Internal Revenue Bulletin 2010-26 (PDF rendition): IRS Revenue Rulings

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
0-26
June 28, 2010
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2010–14, page 773.
Interest rates; underpayment and overpayments.The
rates for interest determined under section 6621 of the Code
for the calendar quarter beginning July 1, 2010, will be 4 per-
cent for overpayments (3 percent in the case of a corporation),
4 percent for underpayments, and 6 percent for large corpo-
rate underpayments. The rate of interest paid on the portion of
a corporate overpayment exceeding $10,000 will be 1.5 per-
cent.
Rev. Rul. 2010–16, page 769.
Application of section 469 to the section 45D new mar-
kets tax credit.This ruling provides that the passive activity
provisions under section 469 of the Code will not disallow a
taxpayer’s new markets tax credit under section 45D, provided
that a taxpayer’s acquisition of the qualified equity investment
in a qualified community development entity (CDE) does not
arise in connection with the conduct of a passive activity by
the taxpayer, without regard to a taxpayer’s interest or extent
of participation in the CDE’s trade or business.
Rev. Rul. 2010–17, page 769.
New markets tax credit.This ruling provides that for pur-
poses of determining the new markets tax credit allowable un-
der section 45D of the Code, the amount of the qualified equity
investment made by an LLC classified as a partnership includes
cash from a recourse loan to the LLC that the LLC invests as
equity in a qualified community development entity. Rev. Rul.
2003–20 amplified.
T.D. 9485, page 771.
Final regulations under section 704(c) of the Code respond to
the Joint Committee on Taxation’s recommendation that the
partnership rules be strengthened to ensure that the allocation
rules in the regulations are not used to generate unwarranted
tax benefits. The regulations achieve this result by amending
the section 1.704–3(a)(10) anti-abuse rule to provide that the
tax effect of an allocation method (or combination of methods)
on both direct and indirect partners is considered. In addition,
the regulations include a cross-reference to the general partner-
ship anti-abuse rule of section 1.701–2 to clarify that section
1.704–3 applies only to contributions of property that are oth-
erwise respected and that one factor that will be considered is
the use of remedial allocations between related partners.
EMPLOYEE PLANS
Notice 2010–47, page 781.
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 June 2010;
the 24–month average segment rates; the funding transitional
segment rates applicable for June 2010; and the minimum
present value transitional rates for May 2010.
Fi
nding Lists begin on page ii.
Index for January through June begins on page vi.

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.
June 28, 20102010–26 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 45D.—New Markets
Tax Credit
26 CFR 1.45D–1: New markets tax credit.
New markets tax credit.This ruling
provides that for purposes of determining
the new markets tax credit allowable under
section 45D of the Code, the amount of
the qualified equity investment made by
an LLC classified as a partnership includes
cash from a recourse loan to the LLC that
the LLC invests as equity in a qualified
community development entity. Rev. Rul.
2003–20 amplified.
Rev. Rul. 2010–17
ISSUE
For purposes of determining the new
markets tax credit allowable under § 45D
of the Internal Revenue Code, does the
amount of the qualified equity invest-
ment made by a limited liability company
(LLC) classified as a partnership include
cash from a recourse loan to the LLC that
the LLC invests as equity in a qualified
community development entity?
ANALYSIS
Section 45D(a) provides a new markets
tax credit to taxpayers who hold a qualified
equity investment in a qualified commu-
nity development entity. Section 45D(b)
provides that a qualified equity investment
means any equity investment in a qualified
community development entity if, among
other requirements, the taxpayer acquired
the investment solely in exchange for cash.
Rev. Rul. 2003–20, 2003–1 C.B. 465,
held that, on the facts presented in that rev-
enue ruling, the amount of the qualified eq-
uity investment under § 45D(b) made by
an LLC classified as a partnership included
cash from a non-recourse loan to the LLC
that the LLC invested as equity in a quali-
fied community development entity. The
rationale of Rev. Rul. 2003–20 applies
equally where the loan is recourse.
HOLDING
For purposes of determining the new
markets tax credit allowable under § 45D,
the amount of the qualified equity invest-
ment made by an LLC classified as a part-
nership includes cash from a recourse loan
to the LLC that the LLC invests as equity
in a qualified community development en-
tity.
EFFECT ON OTHER REVENUE
RULINGS
Rev. Rul. 2003–20 is amplified.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Benjamin H. Weaver of the Office of
Associate Chief Counsel (Passthroughs &
Special Industries). For further informa-
tion regarding this revenue ruling, contact
Benjamin H. Weaver at (202) 622–3050.
For information regarding issues under
§ 45D, contact Julie Hanlon Bolton of
the Office of Associate Chief Counsel
(Passthroughs & Special Industries) at
(202) 622–3040. These are not toll-free
calls.
Se
ction 469.—Passive
A
ctivity Losses and
Credits Limited
26 CFR 1.469–1: General rules.
(Also: § 45D; 1.45D–1; 1.469–4; 1.469–5T;
1.469–9).
Application of section 469 to the sec-
tion 45D new markets tax credit.This
ruling provides that the passive activity
provisions under section 469 of the Code
will not disallow a taxpayer’s new markets
tax credit under section 45D, provided that
a taxpayer’s acquisition of the qualified eq-
uity investment in a qualified community
development entity (CDE) does not arise
in connection with the conduct of a passive
activity by the taxpayer, without regard to
a taxpayer’s interest or extent of participa-
tion in the CDE’s trade or business.
Rev. Rul. 2010–16
ISSUE
Where the acquisition of the qualified
equity investment in a qualified commu-
nity development entity (CDE) is not in
connection with the conduct of a trade or
business (or in anticipation of a trade or
business), is the new markets tax credit
allowable under § 45Da passive activity
credit under § 469?
FACTS
Situa
tion 1.On February 1, 2010, X, an
indiv
idual, acquires a qualified equity in-
vest
ment (as defined in § 45D(b)) in a CDE
(as d
efined in § 45D(c)). Because X holds
the q
ualified equity investment on Febru-
ary 1
, 2010, the initial credit allowance
date
(as defined in § 45D(a)(3)), a new
mar
kets tax credit under § 45D is allow-
abl
e to X. X’s acquisition of the qualified
equ
ity investment in the CDE is not in con-
nec
tion with the conduct of a trade or busi-
nes
sbyX(orinanticipationofatradeor
bu
siness).
Sit
uation 2.On February 1, 2010, ABC,
an
entity treated as a partnership for fed-
er
al tax purposes, acquires a qualified eq-
ui
ty investment (as defined in § 45D(b)) in
aC
DE. Because ABC holds the qualified
eq
uity investment on February 1, 2010, the
i
nitial credit allowance date (as defined in
§
45D(a)(3)), a new markets tax credit un-
d
er § 45D is allowable to ABC. ABC al-
l
ocates the new markets tax credit to its
p
artners A, B, and C, in accordance with
§ 704(b). ABC’s acquisition of the qual-
ified equity investment in the CDE is not
in connection with the conduct of a trade
or business by ABC (or in anticipation of
a trade or business).
LAW AND ANALYSIS
Section 45D(a)(1) provides that for
purposes of § 38, in the case of a taxpayer
who holds a qualified equity investment
on a credit allowance date (as defined in
§ 45D(a)(3)) of the investment that occurs
during the taxable year, the new markets
tax credit determined under § 45D for
the taxable year is an amount equal to
the applicable percentage (as defined in
§ 45D(a)(2)) of the amount paid to the
CDE for the investment at its original
issue. Section 7701(a)(14) defines the
term “taxpayer” to mean any person sub-
ject to any internal revenue tax. Section
7701(a)(1) provides that the term “person”
2010–26 I.R.B.769June 28, 2010

shall be construed to mean and include
an individual, a trust, estate, partnership,
association, company, or corporation.
Section 45D(b)(1) provides that an eq-
uity investment in a CDE is a “qualified
equity investment” if, among other re-
quirements, the CDE uses substantially all
of the cash from the investment to make
qualified low-income community invest-
ments.
Section 45D(d) defines the term “qual-
ified low-income community investment”
as (A) any capital or equity investment
in, or loan to, any qualified active low-in-
come community business, (B) the pur-
chase from another CDE of any loan made
by such entity which is a qualified low-in-
come community investment, (C) finan-
cial counseling and other services speci-
fied in regulations prescribed by the Sec-
retary to businesses located in, or residents
of, low-income communities, and (D) any
equity investment in, or loan to, any CDE.
Section 469(a) provides that for any
taxable year of any individual, estate, trust,
closely-held C corporation, or personal
service corporation, neither the passive
activity loss, nor the passive activity credit
for the taxable year will be allowed.
Section 469(d)(2)(A) defines “passive
activity credit” as the amount (if any) by
which (A) the sum of the credits from all
passive activities allowable for the taxable
year under (i) subpart D of part IV of sub-
chapter A, or (ii) subpart B (other than
§ 27(a)) of part IV, exceeds (b) the regular
tax liability of the taxpayer for the taxable
year allocable to all passive activities.
Section 469(c) defines a “passive activ-
ity” as (1) any activity which involves the
conduct of any trade or business, and in
which the taxpayer does not materially par-
ticipate, and (2) any rental activity, except
as provided by § 469(c)(7).
Section 469(c)(6) provides that, to the
extent provided in the regulations, “trade
or business” includes (A) any activity in
connection with a trade or business, or
(B) any activity with respect to which ex-
penses are allowable as a deduction under
§ 212.
Section 1.469–1(e)(2) of the Income
Tax Regulations provides that trade or
business activities are activities that con-
stitute trade or business activities within
the meaning of § 1.469–4(b)(1).
Section 1.469–4(b)(1) defines “trade or
business activities” as activities, other than
rental activities or activities that are treated
under § 1.469–1T(e)(3)(vi)(B) as inciden-
tal to an activity of holding property for in-
vestment, that (i) involve the conduct of
a trade or business (within the meaning
of § 162), (ii) are conducted in anticipa-
tion of the commencement of a trade or
business, or (iii) involve research or exper-
imental expenditures that are deductible
under § 174.
Section 1.469–9(b)(1) provides that a
trade or business is any trade or business
determined by treating the types of activi-
ties in § 1.469–4(b)(1) as if they involved
the conduct of a trade or business, and any
interest in rental real estate, including any
interest in rental real estate that gives rise
to deductions under § 212.
Section 469(h)(1) provides that a tax-
payer will be treated as materially partic-
ipating in an activity only if the taxpayer
is involved in the operations of the activity
on a basis that is regular, continuous, and
substantial.
The new markets tax credit under § 45D
is subject to the provisions of § 469 since
it is a credit allowable under subpart D of
part IV of subchapter A of the Code. A
credit may be disallowed under § 469 for a
taxable year if the credit attributable to the
taxable year arises in connection with the
conduct of a passive activity. Allowance
of the new markets tax credit under § 45D
is predicated on acquiring a qualified eq-
uity investment in the CDE. The CDE does
not pass through the new markets tax credit
to the person claiming the new markets tax
credit. Rather, the amount of the new mar-
kets tax credit is determined based on a
percentage of the amount paid to the CDE
for the qualified equity investment at its
original issue. Accordingly, in determin-
ing whether the new markets tax credit un-
der § 45D is disallowed under § 469, the
determination depends on whether the ac-
quisition of the qualified equity investment
in the CDE arises in connection with the
conduct of a passive activity. The deter-
mination of whether the new markets tax
credit under § 45D is disallowed under
§ 469 does not depend on the taxpayer’s
interest or extent of participation in the
CDE’s trade or business.
To be a passive activity, the activity of
acquiring a qualified equity investment in
the CDE must be in connection with the
conduct of a trade or business in which
the person claiming the new markets tax
credit does not materially participate, or be
a rental activity. Because the activity of
acquiring an equity investment in a CDE
is not a rental activity, the only issue is
whether the acquisition activity is in con-
nection with the conduct of a trade or busi-
ness activity (or in anticipation of a trade or
business) in which the person claiming the
new markets tax credit does not materially
participate.
The term “trade or business” is not de-
fined in either the Code or the regulations.
The determination of what constitutes a
trade or business depends on the facts and
circumstances of each case. The Supreme
Court, inCommissioner v. Groetzinger,
480 U.S. 23 (1987), has held that there are
generally two requirements for an activity
to constitute a trade or business: the activ-
ity must be conducted for income or profit,
and the activity must be engaged in with
some regularity and continuity.
If it is determined that the acquisition of
a qualified equity investment in a CDE is
in connection with the conduct of a trade
or business activity (or in anticipation of
a trade or business), a determination must
next be made as to whether the person
claiming the new markets tax credit ma-
terially participates in the activity. If the
person claiming the new markets tax credit
materially participates in the activity, the
new markets tax credit under § 45D will
not be disallowed under § 469.
In Situation 1, X’s activity of acquiring
a qualified equity investment in the CDE is
not in connection with the conduct of X’s
trade or business activity (or in anticipa-
tion of a trade or business). Consequently,
X’s new markets tax credit under § 45D
will not be disallowed under § 469.
In Situation 2, ABC allocates to A, B,
and C the amount of the new markets tax
credit that ABC claims. This allocation
must be made in accordance with § 704(b)
(which provides rules regarding a partner-
ship’s allocation of income, gain, loss, de-
duction, or credit (or item thereof) among
the partners). ABC’s activity of acquiring
a qualified equity investment in the CDE
is not in connection with the conduct of
ABC’s trade or business activity (or in an-
ticipation of a trade or business). Conse-
quently, the new markets tax credit allow-
able to ABC, and claimed by A, B, and C,
individually, will not be disallowed under
§469.
June 28, 20107702010–26 I.R.B.

