 28, 20115782011–13 I.R.B. APPENDIX A 365 Day Year 0.5% Compound Ra te 184 Days DaysFactorDaysFactorDaysFactor 10.000013699630.000863380 125 0.001713784 20.000027397640.000877091126 0.001727506 30.000041096 65 0.0008908011270.001741228 4 0.000054796 66 0.000904512 128 0.001754951 50.000068495 670.0009182231290.001768673 6 0.000082195 680.0009319341300.001782396 7 0.000095894 69 0.000945646 1310.001796119 8 0.000109594 70 0.000959357 1320.001809843 90.000123294710.000973069133 0.001823566 10 0.000136995 720.0009867811340.001837290 11 0.000150695 730.001000493 1350.001851013 120.000164396740.0010142061360.001864737 130.00017809 7 75 0.00102791 8 1370.00187846 2 140.000191798760.0010416311380.001892186 150.0002054 99 77 0.0010553 44 139 0.0019059 10 160.0002192 01 78 0.001069057 140 0.001919635 170.000232902790.0010827701410.001933360 180.000246604800.001096484142 0.001947 085 190.000260 306 810.001110 197 1430.001960 811 200.000274008820.001123911144 0.001974536 210.00028771183 0.001137 625 145 0.001988262 220.000301 413 84 0.001151339 1460.002001 988 23 0.000315116850.001165054 147 0.002015714 240.000328819860.0011787681480.002029440 250.000342522 870.00119 2483 1490.00204 3166 26 0.000356225 880.001206198 1500.002056893 270.000369929890.001219913 151 0.002070620 280.0003 83633 900.0012 33629 152 0.0020 84347 290.000397336910.001247344 153 0.002098074 300.000411041920.001261060 154 0.002111801 31 0.000424745 930.001 274776 1550.002125529 320.000438449940.001288492 1560.002139257 33 0.00 0452154 95 0.001302208 1570.00 2152985 34 0.000465859 96 0.001315925158 0.00 2166713 350.000479564 970.001329641 159 0.002180441 360.00049326998 0.0 01343358 1600.002194169 37 0.000506974 99 0.001357075 1610.0 02207898 38 0.000520680 1000.0013707921620.002221627 39 0.0 00534386 101 0.0 01384510 163 0.0 02235356 40 0.000548092 10 2 0. 001398227 16 4 0.002249085 41 0.000561798 103 0.0014119451650.002262815 42 0. 000575504 104 0. 001425663 166 0. 002276544 43 0.000589211105 0. 001439381 16 7 0. 002290274 440.000602917106 0.001453100 1680.002304004 4 5 0.0006166241070.0014668181690.002317734 4 6 0 .000630331 1 08 0.001480537 1 70 0.002331465 470.000644039109 0.001494256 171 0.002345195 48 0.000657746 110 0.001507975 172 0.002358926 49 0.000671454 111 0.001521694 173 0.002372657 500.000685161 112 0.001535414 1740.002386388 51 0.000698869113 0.001549133175 0.002400120 520.000712578 114 0.001562853 176 0.002413851 53 0.000726286 1150.001576573 177 0.002427583 540.000739995 116 0.001590293 178 0.002441315 550.000753703 1170.001604014179 0.002455047 56 0.0007674121180.0016177341800.002468779 2011–13 I.R.B.579March 28, 2011 365 Day Year 0.5% Compound Rate 184 Days DaysFactorDaysFactorDaysFactor 57 0.000781121119 0.001631455 181 0.002482511 58 0.000794831120 0.001645176 1820.002496244 590.000808540 121 0.001658897 183 0.002509977 60 0.000822250 1220.001672619184 0.002523710 61 0.000835960 1230.001686340 620.0008496701240.001700062 366 Day Year 0.5% Compound Rate 184 Days DaysFactorDaysFactorDaysFactor 10.000013661630.000861020 125 0.001709097 20.000027323640.0008746931260.001722782 30.000040984 65 0.0008883661270.001736467 4 0.000054646 660.000902040128 0.001750152 5 0.00006830867 0.000915713 1290.001763837 60.000081970680.000929387130 0.001777522 7 0.000095632 690.0009430611310.001791208 8 0.000109295 70 0.000956735 1320.001804893 9 0.000122958 710.000970409133 0.001818579 100.000136620720.000984084134 0.001832265 11 0.000150283 73 0.0009977581350.001845951 120.000163947740.001011433136 0.001859638 130.000177610 750.001025108 1370.001873324 140.000191274760.0010387831380.001887011 15 0.00020493877 0.001052459 1390.001900698 160.000218602780.001066134140 0.001914385 170.000232266790.0010798101410.001928073 18 0.000245930 800.0010934861420.001941760 19 0.000259595 810.001107162143 0.001955448 200.000273260820.0011208391440.001969136 210.00028692483 0.001134515145 0.001982824 22 0.000300590 840.001148192146 0.001996512 23 0.00031425585 0.0011618691470.002010201 240.00032792086 0.001175546 1480.002023889 250.000341586 870.001189223149 0.002037578 26 0.000355252 880.001202900 1500.002051267 270.00036891889 0.0012165781510.002064957 28 0.000382584 90 0.001230256152 0.002078646 29 0.000396251 910.001243934 153 0.002092336 300.00040991792 0.0012576121540.002106025 31 0.000423584 930.001271291 1550.002119715 32 0.000437251 940.001284969 1560.002133405 33 0.00045091895 0.001298648 157 0.002147096 34 0.000464586 960.001312327 158 0.002160786 350.000478253 970.001326006 159 0.002174477 360.00049192198 0.001339685 1600.002188168 37 0.000505589 99 0.001353365 161 0.002201859 38 0.000519257 1000.001367044162 0.002215550 39 0.000532925 1010.0013807241630.002229242 40 0.000546594 1020.0013944041640.002242933 41 0.000560262 103 0.0014080851650.002256625 42 0.000573931 104 0.001421765 1660.002270317 43 0.0005876001050.001435446 1670.002284010 440.0006012691060.0014491271680.002297702 45 0.0006149391070.001462808169 0.002311395 March 28, 20115802011–13 I.R.B. 366 Day Year 0.5% Compound Rate 184 Days DaysFactorDaysFactorDaysFactor 460.0006286081080.001476489170 0.002325087 470.0006422781090.0014901701710.002338780 48 0.000655948 110 0.001503852 172 0.002352473 490.000669618111 0.001517533 1730.002366167 50 0.000683289112 0.001531215 1740.002379860 510.000696959 113 0.0015448971750.002393554 52 0.000710630114 0.001558580 1760.002407248 53 0.000724301 1150.001572262 1770.002420942 54 0.000737972116 0.001585945 1780.002434636 550.000751643 117 0.001599628 1790.002448331 560.000765315 1180.001613311180 0.002462025 57 0.0007789861190.001626994181 0.002475720 580.000792658 1200.001640678182 0.002489415 59 0.000806330121 0.001654361 183 0.002503110 600.000820003122 0.001668045 184 0.002516806 61 0.000833675 1230.001681729 620.000847348124 0.001695413 TABLE OF INTEREST RATES PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986 OVERPAYMENTS AND UNDERPAYMENTS PERIODRATE In 1995–1 C.B. DAILY RATE TABLE Before Jul. 1, 1975 6% Table 2, pg. 557 Jul. 1, 1975—Jan. 31, 1976 9% Table 4, pg. 559 Feb. 1, 1976—Jan. 31, 19787% Table 3, pg. 558 Feb. 1, 1978—Jan. 31, 19806% Table 2, pg. 557 Feb. 1, 1980—Jan. 31, 198212% Table 5, pg. 560 Feb. 1, 1982—Dec. 31, 198220% Table 6, pg. 560 Jan. 1, 1983—Jun. 30, 198316% Table 37, pg. 591 Jul. 1, 1983—Dec. 31, 198311% Table 27, pg. 581 Jan. 1, 1984—Jun. 30, 198411% Table 75, pg. 629 Jul. 1, 1984—Dec. 31, 198411% Table 75, pg. 629 Jan. 1, 1985—Jun. 30, 1985 13% Table 31, pg. 585 Jul. 1, 1985—Dec. 31, 1985 11% Table 27, pg. 581 Jan. 1, 1986—Jun. 30, 198610% Table 25, pg. 579 Jul. 1, 1986—Dec. 31, 19869% Table 23, pg. 577 TABLE OF INTEREST RATES FROM JAN. 1, 1987 — DEC. 31, 1998 OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLEPGRATE TABLEPG Jan. 1, 1987—Mar. 31, 19878%21 575 9%23 577 Apr. 1, 1987—Jun. 30, 19878%21 575 9%23 577 Jul. 1, 1987—Sep. 30, 19878%21 575 9%23 577 Oct. 1, 1987—Dec. 31, 19879%23 577 10% 25579 Jan. 1, 1988—Mar. 31, 198810%7362711% 75 629 Apr. 1, 1988—Jun. 30, 19889%71 625 10%73627 Jul. 1, 1988—Sep. 30, 19889%71 625 10%73627 Oct. 1, 1988—Dec. 31, 198810%7362711% 75 629 2011–13 I.R.B.581March 28, 2011 TABLE OF INTEREST RATES FROM JAN. 1, 1987 — DEC. 31, 1998 – Continued OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLEPGRATE TABLEPG Jan. 1, 1989—Mar. 31, 198910% 25579 11%27 581 Apr. 1, 1989—Jun. 30, 198911%27 581 12%29 583 Jul. 1, 1989—Se p. 30, 1989 11%27 581 12%29 583 Oct. 1, 1989—Dec. 31, 198910% 25579 11%27 581 Jan. 1, 1990—Mar. 31, 199010% 25579 11%27 581 Apr. 1, 1990—J un. 30, 1990 10% 25579 11%27 581 Jul. 1, 1990—Sep. 30, 199010% 25579 11%27 581 Oct. 1, 1990—Dec. 31, 199010% 25579 11%27 581 Jan. 1, 1991— Mar. 31, 1991 10% 25579 11%27 581 Apr. 1, 1991—Jun. 30, 19919%23 577 10% 25579 Jul. 1, 1991—Sep. 30, 19919%23 577 10% 25579 Oct. 1, 1991 —Dec. 31, 1991 9%23 577 10% 25579 Jan. 1, 1992—Mar. 31, 19928%696239%71 625 Apr. 1, 1992—Jun. 30, 19927%676218%69623 Jul. 1, 1992 —Sep. 30, 1992 7%676218%69623 Oct. 1, 1992—Dec. 31, 19926% 65 6197%67621 Jan. 1, 1993—Mar. 31, 19936%17 571 7%19 573 Apr. 1, 19 93—Jun. 30, 1993 6%17 571 7%19 573 Jul. 1, 1993—Sep. 30, 19936%17 571 7%19 573 Oct. 1, 1993—Dec. 31, 19936%17 571 7%19 573 Jan. 1, 19 94—Mar. 31, 1994 6%17 571 7%19 573 Apr. 1, 1994—Jun. 30, 19946%17 571 7%19 573 Jul. 1, 1994—Sep. 30, 19947%19 573 8%21 575 Oct. 1, 1 994—Dec. 31, 1994 8%21 575 9%23 577 Jan. 1, 1995—Mar. 31, 1995 8%21 575 9%23 577 Apr. 1, 1995—Jun. 30, 1995 9%23 577 10% 25579 Jul. 1, 1995—Sep. 30, 1995 8%21 575 9%23 577 Oct. 1, 1995—Dec. 31, 1995 8%21 575 9%23 577 Jan. 1, 1996—Mar. 31, 19968%696239%71 625 Apr. 1 , 1996—Jun. 30, 1996 7%676218%69623 Jul. 1, 1996—Sep. 30, 19968%696239%71 625 Oct. 1, 1996—Dec. 31, 19968%696239%71 625 Jan. 1, 1997—Mar. 31, 1997 8%21 575 9%23 577 Apr. 1, 1997—Jun. 30, 19978%21 575 9%23 577 Jul. 1, 1997—Sep. 30, 19978%21 575 9%23 577 Oct . 1, 1997—Dec. 31, 1997 8%21 575 9%23 577 Jan. 1, 1998—Mar. 31, 19988%21 575 9%23 577 Apr. 1, 1998—Jun. 30, 19987%19 573 8%21 575 Jul . 1, 1998—Sep. 30, 1998 7%19 573 8%21 575 Oct. 1, 1998—Dec. 31, 19987%19 573 8%21 575 TABLE OF INTEREST RATES FROM JANUARY 1, 1999 — PRESENT NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS 1995–1 C.B. RATETABLEPG Jan. 1, 1999—Mar. 31, 19997%19 573 Apr . 