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


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