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renunsia · 10 days ago

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Internal Revenue Bulletin: 2011-49

December 5, 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. 2011-29 Rev. Rul. 2011-29

Accrual of liability to unknown payees. This ruling holds that an employer can establish the “fact of the liability” under section 461 of the Code for bonuses payable to a group of employees even though the employer does not know the identity of any particular bonus recipient and the amount payable to that recipient until after the end of the taxable year. Rev. Rul. 76-345 revoked.

Rev. Rul. 2011-30 Rev. Rul. 2011-30

2011 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2011, is published as required by section 995(f) of the Code.

Rev. Rul. 2011-31 Rev. Rul. 2011-31

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 2011.

ESTATE TAX

Rev. Rul. 2011-28 Rev. Rul. 2011-28

Substitution of insurance policy. This ruling provides guidance regarding whether a grantor’s retention of a power, exercisable in a nonfiduciary capacity, to acquire an insurance policy held by a trust by substituting other assets of equivalent value will cause the value of the insurance policy to be includible in the grantor’s gross estate under section 2042 of the Code. The ruling provides that a grantor’s retention of the power, exercisable in a nonfiduciary capacity, to acquire an insurance policy held in trust by substituting other assets of equivalent value will not, by itself, cause the value of the insurance policy to be includible in the grantor’s gross estate under section 2042, provided the trustee has a fiduciary obligation (under local law or the trust instrument) to ensure the grantor’s compliance with the terms of this power by satisfying itself that the properties acquired and substituted by the grantor are in fact of equivalent value, and further provided that the substitution power cannot be exercised in a manner that can shift benefits among the trust beneficiaries.

ADMINISTRATIVE

Notice 2011-94 Notice 2011-94

Application of general welfare exclusion to Indian tribal government programs. This notice requests comments describing actual or proposed Indian tribal government programs that provide benefits to members and the application of the general welfare exclusion to the programs and benefits.

Rev. Proc. 2011-56 Rev. Proc. 2011-56

Trusts for Indian minors. This procedure provides a revised safe harbor for Indian tribes to establish trusts for tribal members who are minors or legally incompetent for the distribution of gaming revenues under the Indian Gaming Regulatory Act. Rev. Proc. 2003-14 clarified, modified, and superseded.

Rev. Proc. 2011-57 Rev. Proc. 2011-57

This procedure publishes the amounts of unused housing credit carryovers allocated to qualified states under section 42(h)(3)(D) of the Code for calendar year 2011.

Preface

The IRS Mission

Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce the law with 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 Conventions, 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 substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management 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.—1986 Code. This part includes rulings and decisions based on provisions of the Internal 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, Legislation 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 Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).

Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and 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.

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Rev. Rul. 2011-29

ISSUE

Can an employer establish the “fact of the liability” under § 461 of the Internal Revenue Code for bonuses payable to a group of employees if the employer does not know the identity of any particular bonus recipient and the amount payable to that recipient until after the end of the taxable year?

FACTS

X uses an accrual method of accounting for federal income tax purposes. X pays bonuses to a group of employees pursuant to a program that defines the terms and conditions under which the bonuses are paid for a taxable year. X communicates the general terms of the bonus program to employees when they become eligible and whenever the program is changed.

Under the program, bonuses are paid to X’s employees for services performed during the taxable year. The minimum total amount of bonuses payable under the program to X’s employees as a group is determinable either (a) through a formula that is fixed prior to the end of the taxable year, taking into account financial data reflecting results as of the end of that taxable year, or (b) through other corporate action, such as a resolution of X’s board of directors or compensation committee, made before the end of the taxable year, that fixes the bonuses payable to the employees as a group. To be eligible for a bonus, an employee must perform services during the taxable year and be employed on the date that X pays bonuses. Under the program, bonuses are paid after the end of the taxable year in which the employee performed the related services but before the 15th day of the 3rd calendar month after the close of that taxable year.

