us-irs-revenue-rulings-irb-2011-10-pdf•Internal Revenue Bulletin 2011-10 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2011-10 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2011-10-pdfInternal Revenue Bulletin 2011-10 (PDF rendition): IRS Revenue RulingsGuidance
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Bulletin No. 201 1-10 March 7, 2011 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX Rev. Rul. 2011–6, page 537. Federal rates; adjusted federal rates; adjusted federal long-termrateandthelong-termexemptrate.For pur- poses of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2011. Notice 2011–15, page 539. Low-income housing tax credit; private activity bonds. Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas for purposes of determining the 2011 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k) are reproduced. Notice 2011–17, page 540. This notice informs the public of the effect of Emancipation Day, a legal holiday in the District of Columbia, on the filing deadline for all tax forms required to be filed on April 15, including the Form 1040 series tax returns. EMPLOYEE PLANS Rev. Rul. 2011–7, page 534. Section 403(b) plan termination.Final regulations under section 403(b) of the Code were published in 2007. Under the regulations a section 403(b) plan is permitted to contain provisions that provide for plan termination and that allow ac- cumulated benefits to be distributed on termination. This ruling provides guidance clarifying how the section 403(b) plan termi- nation provisions apply. EXEMPT ORGANIZATIONS Announcement 2011–20, page 542. This announcement advises hospital organizations described in section 501(c)(3) of the Code to delay filing their 2010 Form 990 until July 1, 2011. Hospital organizations with return due dates prior to August 15, 2011, have been granted automatic three-monthextensionsoftimetofileandtheseaffectedhos- pital organizations may rely that no late filing penalties under section 6652(c)(1)(A)(i) will apply if they file by their extended due dates. Finding Lists begin on page ii. The IRS Mission Provide Americ a’s taxpayers top-quality service by helping them understa nd and meet their tax responsibilities and en- force the law wi th integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conven- tions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, mod- ify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indi- cated. Procedures relating solely to matters of internal man- agement are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—19 86 Code. This part i ncludes rulings and decisions based on provisions of the Intern al Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Leg- islation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rul- ings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secre- tary (Enforcement). Part IV .—Items of General Interest. This par t includes notices of proposed rulemakings, disbar- ment an d suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The c ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402. March 7, 20112011–10 I.R.B. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 42.—L ow-Income Housing Credi t The adjusted a pplicable federal short-term, mid- term, and long -term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 280G.—Golden Parachute Payments Federal short-term, mid-term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 382.—Limitation on Net Operating Loss Carryforwa rds and Certain Built-In Losses Following Ownership Change The adjusted applicable federal long-term rate is set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 403.—Taxability of Certain Annuity Contracts 26 CFR 1.403(b)–10: Tax sheltered annuity con- tracts. Section 403(b) plan termination.Fi- nal regulations under section 403(b) of the Code were published in 2007. Under the regulations a section 403(b) plan is permit- ted to contain provisions that provide for plan termination and that allow accumu- lated benefits to be distributed on termina- tion. This ruling provides guidance clari- fying how the section 403(b) plan termina- tion provisions apply. Rev. Rul. 2011–7 ISSUE Whether a retirement plan that takes the actions described below has been ter- minated in accordance with the rules of § 1.403(b)–10(a) of the Income Tax Reg- ulations and whether distributions made to participants or beneficiaries in connection with termination of the plan are included in gross income. FACTS Situation 1 Plan A is a defin ed contribution plan that includes both nonelective employer contribution s and elective deferrals. Prior to the action t aken to terminate the plan as described bel ow, Plan A satisfies the re- quirements of §403(b)and§§1.403(b)–2 through§1.4 03(b)–9. Plan A only permits benefit paym ents to be made after termi- nation from e mploymentoruponplanter- mination. Pl an A is funded solely through the use of fu lly paid individual annuity contracts i ssued by an insurance company. Plan A is not subject to ERISA (because it is a governm ental plan, within the meaning of section 3(32) of ERISA). All amounts held under Plan A are a result of employer contribut ions, including elective deferrals as defined in § 1.403(b)–2(b)(7), and no amounts ar e held there as a result of desig- nated Roth contributions or after-tax con- tributio ns. Neither the sponsoring em- ployer no r any other entity that is treated as the sam e employer under § 414(b), (c), (m), or (o ) on the date of the termination makes co ntributions to any § 403(b) con- tract th at is not part of Plan A, including during t he period beginning on January 1, 2012 and ending on the date that is 12 months a fter distribution of all assets