Internal Revenue Bulletin 2011-12 (PDF rendition): IRS Revenue Procedures

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
1-12
March 21, 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. 2011–8, page 554.
Fringe benefits aircraft valuation formula.For purposes
of regulations section 1.61–21(g), relating to the rule for valu-
ing non-commercial flights on employer-provided aircraft, the
Standard Industry Fare Level (SIFL) cents-per-mile rates and ter-
minal charge in effect for the first half of 2011 are set forth.
Rev. Rul. 2011–9, page 554.
Life insurance contracts.This ruling concludes that if a busi-
ness receives a life insurance contract in a tax-free exchange
for a life insurance contract that is excepted from theprorata
interest disallowance rule of section 264(f)(1) of the Code, the
new contract received in the exchange must be tested to de-
termine whether it, too, is excepted from that rule. Exception
from theproratainterest disallowance rule is not an attribute
that carries over to a contract received in a tax-free exchange.
Rev. Proc. 2011–21, page 560.
Automobile owners and lessees.This procedure provides
the depreciation deduction limitations for owners of passenger
automobiles (including trucks and vans) first placed in service
during calendar year 2011 and amounts to be included in in-
come by lessees of passenger automobiles first leased during
calendar year 2011. Rev. Proc. 2010–18 amplified and mod-
ified.
EMPLOYEE PLANS
Notice 2011–22, page 557.
Weighted average interest rate update; corporate bond
indices; 30-year Treasury securities; segment rates.
This notice contains updates for the corporate bond weighted
average interest rate for plan years beginning in March 2011;
the 24-month average segment rates; the funding transitional
segment rates applicable for March 2011; and the minimum
present value transitional rates for February 2011.
Announcement 2011–21, page 567.
Replacement of Schedule SSA (Form 5500) with Form
8955–SSA.This announcement designates Form 8955–SSA,
Annual Registration Statement Identifying Separated Partici-
pants With Deferred Vested Benefits, as the form to be used
to satisfy the reporting requirements of section 6057(a) of the
Code for plan years beginning on or after January 1, 2009, and
sets forth the due dates for filing the Form 8955–SSA for the
2009 plan year and subsequent plan years.
EXEMPT ORGANIZATIONS
Announcement 2011–23, page 568.
The IRS has revoked its determination that B & B Scholar Foun-
dation, Inc., of Titusville, FL; Gentle Touch Ministries of New-
port, TN; Harbour Credit Counseling Services, Inc., of Virginia
Beach, VA; Initiatives for Community Development, Inc., of New
York, NY; Past Presidents Club, Inc., of Houma, LA; Reproduc-
tive and Child Health Alliance of Henderson, NV; School in the
Clouds Assisi of Coronado, CA; Waukesha Kennel Club, Inc.,
of Mukwonago, WI; and Xelan Foundation, Inc., of Tampa, FL,
qualify as organizations described in sections 501(c)(3) and
170(c)(2) of the Code.
(Continued on the next page)
Announcements of Disbarments and Suspensions begin on page 569.
Finding Lists begin on page ii.

TAX CONVENTIONS
Announcement 2011–18, page 567.
This document is a Competent Authority Agreement entered
into on November 24, 2010, by the competent authorities of
the United States of America and the People’s Republic of China
with respect to the taxation of professors and teachers under
the U.S.-China income tax treaty and protocol.
March 21, 20112011–12 I.R.B.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly and may be obtained from the
Superintendent of Documents on a subscription basis. Bulletin
contents are compiled semiannually into Cumulative Bulletins,
which are sold on a single-copy basis.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application of
the tax laws, including all rulings that supersede, revoke, mod-
ify, or amend any of those previously published in the Bulletin.
All published rulings apply retroactively unless otherwise indi-
cated. Procedures relating solely to matters of internal man-
agement are not published; however, statements of internal
practices and procedures that affect the rights and duties of
taxpayers are published.
Revenue rulings represent the conclusions of the Service on the
application of the law to the pivotal facts stated in the revenue
ruling. In those based on positions taken in rulings to taxpayers
or technical advice to Service field offices, identifying details
and information of a confidential nature are deleted to prevent
unwarranted invasions of privacy and to comply with statutory
requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—19
86 Code.
This part i
ncludes rulings and decisions based on provisions of
the Intern
al Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B, Leg-
islation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Secre-
tary (Enforcement).
Part IV
.—Items of General Interest.
This par
t includes notices of proposed rulemakings, disbar-
ment an
d suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The c
ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402.
2011–12 I.R.B.March 21, 2011

March 21, 20112011–12 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 61.—Gross Income
Defined
26 CFR 1.61–21: Taxation of fringe benefits.
Fringe benefits aircraft valuation for-
mula.For purposes of regulations section
1.61–21(g), relating to the rule for valuing
non-commercial flights on employer-pro-
vided aircraft, the Standard Industry Fare
Level (SIFL) cents-per-mile rates and ter-
minal charge in effect for the first half of
2011 are set forth.
Rev. Rul. 2011–8
For purposes of the taxation of fringe
benefits under section 61 of the Inter-
nal Revenue Code, section 1.61–21(g) of
the Income Tax Regulations provides a
rule for valuing noncommercial flights
on employer-provided aircraft. Section
1.61–21(g)(5) provides an aircraft valua-
tion formula to determine the value of such
flights. The value of a flight is determined
under the base aircraft valuation formula
(also known as the Standard Industry Fare
Level formula or SIFL) by multiplying
the SIFL cents-per-mile rates applicable
for the period during which the flight was
taken by the appropriate aircraft multiple
provided in section 1.61–21(g)(7) and then
adding the applicable terminal charge. The
SIFL cents-per-mile rates in the formula
and the terminal charge are calculated by
the Department of Transportation and are
reviewed semi-annually.
The following chart sets forth the termi-
nal charge and SIFL mileage rates:
2
Period During Which
the Flight Is Taken
Terminal
Charge
SIFL Mileage
Rates
1/1/11 - 6/30/11
$40.90
Up to 500 miles
= $.2237 per mile
501-1500 miles
= $.1706 per mile
Over 1500 miles
= $.1640 per mile
DRAFTING INFORMATION
The principal author of this revenue
ruling is Kathleen Edmondson of the
Office of Division Counsel/Associate
Chief Counsel (Tax Exempt and Govern-
ment Entities). For further information
regarding this revenue ruling, contact
Ms. Edmondson at (202) 622–0047 (not a
toll-free call).
Section 264.—Certain
Amounts Paid in Connection
with Insurance Contracts
(
Also § 1035.)
Life insurance contracts.This ruling
concludes that if a business receives a
life insurance contract in a tax-free ex-
change for a life insurance contract that
is excepted from thepro ratainterest
disallowance rule of section 264(f)(1) of
the Code, the new contract received in
the exchange must be tested to determine
whether it, too, is excepted from that rule.
Exception from thepro ratainterest disal-
lowance rule is not an attribute that carries
over to a contract received in a tax-free
exchange.
Rev. Rul. 2011–9
ISSUE
Does thepro ratainterest expense dis-
allowance rule of § 264(f)(1) of the Inter-
nal Revenue Code apply to Old Policy and
to New Policy in the situations described
below?
FACTS
Situation 1. Taxpayer is a corporation
engaged in a trade or business that has
substantial indebtedness on which it in-
curs interest expense. On January 3, 2000,
Taxpayer purchased a life insurance pol-
icy (“Old Policy”) covering the life ofA,
an employee of Taxpayer, as of that date.
Awas not a 20-percent owner, officer, or
director of Taxpayer, and was the only in-
dividual covered by Old Policy. On Jan-
uary 3, 2011, Taxpayer received a new
life insurance policy (“New Policy”) cov-
ering the life ofAas of January 3, 2011,
in exchange for Old Policy in a transaction
that qualified for non-recognition of gain
or loss under § 1035. New Policy also cov-
ers only the life ofAand has the same death
benefit as Old Policy.Aremained an em-
ployee of Taxpayer as of January 3, 2011.
Both Old Policy and New Policy are life
insurance contracts as defined in § 7702.
Situation 2. The facts are the same as in
Situation 1, except that on January 4, 2010,
Aterminated employment with Taxpayer.
LAW
Under § 264(f)(1), no deduction is al-
lowed for that portion of the taxpayer’s in-
terest expense that is allocable to unbor-
rowedpolicycashvalues.
Section 264(f)(7) defines “interest ex-
pense” as the aggregate amount allowable
to the taxpayer as a deduction for interest
(within the meaning of § 265(b)(4)) for the
taxable year (determined without regard to
§§ 264(f), 265(b) and 291).
Section 264(f)(3) defines “unborrowed
policy cash value” as, with respect to any
life insurance policy or annuity or endow-
ment contract, the excess of (A) the cash
surrender value of the policy or contract
2011–12 I.R.B.554March 21, 2011

