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Filing An Amended Tax Return

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Filing An Amended Tax Return

Filing an amended tax return 3. Filing an amended tax return   Self-Employment Tax Table of Contents Topics - This chapter discusses: Useful Items - You may want to see: Who Must Pay Self-Employment Tax?Employed by a U. Filing an amended tax return S. Filing an amended tax return Church Effect of Exclusion Members of the Clergy Income From U. Filing an amended tax return S. Filing an amended tax return Possessions Exemption From Social Security and Medicare Taxes Topics - This chapter discusses: Who must pay self-employment tax, and Who is exempt from self-employment tax. Filing an amended tax return Useful Items - You may want to see: Publication 334 Tax Guide for Small Business 517 Social Security and Other Information for Members of the Clergy and Religious Workers Form (and Instructions) Form 1040-PR Planilla para la Declaración de la Contribución Federal sobre el Trabajo por Cuenta Propia Form 1040-SS U. Filing an amended tax return S. Filing an amended tax return Self-Employment Tax Return Form 4361 Application for Exemption From Self-Employment Tax for Use by Ministers, Members of Religious Orders and Christian Science Practitioners Schedule SE (Form 1040) Self-Employment Tax See chapter 7 for information about getting these publications and forms. Filing an amended tax return Who Must Pay Self-Employment Tax? If you are a self-employed U. Filing an amended tax return S. Filing an amended tax return citizen or resident, the rules for paying self-employment tax are generally the same whether you are living in the United States or abroad. Filing an amended tax return The self-employment tax is a social security and Medicare tax on net earnings from self- employment. Filing an amended tax return You must pay self-employment tax if your net earnings from self-employment are at least $400. Filing an amended tax return For 2013, the maximum amount of net earnings from self-employment that is subject to the social security portion of the tax is $113,700. Filing an amended tax return All net earnings are subject to the Medicare portion of the tax. Filing an amended tax return Employed by a U. Filing an amended tax return S. Filing an amended tax return Church If you were employed by a U. Filing an amended tax return S. Filing an amended tax return church or a qualified church-controlled organization that chose exemption from social security and Medicare taxes and you received wages of $108. Filing an amended tax return 28 or more from the organization, the amounts paid to you are subject to self-employment tax. Filing an amended tax return However, you can choose to be exempt from social security and Medicare taxes if you are a member of a recognized religious sect. Filing an amended tax return See Publication 517 for more information about church employees and self-employment tax. Filing an amended tax return Effect of Exclusion You must take all of your self-employment income into account in figuring your net earnings from self-employment, even income that is exempt from income tax because of the foreign earned income exclusion. Filing an amended tax return Example. Filing an amended tax return You are in business abroad as a consultant and qualify for the foreign earned income exclusion. Filing an amended tax return Your foreign earned income is $95,000, your business deductions total $27,000, and your net profit is $68,000. Filing an amended tax return You must pay self-employment tax on all of your net profit, including the amount you can exclude from income. Filing an amended tax return Members of the Clergy If you are a member of the clergy, you are treated as self-employed for self-employment tax purposes. Filing an amended tax return Your U. Filing an amended tax return S. Filing an amended tax return self-employment tax is based upon net earnings from self-employment figured without regard to the foreign earned income exclusion or the foreign housing exclusion. Filing an amended tax return You can receive exemption from coverage for your ministerial duties if you conscientiously oppose public insurance due to religious reasons or if you oppose it due to the religious principles of your denomination. Filing an amended tax return You must file Form 4361 to apply for this exemption. Filing an amended tax return This subject is discussed in further detail in Publication 517. Filing an amended tax return Income From U. Filing an amended tax return S. Filing an amended tax return Possessions If you are a U. Filing an amended tax return S. Filing an amended tax return citizen or resident alien and you own and operate a business in Puerto Rico, Guam, the Commonwealth of the Northern Mariana Islands, American Samoa, or the U. Filing an amended tax return S. Filing an amended tax return Virgin Islands, you must pay tax on your net earnings from self-employment (if they are $400 or more) from those sources. Filing an amended tax return You must pay the self-employment tax whether or not the income is exempt from U. Filing an amended tax return S. Filing an amended tax return income taxes (or whether or not you otherwise must file a U. Filing an amended tax return S. Filing an amended tax return income tax return). Filing an amended tax return Unless your situation is described below, attach Schedule SE (Form 1040) to your U. Filing an amended tax return S. Filing an amended tax return income tax return. Filing an amended tax return If you do not have to file Form 1040 with the United States and you are a resident of any of the U. Filing an amended tax return S. Filing an amended tax return possessions listed in the preceding paragraph, figure your self-employment tax on Form 1040-SS. Filing an amended tax return Residents of Puerto Rico may file the Spanish-language Formulario 1040-PR. Filing an amended tax return If you are not enclosing a check or money order, file your return with the: Department of the Treasury Internal Revenue Service Center Austin, TX 73301-0215 If you are enclosing a check or money order, file your return with the: Department of the Treasury P. Filing an amended tax return O. Filing an amended tax return Box 1303 Charlotte, NC 28201-1303 Exemption From Social Security and Medicare Taxes The United States may reach agreements with foreign countries to eliminate dual coverage and dual contributions (taxes) to social security systems for the same work. Filing an amended tax return See Bilateral Social Security (Totalization) Agreements in chapter 2 under Social Security and Medicare Taxes. Filing an amended tax return As a general rule, self-employed persons who are subject to dual taxation will only be covered by the social security system of the country where they reside. Filing an amended tax return For more information on how any specific agreement affects self-employed persons, contact the United States Social Security Administration, as discussed under Bilateral Social Security (Totalization) Agreements in chapter 2. Filing an amended tax return If your self-employment earnings should be exempt from foreign social security tax and subject only to U. Filing an amended tax return S. Filing an amended tax return self-employment tax, you should request a certificate of coverage from the U. Filing an amended tax return S. Filing an amended tax return Social Security Administration, Office of International Programs. Filing an amended tax return The certificate will establish your exemption from the foreign social security tax. Filing an amended tax return Send the request to the: Social Security Administration Office of International Programs P. Filing an amended tax return O. Filing an amended tax return Box 17741 Baltimore, MD 21235-7741 Prev  Up  Next   Home   More Online Publications

Compliance & Enforcement Topics

 

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Whistleblower - Informant Award

The IRS Whistleblower Office pays money to people who blow the whistle on persons who fail to pay the tax that they owe. If the IRS uses information provided by the whistleblower, it can award the whistleblower up to 30 percent of the additional tax, penalty and other amounts it collects.

 


Fiscal 2014 Sequester Notice from Whistleblower Office dated October 1, 2013:  Impact on whistleblower payments.

Fiscal 2013 Sequester Notice from Whistleblower Office dated March 1, 2013: Impact on whistleblower payments.

Treasury proposed regulations to implement 26 USC 7623, as amended, on December 18, 2012. The public comment period has officially closed and the comments received are under evaluation. The IRS often receives comments on proposed regulations after the official comment period has closed and may consider late submissions in preparing final regulations. 

 


The Whistleblower Office has developed new rules that became effective August 1, 2012. We are providing the three Interim Guidance memoranda below. 


Deputy Commissioner for Services and Enforcement Memorandum dated June 20, 2012

 


Who can get an award?

The IRS may pay awards to people who provide specific and credible information to the IRS if the information results in the collection of taxes, penalties, interest or other amounts from the noncompliant taxpayer.

The IRS is looking for solid information, not an “educated guess” or unsupported speculation. We are also looking for a significant Federal tax issue - this is not a program for resolving personal problems or disputes about a business relationship.

What are the rules for getting an award?

The law provides for two types of awards. If the taxes, penalties, interest and other amounts in dispute exceed $2 million, and a few other qualifications are met, the IRS will pay 15 percent to 30 percent of the amount collected. If the case deals with an individual, his or her annual gross income must be more than $200,000. If the whistleblower disagrees with the outcome of the claim, he or she can appeal to the Tax Court. These rules are found at Internal Revenue Code IRC Section 7623(b) - Whistleblower Rules.

The IRS also has an award program for other whistleblowers - generally those who do not meet the dollar thresholds of $2 million in dispute or cases involving individual taxpayers with gross income of less that $200,000. The awards through this program are less, with a maximum award of 15 percent up to $10 million. In addition, the awards are discretionary and the informant cannot dispute the outcome of the claim in Tax Court. The rules for these cases are found at Internal Revenue Code IRC Section 7623(a) - Informant Claims Program, and some of the rules are different from those that apply to cases involving more than $2 million.

If you decide to submit information and seek an award for doing so, use IRS Form 211. The same form is used for both award programs.