from Plan A. On or bef ore January 1, 2012, the em- ployer sponsoring Plan A takes action to termin ate Plan A. That action includes a bindin g resolution of the employer to cease future purchases of annuity contracts un- der Pla n A and to terminate Plan A, effec- tive J anuary 1, 2012. The resolution also provi des that all benefits held under Plan Aaref ully vested and nonforfeitable as of Janua ry 1, 2012, and directs that all ben- efits be distributed as soon as practicable ther eafter. Participants and beneficiaries in Pl an A are notified of the plan termina- tion . Dist ributions pursuant to the terms of Plan A and the termination resolution are made as soon as administratively practica- ble a fter the termination date and are effec- tuat ed by distribution of fully paid individ- ual insurance annuities to all participants, beneficiarie s who are alternate payees, and beneficiarie s of deceased participants. Some of the con tracts permit single- sum payments a s a form of liquidating dis- tribution in c onnection with plan termi- nation and su ch single-sum payments are made as soon a s administratively practi- cable after J anuary 1, 2012. Each insur- ance carrier permits any such payment that is an eligib le rollover distribution (as de- scribedin§ 402(c)(4))tobepaidbya direct tran sfer to an individual retirement account or a nnuity under § 408 (IRA) or other elig ible retirement plan (as defined in§401(a) (31)(E)) in a manner that sat- isfies § 40 1(a)(31). The plan administra- tor provid es a notice to employees describ- ing their r ollover rights, as required by § 402(f). Situatio n2 The facts are the same as inSituation 1, except that Plan A is funded not only by indivi dual annuity contracts, but also by a group an nuity contract. Distribution of amounts from the group annuity contract is effec tuated by issuing individual certifi- cates to each participant, beneficiary who is an alt ernate payee, and beneficiary of a deceas ed participant in the group annu- ity con tract evidencing a fully paid inter- est in h is or her benefits under the con- tract a s soon as administratively practi- cable a fter January 1, 2012. Some par- ticipa nts and beneficiaries receive a sin- gle-su m payment as a liquidating distribu- tion f rom the contract in accordance with the te rms of the contract. Situa tion 3 The fa cts are the same as inSituation 2, excep t that Plan A is funded not only by indiv idual annuity contracts and a group annui ty contract, but also by amounts held by on e or more regulated investment com- pani es (as defined in § 851(a) relating to mutu al funds) in custodial accounts that are t reated as annuity contracts for pur- pose s of § 403(b). Custodial accounts are maintained either under individual or gro up agreements. The distribution of amounts held in the custodial accounts is made as soon as 2011–10 I.R.B.534March 7, 2011 administratively practical after January 1, 2012. Depending on the elections made by the participant or beneficiary, distributions equal to recipient’s account balance under the custodial account are made (in cash or in kind) either to the participant or ben- eficiary or to an IRA established for the participant or beneficiary or another eligi- ble retirement plan, in accordance with the rules of § 1.403(b)–7(b)(1) under which an eligible rollover distribution may be made to an IRA established for the partic- ipant or beneficiary or to another eligible retirement plan. Each custodial account provider permits an eligible rollover dis- tribution (as described in § 402(c)(4)) to be paid by a direct transfer to an individual retirement account orannuity under § 408 (IRA) or other eligible retirement plan (as defined in § 401(a)(31)(E)) in a manner that satisfies § 401(a)(31), including an IRA established by the same provider that permits investment in the same mutual fund in which the participant’s or benefi- ciary’s custodial account is invested. Situation 4 The facts are the same as inSituation 3, except that the plan is a money pur- chase pension plan (i.e.a defined contri- bution plan that is neither a profit shar- ing nor a stock bonus plan) that is subject to the requirements of part 2 of subtitle B of Title I of the Employee Retirement In- come Security Act of 1974 (ERISA) and section 302 of ERISA. Therefore, distribu- tions are made in accordance with section 205 of ERISA (relating to qualified joint and survivor annuities and qualified pre- retirement survivor annuities). If amounts held in the custodial accounts for a partic- ipant are to be paid in the form of an an- nuity under section 205 of ERISA, the dis- tribution is made by purchase and distri- bution of a fully paid individual insurance annuity. Prior to termination, the plan oth- erwise complies with all the requirements of part 2 of subtitle B of Title I of ERISA. For the plan year that includes the final dis- tribution, the plan files a final return/report (Form 5500). LAW Section 403(b) applies to contributions made for employees who are performing services for a public school of a State or a local government or for employees of employers that are tax-exempt organiza- tions under § 501(c)(3). Section 403(b) also applies to contributions made for cer- tain ministers. Under § 403(b), contribu- tions are excluded from gross income only if made to certain funding arrangements: (1) contracts issued by an insurance com- pany qualified to issue annuities in a State that includes payment in the form of an an- nuity; (2) custodial accounts that are exclu- sively invested in stock of a regulated in- vestment company (as defined in § 851(a) relating to mutual funds); or (3) a retire- ment income account for employees