determined without regard to any surren-
der charge, over (B) the amount of any
loan with respect to the policy or contract.
If the amount described in (A) with re-
spect to any policy or contract does not rea-
sonably approximate its actual value, the
amount taken into account under (A) is
the greater of the amount of the insurance
company liability or the insurance com-
pany reserve with respect to the policy or
contract (as determined for purposes of the
annual statement approved by the National
Association of Insurance Commissioners)
or is another amount as determined by the
Secretary.
Section 264(f)(2) states that, for pur-
poses of § 264(f)(1), the portion of the
taxpayer’s interest expense that is alloca-
ble to unborrowed policy cash values is an
amount that bears the same ratio to that
interest expense as the taxpayer’s average
unborrowed policy cash values of life in-
surance policies, and annuity and endow-
ment contracts, issued after June 8, 1997,
bears to the sum of (i) in the case of assets
of the taxpayer that are life insurance poli-
cies or annuity or endowment contracts,
the average unborrowed policy cash val-
ues of those policies and contracts, and (ii)
in the case of any other assets of the tax-
payer, the average adjusted bases (within
the meaning of § 1016) of those assets.
Section 264(f)(4)provides an excep-
tion to thepro ratainterest expense dis-
allowance rule of § 264(f)(1) for certain
policies and contracts. Under § 264(f)(4),
§ 264(f)(1) does not apply to any policy or
contract owned by an entity engaged in a
trade or business if the policy or contract
covers only one individual and if that in-
dividual is (at the time first covered by the
policy or contract) (i) a 20-percent owner
of the entity, or (ii) an individual (not de-
scribed in (i)) who is an officer, director, or
employee of the trade or business.
Section 264(f) applies to contracts is-
sued after June 8, 1997, in taxable years
ending after that date. For this purpose,
any material increase in the death benefit
or other material change in the contract is
treated as a new contract. Taxpayer Relief
Act of 1997, Pub. L. No. 105–34, § 1084.
Section 1035(a)(1) provides that no
gain or loss is recognized on the exchange
of a life insurance contract for another
life insurance contract, or for an endow-
ment or annuity contract or for a qualified
long-term care insurance contract. The
legislative history of § 1035 explains that
§ 1035 provides non-recognition treat-
ment for taxpayers who have “merely
exchanged one insurance policy for an-
other better suited to their needs and who
have not actually realized gain.” H. Rep.
1337, 83d Cong., 2d Sess. 81 (1954). Un-
der § 1.1035–1, the contracts exchanged
must relate to the same insured.
ANALYSIS
Old Policy
In bothSituation 1andSituation
2,Awas an employee of Taxpayer on
January 3, 2000, which was the date as of
whichAwas first covered by Old Policy.
Awas the only individual covered by Old
Policy. Under the exception provided
by § 264(f)(4)(A), thepro ratainterest
expense disallowance rule of § 264(f)(1)
did not apply to Old Policy in either
situation.
New Policy
In general, a contract that is received in
exchange for an existing contract is treated
as a new contract issued on the date of the
exchange for purposes of testing the con-
tract’s qualification as a life insurance con-
tract under § 7702.See1 Staff of Senate
Comm. on Finance, 98th Cong., 2d Sess.,
Deficit Reduction Act of 1984, Explana-
tion of Provisions Approved by the Com-
mittee on March 21, 1984, at 579 (Comm.
Print 1984); Notice 2006–95, 2006–2 C.B.
848, section 5.01. Consistently, the ex-
change of a life insurance contract for an-
other life insurance contract is treated as a
material change, and the contract received
in the exchange is treated as a new con-
tract, for purposes of applying the 7-pay
test of § 7702A(b) to determine whether
the contract is a modified endowment con-
tract (MEC). 2 H.R. Conf. Rep. No.
1104, 100th Cong., 2d Sess. II–98 (1988),
1988–3 C.B. 588.Cf.1 Staff of Senate
Comm. on Finance, 98th Cong., 2d Sess.,
Deficit Reduction Actof 1984, Explanation
of Provisions Approved by the Committee
on March 21, 1984, at 540 (Comm. Print
1984) (date of issuance of a life insurance
contract for purposes of determining the
tax reserve method applicable to the con-
tract under § 807(d)(2) is the date shown
on the policy form).
In some circumstances, the issue date
or other attributes of a contract carry over
in a § 1035 exchange pursuant to an ex-
plicit rule. For example, in the case of
§ 101(j) Congress grandfathered an em-
ployer-owned life insurance contract that
is received after August 17, 2006, in a
§ 1035 exchange for a contract that was
issued on or before that date. Pension
Protection Act of 2006, § 863(a), Pub.
L. No. 109–280.See alsoRev. Rul.
92–95, 1992–2 C.B. 43 (for purposes of
§ 72(q)(2)(I) and 72(u)(4), the “date of pur-
chase” of an annuity contract acquired in a
§ 1035 exchange for another annuity con-
tract is the date of purchase of the annuity
contract that was exchanged for the new
contract). Congress did not provide a rule
under which the status of the insured as
an employee “at the time first covered”
for purposes of § 264(f)(4)(A) would carry
over from a contract given up in a § 1035
tax-free exchange to a contract received in
such an exchange, even though the status
of the insured as an employee is material
to the purpose and application of the ex-
ception provided by § 264(f)(4).
InSituation 1,Awas an employee of
Taxpayer on January 3, 2011, which was
the date as of which A was first covered
by New Policy.Awas the only individ-
ual covered by New Policy. Under the ex-
ception provided by § 264(f)(4)(A), thepro
ratainterest expense disallowance rule of
§ 264(f)(1) did not apply to New Policy in
Situation 1.
InSituation 2,Awas not an employee
of Taxpayer on January 3, 2011, which was
thedateasofwhichAwas first covered by
New Policy, nor wasAa 20-percent owner,
officer, or director of Taxpayer. Accord-
ingly, New Policy does not qualify for the
exceptionprovidedby§264(f)(4)(A).The
fact thatAwas an employee of Taxpayer at
the time first covered by Old Policy (Jan-
uary 3, 2000) does not change this result.
HOLDINGS
In bothSituation 1andSituation 2,Old
Policy qualified for the exception pro-
vided by § 264(f)(4). Therefore, thepro
ratainterest expense disallowance rule of
§ 264(f)(1) did not apply to Old Policy.
In
Situation 1, New Policy qualifies
for the exception provided by § 264(f)(4).
Therefore, thepro ratainterest expense
March 21, 20115552011–12 I.R.B.

disallowance rule of § 264(f)(1) does not
apply to New Policy.
InSituation 2, New Policy does not
qualify for the exception provided by
§ 264(f)(4). Therefore, thepro rata
interest expense disallowance rule of
§ 264(f)(1) applies to New Policy.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Rebecca L. Baxter of the Office of
Associate Chief Counsel (Financial Insti-
tutions & Products). For further infor-
mation regarding this revenue ruling, con-
tact Ms. Baxter at (202) 622–3970 (not a
toll-free call).
2011–12 I.R.B.556March 21, 2011