More Information

What Happens to a Claim for an Informant Award (Whistleblower)
Procedures used and the criteria followed to identify and process informant cases

Whistleblower Law
A brief synopsis of what the new whistleblower law entails. This is the most significant change to the Services’ approach to informant awards in 140 years

How Do You File a Whistleblower Award Claim
Step by step procedures to follow to file an informant claim for award

Confidentiality and Disclosure for Whistleblowers
The rules governing confidentiality of informant information

IRC Section 7623(b) - Whistleblower Rules
The requirements of the new rules enacted in IRC Section 7623(b), the Whistleblower Program

IRC Section 7623(a) - Informant Claims Program
The requirement of the rules governing claims that do not meet the requirements of the provisions in the whistleblower program under IRC Section 7623(b). These claims are part of the Informant Claims Program

IRS Form 211
Application for Award for Original Information

News Release IR-2007-201
Procedure Unveiled for Reporting Violations of the Tax Law, Making Reward Claims

Notice 2008-4 Guidance to the public on how to file claims
Claims Submitted to the IRS Whistleblower Office under Section 7623

History of the Whistleblower/Informant Program
Historical information on the evolution of the concept of paying for leads from its inception up to the current law followed today

Realignment of Informant Claims Examination Unit into Whistleblower Office
The Informant Claims Examination Unit in Ogden, Utah has been realigned with the Whistleblower Office. Their new name is Whistleblower Office - Ogden.

Information and Whistleblower Awards

  • IRM 25.2.1, Receiving Information — This chapter provides procedures and guidance for all Service personnel to follow when receiving information dealing with whistleblowers’ claims for award.
  • IRM 25.2.2, Whistleblower Awards — This chapter provides procedures and guidance for all Service personnel to follow when dealing with payment of whistleblowers’ claims for award.

Whistleblower Office At-a-Glance
 

Annual Reports

Reporting other information to the IRS

If you have information about tax noncompliance but are not interested in an award, or you have other information you believe may be of interest to the IRS:

  • For information on how to Report Suspected Tax Fraud Activity, if you have information about an individual or company you suspect is not complying with the tax law, and you do not want to seek an award . You can remain anonymous
Page Last Reviewed or Updated: 30-Sep-2013

