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Can I File My 2012 Taxes Online Now

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Can I File My 2012 Taxes Online Now

Can i file my 2012 taxes online now Publication 590 - Introductory Material Table of Contents What's New for 2013 What's New for 2014 Reminders IntroductionOrdering forms and publications. Can i file my 2012 taxes online now Tax questions. Can i file my 2012 taxes online now Useful Items - You may want to see: Note. Can i file my 2012 taxes online now After 2013, Publication 590 will be split into two separate publications as follows. Can i file my 2012 taxes online now Publication 590-A, will focus on contributions to traditional IRAs as well as Roth IRAs. Can i file my 2012 taxes online now This publication will include the rules for rollover and conversion contributions. Can i file my 2012 taxes online now Publication 590-B, will focus on distributions from traditional IRAs as well as Roth IRAs. Can i file my 2012 taxes online now This publication will include the rules for required minimum distributions and IRA beneficiaries. Can i file my 2012 taxes online now What's New for 2013 Traditional IRA contribution and deduction limit. Can i file my 2012 taxes online now  The contribution limit to your traditional IRA for 2013 will be increased to the smaller of the following amounts: $5,500, or Your taxable compensation for the year. Can i file my 2012 taxes online now If you were age 50 or older before 2014, the most that can be contributed to your traditional IRA for 2013 will be the smaller of the following amounts: $6,500, or Your taxable compensation for the year. Can i file my 2012 taxes online now For more information, see How Much Can Be Contributed? in chapter 1. Can i file my 2012 taxes online now Roth IRA contribution limit. Can i file my 2012 taxes online now  If contributions on your behalf are made only to Roth IRAs, your contribution limit for 2013 will generally be the lesser of: $5,500, or Your taxable compensation for the year. Can i file my 2012 taxes online now If you were age 50 or older before 2014 and contributions on your behalf were made only to Roth IRAs, your contribution limit for 2013 will generally be the lesser of: $6,500, or Your taxable compensation for the year. Can i file my 2012 taxes online now However, if your modified adjusted gross income (AGI) is above a certain amount, your contribution limit may be reduced. Can i file my 2012 taxes online now For more information, see How Much Can Be Contributed? under Can You Contribute to a Roth IRA? in chapter 2. Can i file my 2012 taxes online now Modified AGI limit for traditional IRA contributions increased. Can i file my 2012 taxes online now  For 2013, if you were covered by a retirement plan at work, your deduction for contributions to a traditional IRA is reduced (phased out) if your modified AGI is: More than $95,000 but less than $115,000 for a married couple filing a joint return or a qualifying widow(er), More than $59,000 but less than $69,000 for a single individual or head of household, or Less than $10,000 for a married individual filing a separate return. Can i file my 2012 taxes online now If you either lived with your spouse or file a joint return, and your spouse was covered by a retirement plan at work, but you were not, your deduction is phased out if your modified AGI is more than $178,000 but less than $188,000. Can i file my 2012 taxes online now If your modified AGI is $188,000 or more, you cannot take a deduction for contributions to a traditional IRA. Can i file my 2012 taxes online now See How Much Can You Deduct? in chapter 1. Can i file my 2012 taxes online now Modified AGI limit for Roth IRA contributions increased. Can i file my 2012 taxes online now  For 2013, your Roth IRA contribution limit is reduced (phased out) in the following situations. Can i file my 2012 taxes online now Your filing status is married filing jointly or qualifying widow(er) and your modified AGI is at least $178,000. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $188,000 or more. Can i file my 2012 taxes online now Your filing status is single, head of household, or married filing separately and you did not live with your spouse at any time in 2013 and your modified AGI is at least $112,000. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $127,000 or more. Can i file my 2012 taxes online now Your filing status is married filing separately, you lived with your spouse at any time during the year, and your modified AGI is more than -0-. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $10,000 or more. Can i file my 2012 taxes online now See Can You Contribute to a Roth IRA? in chapter 2. Can i file my 2012 taxes online now Net Investment Income Tax. Can i file my 2012 taxes online now  For purposes of the Net Investment Income Tax (NIIT), net investment income does not include distributions from a qualified retirement plan (for example, 401(a), 403(a), 403(b), 457(b) plans, and IRAs). Can i file my 2012 taxes online now However, these distributions are taken into account when determining the modified adjusted gross income threshold. Can i file my 2012 taxes online now Distributions from a nonqualified retirement plan are included in net investment income. Can i file my 2012 taxes online now See Form 8960, Net Investment Income Tax—Individuals, Estates, and Trusts, and its instructions for more information. Can i file my 2012 taxes online now Kay Bailey Hutchison Spousal IRA. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now  In 2013, spousal IRAs were renamed to Kay Bailey Hutchison Spousal IRAs. Can i file my 2012 taxes online now There are no changes to the rules regarding these IRAs. Can i file my 2012 taxes online now See Kay Bailey Hutchison Spousal IRA Limit in chapter 1 for more information. Can i file my 2012 taxes online now What's New for 2014 Modified AGI limit for traditional IRA contributions increased. Can i file my 2012 taxes online now  For 2014, if you are covered by a retirement plan at work, your deduction for contributions to a traditional IRA is reduced (phased out) if your modified AGI is: More than $96,000 but less than $116,000 for a married couple filing a joint return or a qualifying widow(er), More than $60,000 but less than $70,000 for a single individual or head of household, or Less than $10,000 for a married individual filing a separate return. Can i file my 2012 taxes online now If you either live with your spouse or file a joint return, and your spouse is covered by a retirement plan at work, but you are not, your deduction is phased out if your modified AGI is more than $181,000 but less than $191,000. Can i file my 2012 taxes online now If your modified AGI is $191,000 or more, you cannot take a deduction for contributions to a traditional IRA. Can i file my 2012 taxes online now Modified AGI limit for Roth IRA contributions increased. Can i file my 2012 taxes online now  For 2014, your Roth IRA contribution limit is reduced (phased out) in the following situations. Can i file my 2012 taxes online now Your filing status is married filing jointly or qualifying widow(er) and your modified AGI is at least $181,000. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $191,000 or more. Can i file my 2012 taxes online now Your filing status is single, head of household, or married filing separately and you did not live with your spouse at any time in 2014 and your modified AGI is at least $114,000. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $129,000 or more. Can i file my 2012 taxes online now Your filing status is married filing separately, you lived with your spouse at any time during the year, and your modified AGI is more than -0-. Can i file my 2012 taxes online now You cannot make a Roth IRA contribution if your modified AGI is $10,000 or more. Can i file my 2012 taxes online now Reminders Future developments. Can i file my 2012 taxes online now  For the latest information about developments related to Publication 590, such as legislation enacted after it was published, go to www. Can i file my 2012 taxes online now irs. Can i file my 2012 taxes online now gov/pub590. Can i file my 2012 taxes online now Simplified employee pension (SEP). Can i file my 2012 taxes online now  SEP IRAs are not covered in this publication. Can i file my 2012 taxes online now They are covered in Publication 560, Retirement Plans for Small Business. Can i file my 2012 taxes online now Deemed IRAs. Can i file my 2012 taxes online now  A qualified employer plan (retirement plan) can maintain a separate account or annuity under the plan (a deemed IRA) to receive voluntary employee contributions. Can i file my 2012 taxes online now If the separate account or annuity otherwise meets the requirements of an IRA, it will be subject only to IRA rules. Can i file my 2012 taxes online now An employee's account can be treated as a traditional IRA or a Roth IRA. Can i file my 2012 taxes online now For this purpose, a “qualified employer plan” includes: A qualified pension, profit-sharing, or stock bonus plan (section 401(a) plan), A qualified employee annuity plan (section 403(a) plan), A tax-sheltered annuity plan (section 403(b) plan), and A deferred compensation plan (section 457 plan) maintained by a state, a political subdivision of a state, or an agency or instrumentality of a state or political subdivision of a state. Can i file my 2012 taxes online now Contributions to both traditional and Roth IRAs. Can i file my 2012 taxes online now  For information on your combined contribution limit if you contribute to both traditional and Roth IRAs, see Roth IRAs and traditional IRAs under How Much Can Be Contributed? in chapter 2. Can i file my 2012 taxes online now Statement of required minimum distribution (RMD). Can i file my 2012 taxes online now  If an RMD is required from your IRA, the trustee, custodian, or issuer that held the IRA at the end of the preceding year must either report the amount of the RMD to you, or offer to calculate it for you. Can i file my 2012 taxes online now The report or offer must include the date by which the amount must be distributed. Can i file my 2012 taxes online now The report is due January 31 of the year in which the minimum distribution is required. Can i file my 2012 taxes online now It can be provided with the year-end fair market value statement that you normally get each year. Can i file my 2012 taxes online now No report is required for section 403(b) contracts (generally tax-sheltered annuities) or for IRAs of owners who have died. Can i file my 2012 taxes online now IRA interest. Can i file my 2012 taxes online now  Although interest earned from your IRA is generally not taxed in the year earned, it is not tax-exempt interest. Can i file my 2012 taxes online now Tax on your traditional IRA is generally deferred until you take a distribution. Can i file my 2012 taxes online now Do not report this interest on your return as tax-exempt interest. Can i file my 2012 taxes online now For more information on tax-exempt interest, see the instructions for your tax return. Can i file my 2012 taxes online now Photographs of missing children. Can i file my 2012 taxes online now  The Internal Revenue Service is a proud partner with the National Center for Missing and Exploited Children. Can i file my 2012 taxes online now Photographs of missing children selected by the Center may appear in this publication on pages that would otherwise be blank. Can i file my 2012 taxes online now You can help bring these children home by looking at the photographs and calling 1-800-THE-LOST (1-800-843-5678) if you recognize a child. Can i file my 2012 taxes online now Introduction This publication discusses individual retirement arrangements (IRAs). Can i file my 2012 taxes online now An IRA is a personal savings plan that gives you tax advantages for setting aside money for retirement. Can i file my 2012 taxes online now What are some tax advantages of an IRA?   Two tax advantages of an IRA are that: Contributions you make to an IRA may be fully or partially deductible, depending on which type of IRA you have and on your circumstances, and Generally, amounts in your IRA (including earnings and gains) are not taxed until distributed. Can i file my 2012 taxes online now In some cases, amounts are not taxed at all if distributed according to the rules. Can i file my 2012 taxes online now What's in this publication?   This publication discusses traditional, Roth, and SIMPLE IRAs. Can i file my 2012 taxes online now It explains the rules for: Setting up an IRA, Contributing to an IRA, Transferring money or property to and from an IRA, Handling an inherited IRA, Receiving distributions (making withdrawals) from an IRA, and Taking a credit for contributions to an IRA. Can i file my 2012 taxes online now   It also explains the penalties and additional taxes that apply when the rules are not followed. Can i file my 2012 taxes online now To assist you in complying with the tax rules for IRAs, this publication contains worksheets, sample forms, and tables, which can be found throughout the publication and in the appendices at the back of the publication. Can i file my 2012 taxes online now How to use this publication. Can i file my 2012 taxes online now   The rules that you must follow depend on which type of IRA you have. Can i file my 2012 taxes online now Use Table I-1 to help you determine which parts of this publication to read. Can i file my 2012 taxes online now Also use Table I-1 if you were referred to this publication from instructions to a form. Can i file my 2012 taxes online now Comments and suggestions. Can i file my 2012 taxes online now   We welcome your comments about this publication and your suggestions for future editions. Can i file my 2012 taxes online now   You can write to us at the following address: Internal Revenue Service Tax Forms and Publications Division 1111 Constitution Ave. Can i file my 2012 taxes online now NW, IR-6526 Washington, DC 20224   We respond to many letters by telephone. Can i file my 2012 taxes online now Therefore, it would be helpful if you would include your daytime phone number, including the area code, in