1, 1999—Jun. 30, 1999 8%21 575 Jul. 1, 1999—Sep. 30, 19998%21 575 Oct. 1, 1999—Dec. 31, 19998%21 57 5 Ja n. 1, 2000—Mar. 31, 2000 8%6962 3 Apr. 1, 2000—Jun. 30, 20009%71 625 March 28, 20115822011–13 I.R.B. TABLE OF INTEREST RATES FROM JANUARY 1, 1999 — PRESENT – Continued NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS 1995–1 C.B. RATETABLEPG Jul. 1, 2000—Sep. 30, 20009%71 625 Oct. 1, 2000—Dec. 31, 20009%71 625 Jan. 1, 2001—Mar. 31, 20019%23 577 Apr. 1, 2001—Jun. 30, 20018%21 575 Jul. 1, 2001—Sep. 30, 20017%19 573 Oct. 1, 2001—Dec. 31, 20017%19 573 Jan. 1, 2002—Mar. 31, 20026%17 571 Apr. 1, 2002—Jun. 30, 20026%17 571 Jul. 1, 2002—Sep. 30, 20026%17 571 Oct. 1, 2002—Dec. 31, 20026%17 571 Jan. 1, 2003—Mar. 31, 2003 5%15569 Apr. 1, 2003—Jun. 30, 2003 5%15569 Jul. 1, 2003—Sep. 30, 2003 5%15569 Oct. 1, 2003—Dec. 31, 20034%13 567 Jan. 1, 2004—Mar. 31, 20044%61 615 Apr. 1, 2004—Jun. 30, 2004 5% 63617 Jul. 1, 2004—Sep. 30, 20044%61 615 Oct. 1, 2004—Dec. 31, 2004 5% 63617 Jan. 1, 2005—Mar. 31, 20055%15569 Apr. 1, 2005—Jun. 30, 2005 6%17 571 Jul. 1, 2005—Sep. 30, 2005 6%17 571 Oct. 1, 2005—Dec. 31, 2005 7%19 573 Jan. 1, 2006—Mar. 31, 20067%19 573 Apr. 1, 2006—Jun. 30, 20067%19 573 Jul. 1, 2006—Sep. 30, 20068%21 575 Oct. 1, 2006—Dec. 31, 20068%21 575 Jan. 1, 2007—Mar. 31, 20078%21 575 Apr. 1, 2007—Jun. 30, 20078%21 575 Jul. 1, 2007—Sep. 30, 20078%21 575 Oct. 1, 2007—Dec. 31, 20078%21 575 Jan. 1, 2008—Mar. 31, 20087%67621 Apr. 1, 2008—Jun. 30, 20086% 65 619 Jul. 1, 2008—Sep. 30, 2008 5% 63617 Oct. 1, 2008—Dec. 31, 20086% 65 619 Jan. 1, 2009—Mar. 31, 2009 5%15569 Apr. 1, 2009—Jun. 30, 20094%13 567 Jul. 1, 2009—Sep. 30, 20094%13 567 Oct. 1, 2009—Dec. 31, 20094%13 567 Jan. 1, 2010—Mar. 31, 20104%13 567 Apr. 1, 2010—Jun. 30, 20104%13 567 Jul. 1, 2010—Sep. 30, 20104%13 567 Oct. 1, 2010—Dec. 31, 20104%13 567 Jan. 1, 2011—Mar. 31, 20113%11 565 Apr. 1, 2011—June 30, 20114%13 567 2011–13 I.R.B.583March 28, 2011 TABLE OF INTEREST RATES FROM JANUARY 1, 1999 — PRESENT CORPORATE OVERPAYMENTS AND UNDERPAYMENTS OVERPAYMENTSUNDERPAYMENTS 1995–1 C.B.1995–1 C.B. RATE TABLEPGRATE TABLEPG Jan. 1, 1999—Mar. 31, 19996%17 571 7%19 573 Apr. 1, 1999—Jun . 30, 1999 7%19 573 8%21 575 Jul. 1, 1999—Sep. 30, 19997%19 573 8%21 575 Oct. 1, 1999—Dec. 31, 19997%19 573 8%21 575 Jan. 1, 2000—Ma r. 31, 2000 7%676218%69623 Apr. 1, 2000—Jun. 30, 20008%696239%71 625 Jul. 1, 2000—Sep. 30, 20008%696239%71 625 Oct. 1, 2000—D ec. 31, 2000 8%696239%71 625 Jan. 1, 2001—Mar. 31, 20018%21 575 9%23 577 Apr. 1, 2001—Jun. 30, 20017%19 573 8%21 575 Jul. 1, 2001— Sep. 30, 2001 6%17 571 7%19 573 Oct. 1, 2001—Dec. 31, 20016%17 571 7%19 573 Jan. 1, 2002—Mar. 31, 2002 5%15569 6%17 571 Apr. 1, 2002 —Jun. 30, 2002 5%15569 6%17 571 Jul. 1, 2002—Sep. 30, 2002 5%15569 6%17 571 Oct. 1, 2002—Dec. 31, 2002 5%15569 6%17 571 Jan. 1, 200 3—Mar. 31, 2003 4%13 5675%15569 Apr. 1, 2003—Jun. 30, 20034%13 5675%15569 Jul. 1, 2003—Sep. 30, 20034%13 5675%15569 Oct. 1, 20 03—Dec. 31, 2003 3%11 565 4%13 567 Jan. 1, 2004—Mar. 31, 20043% 59 6134%61 615 Apr. 1, 2004—Jun. 30, 20044%61 6155% 63617 Jul. 1, 2 004—Sep. 30, 2004 3% 59 6134%61 615 Oct. 1, 2004—Dec. 31, 20044%61 6155% 63617 Jan. 1, 2 005—Mar. 31, 2005 4%13 5675%15569 Apr. 1, 2005—Jun. 30, 20055%15569 6%17 571 Jul. 1, 2005—Sep. 30, 20055%15569 6%17 571 Oct. 1, 2005—Dec. 31, 2005 6%17 571 7%19 573 Jan. 1, 2006—Mar. 31, 2006 6%17 571 7%19 573 Apr. 1, 2006—Jun. 30, 20066%17 571 7%19 573 Jul. 1, 2006—Sep. 30, 20067%19 573 8%21 575 Oct. 1 , 2006—Dec. 31, 2006 7%19 573 8%21 575 Jan. 1, 2007—Mar. 31, 20077%19 573 8%21 575 Apr. 1, 2007—Jun. 30, 20077%19 573 8%21 575 Jul. 1, 2007—Sep. 30, 2007 7%19 573 8%21 575 Oct. 1, 2007—Dec. 31, 20077%19 573 8%21 575 Jan. 1, 2008—Mar. 31, 20086% 65 6197%67621 Apr . 1, 2008—Jun. 30, 2008 5% 636176% 65 619 Jul. 1, 2008—Sep. 30, 20084%61 6155% 63617 Oct. 1, 2008—Dec. 31, 2008 5% 636176% 65 619 Jan . 1, 2009—Mar. 31, 2009 4%13 5675%15569 Apr. 1, 2009—Jun. 30, 20093%11 565 4%13 567 Jul. 1, 2009—Sep. 30, 20093%11 56 5 4%13 56 7 Oc t. 1, 2009—Dec. 31, 2009 3%11 565 4%13 567 Jan. 1, 2010—Mar. 31, 20103%11 565 4%13 567 Apr. 1, 2010—Jun. 30, 20103%11 5 65 4%13 5 67 J ul. 1, 2010—Sep. 30, 2010 3 % 1 1 565 4 % 1 3 567 Oct. 1, 2010—Dec. 31, 20103%11 565 4%13 567 Jan. 1, 2011—Mar. 31, 20112%9 563 3%11 565 Apr. 1, 2011—June 30, 20113%11 565 4%13 567 March 28, 20115842011–13 I.R.B. TABLE OF INTEREST RATES FOR LARGE CORPORATE UNDERPAYMENTS FROM JANUARY 1, 1991 — PRESENT 1995–1 C.B. RATETABLEPG Jan. 1, 1991—Mar. 31, 199113%31 585 Apr. 1, 1991—Jun. 30, 199112%29 583 Jul. 1, 1991—Sep. 30, 199112%29 583 Oct. 1, 1991—Dec. 31, 199112%29 583 Jan. 1, 1992—Mar. 31, 199211% 75 629 Apr. 1, 1992—Jun. 30, 199210%73627 Jul. 1, 1992—Sep. 30, 199210%73627 Oct. 1, 1992—Dec. 31, 19929%71 625 Jan. 1, 1993—Mar. 31, 19939%23 577 Apr. 1, 1993—Jun. 30, 19939%23 577 Jul. 1, 1993—Sep. 30, 19939%23 577 Oct. 1, 1993—Dec. 31, 19939%23 577 Jan. 1, 1994—Mar. 31, 19949%23 577 Apr. 1, 1994—Jun. 30, 19949%23 577 Jul. 1, 1994—Sep. 30, 199410% 25579 Oct. 1, 1994—Dec. 31, 199411%27 581 Jan. 1, 1995—Mar. 31, 1995 11%27 581 Apr. 1, 1995—Jun. 30, 1995 12%29 583 Jul. 1, 1995—Sep. 30, 1995 11%27 581 Oct. 1, 1995—Dec. 31, 1995 11%27 581 Jan. 1, 1996—Mar. 31, 199611% 75 629 Apr. 1, 1996—Jun. 30, 199610%73627 Jul. 1, 1996—Sep. 30, 199611% 75 629 Oct. 1, 1996—Dec. 31, 199611% 75 629 Jan. 1, 1997—Mar. 31, 199711%27 581 Apr. 1, 1997—Jun. 30, 199711%27 581 Jul. 1, 1997—Sep. 30, 199711%27 581 Oct. 1, 1997—Dec. 31, 199711%27 581 Jan. 1, 1998—Mar. 31, 199811%27 581 Apr. 1, 1998—Jun. 30, 199810% 25579 Jul. 1, 1998—Sep. 30, 199810% 25579 Oct. 1, 1998—Dec. 31, 199810% 25579 Jan. 1, 1999—Mar. 31, 19999%23 577 Apr. 1, 1999—Jun. 30, 199910% 25579 Jul. 1, 1999—Sep. 30, 199910% 25579 Oct. 1, 1999—Dec. 31, 199910% 25579 Jan. 1, 2000—Mar. 31, 200010%73627 Apr. 1, 2000—Jun. 30, 200011% 75 629 Jul. 1, 2000—Sep. 30, 200011% 75 629 Oct. 1, 2000—Dec. 31, 200011% 75 629 Jan. 1, 2001—Mar. 31, 200111%27 581 Apr. 1, 2001—Jun. 30, 200110% 25579 Jul. 1, 2001—Sep. 30, 20019%23 577 Oct. 1, 2001—Dec. 31, 20019%23 577 Jan. 1, 2002—Mar. 31, 20028%21 575 Apr. 1, 2002—Jun. 30, 20028%21 575 Jul. 1, 2002—Sep. 30, 20028%21 575 Oct. 1, 2002—Dec. 30, 20028%21 575 Jan. 1, 2003—Mar. 31, 20037%19 573 Apr. 1, 2003—Jun. 30, 20037%19 573 Jul. 1, 2003—Sep. 30, 20037%19 573 Oct. 1, 2003—Dec. 31, 20036%17 571 Jan. 1, 2004—Mar. 31, 20046% 65 619 Apr. 1, 2004—Jun. 30, 20047%67621 Jul. 1, 2004—Sep. 30, 20046% 65 619 Oct. 1, 2004—Dec. 31, 20047%67621 2011–13 I.R.B.585March 28, 2011 TABLE OF INTEREST RATES FOR LARGE CORPORATE UNDERPAYMENTS FROM JANUARY 1, 1991 — PRESENT – Continued 1995–1 C.B. RATETABLEPG Jan. 1, 2005—Mar. 31, 2005 7%19 573 Apr. 1, 2005—Jun. 30, 2005 8%21 575 Jul. 1, 2005—Sep. 30, 2005 8%21 575 Oct. 1, 2005—Dec. 31, 2005 9%23 577 Jan. 1, 2006—Mar. 31, 20069%23 577 Apr. 1, 2006—Jun. 30, 20069%23 577 Jul. 1, 2006—Sep. 30, 200610% 25579 Oct. 1, 2006—Dec. 31, 200610% 25579 Jan. 1, 2007—Mar. 31, 200710% 25579 Apr. 1, 2007—Jun. 30, 200710% 25579 Jul. 1, 2007—Sep. 30, 200710% 25579 Oct. 1, 2007—Dec. 31, 200710% 25579 Jan. 1, 2008—Mar. 31, 20089%71 625 Apr. 1, 2008—Jun. 30, 20088%69623 Jul. 1, 2008—Sep. 30, 20087%67621 Oct. 1, 2008—Dec. 31, 20088%69623 Jan. 1, 2009—Mar. 31, 20097%19 573 Apr. 1, 2009—Jun. 30, 20096%17 571 Jul. 1, 2009—Sep. 30, 20096%17 571 Oct. 1, 2009—Dec. 31, 20096%17 571 Jan. 1, 2010—Mar. 31, 20106%17 571 Apr. 1, 2010—Jun. 30, 20106%17 571 Jul. 1, 2010—Sep. 30, 20106%17 571 Oct. 1, 2010—Dec. 31, 20106%17 571 Jan. 1, 2011—Mar. 31, 2011 5%15569 Apr. 1, 2011—June 30, 20116%17 571 TABLE OF INTEREST RATES FOR CORPORATE OVERP AYMENTS EXCEEDING $10,000 FROM JANUARY 1, 1995 — PRESENT 1995–1 C.B. RATETABLEPG Jan. 1, 1995—Mar. 31, 19956.5% 18 572 Apr. 1, 1995—Jun. 30, 19957.5% 20 574 Jul. 1, 1995—Sep. 30, 19956.5% 18 572 Oct. 1, 1995—Dec. 31, 19956.5% 18 572 Jan. 1, 1996—Mar. 31, 1996 6.5% 66620 Apr. 1, 1996—Jun. 30, 1996 5.5% 64618 Jul. 1, 1996—Sep. 30, 1996 6.5% 66620 Oct. 1, 1996—Dec. 31, 1996 6.5% 66620 Jan. 1, 1997—Mar. 31, 1997 6.5% 18 572 Apr. 1, 1997—Jun. 30, 1997 6.5% 18 572 Jul. 1, 1997—Sep. 30, 1997 6.5% 18 572 Oct. 1, 1997—Dec. 31, 1997 6.5% 18 572 Jan. 1, 1998—Mar. 31, 1998 6.5% 18 572 Apr. 1, 1998—Jun. 30, 1998 5.5% 16 570 Jul. 1, 1998—Sep. 30, 1998 5.5% 16 570 Oct. 1, 1998—Dec. 31, 1998 5.5% 16 570 Jan. 1, 1999—Mar. 31, 1999 4.5% 14 568 Apr. 1, 1999—Jun. 30, 1999 5.5% 16 570 Jul. 1, 1999—Sep. 30, 1999 5.5% 16 570 Oct. 1, 1999—Dec. 31, 1999 5.5% 16 570 March 28, 20115862011–13 I.R.B. TABLE OF INTEREST RATES FOR CORPORATE OVERPAYMENTS E XCEEDING $10,000 FROM JANUARY 1, 1995 — PRESENT – Continued 1995–1 C.B. RATETABLEPG Jan. 1, 2000—Mar. 31, 2000 5.5% 64618 Apr. 1, 2000—Jun. 30, 2000 6.5% 66620 Jul. 1, 2000—Sep. 30, 2000 6.5% 66620 Oct. 1, 2000—Dec. 31, 2000 6.5% 66620 Jan. 1, 2001—Mar. 31, 2001 6.5% 18 572 Apr. 1, 2001—Jun. 30, 2001 5.5% 16 570 Jul. 1, 2001—Sep. 30, 2001 4.5% 14 568 Oct. 1, 2001—Dec. 31, 2001 4.5% 14 568 Jan. 1, 2002—Mar. 31, 2002 3.5% 12 566 Apr. 1, 2002—Jun. 30, 2002 3.5% 12 566 Jul. 1, 2002—Sep. 30, 2002 3.5% 12 566 Oct. 1, 2002—Dec. 31, 2002 3.5% 12 566 Jan. 1, 2003—Mar. 31, 2003 2.5% 10 564 Apr. 1, 2003—Jun. 30, 2003 2.5% 10 564 Jul. 1, 2003—Sep. 30, 2003 2.5% 10 564 Oct. 1, 2003—Dec. 31, 2003 1.5% 8 562 Jan. 1, 2004—Mar. 31, 2004 1.5%56 610 Apr. 1, 2004—Jun. 30, 2004 2.5%58 612 Jul. 1, 2004—Sep. 30, 2004 1.5%56 610 Oct. 1, 2004—Dec. 31, 2004 2.5%58 612 Jan. 1, 2005—Mar. 31, 20052.5% 10 564 Apr. 1, 2005—Jun. 30, 20053.5% 12 566 Jul. 1, 2005—Sep. 30, 20053.5% 12 566 Oct. 1, 2005—Dec. 31, 20054.5% 14 568 Jan. 1, 2006—Mar. 31, 2006 4.5% 14 568 Apr. 1, 2006—Jun. 30, 2006 4.5% 14 568 Jul. 1, 2006—Sep. 30, 2006 5.5% 16 570 Oct. 1, 2006—Dec. 31, 2006 5.5% 16 570 Jan. 1, 2007—Mar. 31, 2007 5.5% 16 570 Apr. 1, 2007—Jun. 30, 2007 5.5% 16 570 Jul. 1, 2007—Sep. 30, 2007 5.5% 16 570 Oct. 1, 2007—Dec. 31, 2007 5.5% 16 570 Jan. 1, 2008—Mar. 31, 2008 4.5% 62616 Apr. 1, 2008—Jun. 30, 2008 3.5% 60614 Jul. 1, 2008—Sep. 30, 2008 2.5%58 612 Oct. 1, 2008—Dec. 31, 2008 3.5% 60614 Jan. 1, 2009—Mar. 31, 2009 2.5% 10 564 Apr. 1, 2009—Jun. 30, 2009 1.5% 8 562 Jul. 1, 2009—Sep. 30, 2009 1.5% 8 562 Oct. 1, 2009—Dec. 31, 2009 1.5% 8 562 Jan. 1, 2010—Mar. 31, 2010 1.5% 8 562 Apr. 1, 2010—Jun. 30, 2010 1.5% 8 562 Jul. 1, 2010—Sep. 30, 2010 1.5% 8 562 Oct. 1, 2010—Dec. 31, 2010 1.5% 8 562 Jan. 1, 2011—Mar. 31, 2011 0.5%* Apr. 1, 2011—June 30, 2011 1.5% 8 562 2011–13 I.R.B.587March 28, 2011 Part III. Administrative, Procedural, and Miscellaneous Request for Comments Regarding Application of § 501(c)(29) of the Internal Revenue Code Notice 2011–23 SECTION 1. PURPOSE This notice addresses the requirements for tax exemption for qualified non- profit health insurance issuers described in new § 501(c)(29), added to the Inter- nal Revenue Code (Code) by § 1322(h) of the Patient Protection and Affordable Care Act (Affordable Care Act), enacted March 23, 2010, Pub. L. No. 111–148. This notice provides guidance