HOLDING
1. Where an individual’s acquisition of
a qualified equity investment in a CDE is
not in connection with the conduct of the
individual’s trade or business (or in antic-
ipation of the individual’s trade or busi-
ness), the new markets tax credit allowable
to an individual under § 45D will not be a
passive activity credit under § 469.
2. Where a partnership’s acquisition of
a qualified equity investment in a CDE is
not in connection with the conduct of the
partnership’s trade or business (or in antic-
ipation of the partnership’s trade or busi-
ness), the new markets tax credit allowable
to the partnership under § 45D will not be
a passive activity credit under § 469.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Benjamin H. Weaver of the Office of
Associate Chief Counsel (Passthroughs &
Special Industries). For further informa-
tion regarding this revenue ruling, contact
Benjamin H. Weaver at (202) 622–3050.
For information regarding issues under
§ 45D, contact Julie Hanlon Bolton of
the Office of Associate Chief Counsel
(Passthroughs & Special Industries) at
(202) 622–3040. These are not toll-free
calls.
Section 704.—Partner’s
Distributive Share
26 CFR 1.704–3: Contributed property.
T.D. 9485
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Contributed Property
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains fi-
nal regulations under section 704(c) of
the Internal Revenue Code (Code) provid-
ing that the section 704(c) anti-abuse rule
takes into account the tax liabilities of both
the partners in a partnership and certain di-
rect and indirect owners of such partners.
These final regulations further provide
that a section 704(c) allocation method
cannot be used to achieve tax results in-
consistent with the intent of subchapter K
of the Code. The final regulations affect
partnerships and their partners.
DATES:Effective Date:These final regu-
lations are effective June 9, 2010.
Applicability Date:These final regula-
tions are applicable for taxable years be-
ginning after June 9, 2010.
FOR FURTHER INFORMATION
CONTACT: Bryan A. Rimmke at (202)
622–3050 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments
to 26 CFR part 1 under section 704 of
the Internal Revenue Code (Code). On
May 19, 2008, a notice of proposed
rulemaking (REG–100798–06, 2008–1
C.B. 1135) was published in theFederal
Register(73 FR 28765) in response
to the Joint Committee on Taxation’s
recommendation that the partnership
rules be strengthened to ensure that the
allocation rules in the regulations under
section 704(c) are not used to generate
unwarranted benefits. SeeThe Report
of Investigation of Enron Corporation
and Related Entities Regarding Federal
Tax and Compensation Issues, and Policy
Recommendations,(JCS–3-03) February
2003 at pg. 220. Because no requests
to speak were submitted by August 18,
2008, no public hearing was held. Written
comments, however, were received
in response to the notice of proposed
rulemaking. After consideration of these
comments, the proposed regulations are
adopted without change by this Treasury
decision.
Summary of Comments and
Explanation of Provisions
The comments on the proposed regu-
lations requested that examples be given
to specifically describe the types of trans-
actions to which these regulations apply.
Additionally, the comments requested ex-
amples to describe the types of transac-
tions which would not be abusive under
this regulation but would be abusive under
the general subchapter K anti-abuse rule
found in §1.701–2. In light of the fact that
these regulations are anti-abuse provisions
and the factually intensive analysis needed
to determine whether this regulation is ap-
plicable, the Treasury Department and the
IRS decline to adopt these comments.
Additional comments requested that the
Treasury Department and the IRS consider
both ade minimispartner rule for direct
partners similar to §1.704–1(b)(2)(iii)
and a rule for indirect partners where the
owners would need to be related to the
look-through entity within the meaning
of sections 267 or 707 in order to be
considered indirect partners for the pur-
poses of the regulation. For purposes of
§1.704–1(b)(2)(iii), ade minimispartner
is any partner, including a look-through
entity, that owns less than 10 percent of
the capital and profits of a partnership,
and who is allocated less than 10 percent
of each partnership item. The Treasury
Department and the IRS have determined
that neither ade minimispartner provision
nor a related partner provision for indirect
partners would conform to the intent of
this anti-abuse provision and therefore
decline to adopt such rules.
This Treasury decision adopts the pro-
posed regulations without substantive
change. Accordingly, the regulations
amend §1.704–3(a)(10) to provide that,
for purposes of applying the anti-abuse
rule, both direct and indirect partners are
considered. The final regulations provide
that an indirect partner is any direct or
indirect owner of a partnership, S corpo-
ration, or controlled foreign corporation
(as defined in section 957(a) or 953(c)), or
direct or indirect beneficiary of a trust or
estate, that is a partner in the partnership,
and any consolidated group of which the
partner in the partnership is a member
(within the meaning of §1.1502–1(h)).
However, an owner of a controlled for-
eign corporation is treated as an indirect
partner only with respect to the allocation
of items that enter into the computation
of a United States shareholder’s inclu-
sion under section 951(a) with respect to
the controlled foreign corporation, enter
into any person’s income attributable to
a United States shareholder’s inclusion
2010–26 I.R.B.771June 28, 2010

under section 951(a) with respect to the
controlled foreign corporation, or would
enter into the computations described in
this paragraph if such items were allocated
to the controlled foreign corporation.
These final regulations further pro-
vide that the principles of section 704(c),
together with the allocation methods de-
scribed in §1.704–3, paragraphs (b), (c)
and (d), apply only with respect to the
contributions of property to the partner-
ship. In that regard, the anti-abuse rule
of §1.701–2(b) provides that, if a partner-
ship is formed or availed of in connection
with a transaction a principal purpose of
which is to reduce substantially the present
value of the partners’ Federal tax liability
in a manner inconsistent with the intent
of subchapter K, the IRS may recast the
transaction for Federal tax purposes as
appropriate to achieve tax results that are
consistent with the intent of subchapter
K. Thus, even though a transaction may
satisfy the literal words of the statute or
regulations, the IRS may recast a trans-
action as appropriate to avoid tax results
that are inconsistent with the intent of
subchapter K, including but not limited to:
(i) disregarding purported partnerships, in
whole or part, so that partnership assets
are treated as owned by the partner; (ii)
disregarding one or more contributions or
(iii) disregarding one or more purported
partners. The final regulations also pro-
vide that, in determining if a purported
contribution of property to a partnership
should be recast to avoid results that are
inconsistent with subchapter K, one fac-
tor that may be relevant is the use of the
remedial method in which allocations of
remedial items of income, gain, loss or
deduction are made to one partner and al-
locations of offsetting remedial items are
made to a related partner.
Effective/Applicability Date
These regulations apply to taxable years
beginning after June 9, 2010. No inference
should be drawn from this effective date
with respect to prior law.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866. Therefore, a regulatory assessment
is not required. It has also been determined
that section 553(b) of the Administrative
Procedure Act (5 U.S.C. chapter 5) does
not apply to these regulations, and because
the regulation does not impose a collection
of information on small entities, the Regu-
latory Flexibility Act (5 U.S.C. chapter 6)
does not apply. Pursuant to section 7805(f)
of the Code, the notice of proposed rule-
making was submitted to the Chief Coun-
sel for Advocacy of the Small Business
Administration for comment on its impact
on small business.
Drafting Information
The principal author of these fi-
nal regulations is Bryan A. Rimmke,
Office of the Associate Chief Counsel
(Passthroughs and Special Industries),
IRS. However, other personnel from the
IRS and Treasury Department participated
in their development.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.704–3 is amended by:
1. Adding four sentences to paragraph
(a)(1) at the end of the last sentence and
revising paragraph (a)(10).
2. Revising the first sentence of para-
graph (f) and adding one sentence to the
end of the paragraph.
The revisions and additions read as fol-
lows:
§1.704–3 Contributed property.
(a)***(1)***Theprinciplesofthis
paragraph (a)(1), together with the meth-
ods described in paragraphs (b), (c) and
(d) of this section, apply only to contri-
butions of property that are otherwise re-
spected. See for example §1.701–2. Ac-
cordingly, even though a partnership’s al-
locationmethodmaybedescribedinthe
literal language of paragraphs (b), (c) or
(d) of this section, based on the particu-
lar facts and circumstances, the Commis-
sioner can recast the contribution as appro-
priate to avoid tax results inconsistent with
the intent of subchapter K. One factor that
may be considered by the Commissioner is
the use of the remedial allocation method
by related partners in which allocations of
remedial items of income, gain, loss or de-
duction are made to one partner and the al-
locations of offsetting remedial items are
made to a related partner.
*****
(10)Anti-abuse rule—(i)In general.
An allocation method (or combination of
methods) is not reasonable if the contri-
bution of property (or event that results in
reverse section 704(c) allocations) and the
corresponding allocation of tax items with
respect to the property are made with a
view to shifting the tax consequences of
built-in gain or loss among the partners
in a manner that substantially reduces the
present value of the partners’ aggregate tax
liability. For purposes of this paragraph
(a)(10), all references to the partners shall
include both direct and indirect partners.
(ii)Definition of indirect partner.An
indirect partneris any direct or indirect
owner of a partnership, S corporation, or
controlled foreign corporation (as defined
in section 957(a) or 953(c)), or direct or in-
direct beneficiary of a trust or estate, that
is a partner in the partnership, and any con-
solidated group of which the partner in the
partnership is a member (within the mean-
ing of §1.1502–1(h)). An owner (whether
directly or through tiers of entities) of a
controlled foreign corporation is treated as
an indirect partner only with respect to al-
locations of items of income, gain, loss,
or deduction that enter into the computa-
tion of a United States shareholder’s in-
clusion under section 951(a) with respect
to the controlled foreign corporation, enter
into any person’s income attributable to a
United States shareholder’s inclusion un-
der section 951(a) with respect to the con-
trolled foreign corporation, or would en-
ter into the computations described in this
sentence if such items were allocated to the
controlled foreign corporation.
*****
(f)Effective/Applicability Dates.
With the exception of paragraphs (a)(1),
(a)(8)(ii), (a)(8)(iii), (a)(10), and (a)(11)
of this section, this section applies
to properties contributed to a partner-
ship and to restatements pursuant to
June 28, 20107722010–26 I.R.B.