of a church-related organization (as defined in § 1.403(b)–2). Final regulations under § 403(b) (T.D. 9340, 2007–2 C.B. 487) were published in the Federal Register (72 FR 41128) on July 26, 2007 (2007 Regulations). Subject to a number of special effective date rules, the 2007 Regulations are generally effective for taxable years beginning after December 31, 2008. Section 1.403(b)–10(a) of the 2007 Regulations provides that an employer is permitted to amend its § 403(b) plan to eliminate future contributions for existing participants or to limit participation to ex- isting participantsand employees (to the extent consistent with § 1.403(b)–5). A § 403(b) plan is permitted to contain pro- visions that provide for plan termination and that allow accumulated benefits to be distributed on termination. However, in the case of a § 403(b) con- tract that is subject to the distribution re- strictions in § 1.403(b)–6(c) or (d) (relating to custodial accounts and § 403(b) elec- tive deferrals), under § 1.403(b)–10(a), ter- mination of the plan and the distribution of accumulated benefits is permitted only if the employer (taking into account all entities that are treated as the same em- ployer under § 414(b), (c), (m), or (o) on the date of the termination) does not make contributions to any § 403(b) contract that is not part of the plan (any such contract is referred to below as “another § 403(b) plan”). For rules relating to entities that are treated as the same employer under § 414(c), see § 1.414(c)–5 and, for con- trolled group rules relating to governmen- tal entities, see Notice 89–23, 1989–1 C.B. 654, as modified by Rev. Rul. 2009–18, 2009–2 C.B. 1. For purposes of the requirement that, after plan termination, the employer make no contributions to any other § 403(b) plan, contributionsare made to “another § 403(b) plan” if and only if contributions are made to a § 403(b) contract during the period beginning on the date of plan termination and ending 12 months after distribution of all assets from the termi- nated plan. However, if at all times during the period beginning 12 months before the termination and ending 12 months after distribution of all assets from the termi- nated plan, fewer than 2 percent of the employees who were eligible under the terminating § 403(b) plan as of the date of plan termination are eligible under an- other § 403(b) plan, that § 403(b) plan is disregarded. To the extent a contract fails to satisfy the nonforfeitability requirement of § 1.403(b)–3(a)(2) of the 2007 Regu- lations at the date of plan termination, the contract is not, and cannot later become, a § 403(b) contract. In order for a § 403(b) plan to be consid- ered terminated under § 1.403(b)–10(a), all accumulated benefits under the plan must be distributed to all participants and beneficiaries as soon as administratively practicable after termination of the plan. (For rules relating to when distributions to all participants and beneficiaries are made as soon as administratively practicable after plan termination in the case of a plan qualified under § 401(a), see Rev. Rul. 89–87, 1989–2 C.B. 81, and Internal Rev- enue Manual 7.12.1.2.3, paragraph 5.) For this purpose, delivery of a fully paid indi- vidual insurance annuity contract is treated as a distribution. The mere provision for, and making of, benefit distributions to participants or beneficiaries upon plan termination does not cause a contract to cease to be a § 403(b) contract. Section 1.403(b)–7 provides rules regarding the tax treatment of benefit distributions, in- cluding § 1.403(b)–7(b)(1) under which an eligible rollover distribution is not in- cluded in gross income if paid in a direct rollover to an eligible retirement plan or if transferred to an eligible retirement plan within 60 days. ANALYSIS The employer inSituation 1adopted a resolution to cease contributions and terminate the plan at a specified date, in- cluding full vesting for all benefits at that date. Since the employer took action to March 7, 20115352011–10 I.R.B. fully vest any participants with respect to amounts not otherwise fully vested at the date of plan termination, all contracts un- der the plan will be § 403(b) contracts upon plan termination. See §§ 1.403(b)–3(d)(2) and 1.403(b)–10(a)(1). Such contracts may permit benefits to begin immediately upon plan termination, or may permit the participant to begin benefits at a later date to the extent provided in the plan document and the termination resolution, subject to applicable Code (and ERISA rules where applicable.) Distribution inSituation 1was made by delivery of a fully paid individual annuity contract or a single-sum payment to each participant or beneficiary as soon as ad- ministratively practicable after the termi- nation date. Because the plan is funded solely through fully paid individual insur- ance annuity contracts, no further action is required to be taken in order to distrib- ute the contracts. In addition, neither the sponsoring employer nor any other entity that is treated as the same employer un- der § 414(b), (c), (m), or (o) on the date of the termination makes contributions to any § 403(b) contract that is not part of Plan A, including during the period beginning on the date of plan termination and ending 12 months after distribution of all assets from the terminated plan. Accordingly, the ac- tions taken by the employer to terminate the plan and distribute accumulated ben- efits satisfy the requirements of § 403(b) and § 1.403(b)–10(a) of the 2007 Regula- tions for plan termination. Following ter- mination of the plan, participants and ben- eficiaries who hold fully paid insurance annuity contracts areentitled to payments