Home Science What Do We Know About The New Planet in Our Solar System?
What Do We Know About The New Planet in Our Solar System?
For better or for worse, Pluto has been downgraded from a full-sized planet to a dwarf planet and there is no going back. But that hasn't stopped astronomers from searching for a 'true' Planet Nine in our solar system, which they might have found and at the same, maybe have found a Planet Ten too.
Since the scientific redefinition of a planet and dwarf planet that got Pluto kicked out of the planetary lineup, astronomers have discovered a number of other dwarf planets at the outer edges of the solar system. The latest possible dwarf planet, named UZ224 and still awaiting official classification, is nearly 8.5 billion miles (13.7 billion km) from the Sun and takes 1,100 Earth years to fully orbit it. It joins a handful of other dwarf planets in the Kuiper Belt just beyond Neptune.
What is important about the dwarf planets and other objects in the Kuiper Belt (KBO) is that it is their unusual orbit paths that are giving scientist indications of the existence of Planet Nine. In 2016, researchers from the California Institute of Technology asserted that not only did Planet Nine exist but that its mass is about 10 times that of Earth's mass. Further, it's orbit is so wide outside of the typical circumference of the solar system that it takes 20,000 Earth years to fully orbit the Sun.
Additionally, in a recent study, Renu Malhotra and KathrynVolk of the University of Arizona have made additional observations of Kuiper Belt objects and believe their orbits indicate not just a ninth planet but also a tenth planet.
Although KBOs are far enough away that the gravity of the larger planets in the solar system does not strongly influence their orbits, they do have typical patterns that can be predicted based on the known observable objects nearby. When their orbits deviate from the predicted orbit, it can be presumed that another object we've yet to see is exerting influence. Lately, some KBOs have been exhibiting orbits 50 AU where from where astronomers think they should be and that bringing up the possibility of a tenth planet in our solar system.
In the research for Planet Nine, astronomers think that it's about 700 **AU from the sun but Malhotra and Volk think that Planet Ten is closer than that. They are also predicting this tenth planet to be approximately the same size as Mars.
However, neither the evidence of Planet Nine nor that of a tenth planet is fully accepted by all astronomers yet. Alessandro Morbidelli from the Côte d'Azur Observatory told New Scientist "I am dubious that a planet so close and so bright would have remained unnoticed.
If more objects in the Kuiper Belt exhibit similar orbit shifts, it will go a long way to support the predictions of a ninth or tenth planet. In the end, though, it won't be until the predicted planets can be visually observed that our solar system will once again have nine planets or possibly grow to include ten.
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There is no doubt about it, people absolutely love cats and they spend a lot of their time thinking about them and searching for them online. In fact, some of the most popular videos are cat videos. Many people find that they are jumping from one video to the next for hours on end. If you are somebody that loves cats and just can't seem to get enough of them, perhaps it is time for you to discover your feline personality.
There are currently 73 cat breeds that are recognized by the International Progressive Cat Breeders Alliance. Each of those different breeds of feline is going to have their own unique look and features, as well as their own personality. While it is true that each animal is unique in their own right, it is the breed that will often help the point the animal in a specific direction.
Discovering your inner cat breed can really make a difference in your life. Not only can it help you to learn a little bit more about yourself by seeing it through an outside source, it can also show you which cat may be best suited for living in your household. That is why this quiz is a win-win for everyone.


Before a busy day in the garden, I managed to get a walk in early morning today. One of the great things about out new home is that its about 5 minutes away from a great coastal bush walk.
I brought out the old Olympus E500 four thirds DSLR. Although getting a little long in the tooth, it has pleasing colours, and still handels well compared to my newer units.
Looking out across the water to the next peninsula I captured the calm, golden morning.


Debra Jayne East is my guest today for the MK tour, and what a wonderful stop it is! We were given the challenge of a flash fiction to an image prompt – and Crimson Snow is what Debra came up with.
Amera Roberts pulled the covers closer as the frigid air assaulted her lithe body. Her arms and head were exposed by the pitifully thin covers, but she had nothing better to use. Her caretakers had left her six days ago on her eighteenth birthday and they had taken everything except her bed and dresser. She had got up for breakfast as usual and to her surprise, she opened the door to a bare room and scribbled note. She still turned the cryptic message over in her mind with anger. Time to worry about the meaning later, but now, she must try to survive with very little wood and an ever dwindling supply of food.
In the dim light of morning, her mind foggy from hunger, she procrastinated whether she should get up to check the fire. In her heart, she feared it must be out already, but she knew her life depended on getting some warmth in the frigid temperatures of early dawn. As her bare feet met the cold stone floor, she cringed at the brief contact before she found her slippers. Her breath painfully expelled frozen little puffs of air as she dressed herself.
Throwing the blanket over her shoulders, she ran the few steps to the hearth and grabbed the fire poker to scrape around in the ashes to find embers. Her heart began to sink. She had only one more match and wanted to save it for an emergency. Panic filled the empty space in her stomach and just as she dreaded the worst, a tiny, glowing, ruby ember sparked warmly and she let out an audible sigh. Frantic, she hurriedly gathered her basket of pinecones and threw a few on top to keep it burning.
Moments later, she laid the oak logs carefully and was rewarded with the crackle of burning wood. If her fire burned out she would have no way to cook her meager allotment of food. If she was really stingy with her rations she could hold out for three more days. It was difficult when she had not been full for almost a week. A dozen potatoes and half a loaf of bread could only go so far. One day she had given into weakness and consumed an extra cup of tea to stave off her hunger. Today, she was sorry for that extravagance because now her little tea box was empty and she would miss her morning cup.
Amera measured her small cup of meal carefully for porridge and added it to the bowl of hot water from the kettle. Sweetened with the last spoon of honey, she ate her meal in silence and waited for the light of dawn to warm up the room.
She finished the last bite, then dared to look out the front door in case her beloved Spike had returned from a hunt with a tasty rabbit or other small game to eat. He had disappeared the next day after Fran and Gregory Braithworth had vanished and she wondered if he went to look for them. Fran did not have much use for the strange little black-faced dog but Gregory adored him. He took him hunting on his trips to the glen and saved little tidbits from his meal for him. The snowstorm had prevented her from looking more for her precious dog that night and now tears stung her eyes as she wondered his fate.
It was over five minutes until she pried the door open partially while the snow trickled in its opening. No sign of her small trusted friend. Now, there must be nearly a foot of snow on the ground and the air smelled of more. She would never see his tracks now if it snowed again. He may be dead by now if he didn't find a barn or cave to go in. She would die also if she could not get out to gather wood and search for food.
Disheartened, she closed the door and went over by the fire to soak in its warmth and read the message for the tenth time. Carefully, she unfolded the scrap piece of parchment and read the few lines that made her temper boil.