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2011–22
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code as in ef-
fect for plan years beginning before 2008.
It also provides guidance on the cor-
porate bond monthly yield curve (and
the corresponding spot segment rates),
and the 24-month average segment rates
under § 430(h)(2). In addition, this no-
tice provides guidance as to the interest
rate on 30-year Treasury securities un-
der § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008, the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I), and the min-
imum present value segment rates under
§ 417(e)(3)(D) as in effect for plan years
beginning after 2007.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004 and by
the Pension Protection Act of 2006 (PPA),
provide that the interest rates used to cal-
culate current liability and to determine
the required contribution under § 412(l)
for plan years beginning in 2004 through
2007 must be within a permissible range
based on the weighted average of the rates
of interest on amounts invested conser-
vatively in long term investment grade
corporate bonds during the 4-year period
ending on the last day before the beginning
of the plan year.
Notice 2004–34, 2004–1 C.B. 848, pro-
vides guidelines for determining the cor-
porate bond weighted average interest rate
and the resulting permissible range of in-
terest rates used to calculate current liabil-
ity. That notice establishes that the corpo-
rate bond weighted average is based on the
monthly composite corporate bond rate de-
rived from designated corporate bond in-
dices. The methodology for determining
the monthly composite corporate bond rate
as set forth in Notice 2004–34 continues to
apply in determining that rate. See Notice
2006–75, 2006–2 C.B. 366.
The composite corporate bond rate for
February 2011 is 5.70 percent. Pursuant
to Notice 2004–34, the Service has de-
termined this rate as the average of the
monthly yields for the included corporate
bond indices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
Corporate
Bond Weighted
Average90%to100%
March20116.08
5.47
6.08
YIELD CURVE AND SEGMENT
RATES
Generally for plan years beginning
after 2007 (except for delayed effective
dates for certain plans under sections 104,
105, and 106 of PPA), § 430 of the Code
specifies the minimum funding require-
ments that apply to single employer plans
pursuant to § 412. Section 430(h)(2) spec-
ifies the interest rates that must be used
to determine a plan’s target normal cost
and funding target. Under this provision,
present value is generally determined us-
ing three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods.
However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates. Sec-
tion 430(h)(2)G) set forth a transitional
rule applicable to plan years beginning in
2008 and 2009 under which the segment
rates were blended with the corporate bond
weighted average described above, includ-
ing an election under § 430(h)(2)(G)(iv)
foranemployertousethesegmentrates
without the transitional rule.
Notice 2007–81, 2007–2 C.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, the
24-month average corporate bond seg-
ment rates, and the funding transitional
segment rates used to compute the tar-
get normal cost and the funding target.
Pursuant to Notice 2007–81, the monthly
corporate bond yield curve derived from
February 2011 data is in Table I at the end
of this notice. The spot first, second, and
third segment rates for the month of Feb-
ruary 2011 are, respectively, 2.02, 5.34,
and 6.54. The three 24-month average
corporate bond segment rates applica-
ble for March 2011 under the election of
§ 430(h)(2)(G)(iv) are as follows:
First
Segment
Second
Segment
Third
Segment
2.67
5.69
6.44
The transitional rule of § 430(h)(2)(G)
does not apply to plan years beginning af-
ter December 31, 2009. Therefore, for a
plan year beginning after 2009 with a look-
back month to March 2011, the funding
segment rates are the three 24-month av-
erage corporate bondsegment rates appli-
cable for March 2011, listed above without
blending for any transitional period.
March 21, 20115572011–12 I.R.B.

30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 417(e)(3)(A)(ii)(II) (prior to
amendment by PPA) defines the appli-
cable interest rate, which must be used
for purposes of determining the minimum
present value of a participant’s benefit
under § 417(e)(1) and (2), as the annual
rate of interest on 30-year Treasury se-
curities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
ble interest rate for a month is the annual
rate of interest on 30-year Treasury secu-
rities as specified by the Commissioner
for that month in revenue rulings, notices
or other guidance published in the Internal
Revenue Bulletin.
The rate of interest on 30-year Treasury
securities for February 2011 is 4.65 per-
cent. The Service has determined this rate
as the average of the yield on the 30-year
Treasury bond maturing in November
2040 determined each day through Febru-
ary 9, 2011, and the yield on the 30-year
Treasury bond maturing in February 2041
determined each day for the balance of the
month.
Generally for plan years beginning
after 2007, § 431 specifies the mini-
mum funding requirements that apply to
multiemployer plans pursuant to § 412.
Section 431(c)(6)(B)specifies a minimum
amount for the full-funding limitation
described in section 431(c)(6)(A), based
on the plan’s current liability. Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 percent
below the weighted average of the rates of
interest on 30-year Treasury securities dur-
ing the four-year period ending on the last
day before the beginning of the plan year.
Notice 88–73, 1988–2 C.B. 383, provides
guidelines for determining the weighted
average interest rate. The following rates
were determined for plan years beginning
in the month shown below.
For Plan Yea
rs
Beginning i
n
Permissibl
e Range
MonthYear
30-Year
Treasury
Weighted
Average
90%to
105%
March20114.28
3.85
4.49
MINIMUM PRESENT VALUE
SEGMENT RATES
Generally for plan years beginning af-
ter December 31, 2007, the applicable in-
terest rates under § 417(e)(3)(D) are seg-
ment rates computed without regard to a
24-month average. For plan years begin-
ning in 2008 through 2011, the applica-
ble interest rates are the monthly spot seg-
ment rates blended with the applicable rate
under § 417(e)(3)(A)(ii)(II) as in effect
for plan years beginning in 2007. Notice
2007–81 provides guidelines for determin-
ing the minimum present value segment
rates. Pursuant to that notice, the min-
imum present value transitional segment
rates determined for February 2011, tak-
ing into account the February 2011 30-year
Treasury rate of 4.65 stated above, are as
follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20103.07
5.065.78
2011
2.555.20
6.16
DRAFTING
INFORMATION
The princ
ipal author of this notice is
Tony Mont
anaro of the Employee Plans,
Tax Exemp
t and Government Entities Di-
vision. M
r. Montanaro may be e-mailed at
Retireme
ntPlanQuestions@irs.gov.
2011–12 I.R.B.558March 21, 2011

Table I
Monthly Yield Curve for February 2011
DerivedfromFebruary2011Data
Maturity YieldMaturity YieldMaturity YieldMaturity YieldMaturity Yield
0.5
0.47
20.5
6.14
40.5
6.59
60.56.7580.5
6.82
1.00.8121.06.1641.06.6061.06.7581.06.83
1.51.1521.5
6.18
41.5
6.60
61.56.7581.5
6.83
2.0
1.51
22.06.2042.06.6162.0
6.75
82.06.83
2.5
1.87
22.5
6.22
42.5
6.61
62.5
6.76
82.5
6.83
3.02.2423.06.2443.06.6263.06.7683.06.83
3.52.5823.56.2543.5
6.62
63.5
6.76
83.5
6.83
4.0
2.91
24.06.2744.06.6364.06.7684.06.83
4.5
3.21
24.5
6.28
44.5
6.63
64.5
6.77
84.5
6.84
5.0
3.48
25.0
6.30
45.0
6.64
65.0
6.77
85.0
6.84
5.5
3.73
25.5
6.31
45.5
6.64
65.5
6.77
85.5
6.84
6.03.9526.06.3346.0
6.65
66.06.7786.06.84
6.54.1526.5
6.34
46.56.6566.5
6.77
86.5
6.84
7.04.3327.06.3647.06.6667.06.7887.06.84
7.54.5027.5
6.37
47.5
6.66
67.5
6.78
87.5
6.84
8.04.6428.06.3848.06.6668.06.7888.06.84
8.5
4.78
28.5
6.39
48.5
6.67
68.5
6.78
88.56.85
9.04.9029.0
6.40
49.0
6.67
69.06.7989.0
6.85
9.5
5.02
29.56.4249.56.6869.5
6.79
89.5
6.85
10.05.1230.06.4350.06.6870.0
6.7990.0
6.85
10.55.2130.5
6.44
50.5
6.68
70.5
6.7990.5
6.85
11.0
5.30
31.0
6.4551.0
6.69
71.0
6.7991.0
6.85
11.55.3831.5
6.46
51.5
6.69
71.5
6.79
91.5
6.85
12.0
5.46
32.06.47
52.0
6.69
72.06.80
92.0
6.85
12.55.5232.5
6.47
52.5
6.70
72.5
6.8092.56.86
13.05.5933.06.4853.06.7073.06.80
93.0
6.86
13.55.6433.5
6.49
53.5
6.71
73.5
6.8093.56.86
14.0
5.70
34.0
6.5054.0
6.7174.06.80
94.0
6.86
14.55.7534.56.5154.5
6.71
74.5
6.8194.56.86
15.0
5.79
35.06.5255.0
6.71
75.0
6.8195.06.86
15.55.8435.56.5255.5
6.72
75.5
6.8195.56.86
16.05.8736.06.5356.06.7276.06.81
96.0
6.86
16.5
5.91
36.56.5456.5
6.72
76.5
6.8196.56.86
17.05.9537.0
6.5557.0
6.7377.06.81
97.0
6.86
17.5
5.98
37.56.5557.5
6.73
77.5
6.8297.56.87
18.06.0138.0
6.5658.0
6.7378.06.82
98.0
6.87
18.5
6.04
38.56.5758.5
6.74
78.5
6.8298.56.87
19.0
6.06
39.0
6.5759.06.74
79.0
6.82
99.0
6.87
19.56.0939.5
6.58
59.56.7479.56.8299.56.87
20.06.1140.0
6.58
60.06.7480.06.82100.06.87
March 21, 20115592011–12 I.R.B.

