Internal Revenue Bulletin: 2010-52
December 27, 2010
Interest rates; underpayments and overpayments. The rates for interest determined under section 6621 of the Code for the calendar quarter beginning January 1, 2011, will be 3 percent for overpayments (2 percent in the case of a corporation), 3 percent for underpayments, and 5 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 0.5 percent.
This notice provides transitional relief for determining the timeliness of federal tax deposits (FTDs) under section 6302 of the Code.
This notice primarily addresses the application of section 909 of the Code to foreign income taxes paid or accrued in taxable years of a section 902 corporation beginning on or before December 31, 2010. It includes an exclusive list of arrangements that will be treated as foreign tax credit splitting events for those taxable years.
The Internal Revenue Service announces the release of Form 8944, Preparer e-file Hardship Waiver Request, which tax return preparers who meet the definition of a specified tax return preparer and who believe they may qualify for an undue hardship waiver may begin to use to voluntarily submit an undue hardship waiver request to the IRS now. Preparers must use Form 8944 to voluntarily request a waiver. This announcement also informs tax return preparers of the time limits for submitting waiver requests for 2011, and that approval of any waiver request is contingent upon and will not occur prior to the publication of final regulations and a final revenue procedure, which is expected in early 2011.
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