on the annual filing requirement for qualified nonprofit health insurance issuers that intend to apply for recognition of exempt status under § 501(c)(29), as well as theeffectivedateofexemptstatusfor certain applicants. The IRS intends to issue a revenue procedure on how and when qualified nonprofit health insurance issuers described in § 501(c)(29) may apply for recognition of exempt status. This notice includesa request for public comments. SECTION 2. BACKGROUND Section 1322 of the Affordable Care Act requires the Department of Health and Human Services (HHS) to establish the Consumer Operated and Oriented Plan program (CO-OP program). The purpose of the CO-OP program is to foster the creation of qualified nonprofit health in- surance issuers to offer qualified health plans in individual and small group mar- kets. The CO-OP program will make available to qualified nonprofit health in- surance issuers loans to provide assistance in meeting start-up costs and/or repayable grants to provide assistance in meeting any state solvency requirements. HHS has published a request for comments regard- ing the CO-OP program. See Planning and Establishment of Consumer Operated and Oriented Plan Program; Request for Com- ments Regarding Provisions of Consumer Operated and Oriented Plan Program, 76 Fed. Reg. 5774 (Feb. 2, 2011). Section 1322(h) of the Affordable Care Act added § 501(c)(29) to the Code. Sec- tion 501(c)(29) sets out rules for tax-ex- emption under § 501(a) of the Code for a qualified nonprofit health insurance issuer that has received a grant or loan under the CO-OP program. SECTION 3. QUALIFIED NONPROFIT HEALTH INSURANCE ISSUERS Section 1322(c)(1) of the Affordable Care Act defines a qualified nonprofit health insurance issuer (“Qualified Is- suer”) as an organization (a) that is orga- nized as a nonprofit, member corporation under State law; (b) substantially all of the activities of which consist of the issuance of qualified health plans in the individual and small group markets in each State in which it is licensed to issue such plans; and (c) that meets additional requirements set forth in subsections (c)(2) through (6). Section 1322(c)(2) of the Affordable Care Act provides that an organization shall not be treated as a Qualified Issuer if (a) the organization, a related entity, or a predecessor of either was a health insurance issuer as of July 16, 2009; or (b) the organization is sponsored by a State or local government, any political subdi- vision thereof, or any instrumentality of such government or political subdivision. Section 1322(c)(3) requires a Qualified Issuer to satisfy certain governance re- quirements. Section1322(c)(4) requires a Qualified Issuer to use any profits that it makes to lower premiums, to improve benefits, or for other programs intended to improve the quality of health care deliv- ered to its members. Section 1322(c)(5) requires a Qualified Issuer to meet all state law requirements that other issuers of qualified health plans are required to meet in any state where the issuer offers a qualified health plan. Section 1322(c)(6) provides that a Qualified Issuer may not offer a health plan in a state until that state has in effect (or the Secretary of HHS has implemented for the state) the market re- forms required by part A of title XXVII of the Public Health Service Act, as amended by the Affordable Care Act. Section 1322(b)(2)(C) of the Afford- able Care Act requires a Qualified Issuer receiving a grant or loan under the CO-OP program to enter into an agreement with HHS, which requires it to meet (and con- tinue to meet) both the requirements under § 1322 to be treated as a Qualified Issuer, and all requirements of the loan or grant agreement. Such an agreement must in- clude a requirement that no portion of the funds made available by any loan or grant under the CO-OP program may be used for carrying on propaganda, or otherwise attempting, to influence legislation, or for marketing. A Qualified Issuer that has received a loan or grant under the CO-OP program may apply to the IRS to be recognized as an organization described in § 501(c)(29) of the Code and exempt from taxation un- der § 501(a) of the Code. The Qualified Issuer will qualify for exempt status un- der § 501(c)(29) only for periods that it is in compliance with the requirements of § 1322 of the Affordable Care Act and any loan or grant agreement with HHS. Un- der § 1322(b)(2)(C)(iii) of the Affordable Care Act, HHS must notify the Secretary of the Treasury of any determination under § 1322 of a failure that results in the termi- nation of a Qualified Issuer’s tax-exempt status under § 501(c)(29) of the Code. If a Qualified Issuer that has received a loan or grant under the CO-OP pro- gram does not apply for recognition of exempt status as an organization described in § 501(c)(29) or loses exempt status, it may be subject to Federal income taxation under appropriate provisions of the Code. If a taxable Qualified Issuer qualifies as an insurance company for Federal income tax purposes, it will be subject to the special tax rules of Subchapter L of the Code. SECTION 4. CONDITIONS FOR TAX EXEMPTION An organization is described in § 501(c)(29) of the Code only if : 1. The organization is a Qualified Is- suer that has received a loan or grant un- der the CO-OP program and is in compli- ance with all requirements of § 1322 and any loan or grant agreement with HHS. 2. The organization has given notice to the Secretary of the Treasury in the manner prescribed by regulations that it is applying for recognition of its exempt status as an organization described in § 501(c)(29); March 28, 20115882011–13 I.R.B. 3. No part of the organization’s net earnings inure to the benefit of any pri- vate shareholder or individual, except as provided in § 1322(c)(4) of the Affordable Care Act (which requires profits to be used to lower premiums, improve benefits, or for other programs intended to improve the quality of health care delivered to the or- ganization’s members); 4. No substantial part of the organiza- tion’s activities consist of carrying on pro- paganda, or otherwise attempting, to influ- ence legislation; and 5. The organization does not participate in, or intervene in (including the publish- ing or distributing of statements), any po- litical campaign on behalf of (or in oppo- sition to) any candidate for public office. SECTION 5. ADDITIONAL INFORMATION REPORTING REQUIRED Section 6033 of the Code requires a tax-exempt organization described in § 501(c)(29) to file an annual information return. Section 1322(h)(2) of the Afford- able Care Act amended § 6033 of the Code to require an organization described in § 501(c)(29) to provide certain additional information on its annual information re- turn. In addition to the general information required, it must report the amount of re- serves required by each State in which the organization is licensed to issue qualified health plans, and the amount of reserves on hand. SECTION 6. APPLICATION OF TAX ON EXCESS BENEFIT TRANSACTIONS Section 4958 of the Code imposes an excise tax, payable by the disqualified person, on each excess benefit transac- tion between an applicable tax-exempt organization and a disqualified person. Section 4958 also imposes an excise tax on organization managers who knowingly participated in an excess benefit transac- tion, unless participation was not willful and was due to reasonable cause. Section 1322(h)(3) of the Affordable Care Act amended § 4958(e)(1) to provide that an organization described in § 501(c)(29) is an “applicable tax-exempt organization” subject to § 4958. SECTION 7. APPLICATIONS FOR RECOGNITION OF EXEMPTION The IRS intends to publish a revenue procedure describing how an organiza- tion may apply for recognition of exempt status as an organization described in § 501(c)(29). Until the revenue procedure is published, the IRS will not accept ap- plications. The revenue procedure will provide that a Qualified Issuer may not submit its request for recognition of ex- emption under § 501(c)(29) until it has entered into an agreement with HHS under § 1322(b)(2)(C) of the Affordable Care Act. The revenue procedure also will ad- dress the effective date of a Qualified Is- suer’s tax exemption. The Treasury De- partment and the IRS intend to recognize a Qualified Issuer that has received a loan or grant under the CO-OP program as ex- empt effective from the later of the date of its formation or March 23, 2010, provided that the Qualified Issuer’s purposes and ac- tivities have been consistent with the re- quirements for exemption since that date. To be recognized as exempt from the date of its formation, a Qualified Issuer must have complied with the conditions of ex- emption described in clauses (ii)-(iv) of § 501(c)(29)(B). SECTION 8. ANNUAL FILING REQUIREMENT PRIOR TO RECOGNITION OF EXEMPT STATUS A Qualified Issuer claiming exempt sta- tus under § 501(c)(29) that has filed or in- tends to file an application for exemption should file Form 990,Return of Organiza- tion Exempt from Income Tax, for taxable years that end before it receives a determi- nation letter. The Qualified Issuer must in- dicate on its return that it is being filed in the belief that the Qualified Issuer is ex- empt under § 501(a), but the IRS has not yet recognized its exemption. SECTION 9. EFFECTIVE DATE The provisions of § 1322 of the Afford- able Care Act, including the addition to the Code of § 501(c)(29) and the amend- mentsto§§6033and4958oftheCodede- scribed above, are effective beginning on March 23, 2010, the date of enactment of theAffordableCareAct. SECTION 10. REQUEST FOR COMMENTS The Treasury Department and the IRS request comments regarding the pro- visions described above, including, in particular, the need, if any, for guidance regarding such provisions. Comments are specifically requested regarding: 1. Any special factors the IRS should consider when establishing the procedures for applying for recognition of tax-exempt status under § 501(c)(29); 2. The proposed effective date of a Qualified Issuer’s tax exemption, as de- scribed in section 7 of this notice; and 3. Any special considerations regard- ing the application to Qualified Issuers of the prohibition on private inurement in § 501(c)(29)(B)(ii), the limitation on lobbying activities in § 501(c)(29)(B)(iii), the prohibition on political activities in 501(c)(29)(B)(iv), the taxation of excess benefit transactions under § 4958, and the taxation of unrelated business taxable income under § 511. Comments should be submitted in writ- ing on or before May 27, 2011. Please in- clude “Notice 2011–23” on the cover page. Comments should be sent to the following address: Internal Revenue Service CC:PA:LPD:PR (Notice 2011–23) Room 5203 P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to: Internal Revenue Service Courier’s Desk 1111 Constitution Ave., N.W. Washington, DC 20224 Attn: CC:PA:LPD:PR (Notice 2011–23) Submissions may also be sent electron- ically to the following e-mail address: Notice.Comments@irscounsel.treas.gov Please include “Notice 2011–23” in the subject line. All comments will be available for pub- lic inspection and copying. 