Under the program, any bonus amount allocable to an employee who is not employed on the date on which X pays bonuses is reallocated among other eligible employees. Thus, the aggregate minimum amount of bonuses X pays to its group of eligible employees is not reduced by the departure of an employee after the end of the taxable year but before bonuses are paid for that year.

LAW

Section 461(a) provides that the amount of any deduction or credit must be taken for the taxable year that is the proper taxable year under the method of accounting the taxpayer uses to compute taxable income.

Section 1.461-1(a)(2)(i) of the Income Tax Regulations provides that, under an accrual method of accounting, a liability is incurred, and is generally taken into account for federal income tax purposes, in the taxable year in which (1) all the events have occurred that establish the fact of the liability, (2) the amount of the liability can be determined with reasonable accuracy, and (3) economic performance has occurred for the liability (collectively, the “all events test”). See also § 1.446-1(c)(1)(ii)(A). This revenue ruling addresses only whether the first prong of the all events test is met.

The first prong of the all events test requires that all the events have occurred that establish the fact of the liability. Generally, all events occur to establish the fact of a liability when (1) the event fixing the liability, whether that be the required performance or other event, occurs, or (2) payment is unconditionally due. Rev. Rul. 2007-3, 2007-1 C.B. 350; Rev. Rul. 80-230, 1980-2 C.B. 169; Rev. Rul. 79-410, 1979-2 C.B. 213, amplified by Rev. Rul. 2003-90, 2003-2 C.B. 353. Although an expense may be deductible before it is due and payable, liability for the expense first must be firmly established. United States v. General Dynamics Corp., 481 U.S. 239, 243-4 (1987).

In Washington Post Co. v. United States, 405 F.2d 1279 (Ct. Cl. 1969), the United States Court of Claims held that a taxpayer incurred a liability to pay bonuses under a plan maintained for the benefit of its circulation dealers as a group. Under the plan, if a dealer did not meet certain specified conditions, a portion of the dealer’s share would be forfeited and reallocated to other dealers. Thus, even though the amount and time of actual payout to individual recipients were, at least in part, not determined, the court held that the total amount of the liability was fixed at the end of the taxable year. In Rev. Rul. 76-345, 1976-2 C.B. 134, the Internal Revenue Service announced that it would not follow Washington Post in similar cases.

In United States v. Hughes Properties, Inc., 476 U.S. 593 (1986), the Supreme Court allowed a casino operator to deduct amounts guaranteed for payment of progressive slot machine jackpots that had not yet been won by casino patrons. The Court reasoned that the taxpayer had a fixed obligation to pay the guaranteed amounts, and that the identification of the eventual recipients of the progressive jackpots was inconsequential. The Court noted that “[t]he obligation is there, and whether it turns out that the winner is one patron or another makes no conceivable difference as to basic liability.” Hughes Properties, 476 U.S. at 602.

ANALYSIS

X’s liability to pay a minimum amount of bonuses to the group of eligible employees is fixed at the end of the year in which the services are rendered. X is obligated under the program to pay to the group the minimum amount of bonuses determined by the end of the taxable year. Any bonus allocable to an employee who is not employed on the date on which bonuses are paid is reallocated to other eligible employees. Thus, the fact of X’s liability for the minimum amount of bonuses is established by the end of the year in which the services are rendered. See Rev. Rul. 55-446, 1955-2 C.B. 531, as modified by Rev. Rul. 61-127, 1961-2 C.B. 36 (holding that bonuses payable to ascertainable employees under an incentive compensation plan that has been communicated to the employees, the exact amounts of which are determinable through a formula in effect prior to the end of the taxable year, are properly accruable for Federal income tax purposes for the year to which they relate). This is true even though the identity of the ultimate recipients and the amount, if any, each employee will receive cannot be determined prior to the end of the taxable year. See Hughes Properties, supra. Accordingly, for purposes of the first prong of the all events test under § 1.461-1(a)(2)(i), all the events have occurred by the end of the taxable year that establish the fact of X’s liability to pay the minimum amount of bonuses.