§1.704–1(b)(2)(iv)(f) on or after Decem-
ber 21, 1993. * * * Paragraphs (a)(1) and
(a)(10) of this section are applicable for
taxable years beginning after June 9, 2010.
Linda E. Stiff,
Deputy Commissioner for
Services and Enforcement.
Approved May 28, 2010.
Michael Mundaca,
Assistant Secretary
oftheTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on June 8, 2010,
8:45 a.m., and published in the issue of the Federal Register
for June 9, 2010, 75 F.R. 32659)
Section 6621.—Determina-
tion of Rate of Interest
26 CFR 301.6621–1: Interest rate.
Interest rates; underpayment and
overpayments.The rates for interest de-
termined under section 6621 of the Code
for the calendar quarter beginning July 1,
2010, will be 4 percent for overpayments
(3 percent in the case of a corporation), 4
percent for underpayments, and 6 percent
for large corporate underpayments. The
rate of interest paid on the portion of a
corporate overpayment exceeding $10,000
will be 1.5 percent.
Rev. Rul. 2010–14
Section 6621 of the Internal Revenue
Code establishes the rates for interest
on tax overpayments and tax underpay-
ments. Under section 6621(a)(1), the
overpayment rate is the sum of the federal
short-term rate plus 3 percentage points
(2 percentage points in the case of a cor-
poration), except the rate for the portion
of a corporate overpayment of tax exceed-
ing $10,000 for a taxable period is the
sum of the federal short-term rate plus
0.5 of a percentage point. Under section
6621(a)(2), the underpayment rate is the
sum of the federal short-term rate plus 3
percentage points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under section
6621(a)(2) is determined by substituting
“5 percentage points” for “3 percentage
points.” See section 6621(c) and section
301.6621–3 of the Regulations on Proce-
dure and Administration for the definition
of a large corporate underpayment and
for the rules for determining the appli-
cable date. Section 6621(c) and section
301.6621–3 are generally effective for
periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal
short-term rate for the first month in each
calendar quarter. Section 6621(b)(2)(A)
provides that the federal short-term rate
determined under section 6621(b)(1) for
any month applies during the first calen-
dar quarter beginning after that month.
Section 6621(b)(3) provides that the fed-
eral short-term rate for any month is the
federal short-term rate determined during
that month by the Secretary in accordance
with section 1274(d), rounded to the near-
est full percent (or, if a multiple of
1
/2of
1 percent, the rate is increased to the next
highest full percent).
Notice 88–59, 1988–1 C.B. 546, an-
nounced that, in determining the quarterly
interest rates to be used for overpayments
and underpayments of tax under section
6621, the Internal Revenue Service will
use the federal short-term rate based on
daily compounding because that rate is
most consistent with section 6621 which,
pursuant to section 6622, is subject to daily
compounding.
The federal short-term rate determined
in accordance with section 1274(d) dur-
ing April 2010 is the rate published in
Revenue Ruling 2010–12, 2010–18 I.R.B.
617 to take effect beginning May 1, 2010.
The federal short-term rate, rounded to the
nearest full percent, based on daily com-
pounding determined during the month of
April 2010 is 1 percent. Accordingly, an
overpayment rate of 4 percent (3 percent
in the case of a corporation) and an under-
payment rate of 4 percent are established
for the calendar quarter beginning July 1,
2010. The overpayment rate for the por-
tion of a corporate overpayment exceeding
$10,000 for the calendar quarter beginning
July 1, 2010, is 1.5 percent. The under-
payment rate for large corporate underpay-
ments for the calendar quarter beginning
July 1, 2010, is 6 percent. These rates ap-
ply to amounts bearing interest during that
calendar quarter.
Interest factors for daily compound in-
terest for annual rates of 1.5 percent, 3 per-
cent, 4 percent, and 6 percent are published
in Tables 8, 11, 13, and 17 of Rev. Proc.
95–17, 1995–1 C.B. 556, 562, 565, 567,
and 571.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Deborah Colbert-James of the Of-
fice of Associate Chief Counsel (Proce-
dure & Administration). For further infor-
mation regarding this revenue ruling, con-
tact Ms. Colbert-James at (202) 622–8143
(not a toll-free call).
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATE
In 1995–1 C.B.
DAILY RATE TABLE
Before Jul. 1, 1975
6%
Table 2, pg. 557
Jul. 1, 1975—Jan. 31, 1976
9%
Table 4, pg. 559
Feb. 1, 1976—Jan. 31, 19787%
Table 3, pg. 558
Feb. 1, 1978—Jan. 31, 19806%
Table 2, pg. 557
2010–26 I.R.B.773June 28, 2010

TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 — PERIODS ENDING DEC. 31, 1986 – Continued
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATE
In 1995–1 C.B.
DAILY RATE TABLE
Jan. 1, 1984—Jun. 30, 198411%
Table 75, pg. 629
Jul. 1, 1984—Dec. 31, 198411%
Table 75, pg. 629
Jan. 1, 1985—Jun. 30, 1985
13%
Table 31, pg. 585
Jul. 1, 1985—Dec. 31, 1985
11%
Table 27, pg. 581
Jan. 1, 1986—Jun. 30, 198610%
Table 25, pg. 579
Jul. 1, 1986—Dec. 31, 19869%
Table 23, pg. 577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1987—Mar. 31, 19878%21
575
9%23
577
Apr. 1, 1987—J
un. 30, 1987
8%21
575
9%23
577
Jul. 1, 1987—Sep. 30, 19878%21
575
9%23
577
Oct. 1, 1987—Dec. 31, 19879%23
577
10%
25579
Jan. 1, 1988—
Mar. 31, 1988
10%7362711%
75
629
Apr. 1, 1988—Jun. 30, 19889%71
625
10%73627
Jul. 1, 1988—Sep. 30, 19889%71
625
10%73627
Oct. 1, 1988
—Dec. 31, 1988
10%7362711%
75
629
Jan. 1, 1989—Mar. 31, 198910%
25579
11%27
581
Apr. 1, 1989—Jun. 30, 198911%27
581
12%29
583
Jul. 1, 198
9—Sep. 30, 1989
11%27
581
12%29
583
Oct. 1, 1989—Dec. 31, 198910%
25579
11%27
581
Jan. 1, 1990—Mar. 31, 199010%
25579
11%27
581
Apr. 1, 199
0—Jun. 30, 1990
10%
25579
11%27
581
Jul. 1, 1990—Sep. 30, 199010%
25579
11%27
581
Oct. 1, 1990—Dec. 31, 199010%
25579
11%27
581
Jan. 1, 19
91—Mar. 31, 1991
10%
25579
11%27
581
Apr. 1, 1991—Jun. 30, 19919%23
577
10%
25579
Jul. 1, 1991—Sep. 30, 19919%23
577
10%
25579
Oct. 1, 1
991—Dec. 31, 1991
9%23
577
10%
25579
Jan. 1, 1992—Mar. 31, 19928%696239%71
625
Apr. 1, 1992—Jun. 30, 19927%676218%69623
Jul. 1,
1992—Sep. 30, 1992
7%676218%69623
Oct. 1, 1992—Dec. 31, 19926%
65
6197%67621
Jan. 1, 1993—Mar. 31, 19936%17
571
7%19
573
Apr. 1
, 1993—Jun. 30, 1993
6%17
571
7%19
573
Jul. 1, 1993—Sep. 30, 19936%17
571
7%19
573
Oct. 1, 1993—Dec. 31, 19936%17
571
7%19
573
Jan.
1, 1994—Mar. 31, 1994
6%17
571
7%19
573
Apr. 1, 1994—Jun. 30, 19946%17
571
7%19
573
Jul. 1, 1994—Sep. 30, 19947%19
573
8%21
575
Oct.
1, 1994—Dec. 31, 1994
8%21
575
9%23
577
Jan. 1, 1995—Mar. 31, 1995
8%21
575
9%23
577
Apr
. 1, 1995—Jun. 30, 1995
9%23
577
10%
25579
Jul. 1, 1995—Sep. 30, 1995
8%21
575
9%23
577
Oct. 1, 1995—Dec. 31, 1995
8%21
575
9%23
577
Jan. 1, 1996—Mar. 31, 19968%696239%71
62
5
Ap
r. 1, 1996—Jun. 30, 1996
7%6762
1
8%6962
3
Jul. 1, 1996—Sep. 30, 19968%696239%71
625
Oct. 1, 1996—Dec. 31, 19968%696239%71
6
25
June 28, 20107742010–26 I.R.B.

TABLE OF INTEREST RATES
FROM JAN. 1, 1987 — DEC. 31, 1998 – Continued
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1997—Mar. 31, 19978%21
575
9%23
577
Apr. 1, 1997—Jun. 30, 19978%21
575
9%23
577
Jul. 1, 1997—Se
p. 30, 1997
8%21
575
9%23
577
Oct. 1, 1997—Dec. 31, 19978%21
575
9%23
577
Jan. 1, 1998—Mar. 31, 19988%21
575
9%23
577
Apr. 1, 1998—J
un. 30, 1998
7%19
573
8%21
575
Jul. 1, 1998—Sep. 30, 19987%19
573
8%21
575
Oct. 1, 1998—Dec. 31, 19987%19
573
8%21
575
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Jan. 1, 1999—M
ar. 31, 1999
7%19
573
Apr. 1, 1999—Jun. 30, 19998%21
575
Jul. 1, 1999—Sep. 30, 19998%21
575
Oct. 1, 1999—
Dec. 31, 1999
8%21
575
Jan. 1, 2000—Mar. 31, 20008%69623
Apr. 1, 2000—Jun. 30, 20009%71
625
Jul. 1, 2000
—Sep. 30, 2000
9%71
625
Oct. 1, 2000—Dec. 31, 20009%71
625
Jan. 1, 2001—Mar. 31, 20019%23
577
Apr. 1, 200
1—Jun. 30, 2001
8%21
575
Jul. 1, 2001—Sep. 30, 20017%19
573
Oct. 1, 2001—Dec. 31, 20017%19
573
Jan. 1, 20
02—Mar. 31, 2002
6%17
571
Apr. 1, 2002—Jun. 30, 20026%17
571
Jul. 1, 2002—Sep. 30, 20026%17
571
Oct. 1, 2
002—Dec. 31, 2002
6%17
571
Jan. 1, 2003—Mar. 31, 2003
5%15569
Apr. 1, 2003—Jun. 30, 2003
5%15569
Jul. 1, 2
003—Sep. 30, 2003
5%15569
Oct. 1, 2003—Dec. 31, 20034%13
567
Jan. 1, 2004—Mar. 31, 20044%61
615
Apr. 1,
2004—Jun. 30, 2004
5%
63617
Jul. 1, 2004—Sep. 30, 20044%61
615
Oct. 1, 2004—Dec. 31, 2004
5%
63617
Jan. 1, 2005—Mar. 31, 20055%15569
Apr. 1, 2005—Jun. 30, 2005
6%17
571
Jul.
1, 2005—Sep. 30, 2005
6%17
571
Oct. 1, 2005—Dec. 31, 2005
7%19
573
Jan. 1, 2006—Mar. 31, 20067%19
573
Apr. 1, 2006—Jun. 30, 20067%19
573
Jul
. 1, 2006—Sep. 30, 2006
8%21
575
Oct. 1, 2006—Dec. 31, 20068%21
575
Jan. 1, 2007—Mar. 31, 20078%21
575
Apr
. 1, 2007—Jun. 30, 2007
8%21
575
Jul. 1, 2007—Sep. 30, 20078%21
575
Oct. 1, 2007—Dec. 31, 20078%21
57
5
Ja
n. 1, 2008—Mar. 31, 2008
7%6762
1
Apr. 1, 2008—Jun. 30, 20086%
65
619
2010–26 I.R.B.775June 28, 2010