2011–13 I.R.B.589March 28, 2011 SECTION 11. DRAFTING INFORMATION The principal author of this notice is Justin Lowe of the Exempt Organizations, Tax Exempt and Government Entities Di- vision. For further information regarding this notice, contact Mr. Lowe at (202) 283–9486 (not a toll-free call). March 28, 20115902011–13 I.R.B. Part IV. Items o fGeneralInterest Notice of Prop osed Rulemaking Disclosure of Information to State Offic ials Regarding Tax-Exempt O rganizations REG–140108–08 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations that amend existing regulations to reflect changes to section 6104(c) of the Internal Revenue Code (Code) made by the Pension Protection Act of 2006 (PPA). These rules provide guidance to states regarding the process by which they may obtain or inspect certain returns and return information (includ- ing information about final and proposed denials and revocations of tax-exempt status) for the purpose of administering state laws governing certain tax-exempt organizations and their activities. These regulations will affect such exempt orga- nizations, as well as those state agencies choosing to obtain information from the Internal Revenue Service (IRS) under sec- tion 6104(c). DATES: Written or electronic comments and requests for a public hearing must be received by June 13, 2011. ADDRESSES: Send submissions to: CC:PA:LPD:PR(REG–140108–08), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–140108–08), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC, or sent electronically viatheFederaleRulemaking Portal atwww.regulations.gov(IRS REG–140108–08). FO R FURTHER INFORMATION CO NTACT: Concerning submission of comments, O luwafunmilayo Taylor, (202) 622–718 0 (not a toll-free number); concerning th e proposed regulations, Casey Lothame r, (202) 622–6070 (not a toll-free num ber). SUPPLEMENTAR Y INFORMATION: Background I. In general This documen t contains proposed amendments t o 26 CFR part 301 under section 6104 (c), which will replace current §301.6104(c )–1initsentirety. Section 6104(c) gov erns when the IRS may dis- close to sta te officials certain information about organ izations described in section 501(c)(3) ( “charitable organizations”), organizati ons that have applied for recog- nition as o rganizations described in section 501(c)(3) (“applicants”), and certain other exempt org anizations. Section 6104(c) was added t o the Code by section 101(e) of the Tax Ref orm Act of 1969 (Public Law 91–172, 8 3 Stat. 523) and significantly amended b y section 1224(a) of the PPA (Public L aw 109–280, 120 Stat. 1091). Section 5 01(c)(3) organizations may be affect ed by the expanded disclosures to state off icials authorized under the statute and prop osed regulations. First, the IRS is now au thorized (under new section 6104(c) (2), as added by the PPA) to dis- close in formation about certain proposed revocat ions and proposed denials before an admi nistrative appeal has been made and a fi nal revocation or denial has been issued . For those organizations that have receiv ed a determination letter stating that they ar e described in section 501(c)(3), the IR S may disclose a proposed revoca- tion ( before any administrative appeal) to an app ropriate state officer (ASO). This broad er authority applies both where the organ ization was required under section 508 t o apply for the determination let- ter a nd where the organization elected to ap ply for a determination letter even thou gh it was not required to do so. The IRS c ontinues to be authorized to disclose fina l revocations and final denials issued aft er any administrative appeal has been con cluded for any section 501(c)(3) or- gan ization. Second, under the authority of new sec- tion 6104(c)( 2)(D), as added by the PPA, the IRS may dis close returns or return in- formation of a ny section 501(c)(3) organ- ization to ASO s on its own initiative, re- gardless of w hether it has initiated an ex- amination, i f it determines that the infor- mation may be evidence of noncompliance with state la ws under the jurisdiction of the ASO. Thu s, if the IRS believes these conditions are met, it may, for example, disclose to ASOs a proposed revocation of exemptio n for a section 501(c)(3) or- ganizatio n that does not have a determina- tion lette r. All disclosures authorized un- der sectio n 6104(c) may be made only if the state r eceiving the information is fol- lowing app licable disclosure, recordkeep- ing and sa feguard procedures. The statut e and proposed regulations also perm it disclosure of information to state off icials about all applicants for sec- tion 501( c)(3) status. Exempt or ganizations other than sec- tion 501( c)(3) organizations also may be affected by the disclosures to state offi- cials au thorized under the statute and pro- posed re gulations. The IRS is authorized to discl ose returns and return information of these organizations to ASOs upon writ- ten requ est, but only to the extent nec- essary to administer state laws regulating the sol icitation or administration of char- itable funds or charitable assets. Again, all suc h disclosures may be made only if the sta te receiving the information is fol- lowin g applicable disclosure, recordkeep- ing an d safeguard procedures. Secti on 6104(c)(1), which is unchanged by the PPA, directs the IRS to share certain infor mation with ASOs regarding charita- ble or ganizations and applicants. Specifi- cally , section 6104(c)(1) provides that the IRS i s to notify the ASO of the follow- ing f inal determinations: (1) a refusal to reco gnize an entity as an organization de- scri bedinsection501(c)(3);(2)theopera- tion of a section 501(c)(3) organization in ama nner not meeting, or no longer meet- ing , the requirements of its exemption; and (3) themailingofanoticeofdeficiency for any tax imposed under section 507, cha pter 41, or chapter 42. See section 610 4(c)(1)(A) and (c)(1)(B). The direc- ti ve under section 6104(c)(1)(A) to notify 2011–13 I.R.B.591March 28, 2011 ASOs of an organization no longer meet- ing the requirements for exemption under section 501(c)(3) includes not only notice of a revocation of exemption, but also no- tice (when the IRS is so informed) that a charitable organization is terminating or has dissolved in accordance with its gov- erning documents. Upon request, an ASO mayinspectandcopythereturns,filed statements, records, reports, and other in- formation relating to a final determination as described in this paragraph, as are rele- vant to any determination under state law. See section 6104(c)(1)(C). II. PPA changes to section 6104(c) The PPA amended section 6104(c) by striking paragraph (2) and inserting new paragraphs (2) through (6) as follows. (1) The IRS may disclose to an ASO proposed refusals to recognize organi- zations as charitable organizations, and proposed revocations of such recognition. The PPA also allows disclosure of no- tices of proposed deficiencies of excise taxes imposed by section 507 and chapters 41 and 42 relating to charitable orga- nizations. See section 6104(c)(2)(A)(i) and (c)(2)(A)(ii). Previously, only final determinations of this kind (denials of recognition, revocations, and notices of deficiency) could be disclosed under sec- tion 6104(c). (2) The IRS may disclose to an ASO the names, addresses, and taxpayer identifica- tion numbers of applicants. See section 6104(c)(2)(A)(iii). Previously, informa- tion on applicants, other than information relating to a denial of recognition, could not be disclosed under section 6104(c). (3) The IRS may disclose to an ASO the returns and return information of organi- zations with respect to which information is disclosed as described in paragraphs (1) and (2) of this section II (proposed deter- minations and applicant identifying infor- mation). See section 6104(c)(2)(B). Prior law allowed for disclosure under section 6104(c) only of returns and return informa- tion related to final determinations. (4) Proposed determinations, identify- ing information, and the related returns and return information with respect to chari- table organizations and applicants may be disclosed to an ASO only upon the ASO’s written request and only as necessary to administer state laws regulating charita- ble organizations, such as laws governing tax-exempt status, charitable trusts, char- itable solicitation, and fraud. See section 6104(c)(2)(C). Prior law provided for au- tomatic disclosure (without a request), but only of final determinations and their re- lated returns and return information. (5) The IRS may disclose to an ASO on its own initiative (without a written request) returns and return information with respect to charitable organizations and applicants if the IRS determines that this information might constitute evidence of noncompliance with the laws under the jurisdiction of the ASO. See