HOLDING

An employer can establish the “fact of the liability” under § 461 for bonuses payable to a group of employees even though the employer does not know the identity of any particular bonus recipient and the amount payable to that recipient until after the end of the taxable year.

APPLICATION

Any change in a taxpayer’s treatment of bonuses to conform with this revenue ruling is a change in method of accounting that must be made in accordance with §§ 446 and 481, the regulations thereunder, and the applicable administrative procedures. See section 19.01(2) of the APPENDIX of Rev. Proc. 2011-14, 2011-4 I.R.B. 330, 403.

EFFECT ON OTHER DOCUMENTS

Rev. Rul. 76-345 is revoked.

DRAFTING INFORMATION

The principal author of this revenue ruling is Jason D. Kristall of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling, contact Mr. Kristall at (202) 622-5020 (not a toll-free call).

Rev. Rul. 2011-30

2011 base period T-bill rate. The “base period T-bill rate” for the period ending September 30, 2011, is published as required by section 995(f) of the Code.

Section 995(f)(1) of the Internal Revenue Code provides that a shareholder of a DISC shall pay interest each taxable year in an amount equal to the product of the shareholder’s DISC-related deferred tax liability for the year and the “base period T-bill rate.” Under section 995(f)(4), the base period T-bill rate is the annual rate of interest determined by the Secretary to be equivalent to the average of the 1-year constant maturity Treasury yields, as published by the Board of Governors of the Federal Reserve System, for the 1-year period ending on September 30 of the calendar year ending with (or of the most recent calendar year ending before) the close of the taxable year of the shareholder. The base period T-bill rate for the period ending September 30, 2011, is 0.22 percent.

Pursuant to section 6222 of the Code, interest must be compounded daily. The table below provides factors for compounding the base period T-bill rate daily for any number of days in the shareholder’s taxable year (including a 52-53 week accounting period) for the 2011 base period T-bill rate. To compute the amount of the interest charge for the shareholder’s taxable year, multiply the amount of the shareholder’s DISC-related deferred tax liability (as defined in section 995(f)(2)) for that year by the base period T-bill rate factor corresponding to the number of days in the shareholder’s taxable year for which the interest charge is being computed. Generally, one would use the factor for 365 days. One would use a different factor only if the shareholder’s taxable year for which the interest charge being determined is a short taxable year, if the shareholder uses the 52-53 week taxable year, or if the shareholder’s taxable year is a leap year.

For the base period T-bill rates for the periods ending in prior years, see Rev. Rul. 2010-28, 2010-49 I.R.B. 804; Rev. Rul. 2009-36, 2009-47 I.R.B. 650; Rev. Rul. 2008-51, 2008-2 C.B. 1171; Rev. Rul. 2007-64, 2007-2 C.B. 953; and Rev. Rul. 2006-54, 2006-2 C.B. 834.

DRAFTING INFORMATION

The principal author of this revenue ruling is Teresa Burridge Hughes of the Office of Associate Chief Counsel (International). For further information regarding this revenue ruling, contact Teresa B. Hughes at (202) 622-3850 (not a toll-free call).