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995–1 C.B.
RATETABLEPG
Jul. 1, 2008—Sep. 30, 2008
5%
63617
Oct. 1, 2008—Dec. 31, 20086%
65
619
Jan. 1, 2009—Mar. 31, 2009
5%15569
Apr. 1, 2009—Jun. 30, 20094%13
567
Jul. 1, 2009—Sep. 30, 20094%13
567
Oct. 1, 2009—Dec. 31, 20094%13
567
Jan. 1, 2010—Mar. 31, 20104%13
567
Apr. 1, 2010—Jun. 30, 20104%13
567
Jul. 1, 2010—Sep. 30, 20104%13
567
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Jan. 1, 1999—Mar. 31, 19996%17
571
7%19
573
Apr. 1, 1999—Jun. 30, 19997%19
573
8%21
575
Jul. 1, 1999—
Sep. 30, 1999
7%19
573
8%21
575
Oct. 1, 1999—Dec. 31, 19997%19
573
8%21
575
Jan. 1, 2000—Mar. 31, 20007%676218%69623
Apr. 1, 2000
—Jun. 30, 2000
8%696239%71
625
Jul. 1, 2000—Sep. 30, 20008%696239%71
625
Oct. 1, 2000—Dec. 31, 20008%696239%71
625
Jan. 1, 200
1—Mar. 31, 2001
8%21
575
9%23
577
Apr. 1, 2001—Jun. 30, 20017%19
573
8%21
575
Jul. 1, 2001—Sep. 30, 20016%17
571
7%19
573
Oct. 1, 20
01—Dec. 31, 2001
6%17
571
7%19
573
Jan. 1, 2002—Mar. 31, 2002
5%15569
6%17
571
Apr. 1, 2002—Jun. 30, 2002
5%15569
6%17
571
Jul. 1, 2
002—Sep. 30, 2002
5%15569
6%17
571
Oct. 1, 2002—Dec. 31, 2002
5%15569
6%17
571
Jan. 1, 2003—Mar. 31, 20034%13
5675%15569
Apr. 1, 2
003—Jun. 30, 2003
4%13
5675%15569
Jul. 1, 2003—Sep. 30, 20034%13
5675%15569
Oct. 1, 2003—Dec. 31, 20033%11
565
4%13
567
Jan. 1,
2004—Mar. 31, 2004
3%
59
6134%61
615
Apr. 1, 2004—Jun. 30, 20044%61
6155%
63617
Jul. 1, 2004—Sep. 30, 20043%
59
6134%61
615
Oct. 1
, 2004—Dec. 31, 2004
4%61
6155%
63617
Jan. 1, 2005—Mar. 31, 2005
4%13
5675%15569
Apr.
1, 2005—Jun. 30, 2005
5%15569
6%17
571
Jul. 1, 2005—Sep. 30, 20055%15569
6%17
571
Oct. 1, 2005—Dec. 31, 2005
6%17
571
7%19
573
Jan. 1, 2006—Mar. 31, 20066%17
571
7%19
573
Apr
. 1, 2006—Jun. 30, 2006
6%17
571
7%19
573
Jul. 1, 2006—Sep. 30, 20067%19
573
8%21
575
Oct. 1, 2006—Dec. 31, 20067%19
573
8%21
575
Jan
. 1, 2007—Mar. 31, 2007
7%19
573
8%21
575
Apr. 1, 2007—Jun. 30, 20077%19
573
8%21
575
Jul. 1, 2007—Sep. 30, 20077%19
57
3
8%21
57
5
June 28, 20107762010–26 I.R.B.

TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 — PRESENT – Continued
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995–1 C.B.1995–1 C.B.
RATE TABLEPGRATE TABLEPG
Oct. 1, 2007—Dec. 31, 20077%19
573
8%21
575
Jan. 1, 2008—Mar. 31, 20086%
65
6197%67621
Apr. 1, 2008—Ju
n. 30, 2008
5%
636176%
65
619
Jul. 1, 2008—Sep. 30, 20084%61
6155%
63617
Oct. 1, 2008—Dec. 31, 2008
5%
636176%
65
619
Jan. 1, 2009—M
ar. 31, 2009
4%13
5675%15569
Apr. 1, 2009—Jun. 30, 20093%11
565
4%13
567
Jul. 1, 2009—Sep. 30, 20093%11
565
4%13
567
Oct. 1, 2009—
Dec. 31, 2009
3%11
565
4%13
567
Jan. 1, 2010—Mar. 31, 20103%11
565
4%13
567
Apr. 1, 2010—Jun. 30, 20103%11
565
4%13
567
Jul. 1, 2010—
Sep. 30, 2010
3%11
565
4%13
567
TABLE OF INTE
REST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1991—Mar. 31, 199113%31
585
Apr. 1, 1991
—Jun. 30, 1991
12%29
583
Jul. 1, 1991—Sep. 30, 199112%29
583
Oct. 1, 1991—Dec. 31, 199112%29
583
Jan. 1, 199
2—Mar. 31, 1992
11%
75
629
Apr. 1, 1992—Jun. 30, 199210%73627
Jul. 1, 1992—Sep. 30, 199210%73627
Oct. 1, 19
92—Dec. 31, 1992
9%71
625
Jan. 1, 1993—Mar. 31, 19939%23
577
Apr. 1, 1993—Jun. 30, 19939%23
577
Jul. 1, 1
993—Sep. 30, 1993
9%23
577
Oct. 1, 1993—Dec. 31, 19939%23
577
Jan. 1, 1994—Mar. 31, 19949%23
577
Apr. 1, 1
994—Jun. 30, 1994
9%23
577
Jul. 1, 1994—Sep. 30, 199410%
25579
Oct. 1, 1994—Dec. 31, 199411%27
581
Jan. 1, 1995—Mar. 31, 1995
11%27
581
Apr. 1, 1995—Jun. 30, 1995
12%29
583
Jul. 1
, 1995—Sep. 30, 1995
11%27
581
Oct. 1, 1995—Dec. 31, 1995
11%27
581
Jan. 1, 1996—Mar. 31, 199611%
75
629
Apr. 1, 1996—Jun. 30, 199610%73627
Jul.
1, 1996—Sep. 30, 1996
11%
75
629
Oct. 1, 1996—Dec. 31, 199611%
75
629
Jan. 1, 1997—Mar. 31, 199711%27
581
Apr
. 1, 1997—Jun. 30, 1997
11%27
581
Jul. 1, 1997—Sep. 30, 199711%27
581
Oct. 1, 1997—Dec. 31, 199711%27
581
Jan
. 1, 1998—Mar. 31, 1998
11%27
581
Apr. 1, 1998—Jun. 30, 199810%
25579
Jul. 1, 1998—Sep. 30, 199810%
2557
9
Oc
t. 1, 1998—Dec. 31, 1998
10%
25579
Jan. 1, 1999—Mar. 31, 19999%23
577
2010–26 I.R.B.777June 28, 2010

TABLE OF INTEREST RATES FOR
LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Apr. 1, 1999—Jun. 30, 199910%
25579
Jul. 1, 1999—Sep. 30, 199910%
25579
Oct. 1, 1999—Dec. 31, 199910%
25579
Jan. 1, 2000—Mar. 31, 200010%73627
Apr. 1, 2000—Jun. 30, 200011%
75
629
Jul. 1, 2000—Sep. 30, 200011%
75
629
Oct. 1, 2000—Dec. 31, 200011%
75
629
Jan. 1, 2001—Mar. 31, 200111%27
581
Apr. 1, 2001—Jun. 30, 200110%
25579
Jul. 1, 2001—Sep. 30, 20019%23
577
Oct. 1, 2001—Dec. 31, 20019%23
577
Jan. 1, 2002—Mar. 31, 20028%21
575
Apr. 1, 2002—Jun. 30, 20028%21
575
Jul. 1, 2002—Sep. 30, 20028%21
575
Oct. 1, 2002—Dec. 30, 20028%21
575
Jan. 1, 2003—Mar. 31, 20037%19
573
Apr. 1, 2003—Jun. 30, 20037%19
573
Jul. 1, 2003—Sep. 30, 20037%19
573
Oct. 1, 2003—Dec. 31, 20036%17
571
Jan. 1, 2004—Mar. 31, 20046%
65
619
Apr. 1, 2004—Jun. 30, 20047%67621
Jul. 1, 2004—Sep. 30, 20046%
65
619
Oct. 1, 2004—Dec. 31, 20047%67621
Jan. 1, 2005—Mar. 31, 2005
7%19
573
Apr. 1, 2005—Jun. 30, 2005
8%21
575
Jul. 1, 2005—Sep. 30, 2005
8%21
575
Oct. 1, 2005—Dec. 31, 2005
9%23
577
Jan. 1, 2006—Mar. 31, 20069%23
577
Apr. 1, 2006—Jun. 30, 20069%23
577
Jul. 1, 2006—Sep. 30, 200610%
25579
Oct. 1, 2006—Dec. 31, 200610%
25579
Jan. 1, 2007—Mar. 31, 200710%
25579
Apr. 1, 2007—Jun. 30, 200710%
25579
Jul. 1, 2007—Sep. 30, 200710%
25579
Oct. 1, 2007—Dec. 31, 200710%
25579
Jan. 1, 2008—Mar. 31, 20089%71
625
Apr. 1, 2008—Jun. 30, 20088%69623
Jul. 1, 2008—Sep. 30, 20087%67621
Oct. 1, 2008—Dec. 31, 20088%69623
Jan. 1, 2009—Mar. 31, 20097%19
573
Apr. 1, 2009—Jun. 30, 20096%17
571
Jul. 1, 2009—Sep. 30, 20096%17
571
Oct. 1, 2009—Dec. 31, 20096%17
571
Jan. 1, 2010—Mar. 31, 20106%17
571
Apr. 1, 2010—Jun. 30, 20106%17
571
Jul. 1, 2010—Sep. 30, 20106%17
571
June 28, 20107782010–26 I.R.B.

TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT
1995–1 C.B.
RATETABLEPG
Jan. 1, 1995—Mar. 31, 19956.5%
18
572
Apr. 1, 1995—Jun. 30, 19957.5%
20
574
Jul. 1, 1995—Sep. 30, 19956.5%
18
572
Oct. 1, 1995—Dec. 31, 19956.5%
18
572
Jan. 1, 1996—Mar. 31, 1996
6.5%
66620
Apr. 1, 1996—Jun. 30, 1996
5.5%
64618
Jul. 1, 1996—Sep. 30, 1996
6.5%
66620
Oct. 1, 1996—Dec. 31, 1996
6.5%
66620
Jan. 1, 1997—Mar. 31, 1997
6.5%
18
572
Apr. 1, 1997—Jun. 30, 1997
6.5%
18
572
Jul. 1, 1997—Sep. 30, 1997
6.5%
18
572
Oct. 1, 1997—Dec. 31, 1997
6.5%
18
572
Jan. 1, 1998—Mar. 31, 1998
6.5%
18
572
Apr. 1, 1998—Jun. 30, 1998
5.5%
16
570
Jul. 1, 1998—Sep. 30, 1998
5.5%
16
570
Oct. 1, 1998—Dec. 31, 1998
5.5%
16
570
Jan. 1, 1999—Mar. 31, 1999
4.5%
14
568
Apr. 1, 1999—Jun. 30, 1999
5.5%
16
570
Jul. 1, 1999—Sep. 30, 1999
5.5%
16
570
Oct. 1, 1999—Dec. 31, 1999
5.5%
16
570
Jan. 1, 2000—Mar. 31, 2000
5.5%
64618
Apr. 1, 2000—Jun. 30, 2000
6.5%
66620
Jul. 1, 2000—Sep. 30, 2000
6.5%
66620
Oct. 1, 2000—Dec. 31, 2000
6.5%
66620
Jan. 1, 2001—Mar. 31, 2001
6.5%
18
572
Apr. 1, 2001—Jun. 30, 2001
5.5%
16
570
Jul. 1, 2001—Sep. 30, 2001
4.5%
14
568
Oct. 1, 2001—Dec. 31, 2001
4.5%
14
568
Jan. 1, 2002—Mar. 31, 2002
3.5%
12
566
Apr. 1, 2002—Jun. 30, 2002
3.5%
12
566
Jul. 1, 2002—Sep. 30, 2002
3.5%
12
566
Oct. 1, 2002—Dec. 31, 2002
3.5%
12
566
Jan. 1, 2003—Mar. 31, 2003
2.5%
10
564
Apr. 1, 2003—Jun. 30, 2003
2.5%
10
564
Jul. 1, 2003—Sep. 30, 2003
2.5%
10
564
Oct. 1, 2003—Dec. 31, 2003
1.5%
8
562
Jan. 1, 2004—Mar. 31, 2004
1.5%56
610
Apr. 1, 2004—Jun. 30, 2004
2.5%58
612
Jul. 1, 2004—Sep. 30, 2004
1.5%56
610
Oct. 1, 2004—Dec. 31, 2004
2.5%58
612
Jan. 1, 2005—Mar. 31, 20052.5%
10
564
Apr. 1, 2005—Jun. 30, 20053.5%
12
566
Jul. 1, 2005—Sep. 30, 20053.5%
12
566
Oct. 1, 2005—Dec. 31, 20054.5%
14
568
Jan. 1, 2006—Mar. 31, 2006
4.5%
14
568
Apr. 1, 2006—Jun. 30, 2006
4.5%
14
568
Jul. 1, 2006—Sep. 30, 2006
5.5%
16
570
Oct. 1, 2006—Dec. 31, 2006
5.5%
16
570
Jan. 1, 2007—Mar. 31, 2007
5.5%
16
570
Apr. 1, 2007—Jun. 30, 2007
5.5%
16
570
Jul. 1, 2007—Sep. 30, 2007
5.5%
16
570
Oct. 1, 2007—Dec. 31, 2007
5.5%
16
570
Jan. 1, 2008—Mar. 31, 2008
4.5%
62616
Apr. 1, 2008—Jun. 30, 2008
3.5%
60614
Jul. 1, 2008—Sep. 30, 2008
2.5%58
612
2010–26 I.R.B.779June 28, 2010

TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS E
XCEEDING $10,000
FROM JANUARY 1, 1995 — PRESENT – Continued
1995–1 C.B.
RATETABLEPG
Oct. 1, 2008—Dec. 31, 2008
3.5%
60614
Jan. 1, 2009—Mar. 31, 2009
2.5%
10
564
Apr. 1, 2009—Jun. 30, 2009
1.5%
8
562
Jul. 1, 2009—Sep. 30, 2009
1.5%
8
562
Oct. 1, 2009—Dec. 31, 2009
1.5%
8
562
Jan. 1, 2010—Mar. 31, 2010
1.5%
8
562
Apr. 1, 2010—Jun. 30, 2010
1.5%
8
562
Jul. 1, 2010—Sep. 30, 2010
1.5%
8
562
June 28, 20107802010–26 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2010–47
This notice provides guidance as to the
corporate bond weighted average interest
rate and the permissible range of interest
rates specified under § 412(b)(5)(B)(ii)(II)
of the Internal Revenue Code as in ef-
fect for plan years beginning before 2008.
It also provides guidance on the corpo-
rate bond monthly yield curve (and the
corresponding spot segment rates), the
24-month average segment rates, and
the funding transitional segment rates
under § 430(h)(2). In addition, this no-
tice provides guidance as to the interest
rate on 30-year Treasury securities un-
der § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008, the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I), and the min-
imum present value segment rates under
§ 417(e)(3)(D) as in effect for plan years
beginning after 2007.
CORPORATE BOND WEIGHTED
AVERAGE INTEREST RATE
Sections412(b)(5)(B)(ii)and
412(l)(7)(C)(i), as amended by the Pen-
sion Funding Equity Act of 2004 and by
the Pension Protection Act of 2006 (PPA),
provide that the interest rates used to cal-
culate current liability and to determine
the required contribution under § 412(l)
for plan years beginning in 2004 through
2007 must be within a permissible range
based on the weighted average of the rates
of interest on amounts invested conser-
vatively in long term investment grade
corporate bonds during the 4-year period
ending on the last day before the beginning
of the plan year.
Notice 2004–34, 2004–1 C.B. 848, pro-
vides guidelines for determining the cor-
porate bond weighted average interest rate
and the resulting permissible range of in-
terest rates used to calculate current liabil-
ity. That notice establishes that the corpo-
rate bond weighted average is based on the
monthly composite corporate bond rate de-
rived from designated corporate bond in-
dices. The methodology for determining
the monthly composite corporate bond rate
as set forth in Notice 2004–34 continues to
apply in determining that rate. See Notice
2006–75, 2006–2 C.B. 366.
The composite corporate bond rate for
May 2010 is 5.67 percent. Pursuant to No-
tice 2004–34, the Service has determined
this rate as the average of the monthly
yields for the included corporate bond in-
dices for that month.
The following corporate bond weighted
average interest rate was determined for
plan years beginning in the month shown
below.
For Plan Years
Beginning inPermissible Range
MonthYear
Corporate
Bond Weighted
Average90%to100%
June20106.34
5.71
6.34
YIELD CURVE AND SEGMENT
RATES
Generally for plan years beginning
after 2007 (except for delayed effective
dates for certain plans under sections 104,
105, and 106 of PPA), § 430 of the Code
specifies the minimum funding require-
ments that apply to single employer plans
pursuant to § 412. Section 430(h)(2) spec-
ifies the interest rates that must be used
to determine a plan’s target normal cost
and funding target. Under this provision,
present value is generally determined us-
ing three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods.
However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates. For
plan years beginning in 2008 and 2009, a
transitional rule under § 430(h)(2)(G) pro-
vides that the segment rates are blended
with the corporate bond weighted average
as specified above. An election may be
made under § 430(h)(2)(G)(iv) to use the
segment rates without applying the transi-
tional rule.
Notice 2007–81, 2007–2 C.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, the
24-month average corporate bond segment
rates, and the funding transitional segment
rates used to compute the target normal
cost and the funding target. Pursuant to
Notice 2007–81, the monthly corporate
bond yield curve derived from May 2010
data is in Table I at the end of this notice.
The spot first, second, and third segment
rates for the month of May 2010 are, re-
spectively, 2.34, 5.42, and 6.26. The three
24-month average corporate bond seg-
ment rates applicable for June 2010 under
the election of § 430(h)(2)(G)(iv) are as
follows:
First
Segment
Second
Segment
Third
Segment
4.16
6.52
6.68
2010–26 I.R.B.781June 28, 2010

The transitional segment rates under
§ 430(h)(2)(G) applicable for June 2010,
taking into account the corporate bond
weighted average of 6.34 stated above, are
as follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
20094.896.46
6.57
The transitional rule of § 430(h)(2)(G)
does not apply to plan years starting in
2010. Therefore, for a plan year starting in
2010 with a lookback month to June 2010,
the funding segment rates are the three
24-month average corporate bond segment
rates applicable for June 2010, listed above
without blending for the transitional pe-
riod.
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 417(e)(3)(A)(ii)(II) (prior to
amendment by PPA) defines the appli-
cable interest rate, which must be used
for purposes of determining the minimum
present value of a participant’s benefit
under § 417(e)(1) and (2), as the annual
rate of interest on 30-year Treasury se-
curities for the month before the date
of distribution or such other time as the
Secretary may by regulations prescribe.
Section 1.417(e)–1(d)(3) of the Income
Tax Regulations provides that the applica-
bleinterestrateforamonthistheannual
rate of interest on 30-year Treasury secu-
rities as specified by the Commissioner
for that month in revenue rulings, notices
or other guidance published in the Internal
Revenue Bulletin.
The rate of interest on 30-year Treasury
securities for May 2010 is 4.29 percent.
The Service has determined this rate as the
average of the yield on the 30-year Trea-
sury bond maturing in February 2040 de-
termined each day through May 12, 2010,
and the yield on the 30-year Treasury bond
maturing in May 2040 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 Years
Beginning inPermissible Range
MonthYear
30-Year
Treasury
Weighted
Average
90%to
105%
June20104.39
3.95
4.61
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 May 2010, taking into
account the May 2010 30-year Treasury
rate of 4.29 stated above, are as follows:
For Plan Years
Beginning in
First
Segment
Second
Segment
Third
Segment
2009
3.51
4.74
5.08
20103.124.97
5.47
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
June 28, 20107822010–26 I.R.B.