Quickly, she folded the note in her pocket and ran to the closet… Husband to be? They had pledged her hand in marriage without even telling her and that he would kill her if she ran? What did they mean by arrangement anyway? All these years she stayed here dreaming of a life outside this glen. They told her nothing of getting married! She had stayed here to please her guardians only to face this calamity?
Through clenched teeth she pulled on old boots left behind by Gregory and wrapped herself as warmly as possible. She had no time to worry about some senile old groom who might come for her. She must go to find wood and food or die here but it would not be without trying.
Bravely, she tramped through the hard crust of white up the hill to the gate. She headed for a clump of trees with some saplings and felt in her pocket for the small hatchet she always carried with her when she went out alone. These woods always seemed ominous on the other side of the hill. She felt safe with Spike, who would bark at anything that moved, but now she was alone and greeted with silence. It took an hour to cross the meadow to the small forest of trees laden with fresh snow. She was exhausted by the time she got there and felt the cold creeping into her feet. Anxiously, she looked at the low-lying branches that were too thick for her to cut with so small a hatchet. Down through the trees she saw a clearing with several small cedars. She was sure she could make out a few broken limbs. Painstakingly, she trudged the path and was only a few feet from the trees when she heard the crunch of something coming through the woods behind her. Panic engulfed her as she glanced around to see the culprit of the disturbance. In the distance, she saw an ominous rider on a black horse bursting through the trees.
The thought fueled her energy and she glanced behind to see he was less than a hundred yards behind. His face was hidden within the hood of his cape. She sucked in large breaths of cold air and headed for a small knoll covered with snowdrifts and rocks. All the while, the fear of not knowing his identity was like a bullet in her chest. Damn them for doing this to her!
As she neared the rocky hill, she stumbled and fell to one knee. Before she could pick herself up to run, a luminous weapon flew overhead and landed in the snow ahead of her. Frozen in shock she suddenly knew who her suitor was!
Debra Jayne East was born the oldest of six girls in Martinsville, Virginia. For as long as she could remember, she loved to keep journals, write poetry and short stories. She researched her family tree and suddenly she understood why. Her distant relative, Violet Florence Martin was an Irish author, born in 1862, who co-wrote a series of novels with cousin Edith Somerville under the pen name of Martin Ross in the late 19th and early 20th centuries.
Learning about her heritage encouraged her to follow her dreams. After she encountered a near-death experience during a routine surgery, she realized her time had come to follow her heart and pursue her calling to be a writer. Her first novel, Radiance:Love after Death was released by XOXO Publishing in June of last year.
Marena Jacobs was not your typical kind of heroine. She's divorced, in her forties and a workaholic. "I always love to read about people and situations that are out of the norm. I believe many readers get tired of getting the same old cookie cutter description of a breathtakingly beautiful heroine and a devilishly handsome man.
Debra lives in North Carolina close to the Blue Ridge Parkway and enjoys photography, volunteering and spending time with her family. Currently, she completing a second book in her Radiance series and also working on a science fiction novel.


Helicobacter pylori commonly known as H. pylori, is a spiral shaped bacteria that causes chronic inflammation of the inner lining of the stomach and duodenum in humans. More than 60% of the world's population harbor H. pylori in their upper gastrointestinal tract. This bacterium also is considered a common cause of ulcers worldwide ( 90% of people with ulcers are infected with H. pylori). Interestingly, many people who have these organisms residing (colonizing) in their stomach and upper part of digestive tract ; have fewer or no symptoms. H. pylori infection may not cause any symptoms for long but if symptoms do appear there will be nausea, heartburn or severe pain in the abdomen, bloating and burping is present in most of the cases as well.
Individuals with H. pylori may experience severe symptoms and conditions such as peptic ulcers, stomach lining inflammation and increased risk of stomach cancer. H. pylori was first discovered in the stomach of patients with gastritis and ulcers by Drs. Barry Marshall and Robin Warren of Perth, Australia n 1982 At the time, the conventional thinking was that no bacterium could live in the acid environment of the human stomach. In recognition of their wonderful work, Marshall and Warren were awarded Nobel Prize in Physiology in the Year 2005.
H.pylori infection is usually spread from one person to another through direct contact. It may also spread by drinking contaminated water or eating contaminated food.
H pylori infection is usually diagnosed by Urease breath test, your doctor my choose to have a blood test and faeces test to diagnose H. pylori infection.
Ayurveda is a great way to treat this disorder from its root cause which imbalance of Pitta humor. imbalance. The Pitta imbalance causes the symptoms of heartburn, gastroesophageal reflux, nausea and occassionaly vomitting may happen. The Pitta imbalance results in disturbance of normal digestive process causing accumulation of Ama( Undigested food) . Ama causes indigestion, bloating, burping and distubance of normal bowel habits.
Ayurvedic approach to treat H. pylori involves treating the imbalance of Pitta dosha and removal of Ama. Ayurvedic herbs such as Turmeric, Licorice, Cumin, Bhumiamalaki, Chitraka and Ginger offers great benefit to treat H. pylori infection. Panchkarma therapy is indicated in severe cases of H. pylori infection.
At Ojus Health Ayurved Clinic in Melbourne, we use pure organic ayurvedic herbal products to treat H pylori infection.
Book an appointment Today to get treated for H pylori infection.


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Archives for posts with tag: Fight Club
Flore Maquin: Movie Poster Mistress
When done well, reimagining movie posters (here and here and here) never gets old. Movie poster design presents a unique challenge to designers… it's usually one of the first representations of a movie people see, so there's a tall order to embody an often complex story with a single image. French designer and illustrator Flore Maquin is clearly up to that challenge. Maquin has a knack for designing movie posters extraordinarily well. We love her bold style, which is evident throughout her pieces. And she has a clear appreciation for typography. But it's her genuine esteem for cinema that really shines through here. These creations feel like a labor of love, and that's what makes them truly special. Well done.