in accordance with the terms of the con- tracts (which may permit single-sum pay- mentsinconnectionwithplantermina- tion). InSituation 2, the same actions were taken, except that the employer provided an individual certificate evidencing fully paid benefits under the contract to each participant or beneficiary whose accu- mulatedbenefitsarefundedbyagroup annuity contract. The issuance of this certificate to each participant or bene- ficiary constitutes a distribution of the participant’s or beneficiary’s accumulated benefit in the group annuity contract for purposes of § 1.403(b)–10(a) of the 2007 Regulations (but no amount is included in gross income until amounts are paid out of the policy). InSituations 3 and 4, the employer also distributed all amounts in the individual and group custodial accounts by payment either to the participant or beneficiary or to an IRA established by the participant or beneficiary or another eligible retirement plan, in accordance with § 1.403(b)–7(b) of the 2007 Regulations, or by delivery of a fully paid individual annuity con- tract. The actions taken by the employer satisfy the requirements of § 403(b) and § 1.403(b)–10(a) of the 2007 Regulations for plan termination. The amounts paid to a participant or beneficiary from custodial accounts in connection with the termina- tion are not included in gross income to the extent those amounts are rolled over to an IRA or other eligible retirement plan. With respect toSituations 1 through 4, the delivery of a fully paid individual an- nuity contract to participants or beneficia- ries, or of an individual certificate evidenc- ing fully paid benefits under a group an- nuity contract, is not included in gross in- come until amounts are actually paid to the participant or beneficiary out of the con- tract, so long as the contract maintains its status as a § 403(b) contract. The § 403(b) status of any such contract is generally maintained if the contract thereafter ad- heres to the requirements of § 403(b) that are in effect at the time of the delivery of such contract. Any other amount paid to a participant or beneficiary, such as a sin- gle-sum payment, is included in the gross income of the participant or beneficiary, except to the extent the amount is rolled over to an IRA or other eligible retirement plan by a direct rollover or by a transfer made within 60 days after the distribution. HOLDING In each ofSituations 1 through 4,Plan A has been terminated in accordance with the rules of § 1.403(b)–10(a). Delivery of a fully paid individual annuity contract to participants or beneficiaries, or of an individual certificate evidencing fully paid benefits under a group annuity contract, is not included in gross income until amounts are actually paid to the participant or ben- eficiary out of the contract, so long as the contract maintains its status as a § 403(b) contract. Any other distributions to a par- ticipant or beneficiary to effectuate plan termination, whether from an insurance annuity contract, an individual certifi- cate evidencing fully paid benefits under a group annuity contract, or a custodial account, are included in gross income, except to the extent the amount is rolled over to an IRA or other eligible retirement plan by a direct rollover or by a transfer made within 60 days after the distribution. DRAFTING INFORMATION The principal authors of this rev- enue ruling are Kathleen Herrmann and Sherri Edelman of the Employee Plans, Tax Exempt and Government Entities Division. Ms. Herrmann and Edelman may be reached by e-mail at RetirementPlanQuestions@irs.gov. Section 412.—Minimum Funding Standards The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 467.—Certain Payments for the Use of Property or Services The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Sectio n 483.—Interest on Certai n Deferred Payments The adj usted applicable federal short-term, mid- term, a nd long-term rates are set forth for the month of Marc h 2011. See Rev. Rul. 2011-6, page 537. 2011–10 I.R.B.536March 7, 2011 Section 642.—Special Rules for Credits and Deductions Federal short-term, mid-term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 807.— Rules for Certain Rese rves The adjusted applicable federal short-term, mid- term, and lon g-term rates are set forth for the month of March 2011 . See Rev. Rul. 2011-6, page 537. Section 846.—Discounted Unpaid Losses Defined The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 1274.—Determi- nation of Issue Price in the Case of Certain Debt Instru- ments Issued for Property (Also Sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.) Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate.For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for March 2011. Rev. Rul. 2011–6 This revenue ruling provides various prescribed rates for federal income tax pur- poses for March 2011 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted appli- cable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-in- come housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new build- ings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520. REV. RUL. 2011–6 TABLE 1 Applicable Federal Rates (AFR) for March 2011 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term AFR .54%.54%.54%.54% 110% AFR .59%.59%.59%.59% 120% AFR .65%.65%.65%.65% 130% AFR.70%.70%.70%.70% Mid-term AFR2.44%2.43%2.42%2.42% 110% AFR2.69%2.67%2.66%2.66% 120% AFR2.94%2.92%2.91%2.90% 130% AFR3.18%3.16% 3.15% 3.14% 150% AFR 3.68% 3.65% 3.63%3.62% 175% AFR 4.30% 4.25% 4.23%4.21% Long-term AFR4.30% 4.25% 4.23%4.21% 110% AFR4.73%4.68% 4.65% 4.64% 120% AFR 5.17%5.10%5.07%5.05% 130% AFR 5.61%5.53%5.49%5.47% March 7, 20115372011–10 