section 6104(c)(2)(D). There was no such provi- sion under section 6104(c) previously. (6) The IRS may disclose returns and return information of section 501(c) or- ganizations other than those described in section 501(c)(1) or (c)(3) to an ASO upon the ASO’s written request, but only to the extent necessary in administering state laws relating to the solicitation or administration of charitable funds or char- itable assets of such organizations. See section 6104(c)(3). Previously, only infor- mation relating to charitable organizations or applicants was disclosed under section 6104(c). (7) Returns and return information of organizations and taxable persons dis- closed under section 6104(c) may be disclosed in civil administrative and civil judicial proceedings pertaining to the en- forcement of state laws regulating such or- ganizations, under procedures prescribed by the IRS similar to those under sec- tion 6103(h)(4). See section 6104(c)(4). There was no such provision under section 6104(c) previously. (8) No return or return information may be disclosed under section 6104(c) to the extent the IRS determines that such disclosure would seriously impair federal tax administration. See section 6104(c)(5). This disclosure prohibition, though new in the PPA, was provided previously by regulation. See current §301.6104(c)–1(b)(3)(ii). (9) The IRS may disclose returns and return information under section 6104(c) to a state officer or employee designated by the ASO to receive such information on the ASO’s behalf. See section 6104(c)(2)(C) (flush language) and (c)(3). Prior law did not provide for IRS disclosures to persons other than ASOs. (10) An ASO is defined as the state attorney general, state tax officer, any state official charged with overseeing charita- ble organizations (in the case of charitable organizations and applicants), and the head of the state agency charged with the primary responsibility for overseeing the solicitation of funds for charitable purposes (in the case of section 501(c) organizations other than those described in section 501(c)(1) or (c)(3)). See sec- tion 6104(c)(6)(B). Before its amendment by the PPA, section 6104(c)(2) defined ASO as the state attorney general, state tax officer, or any state official charged with overseeing organizations of the type described in section 501(c)(3). III. Related PPA provisions The PPA amended section 6103(p) to make the disclosure of returns and return information under section 6104(c) subject to the disclosure, recordkeeping, and safe- guard provisions of section 6103. These provisions include— (1) section 6103(a), which is the general prohibition on the disclosure of returns and return information,except as authorized by Title 26 of the United States Code; (2) section 6103(p)(3), which requires the IRS to maintain permanent standard- ized records of all requests for inspection or disclosure of returns or return infor- mation under section 6104(c) and of all such information inspected or disclosed pursuant to those requests; and (3) section 6103(p)(4), which requires an ASO, as a condition for receiving re- turns or return information under section 6104(c), to establish and maintain certain safeguards, such as keeping permanent standardized records of all requests and disclosures, maintaining a secure infor- mation storage area, restricting access to the information, and providing whatever other safeguards the IRS deems neces- sary to protect the confidentiality of the information. See §301.6103(p)(4)–1 and IRS Publication 1075,Tax Information Security Guidelines for Federal, State and Local Agencies. Publication 1075 can be found atwww.irs.gov/formspubs. The PPA also included amendments to sections 7213, 7213A, and 7431 to impose civil and criminal penalties for the unau- thorized disclosure or inspection of section 6104(c) information. March 28, 20115922011–13 I.R.B. IV. IRS disclosure procedures In general, before any federal or state agency may receive returns and return in- formation from the IRS under a particu- lar Code provision, it must file with the IRS a report detailing the physical, admin- istrative, and technical safeguards imple- mented by the agency to protect this in- formation from unauthorized inspection or disclosure. Only upon approval of these safeguards by the IRS, as well as satis- faction of any other statutory requirements (such as submission of a written request), may an agency receive the information to which it is entitled under the Code, and then only for the use specified by the rele- vant statute. See section 6103(p)(4). Under various disclosure programs, the IRS and other federal and state agen- cies often execute agreements detailing the responsibilities of the parties and the terms and parameters of the disclosure arrangement. For example, under section 6103(d), the IRS executes a disclosure agreement (the “Basic Agreement”) with each state tax agency to which it discloses information. The Basic Agreement, which serves as the written request required by section 6103(d), has been the foundation of the state tax disclosure program un- der this provision of the Code for over 30 years. See Internal Revenue Manual Exhibit 11.3.32–1 (sample Basic Agree- ment). After the PPA, the IRS revised its dis- closure procedures under section 6104(c) to model them after the highly success- ful section 6103(d) program. The section 6104(c) program uses a disclosure agree- ment patterned after the Basic Agreement but tailored to the specific requirements and restrictions of section 6104(c). Explanation of Provisions These proposed regulations provide guidance regarding disclosures under sec- tion 6104(c), as amended by the PPA. The PPA amendmentsto sections 6104(c) and 6103 expand the scope of informa- tion the IRS may disclose to an ASO, but make such disclosures contingent on the ASO adopting the safeguard standards and procedures of section 6103 that apply to federal and state agencies that receive returns and return information under other provisions of the Code. Accordingly, these proposed regulations provide that, without prior safeguard approval, the IRS will not give automatic notification of any determinations or other information that may be disclosed under section 6104(c). Under these proposed regulations, the IRS may (and currently does) require an ASO to enter into a disclosure agreement with the IRS, which will stipulate the procedures for disclosure under section 6104(c), as well as the restrictions on use and redisclosure. These proposed regula- tions provide that this agreement, or any similar document, satisfies the require- ment under section 6104(c) for a written request for disclosure. An ASO who meets the safeguard and other procedural requirements of section 6103(p)(4) may receive information from the IRS to be used in the administration of state laws governing charitable orga- nizations, as well as laws governing the solicitation or administration of charitable funds or charitable assets of certain non- charitable exempt organizations. The in- formation available to ASOs under these proposed regulations not only is greater in scope than what was available under sec- tion 6104(c) before its amendment by the PPA, but comes at an earlier stage in the IRS administrative and enforcement pro- cesses. Thus, the IRS may disclose such information as whether an organization has applied for recognition as a charitable or- ganization and, if so, whether the IRS pro- poses to deny such recognition, or the or- ganization has withdrawn its application; whether an organization’s charitable status has terminated; whether the IRS proposes to assess any chapter 42 excise taxes (for example, the tax on excess benefit transac- tions under section 4958); and whether the IRS has revoked an organization’s exemp- tion, or proposes to revoke the recognition of its exemption. Without a written request, but still subject to the safeguard requirements of section 6103(p)(4), the IRS has the au- thority under section 6104(c)(2)(D) to disclose returns and return information of charitable organizations and applicants if it determines that such information may constitute evidence of noncompliance with the laws under the ASO’s jurisdiction. The IRS may make these disclosures on its own initiative. These proposed regula- tions clarify that the IRS’ authority under section6104(c)(2)(D)isinadditiontoits disclosure authority under other provisions of section 6104(c)(1) and (c)(2), to the effect that discretionary disclosures may be made before the IRS issues a proposed determination or takes other action. The proposed regulations also make clear that the determination required by the statute concerns possible noncompliance with state laws regulating charitable organiza- tions and not just any state law violation. The disclosure provisions of section 6104(c), as amended by the PPA, offer significant advantages to states in their enforcement efforts. The ability of the IRS to disclose returns and return infor- mation early in its own administrative and enforcement processes, as well as the IRS’ authority under section 6104(c)(2)(D) to disclose information on its own initiative, greatly enhance the administration and enforcement of state laws, both tax and nontax, governing charitable activities, funds, and assets. These proposed regulations define cer- tain key terms for purposes of section 6104(c), including “appropriate state offi- cer”, “return”, “return information”, and “taxable person.” Special Analyses It has been determined that this notice of proposed rulemaking is not a signifi- cant regulatory action as defined in Ex- ecutive Order 12866; therefore, a regula- tory assessment is not required. It also has been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply to the proposed regulations; therefore, a reg- ulatory flexibility analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, the proposed regulations have been submitted to the Chief Counsel for Advocacy of the Small Business Ad- ministration for comments