Via flore-maquin.com
Tags Alfred Hitchcock, appreciation, bold, bold style, Brad Pitt, challenge, Christopher Nolan, cinema, complex, creative challenge, digital painting, Django Unchained, Edward Norton, embody, esteem, evident, extraordinarily well, extraordinary, Fight Club, film poster, first representations, Flore Maquin, France, Interstellar, Jamie Fox, Jaws, Jean Reno, Jessica Chastain, Jim Carrey, K2s0, knack, labor of love, Leon, love, Luc Besson, Mad Max Fury Road, Matthew McConaughey, Mila Jovovich, movie poster design, Nathalie Portman, Pulp Fiction, Quentin Tarantino, reimagining, Rogue One, Samuel L Jackson, special, Star Wars, Steven Speilberg, tall order, The Birds, The Fifth Element, The Mask, Uma Thurman
Categories Advertising, Campaign, Color, Design, handlettering, illustration, Inspiration, Marketing, Movie Poster, Posters, Prints, Retro, Series, Typography
Pop Culture-Centric Poster Art by Joshua Budich
February 2, 2015 //
The landing page of Baltimore-based artist Joshua Budich's website simply states "born to illustrate." That's a loaded declaration, but Budich certainly has the goods to back it up. His eclectic body of work is quite impressive, with an obvious love for pop culture. His style is reminiscent of comic book art, which lends itself to his familiar subjects from television, movies and music. Budich relies heavily on line work, and achieves some great, expressive details without overdoing it, or looking like he simply traced celebrities. He also has a great eye for composition and color, making his work recognizable now that we're familiar with it (prints for sale here).
Via joshuabudich.com
Tags Amy Winehouse, Bob Dylan, Bob Marley, Boy Meets World, comic book, comic book art, composition, details, eclectic, Eddie Veddar, Elvis, Elvis Presley, Empire Magazine, Ferris Bueller's Day Off, Fight Club, film, Frank Sinatra, Ghostbusters, Indiana Jones, Inglourious Bastards, Joshua Budich, LOST, movie, movies, music, NASCAR, New Girl, Notorious B.I.G., pop culture, Quentin Tarantino, Radiohead, Silver Linings Playbook, Sports Illustrated Kids, Stand By Me, style, television, The Big Lebowski, The Life Aquatic, Tupac
Categories Advertising, Color, Design, Drawing, For Sale, illustration, Inspiration, Marketing, Movie Poster, Posters, Prints, Retro, Series, Sports, Typography
Famous Costumes
Yes, we are suckers for series, and we especially love this one. Brazilian designer/illustrator Frederico Birchal depicts famous figures from music, movies and television with just costumes. Birchal's attention to detail really elevates this series. Awesome concept, excellent execution. Well done!
Tags Breaking Bad, clothing, costumes, Daft Punk, Django Unchained, Elton John, famous, Fight Club, Freddie Mercury, Frederico Birchal, Johnny Cash, Kurt Cobain, Matrix, Michael Jackson, minimalist, movies, music, Rocky, Slash, television, The Beatles, The Big Bang Theory, The Terminator
Categories Apparel, Color, Design, illustration, Inspiration, Portrait, Posters, Prints, Retro, Series

redpajama_set_name: RedPajamaCommonCrawl


Most college students look forward to the day that they'll cross the stage at graduation and proudly accept their diploma as family, friends, and classmates cheer them on. But, for Lauren Shipman, that walk was more than just a rite of passage—it was the culmination of 14 months of physical rehabilitation, perseverance, and optimism.
Born with cerebral palsy and confined to a wheelchair since age three, Lauren had always assumed that she would use her wheelchair to cross the stage during her graduation from Neumann University in May 2015. She didn't think twice about the decision until the spring of her junior year, when a staff member and friend in the school's Academic Resource Center was interviewed for a student project about Lauren's life with cerebral palsy.
So, in August 2014, Shipman enrolled in outpatient therapy at Bryn Mawr Rehabilitation Hospital to accomplish her goal. Although it wasn't the first time she had gone to therapy, it had been many years since her last visit.
Shipman started off slowly, spending several months at the beginning of her therapy doing manual stretching and using the hospital's Easy Glider to increase her range of motion and the Eva Walker to help support her forearms as she walked. As her comfort level increased, Shipman's physical therapists began including strengthening exercises in her routine, supervising her as she stood without assistance, shifted her weight between two parallel bars, and used the hospital's Nimbo Walker to help improve her stability. Every session concluded with a walk around the hospital gym or down the hallway.
Shipman's therapy team witnessed that drive firsthand.
So it surprised no one when, after nine months of physical therapy, Lauren proudly made her way to the stage on a Saturday in May. With the help of two physical therapy students, Lauren walked across the stage to accept her diploma. That feeling, she says, was incredible.
Although Shipman has been able to cross one goal off her list, she isn't stopping there. She continues to visit Bryn Mawr Rehab once a week for outpatient therapy in hopes of becoming more independent despite her cerebral palsy and increasing her muscle endurance. In the summer of 2015, she began working with the hospital's occupational and speech therapy teams to supplement her physical therapy, as well.
And she has non-therapy goals, too. The college graduate hopes to pursue a Master's degree in pastoral clinical mental health counseling, and dreams of a career as an academic advisor or life coach.
"There is just something about helping people that gives me a sense of great satisfaction. I would like people to understand that, whatever challenges they may face and whether or not they face a disability, there is always a light at the end of the tunnel," says Shipman.
Looking back on the past year, Shipman credits her therapy team at Bryn Mawr Rehab for helping keep her focused on that light.


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Internal Revenue Bulletin: 2011-49
本网业目前尚未译成中文
Highlights of This Issue
The IRS Mission
Part I. Rulings and Decisions Under the Internal Revenue Codeof 1986
Rev. Rul. 2011-29
Part III. Administrative, Procedural, and Miscellaneous
Notice 2011-94
Rev. Proc. 2011-56
Definition of Terms and Abbreviations
Numerical Finding List
Effect of Current Actions on Previously Published Items
Finding List of Current Actions on Previously Published Items
How to get the Internal Revenue Bulletin
INTERNAL REVENUE BULLETIN
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We Welcome Comments About the Internal Revenue Bulletin
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.
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.
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.
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.
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.
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.
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.
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.
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
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?
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.
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.
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.
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.
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.
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).
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.
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
1 .000006027
10 .000060276
100 .000602920
This revenue ruling provides various prescribed rates for federal income tax purposes for December 2011 (the current month). Table 1 contains the short-term, mid-term, and long-term applicable federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted federal long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropriate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%. Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520. Finally, Table 6 contains contains the 2012 interest rate for sections 846 and 807.
REV. RUL. 2011-31 TABLE 1
Applicable Federal Rates (AFR) for December 2011
Period for Compounding
AFR .20% .20% .20% .20%
110% AFR .22% .22% .22% .22%
AFR 1.27% 1.27% 1.27% 1.27%
110% AFR 1.40% 1.40% 1.40% 1.40%
Adjusted AFR for December 2011
Short-term adjusted AFR .45% .45% .45% .45%
Mid-term adjusted AFR 1.69% 1.68% 1.68% 1.67%
Long-term adjusted AFR 3.55% 3.52% 3.50% 3.49%
Rates Under Section 382 for December 2011
Adjusted federal long-term rate for the current month 3.55%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 3.55%
Appropriate Percentages Under Section 42(b)(1) for December 2011
Note: Under Section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, and before December 31, 2013, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit 7.47%
Rate Under Section 7520 for December 2011
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 1.6%
Rates Under Sections 846 and 807
Applicable rate of interest for 2012 for purposes of sections 846 and 807 2.89%
Whether a grantor's retention of the 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 § 2042 of the Internal Revenue Code.