I.R.B. REV. RUL. 2011–6 TABLE 2 Adjusted AFR for March 2011 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term ad justed AFR .77%.77%.77%.77% Mid-term adju sted AFR 2.18%2.17%2.16%2.16% Long-term adj usted AFR 4.55%4.50% 4.47%4.46% REV. RUL. 2011–6 TABLE 3 Rates Under Section 382 for March 2011 Adjusted fede ral long-term rate for the current month 4.55% Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.)4.55% REV. RUL. 2011–6 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for March 2011 Note: Under S ection 42(b)(2), the applicable percentage for non-federally subsidizednew buildings placed in service after July 30, 2008 , and before December 31, 2013, shall not be less than 9%. Appropriate percentage for the 70% present value low-income housing credit7.78% Appropriate percentage for the 30% present value low-income housing credit3.33% REV. RUL. 2011–6 TABLE 5 Rate Under Section 7520 for March 2011 Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest3.0% Section 1288.—Treatment of Original Issue Discount on Tax-Exem pt Obligations The adjuste d applicable federal short-term, mid- term, and l ong-term rates are set forth for the month of March 20 11. See Rev. Rul. 2011-6, page 537. Section 7520.—Valuation Tables The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. Section 7872.—Treatment of Loans With Below-Market Interest Rates The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of March 2011. See Rev. Rul. 2011-6, page 537. 2011–10 I.R.B.538March 7, 2011 Part III. Administrative, Procedural, and Miscellaneous 2011 Calendar Year Resident Population Estimates Notice 2011–15 This notice informs (1) State and lo- cal housing credit agencies that allocate low-income housing tax credits under § 42 of the Internal Revenue Code and (2) States and other issuers of tax-exempt private activity bonds under § 141, of the proper population figures to be used for calculating the 2011 calendar year population-based component of the State housing credit ceiling (Credit Ceiling) under § 42(h)(3)(C)(ii), the 2011 calen- dar year volume cap (Volume Cap) under § 146, and the 2011 volume limit (Volume Limit) under § 142(k)(5). The population figures for both the population-based component of the Credit Ceiling and the Volume Cap are deter- mined by reference to § 146(j). That section provides generally that determina- tions of population for any calendar year are made on the basis of the most recent census estimate of the resident population of a State (or issuing authority) released by the U.S. Census Bureau before the beginning of such calendar year. Section 142(k)(5) provides that the Volume Limit is based on the State population. The population-based component of the Credit Ceiling and the Volume Cap are adjusted for inflation pursuant to §§ 42(h)(3)(H) and 146(d)(2), respec- tively. The adjustments for the 2011 calendar year are published in Rev. Proc. 2010–40, 2010–46 I.R.B. 663. Section 3.04 of Rev. Proc. 2010–40 provides that, for calendar year 2011, the amounts used under § 42(h)(3)(C)(ii) to calculate the Credit Ceiling is the greater of $2.15 multiplied by the State population (see the resident population figures provided below) or $2,465,000. Further, section 3.09 of Rev. Proc. 2010–40 provides that the amounts used under § 146(d)(1) to calculate the Volume Cap for calendar year 2011 is the greater of $95 multiplied by the State population (see the resident population figures provided below) or $277,820,000. The proper population figures for cal- culating the Credit Ceiling, the Volume Cap, and the Volume Limit for the 2011 calendar year are the resident population of the 50 states, the District of Columbia, and Puerto Rico released electronically by the U.S. Census Bureau on December 21, 2010, in Press Release CB10–CN.93. The proper population figures for calculating the Credit Ceiling, the Volume Cap, and the Volume Limit for the 2011 calendar year for Guam and the U.S. Virgin Islands are the figures released electronically by the U.S. Census Bureau on July 17, 2003, and referenced in Census Bureau Tip Sheet TP03–16, dated August 8, 2003. The figures for these two areas are in the U.S. Census Bureau’s International Data Base (IDB) as 2010 midyear population figures. The proper population figure for calculating the Credit Ceiling, the Volume Cap, and the Volume Limit for the 2011 calendar year for American Samoa is the figure released electronically by the U.S. Census Bureau in an IDB release note dated June 18, 2008, which is also in the IDB as a 2010 midyear population figure. The proper population figure for calculating the Credit Ceiling, the Volume Cap, and the Volume Limit for the 2011 calendar year for the Northern Mariana Islands is the figure released electronically by the U.S. Census Bureau in an IDB release note dated June 23, 2009, which is also in the IDB as a 2010 midyear population figure. For convenience, these figures are reprinted below. Resident Population Figures Alabama4,779,736 Alaska710,231 American Samoa66,432 Arizona6,392,017 Arkansas 2,915,918 California 37,253,956 Colorado 5,029,196 Connecticut 3,574,097 Delaware897,934 District of Columbia601,723 Florida18,801,310 Georgia 9,687,653 Guam 180,865 Hawaii1,360,301 Idaho 1,567,582 Illinois12,830,632 Indiana6,483,802 Iowa 3,046,355 March 7, 20115392011–10 I.R.B. Kansas 2,853,118 Kentucky4,339,367 Louisiana 4,533,372 Maine1,328,361 Maryland 5,773,552 Massachusetts 6,547,629 Michigan9,883,640 Minnesota 5,303,925 Mississippi2,967,297 Missouri 5,988,927 Montana 989,415 Nebraska1,826,341 Nevada 2,700,551 New Hampshire1,316,470 New Jersey8,791,894 New Mexico 2,059,179 New York19,378,102 North Carolina 9,535,483 North Dakota 672,591 