Internal Revenue Bulletin 2011-29 (PDF rendition): IRS Notices

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 201
1-29
July 18, 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
Notice 2011–55, page 53.
Section 511 of the Hiring Incentives to Restore Employment
Act (the HIRE Act) amended the Code by adding new section
6038D, Information with respect to foreign financial assets.
This notice suspends the information reporting requirements
until the Service releases Form 8938,Statement of Specified
Foreign Financial Assets,and the revised Form 8621,Informa-
tion Return by a Shareholder of a Passive Foreign Investment
Company or Qualified Electing Fund.
ADMINISTRATIVE
Notice 2011–54, page 53.
This notice provides additional administrative relief to persons
whose requirement to file Form TD F 90–22.1,Report of For-
eign Bank and Financial Accounts,(FBAR)toreportsignature
authority over but no financial interest in foreign financial ac-
counts held during calendar year 2009 or earlier calendar
years was properly deferred under Notice 2009–62, 2009–35
I.R.B. 260, or Notice 2010–23, 2010–11 I.R.B. 441. Notice
2010–23 modified and supplemented.
Notice 2011–56, page 54.
Basis of stock.This notice provides interim guidance to tax-
payers under section 1012 of the Code on issues relating to
the basis of stock that may be subject to broker reporting un-
der section 6045.
Announcement 2011–40, page 56.
Optional standard mileage rates.This announcement ad-
vises the public that the Internal Revenue Service is revising the
optional standard mileage rates for substantiating the costs of
operating an automobile for business, medical, or moving pur-
poses. Beginning July 1, 2011, the rates are 55.5 cents for
business use of an automobile and 23.5 cents for the cost of
using an automobile as a medical or moving expense. Notice
2010–88 modified.
Finding Lists begin on page ii.

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.
July 18, 20112011–29 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
FBAR Filing Requirements
— Additional Administrative
Relief For Individuals Whose
Filing Deadline Was Extended
Under Notice 2010–23
Notice 2011–54
This notice provides additional admin-
istrative relief to persons whose require-
ment to file Form TD F 90–22.1,Report
of Foreign Bank and Financial Accounts,
(FBAR) to report signature authority over
foreign financial accounts held during
calendar year 2009 or earlier calendar
years was properly deferred under Notice
2009–62, 2009–35 I.R.B. 260, or Notice
2010–23, 2010–11 I.R.B. 441.
On August 31, 2009, the Department
of the Treasury and the Internal Revenue
Service published Notice 2009–62, which,
in part, extended the filing deadline for
persons with no financial interest in a
foreign financial account but with signa-
ture or other authority over that account
(hereinafter referredto as “signature au-
thority”) for the 2008 or earlier calendar
years. In Notice 2010–23, the Depart-
ment of the Treasury and the IRS further
extended relief to persons whose filing
deadline was properlydeferredbyNotice
2009–62 and provided a new filing dead-
line to June 30, 2011, to report signature
authority over, but no financial interest
in, foreign financial accounts for calendar
year 2009 or earlier calendar years. The
extensions were provided to allow the
Treasury Department time to develop
comprehensive FBAR guidance.
On February 24, 2011, the Finan-
cial Crimes Enforcement Network
(FinCEN) published final regulations
(76 FR 10234) amending the Bank
Secrecy Act implementing regulations
regarding FBARs, found at 31 CFR
1010.350 (formerly 31 CFR 103.24).
The regulations became effective on
March 28, 2011, and apply to FBARs
required to be filed by June 30, 2011,
with respect to foreign financial accounts
maintained in calendar year 2010, as well
as to FBARs for subsequent calendar
years. The final regulations also provide
that individuals who properly deferred
their FBAR filing obligations pursuant to
Notice 2010–23 may apply the provisions
of the final regulations in determining
their FBAR filing requirements for reports
due June 30, 2011, with respect to foreign
financial accounts maintained in calendar
years beginning before 2010. In March
2011, the IRS released a revised FBAR
form with accompanyinginstructions that
reflect the amendments made by the final
FBAR regulations.
The IRS and FinCEN recently have
been informed that individuals with sig-
nature authority over, but no financial
interest in, foreign financial accounts are
having difficulty compiling the informa-
tion needed to file complete and accurate
FBARs with respect to the 2009 or earlier
calendar years by the June 30, 2011 dead-
line, as previously extended by Notice
2009–62 or Notice 2010–23. Accordingly,
the IRS and FinCEN provide the following
additional administrative relief:
Persons having signature authority
over, but no financial interest in, a for-
eign financial account in 2009 or earlier
calendar years for which the reporting
deadline was extended by Notice 2009–62
or Notice 2010–23 will now have until
November 1, 2011, to file FBARs with
respect to those accounts. The deadline
for reporting signature authority over, or a
financial interest in, foreign financial ac-
counts for the 2010 calendar year remains
June 30, 2011.