D, a United States citizen, established and funded Trust with cash. Thereafter, Trust purchased a life insurance policy on D's life. Trust is an irrevocable trust for the benefit of D's descendants. T is the trustee of Trust, and the terms of Trust prohibit D from serving as trustee of Trust. D makes gifts every year to Trust, and Trust pays the premium on the insurance policy. The proceeds of the policy are payable to Trust upon D's death.
D cannot revoke, alter, amend, or terminate the trust. The governing instrument of Trust, however, provides D with the power, exercisable at any time, to acquire any property held in Trust by substituting other property of equivalent value. The trust instrument provides that the power is exercisable by D in a nonfiduciary capacity, without the approval or consent of any person acting in a fiduciary capacity. To exercise the power of substitution, D must certify in writing that the substituted property and the Trust property for which it is substituted are of equivalent value. In addition, under local law, T has a fiduciary obligation to ensure that the property that D seeks to substitute is equivalent in value to the property distributed to D. Moreover, if a trust has two or more beneficiaries, local law requires the trustee to act impartially in investing and managing the trust assets, taking into account any differing interests of the beneficiaries. Finally, under local law and without restriction in the trust instrument, T has the discretionary power to acquire, invest, reinvest, exchange, sell, convey, control, divide, partition, and manage the trust property in accordance with the standards provided by law.
D has no incidents of ownership in the insurance policy unless D's right of substitution is considered an incident of ownership. D dies without having exercised the power to substitute with respect to the life insurance policy.
Section 2042(2) provides that the value of the gross estate includes the value of all property to the extent of the amount receivable as insurance under policies on the life of the decedent by beneficiaries (other than the executor), with respect to which the decedent possessed at decedent's date of death any of the incidents of ownership in the policies, exercisable either alone or in conjunction with any other person.
Section 20.2042-1(c)(2) of the Estate Tax Regulations provides that the meaning of the term "incidents of ownership" is not confined to ownership of the policy in the technical legal sense. Generally speaking, the term refers to the right of the insured or the insured's estate to the economic benefits of the policy. Thus, the term includes without limitation the power to change the beneficiary, to surrender or cancel the policy, to assign the policy, to revoke an assignment, to pledge the policy for a loan, or to obtain from the insurer a loan against the surrender value of the policy.
Section 20.2042-1(c)(4) provides that a decedent is considered to have an incident of ownership in a policy held in trust if, under the terms of the policy, the decedent (either alone or in conjunction with another person) has the power (as trustee or otherwise) to change the beneficial ownership in the policy or its proceeds, or the time or manner of enjoyment thereof, even though the decedent has no beneficial interest in the trust. Moreover, assuming the decedent created the trust, such a power may result in the inclusion in the decedent's gross estate under § 2036 or 2038 of other property transferred by the decedent to the trust if, for example, the decedent has the power to surrender the insurance policy and if the income otherwise used to pay premiums on the policy would become currently payable to a beneficiary of the trust in the event that the policy were surrendered.
In Rev. Rul. 84-179, 1984-2 C.B. 195, the decedent purchased an insurance policy on his life and transferred all incidents of ownership to his spouse. His spouse designated their adult child as the policy beneficiary. Subsequently, the spouse died and her will established a residuary trust for the benefit of the child. The decedent was designated the trustee of this trust. The insurance policy on the decedent's life, which was part of the residuary estate, passed to the testamentary trust. As trustee, the decedent had broad discretionary powers in the management of the trust property and the power to distribute or accumulate income. Under the terms of the policy, the owner could elect to have the proceeds made payable according to various plans, use the loan value to pay the premiums, borrow on the policy, assign or pledge the policy, and elect to receive annual dividends. The will did not preclude the decedent from exercising these powers, although the decedent could not do so for his own benefit. The decedent paid the premiums on the policy out of other trust property and was still serving as trustee when he died.
Citing the legislative history of § 2042(2), the ruling states that Congress intended § 2042 to parallel the statutory scheme governing those powers that would cause other types of property to be included in a decedent's estate under §§ 2036 and 2038. Section 2036 applies to the transfer of property where rights or powers are retained incident to the transfer, and § 2038 pertains to situations where property is transferred and power over the property subsequently returns to the transferor-decedent.
Under the facts in Rev. Rul. 84-179, the decedent transferred the policy to his wife and subsequently, in an unrelated transaction, reacquired incidents of ownership over the policy in a fiduciary capacity. The ruling holds that the decedent will not be considered to possess incidents of ownership in the policy for purposes of § 2042(2), provided the decedent could not exercise the powers for the decedent's personal benefit, the decedent did not transfer the policy or any of the consideration for purchasing or maintaining the policy to the trust from personal assets, and the devolution of the powers to the decedent was not part of a prearranged plan involving the participation of decedent.
The ruling further states, however, that the decedent will be deemed to have incidents of ownership over an insurance policy on the decedent's life where decedent's powers are held in a fiduciary capacity and the decedent has transferred the policy or any of the consideration for purchasing and maintaining the policy to the trust. Also, where the decedent's powers could have been exercised for decedent's benefit, they will constitute incidents of ownership in the policy, without regard to how those powers were acquired and without consideration of whether the decedent transferred property to the trust. Thus, in such a situation, if the decedent reacquires powers over insurance policies in an individual capacity, the powers will constitute incidents of ownership even though the decedent is a transferee. See Estate of Fruehauf v. Commissioner, 427 F.2d 80 (6th Cir. 1970); Estate of Skifter v. Commissioner, 468 F. 2d 699 (2d Cir. 1972).
In Estate of Jordahl v. Commissioner, 65 T.C. 92 (1975), acq. in result, 1977-2 C.B. 1, the decedent created an inter vivos trust. The corpus of the trust included insurance policies on the decedent's life and other income producing assets. Under the terms of the trust, the decedent reserved the power to substitute other securities or property for those held in trust, provided the substituted property was equal in value to the property replaced. After the decedent's death, the Service argued that the trust assets were includible in the decedent's gross estate under § 2038 because the decedent's power to substitute assets of equal value could be exercised to alter the beneficial interests in the trust. The Service also argued that the proceeds from the insurance policies should also be included under § 2042(2) because the power to substitute the insurance policies allowed the decedent to reacquire full ownership of the policies in the trust.
