IRS Extends Interim Guidance on Code Sec. 833 Treatment of Certain Health Organizations (Notice 2011-51)

The IRS has extended the interim guidance provided in Notice 2010-79, I.R.B. 2010-49, 809, as clarified and modified by Notice 2011-4, I.R.B. 2011-2, 282, and Rev. Proc. 2011-14, I.R.B. 2011-4, 330, on the interpretation and application of Code Sec. 833(c)(5) to certain health organizations. To provide affected taxpayers with sufficient time to adapt to the reporting requirements under Section 2718 of the Public Health Service Act that bear on data used to compute the medical loss ratio under Code Sec. 833(c)(5) and to make any administrative or other adjustments that may be necessary in light of the possible nonapplication of Code Sec. 833 to such taxpayers, the interim guidance provided in Notice 2010-79 is extended to any tax year beginning in 2010 and the first tax year beginning after December 31, 2010.

Notice 2011-51, 2011FED ¶46,392

Other References:

Code Sec. 446

CCH Reference – 2010FED ¶20,620.284

Code Sec. 833

CCH Reference – 2011FED ¶26,171.21

Tax Research Consultant

CCH Reference – TRC EXEMPT: 15,160.10

AUTHOR

Wolters Kluwer Tax and Accounting

Wolters Kluwer Tax and Accounting is a leading provider of software solutions and local expertise that helps tax, accounting, and audit professionals research and navigate complex regulations, comply with legislation, manage their businesses and advise clients with speed, accuracy and efficiency. Wolters Kluwer Tax and Accounting is part of Wolters Kluwer N.V. (AEX: WKL), a global leader in information services and solutions for professionals in the health, tax and accounting, risk and compliance, finance and legal sectors. We help our customers make critical decisions every day by providing expert solutions that combine deep domain knowledge with specialized technology and services. Wolters Kluwer reported 2016 annual revenues of €4.3 billion. The company, headquartered in Alphen aan den Rijn, the Netherlands, serves customers in over 180 countries, maintains operations in over 40 countries and employs 19,000 people worldwide. Wolters Kluwer shares are listed on Euronext Amsterdam (WKL) and are included in the AEX and Euronext 100 indices. Wolters Kluwer has a sponsored Level 1 American Depositary Receipt program. The ADRs are traded on the over-the-counter market in the U.S. (WTKWY).

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