The administrative relief provided in
this notice does not limit the relief pro-
vided in FinCEN’s Notice 2011–1, which
was released on May 31, 2011, and re-
vised on June 6, 2011. A copy of revised
FinCEN Notice 2011–1 may be found at
www.fincen.gov. Additionally, the admin-
istrative relief provided in this notice does
not affect the requirements to provide in-
formation or file FBARs in connection
with the IRS’s 2009 Offshore Voluntary
Disclosure Program or the 2011 Offshore
Voluntary Disclosure Initiative. Nor does
this notice alter the deadlines for electing
to participate in, or fulfilling the sub-
mission requirements of, the Offshore
Voluntary Disclosure Program or the Off-
shore Voluntary Disclosure Initiative.
EFFECT ON OTHER DOCUMENTS
Notice 2010–23 is modified and supple-
mented.
The principal author of this notice
is Emily M. Lesniak of the Office of
Associate Chief Counsel (Procedure
and Administration).For further
information regarding this notice, contact
Emily M. Lesniak at (202) 622–4570 (not
a toll-free call).
Information Reporting With
Respect to Foreign Financial
Assets and Certain Interests
in a PFIC — Suspension
of Information Reporting
Requirements Until the
Internal Revenue Service
Releases Form 8938,
Statement of Specified
Foreign Financial Assets,
and Revised Form 8621,
InformationReturnbya
Shareholder of a Passive
Foreign Investment Company
or Qualified Electing Fund
Notice 2011–55
I.Background and Purpose
Section 511 of the Hiring Incentives
to Restore Employment Act, Pub. L.
No. 111–147, 124 Stat. 71, enacted on
March 18, 2010 (the HIRE Act), amended
the Internal Revenue Code by adding
new section 6038D, Information With
Respect to Foreign Financial Assets.
Section 6038D applies to taxable years
beginning after March 18, 2010. Under
section 6038D(a), any individual who
during the taxable year holds an interest
in any specified foreign financial asset is
required to attach to his or her income tax
return for the taxable year certain required
information with respect to each specified
foreign financial asset if the aggregate
value of all of the individual’s specified
foreign financial assets exceeds $50,000.
Section 521 of the HIRE Act further
amended the Internal Revenue Code by
2011–29 I.R.B.53July 18, 2011

adding new section1298(f). Section
1298(f) is effective on March 18, 2010.
Under section 1298(f), United States per-
sons who are shareholders of a passive
foreign investment company (PFIC) are
required to file an annual report contain-
ing such information as the Secretary may
require. Prior to the enactment of section
1298(f), PFIC shareholders were required
to file Form 8621 in certain circumstances.
On April 6, 2010, the Department of the
Treasury and the Internal Revenue Ser-
vice (IRS) published Notice 2010–34,
“PFIC Shareholder Reporting Under New
Section 1298(f) for Tax Years Beginning
Before March 18, 2010,” 2010–17 I.R.B.
612, which provided that shareholders of
a PFIC that were not otherwise required to
file Form 8621 annually prior to the enact-
ment of section 1298(f) would not be re-
quired to file an annual report as a result of
the addition of section 1298(f) for taxable
years beginning before March 18, 2010.
The Department of the Treasury and the
IRS intend to issue regulations under sec-
tions 6038D and 1298(f), and the IRS in-
tends to releaseForm 8938, “Statement of
Specified Foreign Financial Assets,”and
a revised Form 8621,“Information Re-
turn by a Shareholder of a Passive Foreign
Investment Company or Qualified Elect-
ing Fund,”modified to reflect the require-
ments of section 1298(f). An individual
required to report an interest in one or
more specified foreign financial assets un-
der section 6038D will be required to at-
tach Form 8938 to the individual’s income
tax return for the taxable year to report
the required information. A PFIC share-
holder required to report information un-
der section 1298(f) will be required to at-
tach the revised Form 8621 to the PFIC
shareholder’s income tax return or infor-
mation return (e.g., Form 1065,“U.S. Re-
turn of Partnership Income”)forthetax-
able year to report the required informa-
tion.