The Tax Court determined that, because the decedent was bound by fiduciary standards and was therefore accountable in equity to the succeeding income beneficiary and remaindermen, the decedent could not exercise the power to deplete the trust or to shift trust benefits among the beneficiaries. Accordingly, the Court held that the substitution power was not a power to alter, amend, or revoke the trust within the meaning of § 2038. The court further concluded that the decedent's power to substitute an insurance policy was merely a power to exchange at arm's length. The Court held that such a power was in effect a right to purchase the policy and that such a right could not be considered an incident of ownership.
In Rev. Rul. 2008-22, 2008-16 I.R.B. 796, the grantor created an irrevocable inter vivos trust for the benefit of the grantor's descendants. The grantor retained the power, exercisable in a nonfiduciary capacity, to acquire any property held in the trust by substituting other property of equivalent value. The ruling concludes that the grantor's retained power to substitute assets of equivalent value will not, by itself, cause the value of the trust corpus to be includible in the grantor's gross estate under § 2036 or 2038, 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. The ruling further provides that the substitution power cannot be exercised in a manner that would cause the shifting of benefits among the trust beneficiaries.
In the instant case, like the situation presented in Rev. Rul. 2008-22, the trust instrument expressly prohibits D from serving as trustee and states that D's power to substitute assets of equivalent value is held in a nonfiduciary capacity. However, under the terms of Trust, the assets that D may transfer into Trust must be equivalent in value to the insurance policies that D will receive. In addition, T has a fiduciary obligation to ensure that the assets substituted are of equivalent value. Thus, D cannot exercise the power to substitute assets in a manner that will reduce the value of the trust corpus or increase D's net worth. Further, in view of T's ability to reinvest the assets and T's duty of impartiality to the trust beneficiaries, there will be no shifting of benefits between or among the beneficiaries that could otherwise result from a substitution of property by D. Under these circumstances, D's retained power to substitute assets of equivalent value for a life insurance policy held by Trust is not, by itself, an incident of ownership under § 2042(2).
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 § 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. A substitution power cannot be exercised in a manner that can shift benefits if: (a) the trustee has both the power (under local law or the trust instrument) to reinvest the trust corpus and a duty of impartiality with respect to the trust beneficiaries; or (b) the nature of the trust's investments or the level of income produced by any or all of the trust's investments does not impact the respective interests of the beneficiaries, such as when the trust is administered as a unitrust (under local law or the trust instrument) or when distributions from the trust are limited to discretionary distributions of principal and income.
The principal author of this revenue ruling is Mayer Samuels of the Office of the Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue ruling, contact Mr. Samuels at (202) 622-3090 (not a toll-free call).
Application of General Welfare Exclusion to Benefits Provided Under Indian Tribal Government Programs
This notice invites comments concerning the application of the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.
Section 61(a) of the Internal Revenue Code provides that, except as otherwise provided by law, gross income means all income from whatever source derived. The Internal Revenue Service has consistently held, however, under a limited general welfare exclusion (the exclusion), that payments under governmental social benefit programs for the promotion of the general welfare are not includible in a recipient's gross income. Rev. Rul. 2009-19, 2009-28 I.R.B. 111; Rev. Rul. 98-19, 1998-1 C.B. 840; Rev. Rul. 74-205, 1974-1 C.B. 20. To qualify under the exclusion, the payments must (1) be made to an individual under a governmental program, (2) be for the promotion of the general welfare (that is, based on need), and (3) not represent compensation for services. Rev. Rul. 2003-12, 2003-1 C.B. 283; Rev. Rul. 2005-46, 2005-2 C.B. 120.
E.O. 13175 (November 6, 2000) requires Federal agencies to consult with tribal officials before formulating and implementing policies that have tribal implications.
REQUEST FOR COMMENTS
The Service has received inquiries from Indian tribal governments about the application of the exclusion to tribal government programs that provide benefits to tribal members. These programs may include, but are not limited to:
Housing (for example, programs providing housing on and off the reservation, with income limits different from those of the United States Department of Housing and Urban Development);
Cultural (for example, programs involving tours of sites that are historically significant to a tribe; language preservation programs; community recreational programs; cultural and social events);
Education (for example, programs providing tutors or supplies to primary and secondary school students; job retraining programs for adults);
Elder programs (for example, programs providing heating assistance or meals).
In response to these inquiries, and to provide clarity and certainty to Indian tribal governments and consistency in applying the exclusion, the Service and the Treasury Department are considering issuing guidance. Pursuant to E.O. 13175, comments are invited describing actual or proposed Indian tribal government programs that provide benefits to members and the application of the exclusion to these programs and benefits.
Comments may be submitted in writing on or before February 13, 2012. Comments should be submitted to Internal Revenue Service, CC:PA:LPD:PR (Notice 2011-94), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044, or electronically to Notice.Comments@irscounsel.treas.gov. Please include "Notice 2011-94" in the subject line of any electronic communications. Alternatively, comments may be hand delivered between the hours of 8:00 a.m. and 4:00 p.m. Monday to Friday to CC:PA:LPD:PR (Notice 2011-94), Courier's Desk, Internal Revenue Service, 1111 Constitution Avenue NW, Washington, D.C. All comments will be available for public inspection and copying.
The principal author of this notice is Sheldon Iskow of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information, please contact Mr. Iskow at (202) 622-4920 (not a toll-free call).
SECTION 1. PURPOSE AND CHANGES
.01 Purpose.
(1) This revenue procedure clarifies, modifies, and supersedes Rev. Proc. 2003-14, 2003-1 C.B. 319, which provides a safe harbor under which the Internal Revenue Service treats an Indian tribe as the grantor and owner of a trust for the receipt of gaming revenues under the Indian Gaming Regulatory Act (25 U.S.C. §§ 2701-2721) (IGRA) for the benefit of minors or legal incompetents. Under the safe harbor, beneficiaries of an IGRA trust are not required to include amounts in gross income under the economic benefit doctrine when transferred to, or earned by, the IGRA trust, but must include trust distributions in income when actually or constructively received.
(2) Rev. Proc. 2003-14 requested public comments. In response to those comments, this revenue procedure revises sections 5.02(5), 5.02(6), 5.02(8)(a), 5.02(8)(b), and 5.02(8)(e) of Rev. Proc. 2003-14, and adds a new section 5.02(9).
.02 Changes.
(1) Section 6 of Rev. Proc. 2003-14 added to Rev. Proc. 2003-3, 2003-1 C.B. 113, certain areas under § 451 and §§ 671-679 of the Internal Revenue Code in which the Service will not issue ruling or determination letters concerning IGRA trusts. Guidance superseding Rev. Proc. 2003-3 incorporates these no-rule areas. See sections 4.01(34), 4.01(41), 5.08, and 5.10 of Rev. Proc. 2011-3, 2011-1 I.R.B. 111, and its successors. Therefore, section 6 of Rev. Proc. 2003-14 is obsolete.