your correspondence. Can i file my 2012 taxes online now   You can send your comments from www. Can i file my 2012 taxes online now irs. Can i file my 2012 taxes online now gov/formspubs/. Can i file my 2012 taxes online now Click on “More Information” and then on “Comment on Tax Forms and Publications”. Can i file my 2012 taxes online now   Although we cannot respond individually to each comment received, we do appreciate your feedback and will consider your comments as we revise our tax products. Can i file my 2012 taxes online now Ordering forms and publications. Can i file my 2012 taxes online now   Visit www. Can i file my 2012 taxes online now irs. Can i file my 2012 taxes online now gov/formspubs/ to download forms and publications, call 1-800-TAX-FORM (1-800-829-3676), or write to the address below and receive a response within 10 days after your request is received. Can i file my 2012 taxes online now Internal Revenue Service 1201 N. Can i file my 2012 taxes online now Mitsubishi Motorway Bloomington, IL 61705-6613 Tax questions. Can i file my 2012 taxes online now   If you have a tax question, check the information available on IRS. Can i file my 2012 taxes online now gov or call 1-800-829-1040. Can i file my 2012 taxes online now We cannot answer tax questions sent to either of the above addresses. Can i file my 2012 taxes online now Useful Items - You may want to see: Publications 560 Retirement Plans for Small Business (SEP, SIMPLE, and Qualified Plans) 571 Tax-Sheltered Annuity Plans (403(b) Plans) 575 Pension and Annuity Income 939 General Rule for Pensions and Annuities Forms (and instructions) W-4P Withholding Certificate for Pension or Annuity Payments 1099-R Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc. Can i file my 2012 taxes online now 5304-SIMPLE Savings Incentive Match Plan for Employees of Small Employers (SIMPLE)–Not for Use With a Designated Financial Institution 5305-S SIMPLE Individual Retirement Trust Account 5305-SA SIMPLE Individual Retirement Custodial Account 5305-SIMPLE Savings Incentive Match Plan for Employees of Small Employers (SIMPLE)–for Use With a Designated Financial Institution 5329 Additional Taxes on Qualified Plans (Including IRAs) and Other Tax-Favored Accounts 5498 IRA Contribution Information 8606 Nondeductible IRAs 8815 Exclusion of Interest From Series EE and I U. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now Savings Bonds Issued After 1989 8839 Qualified Adoption Expenses 8880 Credit for Qualified Retirement Savings Contributions See chapter 5 for information about getting these publications and forms. Can i file my 2012 taxes online now Table I-1. Can i file my 2012 taxes online now Using This Publication IF you need information on . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now THEN see . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now traditional IRAs chapter 1. Can i file my 2012 taxes online now Roth IRAs chapter 2, and parts of  chapter 1. Can i file my 2012 taxes online now SIMPLE IRAs chapter 3. Can i file my 2012 taxes online now the credit for qualified retirement savings contributions (the saver's credit) chapter 4. Can i file my 2012 taxes online now how to keep a record of your contributions to, and distributions from, your traditional IRA(s) appendix A. Can i file my 2012 taxes online now SEP IRAs and 401(k) plans Publication 560. Can i file my 2012 taxes online now Coverdell education savings accounts (formerly called education IRAs) Publication 970. Can i file my 2012 taxes online now IF for 2013, you received social security benefits, had taxable compensation, contributed to a traditional IRA, and you or your spouse was covered by an employer retirement plan, and you want to. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now THEN see . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now . Can i file my 2012 taxes online now first figure your modified adjusted gross income (AGI) appendix B, worksheet 1. Can i file my 2012 taxes online now then figure how much of your traditional IRA contribution you can deduct appendix B, worksheet 2. Can i file my 2012 taxes online now and finally figure how much of your social security is taxable appendix B, worksheet 3. Can i file my 2012 taxes online now Table I-2. Can i file my 2012 taxes online now How Are a Traditional IRA and a Roth IRA Different? This table shows the differences between traditional and Roth IRAs. Can i file my 2012 taxes online now Answers in the middle column apply to traditional IRAs. Can i file my 2012 taxes online now Answers in the right column apply to Roth IRAs. Can i file my 2012 taxes online now Question Answer   Traditional IRA? Roth IRA? Is there an age limit on when I can open and contribute to a Yes. Can i file my 2012 taxes online now You must not have reached age  70½ by the end of the year. Can i file my 2012 taxes online now See Who Can Open a Traditional IRA? in chapter 1. Can i file my 2012 taxes online now No. Can i file my 2012 taxes online now You can be any age. Can i file my 2012 taxes online now See Can You Contribute to a Roth IRA? in chapter 2. Can i file my 2012 taxes online now If I earned more than $5,500 in 2013 ($6,500 if I was 50 or older by the end of 2013), is there a limit on how much I can contribute to a Yes. Can i file my 2012 taxes online now For 2013, you can contribute to a traditional IRA up to: $5,500, or $6,500 if you were age 50 or older by the end of 2013. Can i file my 2012 taxes online now  There is no upper limit on how much you can earn and still contribute. Can i file my 2012 taxes online now See How Much Can Be Contributed? in chapter 1. Can i file my 2012 taxes online now Yes. Can i file my 2012 taxes online now For 2013, you may be able to contribute to a Roth IRA up to: $5,500, or $6,500 if you were age 50 or older by the end of 2013,  but the amount you can contribute may be less than that depending on your income, filing status, and if you contribute to another IRA. Can i file my 2012 taxes online now See How Much Can Be Contributed? and Table 2-1 in chapter 2. Can i file my 2012 taxes online now Can I deduct contributions to a Yes. Can i file my 2012 taxes online now You may be able to deduct your contributions to a traditional IRA depending on your income, filing status, whether you are covered by a retirement plan at work, and whether you receive social security benefits. Can i file my 2012 taxes online now See How Much Can You Deduct? in chapter 1. Can i file my 2012 taxes online now No. Can i file my 2012 taxes online now You can never deduct contributions to a Roth IRA. Can i file my 2012 taxes online now See What Is a Roth IRA? in chapter 2. Can i file my 2012 taxes online now Do I have to file a form just because I contribute to a Not unless you make nondeductible contributions to your traditional IRA. Can i file my 2012 taxes online now In that case, you must file Form 8606. Can i file my 2012 taxes online now See Nondeductible Contributions in chapter 1. Can i file my 2012 taxes online now No. Can i file my 2012 taxes online now You do not have to file a form if you contribute to a Roth