II.Interim Guidance
Individuals with reporting requirements
under section 6038D may have to file an
income tax return for a taxable year be-
fore the IRS releases Form 8938. This no-
tice suspends the requirement for these in-
dividuals to attach Form 8938 to income
tax returns that are filed before the release
of Form 8938.
Similarly, PFIC shareholders that
would not be required to file Form 8621
under the current Instructions to such
form may, under section 1298(f), have
to file an income tax return or informa-
tion return (e.g., Form 1065) for a taxable
year beginning on or after March 18,
2010, but before the IRS releases revised
Form 8621. Pending the release of the
revised Form 8621, modified to reflect
the requirements of section 1298(f), this
notice suspends the section 1298(f) re-
porting requirement for taxable years
beginning on or after March 18, 2010, for
PFIC shareholders that are not otherwise
required to file Form 8621 as provided
in the current Instructions to Form 8621.
PFIC shareholders with Form 8621
reporting obligations as provided in the
current Instructions to Form 8621 (e.g.,
upon disposition of stock of a PFIC or
with respect to a qualified electing fund
under section 1293) must continue to file
the current Form 8621 with an income
tax or information return filed prior to the
release of the revised Form 8621.
Following the release of Form 8938 or
revised Form 8621, individuals and PFIC
shareholders for which the filing of Form
8938 or 8621 has been suspended under
this notice for a taxable year (suspended
taxable year) will be required to attach
Form 8938, Form 8621, or both, as appro-
priate, for the suspended taxable year to
their next income tax or information return
required to be filed with the IRS.
Under section 6501(c)(8), the period of
limitation for assessment of tax with re-
spect to periods for which reporting is re-
quired under sections 6038D or 1298(f)
will not expire before three years after
the date on which the IRS receives Forms
8938 or 8621, as appropriate, for the tax-
able year. A Form 8938 or 8621 filed for a
suspended taxable year with a timely filed
income tax or information return (taking
into account extensions) as required by this
notice will be treated as having been filed
on the date that the income tax or informa-
tion return for the suspended taxable year
was filed. The failure to furnish Forms
8938 and 8621 for the suspended taxable
year as described in this notice may result
in the extension of the period of limitation
for the suspended taxable year under sec-
tion 6501(c)(8), and penalties may apply.
Compliance with sections 6038D and
1298(f) does not relieve a person of the
responsibility to file Form TD F 90–22.1,
“Report of Foreign Bank and Financial Ac-
counts,” (FBAR) if the FBAR is otherwise
required to be filed.
The principal author of this notice is
Joseph Henderson of the Office of the
Associate Chief Counsel (International).
For further information regarding this
notice as it relates to section 6038D,
please contact Mr. Henderson at (202)
622–3880 (not a toll-free call). For further
information regarding this notice as it
relates to section 1298(f), please contact
Susan E. Massey at (202) 622–3840 (not a
toll-free call).
Stock Basis
Notice 2011–56
PURPOSE
This notice provides interim guidance
under § 1012 of the Internal Revenue Code
on issues relating to the basis of stock.
BACKGROUND
Under § 1.1012–1(e) of the Income Tax
Regulations, taxpayers may use the aver-
age basis method to determine the basis of
stock in a regulated investment company
(RIC). Section 403 of the Energy Improve-
ment and Extension Act of 2008, Div. B
of Pub. L. No. 110–343, 122 Stat. 3765
(the Act), amended § 1012 to allow taxpay-
ers to average the basis of stock acquired
after December 31, 2010, in connection
with a dividend reinvestment plan (DRP),
as well. A taxpayer that does not use the
average basis method determines the basis
of stock under § 1012(a) by its cost.
The Act also amended § 6045 to re-
quire brokers to report, upon the sale of
stock, adjusted basis of the stock sold and
whether gain or loss is long-term or short-
term, effective generally for stock acquired
after December 31, 2010, and for RIC or
DRP stock acquired after December 31,
2011.
Final regulations implementing
these amendments were published on
October 18, 2010, T.D. 9504, 2010–47
I.R.B. 670, 75 F.R. 64072. Thereafter,
public stakeholders requested clarification
or raised new issues. The Internal Revenue
Service and Treasury Department intend
to publish proposed regulations addressing
July 18, 2011542011–29 I.R.B.

some of these issues. Taxpayers may
rely on the guidance provided in this
notice pending publication of superseding
guidance.
INTERIM GUIDANCE
Change from Broker Default Average
Basis Method
A stakeholder suggested that, when a
taxpayer changes from a broker’s default
average basis method to the cost basis
method, the basis of the shares should
revert to the cost basis under certain cir-
cumstances.