(2) Section 5.02(5) removes the references to federal and local trust law because the validity of trusts is governed by state or tribal law.
(3) Section 5.02(6) clarifies that an IGRA trust must be an ordinary trust for purposes of the federal tax laws.
(4) Section 5.02(8)(a) expressly allows a trust instrument to provide that the distributions to or for the benefit of minors or legal incompetents at the discretion of the trustee must comply with the requirements of 25 U.S.C. § 2710(b)(3) and 25 CFR § 290.12(b)(3).
(5) Section 5.02(8)(b) removes the term "contractual" because the rights created under an IGRA trust instrument are not contractual.
(6) Section 5.02(8)(e) expands the class of persons who may receive a deceased beneficiary's share of the trust to include persons who receive property or interests under the beneficiary's will or trust, or in accordance with state or tribal intestacy law.
(7) Section 5.02(9) expressly allows a trust instrument to provide for trust distributions at a specified age or ages or upon the occurrence or nonoccurrence of a specified event or events.
SECTION 2. BACKGROUND
.01 Indian tribes and their members have requested guidance on determining the taxable years in which beneficiaries must include in gross income amounts transferred to, or earned by, an IGRA trust, and under what circumstances a tribe will be considered the grantor and owner of an IGRA trust.
.02 Under § 451 and §§ 1.451-1(a) and 1.451-2 of the Income Tax Regulations, a taxpayer using the cash receipts and disbursements method of accounting must include gains, profits, and income in gross income for the taxable year in which those items are actually or constructively received. In addition, under the economic benefit doctrine, a taxpayer using the cash receipts and disbursements method of accounting must include in gross income currently any financial or economic benefit derived from the absolute right to receive property in the future that has been irrevocably and unconditionally set aside for the taxpayer in a trust or fund. Sproull v. Commissioner, 16 T.C. 244 (1951), aff'd per curiam, 194 F.2d 541 (6th Cir. 1952); Pulsifer v. Commissioner, 64 T.C. 245 (1975).
.03 Section 671 provides that, when specified under subpart E, part 1, subchapter J, chapter 1, subtitle A (subpart E) that a grantor or another person is treated as the owner of any portion of a trust, then the taxable income and credits of the grantor or other person includes the items of income, deductions, and credits of the trust attributable to that portion of the trust to the extent that these items are included in computing an individual's taxable income or credits.
.04 IGRA provides rules regarding the conduct of class II and class III gaming on Indian lands within an Indian tribe's jurisdiction and an Indian tribe's use of revenues from that gaming. Under IGRA, an Indian tribe may use net revenues from any class II and class III gaming activities it conducts or licenses to make per capita payments to members of the Indian tribe only if: (1) the Indian tribe has prepared a plan to allocate revenues to authorized uses; (2) the Secretary of the Interior approves the plan as adequate; (3) the interests of minors and other legally incompetent persons who are entitled to receive any of the per capita payments are protected and preserved and the per capita payments are disbursed to the parents or legal guardians of the minors or legal incompetents in such amounts as may be necessary for the health, education, or welfare of the minors or other legally incompetent persons under a plan approved by the Secretary of the Interior and the governing body of the Indian tribe; and (4) the per capita payments are subject to federal taxation and the Indian tribe notifies members of that tax liability when payments are made. Section 11(b)(3) and (d)(1)(A) of IGRA, 25 U.S.C. § 2710(b)(3) and (d)(1)(A).
SECTION 3. SCOPE
This revenue procedure applies to Indian tribes, IGRA trusts, and beneficiaries of IGRA trusts.
SECTION 4. DEFINITIONS
For purposes of this revenue procedure:
.01 Indian tribe. The term "Indian tribe" has the same meaning as in 25 U.S.C. § 2703(5).
.02 IGRA trust. An "IGRA trust" is a trust that an Indian tribe establishes under IGRA to receive and invest per capita payments for its members who are minors or legal incompetents pending distribution of the trust assets to those members after they attain the age of majority or cease to be legal incompetents.
.03 Minor and legal incompetent. The terms "minor" and "legal incompetent" have the same meaning as in 25 CFR § 290.2 (relating to review of Indian tribal revenue allocation plans adopted under IGRA).
.04 Per capita payment. The term "per capita payment" has the same meaning as in 25 CFR § 290.2, but does not include compensation for services.
SECTION 5. APPLICATION
.01 In general. For any period in which each of the requirements of section 5.02 of this revenue procedure is met:
(1) The Service will treat an Indian tribe that establishes (or has established) an IGRA trust as the grantor and owner of the trust under subpart E, and
(2) The Service will not require beneficiaries of an IGRA trust to include per capita payments received by the trust, and any earnings on the per capita payments, in gross income until the taxable year that the beneficiaries actually or constructively receive the amounts under § 451 and the regulations thereunder.
.02 Requirements and Options for IGRA trusts.
(1) The Indian tribe has complied with the requirements of § 11(b)(3) of IGRA, 25 U.S.C. § 2710(b)(3), regarding the disbursement of per capita payments to members of the Indian tribe.
(2) All contributions to the trust are per capita payments disbursed under a revenue allocation plan that complies with the requirements of § 11(b)(3) of IGRA, 25 U.S.C. § 2710(b)(3).
(3) Each trust beneficiary is a member of the Indian tribe that establishes the trust.
(4) Each trust beneficiary is a minor or legal incompetent at the time of the establishment of a trust interest for the beneficiary, and all contributions to the trust for that beneficiary are made for the period that the beneficiary is a minor or legal incompetent.
(5) The trust is a valid trust under applicable state or tribal law and all of the material terms and provisions of the trust are enforceable under that law.
(6) The trust satisfies the definition of an ordinary trust in § 301.7701-4(a) of the Procedure and Administration Regulations and the governing trust instrument states that the trust is intended to be a grantor trust, that the Indian tribe is the grantor of the trust (within the meaning of subpart E), and that the trust will be construed accordingly.
(7) The governing trust instrument grants to the Indian tribe a power, an interest, or a combination thereof, described in §§ 673 through 677, that would cause the Indian tribe to be treated as owner of the trust under subpart E.
(8) The governing trust instrument includes the following provisions.
(a) Trust assets are not available to or for the benefit of a beneficiary until the beneficiary ceases to be a minor or legal incompetent, except for distributions for the health, education, or welfare of the beneficiary made at the discretion of the trustee pursuant to the governing trust instrument. The trust instrument may provide that these discretionary distributions are made under a plan approved by the governing body of the Indian tribe meeting the requirements of 25 CFR § 290.12(b)(3) (requiring criteria for distributions and a dispute resolution process).
