Final regulations under section 1563 of the Code, that apply to a controlled group of corporations, clarify that a corporation that satisfies the controlled group rules for stock ownership and qualification is a member of such group, without regard to its status as a component member.

This notice extends to taxable years that begin before the date that final regulations under regulations section 1.67-4 are published in the Federal Register, the interim guidance provided in Notice 2010-32, 2010-16 I.R.B. 594, Notice 2008-166, 2008-52 I.R.B. 1372, and Notice 2008-32, 2008-11 I.R.B 593, on the treatment under section 67 of the Code of investment advisory costs and other costs subject to the 2-percent floor under section 67(a) that are integrated as part of one commission or fee paid to the trustee or executor and are incurred by a trust other than a grantor trust or an estate. Notice 2010-32 modified and superseded.

This announcement contains a rescheduled notice of public hearing on proposed regulations (REG-146097-09, 2011-8 I.R.B. 516) providing guidance on the reporting requirements for interest on deposits maintained at U.S. offices of certain financial institutions and paid to nonresident alien individuals. A public hearing is rescheduled for May 18, 2011.

This revenue procedure establishes a dispute resolution process for the preliminary fee calculation for the 2011 annual fee imposed on covered entities engaged in the business of manufacturing or importing branded prescription drugs. The fee was enacted by section 9008 of the Patient Protection and Affordable Care Act, as amended by section 1404 of the Health Care and Reconciliation Act of 2010. The procedure describes the information necessary to assert a fee error, describes how the information must be formatted and submitted, identifies who may submit the information, and provides the date by which the information must be provided.

Final regulations under Part 300 of the Code amend the regulations relating to the imposition of user fees for enrolled agents and enrolled retirement plan agents.

This notice announces an extension to calendar years 2011 and 2012 and modification of the pilot program announced in Notice 2009-93, 2009-51 I.R.B. 863. Notice 2009-93 authorized filers of certain information returns to truncate an individual payee’s nine-digit identifying number on specified paper payee statements furnished for calendar years 2009-2010, if the filers met certain requirements. Notice 2009-93 modified.

The Department of Treasury and the Service invite public comment on recommendations for items that should be included on the 2011-2012 Guidance Priority List. Taxpayers may submit recommendations for guidance at any time during the year. Please submit recommendations by June 1, 2011, for possible inclusion on the original 2011-2012 Guidance Priority List. Recommendations received after June 1, 2011, will be reviewed for inclusion in the next periodic update.