26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability.
(Also: Part I, §§ 280F; 1.280F–7.)
Rev. Proc. 2011–21
SECTION 1. PURPOSE
This revenue procedure provides: (1)
limitations on depreciation deductions
for owners of passenger automobiles first
placed in service by the taxpayer during
calendar year 2011, including separate ta-
bles of limitations on depreciation deduc-
tions for trucks and vans; (2) the amounts
that must be included in income by lessees
of passenger automobiles first leased by
the taxpayer during calendar year 2011,
including a separate table of inclusion
amounts for lessees of trucks and vans; and
(3) revised tables of depreciation limita-
tions and lessee inclusion amounts for pas-
senger automobiles that were first placed
in service or first leased by the taxpayer,
respectively, during 2010 and to which
the 50 percent additional first year depre-
ciation deduction under § 168(k)(1)(A)
of the Internal Revenue Code or the 100
percent additional first year depreciation
deduction under § 168(k)(5) applies. The
tables detailing these depreciation limita-
tions and lessee inclusion amounts reflect
the automobile price inflation adjustments
required by § 280F(d)(7).
SECTION 2. BACKGROUND
.01 For owners of passenger automo-
biles, § 280F(a) imposes dollar limitations
on the depreciation deduction for the year
the taxpayer places the passenger auto-
mobile in service and for each succeeding
year. For passenger automobiles placed in
service after 1988, § 280F(d)(7) requires
the Internal Revenue Service to increase
the amounts allowable as depreciation de-
ductions by a price inflation adjustment
amount. The method of calculating this
price inflation amount for trucks and vans
placed in service in or after calendar year
2003 uses a different CPI “automobile
component” (the “new trucks” compo-
nent) than that used in the price inflation
amount calculation for other passenger
automobiles (the “new cars” component),
resulting in somewhat higher deprecia-
tion deductions for trucks and vans. This
change reflects the higher rate of price
inflation for trucks and vans since 1988.
.02 Section 2022(a) of the Small
Business Jobs Act of 2010, Pub. L. No.
111–240, 124 Stat. 2504 (September 27,
2010), extended the 50 percent additional
first year depreciation deduction under
§ 168(k) to qualified property (as defined
in § 168(k)(2)) acquired by the taxpayer
after December 31, 2007, and before Jan-
uary 1, 2011, if no written binding contract
for the acquisition of the property existed
before January 1, 2008, and if the taxpayer
places the property in service generally
before January 1, 2011. Section 401(a)
of the Tax Relief, Unemployment Insur-
ance Reauthorization, and Job Creation
Act of 2010, Pub. L. No. 111–312, 124
Stat. 3296 (Dec. 17, 2010) (the “Act”)
further extended the 50 percent additional
first year depreciation deduction under
§ 168(k) to qualified property acquired
by the taxpayer after December 31, 2007,
and before January 1, 2013, if no written
binding contract for the acquisition of the
property existed before January 1, 2008,
and if the taxpayer places the property in
service generally before January 1, 2013.
Section 401(b) of the Act further
amended § 168(k) by adding § 168(k)(5).
It allows a 100 percent additional first
year depreciation deduction for quali-
fied property acquired by a taxpayer after
September 8, 2010, and before January 1,
2012, if the taxpayer places the property in
service generally before January 1, 2012.
Section 168(k)(2)(F)(i) increases the
first year depreciation allowed under
§ 280F(a)(1)(A)(i) by $8,000 for pas-
senger automobiles to which the addi-
tional first year depreciation deduction
under § 168(k) (hereinafter, referred to as
Ҥ 168(k) additional first year depreciation
deduction”) applies.
.03 Section 168(k)(2)(D)(i) provides
that the § 168(k) additional first year de-
preciation deduction does not apply to
any property required to be depreciated
under the alternative depreciation system
of § 168(g), including property described
in § 280F(b)(1). Section 168(k)(2)(D)(iii)
permits a taxpayer to elect out of the
§ 168(k) additional first year deprecia-
tion deduction for any class of property.
Section 168(k)(4), as amended by the
Act, permits a corporation to elect to
increase the alternative minimum tax
(“AMT”) credit limitation under § 53(c),
instead of claiming the § 168(k) addi-
tional first year depreciation deduction for
all eligible qualified property placed in
service after December 31, 2010, that is
round 2 extension property (as defined in
§ 168(k)(4)(I)(iv).
Accordingly, this revenue procedure
provides tables for passenger automo-
biles for which the § 168(k) additional
first year depreciation deduction applies.
This revenue procedure also provides ta-
bles for passenger automobiles for which
the § 168(k) additional first year depre-
ciation deduction does not apply, either
because taxpayer (1) purchased the pas-
senger automobile used; (2) did not use the
passenger automobile during 2011 more
than 50 percent for business purposes;
(3) elected out of the § 168(k) additional
first year depreciation deduction pursuant
to § 168(k)(2)(D)(iii); or (4) elected to
increase the § 53 AMT credit limitation in
lieu of claiming § 168(k) additional first
year depreciation.
.04 Section 280F(c) requires a reduc-
tion in the deduction allowed to the lessee
of a leased passenger automobile. The re-
duction must be substantially equivalent to
the limitations on the depreciation deduc-
tions imposed on owners of passenger au-
tomobiles. Under § 1.280F–7(a) of the In-
come Tax Regulations, this reduction re-
quires a lessee to include in gross income
an amount determined by applying a for-
mula to the amount obtained from a table.
One table applies to lessees of trucks and
vans and another table applies to all other
passenger automobiles. Each table shows
inclusion amounts for a range of fair mar-
ket values for each taxable year after the
passenger automobile is first leased.
SECTION 3. SCOPE
.01 The limitations on depreciation de-
ductions in section 4.01(2) of this revenue
procedure apply to passenger automobiles
(other than leased passenger automobiles)
that are placed in service by the taxpayer
in calendar year 2011, and continue to ap-
ply for each taxable year that the passenger
automobile remains in service.
.02 The tables in section 4.02 of this
revenue procedure apply to leased pas-
senger automobiles for which the lease
term begins during calendar year 2011.
Lessees of these passenger automobiles
must use these tables to determine the
2011–12 I.R.B.560March 21, 2011

inclusion amount for each taxable year
during which the passenger automobile is
leased. See Rev. Proc. 2006–18, 2006–1
C.B. 645, for passenger automobiles first
leased during calendar year 2006; Rev.
Proc. 2007–30, 2007–1 C.B. 1104, for
passenger automobiles first leased during
calendar year 2007; Rev. Proc. 2008–22,
2008–1 C.B. 658, for passenger auto-
mobiles first leased during calendar year
2008; Rev. Proc. 2009–24, 2009–1 C.B.
885, for passenger automobiles first leased
during calendar year 2009; and Rev. Proc.
2010–18, 2010–1 C.B. 427, as amplified
and modified by section 4.03 of this rev-
enue procedure, for passenger automobiles
first leased during calendar year 2010.
SECTION 4. APPLICATION
.01Limitations on Depreciation Deduc-
tions for Certain Automobiles.
(1)Amount of the inflation adjustment.
(a)Passenger automobiles (other than
trucks or vans). Under § 280F(d)(7)(B)(i),
the automobile price inflation adjustment
for any calendar year is the percentage
(if any) by which the CPI automobile
component for October of the preceding
calendar year exceeds the CPI automobile
component for October 1987. Section
280F(d)(7)(B)(ii) defines the term “CPI
automobile component” as the automobile
component of the Consumer Price Index
for all Urban Consumers published by the
Department of Labor. The new car com-
ponent of the CPI was 115.2 for October
1987 and 137.880 for October 2010. The
October 2010 index exceeded the Octo-
ber 1987 index by 22.680. Therefore, the
automobile price inflation adjustment for
2011 for passenger automobiles (other
than trucks and vans) is 19.69 percent
(22.680/115.2 x 100%). The dollar lim-
itations in § 280F(a) are multiplied by
a factor of 0.1969, and the resulting in-
creases, after rounding to the nearest $100,
are added to the 1988 limitations to give
the depreciation limitations applicable to
passenger automobiles (other than trucks
and vans) for calendar year 2011. This
adjustment applies to all passenger auto-
mobiles (other than trucks and vans) that
are first placed in service in calendar year
2011.
(b)Trucks and vans. To determine the
dollar limitations for trucks and vans first
placed in service during calendar year
2011, the Service uses the new truck com-
ponent of the CPI instead of the new car
component. The new truck component
of the CPI was 112.4 for October 1987
and 142.556 for October 2010. The Oc-
tober 2010 index exceeded the October
1987 index by 30.156. Therefore, the
automobile price inflation adjustment for
2011 for trucks and vans is 26.83 percent
(30.156/112.4 x 100%). The dollar lim-
itations in § 280F(a) are multiplied by
a factor of 0.2683, and the resulting in-
creases, after rounding to the nearest $100,
are added to the 1988 limitations to give
the depreciation limitations for trucks and
vans. This adjustment applies to all trucks
and vans that are first placed in service in
calendar year 2011.
(2)Amount of the limitation.Tables1
through 4 contain the dollar amount of the
depreciation limitation for each taxable
year for passenger automobiles a taxpayer
places in service in calendar year 2011.
Use Table 1 for a passenger automobile
(other than a truck or van), and Table 2 for
a truck or van, placed in service in calendar
year 2011 for which the § 168(k) additional
first year depreciation deduction applies.
Use Table 3 for a passenger automobile
(other than a truck or van), and Table
4 for a truck or van, placed in service
in calendar year 2011 for which the
§ 168(k) additional first year depreciation
deduction does not apply. The Service
intends to issue additional guidance
addressing the interaction between the 100
percent additional first year depreciation
deduction and § 280F(a) for the taxable
years subsequent to the first taxable year.
REV. PROC. 2011–21 TABLE 1
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN
CALENDAR YEAR 2011 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR
DEPRECIATION DEDUCTION APPLIES
Tax YearAmount
1st Tax Year
$11,060
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
March 21, 20115612011–12 I.R.B.