The Filing An Amended Tax Return

Filing an amended tax return Internal Revenue Bulletin:  2009-36  September 8, 2009  Rev. Filing an amended tax return Proc. Filing an amended tax return 2009-37 Table of Contents SECTION 1. Filing an amended tax return PURPOSE SECTION 2. Filing an amended tax return BACKGROUND SECTION 3. Filing an amended tax return SCOPE SECTION 4. Filing an amended tax return ELECTION PROCEDURES SECTION 5. Filing an amended tax return REQUIRED INFORMATION STATEMENT SECTION 6. Filing an amended tax return EFFECTIVE DATE SECTION 7. Filing an amended tax return TRANSITION RULE SECTION 8. Filing an amended tax return PAPERWORK REDUCTION ACT DRAFTING INFORMATION SECTION 1. Filing an amended tax return PURPOSE . Filing an amended tax return 01 This revenue procedure provides the exclusive procedures for taxpayers to make an election to defer recognizing discharge of indebtedness income (“COD income”) under § 108(i) of the Internal Revenue Code. Filing an amended tax return . Filing an amended tax return 02 This revenue procedure also requires taxpayers making the § 108(i) election to provide additional information on returns beginning with the taxable year following the taxable year for which the taxpayer makes the election. Filing an amended tax return This revenue procedure describes the time and manner of providing this additional information. Filing an amended tax return . Filing an amended tax return 03 The Internal Revenue Service and Treasury Department intend to issue additional guidance under § 108(i) that may include regulations addressing matters in this revenue procedure. Filing an amended tax return Taxpayers should be aware that these regulations may be retroactive. Filing an amended tax return See § 7805(b)(2). Filing an amended tax return This revenue procedure may be modified to provide procedures consistent with additional guidance. Filing an amended tax return SECTION 2. Filing an amended tax return BACKGROUND . Filing an amended tax return 01 Section 108(i), Generally. Filing an amended tax return Section 108(i) was added to the Code by § 1231 of the American Recovery and Reinvestment Tax Act of 2009, Pub. Filing an amended tax return L. Filing an amended tax return No. Filing an amended tax return 111-5, 123 Stat. Filing an amended tax return 338. Filing an amended tax return In general, § 108(i) provides that, at the election of a taxpayer, COD income realized in connection with a reacquisition after December 31, 2008, and before January 1, 2011, of an applicable debt instrument is includible in gross income ratably over a 5-taxable-year inclusion period, beginning with the taxpayer’s fourth or fifth taxable year following the taxable year of the reacquisition. Filing an amended tax return Generally, if a taxpayer makes a § 108(i) election and reacquires (or is treated as reacquiring) the applicable debt instrument generating the COD income for a new debt instrument with original issue discount (“OID”), then interest deductions for this OID also are deferred, as provided in § 108(i)(2). Filing an amended tax return The OID deferral rule, however, does not apply if the amount of OID is less than a de minimis amount, as determined under § 1273(a)(3) and § 1. Filing an amended tax return 1273-1(d) of the Income Tax Regulations. Filing an amended tax return The OID deferral rule in § 108(i)(2) applies at the entity level for a pass-through entity. Filing an amended tax return For example, a partnership (and therefore its partners) may not deduct currently the OID described in § 108(i)(2)(A)(i). Filing an amended tax return A taxpayer must take into account any item of income or deduction deferred under § 108(i), and not previously taken into account, in the taxable year in which certain events occur (such as the liquidation of the taxpayer and upon other events specified in administrative guidance). Filing an amended tax return See § 108(i)(5)(D). Filing an amended tax return The rule regarding acceleration of deferred COD income and OID deductions also applies in the case of certain dispositions by persons holding ownership interests in pass-through entities. Filing an amended tax return Section 108(i)(5)(D)(ii). Filing an amended tax return For purposes of § 108(i), regulated investment companies (as defined in § 851(a)) and real estate investment trusts (as defined in § 856(a)) are not pass-through entities. Filing an amended tax return . Filing an amended tax return 02 Applicable Debt Instrument. Filing an amended tax return Section 108(i)(3)(A) defines the term “applicable debt instrument” to mean any debt instrument issued by a C corporation or by any other person in connection with the conduct of a trade or business by that person. Filing an amended tax return The term “debt instrument” means any bond, debenture, note, certificate, or any other instrument or contractual arrangement constituting indebtedness within the meaning of § 1275(a)(1). Filing an amended tax return Section 108(i)(3)(B). Filing an amended tax return For purposes of § 108(i), in the case of an intercompany obligation (as defined in § 1. Filing an amended tax return 1502-13(g)(2)(ii)), an applicable debt instrument includes only an instrument for which COD income is realized upon the instrument’s deemed satisfaction under § 1. Filing an amended tax return 1502-13(g)(5). Filing an amended tax return . Filing an amended tax return 03 Reacquisition. Filing an amended tax return Section 108(i)(4)(A) defines the term “reacquisition” to mean, with respect to any applicable debt instrument, any acquisition of the debt instrument by the debtor that issued (or is otherwise the obligor under) the debt instrument, or a person related to the debtor under § 108(e)(4). Filing an amended tax return The term “acquisition” includes an acquisition of the debt instrument for cash or other property, the exchange of the debt instrument for another debt instrument (including an exchange resulting from a modification of the debt instrument), the exchange of the debt instrument for corporate stock or a partnership interest, the contribution of the debt instrument to capital, and the complete forgiveness of the indebtedness by the holder of the debt instrument. Filing an amended tax return See § 108(i)(4)(B). Filing an amended tax return The term “acquisition” also includes an indirect acquisition within the meaning of § 1. Filing an amended tax return 108-2(c) if a direct acquisition of the debt instrument would qualify for an election under § 108(i). Filing an amended tax return For example, if a corporation acquires debt of a partnership that the partnership issued in connection with its trade or business, and the partnership and corporation become related within six months of the corporation’s acquisition of the debt, the indirect acquisition is an acquisition for which an election under § 108(i) may be made. Filing an amended tax return . Filing an amended tax return 04 General Requirements for the Section 108(i) Election. Filing an amended tax return Section 108(i)(5)(B) provides, in general, that a taxpayer makes the § 108(i) election by including a statement that clearly identifies the applicable debt instrument with the return of tax imposed for the taxable year in which the reacquisition of the instrument occurs. Filing an amended tax return (For purposes of this revenue procedure, a return of tax or income tax return includes an information return, and a taxpayer includes a person that files an information return. Filing an amended tax return ) The statement must include the amount of income to which § 108(i)(1) applies and other information the Service may prescribe. Filing an amended tax return Once made, a § 108(i) election is irrevocable and, except as provided in section 7 of this revenue procedure, may not be modified. Filing an amended tax return . Filing an amended tax return 05 Section 108(i) Elections Made by Pass-through Entities. Filing an amended tax return In the case of COD income realized by a pass-through entity from the reacquisition of an applicable debt instrument, the pass-through entity makes the § 108(i) election. Filing an amended tax return Section 108(i)(5)(B)(iii). Filing an amended tax return . Filing an amended tax return 06 Additional Information on Subsequent Years’ Returns. Filing an amended tax return Section 108(i)(7) authorizes the Service to issue guidance necessary or appropriate for applying § 108(i), including requiring reporting the election and other information on returns of tax for subsequent taxable years. Filing an amended tax return . Filing an amended tax return 07 Exclusivity. Filing an amended tax return Section 108(i)(5)(C) provides that if a taxpayer elects to apply § 108(i) to an applicable debt instrument, § 108(a)(1)(A), (B), (C), and (D) do not apply to COD income deferred under § 108(i). Filing an amended tax return . Filing an amended tax return 08 Allocation of Deferred COD Income on Partnership Indebtedness. Filing an amended tax return Section 4. Filing an amended tax return 04(3) of this revenue procedure describes how a partnership may elect under § 108(i) to defer a portion of the COD income realized from the reacquisition of an applicable debt instrument. Filing an amended tax return If a partnership elects to defer all or any portion of COD income realized from the reacquisition of an applicable debt instrument, all of the COD income with respect to that debt instrument, without regard to § 108(i), is allocated to the partners in the partnership immediately before the reacquisition in the manner in which the income would be included in the distributive shares of these partners under § 704 and the regulations thereunder, including § 1. Filing an amended tax return 704-1(b)(2)(iii). Filing an amended tax return Each partner’s share of this COD income is the partner’s COD income amount (“COD income amount”). Filing an amended tax return The partner’s COD income amount that is deferred under § 108(i) is the partner’s deferred amount (“deferred amount”). Filing an amended tax return The partner’s COD income amount that is not deferred and is included in the partner’s distributive share of partnership income for the taxable year of the partnership in which the reacquisition occurs is the partner’s included amount (“included amount”). Filing an amended tax return . Filing an amended tax return 09 Partner’s Deferred § 752 Amount. Filing an amended tax return A decrease in a partner’s share of a partnership liability resulting from the reacquisition of an applicable debt instrument that is not treated as a current distribution of money to the partner under § 752 by reason of § 108(i)(6) is the partner’s deferred § 752 amount (“deferred § 752 amount”). Filing an amended tax return A partner’s deferred § 752 amount may not exceed the lesser of (i) the partner’s deferred amount or (ii) gain that the partner would recognize in the year of reacquisition under § 731 as a result of the reacquisition absent § 108(i)(6). Filing an amended tax return To determine the amount of gain the partner would recognize under clause (ii) of the preceding sentence, the amount of any deemed distribution of money under § 752(b) resulting from the decrease in the partner’s share of a reacquired applicable debt instrument that is treated as an advance or draw of money under § 1. Filing an amended tax return 731-1(a)(1)(ii) is determined as if no COD income resulting from the reacquisition of the applicable debt instrument is deferred under § 108(i). Filing an amended tax return See Rev. Filing an amended tax return Rul. Filing an amended tax return 92-97, 1992-2 C. Filing an amended tax return B. Filing an amended tax return 124, and Rev. Filing an amended tax return Rul. Filing an amended tax return 94-4, 1994-1 C. Filing an amended tax return B. Filing an amended tax return 195. Filing an amended tax return A partner’s deferred § 752 amount is treated as a distribution of money to the partner under § 752 at the same time, and to the extent remaining in the same amount, as the partner recognizes the COD income deferred under § 108(i). Filing an amended tax return . Filing an amended tax return 10 Allocation of Deferred COD Income on S Corporation Indebtedness. Filing an amended tax return For purposes of § 108(i), an S corporation’s COD income deferred under § 108(i) is shared