This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA Program during calendar year 2010. This document does not provide guidance regarding the application of the arm’s length standard. Instead, it reports on the structure and activities of the APA Program.

This notice provides that, pending the resolution of a number of legal and factual issues, the IRS will not challenge a taxpayer’s position that the Puerto Rican excise tax is a tax in lieu of an income tax under section 903 of the Code.

This procedure provides guidance with respect to the 100-percent additional first year depreciation deduction under sections 168(k)(5) of the Code, and the extension of the 50-percent bonus depreciation deduction for qualified property placed in service in 2010. This procedure defines which property is eligible for the 100-percent bonus depreciation deduction and provides guidance regarding the time and manner for making certain elections under sections 168(k)(2) and (5). The procedure also provides a safe harbor method of accounting for passenger automobiles that qualify for the 100-percent additional first year depreciation deduction and that are subject to first-year limitations under section 280F. Rev. Proc. 2011-21 amplified.

This notice addresses the application of section 501(c)(3) of the Code to tax-exempt organizations participating in the Medicare Shared Savings Program (MSSP) through an accountable care organization (ACO) as described in section 3022 of the Patient Protection and Affordable Care Act. In addition, the notice includes a request for public comments.

This notice provides interim guidance to employers with respect to reporting the cost of coverage under an employer-sponsored group health plan on Form W-2, Wage and Tax Statement, pursuant to § 6051(a)(14) of the Code.