REV. PROC. 2011–21 TABLE 2
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
PLACED IN SERVICE IN CALENDAR YEAR 2011 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR
DEPRECIATION DEDUCTION APPLIES
Tax YearAmount
1st Tax Year
$11,260
2nd Tax Year
$5,200
3rd Tax Year
$3,150
Each Succeeding Year
$1,875
REV. PROC. 2011–21 TABLE 3
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2011
FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION DOES NOT APPLY
Tax YearAmount
1st Tax Year
$3,060
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
REV. PROC. 2011–21 TABLE 4
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
PLACED IN SERVICE IN CALENDAR YEAR 2011 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR
DEPRECIATION DEDUCTION DOES NOT APPLY
Tax YearAmount
1st Tax Year
$3,260
2nd Tax Year
$5,200
3rd Tax Year
$3,150
Each Succeeding Year
$1,875
.02Inclusions in Income of Lessees of
Passenger Automobiles.
A taxpayer must follow the procedures
in § 1.280F–7(a) for determining the inclu-
sion amounts for passenger automobiles
first leased in calendar year 2011. In ap-
plying these procedures, lessees of passen-
ger automobiles other than trucks and vans
should use Table 5 of this revenue pro-
cedure, while lessees of trucks and vans
should use Table 6 of this revenue proce-
dure.
REV. PROC. 2011–21 TABLE 5
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
(THATARENOTTRUCKSORVANS)
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2011
Fair Market Value of Passenger
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th
5th & later
$18,500$19,000
38111316
19,000
19,500
4913
15
18
19,500
20,000410
15
1720
20,000
20,5005
11161923
20,500
21,000
5
121821
25
21,000
21,500
6131924 26
21,500
22,000614212629
2011–12 I.R.B.562March 21, 2011

REV. PROC. 2011–21 TABLE 5—Continued
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
(THATARENOTTRUCKSORVANS)
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2011
Fair Market Value of Passenger
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th
5th & later
22,00023,000716232932
23,00024,000818273237
24,000
25,000
9203036 42
25,000
26,0001023334046
26,00027,00011
25
3644
51
27,00028,00012274048
55
28,00029,000132943
52
60
29,00030,000143147
5565
30,00031,000
15
34496069
31,00032,0001636
53
6373
32,00033,0001738
56
6877
33,00034,0001840607182
34,000
35,000
194263
75
87
35,000
36,00020
45
667991
36,00037,0002147698396
37,00038,00022497387100
38,00039,00023
51
7691
105
39,00040,00024
53
8094110
40,00041,000
2556
8299114
41,00042,00026
58
86102119
42,00043,000276089107123
43,00044,000286293110128
44,000
45,000
296496114133
45,000
46,000306798119137
46,00047,0003169102122141
47,00048,0003271
105
127
145
48,00049,0003373109130
150
49,000
50,000
3476111134
155
50,00051,00035
78
115
138
159
51,00052,000
3680118142164
52,00053,000
3782122146168
53,00054,000
3884
125150
173
54,00055,000
3987128
153
178
55,00056,000
4089131
158
182
56,00057,000
4191
135
161187
57,00058,000
4293138166191
58,00059,000
43
95
142169196
59,000
60,0004498144174200
60,00062,00046101149179207
62,00064,00048
105156
187216
64,00066,000
50
109163
195225
66,00068,000
52
114169203234
68,00070,000
54
118176211243
70,00072,000
56
123182218
253
72,00074,000
58
127189226262
74,00076,00060132
195
234270
76,00078,00062136202242279
78,00080,00064140209
250
288
80,000
85,000
67148220264304
85,000
90,00072
159
237283327
90,000
95,000
77170
253
303
350
95,000
100,00082181269323372
100,000110,00090198293
352
406
March 21, 20115632011–12 I.R.B.

REV. PROC. 2011–21 TABLE 5—Continued
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
(THATARENOTTRUCKSORVANS)
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2011
Fair Market Value of Passenger
Automobile
Tax Year During Lease
OverNot Over1st2nd3rd4th
5th & later
110,000120,000100220326391
452
120,000130,000110242
359
430497
130,000140,000120264392469
543
140,000
150,000
130286424
509588
150,000
160,000140308
457548
633
160,000170,000
150
330490
587
679
170,000180,000160
352523
626724
180,000190,000170374
555
666769
190,000200,000180396
588705815
200,000210,000190418621744860
210,000220,000200440
654
784904
220,000230,000210462687823
950
230,000240,000220484719863
995
240,000And up230
506752
9021,040
REV. PROC. 2011–21 TABLE 6
DOLLAR AMOUNTS FOR TRUCKS AND VANS
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2011
Fair Market Value of Truck or VanTax Year During Lease
OverNot Over1st2nd3rd4th
5th & later
$19,000$19,500
3791213
19,500
20,000381114
15
20,000
20,500
4913
15
18
20,500
21,000410
15
1720
21,000
21,5005
11162022
21,500
22,000
5
12182224
22,00023,000614202429
23,00024,000716242832
24,000
25,000
8182732 37
25,000
26,000920313641
26,00027,0001023334046
27,00028,00011
25
3743
51
28,00029,00012274048
55
29,00030,000132943
52
60
30,00031,000143147
56
64
31,00032,000
15
34496069
32,00033,0001636
53
6374
33,00034,0001738
56
6878
34,000
35,000
1840607183
35,000
36,0001943627687
36,00037,00020
45
667992
37,00038,0002147698397
38,00039,00022497387101
39,00040,00023
51
7691
105
40,00041,00024
54
79
95
109
41,00042,000
2556
8299114
42,00043,00026
58
86103118
43,00044,000276089107123
44,000
45,000
286293110128
2011–12 I.R.B.564March 21, 2011