pro rata only among those shareholders that are shareholders of the S corporation immediately before the reacquisition transaction. Filing an amended tax return . Filing an amended tax return 11 Deferred COD Income, Earnings and Profits, and Alternative Minimum Taxable Income. Filing an amended tax return (1) In general. Filing an amended tax return The Service and Treasury Department intend to issue regulations regarding the computation of a corporation’s earnings and profits with respect to COD income and OID deductions that are deferred under § 108(i). Filing an amended tax return These regulations generally will provide that deferred COD income increases earnings and profits in the taxable year that it is realized and not in the taxable year or years that the deferred COD income is includible in gross income. Filing an amended tax return OID deductions deferred under § 108(i) generally will decrease earnings and profits in the taxable year or years in which the deduction would be allowed without regard to § 108(i). Filing an amended tax return COD income and OID deductions that are deferred increase or decrease adjusted current earnings under § 56(g)(4) in the taxable year or years that the income or deduction is includible or deductible in determining taxable income. Filing an amended tax return See § 1. Filing an amended tax return 56(g)-1(c)(1). Filing an amended tax return (2) Exceptions for certain special status corporations. Filing an amended tax return The Service and Treasury Department intend to issue regulations providing that in the case of regulated investment companies and real estate investment trusts, COD income deferred under § 108(i) generally increases earnings and profits in the taxable year or years in which the deferred COD income is includible in gross income and not in the year that the deferred COD income is realized. Filing an amended tax return OID deductions deferred under § 108(i) generally decrease earnings and profits in the taxable year or years that the deferred OID deductions are deductible. Filing an amended tax return . Filing an amended tax return 12 Extension of Time to Make Election. Filing an amended tax return Under § 301. Filing an amended tax return 9100-1 of the Procedure and Administration Regulations, the Service may grant an extension of time to make a regulatory election. Filing an amended tax return An election is a regulatory election if the due date is prescribed by regulation or other published guidance of general applicability. Filing an amended tax return Section 301. Filing an amended tax return 9100-2(a) provides an automatic 12-month extension from the due date for making certain regulatory elections. Filing an amended tax return SECTION 3. Filing an amended tax return SCOPE This revenue procedure applies to taxpayers that realize COD income from a reacquisition after December 31, 2008, and before January 1, 2011, of an applicable debt instrument, as provided in § 108(i). Filing an amended tax return SECTION 4. Filing an amended tax return ELECTION PROCEDURES . Filing an amended tax return 01 In General. Filing an amended tax return (1) A taxpayer within the scope of this revenue procedure makes the § 108(i) election by— (a) Attaching a statement meeting the requirements of section 4. Filing an amended tax return 05 of this revenue procedure to the taxpayer’s timely filed (including extensions) original federal income tax return for the taxable year in which the reacquisition of the applicable debt instrument occurs, and (b) If applicable, satisfying the additional requirements of section 4. Filing an amended tax return 07, 4. Filing an amended tax return 08, 4. Filing an amended tax return 09, or 4. Filing an amended tax return 10 of this revenue procedure. Filing an amended tax return (2) The Service grants an automatic extension of 12 months from the due date prescribed in section 4. Filing an amended tax return 01(1)(a) of this revenue procedure for making the § 108(i) election. Filing an amended tax return The rules that apply to an automatic extension under § 301. Filing an amended tax return 9100-2(a) apply to this automatic extension. Filing an amended tax return . Filing an amended tax return 02 Section 108(i) Elections Made by Members of Consolidated Groups. Filing an amended tax return The common parent of a consolidated group makes the § 108(i) election on behalf of all members of the group. Filing an amended tax return See § 1. Filing an amended tax return 1502-77(a). Filing an amended tax return . Filing an amended tax return 03 Aggregation Rule. Filing an amended tax return A taxpayer within the scope of this revenue procedure may treat two or more applicable debt instruments that are part of the same issue and that are reacquired during the same taxable year as one applicable debt instrument for purposes of this revenue procedure. Filing an amended tax return A pass-through entity may not treat two or more applicable debt instruments as one applicable debt instrument under this section 4. Filing an amended tax return 03 if the owners and their ownership interests in the pass-through entity immediately prior to the reacquisition of each applicable debt instrument are not identical. Filing an amended tax return . Filing an amended tax return 04 Partial Elections. Filing an amended tax return (1) A taxpayer within the scope of this revenue procedure may make an election for any portion of COD income realized from the reacquisition of any applicable debt instrument. Filing an amended tax return Thus, for example, if a taxpayer realizes $100 of COD income from the reacquisition of an applicable debt instrument, the taxpayer may elect under § 108(i)(1) to defer only $40 of the $100 of COD income. Filing an amended tax return The taxpayer may exclude from income the portion of COD income that the taxpayer does not elect to defer under § 108(i) ($60 in this example) under § 108(a)(1)(A), (B), (C), or (D), if applicable. Filing an amended tax return (2) A taxpayer is not required to make an election for the same portion of COD income arising from each applicable debt instrument that it reacquires, but may make an election for different portions of COD income arising from different applicable debt instruments (whether or not part of the same issue). Filing an amended tax return Thus, for example, if a taxpayer realizes $100 of COD income from the reacquisition of an applicable debt instrument (Instrument A) and $100 of COD income from the reacquisition of a different applicable debt instrument (Instrument B), the taxpayer may elect to defer all or a portion of the COD income associated with Instrument A and none or a different portion of the COD income associated with Instrument B. Filing an amended tax return (3) A partnership that elects to defer less than all of the COD income realized from the reacquisition of an applicable debt instrument may determine, in any manner, the portion, if any, of a partner’s COD income amount that is the partner’s deferred amount and the portion, if any, of a partner’s COD income amount that is the partner’s included amount. Filing an amended tax return Thus, for example, one partner’s deferred amount may be zero while another partner’s deferred amount may equal that partner’s COD income amount (or any portion thereof). Filing an amended tax return A partner may exclude from income the partner’s included amount under § 108(a)(1)(A), (B), (C), or (D), if applicable. Filing an amended tax return The provisions of this section 4. Filing an amended tax return 04(3) apply for purposes of § 108(i) only and are not intended as an interpretation of or a change to existing law under § 704. Filing an amended tax return . Filing an amended tax return 05 Contents of Election Statement. Filing an amended tax return A statement meets the requirements of this section 4. Filing an amended tax return 05 if the statement— (1) Label. Filing an amended tax return States “Section 108(i) Election” across the top. Filing an amended tax return (2) Required information. Filing an amended tax return Provides, for each applicable debt instrument the reacquisition of which generates COD income that the taxpayer is electing to defer under § 108(i)— (a) The name and taxpayer identification numbers, if any, of the issuer or issuers of the applicable debt instrument; (b) A general description of the applicable debt instrument (including the issue and maturity dates) and, in the case of any person other than a C corporation, a general description of the person’s trade or business to which the applicable debt instrument is connected; (c) A general description of the reacquisition transaction or transactions generating the COD income (including the date(s) of the transaction(s)); (d) The total amount of COD income for the applicable debt instrument that results from the reacquisition (in the case of a partnership, the aggregate of the partners’ COD income amounts) and a general description of the manner in which this amount is calculated; (e) The amount of COD income for the applicable debt instrument that the taxpayer is electing to defer under § 108(i); (f) In the case of a partnership, a list of partners that have a deferred amount, their identifying information and each partner’s deferred amount; and in the case of an S corporation, a list of shareholders with COD income deferred under § 108(i), their identifying information and each shareholder’s share of the S corporation’s deferred COD income; and (g) In cases in which a new debt instrument is issued or deemed issued in exchange for the applicable debt instrument (including exchanges under § 108(e)(4), § 108(i)(2)(B), and § 1. Filing an amended tax return 1001-3), the issuer’s name, the issuer’s taxpayer identification number, if any, a general description of the new debt instrument and whether the new debt instrument has OID, and if the new debt instrument has OID, a schedule of the OID that the issuer expects to accrue each taxable year on the instrument and the amount of OID that the issuer expects to defer under § 108(i)(2) each taxable year. Filing an amended tax return . Filing an amended tax return 06 Supplemental information. Filing an amended tax return The statement described in section 4. Filing an amended tax return 05 of this revenue procedure may specify for each applicable debt instrument an amount greater than the amount identified in section 4. Filing an amended tax return 05(2)(e) of this revenue procedure that the taxpayer elects to defer under § 108(i) in the event the Service subsequently concludes that the taxpayer understated the amount of COD income described in section 4. Filing an amended tax return 05(2)(d) of this revenue procedure. Filing an amended tax return This additional amount of COD income the taxpayer elects to defer may be described as the entire additional COD income, or as a percentage of any additional COD income. Filing an amended tax return If the taxpayer is a partnership, the partnership must specify each partner’s share of the partnership’s additional COD income that would be deferred (the partner’s additional deferred amount), which the partnership may describe for each partner as the partner’s entire share of the partnership’s additional COD income or as a percentage of the partner’s share of the partnership’s additional COD income. Filing an amended tax return If the taxpayer is an S corporation, the S corporation must specify each shareholder’s share of the S corporation’s additional COD income that would be deferred, which the S corporation may describe for each shareholder as the shareholder’s entire share of the S corporation’s additional COD income or as a percentage of the shareholder’s share of the S corporation’s additional COD income. Filing an amended tax return In the case of partnerships and S corporations, the additional COD income and the portion of additional COD income that would be deferred are allocated or determined as provided in sections 2. Filing an amended tax return 08, 2. Filing an amended tax return 10 and, if applicable, 4. Filing an amended tax return 04(3) of this revenue procedure, respectively, as if the additional COD income was realized. Filing an amended tax return . Filing an amended tax return 07 Additional Requirements for Certain Partnerships Making a § 108(i) Election. Filing an amended tax