Section 6045(g)(2)(B)(i)(II) provides
that, for purposes of broker reporting, the
adjusted basis of RIC or DRP stock is
determined by a broker’s default method
unless a taxpayer elects another method.
Section 1.1012–1(e)(2)(i) provides that,
unless a taxpayer elects another method,
the basis of RIC or DRP stock is deter-
mined by the broker’s default method.
Section 1.1012–1(e)(9)(i) provides that,
beginning in 2012, a taxpayer elects the av-
erage basis method by notifying a broker
in writing. Under § 1.1012–1(e)(9)(iii),
a taxpayer that wants to revoke its aver-
age basis method election must revoke the
election within one year after making the
election or, if earlier, by the date of the first
disposition of the stock. A broker may ex-
tend the one-year period but not beyond
the first disposition of the stock. After a
revocation, the basis of the stock reverts to
the cost basis.
After the revocation period has expired,
a taxpayer may change from the average
basis method to the cost method at any
time, but only for stock acquired after the
date of the change (the change is prospec-
tive). After the change, the basis of the
stock that was averaged remains averaged.
Section 1.1012–1(e)(9)(iv).
Section 1.1012–1(e)(9)(i) provides that
a taxpayer has not made a basis election
if (1) the taxpayer fails to choose a ba-
sis determination method, and (2) basis is
determined by a broker’s default method.
Section 1.1012–1(e)(9)(v),Example 2,il-
lustrates that, because averaging under a
broker’s default method is not a taxpayer’s
election, a taxpayer’s change from a bro-
ker’s default averaging method to the cost
method is prospective and stock acquired
before the change retains the averaged ba-
sis.
To provide consistency between revok-
ing a taxpayer’s average basis election and
changing from a broker’s default average
basis method, the proposed regulations are
expected to provide that, when a taxpayer
changes from a broker’s default averaging
method for RIC or DRP stock to the cost
basis method, the basis of the stock reverts
to the cost basis if the taxpayer requests the
change by the earlier of (1) one year af-
ter receiving notice of the broker’s default
method, or (2) the date of the first sale,
transfer, or other disposition of the stock.
A broker may extend the one-year period,
but not later than the date of the first sale,
transfer, or disposition of the stock.
To determine the beginning of the one-
year period, a broker using the average
basis method as a default method must
use reasonable means to notify taxpayers.
Reasonable means may be mailings, cir-
culars, or electronic mail sent separately
or included in a taxpayer’s account state-
ment, or other means reasonably calcu-
lated to provide actual notice. The notice
must identify the securities subject to the
broker’s default average basis method.
Ten Percent Reinvestment Rule and
Fractional Shares
Under § 1012(d)(4)(A), a DRP is an
arrangement under which dividends are
reinvested in identical stock. Section
1.1012–1(e)(6)(i) provides that a plan, ar-
rangement, or program qualifies as a DRP
if the written plan documents require that
at least 10 percent of every dividend on
any share of stock is reinvested in identical
stock.
A stakeholder asked if a plan that pays
only cash in lieu of fractional shares meets
the 10 percent requirement if the dividends
on some shareholders’ stock are insuffi-
cient to acquire at least one whole share of
identical stock. For example, if a share-
holder in a plan receives a dividend of
$30.00 but the price of one share of stock
exceeds $30.00, the shareholder will not be
able to reinvest 10 percent and will receive
the dividend in cash.
It is expected that the proposed regula-
tions will clarify that a DRP does not fail
the 10 percent reinvestment requirement
because it pays cash in lieu of fractional
shares when the amount of a dividend is in-
sufficient for some shareholders to acquire
stock.
Lot Selection Methods Across Accounts
Section 1012(c)(1) provides that the
“conventions” prescribed in the § 1012
regulations apply to stock disposed of after
certain dates on an account-by-account ba-
sis. The legislative history identifies these
“conventions” as first-in, first-out (FIFO),
specific identification, and average ba-
sis. H. Rep. No. 606, 110
th
Cong., 2d
Sess. 62 (2008). However, § 1.1012–1(e)
provides account-by-account rules only
for averaged stock. The proposed reg-
ulations are expected to clarify that the
lot selection methods, such as FIFO and
specific identification, also apply on an
account-by-account basis.
REQUEST FOR COMMENTS
Comments are requested on is-
sues arising under this notice. Com-
ments should be submitted in writ-
ing on or before August 8, 2011, and
should include a reference to Notice
2011–56. Comments may be submitted to
CC:PA:LPD:PR (Notice 2011–56), Room
5203, Internal Revenue Service, P.O.
