Internal Revenue Bulletin:  2011-18 

May 2, 2011 

INCOME TAX


Notice 2011-32 Notice 2011-32

Japan earthquake and tsunami in 2011. This notice designates the Japan earthquake and tsunami occurring in March 2011 as a qualified disaster for purposes of section 139 of the Code.

Rev. Proc. 2011-22 Rev. Proc. 2011-22

This procedure provides a safe harbor method of accounting for determining the recovery periods for depreciation of certain tangible assets used by wireless telecommunications carriers. The procedure also explains how a taxpayer may obtain automatic consent from the Commissioner of Internal Revenue to change to the safe harbor method of accounting provided. Rev. Proc. 2011-14 modified and amplified.

Rev. Proc. 2011-27 Rev. Proc. 2011-27

This procedure provides two alternative safe harbor approaches that taxpayers may use to determine whether expenditures to maintain, replace, or improve wireline network assets must be capitalized under section 263(a) of the Code: a network asset maintenance allowance method or a units of property method. This procedure also provides procedures for obtaining automatic consent to change to either safe harbor method. A companion revenue procedure (Rev. Proc. 2011-28) provides similar safe harbor approaches that may be used for wireless network assets. Rev. Proc. 2011-14 modified.

Rev. Proc. 2011-28 Rev. Proc. 2011-28

This procedure provides two alternative safe harbor approaches that taxpayers may use to determine whether expenditures to maintain, replace, or improve wireless network assets must be capitalized under section 263(a) of the Code: a network asset maintenance allowance method or a units of property method. This procedure also provides procedures for obtaining automatic consent to change to either safe harbor method. A companion revenue procedure (Rev. Proc. 2011-27) provides similar safe harbor approaches that may be used for wireline network assets. Rev. Proc. 2011-14 modified.

Rev. Proc. 2011-29 Rev. Proc. 2011-29

This procedure provides a safe harbor election for allocating success-based fees paid in business acquisitions or reorganizations described in regulations section 1.263(a)-5(e)(3). In lieu of maintaining the documentation required by section 1.263(a)-5(f), this safe harbor permits electing taxpayers to treat 70 percent of the success-based fee as an amount that does not facilitate the transaction. The remaining portion of the fee must be capitalized as an amount that facilitates the transaction.

Announcement 2011-28 Announcement 2011-28

This announcement provides notice of a public hearing on proposed regulations relating to the payment of rewards under section 7623(a) of the Code and awards under section 7623(b). The guidance is necessary to clarify the definition of proceeds of amounts collected and collected proceeds under section 7623. This regulation provides needed guidance to the general public as well as officers and employees of the IRS who review claims under section 7623. A public hearing is scheduled for May 11, 2011.


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