return The rules of this section 4. Filing an amended tax return 07 apply to partnerships other than partnerships described in section 4. Filing an amended tax return 10 of this revenue procedure. Filing an amended tax return (1) Information filing on Schedule K-1 (Form 1065 and Form 1065-B). Filing an amended tax return For the taxable year in which the § 108(i) election is made, the partnership must report on the Schedule K-1 (Form 1065 or Form 1065-B), Partner’s Share of Income, Deductions, Credits, etc. Filing an amended tax return , in the manner specified in the instructions to the forms, for each partner § 108(i) information on an aggregate basis for all applicable debt instruments for which a § 108(i) election is made. Filing an amended tax return Partnerships reporting § 108(i) information on the 2008 Schedule K-1 (Form 1065 or Form 1065-B) must report for each partner on an aggregate basis for all applicable debt instruments for which a § 108(i) election is made: (a) The partner’s deferred amount that the partner must include in income in the current taxable year under § 108(i)(1) or § 108(i)(5)(D)(i) or (ii), in box 11 (“other income”) using code F for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B); (b) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(2)(A)(ii) or § 108(i)(5)(D)(i) or (ii), in box 13 (“other deductions”) using code W for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B); (c) The partner’s deferred amount that has not been included in income in the current or prior taxable years, in box 20 (“other information”) using code X for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B); (d) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that has not been deducted in the current or prior taxable years, in box 20 (“other information”) using code X for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B); (e) The partner’s deferred § 752 amount that is treated as a distribution of money to the partner under § 752 in the current taxable year, in box 20 (“other information”) using code X for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B); and (f) The partner’s deferred § 752 amount remaining as of the end of the current taxable year, in box 20 (“other information”) using code X for Schedule K-1 (Form 1065) or in box 9 (“other”) using code U for Schedule K-1 (Form 1065-B). Filing an amended tax return (2) Election information statement provided to partners. Filing an amended tax return The partnership must attach to the Schedule K-1 (Form 1065 or Form 1065-B) provided to each partner for the taxable year in which the § 108(i) election is made a statement satisfying the requirements of this section 4. Filing an amended tax return 07(2). Filing an amended tax return The partnership should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain these statements, and each partner must retain that partner’s statement, in their respective books and records. Filing an amended tax return A statement meets the requirements of this section 4. Filing an amended tax return 07(2) if the statement— (a) Label. Filing an amended tax return States “Section 108(i) Election Information Statement for Partners” across the top. Filing an amended tax return (b) Required information. Filing an amended tax return Clearly identifies for each applicable debt instrument to which an election under § 108(i) applies— (i) The partner’s COD income amount, the partner’s deferred amount, and the partner’s included amount; (ii) The partner’s deferred amount that the partner must include in income in the current taxable year under § 108(i)(5)(D)(i) or (ii); (iii) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) in the current taxable year; (iv) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(5)(D)(i) or (ii); (v) The partner’s share of each liability of the partnership described in section 4. Filing an amended tax return 05(2)(g) of this revenue procedure; (vi) The partner’s share of the decrease in the partnership liability that results from the reacquisition of the applicable debt instrument; (vii) The partner’s share of the decrease in the partnership liability that results from the reacquisition of the applicable debt instrument that is treated as a distribution of money to the partner under § 752 in the current taxable year; (viii) The partner’s deferred § 752 amount as described in section 2. Filing an amended tax return 09 of this revenue procedure; (ix) The partner’s additional deferred amount as described in section 4. Filing an amended tax return 06 of this revenue procedure; and (x) The date of the reacquisition transaction generating the COD income. Filing an amended tax return (c) If a partner fails to provide the written statement required by section 4. Filing an amended tax return 07(3) of this revenue procedure, the partnership must indicate that the amounts described in section 4. Filing an amended tax return 07(2)(b)(vii) and (viii) of this revenue procedure cannot be calculated because the partner did not provide the information necessary to report these amounts. Filing an amended tax return (3) Partner reporting requirements. Filing an amended tax return The partnership must make reasonable efforts prior to making a § 108(i) election to secure from each partner with a deferred amount for which it does not have the information necessary to compute the partner’s basis in its partnership interest (and its deferred § 752 amount as described in section 2. Filing an amended tax return 09 of this revenue procedure) a written statement signed under penalties of perjury that includes this information. Filing an amended tax return Each partner with a deferred amount must provide this written statement to the partnership within 30 days of the date of request by the partnership. Filing an amended tax return A partner’s failure to comply with this reporting requirement does not invalidate the partnership’s election under § 108(i) for an applicable debt instrument only if the partnership makes reasonable efforts before making the § 108(i) election to obtain the written statement from the partner and otherwise complies with the requirements of section 4 of this revenue procedure. Filing an amended tax return If a partner provides its written statement under this section 4. Filing an amended tax return 07(3) after the partnership has provided to the partner the Section 108(i) Election Information Statement for Partners, the partnership must provide to the partner a revised Section 108(i) Election Information Statement for Partners reporting the information required under section 4. Filing an amended tax return 07(2)(b)(vii) and (viii) of this revenue procedure and report the partner’s deferred § 752 amount on the partner’s Schedule K-1 (Form 1065 or Form 1065-B) in subsequent taxable years. Filing an amended tax return . Filing an amended tax return 08 Additional Requirements for an S Corporation Making a § 108(i) Election. Filing an amended tax return (1) Information filing on Schedule K-1 (Form 1120S). Filing an amended tax return For the taxable year in which the § 108(i) election is made, the S corporation must report on the Schedule K-1 (Form 1120S), Shareholder’s Share of Income, Deductions, Credits, etc. Filing an amended tax return , in the manner specified in the instructions to the forms, for each shareholder § 108(i) information on an aggregate basis for all applicable debt instruments for which a § 108(i) election is made. Filing an amended tax return S corporations reporting § 108(i) information on the 2008 Schedule K-1 (Form 1120S) must report for each shareholder, on an aggregate basis for all applicable debt instruments for which a § 108(i) election is made, the shareholder’s share of the S corporation’s: (a) COD income deferred under § 108(i) that the shareholder must include in income in the current taxable year under § 108(i)(1) or § 108(i)(5)(D)(i) or (ii), in box 10 (“other income”) using code E; (b) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(2)(A)(ii), or § 108(i)(5)(D)(i) or (ii), in box 12 (“other deductions”) using code S; (c) COD income deferred under § 108(i) that has not been included in income in the current or prior taxable years, in box 17 (“other information”) using code T; and (d) OID deduction deferred under § 108(i)(2)(A)(i) that has not been deducted in the current or prior taxable years, in box 17 (“other information”) using code T. Filing an amended tax return (2) Election information statement provided to shareholders. Filing an amended tax return The S corporation must attach to the Schedule K-1 (Form 1120S) provided to each shareholder for the taxable year in which the § 108(i) election is made, a statement satisfying the requirements of this section 4. Filing an amended tax return 08(2). Filing an amended tax return The S corporation should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain these statements, and each shareholder must retain that shareholder’s statement, in their respective books and records. Filing an amended tax return A statement meets the requirements of this section 4. Filing an amended tax return 08(2) if the statement— (a) Label. Filing an amended tax return States “Section 108(i) Election Information Statement for Shareholders” across the top. Filing an amended tax return (b) Required information. Filing an amended tax return Clearly identifies for each applicable debt instrument to which an election under § 108(i) applies, the shareholder’s share of the S corporation’s— (i) COD income that the S corporation elects to defer under § 108(i); (ii) COD income deferred under § 108(i) that the shareholder must include in income in the current taxable year under § 108(i)(5)(D)(i) or (ii); (iii) OID deduction deferred under § 108(i)(2)(A)(i) in the current taxable year; (iv) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(5)(D)(i) or (ii); and (v) Additional COD income that would be deferred as described in section 4. Filing an amended tax return 06 of this revenue procedure. Filing an amended tax return . Filing an amended tax return 09 Section 108(i) Elections Made on Behalf of Certain Foreign Corporations. Filing an amended tax return The controlling domestic shareholder(s) (or common parent of the controlling domestic shareholder(s), if applicable) of a controlled foreign corporation or a noncontrolled § 902 corporation not otherwise required to file a return of tax may make the § 108(i) election on behalf of the foreign corporation by satisfying the requirements of § 1. Filing an amended tax return 964-1(c)(3). Filing an amended tax return Each controlling domestic shareholder must attach a statement identifying the foreign corporation and satisfying the requirements of section 4. Filing an amended tax return 05 of this revenue procedure and, if applicable, section 4. Filing an amended tax return 06 of this revenue procedure, to its federal income tax return for the taxable year ending within or with the taxable year of the foreign corporation for which the § 108(i) election is made. Filing an amended tax return . Filing an amended tax return 10 Section 108(i) Elections Made By Certain Foreign Partnerships. Filing an amended tax return The rules of this section 4. Filing an amended tax return 10 apply to a foreign partnership making a § 108(i) election that is not otherwise required to file a federal partnership return (“nonfiling foreign partnership”). Filing an amended tax return See § 1. Filing an amended tax return 6031(a)-1(b). Filing an amended tax return (1) A nonfiling foreign partnership making the election must attach a statement satisfying the requirements of section 4. Filing an amended tax return 05 of this revenue procedure and, if applicable, section 4. Filing an amended tax return 06 of this revenue procedure, to a partnership return satisfying the requirements of § 1. Filing an amended tax return 6031(a)-1(b)(5) it files with the Service. Filing an amended tax return In addition, a nonfiling foreign partnership must include in the information required in section 4. Filing an amended tax return 05(2)(d) and (e) of this revenue procedure the aggregate amounts for all partners as well as the aggregate amounts for all U. Filing an amended tax return S. Filing an amended tax return persons (as defined in § 7701(a)(30)) and controlled foreign corporation(s) that are partners with deferred