Box7604,BenFranklinStation,Wash-
ington, DC 20044, or electronically to
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2011–56” in
the subject line of any electronic
communications.
Submissions may be hand delivered
Monday through Friday between the hours
of 8 a.m. and 4 p.m. to CC:PA:LPD:PR
(Notice 2011–56), Courier’s Desk, Inter-
nal Revenue Service, 1111 Constitution
Avenue, NW, Washington, DC 20224. All
comments are available for public inspec-
tion and copying.
DRAFTING INFORMATION
The principal authors of this notice are
Amy Pfalzgraf and Edward C. Schwartz of
the Office of the Associate Chief Counsel
(Income Tax & Accounting). For further
information regarding this notice, please
contact Mr. Schwartz at (202) 622–4960
(not a toll-free call).
2011–29 I.R.B.55July 18, 2011

Part IV. Items o
fGeneralInterest
Optional Stan
dard Mileage
Rates
Announcement
2011–40
This announc
ement informs taxpayers
that the Inte
rnal Revenue Service is mod-
ifying Notice
2010–88, 2010–51 I.R.B.
882, by revisi
ng the optional standard
mileage rates
for computing the deductible
costs of opera
ting an automobile for busi-
ness, medical
, or moving expense pur-
poses and for
determining the reimbursed
amount of the
se expenses that is deemed
substantiate
d. This modification results
from recent in
creases in the price of fuel.
The revised st
andard mileage rates are:
(1) Business
55.5 cents per mile
(2) Medical and moving
23.5 cents pe
rmile
The mileage rate that applies to the
deduction for charitable contributions is
fixed under § 170(i) of the Internal Rev-
enue Code at 14 cents per mile.
The revised standard mileage rates set
forth in this announcement apply to de-
ductible transportation expenses paid or
incurred for business, medical, or moving
expense purposes on or after July 1, 2011,
and to mileage allowances that are paid
both(1)toanemployeeonorafterJuly1,
2011, and (2) for transportation expenses
paid or incurred by the employee on or af-
ter July 1, 2011.
The standard mileage rates set forth
in Notice 2010–88 continue to apply to
deductible transportation expenses paid or
incurred for business, medical, or moving
expense purposes before July 1, 2011,
and to mileage allowances paid (1) to
an employee before July 1, 2011, or (2)
with respect to transportation expenses
paid or incurred by the employee before
July 1, 2011. All other provisions of
Notice 2010–88 remain in effect.
EFFECT ON OTHER DOCUMENTS
Notice 2010–88 is modified.
DRAFTING INFORMATION
The principal author of this announce-
ment is Bernard P. Harvey of the Office
of Associate Chief Counsel (Income Tax
and Accounting). For further information
regarding this announcement, contact
Mr. Harvey at (202) 622–4930 (not a
toll-free call).
July 18, 2011562011–29 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.
2011–29 I.R.B.iJuly 18, 2011

Numerical Finding List
1
Bulletins 2011–27 through 2011–29
Announcements:
2011-37, 2011-27 I.R.B.37
2011-38, 2011-28 I.R.B.45
2011-39, 2011-28 I.R.B.46
2011-40, 2011-29 I.R.B.56
2011-41, 2011-28 I.R.B.47
Notices:
2011-47, 2011-27 I.R.B.34
2011-50, 2011-27 I.R.B.35
2011-51, 2011-27 I.R.B.36
2011-54, 2011-29 I.R.B.53
2011-55, 2011-29 I.R.B.53
2011-56, 2011-29 I.R.B.54
Proposed Regulations:
REG-137128-08, 2011-28 I.R.B.43
Revenue Rulings:
2011-14, 2011-27 I.R.B.31
Treasury Decisions:
9527, 2011-27 I.R.B.1
9528, 2011-28 I.R.B.38
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2011–1 through 2011–26 is in Internal Revenue Bulletin
2011–26, dated June 27, 2011.
July 18, 2011ii2011–29 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2011–27 through 2011–29
Notices:
2010-23
Modified and supplemented by
Notice 2011-54, 2011-29 I.R.B.53
2010-88
Modified by
Ann. 2011-40, 2011-29 I.R.B.56
Proposed Regulations:
REG-118761-09
Hearing scheduled by
Ann. 2011-38, 2011-28 I.R.B.45
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2011–1 through 2011–26 is in Internal Revenue Bulletin 2011–26, dated June 27, 2011.
2011–29 I.R.B.iiiJuly 18, 2011

July 18, 20112011–29 I.R.B.

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