Table I
Monthly Yield Curve for May 2010
Derived from May 2010 Data
Maturity YieldMaturity YieldMaturity YieldMaturity YieldMaturity Yield
0.5
1.13
20.5
6.02
40.5
6.29
60.5
6.39
80.5
6.43
1.01.3121.06.0341.0
6.29
61.0
6.39
81.06.43
1.51.5321.5
6.04
41.5
6.30
61.5
6.39
81.5
6.44
2.01.8022.0
6.05
42.06.3062.0
6.39
82.06.44
2.5
2.11
22.5
6.06
42.5
6.30
62.5
6.39
82.5
6.44
3.0
2.45
23.06.0743.06.3163.0
6.39
83.06.44
3.5
2.80
23.5
6.08
43.5
6.31
63.5
6.39
83.5
6.44
4.03.1324.0
6.09
44.06.3164.06.4084.06.44
4.5
3.44
24.5
6.10
44.5
6.32
64.5
6.40
84.5
6.44
5.0
3.72
25.0
6.11
45.0
6.32
65.0
6.40
85.0
6.44
5.5
3.97
25.5
6.12
45.5
6.32
65.5
6.40
85.5
6.44
6.0
4.19
26.06.1346.06.3266.06.4086.06.44
6.5
4.39
26.5
6.14
46.5
6.33
66.5
6.40
86.5
6.44
7.04.5627.06.1547.06.3367.06.4087.06.44
7.5
4.71
27.56.1547.5
6.33
67.5
6.41
87.56.45
8.0
4.85
28.06.1648.06.3468.06.4188.0
6.45
8.5
4.97
28.5
6.17
48.5
6.34
68.5
6.41
88.56.45
9.0
5.08
29.0
6.18
49.0
6.34
69.0
6.41
89.0
6.45
9.5
5.18
29.56.1849.56.3469.56.4189.5
6.45
10.05.2730.0
6.19
50.06.34 70.06.41
90.0
6.45
10.55.3530.5
6.19
50.56.3570.5
6.4190.5
6.45
11.0
5.42
31.06.20
51.06.35
71.06.41
91.0
6.45
11.5
5.49
31.5
6.21
51.56.3571.5
6.4291.5
6.45
12.0
5.55
32.06.21
52.06.35
72.06.42
92.0
6.45
12.55.6032.5
6.22
52.5
6.36
72.5
6.4292.5
6.45
13.05.6533.06.2253.06.3673.06.42
93.0
6.45
13.5
5.69
33.5
6.23
53.5
6.36
73.5
6.4293.5
6.45
14.0
5.73
34.06.23
54.0
6.3674.06.42
94.0
6.45
14.55.7734.5
6.24
54.5
6.36
74.5
6.4294.56.46
15.05.8035.0
6.24
55.0
6.37
75.0
6.4295.06.46
15.55.8335.56.2555.5
6.37
75.5
6.4295.56.46
16.05.8536.06.2556.06.3776.06.43
96.0
6.46
16.55.8836.5
6.26
56.5
6.37
76.5
6.4396.56.46
17.05.9037.06.26
57.0
6.3777.06.43
97.0
6.46
17.5
5.92
37.5
6.27
57.5
6.38
77.5
6.4397.56.46
18.05.9438.06.27
58.0
6.3878.06.43
98.0
6.46
18.5
5.96
38.5
6.27
58.5
6.38
78.5
6.4398.56.46
19.0
5.97
39.0
6.2859.06.38
79.0
6.43
99.0
6.46
19.55.9939.56.2859.56.3879.56.4399.56.46
20.06.0040.0
6.29
60.06.3880.06.43100.06.46
2010–26 I.R.B.783June 28, 2010

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that the
same principle also applies to B, the earlier
ruling is amplified. (Compare withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
It is not used where a position in a prior
ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is self
contained. In this case, the previously pub-
lished ruling is first modified and then, as
modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names in
subsequent rulings. After the original rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings in
the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases
in litigation, or the outcome of a Service
study.
Abbreviations
The fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
DC—Dummy Corporation.
DE—Donee.
Del. Order
—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
June 28, 2010i2010–26 I.R.B.

Numerical Finding List
1
Bulletins 2010–1 through 2010–26
Announcements:
2010-1, 2010-4 I.R.B.333
2010-2, 2010-2 I.R.B.271
2010-3, 2010-4 I.R.B.333
2010-4, 2010-5 I.R.B.384
2010-5, 2010-6 I.R.B.402
2010-6, 2010-6 I.R.B.402
2010-7, 2010-6 I.R.B.403
2010-8, 2010-7 I.R.B.408
2010-9, 2010-7 I.R.B.408
2010-10, 2010-7 I.R.B.410
2010-11, 2010-10 I.R.B.438
2010-12, 2010-7 I.R.B.410
2010-13, 2010-8 I.R.B.426
2010-14, 2010-11 I.R.B.449
2010-15, 2010-10 I.R.B.438
2010-16, 2010-11 I.R.B.450
2010-17, 2010-13 I.R.B.515
2010-18, 2010-12 I.R.B.460
2010-19, 2010-14 I.R.B.529
2010-20, 2010-15 I.R.B.551
2010-21, 2010-15 I.R.B.551
2010-22, 2010-16 I.R.B.602
2010-23, 2010-16 I.R.B.602
2010-24, 2010-15 I.R.B.587
2010-25, 2010-15 I.R.B.588
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
2010-28, 2010-17 I.R.B.616
2010-29, 2010-17 I.R.B.616
2010-30, 2010-19 I.R.B.668
2010-31, 2010-19 I.R.B.681
2010-32, 2010-19 I.R.B.681
2010-33, 2010-18 I.R.B.658
2010-34, 2010-20 I.R.B.685
2010-35, 2010-20 I.R.B.685
2010-36, 2010-21 I.R.B.696
2010-37, 2010-20 I.R.B.685
2010-38, 2010-21 I.R.B.696
2010-39, 2010-22 I.R.B.724
2010-40, 2010-22 I.R.B.725
2010-41, 2010-25 I.R.B.767
2010-42, 2010-25 I.R.B.768
Notices:
2010-1, 2010-2 I.R.B.251
2010-2, 2010-2 I.R.B.251
2010-3, 2010-2 I.R.B.253
2010-4, 2010-2 I.R.B.253
2010-5, 2010-2 I.R.B.256
2010-6, 2010-3 I.R.B.275
2010-7, 2010-3 I.R.B.296
Notices— Continued:
2010-8, 2010-3 I.R.B.297
2010-9, 2010-3 I.R.B.298
2010-10, 2010-3 I.R.B.299
2010-11, 2010-4 I.R.B.326
2010-12, 2010-4 I.R.B.326
2010-13, 2010-4 I.R.B.327
2010-14, 2010-5 I.R.B.344
2010-15, 2010-6 I.R.B.390
2010-16, 2010-6 I.R.B.396
2010-17, 2010-14 I.R.B.519
2010-18, 2010-14 I.R.B.525
2010-19, 2010-7 I.R.B.404
2010-20, 2010-8 I.R.B.422
2010-21, 2010-12 I.R.B.451
2010-22, 2010-10 I.R.B.435
2010-23, 2010-11 I.R.B.441
2010-24, 2010-12 I.R.B.452
2010-25, 2010-14 I.R.B.527
2010-26, 2010-14 I.R.B.527
2010-27, 2010-15 I.R.B.531
2010-28, 2010-15 I.R.B.541
2010-29, 2010-15 I.R.B.547
2010-30, 2010-18 I.R.B.650
2010-31, 2010-16 I.R.B.594
2010-32, 2010-16 I.R.B.594
2010-33, 2010-17 I.R.B.609
2010-34, 2010-17 I.R.B.612
2010-35, 2010-19 I.R.B.660
2010-36, 2010-17 I.R.B.612
2010-37, 2010-18 I.R.B.654
2010-38, 2010-20 I.R.B.682
2010-39, 2010-24 I.R.B.756
2010-40, 2010-21 I.R.B.693
2010-41, 2010-22 I.R.B.715
2010-42, 2010-23 I.R.B.733
2010-43, 2010-22 I.R.B.716
2010-44, 2010-22 I.R.B.717
2010-45, 2010-23 I.R.B.734
2010-46, 2010-24 I.R.B.757
2010-47, 2010-26 I.R.B.781
Proposed Regulations:
REG-132232-08, 2010-6 I.R.B.401
REG-134235-08, 2010-16 I.R.B.596
REG-137036-08, 2010-6 I.R.B.398
REG-101896-09, 2010-5 I.R.B.347
REG-117501-09, 2010-11 I.R.B.442
REG-131028-09, 2010-4 I.R.B.332
REG-148681-09, 2010-11 I.R.B.443
REG-106750-10, 2010-25 I.R.B.765
REG-114494-10, 2010-22 I.R.B.723
Revenue Procedures:
2010-1, 2010-1 I.R.B.1
2010-2, 2010-1 I.R.B.90
Revenue Procedures— Continued:
2010-3, 2010-1 I.R.B.110
2010-4, 2010-1 I.R.B.122
2010-5, 2010-1 I.R.B.165
2010-6, 2010-1 I.R.B.193
2010-7, 2010-1 I.R.B.231
2010-8, 2010-1 I.R.B.234
2010-9, 2010-2 I.R.B.258
2010-10, 2010-3 I.R.B.300
2010-11, 2010-2 I.R.B.269
2010-12, 2010-3 I.R.B.302
2010-13, 2010-4 I.R.B.329
2010-14, 2010-12 I.R.B.456
2010-15, 2010-7 I.R.B.404
2010-16, 2010-19 I.R.B.664
2010-17, 2010-8 I.R.B.425
2010-18, 2010-9 I.R.B.427
2010-19, 2010-13 I.R.B.469
2010-20, 2010-14 I.R.B.528
2010-21, 2010-13 I.R.B.473
2010-22, 2010-23 I.R.B.747
2010-23, 2010-24 I.R.B.762
2010-24, 2010-25 I.R.B.764
Revenue Rulings:
2010-1, 2010-2 I.R.B.248
2010-2, 2010-3 I.R.B.272
2010-3, 2010-3 I.R.B.272
2010-4, 2010-4 I.R.B.309
2010-5, 2010-4 I.R.B.312
2010-6, 2010-6 I.R.B.387
2010-7, 2010-8 I.R.B.417
2010-8, 2010-10 I.R.B.432
2010-9, 2010-13 I.R.B.461
2010-10, 2010-13 I.R.B.461
2010-11, 2010-14 I.R.B.516
2010-12, 2010-18 I.R.B.617
2010-13, 2010-21 I.R.B.691
2010-14, 2010-26 I.R.B.773
2010-15, 2010-23 I.R.B.730
2010-16, 2010-26 I.R.B.769
2010-17, 2010-26 I.R.B.769
Tax Conventions:
2010-2, 2010-2 I.R.B.271
2010-26, 2010-16 I.R.B.604
2010-27, 2010-18 I.R.B.657
Treasury Decisions:
9474, 2010-4 I.R.B.322
9475, 2010-4 I.R.B.304
9476, 2010-5 I.R.B.336
9477, 2010-6 I.R.B.385
9478, 2010-4 I.R.B.315
9479, 2010-18 I.R.B.618
9480, 2010-11 I.R.B.439
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin
2009–52, dated December 28, 2009.
2010–26 I.R.B.iiJune 28, 2010