amounts in the nonfiling foreign partnership (“affected partners”). Filing an amended tax return (2) The nonfiling foreign partnership must make the election, in accordance with § 1. Filing an amended tax return 6031(a)-1(b)(5), by the date provided in section 4. Filing an amended tax return 01(1)(a) of this revenue procedure, as if it had a filing obligation for the taxable year in which the reacquisition of the applicable debt instrument occurs. Filing an amended tax return (3) For each affected partner, the partnership must file with the Service a Schedule K-1 (Form 1065) and report on the Schedule K-1 (Form 1065) for the affected partner as provided in section 4. Filing an amended tax return 07(1) of this revenue procedure. Filing an amended tax return Except for this § 108(i) information, the partnership need not complete Part III of the Schedule K-1 (Form 1065). Filing an amended tax return The partnership must provide a copy of the respective Schedule K-1 (Form 1065) to each affected partner and must also attach to the Schedule K-1 (Form 1065) provided to each affected partner a statement satisfying the requirements of section 4. Filing an amended tax return 07(2) of this revenue procedure by the date provided in section 4. Filing an amended tax return 01(1)(a) of this revenue procedure. Filing an amended tax return The partnership should not attach any statement described in section 4. Filing an amended tax return 07(2) of this revenue procedure to the Schedules K-1 that are filed with the Service. Filing an amended tax return However, the partnership must retain the statements provided to the affected partners, and each affected partner must retain that partner’s statement, in their respective books and records. Filing an amended tax return (4) The partnership and each affected partner must satisfy the requirements of section 4. Filing an amended tax return 07(3) of this revenue procedure. Filing an amended tax return . Filing an amended tax return 11 Protective § 108(i) Election. Filing an amended tax return (1) In general. Filing an amended tax return A taxpayer may make a protective election under § 108(i) for an applicable debt instrument if the taxpayer concludes that a particular transaction does not result in the realization of COD income, reports the transaction on its federal income tax return in a manner consistent with the taxpayer’s conclusion, and would be within the scope of this revenue procedure if the taxpayer’s conclusion were incorrect. Filing an amended tax return If the Service at any time determines the taxpayer’s conclusion that the particular transaction does not result in the realization of COD income is incorrect, the taxpayer’s protective election is treated as a valid, irrevocable election under § 108(i). Filing an amended tax return Thus, if a taxpayer makes a protective election, the Service subsequently may require the taxpayer to report COD income deferred pursuant to the valid and irrevocable protective election even if the statute of limitations has expired for the year in which the COD income was realized and the protective election was made. Filing an amended tax return A taxpayer makes a protective election by attaching a statement satisfying the requirements of this section 4. Filing an amended tax return 11(1) to the taxpayer’s original federal income tax return within the period described in section 4. Filing an amended tax return 01(1)(a) of this revenue procedure. Filing an amended tax return The taxpayer also must attach the election to its federal income tax return in each of the 8 or 9 taxable years, as applicable, following the taxable year of the election. Filing an amended tax return A statement meets the requirements of this section 4. Filing an amended tax return 11(1) if the statement— (a) States “Section 108(i) Protective Election” across the top; (b) Provides the information required under section 4. Filing an amended tax return 05(2)(a), (b), and (c) of this revenue procedure; (c) Provides that the amounts described in sections 4. Filing an amended tax return 05(2)(d) and (e) of this revenue procedure are zero; and (d) Provides the information described in section 4. Filing an amended tax return 06 of this revenue procedure. Filing an amended tax return (2) Statements provided to shareholders and partners. Filing an amended tax return (a) For each applicable debt instrument, a partnership or S corporation that makes a protective election must attach to the Schedule K-1 (Form 1065, Form 1065-B, or Form 1120S) it provides each of its partners or shareholders, as the case may be, for the taxable year in which the protective election is made a statement containing the information described in section 4. Filing an amended tax return 11(1)(b) of this revenue procedure (an S corporation need not provide its shareholders with the date(s) of the transaction(s) that would constitute the reacquisition transaction or transactions) and the partner’s or shareholder’s share of the additional COD income that would be deferred as described in section 4. Filing an amended tax return 11(1)(d) of this revenue procedure. Filing an amended tax return (b) The partnership or S corporation should not attach the statements described in this section 4. Filing an amended tax return 11(2) to the Schedules K-1 that are filed with the Service but must retain these statements, and each partner and shareholder must retain that partner’s or shareholder’s statement, in their respective books and records. Filing an amended tax return . Filing an amended tax return 12 Election-Year Reporting by Tiered Pass-Through Entities. Filing an amended tax return (1) A partnership required to file a U. Filing an amended tax return S. Filing an amended tax return partnership return other than under § 1. Filing an amended tax return 6031(a)-1(b)(5), or an S corporation, that receives a Schedule K-1 (Form 1065 or Form 1065-B) reflecting its share of any items listed in section 4. Filing an amended tax return 07(1) of this revenue procedure, must report on the Schedules K-1 (Form 1065, Form 1065-B, or Form 1120S) to its partners or shareholders, as the case may be, each partner’s or shareholder’s share of those items (an S corporation only reports to its shareholders the items described in section 4. Filing an amended tax return 07(1)(a) through (d) of this revenue procedure). Filing an amended tax return (2) If a partnership described in section 4. Filing an amended tax return 12(1) of this revenue procedure receives a statement described in sections 4. Filing an amended tax return 07(2) or 4. Filing an amended tax return 10(3) of this revenue procedure or this section 4. Filing an amended tax return 12(2), it must provide each of its partners a statement containing the partner’s share of each of the items listed on each statement received by the partnership, including the information described in section 4. Filing an amended tax return 07(2)(b)(x) of this revenue procedure. Filing an amended tax return If an S corporation receives a statement described in sections 4. Filing an amended tax return 07(2) or 4. Filing an amended tax return 10(3) of this revenue procedure or this section 4. Filing an amended tax return 12(2), it must provide each of its shareholders a statement containing the shareholder’s share of each of the items listed on each statement received by the S corporation that are described in section 4. Filing an amended tax return 07(2)(b)(i), (ii), (iii), (iv) and (ix) of this revenue procedure. Filing an amended tax return The partnership or S corporation must attach this statement or statements to the Schedule K-1 (Form 1065, Form 1065-B, or Form 1120S) that it provides to each of its partners or shareholders, as the case may be, for the taxable year of the partnership or S corporation. Filing an amended tax return The partnership or S corporation should not attach these statements to the Schedules K-1 that are filed with the Service but must retain these statements, and each partner and shareholder must retain that partner’s or shareholder’s statement, in their respective books and records. Filing an amended tax return (3) A partnership that receives a statement described in this section 4 identifying its COD income amount with respect to an applicable debt instrument must allocate its COD income amount, without regard to § 108(i), to the partners in the partnership immediately before the reacquisition transaction in the manner in which the income would be included in the distributive shares of these partners under § 704 and the regulations thereunder, including § 1. Filing an amended tax return 704-1(b)(2)(iii). Filing an amended tax return The partnership may determine in any manner the portion, if any, of a partner’s COD income amount that is the partner’s deferred amount and the portion, if any, of a partner’s COD income amount that is the partner’s included amount. Filing an amended tax return No partner’s deferred amount with respect to an applicable debt instrument may exceed its COD income amount with respect to the applicable debt instrument, and the aggregate of deferred amounts of its partners with respect to an applicable debt instrument must equal the partnership’s deferred amount with respect to the applicable debt instrument. Filing an amended tax return The partnership allocates amounts described in section 4. Filing an amended tax return 06 of this revenue procedure under this section 4. Filing an amended tax return 12(3) as if the additional COD income was realized. Filing an amended tax return (4) The deferred § 752 amount for partners in a partnership making a § 108(i) election is calculated only for the partnership’s direct partners. Filing an amended tax return No further adjustment to the deferred § 752 amount is made to reflect the basis or other attributes of partners that are indirect partners in the partnership. Filing an amended tax return (5) If an S corporation receives a statement described in this section 4 identifying its COD income amount, deferred amount, included amount or additional COD income that would be deferred with respect to an applicable debt instrument, these amounts are shared pro rata only among those shareholders that are shareholders in the S corporation immediately before the reacquisition transaction. Filing an amended tax return (6) This paragraph 4. Filing an amended tax return 12(6) provides the rules for Category 1 and Category 2 filers of Form 8865, Return of U. Filing an amended tax return S. Filing an amended tax return Persons With Respect to Certain Foreign Partnerships, as defined in the instructions for Form 8865, if the foreign partnership, for which the Category 1 or Category 2 filer has a filing requirement, receives a Schedule K-1 (Form 1065 or Form 1065-B) reflecting the partnership’s share of any items listed in section 4. Filing an amended tax return 07(1) of this revenue procedure, or a statement described in sections 4. Filing an amended tax return 07(2) or 4. Filing an amended tax return 10(3) of this revenue procedure (because the foreign partnership owns an interest directly or indirectly in another partnership in which an election was made under § 108(i) with respect to that foreign partnership’s distributive share from the other entity). Filing an amended tax return (a) For each partner for whom the Category 1 filer is required to complete a Schedule K-1 (Form 8865) (which includes the Category 1 filer itself), the Category 1 filer must: (i) Include the information described in section 4. Filing an amended tax return 07(1) of this revenue procedure in the Schedule K-1 (Form 8865) that the Category 1 filer files with the Service and completes for the partner; (ii) Produce a statement containing the partner’s share of the items listed on each statement received by the partnership; and (iii) Attach the statement described in section 4. Filing an amended tax return 12(6)(a)(ii) of this revenue procedure to each Schedule K-1 (Form 8865) that it is required to provide to a partner of the foreign partnership. Filing an amended tax return (b) A Category 2 filer must include its share of the information described in section 4. Filing an amended tax return 07(1) on the Schedule K-1 (Form 8865) that it is required to complete. Filing an amended tax return Category 2 filers also must complete a statement