REV. PROC. 2011–21 TABLE 6—Continued
DOLLAR AMOUNTS FOR TRUCKS AND VANS
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2011
Fair Market Value of Truck or VanTax Year During Lease
OverNot Over1st2nd3rd4th
5th & later
45,000
46,00029
6595115
132
46,00047,000306799118137
47,00048,0003169102123141
48,00049,0003271106126146
49,000
50,000
3373109130
151
50,00051,000
3476112134
155
51,00052,00035
78
115
138160
52,00053,000
3680118143164
53,00054,000
3782122146169
54,00055,000
3884
125150
173
55,00056,000
3987128
154
177
56,00057,000
4089131
158
182
57,00058,000
4191
135
162186
58,00059,000
4293138166191
59,000
60,00043
95
142169196
60,00062,000
45
99146
175
203
62,00064,00047103
153
183212
64,00066,00049107160191221
66,00068,000
51
112166199229
68,00070,000
53
116173206239
70,00072,000
55
121179214248
72,00074,000
57125
186222
257
74,00076,000
59
129192231266
76,00078,00061134198239
275
78,00080,00063138
205
246
285
80,000
85,000
66146217260300
85,000
90,00071
157
233280322
90,000
95,000
76168
250
299
345
95,000
100,00081179266319368
100,000110,00089196290348402
110,000120,00099218323387447
120,000130,000109240
355
427493
130,000140,000119262388466
538
140,000
150,000
129284421
505583
150,000
160,000139306
454544
629
160,000170,000149328487
583
674
170,000180,000
159350519
623719
180,000190,000169372
552
662
765
190,000200,000179394
585
701810
200,000210,000189416618740
856
210,000220,000199438
651
779901
220,000230,000209460683819946
230,000240,000219482716
858
992
240,000And up229
504
7498971,037
.03Revised Amounts for Passenger Au-
tomobiles Placed in Service During 2010.
(1)Calculation of the Revised Amount.
The revised depreciation limits provided
in this section 4.03 were calculated by in-
creasing the existing limitations on the first
year allowance in Rev. Proc. 2010–18 by
$8,000 as provided in§ 168(k)(2)(F)(i).
(2)Amount of the Revised Limitation.
For passenger automobiles (that are not
trucks or vans) placed in service by the
taxpayer in calendar year 2010 for which
the § 168(k) additional first year deprecia-
tion deduction applies, Table 7 of this rev-
enue procedure contains the revised dol-
lar amount of the depreciation limitations
for each taxable year. For trucks or vans
placed in service by the taxpayer in calen-
dar year 2010 for which the § 168(k) ad-
ditional first year depreciation deduction
applies, Table 8 of this revenue procedure
contains the revised dollar amount of the
depreciation limitations for each taxable
year. If the § 168(k) additional first year
depreciation deduction does not apply to a
passenger automobile placed in service by
the taxpayer in calendar year 2010, the de-
preciation limitations for each taxable year
in Tables 1 and 2 of Rev. Proc. 2010–18
apply.
March 21, 20115652011–12 I.R.B.

REV. PROC. 2011–21 TABLE 7
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES
(THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN
CALENDAR YEAR 2010 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR
DEPRECIATION DEDUCTION APPLIES
Tax YearAmount
1st Tax Year
$11,060
2nd Tax Year
$4,900
3rd Tax Year
$2,950
Each Succeeding Year
$1,775
REV. PROC. 2011–21 TABLE 8
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS
PLACED IN SERVICE IN CALENDAR YEAR 2010 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR
DEPRECIATION DEDUCTION APPLIES
Tax YearAmount
1st Tax Year
$11,160
2nd Tax Year
$5,100
3rd Tax Year
$3,050
Each Succeeding Year
$1,875
(3)Modification to lease inclusion
amounts for 2010. The lease inclusion
amounts in Tables 3 and 4 of Rev. Proc.
2010–18 are modified by striking the
first four lines of the inclusion amounts
in each table. Consequently, Table 3 of
Rev. Proc. 2010–18 applies to passenger
automobiles (other than trucks and vans)
that are first leased by the taxpayer in cal-
endar year 2010 with a fair market value
over $18,500, and Table 4 of Rev. Proc.
2010–18 applies to trucks and vans that
are first leased by the taxpayer in calendar
year 2010 with a fair market value over
$19,000.
SECTION 5. EFFECTIVE DATE
This revenue procedure, with the ex-
ception of section 4.03, applies to passen-
ger automobiles that a taxpayer first places
in service or first leases during calendar
year 2011. Section 4.03 of this revenue
procedure applies to passenger automo-
biles that a taxpayer first places in service
or first leases during calendar year 2010.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2010–18 is amplified and
modified.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Bernard P. Harvey of the Of-
fice of Associate Chief Counsel (Income
Tax & Accounting). For further infor-
mation regarding this revenue procedure,
contact Mr. Harvey at (202) 622–4930
(not a toll-free call).
2011–12 I.R.B.566March 21, 2011

Part IV. Items o
fGeneralInterest
China Professors and
Teachers MAP Agreement
Announcement 2011–18
ThefollowingisacopyoftheCompe-
tent Authority Agreement entered into on
November 24, 2010, by the competent au-
thorities of the United States of America
and the People’s Republic of China with
respect to the taxation of professors and
teachers under the U.S.-China income tax
treaty and protocol.
The text of the Competent Authority
Agreement is as follows:
COMPETENT AUTHORITY
AGREEMENT REGARDING
THE INTERPRETATION
OF ARTICLE 19 OF THE
AGREEMENT BETWEEN
THE GOVERNMENT OF THE
UNITED STATES OF AMERICA
AND THE GOVERNMENT OF
THE PEOPLE’S REPUBLIC OF
CHINA FOR THE AVOIDANCE
OF DOUBLE TAXATION AND
THE PREVENTION OF FISCAL
EVASION WITH RESPECT TO
TAXES ON INCOME
The competent authorities of the United
States and the People’s Republic of China
hereby enter into the following agreement
(the “Agreement”) regarding the applica-
tion of Article 19 (Professors and Teach-
ers) of the Agreement Between the Gov-
ernment of the United States of America
and the Government of the People’s Re-
public of China for the Avoidance of Dou-
ble Taxation and the Prevention of Tax
Evasion with Respect to Taxes on Income
and accompanying Protocol, signed at Bei-
jing on April 30, 1984, as amended by
the Protocol signed at Beijing on May 10,
1986 (the “Treaty”). The Agreement is en-
tered into under paragraph 3 of Article 24
(Mutual Agreement Procedure).
Article 19 (Professors and Teachers) of
the Treaty states:
An individual who is, or immediately
before visiting a Contracting State was,
a resident of the other Contracting State
and is temporarily present in the first-
mentioned Contracting State for the pri-
mary purpose of teaching, giving lec-
tures or conducting research at a univer-
sity, college, school or other accredited
educational institution or scientific re-
search institution in the first-mentioned
Contracting State shall be exempt from
tax in the first-mentioned Contracting
State for a period not exceeding three
years in the aggregate in respect of re-
muneration for such teaching, lectures
or research.
It is understood that the three-year
exemption period begins to run from
the first day the individual enters the
first-mentioned Contracting State (here-
inafter referred to as the “host state”) for
the primary purpose of teaching, giving
lectures or conducting research at a uni-
versity, college, school or other accredited
educational institution or scientific re-
search institution (the “entry date”). It
is agreed that if an individual to whom
Article 19 applies is present in the host
state for the primary purpose of teaching,
giving lectures, or conducting research for
more than three years following the entry
date, then the host state may begin to tax
the individual’s remuneration for teach-
ing, giving lectures or conducting research
starting with the first day of the fourth
year. Such an individual’s remuneration
for the first three years will not lose its
host state exemption.
It is further agreed that the three-year
exemption period is suspended when an in-
dividual to whom Article 19 applies dis-
continues teaching, giving lectures or con-
ducting research and departs the host state.
Provided that the individual is, or imme-
diately before returning to the host state
was, a resident of the other Contracting
State, the three-yearexemption period re-
sumes when the individual returns to the
host state for the primary purpose of teach-
ing, giving lectures or conducting research
at a university, college, school or other ac-
credited educational institution or scien-
tific research institution.
It is understood that the exemption pro-
vided in Article 19 is not available if the
research is not undertaken in the public in-
terest, but for the private gain of a specific
person or persons.
Michael DanilackWANG Xiaoping
United States Competent AuthorityP.R. China Competent Authority
Internal Revenue ServiceState Administration of Taxation
Date:
Date:
Replacement of Schedule
SSA (Form 5500) with Form
8955–SSA
Announcement 2011–21
This announcement designates Form
8955–SSA,Annual Registration Statement
Identifying Separated Participants With
Deferred Vested Benefits, as the form to be
used to satisfy the reporting requirements
of § 6057(a) of the Internal Revenue Code
for plan years beginning on or after Jan-
uary 1, 2009, and sets forth the due dates
for filing the Form 8955–SSA for the 2009
plan year and subsequent plan years.
Section 6057(a) requires the plan ad-
ministrator of a plan that is subject to the
vesting standards of section 203 of the Em-
ployee Retirement Income Security Act of
1974 (ERISA) to report certain informa-
tion relating to each plan participant with a
deferred vested benefit in accordance with
regulations prescribed by the Secretary of
Treasury. Schedule SSA, an attachment
to theAnnual Return/Report of Employee
Benefit Plan(Form 5500 Series), has been
the form used by plan administrators to
comply with the reporting requirements of
§ 6057(a).
In 2007, the Department of Labor
(DOL) published a final rule requiring
plans subject to the annual reporting re-
March 21, 20115672011–12 I.R.B.