(b) Beneficiaries have no preferred claim on, or any beneficial ownership interest in, any assets of the trust; any rights created under the trust instrument are mere unsecured rights of beneficiaries against the Indian tribe; and at all times during the continuance of the trust, the principal and income of the trust are subject to claims of general creditors of the Indian tribe under applicable federal, state, local, and tribal law.
(c) The trustee shall cease payments to or for the benefit of beneficiaries and shall hold the assets of the trust for the benefit of the Indian tribe's general creditors throughout any period during which the trustee believes or has reason to believe that the Indian tribe is unable to pay its debts as they become due, or is subject to a pending insolvency or bankruptcy proceeding.
(d) Amounts payable to or for the benefit of beneficiaries under the governing trust instrument may not be anticipated, assigned (either at law or in equity), alienated, pledged, encumbered or subjected to attachment, garnishment, levy, execution, or other legal or equitable process.
(e) The beneficiary's share will be paid to the Indian tribe if the beneficiary dies while a minor, legal incompetent, or before the conditions for full distribution provided in the governing trust instrument occur. However, the governing trust instrument may provide that the beneficiary's share may be paid pursuant to a valid will or trust of the beneficiary, or to persons who may inherit from the beneficiary under applicable state or tribal intestacy laws.
(9) The trust instrument may provide that after the beneficiary ceases to be a minor or legal incompetent, the trust may make distributions to or for the benefit of the beneficiary at a specified age or ages or upon the occurrence or nonoccurrence of a specified event or events.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective for IGRA trusts established or amended on or after November 14, 2011. Taxpayers may apply this revenue procedure to IGRA trusts established before November 14, 2011, for taxable years for which the period of limitation on refund or credit under § 6511 has not expired.
SECTION 7. TRANSITION RELIEF
The Service will not treat as a taxable event under § 1001 a modification or amendment of an IGRA trust made to come within this revenue procedure.
SECTION 8. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2003-14 is clarified, modified, and superseded.
The principal author of this revenue procedure is Christina Glendening of the Office of the Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Glendening at (202) 622-4920 (not a toll-free call).
SECTION 1. PURPOSE
This revenue procedure publishes the amounts of unused housing credit carryovers allocated to qualified states under § 42(h)(3)(D) of the Internal Revenue Code for calendar year 2011.
Rev. Proc. 92-31, 1992-1 C.B. 775, provides guidance to state housing credit agencies of qualified states on the procedure for requesting an allocation of unused housing credit carryovers under § 42(h)(3)(D). Section 4.06 of Rev. Proc. 92-31 provides that the Internal Revenue Service will publish in the Internal Revenue Bulletin the amount of unused housing credit carryovers allocated to qualified states for a calendar year from a national pool of unused credit authority (the National Pool). This revenue procedure publishes these amounts for calendar year 2011.
SECTION 3. PROCEDURE
The unused housing credit carryover amount allocated from the National Pool by the Secretary to each qualified state for calendar year 2011 is as follows:
Qualified State
Amount Allocated
California 570,425
District of Columbia 9,213
Florida 287,882
Georgia 148,335
Illinois 196,460
Kansas 43,686
Kentucky 66,444
Louisiana 69,414
Maine 20,340
Maryland 88,404
Massachusetts 100,256
Michigan 151,336
Minnesota 81,213
Nebraska 27,965
New Jersey 134,620
New York 296,714
North Carolina 146,051
Ohio 176,645
Pennsylvania 194,496
South Carolina 70,823
Texas 385,024
Utah 42,320
Vermont 9,581
Virginia 122,510
Washington 102,965
This revenue procedure is effective for allocations of housing credit dollar amounts attributable to the National Pool component of a qualified state's housing credit ceiling for calendar year 2011.
The principal author of this revenue procedure is Christopher J. Wilson of the Office of Associate Chief Counsel (Passthroughs and Special Industries). For further information regarding this revenue procedure, contact Mr. Wilson at (202) 622-3040 (not a toll-free call).
Amplified describes a situation where no change is being made in a prior published position, but the prior position is being extended to apply to a variation of the fact situation set forth therein. Thus, if an earlier ruling held that a principle applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below).
Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed.
Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.
Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted.
Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling.
Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded.
Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study.
Revenue rulings and revenue procedures (hereinafter referred to as "rulings") that have an effect on previous rulings use the following defined terms to describe the effect:
The following abbreviations in current use and formerly used will appear in material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel's Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D. —Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2011-1 through 2011-26 is in Internal Revenue Bulletin 2011-26, dated June 27, 2011.
Bulletins 2011-27 through 2011-49
2011-37 2011-27 I.R.B. 2011-27 37
2011-42 2011-32 I.R.B. 2011-32 138
2011-94 2011-49 I.R.B. 2011-49
128224-06 2011-42 I.R.B. 2011-42 533
137128-08 2011-28 I.R.B. 2011-28 43
Revenue Procedures
Revenue Rulings
Treasury Decisions
9527 2011-27 I.R.B. 2011-27 1
9528 2011-28 I.R.B. 2011-28 38
9533 2011-33 I.R.B. 2011-33 139
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2011-1 through 2011-26 is in Internal Revenue Bulletin 2011-26, dated June 27, 2011.
