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IRB 2010-50

Table of Contents
(Dated December 13, 2010)
(back to all IRBs)


This is the table of contents of Internal Revenue Bulletin IRB 2010-50. Click on an entry to view the entry. Items shown under "Highlights of This Issue" open summaries of each IRB-referenced document only. Scroll to Parts I, II, etc. to view the full text versions of each IRB-referenced document. Use the "Keyword Search" option of TouchTax to search the full text of all Internal Revenue Bulletins, including this IRB.

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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

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 December 2010.

Section 1274A - inflation adjusted numbers for 2011. This ruling provides the dollar amounts, increased by the 2011 inflation adjustment, for section 1274A of the Code. Rev. Rul. 2010-2 supplemented and superseded.

This notice provides guidance on the determination of when state and local bonds (as defined in section 103(c)) are considered “issued” for purposes of deadlines on issuing bonds. The notice provides guidance on the relevant distinction between the “issue date” of a “bond” versus the “issue date” of an “issue” for purposes of this determination. One instance, among others in which this notice applies, is in determining when Build America Bonds, structured as “draw-down” bonds or loans in which draws are funded at different times are considered issued for purposes of statutory deadlines on issuing these bonds under section 54AA.

Cost limitations for expensing section 179 property. This procedure provides that for taxable years beginning in 2010, the aggregate cost of any section 179 property a taxpayer elects to treat as an expense cannot exceed $500,000. This amount is reduced by the amount by which the cost of the property placed in service during the year exceeds $2,000,000. Rev. Proc. 2009-50 modified and superseded. Rev. Proc. 2010-24 superseded.

Insurance companies; loss reserves; discounting unpaid losses. This procedure sets forth the loss payment patterns and discount factors for accident year 2010. Under section 846 of the Code, discount factors are determined by the Secretary based on the interest rate determined annually under section 846(c) and on loss payment patterns determined every five years under section 846(d). Section 846(d) directs the Secretary to use the most recent aggregate loss payment data of property and casualty insurance companies to determine and publish a loss payment pattern for each line of business every five years.

Insurance companies; discounting estimated salvage recoverable. This procedure sets forth the salvage discount factors for accident year 2010 for purposes of section 832 of the Code. Under section 832, discount factors are determined by the Secretary based on the interest rate determined annually under section 846(c) and on salvage recovery patterns determined every five years by the Secretary.

EMPLOYEE PLANS

This procedure provides guidance to drafters and users of pre-approved IRAs. Section 3 provides guidance to drafters and users of prototype IRAs, including rules for when documents must be submitted to the Internal Revenue Service and for new user fees for individual retirement annuities. Section 4 provides guidance to users of the Service’s model IRAs and describes the availability of new model individual retirement annuities. Rev. Procs. 87-50 and 98-59 modified.

EXEMPT ORGANIZATIONS

The IRS has revokded its determination that Debt Management Corporation of Orange Park, FL, qualifies as an organization described in sections 501(c)(3) and 170(c)(2) of the Code.

EMPLOYMENT TAX

2011 social security contribution and benefit base; domestic employee coverage threshold. The Commissioner of the Social Security Administration has announced (1) the OASDI contribution and benefit base for remuneration paid in 2011 and self-employment income earned in taxable years beginning in 2011, and (2) the domestic employee coverage threshold amount for 2011.

EXCISE TAX

This notice provides guidance on the annual fee imposed on covered entities engaged in the business of manufacturing or importing branded prescription drugs by section 9008 of the Patient Protection and Affordable Care Act (ACA), as amended by section 1404 of the Health Care and Education Reconciliation Act of 2010 (HCERA).

ADMINISTRATIVE

This document contains corrections to final regulations (T.D. 9340, 2007-2 C.B. 487) providing updated guidance on section 403(b) contracts of public schools and tax-exempt organizations described in section 501(c)(3). These regulations will affect sponsors of section 403(b) contracts, administrators, participants, and beneficiaries.



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