regarding their impact on small businesses. Comments and Requests for a Public Hearing Before these proposed regulations are adopted as final, any written (signed orig- inal and 8 copies) or electronic comments timely submitted to the IRS will be consid- ered. The IRS and Treasury Department request comments on the clarity of these proposed regulations and how they might 2011–13 I.R.B.593March 28, 2011 be made easier to understand. Of particu- lar interest are comments on whether para- graph (e) of these proposed regulations, describing the organizations to which dis- closure applies, lists all the organizations with respect to which ASOs might legit- imately need information. All comments will be available for public inspection and copying. A public hearing will be sched- uled if requested in writing by any person who timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place for the public hearing will be published in theFederal Register. Drafting Information The principal author of these regula- tions is Casey Lothamer of the Office of Division Counsel/Associate Chief Coun- sel (Tax Exempt and Government Enti- ties), though other persons in the IRS and Treasury Department participated in their development. ***** Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is pro- posedtobeamendedasfollows: PART 301—PROCEDURE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 is amended by adding an entry in numerical order to read in part as follows: Authority: 26 U.S.C. 7805 * * * Section 301.6104(c)–1 also issued un- der 26 U.S.C. 6104(c). * * * Par. 2. Section 301.6104(c)–1 is re- vised to read as follows: §301.6104(c)–1 Disclosure of certain information to state officials. (a)In general.—(1) Subject to the dis- closure, recordkeeping, and safeguard pro- visions of section 6103, and upon writ- ten request by an appropriate state offi- cer (ASO, as defined in paragraph (i)(1) of this section), the IRS may disclose or make available to the ASO the returns and return information described in paragraph (c) of this section with respect to— (i) any organization described or for- merly described in section 501(c)(3) and exempt or formerly exempt from taxation under section 501(a) (a charitable organi- zation); or (ii) any organization that has applied for recognition as an organization described in section 501(c)(3) (an applicant). Such information shall be disclosed or made available only as necessary to ad- minister state laws regulating charitable organizations. (2) Subject to the disclosure, record- keeping, and safeguard provisions of section 6103, and upon written request by an ASO, the IRS may disclose or make available to the ASO returns and return information regarding any organization described or formerly described in sec- tion 501(c) other than section 501(c)(1) or (c)(3). Such information shall be disclosed or made available only as necessary to administer state laws regulating the solic- itation or administration of the charitable funds or charitable assets of these organi- zations. (b)Disclosure agreement.TheIRS may require an ASO to execute a dis- closure agreement or similar document specifying the procedures, terms, and con- ditions for the disclosure or inspection of information under section 6104(c), includ- ing compliance with the safeguards pre- scribed by section 6103(p)(4), as well as specifying the informationtobedisclosed. Such an agreement or similar document shall constitute the request for disclosure required by section 6104(c)(1)(C), as well as the written request required by section 6104(c)(2)(C)(i) and (c)(3). For security guidelines and othersafeguards for pro- tecting returns and return information, see guidance published by the IRS. See, for example, IRS Publication 1075, “Tax In- formation Security Guidelines for Federal, State and Local Agencies.” (c)Disclosures regarding charitable organizations and applicants.—(1) With respect to any organization described in paragraph (d) of this section, the IRS may disclose or make available for inspection under section 6104(c)(1) and (c)(2) to an ASO the following returns and return information with respect to a charitable organization or applicant: (i) A refusal or proposed refusal to rec- ognize an organization’s exemption as a charitable organization (a final or proposed denial letter). (ii) Information regarding a grant of ex- emption following a proposed denial. (iii) A revocation of exemption as a charitable organization (a final revocation letter), including a notice of termination or dissolution. (iv) A proposed revocation of recogni- tion of exemption as acharitable organiza- tion (a proposed revocation letter). (v) Information regarding the final dis- position of a proposed revocation of recog- nition other than by final revocation. (vi) A notice of deficiency or proposed notice of deficiency of tax imposed un- der section 507 or chapter 41 or 42 on the organization or a taxable person (as de- scribed in paragraph (i)(4) of this section). (vii) Information regarding the final disposition of a proposed notice of defi- ciency of tax imposed under section 507 or chapter 41 or 42 on the organization other than by issuance of a final notice of deficiency. (viii) The names, addresses, and tax- payer identification numbers of applicants for charitable status, provided on an ap- plicant-by-applicant basis or by periodic lists of applicants. Under this provision the IRS may respond to inquiries from an ASO as to whether a particular organization has applied for recognition of exemption as a charitable organization. (ix) Information regarding the final dis- position of an application for recognition of exemption where no proposed denial letter is issued, including whether the ap- plication was withdrawn or whether the applicant failed to establish its exemption. (x) Returns and other return informa- tion relating to the return information de- scribed in this paragraph (c)(1), except for returns and return information relating to proposed notices of deficiency described in paragraph (c)(1)(vi) of this section with respect to taxable persons. (2) The IRS may disclose or make avail- able for inspection returns and return in- formation of a charitable organization or applicant, if the IRSdetermines that such information might constitute evidence of noncompliance with the laws under the ju- risdiction of the ASO regulating charitable organizations and applicants. Such infor- mation may be disclosed on the IRS’ own initiative. Disclosures under this para- graph (c)(2) may be made before the IRS issues a proposed determination (denial of recognition, revocation, or notice of defi- ciency) or any other action by the IRS de- scribedinthissection. March 28, 20115942011–13 I.R.B. (d)Organizations to which disclosure applies. Regarding the information de- scribed in paragraphs (a)(2) and (c) of this section, the IRS will disclose or make available for inspection to an ASO such information only with respect to— (1) an organization formed under the laws of the ASO’s state; (2) an organization, the principal office of which is located in the ASO’s state; (3) an organization that, as determined by the IRS, is or might be subject to the laws of the ASO’s state regulating charita- ble organizations or the solicitation or ad- ministration of charitable funds or charita- ble assets; or (4) a private foundation required by §1.6033–2(a)(iv) to list the ASO’s state on any of the foundation’s returns filed for its last five years. (e)Disclosurelimita- tions.—Notwithstanding any other provision of this section, the IRS will not disclose or make available for inspection under section 6104(c) any information, the disclosure of which it determines would seriously impair federal tax admin- istration, including, but not limited to— (1) identification of a confidential infor- mant or interference with a civil or crimi- nal tax investigation; and (2) information obtained pursuant to a tax convention between the United States and a foreign government (see section 6105(c)(2) for the definition oftax con- vention). (f)Disclosure recipients.—(1)In gen- eral. The IRS may disclose returns and re- turn information under section 6104(c) to, or make it available for inspection by— (i) an ASO, as defined in paragraph (i)(1) of this section, or (ii) a person other than an ASO, but only if that person is a state officer or em- ployee designated by the ASO to receive information under section 6104(c) on be- half of the ASO, as specified in paragraph (f)(2) of this section. (2)Designation by ASO.AnASOmay designate state officers or employees to re- ceive information under section 6104(c) on the ASO’s behalf by specifying in writ- ing each person’s name and job title, and the name and address of the person’s of- fice. The ASO must promptly notify the IRS in writing of any additions, deletions, or other changes to the list of designated persons. (g)Redisclosure. An ASO to whom a return or return information has been dis- closed may thereafter disclose such infor- mation— (1) to another state officer or employee only as necessary to administer state laws governing charitable organizations or state laws regulating the solicitation or admin- istration of charitable funds or charitable assets of noncharitable exempt organiza- tions; or (2) except as provided in paragraph (h)(1) of this section, to another state of- ficer or employee who is personally and directly preparing for a civil proceeding before a state administrative body or court in a matter involving the enforcement of state laws regulating organizations with respect to which information can be dis- closed under this section, solely for use in such a proceeding, but only if— (i) the organization or a taxable person is a party to the proceeding, or the proceed- ing arose out of, or in connection with, de- termining the civil liability of the organiza- tion or a taxable person, or collecting such civil liability, under state laws governing organizations with respect to which infor- mation can be disclosed under this section; (ii) the treatment of an item reflected on such a return is directly related to the resolution of an issue in the proceeding; or (iii) the return or return information di- rectly relates to a transactional relationship between the organization or a taxable per- son and a person who is a party to the pro- ceeding that directly affects the resolution of an issue in the proceeding. (h)Redisclosure limitations.