quirements of Title I of ERISA to elec-
tronically file the Form 5500 annual re-
turn/report (72 Fed. Reg. 64710). The
DOL electronic filing mandate is effec-
tive for plan years beginning on or after
January 1, 2009, but does not apply to
the reporting requirements imposed by
§ 6057(a). In order to accommodate the
DOL’s mandate for electronic filing of the
Form 5500 annual return/report, a number
of changes were made to the Form 5500
Series and accompanying schedules and
attachments. One of these changes was the
removal of Schedule SSA from the Form
5500 annual return/report beginning with
filings covering a plan year that begins on
or after January 1, 2009.
The Internal Revenue Service (IRS),
in coordination with the Social Secu-
rity Administration, has developed Form
8955–SSA, a stand-alone form to be filed
with the IRS, as the successor to the Sched-
ule SSA (Form 5500). For plan years
beginning on or after January 1, 2009,
the Form 8955–SSA should be used to
comply with the reporting requirements of
§ 6057(a). Form 8955–SSA for the 2009
plan year is expected to be available for
filing by plan administrators shortly. Form
8955–SSA for the 2010 plan year is being
developed and is expected to be available
for filing later this year. Plan administra-
tors are permitted to report information
that would otherwise be required to be re-
ported on the 2010 Form 8955–SSA using
a 2009 Form 8955–SSA. The IRS has also
developed a voluntary electronic filing
system for filing Form 8955–SSA for the
2009 plan year and subsequent plan years.
This system is ready to accept filings of
Form 8955–SSA when the form becomes
available for filing.
In general, as with Schedule SSA (Form
5500), if a Form 8955–SSA must be filed
for a plan year, it must be filed by the last
day of the seventh month following the
last day of that plan year (plus extensions).
Thus, for example, for plans on a calen-
dar year, any 2011 Form 8955–SSA that is
required to be filed under § 6057(a) must
be filed with the IRS by July 31, 2012.
However, in order to provide plan admin-
istrators with additional time to complete
and file the new Form 8955–SSA, this an-
nouncement provides that the due date for
filing the Form 8955–SSA for the 2009
and the 2010 plan years is the later of (1)
the due date that generally applies for fil-
ing the Form 8955–SSA for the 2010 plan
year, and (2) August 1, 2011. For exam-
ple, in the case of a 2009 plan year or a
short 2010 plan year, the Form 8955–SSA
is not required to be filed before August 1,
2011.
The rules applicable to the extension
of time for filing Form 8955–SSA are the
same as those applicable to the extension
of time for filing Schedule SSA (Form
5500). Thus, for example, Form 5558,
Application for Extension of Time To File
Certain Employee Plan Returns,maybe
used to file for a one-time extension of
time to file the Form 8955–SSA. The IRS
is revising the Form 5558 to enable filers to
obtain extensions of the time to file Form
8955–SSA and expects to have the revised
Form 5558 available soon. Also, plan ad-
ministrators are granted an automatic ex-
tension of time to file Form 8955–SSA
(without filing a Form 5558) until the due
date of the federal income tax return of
the employer if certain conditions are satis-
fied. See Part II of the General Instructions
to the Form 5558.
Some plan administrators have submit-
ted a Schedule SSA to the IRS for the
2009 plan year or may be in the process of
completing the Schedule SSA for the 2009
and/or 2010 plan year. In order to reduce
the burdens on these plan administrators,
the IRS will treat a Schedule SSA that is
filed with the IRS for the 2009 or 2010 plan
year no later than April 20, 2011, as satis-
fying the reporting requirements of § 6057
(and no Form 8955–SSA is required to be
filed for the 2009 or 2010 plan year if a
Schedule SSA for the applicable plan year
is filed with the IRS by this date).
Section 6057(b) requires the plan ad-
ministrator of a plan that is subject to the
vesting standards of section 203 of the
Employee Retirement Income Security
Act of 1974 (ERISA) to notify the Sec-
retary of the Treasury of certain changes
relating to the plan and plan administrator.
These changes are reported on the plan’s
Form 5500 annual return/report. Neither
the removal of the Schedule SSA from the
Form 5500 annual return/report nor the
creation of the Form 8955–SSA affect this
requirement. Therefore, a plan adminis-
trator should continue to report changes
in plan status on the Form 5500 annual
return/report for the plan year in which
the change occurs in accordance with the
applicable instructions.
DRAFTING INFORMATION
The principal authors of this announce-
ment are Robert M. Walsh of the Employee
Plans, Tax Exempt and Government En-
tities Division and William Gibbs of the
Office of the Division Counsel/Asso-
ciate Chief Counsel (Tax Exempt and
Government Entities). For further in-
formation regardingthis announcement,
please call the Employee Plans taxpayer
assistance number at (877) 829–5500 (a
toll-free number) or email Mr. Walsh at
retirementplanquestions@irs.gov.
Deletions From Cumulative
List of Organizations
Contributions to Which
are Deductible Under Section
170 of the Code
Announcement 2011–23
The Internal Revenue Service has re-
voked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the Service will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletinthatanorganizationnolonger
qualifies. However, the Service is not
precluded from disallowing a deduction
for any contributions made after an or-
ganization ceases to qualify under section
170(c)(2) if the organization has not timely
filed a suit for declaratory judgment under
section 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on March 21, 2011
and would end on the date the court first
determines that the organization is not de-
2011–12 I.R.B.568March 21, 2011

scribed in section 170(c)(2) as more partic-
ularly set forth in section 7428(c)(1). For
individual contributors, the maximum de-
duction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were the
basis for revocation.
B & B Scholar Foundation, Inc.
Titusville, FL
Gentle Touch Ministries
Newport, TN
Harbour Credit Counseling Services, Inc.
Virginia Beach, VA
Initiatives for Community Development,
Inc.
New York, NY
Past Presidents Club, Inc.
Houma, LA
Reproductive and Child Health Alliance
Henderson, NV
School in the Clouds Assisi
Coronado, CA
Waukesha Kennel Club, Inc.
Mukwonago, WI
Xelan Foundation, Inc.
Tampa, FL
Announcement of Disciplinary Sanctions From the Office
of Professional Responsibility
Announcement 2011-24
TheOfficeofProfessionalResponsi-
bility (OPR) announcesrecent disciplinary
sanctions involving attorneys, certified
public accountants, enrolled agents, en-
rolled actuaries, enrolled retirement plan
agents, and appraisers. These individuals
are subject to the regulations governing
practice before the Internal Revenue Ser-
vice (IRS), which are set out in Title 31,
Code of Federal Regulations, Part 10, and
which are published in pamphlet form as
Treasury Department Circular No. 230.
The regulations prescribe the duties and
restrictions relating to such practice and
prescribe the disciplinary sanctions for
violating the regulations.
The disciplinary sanctions to be im-
posed for violation of the regulations are:
Disbarred from practice before the
IRS—An individual who is disbarred is
not eligible to represent taxpayers before
the IRS.
Suspended from practice before the
IRS—An individual who is suspended is
not eligible to represent taxpayers before
the IRS during the term of the suspension.
Censured in practice before the
IRS—Censure is a public reprimand. Un-
like disbarment or suspension, censure
does not affect an individual’s eligibility
to represent taxpayers before the IRS, but
OPR may subject the individual’s future
representations to conditions designed to
promote high standards of conduct.
Monetary penalty—A monetary
penalty may be imposed on an individual
who engages in conduct subject to sanc-
tion or on an employer, firm, or entity
if the individual was acting on its behalf
and if it knew, or reasonably should have
known, of the individual’s conduct.
Disqualification of appraiser—An
appraiser who is disqualified is barred
from presenting evidence or testimony in
any administrative proceeding before the
Department of the Treasury or the IRS.
Under the regulations, attorneys, cer-
tified public accountants, enrolled agents,
enrolled actuaries, and enrolled retirement
plan agents may not assist, or accept assis-
tance from, individuals who are suspended
or disbarred with respect to matters consti-
tuting practice (i.e., representation) before
the IRS, and they may not aid or abet sus-
pended or disbarred individuals to practice
before the IRS.
Disciplinary sanctions are described in
these terms:
Disbarred by decision after hearing,
Suspended by decision after hearing,
Censured by decision after hearing,
Monetary penalty imposed after hear-
ing, and Disqualified after hearing—An
administrative law judge (ALJ) conducted
an evidentiary hearing upon OPR’s com-
plaint alleging violation of the regulations
and issued a decision imposing one of
these sanctions. After 30 days from the
issuance of the decision, in the absence of
an appeal, the ALJ’s decision became the
final agency decision.
Disbarred by default decision, Sus-
pended by default decision, Censured by
default decision, Monetary penalty im-
posed by default decision, and Disqual-
ified by default decision—An ALJ, after
findingthatnoanswertoOPR’scomplaint
had been filed, granted OPR’s motion for a
default judgment and issued a decision im-
posing one of these sanctions.
Disbarment by decision on appeal,
Suspended by decision on appeal, Cen-
sured by decision on appeal, Monetary
penalty imposed by decision on ap-
peal, and Disqualified by decision on
appeal—The decision of the ALJ was
appealed to the agency appeal authority,
acting as the delegate of the Secretary
of the Treasury, and the appeal authority
issued a decision imposing one of these
sanctions.
Disbarred by consent, Suspended by
consent, Censured by consent, Mone-
tary penalty imposed by consent, and
Disqualified by consent—Inlieuofa
disciplinary proceeding being instituted
or continued, an individual offered a con-
sent to one of these sanctions and OPR
accepted the offer. Typically, an offer
of consent will provide for: suspension
for an indefinite term; conditions that the
individual must observe during the sus-
pension; and the individual’s opportunity,
after a stated number of months, to file
with OPR a petition for reinstatement af-
firming compliance with the terms of the
consent and affirming current eligibility
to practice (i.e., an active professional
license or active enrollment status). An
enrolled agent or an enrolled retirement
plan agent may also offer to resign in order
to avoid a disciplinary proceeding.
Suspended by decision in expedited
proceeding, Suspended by default de-
cision in expedited proceeding, Sus-
pended by consent in expedited pro-
ceeding—OPR instituted an expedited
March 21, 20115692011–12 I.R.B.