Treasury Decisions— Continued:
9481, 2010-17 I.R.B.605
9482, 2010-22 I.R.B.698
9483, 2010-23 I.R.B.726
9484, 2010-24 I.R.B.748
9485, 2010-26 I.R.B.771
June 28, 2010iii2010–26 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2010–1 through 2010–26
Announcements:
2009-23
Corrected by
Ann. 2010-29, 2010-17 I.R.B.616
2009-51
Supplemented and superseded by
Ann. 2010-16, 2010-11 I.R.B.450
2010-4
Corrected by
Ann. 2010-10, 2010-7 I.R.B.410
2010-22
Corrected by
Ann. 2010-34, 2010-20 I.R.B.685
Notices:
97-66
Modified by
Notice 2010-46, 2010-24 I.R.B.757
2005-88
Superseded by
Notice 2010-13, 2010-4 I.R.B.327
2006-87
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-25
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2007-77
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
2008-14
Modified and superseded by
Notice 2010-33, 2010-17 I.R.B.609
2008-41
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-55
Modified by
Notice 2010-3, 2010-2 I.R.B.253
2008-88
Modified by
Notice 2010-7, 2010-3 I.R.B.296
2008-107
Superseded by
Notice 2010-27, 2010-15 I.R.B.531
Notices— Continued:
2008-113
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-115
Modified by
Notice 2010-6, 2010-3 I.R.B.275
2008-116
Modified and superseded by
Notice 2010-32, 2010-16 I.R.B.594
2009-11
Amplified by
Notice 2010-9, 2010-3 I.R.B.298
2009-13
Obsoleted by
T.D. 9478, 2010-4 I.R.B.315
REG-131028-09, 2010-4 I.R.B.332
2009-35
Supplemented by
Notice 2010-17, 2010-14 I.R.B.519
2009-38
Amplified and superseded by
Notice 2010-2, 2010-2 I.R.B.251
2009-62
Modified and supplemented by
Notice 2010-23, 2010-11 I.R.B.441
Proposed Regulations:
REG-127270-06
Hearing scheduled by
Ann. 2010-6, 2010-6 I.R.B.402
REG-134235-08
Hearing scheduled by
Ann. 2010-33, 2010-18 I.R.B.658
Revenue Procedures:
80-59
Modified and superseded by
Rev. Proc. 2010-11, 2010-2 I.R.B.269
87-35
Obsoleted by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2001-18
Superseded by
Rev. Proc. 2010-16, 2010-19 I.R.B.664
2008-14
Updated by
Rev. Proc. 2010-15, 2010-7 I.R.B.404
2009-1
Superseded by
Rev. Proc. 2010-1, 2010-1 I.R.B.1
Revenue Procedures— Continued:
2009-2
Superseded by
Rev. Proc. 2010-2, 2010-1 I.R.B.90
2009-3
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-4
Superseded by
Rev. Proc. 2010-4, 2010-1 I.R.B.122
2009-5
Superseded by
Rev. Proc. 2010-5, 2010-1 I.R.B.165
2009-6
Superseded by
Rev. Proc. 2010-6, 2010-1 I.R.B.193
2009-7
Superseded by
Rev. Proc. 2010-7, 2010-1 I.R.B.231
2009-8
Superseded by
Rev. Proc. 2010-8, 2010-1 I.R.B.234
2009-9
Superseded by
Rev. Proc. 2010-9, 2010-2 I.R.B.258
2009-15
Amplified and superseded by
Rev. Proc. 2010-12, 2010-3 I.R.B.302
2009-17
Superseded by
Rev. Proc. 2010-21, 2010-13 I.R.B.473
2009-25
Superseded by
Rev. Proc. 2010-3, 2010-1 I.R.B.110
2009-27
Obsoleted by
Rev. Proc. 2010-23, 2010-24 I.R.B.762
2009-50
Section 3.20 modified and superseded by
Rev. Proc. 2010-24, 2010-25 I.R.B.764
2009-55
Corrected by
Ann. 2010-11, 2010-10 I.R.B.438
2010-1
Corrected by
Ann. 2010-5, 2010-6 I.R.B.402
Revenue Rulings:
67-436
Obsoleted by
REG-101896-09, 2010-5 I.R.B.347
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2009–27 through 2009–52 is in Internal Revenue Bulletin 2009–52, dated December 28,
2009.
2010–26 I.R.B.ivJune 28, 2010

Revenue Rulings— Continued:
92-19
Supplemented in part by
Rev. Rul. 2010-7, 2010-8 I.R.B.417
2003-20
Amplified by
Rev. Rul. 2010-17, 2010-26 I.R.B.769
2008-52
Supplemented and superseded by
Rev. Rul. 2010-2, 2010-3 I.R.B.272
Treasury Decisions:
9350
Corrected by
Ann. 2010-38, 2010-21 I.R.B.696
Ann. 2010-39, 2010-22 I.R.B.724
9424
Corrected by
Ann. 2010-18, 2010-12 I.R.B.460
9443
Corrected by
Ann. 2010-8, 2010-7 I.R.B.408
9458
Corrected by
Ann. 2010-7, 2010-6 I.R.B.403
June 28, 2010v2010–26 I.R.B.

INDEX
Internal Revenue Bulletins 2010–1 through
2010–26
The abbreviation and number in parenthesis following the index entry
refer to the specific item; numbers in roman and italic type following
the parenthesis refers to the Internal Revenue Bulletin in which the item
may be found and the page number on which it appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
EMPLOYEE PLANS
Correction of certain failures of nonqualified deferred compen-
sation plans to comply with the plan document requirements
of section 409A (Notice 6) 3,275
Defined benefit plans, determination letters (Ann 20) 15,551
Dependent coverage of children under group health plans to age
26 (TD 9482) 22,698; (REG–114494–10) 22,723
Determination letters, issuing procedures (RP 6) 1,193
Diversification requirements for certain defined contribution
plans (TD 9484) 24,748
FBAR administrative relief forsignature authority and certain
commingled funds (Notice 23) 11,441
FBAR filing requirements (Ann 16) 11,450
Full funding limitations, weighted average interest rates, seg-
ment rates for:
January 2010 (Notice 14) 5,344
February 2010 (Notice 20) 8,422
March 2010 (Notice 24) 12,452
April 2010 (Notice 36) 17,612
May2010(Notice40)21,693
June 2010 (Notice 47) 26,781
Health care benefits with respect to children under age 27, tax
treatment (Notice 38) 20,682
Letter rulings:
And determination letters, areas which will not be issued
from:
Associates Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,110
Associate Chief Counsel (International) (RP 7) 1,231
And general information letters, procedures (RP 4) 1,122
User fees, request for letter rulings (RP 8) 1,234
Parity in mental health and substance use disorder benefits under
group health plans (TD 9479) 18,618
EMPLOYEE PLANS—Cont.
Proposed regulations:
26 CFR 54.9815–2714, added; dependent coverage of chil-
dren under group health plans to age 26 (REG–114494–10)
22,723
Regulations:
26 CFR 1.401(a)35–1, added; diversification requirements for
certain defined contribution plans (TD 9484) 24,748
26 CFR 54.9812–1T, revised; 602.101, amended; interim
final rules under the Paul Wellstone and Pete Domenici
Mental Health Parity and Addiction Equity Act of 2008
(MHPAEA) (TD 9479) 18,618
26 CFR 54.9815–2714T, added; 602.101, amended; depen-
dent coverage of children under group health plans to age
26 (TD 9482) 22,698
Technical advice to IRS employees (RP 5) 1,165
Qualified plans:
Changes in funding method (Ann 3) 4,333
Military services, HEART Act (Notice 15) 6,390
EMPLOYMENT TAX
Definition of last known address (RP 16) 19,664
Designation of section 3504 agent for FUTA tax purposes
(REG–137036–08) 6,398
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Health care benefits with respect to children under age 27, tax
treatment (Notice 38) 20,682
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann5)6,402
Proposed regulations:
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
26 CFR 31.3504, revised; section 3504 agent employment tax
liability (REG–137036–08) 6,398
Technical Advice Memoranda (TAMs) (RP 2) 1,90
ESTATE TAX
Definition of last known address (RP 16) 19,664
FBAR administrative relief for signature authority and certain
commingled funds (Notice 23) 11,441
FBAR filing requirements (Ann 16) 11,450
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann5)6,402
Proposed regulations:
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
Technical Advice Memoranda (TAMs) (RP 2) 1,90
2010–26 I.R.B.viJune 28, 2010

EXCISE TAX
Dependent coverage of children under group health plans to age
26 (TD 9482) 22,698; (REG–114494–10) 22,723
FBAR administrative relief forsignature authority and certain
commingled funds (Notice 23) 11,441
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann5)6,402
Parity in mental health and substance use disorder benefits under
group health plans (TD 9479) 18,618
Proposed regulations:
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
26 CFR 54.9815–2714, added; dependent coverage of chil-
dren under group health plans to age 26 (REG–114494–10)
22,723
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Regulations:
26 CFR 54.9812–1T, revised; 602.101, amended; interim
final rules under the Paul Wellstone and Pete Domenici
Mental Health Parity and Addiction Equity Act of 2008
(MHPAEA) (TD 9479) 18,618
26 CFR 54.9815–2714T, added; 602.101, amended; depen-
dent coverage of children under group health plans to age
26 (TD 9482) 22,698
EXEMPT ORGANIZATIONS
Additional requirements for tax-exempt hospitals, request for
comments (Notice 39) 24,756
Definition of last known address (RP 16) 19,664
FBAR administrative relief forsignature authority and certain
commingled funds (Notice 23) 11,441
FBAR filing requirements (Ann 16) 11,450
Frivolous tax return positions (Notice 33) 17,609
Letters rulings:
And determination letters:
Areas which will not be issued from Associates Chief
Counsel and Division Counsel (TE/GE) (RP 3) 1,110
Exemption application determination letter rulings under sec-
tions 501 and 521 (RP 9) 2,258
And general information letters, procedures (RP 4) 1,122
User fees, request for letter rulings (RP 8) 1,234
List of organizations classifiedas private foundations (Ann 23)
16,602; (Ann 29) 17,616; (Ann 31) 19,681;(Ann36)21,696
Procedures for charitable trusts to obtain Type III supporting or-
ganization classification rulings and refunds of section 4940
taxes for 2008 (Ann 19) 14,529
Revocations (Ann 1) 4,333;(Ann4)5,384;correction(Ann10)
7,410;(Ann13)8,426; (Ann 15) 10,438; (Ann 24) 15,587;
(Ann 28) 17,616; (Ann 35) 20,685; (Ann 40) 22,725;(Ann
42) 25,768
Technical advice to IRS employees (RP 5) 1,165
GIFT TAX
Definition of last known address (RP 16) 19,664
FBAR administrative relief for signature authority and certain
commingled funds (Notice 23) 11,441
FBAR filing requirements (Ann 16) 11,450
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann5)6,402
Proposed regulations:
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Treatment of transfers made in trust during 2010 (Notice 19) 7,
404
INCOME TAX
American Jobs Creation Act (AJCA) modification to the Section
6011 regulations, correction (Ann 38) 21,696; additional cor-
rection (Ann 39) 22,724
Accounting methods, December 2009 revision of Form 3115
(Ann 32) 19,681
Advance Pricing Agreement (APA) program, 2009 (Ann 21) 15,
551
Apportionment of tax items among the members of a controlled
group of corporations (TD 9476) 5,336
Arbitrage treatment of certain perpetual funds (Notice 5) 2,256
Backup withholding procedures for social security number vali-
dation following receipt of second B notice (Ann 41) 25,767
Basis reporting by securities brokers and basis determination for
stock (REG–101896–09) 5,347
Bonds:
Allocation of qualified school construction bonds (QSCBs),
national limitation for 2010 (Notice 17) 14,519
Midwestern Disaster Area Bonds, Hurricane Ike Bonds, Gulf
Opportunity Zone Bonds (Notice 10) 3,299
National and area median gross income figures, guidance for
2010 (RP 23) 24,762
Qualified zone academy bond limitation for year 2010 (Notice
22) 10,435
Reissuance of tax-exempt bonds (Notice 7) 3,296
Consumer Price Index (CPI) adjustments, certain loans under
section 1274A for 2010 (RR 2) 3,272
Corporations:
Nonshareholder contribution to capital, Smart Grid Invest-
ment Grant (RP 20) 14,528
Reorganizations, distributionunder sections 368(a)(1)(D) and
354(b)(1)(B) (TD 9475) 4,304
Cost-of-living adjustments for inflation for 2010, modification
to Rev. Proc. 2009-50 (RP 24) 25,764
Credits:
Alternative motor vehicle credit, Volkswagen phase-out (No-
tice 42) 23,733
June 28, 2010vii2010–26 I.R.B.