—(1) Be- fore disclosing in a state administrative or judicial proceeding, or to any party as provided by paragraph (g)(2) of this sec- tion, any return or return information re- ceived under section 6104(c), the ASO shall notify the IRS of the intention to make such a disclosure. No state officer or employee shall make such a disclosure except in accordance with any conditions the IRS might impose in response to the ASO’s notice of intent. No such disclo- sure shall be made if the IRS determines that the disclosure would seriously impair federal tax administration. (2) An ASO to whom a return or return information has been disclosed shall not disclose that information to an agent or contractor. (i)Definitions.—(1)Appropriate state officermeans— (i) the state attorney general; (ii) the state tax officer; (iii) with respect to a charitable organi- zation or applicant, any state officer other than the attorney general or tax officer charged with overseeing charitable organi- zations; and (iv) with respect to a section 501(c) or- ganization that is not described in section 501(c)(1) or (c)(3), the head of the agency designated by the state attorney general as having primary responsibility for oversee- ing the solicitation of funds for charitable purposes. A state officer described in paragraph (i)(1)(iii) or (i)(1)(iv) of this section must show that the officer is an ASO by present- ing a letter from the state attorney general describing the functions and authority of the officer under state law, with sufficient facts for the IRS to determine that the offi- cer is an ASO. (2)Returnhas the same meaning as in section 6103(b)(1). (3)Return informationhas the same meaning as in section 6103(b)(2). (4)Taxable personmeans any person who is liable or potentially liable for ex- cise taxes under chapter 41 or 42. Such a person includes— (i) a disqualified person described in section 4946(a)(1), 4951(e)(4), or 4958(f); (ii) a foundation manager described in section 4946(b); (iii) an organization manager described in section 4955(f)(2) or 4958(f)(2); (iv) a person described in section 4958(c)(3)(B); (v) an entity manager described in sec- tion 4965(d); and (vi) a fund manager described in section 4966(d)(3). (j)Failure to comply. Upon a de- termination that an ASO has failed to comply with the requirements of section 6103(p)(4), the IRS may take the actions it deems necessary to ensure compliance, in- cluding the refusal to disclose any further returns or return information to the ASO until the IRS determines that the require- ments have been met. For procedures for the administrative review of a determina- tion that an authorized recipient has failed to safeguard returns or return information, see §301.6103(p)(7)–1. 2011–13 I.R.B.595March 28, 2011 (k)Effective/applicability date.The rules of this section apply to taxable years beginning on or after the date of pub- lication in theFederal Registerof the Treasury decision adopting these rules as final regulations. Steven T. Miller, Deputy Commissioner for Services and Enforcement. (Filed by the Office of the Federal Register on March 14, 2011, 8:45 a.m., and published in the issue of the Federal Register for March 15, 2011, 76 F.R. 13932) March 28, 20115962011–13 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. 2011–13 I.R.B.iMarch 28, 2011 Numerical Finding List 1 Bulletin 2011–1 through 2011–13 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 2011-23, 2011-12 I.R.B.568 2011-24, 2011-12 I.R.B.569 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 2011-17, 2011-10 I.R.B.540 2011-18, 2011-11 I.R.B.549 2011-19, 2011-11 I.R.B.550 2011-22, 2011-12 I.R.B.557 2011-23, 2011-13 I.R.B.588 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-124018-10, 2011-2 I.R.B.301 Proposed Regulations— Continued: 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 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 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 9516, 2011-13 I.R.B.575 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. March 28, 2011ii2011–13 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletin 2011–1 through 2011–13 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 2010-27 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2010-59 Modified by Notice 2011-5, 2011-3 I.R.B.314 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 Revenue Procedures: 72-50 Modified and superseded by Rev. Proc. 2011-10, 2011-2 I.R.B.294 Revenue Procedures— Continued: 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. 2011-4, 2011-1 I.R.B.330 2001-10 Modified by Rev. Proc. 2011-4, 2011-4 I.R.B.330 2002-28 Modified by Rev. Proc. 2011-4, 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 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.283 Revenue Procedures— Continued: 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 2010-18 Amplified and modified by Rev. Proc. 2011-21, 2011-12 I.R.B.560 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 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 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. 2011–13 I.R.B.iiiMarch 28, 2011 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 March 28, 2011iv2011–13 I.R.B. INDEX Internal Revenue Bulletin 2011–1 through 2011–13 The abbreviation and number in parenthesis following the index entry refer to the specific item; numbers in roman and italic type following the parenthesis refers to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears. Key to Abbreviations: AnnAnnouncement CDCourt Decision DODelegation Order EOExecutive Order PLPublic Law PTEProhibited Transaction Exemption RPRevenue Procedure RRRevenue Ruling SPRStatement of Procedural Rules TCTax Convention TDTreasury Decision TDOTreasury Department Order EMPLOYEE PLANS Affordable Care Act, nondiscrimination provisions applicable to insured group health plans (Notice 1) 2,259 Cash balance plans and other hybrid defined benefit pension plans, correction to TD 9505 (Ann 10) 7,499; correction to REG–132554–08 (Ann 11) 7,500 Determination letters, issuing procedures (RP 6) 1,195 Full funding limitations, weighted average interest rates, seg- ment rates for: January 2011 (Notice 7) 5,437 February 2011 (Notice 13) 9,529 March 2011 (Notice 22) 12,557 Guidance under section 162(m)(6) (Notice 2) 2,260 Letter rulings: 403(b) plans, plan termination (RR 7) 10,534 And determination letters, areas which will not be issued from: Associates Chief Counsel and Division Counsel (TE/GE) (RP 3) 1,111 Associate Chief Counsel (International) (RP 7) 1,233 And general information letters, procedures (RP 4) 1,123 User fees, request for letter rulings (RP 8) 1,237; correction (Ann 8) 5,446 Proposed Regulations: 26 CFR 1.411(b)(5)–1, revised;hybrid retirement plans; cor- rection to REG–132554–08 (Ann 11) 7,500 Qualified plans: Covered compensation tables, permitted disparity (RR 3) 4, 326; correction (Ann 16) 7,500 Group trusts (RR 1) 2,251 Minimum funding requirements relief (Notice 3) 2,263 Readily tradable securities (Notice 19) 11,550 Reporting requirements, Form 8955-SSA (Ann 21) 12,567 EMPLOYEE PLANS—Cont. Regulations: 26 CFR 1.411(b)(5)–1, revised; hybrid retirement plans; cor- rection to TD 9505 (Ann 10) 7,499 Technical advice to IRS employees (RP 5) 1,167 EMPLOYMENT TAX Electronic Funds Transfer (ETF) of depository taxes (TD 9507) 3,305 Letter rulings and information letters issued by Associate Of- fices, determination letters issued by Operating Divisions (RP 1) 1,1;correction(Ann7)5,446 Proposed Regulations: 26 CFR 301.7623–1, amended; rewards and awards for in- formation relating to violations of internal revenue laws (REG–131151–10) 8,519 Regulations: 26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended; 31.6071, amended; 31.6302–0 thru –2, –4, amended; 31.6302(c)–2A, removed; 31.6302(c)–3, amended; 40.6302(c)–1 thru –3, amended; 301.6302–1, amended; 301.6656–1, amended; 301.7502–2, removed; Electronic Funds Transfer (ETF) of depository taxes (TD 9507) 3,305 Rewards and awards for information relating to violations of in- ternal revenue laws (REG–131151–10) 8,519 Technical Advice Memoranda (TAMs) (RP 2) 1,90 Withholding on wages of nonresident alien employees perform- ing services within the United States (Notice 12) 8,514 ESTATE TAX Letter rulings and information letters issued by Associate Of- fices, determination letters issued by Operating Divisions (RP 1) 1,1;correction(Ann7)5,446 Proposed Regulations: 26 CFR 301.7623–1, amended; rewards and awards for in- formation relating to violations of internal revenue laws (REG–131151–10) 8,519 Rewards and awards for information relating to violations of in- ternal revenue laws (REG–131151–10) 8,519 Technical Advice Memoranda (TAMs) (RP 2) 1,90 EXCISE TAX Biodiesel and alternative fuels, claims for 2010 (Notice 10) 6, 463 Branded prescription drug sales (Notice 9) 6,459 Electronic Funds Transfer (ETF) of depository taxes (TD 9507) 3,305 Letter rulings and information letters issued by Associate Of- fices, determination letters issued by Operating Divisions (RP 1) 1,1;correction(Ann7)5,446 2011–13 I.R.B.vMarch 28, 2011 EXCISE TAX—Cont. Proposed Regulations: 26 CFR 301.7623–1, amended; rewards and awards for in- formation relating to violations of internal revenue laws (REG–131151–10) 8,519 Regulations: 26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended; 31.6302–0 thru –2, –4, amended; 31.6071, amended; 31.6302(c)–2A, removed; 31.6302(c)–3, amended; 40.6302(c)–1 thru –3, amended; 301.6302–1, amended; 301.6656–1, amended; 301.7502–2, removed; Electronic Funds Transfer (EFT) of depository taxes (TD 9507) 3,305 