IRA. Can i file my 2012 taxes online now See Contributions not reported in chapter 2. Can i file my 2012 taxes online now Do I have to start taking distributions when I reach a certain age from a Yes. Can i file my 2012 taxes online now You must begin receiving required minimum distributions by April 1 of the year following the year you reach age 70½. Can i file my 2012 taxes online now See When Must You Withdraw Assets? (Required Minimum Distributions) in chapter 1. Can i file my 2012 taxes online now No. Can i file my 2012 taxes online now If you are the original owner of a Roth IRA, you do not have to take distributions regardless of your age. Can i file my 2012 taxes online now See Are Distributions Taxable? in chapter 2. Can i file my 2012 taxes online now However, if you are the beneficiary of a Roth IRA, you may have to take distributions. Can i file my 2012 taxes online now See Distributions After Owner's Death in chapter 2. Can i file my 2012 taxes online now How are distributions taxed from a Distributions from a traditional IRA are taxed as ordinary income, but if you made nondeductible contributions, not all of the distribution is taxable. Can i file my 2012 taxes online now See Are Distributions Taxable? in chapter 1. Can i file my 2012 taxes online now Distributions from a Roth IRA are not taxed as long as you meet certain criteria. Can i file my 2012 taxes online now See Are Distributions Taxable? in chapter 2. Can i file my 2012 taxes online now Do I have to file a form just because I receive distributions from a Not unless you have ever made a nondeductible contribution to a traditional IRA. Can i file my 2012 taxes online now If you have, file Form 8606. Can i file my 2012 taxes online now See Nondeductible Contributions in chapter 1. Can i file my 2012 taxes online now Yes. Can i file my 2012 taxes online now File Form 8606 if you received distributions from a Roth IRA (other than a rollover, qualified charitable distribution, one-time distribution to fund an HSA, recharacterization, certain qualified distributions, or a return of certain contributions). Can i file my 2012 taxes online now Prev  Up  Next   Home   More Online Publications
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The Can I File My 2012 Taxes Online Now

Can i file my 2012 taxes online now Internal Revenue Bulletin:  2009-36  September 8, 2009  Rev. Can i file my 2012 taxes online now Proc. Can i file my 2012 taxes online now 2009-37 Table of Contents SECTION 1. Can i file my 2012 taxes online now PURPOSE SECTION 2. Can i file my 2012 taxes online now BACKGROUND SECTION 3. Can i file my 2012 taxes online now SCOPE SECTION 4. Can i file my 2012 taxes online now ELECTION PROCEDURES SECTION 5. Can i file my 2012 taxes online now REQUIRED INFORMATION STATEMENT SECTION 6. Can i file my 2012 taxes online now EFFECTIVE DATE SECTION 7. Can i file my 2012 taxes online now TRANSITION RULE SECTION 8. Can i file my 2012 taxes online now PAPERWORK REDUCTION ACT DRAFTING INFORMATION SECTION 1. Can i file my 2012 taxes online now PURPOSE . Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now This revenue procedure describes the time and manner of providing this additional information. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now Taxpayers should be aware that these regulations may be retroactive. Can i file my 2012 taxes online now See § 7805(b)(2). Can i file my 2012 taxes online now This revenue procedure may be modified to provide procedures consistent with additional guidance. Can i file my 2012 taxes online now SECTION 2. Can i file my 2012 taxes online now BACKGROUND . Can i file my 2012 taxes online now 01 Section 108(i), Generally. Can i file my 2012 taxes online now Section 108(i) was added to the Code by § 1231 of the American Recovery and Reinvestment Tax Act of 2009, Pub. Can i file my 2012 taxes online now L. Can i file my 2012 taxes online now No. Can i file my 2012 taxes online now 111-5, 123 Stat. Can i file my 2012 taxes online now 338. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 1273-1(d) of the Income Tax Regulations. Can i file my 2012 taxes online now The OID deferral rule in § 108(i)(2) applies at the entity level for a pass-through entity. Can i file my 2012 taxes online now For example, a partnership (and therefore its partners) may not deduct currently the OID described in § 108(i)(2)(A)(i). Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now See § 108(i)(5)(D). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now Section 108(i)(5)(D)(ii). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 02 Applicable Debt Instrument. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now Section 108(i)(3)(B). Can i file my 2012 taxes online now For purposes of § 108(i), in the case of an intercompany obligation (as defined in § 1. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 1502-13(g)(5). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 03 Reacquisition. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now See § 108(i)(4)(B). Can i file my 2012 taxes online now The term “acquisition” also includes an indirect acquisition within the meaning of § 1. Can i file my 2012 taxes online now 108-2(c) if a direct acquisition of the debt instrument would qualify for an election under § 108(i). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 04 General Requirements for the Section 108(i) Election. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now ) The statement must include the amount of income to which § 108(i)(1) applies and other information the Service may prescribe. Can i file my 2012 taxes online now Once made, a § 108(i) election is irrevocable and, except as provided in section 7 of this revenue procedure, may not be modified. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 05 Section 108(i) Elections Made by Pass-through Entities. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now Section 108(i)(5)(B)(iii). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 06 Additional Information on Subsequent Years’ Returns. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 07 Exclusivity. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 08 Allocation of Deferred COD Income on Partnership Indebtedness. Can i file my 2012 taxes online now Section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 704-1(b)(2)(iii). Can i file my 2012 taxes online now Each partner’s share of this COD income is the partner’s COD income amount (“COD income amount”). Can i file my 2012 taxes online now The partner’s COD income amount that is deferred under § 108(i) is the partner’s deferred amount (“deferred amount”). Can i file my 2012 taxes online now 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”). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 09 Partner’s Deferred § 752 Amount. Can i file my 2012 taxes online now 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”). Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now See Rev. Can i file my 2012 taxes online now Rul. Can i file my 2012 taxes online now 92-97, 1992-2 C. Can i file my 2012 taxes online now B. Can i file my 2012 taxes online now 124, and Rev. Can i file my 2012 taxes online now Rul. Can i file my 2012 taxes online now 94-4, 1994-1 C. Can i file my 2012 taxes online now B. Can i file my 2012 taxes online now 195. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 10 Allocation of Deferred COD Income on S Corporation Indebtedness. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 11 Deferred COD Income, Earnings and Profits, and Alternative Minimum Taxable Income. Can i file my 2012 taxes online now (1) In general. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now See § 1. Can i file my 2012 taxes online now 56(g)-1(c)(1). Can i file my 2012 taxes online now (2) Exceptions for certain special status corporations. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now OID deductions deferred under § 108(i) generally decrease earnings and profits in the taxable year or years that the deferred OID deductions are deductible. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 12 Extension of Time to Make Election. Can i file my 2012 taxes online now Under § 301. Can i file my 2012 taxes online now 9100-1 of the Procedure and Administration Regulations, the Service may grant an extension of time to make a regulatory election. Can i file my 2012 taxes online now An election is a regulatory election if the due date is prescribed by regulation or other published guidance of general applicability. Can i file my 2012 taxes online now Section 301. Can i file my 2012 taxes online now 9100-2(a) provides an automatic 12-month extension from the due date for making certain regulatory elections. Can i file my 2012 taxes online now SECTION 3. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now SECTION 4. Can i file my 2012 taxes online now ELECTION PROCEDURES . Can i file my 2012 taxes online now 01 In General. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07, 4. Can i file my 2012 taxes online now 08, 4. Can i file my 2012 taxes online now 09, or 4. Can i file my 2012 taxes online now 10 of this revenue procedure. Can i file my 2012 taxes online now (2) The Service grants an automatic extension of 12 months from the due date prescribed in section 4. Can i file my 2012 taxes online now 01(1)(a) of this revenue procedure for making the § 108(i) election. Can i file my 2012 taxes online now The rules that apply to an automatic extension under § 301. Can i file my 2012 taxes online now 9100-2(a) apply to this automatic extension. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 02 Section 108(i) Elections Made by Members of Consolidated Groups. Can i file my 2012 taxes online now The common parent of a consolidated group makes the § 108(i) election on behalf of all members of the group. Can i file my 2012 taxes online now See § 1. Can i file my 2012 taxes online now 1502-77(a). Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 03 Aggregation Rule. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A pass-through entity may not treat two or more applicable debt instruments as one applicable debt instrument under this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 04 Partial Elections. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now A partner may exclude from income the partner’s included amount under § 108(a)(1)(A), (B), (C), or (D), if applicable. Can i file my 2012 taxes online now The provisions of this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 05 Contents of Election Statement. Can i file my 2012 taxes online now A statement meets the requirements of this section 4. Can i file my 2012 taxes online now 05 if the statement— (1) Label. Can i file my 2012 taxes online now States “Section 108(i) Election” across the top. Can i file my 2012 taxes online now (2) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 06 Supplemental information. Can i file my 2012 taxes online now The statement described in section 4. Can i file my 2012 taxes online now 05 of this revenue procedure may specify for each applicable debt instrument an amount greater than the amount identified in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 05(2)(d) of this revenue procedure. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 08, 2. Can i file my 2012 taxes online now 10 and, if applicable, 4. Can i file my 2012 taxes online now 04(3) of this revenue procedure, respectively, as if the additional COD income was realized. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 07 Additional Requirements for Certain Partnerships Making a § 108(i) Election. Can i file my 2012 taxes online now The rules of this section 4. Can i file my 2012 taxes online now 07 apply to partnerships other than partnerships described in section 4. Can i file my 2012 taxes online now 10 of this revenue procedure. Can i file my 2012 taxes online now (1) Information filing on Schedule K-1 (Form 1065 and Form 1065-B). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now , 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now (2) Election information statement provided to partners. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(2). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A statement meets the requirements of this section 4. Can i file my 2012 taxes online now 07(2) if the statement— (a) Label. Can i file my 2012 taxes online now States “Section 108(i) Election Information Statement for Partners” across the top. Can i file my 2012 taxes online now (b) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 09 of this revenue procedure; (ix) The partner’s additional deferred amount as described in section 4. Can i file my 2012 taxes online now 06 of this revenue procedure; and (x) The date of the reacquisition transaction generating the COD income. Can i file my 2012 taxes online now (c) If a partner fails to provide the written statement required by section 4. Can i file my 2012 taxes online now 07(3) of this revenue procedure, the partnership must indicate that the amounts described in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (3) Partner reporting requirements. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 09 of this revenue procedure) a written statement signed under penalties of perjury that includes this information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now If a partner provides its written statement under this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 08 Additional Requirements for an S Corporation Making a § 108(i) Election. Can i file my 2012 taxes online now (1) Information filing on Schedule K-1 (Form 1120S). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now , 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (2) Election information statement provided to shareholders. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 08(2). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A statement meets the requirements of this section 4. Can i file my 2012 taxes online now 08(2) if the statement— (a) Label. Can i file my 2012 taxes online now States “Section 108(i) Election Information Statement for Shareholders” across the top. Can i file my 2012 taxes online now (b) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 06 of this revenue procedure. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 09 Section 108(i) Elections Made on Behalf of Certain Foreign Corporations. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 964-1(c)(3). Can i file my 2012 taxes online now Each controlling domestic shareholder must attach a statement identifying the foreign corporation and satisfying the requirements of section 4. Can i file my 2012 taxes online now 05 of this revenue procedure and, if applicable, section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 10 Section 108(i) Elections Made By Certain Foreign Partnerships. Can i file my 2012 taxes online now The rules of this section 4. Can i file my 2012 taxes online now 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”). Can i file my 2012 taxes online now See § 1. Can i file my 2012 taxes online now 6031(a)-1(b). Can i file my 2012 taxes online now (1) A nonfiling foreign partnership making the election must attach a statement satisfying the requirements of section 4. Can i file my 2012 taxes online now 05 of this revenue procedure and, if applicable, section 4. Can i file my 2012 taxes online now 06 of this revenue procedure, to a partnership return satisfying the requirements of § 1. Can i file my 2012 taxes online now 6031(a)-1(b)(5) it files with the Service. Can i file my 2012 taxes online now In addition, a nonfiling foreign partnership must include in the information required in section 4. Can i file my 2012 taxes online now 05(2)(d) and (e) of this revenue procedure the aggregate amounts for all partners as well as the aggregate amounts for all U. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now 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”). Can i file my 2012 taxes online now (2) The nonfiling foreign partnership must make the election, in accordance with § 1. Can i file my 2012 taxes online now 6031(a)-1(b)(5), by the date provided in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 07(1) of this revenue procedure. Can i file my 2012 taxes online now Except for this § 108(i) information, the partnership need not complete Part III of the Schedule K-1 (Form 1065). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(2) of this revenue procedure by the date provided in section 4. Can i file my 2012 taxes online now 01(1)(a) of this revenue procedure. Can i file my 2012 taxes online now The partnership should not attach any statement described in section 4. Can i file my 2012 taxes online now 07(2) of this revenue procedure to the Schedules K-1 that are filed with the Service. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (4) The partnership and each affected partner must satisfy the requirements of section 4. Can i file my 2012 taxes online now 07(3) of this revenue procedure. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 11 Protective § 108(i) Election. Can i file my 2012 taxes online now (1) In general. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A taxpayer makes a protective election by attaching a statement satisfying the requirements of this section 4. Can i file my 2012 taxes online now 11(1) to the taxpayer’s original federal income tax return within the period described in section 4. Can i file my 2012 taxes online now 01(1)(a) of this revenue procedure. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A statement meets the requirements of this section 4. Can i file my 2012 taxes online now 11(1) if the statement— (a) States “Section 108(i) Protective Election” across the top; (b) Provides the information required under section 4. Can i file my 2012 taxes online now 05(2)(a), (b), and (c) of this revenue procedure; (c) Provides that the amounts described in sections 4. Can i file my 2012 taxes online now 05(2)(d) and (e) of this revenue procedure are zero; and (d) Provides the information described in section 4. Can i file my 2012 taxes online now 06 of this revenue procedure. Can i file my 2012 taxes online now (2) Statements provided to shareholders and partners. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 11(1)(d) of this revenue procedure. Can i file my 2012 taxes online now (b) The partnership or S corporation should not attach the statements described in this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 12 Election-Year Reporting by Tiered Pass-Through Entities. Can i file my 2012 taxes online now (1) A partnership required to file a U. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now partnership return other than under § 1. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1)(a) through (d) of this revenue procedure). Can i file my 2012 taxes online now (2) If a partnership described in section 4. Can i file my 2012 taxes online now 12(1) of this revenue procedure receives a statement described in sections 4. Can i file my 2012 taxes online now 07(2) or 4. Can i file my 2012 taxes online now 10(3) of this revenue procedure or this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(2)(b)(x) of this revenue procedure. Can i file my 2012 taxes online now If an S corporation receives a statement described in sections 4. Can i file my 2012 taxes online now 07(2) or 4. Can i file my 2012 taxes online now 10(3) of this revenue procedure or this section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(2)(b)(i), (ii), (iii), (iv) and (ix) of this revenue procedure. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 704-1(b)(2)(iii). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now The partnership allocates amounts described in section 4. Can i file my 2012 taxes online now 06 of this revenue procedure under this section 4. Can i file my 2012 taxes online now 12(3) as if the additional COD income was realized. Can i file my 2012 taxes online now (4) The deferred § 752 amount for partners in a partnership making a § 108(i) election is calculated only for the partnership’s direct partners. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now (6) This paragraph 4. Can i file my 2012 taxes online now 12(6) provides the rules for Category 1 and Category 2 filers of Form 8865, Return of U. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1) of this revenue procedure, or a statement described in sections 4. Can i file my 2012 taxes online now 07(2) or 4. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (b) A Category 2 filer must include its share of the information described in section 4. Can i file my 2012 taxes online now 07(1) on the Schedule K-1 (Form 8865) that it is required to complete. Can i file my 2012 taxes online now Category 2 filers also must complete a statement containing their share of the items listed on each statement received by the partnership. Can i file my 2012 taxes online now (c) The Category 1 and Category 2 filers should not attach the statements described in sections 4. Can i file my 2012 taxes online now 12(6)(a)(ii) and 4. Can i file my 2012 taxes online now 12(6)(b) of this revenue procedure, respectively, to the Schedules K-1 that are filed with the Service. Can i file my 2012 taxes online now However, Category 1 filers must retain the statements they complete and each partner must retain its own statement, in their respective books and records. Can i file my 2012 taxes online now (7) If as a result of § 108(i)(5)(D)(ii), a partner of a partnership described in section 4. Can i file my 2012 taxes online now 12(1) of this revenue procedure or a shareholder of an S corporation described in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 12(1) and (2) of this revenue procedure. Can i file my 2012 taxes online now Similar rules apply to Category 1 and Category 2 filers (Form 8865) described in section 4. Can i file my 2012 taxes online now 12(6) of this revenue procedure. Can i file my 2012 taxes online now (8) The provisions of section 4. Can i file my 2012 taxes online now 12(2), (3), (5) and (6) of this revenue procedure also apply to a statement received that is described in section 4. Can i file my 2012 taxes online now 11(2) of this revenue procedure, except that the information that must be provided are those items described in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 11(1)(d) of this revenue procedure. Can i file my 2012 taxes online now SECTION 5. Can i file my 2012 taxes online now REQUIRED INFORMATION STATEMENT . Can i file my 2012 taxes online now 01 Annual Information Statements. Can i file my 2012 taxes online now Pursuant to § 108(i)(7)(B), a taxpayer that makes an election under § 108(i) (except for a protective election under section 4. Can i file my 2012 taxes online now 11(1) of this revenue procedure) must attach a statement meeting the requirements of section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 02 Contents of Statement. Can i file my 2012 taxes online now A statement meets the requirements of this section 5. Can i file my 2012 taxes online now 02 if the statement— (1) Label. Can i file my 2012 taxes online now States “Section 108(i) Information Statement” across the top; (2) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (3) Election attached. Can i file my 2012 taxes online now Includes a copy of the election statement described in section 4. Can i file my 2012 taxes online now 05 of this revenue procedure. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 03 Additional Annual Reporting Requirements for Certain Partnerships. Can i file my 2012 taxes online now The rules of this section 5. Can i file my 2012 taxes online now 03 apply to partnerships other than partnerships described in section 5. Can i file my 2012 taxes online now 05 of this revenue procedure. Can i file my 2012 taxes online now (1) In general. Can i file my 2012 taxes online now A partnership that makes an election under § 108(i) (except for a protective election under section 4. Can i file my 2012 taxes online now 11(1) of this revenue procedure) must attach to its federal income tax returns the statements required under section 5. Can i file my 2012 taxes online now 01 of this revenue procedure. Can i file my 2012 taxes online now In addition, for each taxable year in which a statement is required under section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1) of this revenue procedure. Can i file my 2012 taxes online now (2) Annual information statements provided to partners. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 01 of this revenue procedure, a statement meeting the requirements of this section 5. Can i file my 2012 taxes online now 03(2). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A statement meets the requirements of this section 5. Can i file my 2012 taxes online now 03(2) if the statement— (a) Label. Can i file my 2012 taxes online now States “Section 108(i) Annual Information Statement for Partners” across the top of the statement. Can i file my 2012 taxes online now (b) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now If a partner fails to provide the written statement required by section 4. Can i file my 2012 taxes online now 07(3) of this revenue procedure, the partnership must indicate that the amounts described in this section 5. Can i file my 2012 taxes online now 03(2)(b)(ix) cannot be calculated because the partner did not provide the information necessary to report these amounts. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 04 Additional Annual Reporting Requirements for an S Corporation. Can i file my 2012 taxes online now (1) In general. Can i file my 2012 taxes online now An S corporation that makes an election under § 108(i) (except for a protective election under section 4. Can i file my 2012 taxes online now 11(1) of this revenue procedure) must attach to its federal income tax returns the statements required under section 5. Can i file my 2012 taxes online now 01 of this revenue procedure. Can i file my 2012 taxes online now In addition, for each taxable year in which a statement is required under section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 08(1) of this revenue procedure. Can i file my 2012 taxes online now (2) Annual information statements provided to shareholders. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 01 of this revenue procedure a statement meeting the requirements of this section 5. Can i file my 2012 taxes online now 04(2). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now A statement meets the requirements of this section 5. Can i file my 2012 taxes online now 04(2) if the statement— (a) Label. Can i file my 2012 taxes online now States “Section 108(i) Annual Information Statement for Shareholders” across the top; (b) Required information. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 05 Additional Annual Reporting Requirements for Certain Foreign Partnerships. Can i file my 2012 taxes online now (1) The rules of this section 5. Can i file my 2012 taxes online now 05 apply to nonfiling foreign partnerships. Can i file my 2012 taxes online now (2) A nonfiling foreign partnership that makes an election under § 108(i) (except for a protective election under section 4. Can i file my 2012 taxes online now 11(1) of this revenue procedure) must file federal income tax returns with the Service containing the information under § 1. Can i file my 2012 taxes online now 6031(a)-1(b)(5) for each taxable year in which a statement is required by section 5. Can i file my 2012 taxes online now 01 of this revenue procedure. Can i file my 2012 taxes online now (3) The nonfiling foreign partnership must attach to its federal income tax returns the statements required under section 5. Can i file my 2012 taxes online now 01 of this revenue procedure, but only for that portion of the COD income allocated to affected partners. Can i file my 2012 taxes online now (4) For each taxable year in which a statement is required under section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1) of this revenue procedure. Can i file my 2012 taxes online now Except for this § 108(i) information, the partnership need not complete Part III of the Schedule K-1 (Form 1065). Can i file my 2012 taxes online now The partnership must provide each affected partner with a copy of the Schedule K-1 (Form 1065) by the date provided in § 1. Can i file my 2012 taxes online now 6031(b)-1T(b). Can i file my 2012 taxes online now The partnership must attach the Schedules K-1 (Form 1065) to the federal income tax returns filed with the Service pursuant to section 5. Can i file my 2012 taxes online now 05(2) of this revenue procedure. Can i file my 2012 taxes online now (5) For each taxable year for which a statement is required under section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 03(2) of this revenue procedure. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 06 Information Statements Made on Behalf of Certain Foreign Corporations. Can i file my 2012 taxes online now Each controlling domestic shareholder must attach a statement identifying the foreign corporation and meeting the requirements of section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 01 of this revenue procedure. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 07 Additional Annual Reporting Requirements for Tiered Pass-Through Entities. Can i file my 2012 taxes online now (1) A partnership required to file a U. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now partnership return other than under § 1. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1)(a) through (d) of this revenue procedure). Can i file my 2012 taxes online now (2) If a partnership described in section 5. Can i file my 2012 taxes online now 07(1) of this revenue procedure receives a statement described in sections 5. Can i file my 2012 taxes online now 03(2) or 5. Can i file my 2012 taxes online now 05(5) of this revenue procedure or this section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now If an S corporation receives a statement described in sections 5. Can i file my 2012 taxes online now 03(2) or 5. Can i file my 2012 taxes online now 05(5) of this revenue procedure or this section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 03(2)(b)(i) through (viii) of this revenue procedure. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (3) This paragraph 5. Can i file my 2012 taxes online now 07(3) provides the rules for persons described in section 4. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 03(1) of this revenue procedure, or a statement described in sections 5. Can i file my 2012 taxes online now 03(2) or 5. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now (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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now (b) A Category 2 filer must include its share of the information described in section 4. Can i file my 2012 taxes online now 07(1) on the Schedule K-1 (Form 8865) that it is required to complete. Can i file my 2012 taxes online now Category 2 filers also must complete a statement containing their share of the items listed on each statement received by the partnership. Can i file my 2012 taxes online now (c) The Category 1 and Category 2 filers should not attach the statements described in sections 5. Can i file my 2012 taxes online now 07(3)(a)(ii) and 5. Can i file my 2012 taxes online now 07(3)(b) of this revenue procedure, respectively, to the Schedules K-1 that are filed with the Service. Can i file my 2012 taxes online now However, Category 1 filers must retain the statements they complete and each partner must retain its own statement, in their respective books and records. Can i file my 2012 taxes online now (4) If as a result of § 108(i)(5)(D)(ii), a partner of a partnership described in section 5. Can i file my 2012 taxes online now 07(1) of this revenue procedure or a shareholder of an S corporation described in section 5. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 07(1) and (2) of this revenue procedure. Can i file my 2012 taxes online now Similar rules apply to Category 1 and Category 2 filers (Form 8865) described in section 4. Can i file my 2012 taxes online now 12(6) of this revenue procedure. Can i file my 2012 taxes online now SECTION 6. Can i file my 2012 taxes online now EFFECTIVE DATE This revenue procedure is effective for reacquisitions of applicable debt instruments in taxable years ending after December 31, 2008. Can i file my 2012 taxes online now SECTION 7. Can i file my 2012 taxes online now TRANSITION RULE . Can i file my 2012 taxes online now 01 Noncomplying Election. Can i file my 2012 taxes online now Except as otherwise provided in this section 7. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 02 Modification of Election. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now . Can i file my 2012 taxes online now 03 Notations. Can i file my 2012 taxes online now A taxpayer that files the amended return on paper must write “Section 108(i) Election” on the top of the first page. Can i file my 2012 taxes online now A taxpayer that files the amended return electronically should indicate “Section 108(i) Election” on the return. Can i file my 2012 taxes online now See Publication 4163, Modernized e-File (MeF) Information for Authorized IRS e-file Providers for Business Returns Tax Year 2008 for more details. Can i file my 2012 taxes online now SECTION 8. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now S. Can i file my 2012 taxes online now C. Can i file my 2012 taxes online now 3507) under control number 1545-2147. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now The collection of information in this revenue procedure is in sections 4, 5 and 7. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now This information will be used during examination to verify that a taxpayer has correctly deferred income and deductions. Can i file my 2012 taxes online now The collection of information is required to obtain a benefit. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now The estimated total annual reporting burden is 300,000 hours. Can i file my 2012 taxes online now The estimated annual burden per respondent varies from 1 to 8 hours, depending on individual circumstances, with an estimated average of 6 hours. Can i file my 2012 taxes online now The estimated number of respondents is 50,000. Can i file my 2012 taxes online now 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. Can i file my 2012 taxes online now Generally, tax returns and return information are confidential, as required by § 6103. Can i file my 2012 taxes online now DRAFTING INFORMATION The principal authors of this revenue procedure are Megan A. Can i file my 2012 taxes online now Stoner of the Office of Associate Chief Counsel (Passthroughs & Special Industries) and Craig Wojay of the Office of Associate Chief Counsel (Income Tax & Accounting). Can i file my 2012 taxes online now For further information regarding this revenue procedure, contact Megan A. Can i file my 2012 taxes online now Stoner at (202) 622-3070 for questions involving partnerships and S corporations, William E. Can i file my 2012 taxes online now Blanchard at (202) 622-3950 for questions involving OID, Ronald M. Can i file my 2012 taxes online now 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). Can i file my 2012 taxes online now Prev  Up  Next   Home   More Internal Revenue Bulletins