containing their share of the items listed on each statement received by the partnership. Filing an amended tax return (c) The Category 1 and Category 2 filers should not attach the statements described in sections 4. Filing an amended tax return 12(6)(a)(ii) and 4. Filing an amended tax return 12(6)(b) of this revenue procedure, respectively, to the Schedules K-1 that are filed with the Service. Filing an amended tax return However, Category 1 filers must retain the statements they complete and each partner must retain its own statement, in their respective books and records. Filing an amended tax return (7) If as a result of § 108(i)(5)(D)(ii), a partner of a partnership described in section 4. Filing an amended tax return 12(1) of this revenue procedure or a shareholder of an S corporation described in section 4. Filing an amended tax return 12(1) of this revenue procedure must recognize items deferred under § 108(i), the partnership or S corporation must report these items on the Schedule K-1 (Form 1065, Form 1065-B, or Form 1120S) and statements provided to the partner or shareholder pursuant to section 4. Filing an amended tax return 12(1) and (2) of this revenue procedure. Filing an amended tax return Similar rules apply to Category 1 and Category 2 filers (Form 8865) described in section 4. Filing an amended tax return 12(6) of this revenue procedure. Filing an amended tax return (8) The provisions of section 4. Filing an amended tax return 12(2), (3), (5) and (6) of this revenue procedure also apply to a statement received that is described in section 4. Filing an amended tax return 11(2) of this revenue procedure, except that the information that must be provided are those items described in section 4. Filing an amended tax return 11(1)(b) of this revenue procedure (an S corporation need not provide its shareholders with the date(s) of the transaction(s) that would constitute the reacquisition transaction or transactions) and the share of the partner or shareholder in the amounts described in section 4. Filing an amended tax return 11(1)(d) of this revenue procedure. Filing an amended tax return SECTION 5. Filing an amended tax return REQUIRED INFORMATION STATEMENT . Filing an amended tax return 01 Annual Information Statements. Filing an amended tax return Pursuant to § 108(i)(7)(B), a taxpayer that makes an election under § 108(i) (except for a protective election under section 4. Filing an amended tax return 11(1) of this revenue procedure) must attach a statement meeting the requirements of section 5. Filing an amended tax return 02 of this revenue procedure to its federal income tax return for each taxable year beginning with the taxable year following the taxable year for which the taxpayer makes the election and ending with the first taxable year in which all items deferred under § 108(i) have been recognized. Filing an amended tax return . Filing an amended tax return 02 Contents of Statement. Filing an amended tax return A statement meets the requirements of this section 5. Filing an amended tax return 02 if the statement— (1) Label. Filing an amended tax return States “Section 108(i) Information Statement” across the top; (2) Required information. Filing an amended tax return Clearly identifies for each applicable debt instrument to which an election under § 108(i) applies— (a) COD income deferred under § 108(i) that is included in income in the current taxable year under § 108(i)(1); (b) COD income deferred under § 108(i) that is included in income in the current taxable year under § 108(i)(5)(D), including a description and date of the acceleration event described in § 108(i)(5)(D); (c) COD income deferred under § 108(i) that has not been included in income in the current or prior taxable years (in the case of a partnership, the aggregate of the partners’ deferred amounts that have not been included in income in the current or prior taxable years, and in the case of an S corporation, the S corporation’s COD income deferred under § 108(i) that has not been included in income in the current or prior taxable years); (d) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(2)(A)(ii); (e) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(5)(D); and (f) OID deduction deferred under § 108(i)(2)(A)(i) that has not been deducted in the current or prior taxable years. Filing an amended tax return (3) Election attached. Filing an amended tax return Includes a copy of the election statement described in section 4. Filing an amended tax return 05 of this revenue procedure. Filing an amended tax return . Filing an amended tax return 03 Additional Annual Reporting Requirements for Certain Partnerships. Filing an amended tax return The rules of this section 5. Filing an amended tax return 03 apply to partnerships other than partnerships described in section 5. Filing an amended tax return 05 of this revenue procedure. Filing an amended tax return (1) In general. Filing an amended tax return A partnership that makes an election under § 108(i) (except for a protective election under section 4. Filing an amended tax return 11(1) of this revenue procedure) must attach to its federal income tax returns the statements required under section 5. Filing an amended tax return 01 of this revenue procedure. Filing an amended tax return In addition, for each taxable year in which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure, the partnership must report on the Schedule K-1 (Form 1065 or Form 1065-B) for each partner § 108(i) information in the manner described in section 4. Filing an amended tax return 07(1) of this revenue procedure. Filing an amended tax return (2) Annual information statements provided to partners. Filing an amended tax return The partnership must attach to the Schedule K-1 (Form 1065) provided to each partner for each taxable year in which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure, a statement meeting the requirements of this section 5. Filing an amended tax return 03(2). Filing an amended tax return The partnership should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain these statements, and each partner must retain that partner’s statement, in their respective books and records. Filing an amended tax return A statement meets the requirements of this section 5. Filing an amended tax return 03(2) if the statement— (a) Label. Filing an amended tax return States “Section 108(i) Annual Information Statement for Partners” across the top of the statement. Filing an amended tax return (b) Required information. Filing an amended tax return Clearly identifies for each applicable debt instrument to which a § 108(i) election applies— (i) The partner’s deferred amount that has not been included in income as of the end of the prior taxable year; (ii) The partner’s deferred amount that the partner must include in income in the current taxable year under § 108(i)(1); (iii) The partner’s deferred amount that the partner must include in income in the current taxable year under § 108(i)(5)(D)(i) or (ii); (iv) The partner’s deferred amount that has not been included in income in the current or prior taxable years; (v) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) in the current taxable year; (vi) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(2)(A)(ii); (vii) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(5)(D)(i) or (ii); (viii) The partner’s share of the partnership’s OID deduction deferred under § 108(i)(2)(A)(i) that has not been deducted in the current or prior taxable years; and (ix) The partner’s deferred § 752 amount that is treated as a distribution of money to the partner under § 752 in the current taxable year and any remaining deferred § 752 amount. Filing an amended tax return If a partner fails to provide the written statement required by section 4. Filing an amended tax return 07(3) of this revenue procedure, the partnership must indicate that the amounts described in this section 5. Filing an amended tax return 03(2)(b)(ix) cannot be calculated because the partner did not provide the information necessary to report these amounts. Filing an amended tax return . Filing an amended tax return 04 Additional Annual Reporting Requirements for an S Corporation. Filing an amended tax return (1) In general. Filing an amended tax return An S corporation that makes an election under § 108(i) (except for a protective election under section 4. Filing an amended tax return 11(1) of this revenue procedure) must attach to its federal income tax returns the statements required under section 5. Filing an amended tax return 01 of this revenue procedure. Filing an amended tax return In addition, for each taxable year in which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure, the S corporation must report on the Schedule K-1 (Form 1120S) for each shareholder § 108(i) information in the manner described in section 4. Filing an amended tax return 08(1) of this revenue procedure. Filing an amended tax return (2) Annual information statements provided to shareholders. Filing an amended tax return The S corporation must attach to the Schedule K-1 (Form 1120S) provided to each shareholder for each taxable year in which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure a statement meeting the requirements of this section 5. Filing an amended tax return 04(2). Filing an amended tax return The S corporation should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain these statements, and each shareholder must retain that shareholder’s statement, in their respective books and records. Filing an amended tax return A statement meets the requirements of this section 5. Filing an amended tax return 04(2) if the statement— (a) Label. Filing an amended tax return States “Section 108(i) Annual Information Statement for Shareholders” across the top; (b) Required information. Filing an amended tax return Clearly identifies for each applicable debt instrument to which an election under § 108(i) applies, the shareholder’s share of the S corporation’s— (i) COD income deferred under § 108(i) that has not been included in income as of the end of the prior taxable year; (ii) COD income deferred under § 108(i) that the shareholder must include in income in the current taxable year under § 108(i)(1); (iii) COD income deferred under § 108(i) that the shareholder must include in income in the current taxable year under § 108(i)(5)(D)(i) or (ii); (iv) COD income deferred under § 108(i) that has not been included in income in the current or prior taxable years; (v) OID deduction deferred under § 108(i)(2)(A)(i) in the current taxable year; (vi) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(2)(A)(ii); (vii) OID deduction deferred under § 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under § 108(i)(5)(D)(i) or (ii); and (viii) OID deduction deferred under § 108(i)(2)(A)(i) that has not been deducted in the current or prior taxable years. Filing an amended tax return . Filing an amended tax return 05 Additional Annual Reporting Requirements for Certain Foreign Partnerships. Filing an amended tax return (1) The rules of this section 5. Filing an amended tax return 05 apply to nonfiling foreign partnerships. Filing an amended tax return (2) A nonfiling foreign partnership that makes an election under § 108(i) (except for a protective election under section 4. Filing an amended tax return 11(1) of this revenue procedure) must file federal income tax returns with the Service containing the information under § 1. Filing an amended tax return 6031(a)-1(b)(5) for each taxable year in which a statement is required by section 5. Filing an amended tax return 01 of this revenue procedure. Filing an amended tax return (3) The nonfiling foreign partnership must attach to its federal income tax returns the statements required under section 5. Filing an amended tax return 01 of this revenue procedure, but only for that portion of the COD income allocated to affected partners. Filing an amended tax return (4) For each taxable year in which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure, the nonfiling foreign partnership must provide each affected partner a Schedule K-1 (Form 1065) reporting § 108(i) information in the manner described in section 4. Filing an amended tax return 07(1) of this revenue procedure. Filing an amended tax return Except for this § 108(i) information, the