2011 ANNUAL RATE, COMPOUNDED DAILY

0.22 PERCENT

DAYS FACTOR

1 .000006027

2 .000012055

3 .000018082

4 .000024110

5 .000030137

6 .000036165

7 .000042193

8 .000048220

9 .000054248

10 .000060276

11 .000066303

12 .000072331

13 .000078359

14 .000084387

15 .000090415

16 .000096443

17 .000102471

18 .000108499

19 .000114527

20 .000120555

21 .000126583

22 .000132611

23 .000138639

24 .000144668

25 .000150696

26 .000156724

27 .000162752

28 .000168781

29 .000174809

30 .000180838

31 .000186866

32 .000192895

33 .000198923

34 .000204952

35 .000210981

36 .000217009

37 .000223038

38 .000229067

39 .000235095

40 .000241124

41 .000247153

42 .000253182

43 .000259211

44 .000265240

45 .000271269

46 .000277298

47 .000283327

48 .000289356

49 .000295385

50 .000301414

51 .000307444

52 .000313473

53 .000319502

54 .000325531

55 .000331561

56 .000337590

57 .000343620

58 .000349649

59 .000355679

60 .000361708

61 .000367738

62 .000373767

63 .000379797

64 .000385827

65 .000391856

66 .000397886

67 .000403916

68 .000409946

69 .000415976

70 .000422006

71 .000428035

72 .000434065

73 .000440095

74 .000446126

75 .000452156

76 .000458186

77 .000464216

78 .000470246

79 .000476276

80 .000482307

81 .000488337

82 .000494367

83 .000500398

84 .000506428

85 .000512458

86 .000518489

87 .000524519

88 .000530550

89 .000536581

90 .000542611

91 .000548642

92 .000554673

93 .000560703

94 .000566734

95 .000572765

96 .000578796

97 .000584827

98 .000590858

99 .000596889

100 .000602920

101 .000608951

102 .000614982

103 .000621013

104 .000627044

105 .000633075

106 .000639106

107 .000645138

108 .000651169

109 .000657200

110 .000663232

111 .000669263

112 .000675294

113 .000681326

114 .000687357

115 .000693389

116 .000699420

117 .000705452

118 .000711484

119 .000717515

120 .000723547

121 .000729579

122 .000735611

123 .000741643

124 .000747674

125 .000753706

126 .000759738

127 .000765770

128 .000771802

129 .000777834

130 .000783866

131 .000789898

132 .000795931

133 .000801963

134 .000807995

135 .000814027

136 .000820060

137 .000826092

138 .000832124

139 .000838157

140 .000844189

141 .000850222

142 .000856254

143 .000862287

144 .000868319

145 .000874352

146 .000880385

147 .000886417

148 .000892450

149 .000898483

150 .000904516

151 .000910549

152 .000916581

153 .000922614

154 .000928647

155 .000934680

156 .000940713

157 .000946746

158 .000952780

159 .000958813

160 .000964846

161 .000970879

162 .000976912

163 .000982946

164 .000988979

165 .000995012

166 .001001046

167 .001007079

168 .001013113

169 .001019146

170 .001025180

171 .001031213

172 .001037247

173 .001043280

174 .001049314

175 .001055348

176 .001061382

177 .001067415

178 .001073449

179 .001079483

180 .001085517

181 .001091551

182 .001097585

183 .001103619

184 .001109653

185 .001115687

186 .001121721

187 .001127755

188 .001133790

189 .001139824

190 .001145858

191 .001151892

192 .001157927

193 .001163961

194 .001169995

195 .001176030

196 .001182064

197 .001188099

198 .001194133

199 .001200168

200 .001206203

201 .001212237

202 .001218272

203 .001224307

204 .001230342

205 .001236376

206 .001242411

207 .001248446

208 .001254481

209 .001260516

210 .001266551

211 .001272586

212 .001278621

213 .001284656

214 .001290691

215 .001296727

216 .001302762

217 .001308797

218 .001314832

219 .001320868

220 .001326903

221 .001332938

222 .001338974

223 .001345009

224 .001351045

225 .001357080

226 .001363116

227 .001369151

228 .001375187

229 .001381223

230 .001387259

231 .001393294

232 .001399330

233 .001405366

234 .001411402

235 .001417438

236 .001423474

237 .001429510

238 .001435546

239 .001441582

240 .001447618

241 .001453654

242 .001459690

243 .001465726

244 .001471762

245 .001477799

246 .001483835

247 .001489871

248 .001495908

249 .001501944

250 .001507981

251 .001514017

252 .001520054

253 .001526090

254 .001532127

255 .001538163

256 .001544200

257 .001550237

258 .001556274

259 .001562310

260 .001568347

261 .001574384

262 .001580421

263 .001586458

264 .001592495

265 .001598532

266 .001604569

267 .001610606

268 .001616643

269 .001622680

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renunsia · 10 days ago

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