INCOME TAX—Cont.
Average premium for the small group market (RR 13) 21,691
Low-income housing tax credit:
2010 population figures used for calculation (Notice 21)
12,451
American Recovery and Reinvestment Tax Act of 2009
clarifications (Notice 18) 14,525
New markets tax credit, application of section 469 (RR 16)
26,769
New markets tax credit, recourse debt, amplifying
RR 2003-20 (RR 17) 26,769
Nonconventional source fuel credit, inflation adjustment fac-
tor and phase-out amount for CY 2009 (Notice 31) 16,594
Qualifying therapeutic discovery project credit (Notice 45)
23,734
Renewable electricity, refined coal, and Indian coal produc-
tion credit, 2010 inflation adjustment (Notice 37) 18,654
Specified tax credit bonds (Notice 35) 19,660
Stripping transactions for qualified tax credit bonds (Notice
28) 15,541
Tax credit for employee health insurance expenses of small
employers (Notice 44) 22,717
Damages received on account of personal physical injuries or
physical sickness, hearing on REG–127270–06 (Ann 6) 6,402
Deemed dispositions by individuals emigrating from Canada (RP
19) 13,469
Definition of foreign partnership, sections 7701(a)(4),
7701(a)(5), and 7805 (Notice 41) 22,715
Definition of last known address (RP 16) 19,664
Depreciation, 2010 limitations on depreciation deductions for
passenger automobiles (RP 18) 9,427
Deterioration in financial condition of the issuer of a debt instru-
ment (REG–106750–10) 25,765
Disciplinary actions involving attorneys, certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 12) 7,410;
(Ann 25) 15,588; (Ann 37) 20,685
Disclosure of activity grouping under Code section 469 (RP 13)
4,329
Disclosure or use of information by return preparers:
Amendments to section 7216 regulations (TD 9478) 4,315;
(REG–131028–09) 4,332
In communicating with taxpayers (RR 4) 4,309
In connection with professional liability insurance (RR 5) 4,
312
Draft schedule and instructionsfor uncertain tax positions pro-
posal (Ann 30) 19,668
Electronic filing, waiver request procedures (Notice 13) 4,327
Employer-provided vehicles,cents-per-mile rule, maximum
2010 values for vehicle (RP 10) 3,300
Expenses, housing cost amounts eligible for exclusion or deduc-
tion, 2010 (Notice 27) 15,531
Extension of interim guidance on section 67 limitation on estates
or trusts (Notice 32) 16,594
Extension of timeframe for disclosures to persons designated in a
written request or consent pursuant to section 6103(c) (Notice
8) 3,297
INCOME TAX—Cont.
Extension of time to submit comments on Announcement 2010-9
regarding reporting uncertain tax positions, draft schedule, and
implementation date (Ann 17) 13,515
FATCA, implementation and request for comments (Ann 22) 16,
602;correction(Ann34)20,685
FBAR administrative relief for signature authority and certain
commingled funds (Notice 23) 11,441
FBAR filing requirements (Ann 16) 11,450
Foreign earned income exclusion (RP 17) 8,425
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Guidance priority list, recommendations for 2010–2011 (Notice
43) 22,716
Health care benefits with respect to children under age 27, tax
treatment (Notice 38) 20,682
Health savings accounts (HSAs), cost-of-living adjustments for
inflation for 2011 (RP 22) 23,747
Information reporting, deadline to furnish payee statements (No-
tice 9) 3,298
Insurance companies:
Interest rate tables (RR 7) 8,417
Life insurance reserves, actuarial guideline XLIII, AG 43,
CARVM (Notice 29) 15,547
Loss payment patterns and discount factors for the 2009 acci-
dent year, correction to RP 2009–55 (Ann 11) 10,438
Interest:
Certain applicable high yield discount obligations issued in
2010 (Notice 11) 4,326
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2010 (RR 1) 2,248
February 2010 (RR 6) 6,387
March 2010 (RR 8) 10,432
April 2010 (RR 11) 14,516
May 2010 (RR 12) 18,617
June 2010 (RR 15) 23,730
Rates:
Underpayments and overpayments, quarter beginning:
April 1, 2010 (RR 9) 13,461
July 1, 2010 (RR 14) 26,773
Investment in U.S. property, extension of regulations (Notice 12)
4,326
Letter rulings:
And determination letters, areas which will not be issued
from:
Associate Chief Counsel and Division Counsel (TE/GE)
(RP 3) 1,110
Associates Chief Counsel(International) (RP 7) 1,231
And information letters issued byAssociate Offices, determi-
nation letters issued by Operating Divisions (RP 1) 1,1;
correction (Ann 5) 6,402
Like-kind exchanges (RP 14) 12,456
Military Spouses Residency Relief Act (MSRRA), transitional
guidance for taxpayers claiming relief (Notice 30) 18,650
2010–26 I.R.B.viiiJune 28, 2010

INCOME TAX—Cont.
Modification to consolidated return regulation (TD 9458) per-
mitting an election to treat a liquidation of a target, followed
by a recontribution to a new target, as a cross-chain reorgani-
zation(Ann7)6,403
Penalties, substantial understatement, preparer penalty (RP 15)
7,404
Personal exemption, additional for Hurricane Katrina displaced
individual (TD 9474) 4,322
PFIC shareholder reporting under new section 1298(f) for tax
years beginning before March 18, 2010 (Notice 34) 17,612
Postponement of certain tax-related deadlines by reason of a fed-
erally declared disaster or terroristic or military action, correc-
tion to TD 9443 (Ann 8) 7,408
Private foundations, organizations now classified as (Ann 23) 16,
602; (Ann 29) 17,616; (Ann 31) 19,681; (Ann 36) 21,696
Proposed Regulations:
26 CFR 1.304–4 revised; use of controlled corporations to
avoid the application of section 304 (REG–132232–08) 6,
401
26 CFR 1.408–7, amended; 1.1012–1, amended; 1.6039–2,
amended; 1.6042–4, amended; 1.6044–5, amended;
1.6045–1 thru –5, amended; 1.6045A–1, added;
1.6045B–1, added; 1.6049–6, amended; 31.3406(b)(3)–2,
amended; 31.6051–4, amended; 301.6721–1, amended;
301.6722–1, amended; basis reporting by securities bro-
kers and basis determination for stock (REG–101896–09)
5,347
26 CFR 1.1001–3, amended; deterioration in financial condi-
tion of the issuer of a debt instrument (REG–106750–10)
25,765
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
26 CFR 1.6654–2, amended; reduced 2009 estimated income
tax payments for individuals with small business income
(REG–117501–09) 11,442
26 CFR 301.7216–2, amended; amendments to section 7216
regulations-disclosure or use of information by preparers of
returns (REG–131028–09) 4,332
Publications:
1167, General Rules and Specifications for Substitute Forms
and Schedules (RP 21) 13,473
Qualified disasters:
Chile earthquake occurring in February 2010 (Notice 26) 14,
527
Haiti earthquake occurring in January 2010 (Notice 16) 6,396
Qualified nonpersonal use vehicle, public safety officer vehicles
(TD 9483) 23,726
Recourse debt, new markets tax credit, amplifying RR 2003–20
(RR 17) 26,769
Reduced 2009 estimated income tax payments for indi-
viduals with small business income (TD 9480) 11,439;
(REG–117501–09) 11,442
Regulations:
26 CFR 1.132–5, revised; 1.274–5, –5T, revised; 1.280F–6,
amended; qualified nonpersonal use vehicle (TD 9483) 23,
726
INCOME TAX—Cont.
26 CFR 1.162–24, added; 301.9100–4T; amended; 602.101,
amended; travel expenses of state legislators (TD 9481) 17,
605
26 CFR 1.304–4, added; 1.304–4T, revised; use of controlled
corporations to avoid the application of section 304 (TD
9477) 6,385
26 CFR 1.358–2, amended; 1.368–2, amended; 1.368–2T,
removed; 1.1502–13, amended; corporate reorganizations,
distribution under sections 368(a)(1)(D) and 354(b)(1)(B)
(TD 9475) 4,304
26 CFR 1.704–3, amended; contributed property (TD 9485)
26,771
26 CFR 1.924(a), amended; 1.1502–43, amended;
1.1502–43T, removed; 1.1502–47, amended; 1.1502–47T,
removed; 1.561–0 thru –3, added; 1.1561–0T thru –3T,
removed; apportionment of tax items among the members
of a controlled groups of corporation (TD 9476) 5,336
26 CFR 1.1502–13T, amended; modification to consolidated
return regulation permitting an election to treat a liquidation
of a target, followed by a recontribution to a new target, as
a cross-chain reorganization; correction to TD 9458 (Ann
7) 6,403
26 CFR 1.6011–4, revised; correction to TD 9350 (Ann 39)
22,724
26 CFR 1.6654–2, amended; 1.6654–2T, added; reduced 2009
estimated income tax payments for individuals with small
business income (TD 9480) 11,439
26 CFR 1.9300–1, added; 1.9300–1T, removed; reduction in
taxable income for housing Hurricane Katrina displaced in-
dividuals (TD 9474) 4,322
26 CFR 301.7216–0, –2, amended; 301.7216–0T, –2T, added;
amendments to section 7216 regulations-disclosure or use
of information by preparers of returns (TD 9478) 4,315
Requirements, trustee of a blind trust (RP 11) 2,269
Revocations, exempt organizations (Ann 1) 4,333;(Ann4)5,
384; correction (Ann 10) 7,410; (Ann 13) 8,426; (Ann 15)
10,438;(Ann24)15,587; (Ann 28) 17,616;(Ann35)20,
685; (Ann 40) 22,725;(Ann42)25,768
Section 305 distributions of stock (RP 12) 3,302
Section 338 election, qualified foreign contract (Notice 1) 2,251
Section 368 reorganizations, continuity of interest (Notice 25)
14,527
Section 382 limitation, ownership changes, pre-change losses
(Notice 2) 2,251
Section 385, auction rate preferred stock (Notice 3) 2,253
Section 469, application to the section 45D new markets tax
credit (RR 16) 26,769
Section 704(c) allocations (TD 9485) 26,771
Section 1256(g)(7)(C) qualified board or exchange (RR 3) 3,272
Securities lending transactions, substitute dividend payments,
withholding (Notice 46) 24,757
Standard Industry Fare Level (SIFL) formula (RR 10) 13,461
State legislators, section 162(h) election to deduct deemed living
expenses (TD 9481) 17,605
Substitute forms and schedules, general rules and specifications
(RP 21) 13,473
June 28, 2010ix2010–26 I.R.B.

INCOME TAX—Cont.
Tax treatment of health care benefits provided with respect to
children under age 27 (Notice 38) 20,682
Technical Advice Memoranda (TAMs) (RP 2) 1,90
Tax conventions:
U.S.-Belgium Tax Convention,agreement on pension plans
under Article 17 (Ann 27) 18,657
U.S.-Canada Tax Convention,Article XIII(7) election (RP
19) 13,469
U.S.-Germany agreement with respect to consular employees
(Ann 2) 2,271
U.S.-Netherlands agreement with respect to the elimination of
the Dutch “qualification”certification (Ann 26) 16,604
Transfers of stock or securities to foreign corporations under sec-
tion 304 (TD 9477) 6,385; (REG–132232–08) 6,401
Uncertain tax positions, policy of restraint (Ann 9) 7,408
Unified rule for loss on subsidiary stock (Ann 18) 12,460
Widely held fixed investment trusts (WHIFT) transition guid-
ance (Notice 4) 2,253
SELF-EMPLOYMENT TAX
Frivolous tax return positions (Notice 33) 17,609
Furnishing identifying number of tax return preparer
(REG–134235–08) 16,596
Letter rulings and information letters issued by Associate Of-
fices, determination letters issued by Operating Divisions (RP
1) 1,1;correction(Ann5)6,402
Proposed regulations:
26 CFR 1.6109–2, amended; furnishing identifying number
of tax return preparer (REG–134235–08) 16,596
Technical Advice Memoranda (TAMs) (RP 2) 1,90
2010–26 I.R.B.xJune 28, 2010

June 28, 20102010–26 I.R.B.

2010–26 I.R.B.June 28, 2010

June 28, 20102010–26 I.R.B.

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