partnership need not complete Part III of the Schedule K-1 (Form 1065). Filing an amended tax return The partnership must provide each affected partner with a copy of the Schedule K-1 (Form 1065) by the date provided in § 1. Filing an amended tax return 6031(b)-1T(b). Filing an amended tax return The partnership must attach the Schedules K-1 (Form 1065) to the federal income tax returns filed with the Service pursuant to section 5. Filing an amended tax return 05(2) of this revenue procedure. Filing an amended tax return (5) For each taxable year for which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure, the nonfiling foreign partnership must attach to each affected partner’s Schedule K-1 (Form 1065) a statement meeting the requirements of section 5. Filing an amended tax return 03(2) of this revenue procedure. Filing an amended tax return The partnership should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain the statements, and each partner must retain that partner’s statement, in their respective books and records. Filing an amended tax return . Filing an amended tax return 06 Information Statements Made on Behalf of Certain Foreign Corporations. Filing an amended tax return Each controlling domestic shareholder must attach a statement identifying the foreign corporation and meeting the requirements of section 5. Filing an amended tax return 02 of this revenue procedure to the shareholder’s federal income tax return for each taxable year for which a statement is required under section 5. Filing an amended tax return 01 of this revenue procedure. Filing an amended tax return . Filing an amended tax return 07 Additional Annual Reporting Requirements for Tiered Pass-Through Entities. Filing an amended tax return (1) A partnership required to file a U. Filing an amended tax return S. Filing an amended tax return partnership return other than under § 1. Filing an amended tax return 6031(a)-1(b)(5), or an S corporation, that receives a Schedule K-1 (Form 1065 or Form 1065-B) described in the second sentence of section 5. Filing an amended tax return 03(1) of this revenue procedure reflecting its share of any § 108(i) information must report on the Schedules K-1 (Form 1065, Form 1065-B, or Form 1120S) to its partners or shareholders, as the case may be, each partner’s or shareholder’s share of those items (an S corporation only reports to its shareholders the items described in section 4. Filing an amended tax return 07(1)(a) through (d) of this revenue procedure). Filing an amended tax return (2) If a partnership described in section 5. Filing an amended tax return 07(1) of this revenue procedure receives a statement described in sections 5. Filing an amended tax return 03(2) or 5. Filing an amended tax return 05(5) of this revenue procedure or this section 5. Filing an amended tax return 07(2), it must provide each of its partners a statement containing the partner’s share of each of the items listed on each statement received by the partnership. Filing an amended tax return If an S corporation receives a statement described in sections 5. Filing an amended tax return 03(2) or 5. Filing an amended tax return 05(5) of this revenue procedure or this section 5. Filing an amended tax return 07(2), it must provide each of its shareholders a statement containing the shareholder’s share of each of the items listed on each statement received by the S corporation that are described in section 5. Filing an amended tax return 03(2)(b)(i) through (viii) of this revenue procedure. Filing an amended tax return The partnership or S corporation must attach the statement or statements to the Schedule K-1 (Form 1065 or Form 1065-B) or Schedule K-1 (Form 1120S) that is provided to each of its partners or shareholders, as the case may be, for the taxable year of the partnership or S corporation. Filing an amended tax return The partnership or S corporation should not attach these statements to the Schedules K-1 that are filed with the Service, but must retain these statements, and each partner and shareholder must retain that partner’s or shareholder’s statement, in their respective books and records. Filing an amended tax return (3) This paragraph 5. Filing an amended tax return 07(3) provides the rules for persons described in section 4. Filing an amended tax return 12(6) of this revenue procedure if the foreign partnership, for which the Category 1 or 2 filer has a filing requirement, receives a Schedule K-1 (Form 1065 or Form 1065-B) reflecting the partnership’s share of any items described in the second sentence of section 5. Filing an amended tax return 03(1) of this revenue procedure, or a statement described in sections 5. Filing an amended tax return 03(2) or 5. Filing an amended tax return 05(5) of this revenue procedure (because the foreign partnership owns an interest directly or indirectly in another partnership in which an election was made under § 108(i) with respect to that foreign partnership’s distributive share from the other entity). Filing an amended tax return (a) For each partner for whom the Category 1 filer is required to complete a Schedule K-1 (Form 8865) (which includes the Category 1 filer itself), the Category 1 filer must: (i) Include the information described in section 4. Filing an amended tax return 07(1) of this revenue procedure in the Schedule K-1 (Form 8865) that the Category 1 filer files with the Service and completes for the partner; (ii) Produce a statement containing the partner’s share of the items listed on each statement received by the partnership; and (iii) Attach the statement described in section 5. Filing an amended tax return 07(3)(a)(ii) of this revenue procedure to each Schedule K-1 (Form 8865) that it is required to provide to a partner of the foreign partnership. Filing an amended tax return (b) A Category 2 filer must include its share of the information described in section 4. Filing an amended tax return 07(1) on the Schedule K-1 (Form 8865) that it is required to complete. Filing an amended tax return Category 2 filers also must complete a statement containing their share of the items listed on each statement received by the partnership. Filing an amended tax return (c) The Category 1 and Category 2 filers should not attach the statements described in sections 5. Filing an amended tax return 07(3)(a)(ii) and 5. Filing an amended tax return 07(3)(b) of this revenue procedure, respectively, to the Schedules K-1 that are filed with the Service. Filing an amended tax return However, Category 1 filers must retain the statements they complete and each partner must retain its own statement, in their respective books and records. Filing an amended tax return (4) If as a result of § 108(i)(5)(D)(ii), a partner of a partnership described in section 5. Filing an amended tax return 07(1) of this revenue procedure or a shareholder of an S corporation described in section 5. Filing an amended tax return 07(1) of this revenue procedure must recognize items deferred under § 108(i), the partnership or S corporation must report these items on the Schedule K-1 (Form 1065, Form 1065-B, or Form 1120S) and statements provided to the partner or shareholder pursuant to section 5. Filing an amended tax return 07(1) and (2) of this revenue procedure. Filing an amended tax return Similar rules apply to Category 1 and Category 2 filers (Form 8865) described in section 4. Filing an amended tax return 12(6) of this revenue procedure. Filing an amended tax return SECTION 6. Filing an amended tax return EFFECTIVE DATE This revenue procedure is effective for reacquisitions of applicable debt instruments in taxable years ending after December 31, 2008. Filing an amended tax return SECTION 7. Filing an amended tax return TRANSITION RULE . Filing an amended tax return 01 Noncomplying Election. Filing an amended tax return Except as otherwise provided in this section 7. Filing an amended tax return 01, the Service will treat a § 108(i) election as effective if a taxpayer files an election with the taxpayer’s federal income tax return filed on or before September 16, 2009, using any reasonable procedure to make the election. Filing an amended tax return However, an election that does not comply with section 4 of this revenue procedure will not be effective unless the taxpayer on or before November 16, 2009, files an amended return for the taxable year of the election and complies with the requirements of section 4 of this revenue procedure. Filing an amended tax return . Filing an amended tax return 02 Modification of Election. Filing an amended tax return A taxpayer that files a § 108(i) election on or before September 16, 2009, may modify that election by filing an amended return on or before November 16, 2009 (for example, to modify the amount of COD income the taxpayer elects to defer). Filing an amended tax return To be effective, a modification of an election described in the preceding sentence must satisfy the requirements for an election described in section 4 of this revenue procedure. Filing an amended tax return . Filing an amended tax return 03 Notations. Filing an amended tax return A taxpayer that files the amended return on paper must write “Section 108(i) Election” on the top of the first page. Filing an amended tax return A taxpayer that files the amended return electronically should indicate “Section 108(i) Election” on the return. Filing an amended tax return See Publication 4163, Modernized e-File (MeF) Information for Authorized IRS e-file Providers for Business Returns Tax Year 2008 for more details. Filing an amended tax return SECTION 8. Filing an amended tax return PAPERWORK REDUCTION ACT The collection of information contained in this revenue procedure has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act (44 U. Filing an amended tax return S. Filing an amended tax return C. Filing an amended tax return 3507) under control number 1545-2147. Filing an amended tax return An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Filing an amended tax return The collection of information in this revenue procedure is in sections 4, 5 and 7. Filing an amended tax return This information is required to determine the amount of income and deductions a taxpayer elects to defer and to track those amounts until the taxpayer has reported all deferred income and deductions on the taxpayer’s tax return. Filing an amended tax return This information will be used during examination to verify that a taxpayer has correctly deferred income and deductions. Filing an amended tax return The collection of information is required to obtain a benefit. Filing an amended tax return The likely respondents are C corporations, shareholders of S corporations, partners of partnerships, and other individuals engaged in a trade or business, that reacquire applicable debt instruments in 2009 or 2010. Filing an amended tax return The estimated total annual reporting burden is 300,000 hours. Filing an amended tax return The estimated annual burden per respondent varies from 1 to 8 hours, depending on individual circumstances, with an estimated average of 6 hours. Filing an amended tax return The estimated number of respondents is 50,000. Filing an amended tax return Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Filing an amended tax return Generally, tax returns and return information are confidential, as required by § 6103. Filing an amended tax return DRAFTING INFORMATION The principal authors of this revenue procedure are Megan A. Filing an amended tax return Stoner of the Office of Associate Chief Counsel (Passthroughs & Special Industries) and Craig Wojay of the Office of Associate Chief Counsel (Income Tax & Accounting). Filing an amended tax return For further information regarding this revenue procedure, contact Megan A. Filing an amended tax return Stoner at (202) 622-3070 for questions involving partnerships and S corporations, William E. Filing an amended tax return Blanchard at (202) 622-3950 for questions involving OID, Ronald M. Filing an amended tax return Gootzeit at (202) 622-3860 for questions involving foreign entities, Robert Rhyne at (202) 622-7790 for questions involving earnings and profits and consolidated groups, and Craig Wojay at (202) 622-4920 for questions on § 108(i) generally (not toll-free calls). 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