Old Article
2007-47 Updated and superseded by Ann. 2011-59 2011-37 I.R.B. 2011-37 335
2002-1 Amplified by Notice 2011-86 2011-45 I.R.B. 2011-45 698
2006-101 Amplified and superseded by Notice 2011-64 2011-37 I.R.B. 2011-37 231
2007-93 Obsoleted by T.D. 9545 2011-41 I.R.B. 2011-41 490
2010-23 Modified and supplemented by Notice 2011-54 2011-29 I.R.B. 2011-29 53
2010-77 Modified by Notice 2011-85 2011-44 I.R.B. 2011-44 605
2010-81 Amended and supplemented by Notice 2011-63 2011-34 I.R.B. 2011-34 172
2010-88 Modified by Ann. 2011-40 2011-29 I.R.B. 2011-29 56
158677-05 Withdrawn by Ann. 2011-75 2011-48 I.R.B. 2011-48 823
118761-09 Hearing scheduled by Ann. 2011-38 2011-28 I.R.B. 2011-28 45
151687-10 Hearing scheduled by Ann. 2011-48 2011-36 I.R.B. 2011-36 227
72-36 Amplified and modified by Rev. Proc. 2011-42 2011-37 I.R.B. 2011-37 318
2003-14 Clarified, modified, and superseded by Rev. Proc. 2011-56 2011-49 I.R.B. 2011-49
2004-29 Amplified and modified by Rev. Proc. 2011-42 2011-37 I.R.B. 2011-37 318
2005-16 Modified and superseded by Rev. Proc. 2011-49 2011-44 I.R.B. 2011-44 608
2006-56 Modified and amplified by Rev. Proc. 2011-46 2011-42 I.R.B. 2011-42 518
2008-24 Modified and superseded by Rev. Proc. 2011-38 2011-30 I.R.B. 2011-30 66
2008-32 Superseded by Rev. Proc. 2011-39 2011-30 I.R.B. 2011-30 68
2010-33 Superseded by Rev. Proc. 2011-50 2011-44 I.R.B. 2011-44 628
2010-39 Amplified, modified, and superseded by Rev. Proc. 2011-47 2011-42 I.R.B. 2011-42 520
2011-4 Modified by Rev. Proc. 2011-44 2011-39 I.R.B. 2011-39 446
2011-14 Modified by Rev. Proc. 2011-43 2011-37 I.R.B. 2011-37 326
2011-24 Obsoleted by Notice 2011-92 2011-48 I.R.B. 2011-48 809
58-225 Obsoleted by Rev. Rul. 2011-15 2011-30 I.R.B. 2011-30 57
76-345 Revoked by Rev. Rul. 2011-29 2011-49 I.R.B. 2011-49
92-19 Supplemented in part by Rev. Rul. 2011-23 2011-43 I.R.B. 2011-43 585
2007-28 Superseded by Rev. Rul. 2011-26 2011-48 I.R.B. 2011-48 803
2010-30 Supplemented and superseded by Rev. Rul. 2011-27 2011-48 I.R.B. 2011-48 805
9527 Corrected by Ann. 2011-49 2011-36 I.R.B. 2011-36 228
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superintendent of Documents when their subscriptions must be renewed.
The contents of this weekly Bulletin are consolidated semiannually into a permanent, indexed, Cumulative Bulletin. These are sold on a single copy basis and are not included as part of the subscription to the Internal Revenue Bulletin. Subscribers to the weekly Bulletin are notified when copies of the Cumulative Bulletin are available. Certain issues of Cumulative Bulletins are out of print and are not available. Persons desiring available Cumulative Bulletins, which are listed on the reverse, may purchase them from the Superintendent of Documents.
You may view the Internal Revenue Bulletin on the Internet at www.irs.gov. Select Businesses. Under Businesses Topics, select More Topics. Then select Internal Revenue Bulletins.
Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
Check the publications and/or subscription(s) desired on the reverse, complete the order blank, enclose the proper remittance, detach entire page, and mail to the
P.O. Box 979050, St. Louis, MO 63197-9000
Please allow two to six weeks, plus mailing time, for delivery.
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the
IRS Bulletin Unit, SE:W:CAR:MP:T:T:SP, Washington, DC 20224.
Page Last Reviewed or Updated: 23-Sep-2017
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CAPITOL HEIGHTS– Prince George's County in Maryland has taken delivery of a Custom Bomb Truck built by Rosenbauer. The truck is one of six delivered through a contract with the Metropolitan Washington Council of Governments (COG) for Bomb Squad Vehicles. The procurement process was handled by Arlington County, VA whose Fire Department will be recieving one of the units.


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Bodyandstrength.com Delhi-Date with Kaizzad Capadia
Why Mr. Capadia thinks that there is a need of holding knowledge and awareness disseminating conventions and bringing the fitness community together at one platform. Find out more in his candid conversation with bodyandstrength.com!
Bodyandstrength.com team met Mr. Kaizzad Capadia in Delhi who was here to preside upon one of his master-classes at K11 Academy on April 5, 2019. What followed was unexpected and intriguing conversation with the Indian fitness industry icon and academician. Mr. Capadia shared his view on the present scenario of competitions and bodybuilding events in the country.
He said that fitness is a bigger frame and bodybuilding perhaps is just a small percentage of the industry. He also stated with concern that bodybuilding is a sport which has changed its form over the period of time and new elements like 'physique' has been added to it. In one sense it gives opportunity to more fitness athletes who don't put on the bodybuilding bulk on whole of the body. On the flip side, a fitness athlete cannot be termed a 'fitness' athlete without assessment of the overall fitness of the body, we can't leave legs out of it.
Mr. Capadia appreciates the efforts of athletes in India and says that they can do a lot for the sport but only with right kind of scientific knowledge and approach towards their body which comes from an able trainer of course. He emphasized again that bodybuilding is not a career and in fact, cannot be termed as a profession at all. It is just a sport not only in India but abroad as well. Hence, bodybuilding athletes should not be blinded until and unless they know how to make a decent living out of this field. They must think that the sport demands lots of investment in terms of money, with no certainty of rewards. Even if they make it a hit on-stage, the success will be short-lived until they decide to carve out a meaningful long running career out of it by gaining right practical training and knowledge.
Bodyandstrength.com published a news article earlier this year with the title – 'An Eye-Opener: Is Competing a Career Goal?' Mr. Kaizzad Capadia's analysis and point of view resonates the crux of that article and we are glad that we got a chance to hear it from him.
Mr. Capadia said that there is a need of holding knowledge and awareness disseminating conventions and bringing the fitness community together at one platform. Only holding expos, will not promote the sport, also, it won't guide anyone towards a stable long term career. After giving more than half of your life to the fitness industry as an athlete, your term gets over, what would one do after that to sustain and what is the probability of his/her success even if one manages to start a career in the fitness industry as a trainer or entrepreneur. The right direction, evaluation and avenues according to one's capacity, has to be explored.
He was concerned that the quality of competitions is deteriorating because even the unprepared or half-prepared athletes are encouraged to compete on the stage just because he or she will be registering by giving money and will add to the crowd on the stage. This instead lowers the standard of any competition. Athletes are being misguided in this context. The competition should be such that it becomes difficult for the judges to select one and best of the best comes out as the winner. Also, the issue of fair judgment by able, experienced and well-educated judges is under scrutiny at most of the shows these days.
Mr. Capadia also raised his concern for the female athletes on the stage and shunned the idea of female bikini athletes standing on the stage with mediocre or sometimes no physique. He concluded that changes are always welcome but it should not pull down the standard to bring more profit, instead the bar should be raised along with the business of sports. It should benefit the competing athletes and must contribute to their holistic development. He also appreciated some of the competitive shows which are trying to keep up with the fair and just standards of the sport in India.
If more visionaries like Mr. Kaizzad Capadia spearhead the Indian fitness industry, a meaningful concrete direction can be given to all kinds of players, trainers and prospective entrepreneurs here. People like him not only are capable of doing their job deftly but also can speak their mind freely. The art of generating a stable career out of an uncertain independent sport like bodybuilding in fitness industry is mastered by him and it is high-time, we understand the logic before taking the action packed nose-dive in this sport!
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