proceeding for suspension (based on cer-
tain limited grounds, including loss of a
professional license and criminal convic-
tions).
OPR has authority to disclose the
grounds for disciplinary sanctions in these
situations: (1) an ALJ or the Secretary’s
delegate on appeal has issued a decision
on or after September 26, 2007, which was
the effective date of amendments to the
regulations that permit making such deci-
sions publicly available; (2) the individual
has settled a disciplinary case by signing
OPR’s “consent to sanction” form, which
requires consenting individuals to admit to
one or more violations of the regulations
and to consent to the disclosure of the in-
dividual’s own return information related
to the admitted violations (for example,
failure to file Federal income tax returns);
or (3) OPR has issued a decision in an
expedited proceeding for suspension.
Announcements of disciplinary sanc-
tions appear in the Internal Revenue Bul-
letin at the earliest practicable date. The
sanctions announced below are alphabet-
ized first by the names of states and sec-
ond by the last names of individuals. Un-
less otherwise indicated, section numbers
(e.g., § 10.51) refer to the regulations.
City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
California
Citrus HeightsBenoit, George L.Enrolled AgentDisbarred by consent
for violation of § 10.51
(failure to timely file
Federal individual income
tax returns for tax years
2002–2004 and failure
to file Federal individual
income tax return for tax
years 2005–2009).
Indefinite from
December 7, 2010
Newport BeachPrendiville, AndrewJ. AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
January 7, 2011
San DiegoWithers, Roy R.AttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment)
Indefinite from
January 7, 2011
Monterey ParkWong, Richard
Po-Chung
CPASuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction under
18 U.S.C. § 1343, wire
fraud, aiding and abetting,
26 U.S.C. § 7201, tax
evasion, and 26 U.S.C.
§ 7206, willful aiding
and assisting preparation
of false tax return and
license revocation)
Indefinite from
December 13,
2010
2011–12 I.R.B.570March 21, 2011

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Colorado
AuroraKrech, Robert G.CPASuspension by consent
for violation of § 10.22,
(practitioner did not
follow due diligence in
the determination of the
validity of credits and
deductions under Section
44 of the Internal Revenue
Code).
Indefinite from
December 31,
2010
Hawaii
HonoluluPaco, NathanAttorneySuspended by default
decision in expedited
proceeding under § 10.82
(attorney disbarment in
California)
Indefinite from
January 7, 2011
Indiana
AvonAndrews, Ted E.CPAReinstated to
practice before
theIRS,effective
December 20,
2010
March 21, 20115712011–12 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Kansas
Overland ParkDavison, Allen R.CPA (Kansas)/ Attorney
(Nebraska)
Suspended by decision in
expedited proceeding
under § 10.82
(permanently enjoined by
U.S. District Court from
organizing, establishing,
promoting, selling,
offering for sale or
helping to organize,
establish, promote, sell or
offer for sale any tax plan,
involving sham parallel C
management companies,
sham 412(i) plans, sham
flock contracts or any
other illegal tax scheme,
plan or device; shall
not organize, establish,
promote, sell, offer for
sale or assist in any
financial or tax related
arrangement without
submitting in writing
to an IRS designee, a
detailed plan explaining
the financial or tax
arrangement and all
steps necessary for the
arrangement to be legal
under the tax code.
Indefinite from
December 17,
2010
Louisiana
MonroeBradley, Louis R.CPASuspended by decision
in expedited proceeding
under § 10.82 (suspension
of CPA certificate)
Indefinite from
January 18, 2011
Michigan
LansingHorton, Darryl S.CPASuspended by default
decision in expedited
proceeding under
§ 10.82 (conviction
under 26 U.S.C. § 7206,
aiding and assisting
in the preparation and
presentation of a false
and fraudulent income tax
return)
Indefinite from
January 7, 2011
2011–12 I.R.B.572March 21, 2011

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Nebraska
Davidson, Allen R.
See Kansas
New Jersey
AnnandaleOrlando, Charles J.CPASuspended by consent
for violation of § 10.51
(failure to file Federal
individual income tax
returns for tax years
2007 and 2008, failure
to timely file Federal
individual income tax
returns for tax years
1998–2006, failure to
file employer’s quarterly
Federal tax return for
five quarters, failure to
timely file employer’s
quarterly Federal tax
returns for most quarters
2001–2008, failure to
pay Federal individual
income tax 1998–1999
and 2002–2006, failure
to pay taxes due on
employer’s quarterly
Federal tax returns for
most quarters 2001–2007
and 2008–2009, and
failure to timely pay
taxes due on employer’s
quarterly Federal tax
return for one quarter in
2008.
Indefinite from
December 17,
2010
North Carolina
NewtonWentz, DeborahCPAReinstated to
practice before
theIRS,effective
November 1, 2010
March 21, 20115732011–12 I.R.B.

City & StateNameProfessionalDisciplinary SanctionEffective Date(s)
Designation
Texas
McAllenBurford, Kenneth F.AttorneySuspended by consent
for violation of § 10.51,
(failure to timely file
Federal individual income
tax returns for 2006–2007,
failure to pay Federal
individual income tax
for 2007–2008, failure
to timely file employer’s
quarterly Federal tax
returns for eight quarters
2004–2009, and failure to
pay Federal tax liabilities
for Kenneth Burford,
CPA, JD)
Indefinite from
December 21,
2010
OdessaHargus, Richard L.Enrolled AgentReinstated to
practice before
theIRS,effective
October 22, 2010
BedfordMorse, Kyle K.CPAReinstated to
practice before
theIRS,effective
December 22,
2010
2011–12 I.R.B.574March 21, 2011

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.
March 21, 2011i2011–12 I.R.B.

Numerical Finding List
1
Bulletin 2011–1 through 2011–12
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
Proposed Regulations:
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
REG-131151-10, 2011-8 I.R.B.519
REG-131947-10, 2011-8 I.R.B.521
Proposed Regulations— Continued:
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
2011-6, 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
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.
2011–12 I.R.B.iiMarch 21, 2011

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2011–1 through 2011–12
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.
March 21, 2011iii2011–12 I.R.B.

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
2011–12 I.R.B.ivMarch 21, 2011

March 21, 20112011–12 I.R.B.

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