Northern Mariana Islands48,317 Ohio 11,536,504 Oklahoma 3,751,351 Oregon3,831,074 Pennsylvania12,702,379 Puerto Rico 3,725,789 Rhode Island 1,052,567 South Carolina 4,625,364 South Dakota814,180 Tennessee 6,346,105 Texas 25,145,561 Utah 2,763,885 Vermont 625,741 Virginia8,001,024 Virgin Islands, U.S. 109,750 Washington 6,724,540 West Virginia 1,852,994 Wisconsin 5,686,986 Wyoming 563,626 The principal authors of this notice are Julie Hanlon Bolton, Office of the As- sociate Chief Counsel (Passthroughs and Special Industries) and Timothy L. Jones, Office of the Associate Chief Counsel (Fi- nancial Institutions and Products). For fur- ther information regarding this notice, con- tact Ms. Hanlon Bolton at (202) 622–3040 (not a toll-free call). Effect of Emancipation Day on Filing and Payment Deadlines Notice 2011–17 Purpose This notice advises of the effect of Emancipation Day, a legal holiday in the District of Columbia, on the filing deadline for all tax forms and payments required to be filed or completed on or before April 15, including the Form 1040 series tax returns. Background Section 6072(a) of the Internal Revenue Code imposes a deadline of April 15 for filing income tax returns. When April 15 falls on a Saturday, Sunday, or legal holi- day, a return is considered timely filed if filed on the next succeeding day that is not a Saturday, Sunday, or legal holiday. I.R.C. § 7503. Legal holiday means a le- gal holiday in the District of Columbia.Id. Under District of Columbia law, Eman- cipation Day, April 16, is a legal holiday. D.C. Code § 28–2701 (2010). When April 16 falls on a Saturday, the preceding 2011–10 I.R.B.540March 7, 2011 day is the observed holiday, and when it falls on a Sunday, the succeeding day is the observed holiday.Id.Because Emancipation Day is a legal holiday in the District of Columbia, in certain years it will have implications for taxpayers nationwide with respect to the filing deadlines for all tax forms and payments required to be filed or completed on or before April 15, including the Form 1040 series tax returns. Effect of Emancipation Day on Filing Deadlines For taxpayers nationwide, when Eman- cipation Day, April 16, falls on a: •Saturday: Friday, April 15 is the ob- served date and the filing deadline for all tax forms and payments required to be filed or completed on or before April 15, is Monday, April 18. •Sunday: Monday, April 17 is the ob- served date and the filing deadline for all tax forms and payments required to be filed or completed on or before April 15, is Tuesday, April 18. •Monday: Monday, April 16 is the holi- day and the filing deadline for all forms and payments required to be filed or completed on or before April 15, is Tuesday, April 17. For example, in 2011, Emancipation Day falls on a Saturday, meaning that it will be observed on Friday, April 15, 2011. The filing deadline for all tax forms and payments required to be filed or completed on or before April 15 (as described in Sec- tion 6072(a), including the Form 1040 se- ries of returns) will be Monday, April 18, 2011. The IRS will widely publicize the rule in this notice in affected years to re- mind the public that the filing deadline is extended. Drafting Information The principal author of this notice is Channpreet Singh of the Office of Asso- ciate Chief Counsel (Procedure & Admin- istration). For further information regard- ing this notice, contact Procedure & Ad- ministration, Branches 6 & 7, at (202) 622–4570 (not a toll-free call). March 7, 20115412011–10 I.R.B. Part IV. Items o fGeneralInterest Delayed Filin gSeasonfor Certain Tax-E xempt Hospitals Announcement 2011–20 This announce ment grants tax-exempt organization s that operate one or more hos- pital facili ties (hospital organizations), and that would ot herwise be required to file Form 990,Ret urn of Organization Exempt From Income T ax, including Schedule H, Hospitals,f or the 2010 tax year before Au- gust 15, 201 1, an automatic three-month extension o f time to file the Form 990 for 2010. In add ition, this announcement di- rects these hospital organizations not to file the 2010 Fo rm 990 before July 1, 2011. In order to c omplete implementation of changes to IRS forms and systems that are required t o reflect additional requirements for charit able hospitals enacted by Section 9007 of the Patient Protection and Afford- able Care A ct of 2010 (Pub. L. 111–148), the IRS is delaying the start of the 2010 filing se ason for certain hospital organiza- tions. Pu rsuant to section 6081 of the In- ternal Re venue Code, this announcement grants h ospital organizations with original 2010 tax year filing due dates before Au- gust 15, 2011, an automatic three-month extensi on of time to file the Form 990. This aut omatic extension of the filing due date applies o nly to hospital organizations that are requi redtofileScheduleHwith the 2010 Form 9 90 and that would other- wise be requir ed to file the 2010 Form 990 before August 15, 2011. This automatic extension of the filing due date does not apply to any o ther tax-exempt organization requiredtof ile Form 990. In addition, this announcement directs hospital org anizations not to file 2010 Forms 990 (wi th Schedule H attached) before July 1, 2011, regardless of whether the hospita l organization files an elec- tronic retu rn or a paper return. This delay of the filin g season does not apply to any other tax- exempt organization required to file Form 9 90. Hospital o rganizations affected by this announcem ent are not required to file Form 8868, Application for Extension of Time To F ile an Exempt Organization Returnin order to take advantage of the au- tomatic e xtension. Nevertheless, recently formed