IRB 2011-49 (Rev December 5, 2011).pdfVIP

Bulletin No. 2011-49 December 5, 2011 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX icy to be includible in the grantor’s gross estate under section 2042, provided the trustee has a fiduciary obligation (under local law or the trust instrument) to ensure the grantor’s com- Rev. Rul. 2011–29, page 824. pliance with the terms of this power by satisfying itself that the Accrual of liability to unknown payees. This ruling holds properties acquired and substituted by the grantor are in fact that an employer can establish the “fact of the liability” under of equivalent value, and further provided that the substitution section 461 of the Code for bonuses payable to a group of power cannot be exercised in a manner that can shift benefits employees even though the employer does not know the iden- among the trust beneficiaries. tity of any particular bonus recipient and the amount payable to that recipient until after the end of the taxable year. Rev. Rul. 76–345 revoked. ADMINISTRATIVE Rev. Rul. 2011–30, page 826. 2011 base period T-bill rate. The “base period T-bill rate” Notice 2011–94, page 834. for the period ending September 30, 2011, is published as Application of general welfa