Rewards and awards for information relating to violations of in- ternal revenue laws (REG–131151–10) 8,519 Technical Advice Memoranda (TAMs) (RP 2) 1,90 EXEMPT ORGANIZATIONS Delayed filing season for certain tax-exempt hospitals (Ann 20) 10,542 Disclosure of information to stateofficials regarding tax-exempt organizations (REG–140108–08) 13,591 Electronic Funds Transfer (EFT) of depository taxes (TD 9507) 3,305 Filing thresholds for Form 990 (RP 15) 3,322 Letter rulings: And determination letters: Areas which will not be issued from Associates Chief Counsel and Division Counsel (TE/GE) (RP 3) 1,111 Exemption application determination letter rulings under sections 501, 509, 4940, and 4942 (RP 10) 2,294 Exemption application determination letter rulings under sections 501 and 521 (RP 9) 2,283 And general information letters, procedures (RP 4) 1,123 User fees, request for letter rulings (RP 8) 1,237; correction (Ann 8) 5,446 List of organizations classified as private foundations (Ann 3) 3, 324; (Ann 13) 8,525 Notice requesting comments onsection 501(c)(29) (Notice 23) 13,588 Proposed regulations: 26 CFR 301.6104(c)–1, revised; disclosure of informa- tion to state officials regarding tax-exempt organizations (REG–140108–08) 13,591 Regulations: 26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended; 31.6071, amended; 31.6302–0 thru –2, –4, amended; 31.6302(c)–2A, removed; 31.6302(c)–3, amended; 40.6302(c)–1 thru –3, amended; 301.6302–1, amended; 301.6656–1, amended; 301.7502–2, removed; Electronic Funds Transfer (EFT) of depository taxes (TD 9507) 3,305 Revocations (Ann 2) 3,324;(Ann15)8,526;(Ann17)9,532; (Ann 23) 12,568 Technical advice to IRS employees (RP 5) 1,167 GIFT TAX Letter rulings and information letters issued by Associate Of- fices, determination letters issued by Operating Divisions (RP 1) 1,1;correction(Ann7)5,446 Proposed Regulations: 26 CFR 301.7623–1, amended; rewards and awards for in- formation relating to violations of internal revenue laws (REG–131151–10) 8,519 Rewards and awards for information relating to violations of in- ternal revenue laws (REG–131151–10) 8,519 Technical Advice Memoranda (TAMs) (RP 2) 1,90 INCOME TAX Accounting methods, automatic consent for Blue Cross/Blue Shield and certain other health organizations to change method of accounting for unearned premiums (Notice 4) 2,282 Accrual of liabilities (RP 17) 5,441 Bonds: Qualified Zone Academy Bond limitation for 2011 (RP 19) 6, 465 Capital assets, election for certain musical works (TD 9415) 9, 527 Cost-of-living adjustments for inflation for 2011 (RP 12) 2,297 Credits: Low-income housing tax credit, 2011 population figures used for calculation (Notice 15) 10,539 Debt instruments: Deterioration in financial condition of issuer (TD 9513) 8,501 For publicly traded property, issue price (REG–131947–10) 8,521 Deductions for contributions toqualified nuclear decommission- ing trusts (TD 9512) 7,473 Deductions for medical expenses (Ann 14) 9,532 Definition of omission from gross income (TD 9511) 6,455 Depreciation, 2011 limitationson depreciation deductions for passenger automobiles (RP 21) 12,560 Disciplinary actionsinvolving attorneys,certified public accoun- tants, enrolled agents, and enrolled actuaries (Ann 4) 4,424; (Ann 24) 12,569 Disclosure of return information in connection with written con- tracts among the IRS, whistleblowers, and legal representa- tives of whistleblowers (TD 9516) 13,575 Electronic Funds Transfer (EFT) of depository taxes (TD 9507) 3,305 Emancipation day and tax filingand payment deadlines (Notice 17) 10,540 Employer-provided vehicles, cents-per-mile rule, maximum ve- hicle values for 2011 (RP 11) 4,329;correction(Ann9)7,499 Extension of Fast Track Settlement (FTS) for SB/SE taxpayer pilot program (Ann 5) 4,430 Farmer and fisherman income averaging (TD 9509) 6,450 Foreign earned income exclusion (RP 20) 11,551 Guidance under section 162(m)(6) (Notice 2) 2,260 Health FSA/HRA debit cards, purchase over-the-counter drug purchases (Notice 5) 3,314 March 28, 2011vi2011–13 I.R.B. INCOME TAX—Cont. Housing cost amounts eligible for exclusion or deduction, 2011 (Notice 8) 8,503 Implementation of rules governing tax return preparers (Notice 6) 3,315 Income recognition for advance payments received from the sale of gift cards (RP 18) 5,443 Information reporting: Mortgage assistance programs (Notice 14) 11,544 Requirements for issuers of stock (Notice 18) 11,549 Insurance: Tax-free exchange of life insurance contract that is excepted from the pro rata interest disallowance rule of section 264(f) (RR 9) 12,554 Interest: Investment: Federal short-term, mid-term, and long-term rates for: January 2011 (RR 2) 2,256 February 2011 (RR 4) 6,448 March 2011 (RR 6) 10,537 Rates: Underpayments and overpayments, quarter beginning April 1, 2011 (RR 5) 13,577 Letter rulings: And determination letters, areas which will not be issued from: Associate Chief Counsel andDivision Counsel (TE/GE) (RP 3) 1,111 Associate Chief Counsel (International) (RP 7) 1,233 And information letters issued by Associate Offices, determi- nation letters issued by Operating Divisions (RP 1) 1,1; correction to Rev. Proc. 2011–1 (Ann 7) 5,446 Method of accounting, automatic and non-automatic changes (RP 14) 4,330 Mortgage assistance programs, income exclusion, safe harbor deduction method (Notice 14) 11,544 Penalties, substantial understatement, preparer penalty (RP 13) 3,318 Private foundations, organizations now classified as (Ann 3) 3, 324; (Ann 13) 8,525 Proposed Regulations: 26 CFR 1.263A–0 thru –3, amended; 1.471–3, amended; sales-based royalties and vendor allowances (REG–149335–08) 6,468 26 CFR 1.863–10, added; source of income from qualified fails charges (REG–132724–10) 7,498 26 CFR 1.1273–1, –2, amended; 1.1274–3, amended; 1.1275–2, amended; property traded on an established market (REG–131947–10) 8,521 26 CFR 1.6049–4, revised; 1.6049–5, –6, amended; 1.6049–8, revised; 31.3406(g)–1, revised; guid- ance on reporting interest paid to nonresident aliens (REG–146097–09) 8,516 26 CFR Part 300.0, .4, 5, .6, amended; Parts 300.9 thru .11, added; user fees relative to retirement plan agents (REG–124018–10) 2,301 INCOME TAX—Cont. 26 CFR 301.7623–1, amended; rewards and awards for in- formation relating to violations of internal revenue laws (REG–131151–10) 8,519 Publication: 1220, changes affecting tax year 2010 filing of information returns (Ann 1) 2,304 Real Estate Investment Trust (REIT) distressed debt (RP 16) 5, 440 Regulations: 26 CFR 1.468A–0T thru –9T, removed; 1.468A–0 thru –9, added; 602.101, amended; deductions for contributions to qualified nuclear decommissioning trusts (TD 9512) 7,473 26 CFR 1.863–10T, added; source of income from qualified fails charges (TD 9508) 7,495 26 CFR 1.932–1, amended; source rules involving U.S. pos- sessions and other conforming changes, correction to TD 9391 (Ann 12) 9,532 26 CFR 1.1001–3, amended; modifications of debt instru- ments (TD 9513) 8,501 26 CFR 1.1221–3; added; 1.221–1–3T, removed; time and manner rules for electing capital asset treatment for certain self-created musical works (TD 9514) 9,527 26 CFR 1.1301–1, amended; 1.1301–1T, removed; farmer and fisherman income averaging (TD 9509) 6,450 26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended; 31.6302–0 thru –2, –4, amended; 31.6302(c)–2A, re- moved; 31.6302(c)–3, amended; 40.6302–1T, amended; 40.6302(c)–3, amended; 301.6302–1, amended; 301.6656–1, amended; 301.7502–2, removed; electronic funds transfer of depository taxes (TD 9507) 3,305 26 CFR 1.6012–2, amended; requirement of a statement dis- closing uncertain tax positions (TD 9510) 6,453 26 CFR 301.6103(n)–2, added; 301.6103(n)–2T, removed; disclosure of return information in connection with written contracts among the IRS, whistleblowers, and legal repre- sentatives of whistleblowers (TD 9516) 13,575 26 CFR 301.6229(c)(2)–1, added; 301.6229(c)(2)–1T, re- moved; 301.6501(e)–1, added; 301.6501(e)–1T, removed; definition of omission from gross income (TD 9511) 6,455 Relief for tax return preparers who have pending PTIN applica- tions (Notice 11) 7,497 Reporting requirements for interest paid to nonresident alien in- dividuals (REG–146097–09) 8,516 Requirement of a statement disclosing uncertain tax positions (TD 9510) 6,453 Revocations, exempt organizations (Ann 2) 3,324;(Ann15)8, 526; (Ann 17) 9,532; (Ann 23) 12,568 Rewards and awards for information relating to violations of in- ternal revenue laws (REG–131151–10) 8,519 Sales-based royalties and vendor allowances (REG–149335–08) 6,468 Source of income from qualified fails charges (TD 9508) 7,495; (REG–132724–10) 7,498 Source rules involving U.S. possessions and other conforming changes, correction to TD 9391 (Ann 12) 9,532 Standard Industry Fare Level (SIFL) formula (RR 8) 12,554 2011–13 I.R.B.viiMarch 28, 2011 INCOME TAX—Cont. State and local government bonds, TEB VCAP (Ann 19) 11,553 Tax convention: U.S.-China agreement with respect to professors and teachers (Ann 18) 12,567 Technical Advice Memoranda (TAMs) (RP 2) 1,90 Test of procedures for mediation and arbitration for Offer in Compromise (OIC) and Trust Fund Recovery Penalty (TFRP) cases in appeals (Ann 6) 4,433 User fees relating to enrolled agents and enrolled retirement plan agents (REG–124018–10) 2,301 SELF-EMPLOYMENT TAX Electronic Funds Transfer (EFT) of depository taxes (TD 9507) 3,305 Letter rulings and information letters issued by Associate Of- fices, determination letters issued by Operating Divisions (RP 1) 1,1;correction(Ann7)5,446 Regulations: 26 CFR 1.1462–1, amended; 1.6302–1 thru –4, amended; 31.6071, amended; 31.6302–0 thru –2, –4, amended; 31.6302(c)–2A, removed; 31.6302(c)–3, amended; 40.6302(c)–1 thru –3, amended; 301.6302–1, amended; 301.6656–1, amended; 301.7502–2, removed; Electronic Funds Transfer (ETF) of depository taxes (TD 9507) 3,305 Technical Advice Memoranda (TAMs) (RP 2) 1,90 March 28, 2011viii2011–13 I.R.B. 2011–13 I.R.B.March 28, 2011 March 28, 20112011–13 I.R.B. 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