ho spital organizations that did not file Form 990 Schedule H for tax year 2009, and who believe they are entitled to the exte nsion of time under this announce- ment, ar e encouraged to file Form 8868 to reduce t he risk that they may incorrectly receive a penalty notice from the IRS. No late f iling penalties under Sec- tion 665 2(c)(1)(A)(i) will apply to a tax year 2010 Form 990 (with Schedule H attached) fil ed by an affected hospital or- ganization on or before the extended due date describe d in this announcement. If an affected hosp ital organization determines that it needs additional time beyond the automatic th ree-month extension period to file its Form 990, the hospital organization may request a n additional three-month extension o ftimetofilebyproperlycom- pleting and filing Form 8868, Part II. An affected ho spital organization may receive no more than a six-month extension of time to fil e for its 2010 tax year. If a hospital o rganization that was granted an automatic extension of time to file pur- suant to th is announcement and filed by its extend ed due date receives a late filing penalty n otice from the IRS, the hospi- tal organ ization should call the telephone number on the penalty notice to request that the I RS abate the late filing penalty. Drafting Information The princ ipal author of this announce- ment is Ch ris Giosa of the Tax Exempt and Governm ent Entities Division. For fur- ther inf ormation regarding this announce- ment, pl ease contact Mr. Giosa at (202) 283–985 1 (not a toll-free number). 2011–10 I.R.B.542March 7, 2011 Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the ef- fect: Amplifieddescribes a situation where no change is being made in a prior pub- lished position, but the prior position is be- ingextendedtoapplytoavariationofthe fact situation set forth therein. Thus, if an earlier ruling held that a principle ap- plied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare withmodi- fied,below). Clarifiedis used in those instances where the language in a prior ruling is be- ing made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously pub- lished ruling and points out an essential difference between them. Modifiedis used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare withamplifiedandclarified, above). Obsoleteddescribes a previously pub- lished ruling that is not considered deter- minative with respect to future transac- tions. This term is most commonly used in a ruling that lists previously published rul- ings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revokeddescribes situations where the position in the previously published ruling is not correct and the correct position is beingstatedinanewruling. Supersededdescribes a situation where the new ruling does nothing more than re- state the substance and situation of a previ- ously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same po- sition published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single rul- ing a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new rul- ing does more than restate the substance of a prior ruling, a combination of terms is used. For example,modifiedandsu- persededdescribes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously pub- lished ruling is first modified and then, as modified, is superseded. Supplementedis used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original rul- ing has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the ad- ditions, and supersedes all prior rulings in the series. Suspendedis used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The fol lowing abbreviations in current use and for merly used will appear in material publis hedintheBulletin. A—Individual. Acq.—A cquiescence. B—Individual. BE—Beneficiary. BK—Bank . B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cu mulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Coo perative. Ct.D.—Court Decision. CY—County. D—Decede nt. DC—Dummy Corporation. DE—Donee. Del. Order —Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Emp loyer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduc iary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Fo reign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Fed eral Unemployment Tax Act. FX—Foreign corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grante e. GP—General Partner. GR—Grantor. IC—Insura nce Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—No nacquiescence. O—Organization. P—Parent Corporation. PHC—Persona l Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Pa rtnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Re al Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsi diary. S.P.R.—Statement of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Trans feree. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpay er. TR—Trust. TT—Trustee. U.S.C.—Uni ted States Code. X—Corporation. Y—Corporation. Z—Corporat ion. March 7, 2011i2011–10 I.R.B. Numerical Finding List 1 Bulletin 2011–1 through 2011–10 Announcements: 2011-1, 2011-2 I.R.B.304 2011-2, 2011-3 I.R.B.324 2011-3, 2011-3 I.R.B.324 2011-4, 2011-4 I.R.B.424 2011-5, 2011-4 I.R.B.430 2011-6, 2011-4 I.R.B.433 2011-7, 2011-5 I.R.B.446 2011-8, 2011-5 I.R.B.446 2011-9, 2011-7 I.R.B.499 2011-10, 2011-7 I.R.B.499 2011-11, 2011-7 I.R.B.500 2011-12, 2011-9 I.R.B.532 2011-13, 2011-8 I.R.B.525 2011-14, 2011-9 I.R.B.532 2011-15, 2011-8 I.R.B.526 2011-16, 2011-7 I.R.B.500 2011-17, 2011-9 I.R.B.532 2011-20, 2011-10 I.R.B.542 Notices: 2011-1, 2011-2 I.R.B.259 2011-2, 2011-2 I.R.B.260 2011-3, 2011-2 I.R.B.263 2011-4, 2011-2 I.R.B.282 2011-5, 2011-3 I.R.B.314 2011-6, 2011-3 I.R.B.315 2011-7, 2011-5 I.R.B.437 2011-8, 2011-8 I.R.B.503 2011-9, 2011-6 I.R.B.459 2011-10, 2011-6 I.R.B.463 2011-11, 2011-7 I.R.B.497 2011-12, 2011-8 I.R.B.514 2011-13, 2011-9 I.R.B.529 2011-15, 2011-10 I.R.B.539 2011-17, 2011-10 I.R.B.540 Proposed Regulations: REG-149335-08, 2011-6 I.R.B.468 REG-146097-09, 2011-8 I.R.B.516 REG-124018-10, 2011-2 I.R.B.301 REG-131151-10, 2011-8 I.R.B.519 REG-131947-10, 2011-8 I.R.B.521 REG-132724-10, 2011-7 I.R.B.498 Revenue Procedures: 2011-1, 2011-1 I.R.B.1 2011-2, 2011-1 I.R.B.90 2011-3, 2011-1 I.R.B.111 2011-4, 2011-1 I.R.B.123 2011-5, 2011-1 I.R.B.167 2011-6, 2011-1 I.R.B.195 Revenue Procedures— Continued: 2011-7, 2011-1 I.R.B.233 2011-8, 2011-1 I.R.B.237 2011-9, 2011-2 I.R.B.283 2011-10, 2011-2 I.R.B.294 2011-11, 2011-4 I.R.B.329 2011-12, 2011-2 I.R.B.297 2011-13, 2011-3 I.R.B.318 2011-14, 2011-4 I.R.B.330 2011-15, 2011-3 I.R.B.322 2011-16, 2011-5 I.R.B.440 2011-17, 2011-5 I.R.B.441 2011-18, 2011-5 I.R.B.443 2011-19, 2011-6 I.R.B.465 Revenue Rulings: 2011-1, 2011-2 I.R.B.251 2011-2, 2011-2 I.R.B.256 2011-3, 2011-4 I.R.B.326 2011-4, 2011-6 I.R.B.448 2011-6, 2011-10 I.R.B.537 2011-7, 2011-10 I.R.B.534 Treasury Decisions: 9507, 2011-3 I.R.B.305 9508, 2011-7 I.R.B.495 9509, 2011-6 I.R.B.450 9510, 2011-6 I.R.B.453 9511, 2011-6 I.R.B.455 9512, 2011-7 I.R.B.473 9513, 2011-8 I.R.B.501 9514, 2011-9 I.R.B.527 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin 2010–52, dated December 27, 2010. 2011–10 I.R.B.iiMarch 7, 2011 Finding List of Current Actions on Previously Published Items 1 Bulletin 2011–1 through 2011–10 Announcements: 85-88 Obsoleted by Rev. Proc. 2011-10, 2011-2 I.R.B.294 2008-11 Modified by Ann. 2011-6, 2011-4 I.R.B.433 2009-62 Obsoleted by Rev. Proc. 2011-10, 2011-2 I.R.B.294 Notices: 2006-87 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2007-25 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2007-77 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2008-107 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2010-27 Superseded by Notice 2011-8, 2011-8 I.R.B.503 2010-59 Modified by Notice 2011-5, 2011-3 I.R.B.314 2010-71 Modified and superseded by Notice 2011-9, 2011-6 I.R.B.459 2010-79 Clarified and modified by Notice 2011-4, 2011-2 I.R.B.282 Proposed Regulations: REG-132554-08 Corrected by Ann. 2011-11, 2011-7 I.R.B.500 Revenue Procedures: 72-50 Modified and superseded by Rev. Proc. 2011-10, 2011-2 I.R.B.294 Revenue Procedures— Continued: 76-34 Modified and supersed by Rev. Proc. 2011-10, 2011-2 I.R.B.294 83-23 Modified and superseded by Rev. Proc. 2011-15, 2011-3 I.R.B.322 94-17 Modified and superseded by Rev. Proc. 2011-15, 2011-3 I.R.B.322 97-27 Clarified and modified by Rev. Proc. 2011-4, 2011-1 I.R.B.330 2001-10 Modified by Rev. Proc. 2011-4, 2011-4 I.R.B.330 2002-28 Modified by Rev. Proc. 2011-4, 2011-4 I.R.B.330 2003-21 Modified and superseded by Rev. Proc. 2011-15, 2011-3 I.R.B.322 2004-34 Modified by Rev. Proc. 2011-14, 2011-4 I.R.B.330 Modified and clarified by Rev. Proc. 2011-18, 2011-5 I.R.B.443 2006-44 Modified by Ann. 2011-6, 2011-4 I.R.B.433 2006-56 Modified by Rev. Proc. 2011-14, 2011-4 I.R.B.330 2008-52 Modified by Notice 2011-4, 2011-2 I.R.B.282 Rev. Proc. 2011-17, 2011-5 I.R.B.441 Superseded in part by Rev. Proc. 2011-14, 2011-4 I.R.B.330 2009-39 Superseded in part by Rev. Proc. 2011-14, 2011-4 I.R.B.330 2009-44 Modified by Ann. 2011-6, 2011-4 I.R.B.433 2010-1 Superseded by Rev. Proc. 2011-1, 2011-1 I.R.B.1 2010-2 Superseded by Rev. Proc. 2011-2, 2011-1 I.R.B.283 Revenue Procedures— Continued: 2010-3 Superseded by Rev. Proc. 2011-3, 2011-1 I.R.B.111 2010-4 Superseded by Rev. Proc. 2011-4, 2011-1 I.R.B.123 2010-5 Superseded by Rev. Proc. 2011-5, 2011-1 I.R.B.167 2010-6 Superseded by Rev. Proc. 2011-6, 2011-1 I.R.B.195 2010-7 Superseded by Rev. Proc. 2011-7, 2011-1 I.R.B.233 2010-8 Superseded by Rev. Proc. 2011-8, 2011-1 I.R.B.237 2010-9 Superseded by Rev. Proc. 2011-9, 2011-2 I.R.B.283 2010-15 Updated by Rev. Proc. 2011-13, 2011-3 I.R.B.318 2011-1 Corrected by Ann. 2011-7, 2011-5 I.R.B.446 2011-8 Corrected by Ann. 2011-8, 2011-5 I.R.B.446 2011-11 Corrected by Ann. 2011-9, 2011-7 I.R.B.499 Revenue Rulings: 81-100 Modified by Rev. Rul. 2011-1, 2011-2 I.R.B.251 2004-67 Modified by Rev. Rul. 2011-1, 2011-2 I.R.B.251 2008-40 Modified by Rev. Rul. 2011-1, 2011-2 I.R.B.251 2011-3 Corrected by Ann. 2011-16, 2011-7 I.R.B.500 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2010–27 through 2010–52 is in Internal Revenue Bulletin 2010–52, dated December 27, 2010. March 7, 2011iii2011–10 I.R.B. Treasury Decisions: 9391 Corrected by Ann. 2011-12, 2011-9 I.R.B.532 9505 Corrected by Ann. 2011-10, 2011-7 I.R.B.499 2011–10 I.R.B.ivMarch 7, 2011 March 7, 20112011–10 I.R.B. 2011–10 I.R.B.March 7, 2011 March 7, 20112011–10 I.R.B. INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin- tendent of Documents when their subscriptions must be renewed. CUMULATIVE BULLETINS The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis andare notincluded as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents. ACCESS THE INTERNAL REVENUE BULLETIN ON THE INTERNET You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select More Topics. Then select Internal Revenue Bulletins. INTERNAL REVENUE BULLETINS ON CD-ROM Internal Revenue Bulletins are available annually as part ofPublication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January. HOW TO ORDER Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the Superintendent of Documents, P.O. Box 371954, Pittsburgh PA, 15250–7954. Please allow two to six weeks, plus mailing time, for delivery. WE WELCOME COMMENTS ABOUT THE INTERNAL REVENUE BULLETIN If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224. 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