SECTION 4. ELECTION — Internal Revenue Bulletin 2009-36

PROCEDURES

.01 In General. (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 4.05 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 4.07, 4.08, 4.09, or 4.10 of this revenue procedure. (2) The Service grants an automatic extension of 12 months from the due date prescribed in section 4.01(1)(a) of this revenue procedure for making the § 108(i) election. The rules that apply to an automatic extension under § 301.9100–2(a) apply to this automatic extension.

.02 Section 108(i) Elections Made by Members of Consolidated Groups . The common parent of a consolidated group makes the § 108(i) election on behalf of all members of the group. See § 1.1502–77(a).

.03 Aggregation Rule . 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. A pass-through entity may not treat two or more applicable debt instruments as one applicable debt instrument under this section 4.03 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.

.04 Partial Elections . (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. 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. 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.

(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). 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.

(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. 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). A partner may exclude from income the partner’s included amount under § 108(a)(1)(A), (B), (C), or (D), if applicable. The provisions of this section 4.04(3) apply for purposes of § 108(i) only and are not intended as an interpretation of or a change to existing law under § 704.

.05 Contents of Election Statement . A statement meets the requirements of this section 4.05 if the statement—

(1) Label . States “Section 108(i) Election” across the top.

(2) Required information . 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 gen

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(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 4.05(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 2.09 of this revenue procedure;

(ix) The partner’s additional deferred amount as described in section 4.06 of this revenue procedure; and

(x) The date of the reacquisition transaction generating the COD income.

(c) If a partner fails to provide the written statement required by section 4.07(3) of this revenue procedure, the partnership must indicate that the amounts described in section 4.07(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.

(3) Partner reporting requirements . 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 2.09 of this revenue procedure) a written statement signed under penalties of perjury that includes this information. Each partner with a deferred

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. 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. 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 2.08, 2.10 and, if applicable, 4.04(3) of this revenue procedure, respectively, as if the additional COD income was realized.

.07 Additional Requirements for Cer- tain Partnerships Making a § 108(i) Elec- tion . The rules of this section 4.07 apply to partnerships other than partnerships described in section 4.10 of this revenue procedure.

(1) Information filing on Schedule K–1 (Form 1065 and Form 1065–B) . 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, De- ductions, Credits, etc., 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. 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).

(2) Election information statement pro- vided to partners. 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 4.07(2). 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. A statement meets the requirements of this section 4.07(2) if the statement—

(a) Label . States “Section 108(i) Election Information Statement for Partners” across the top.

(b) Required information . Clearly identifies for each applicable debt instrument to which an election under § 108(i) applies—

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trolling domestic shareholder must attach a statement identifying the foreign corporation and satisfying the requirements of section 4.05 of this revenue procedure and, if applicable, section 4.06 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.

.10 Section 108(i) Elections Made By Certain Foreign Partnerships. The rules of this section 4.10 apply to a foreign partnership making a § 108(i) election that is not otherwise required to file a federal partnership return (“nonfiling foreign partnership”). See § 1.6031(a)–1(b).

(1) A nonfiling foreign partnership making the election must attach a statement satisfying the requirements of section 4.05 of this revenue procedure and, if applicable, section 4.06 of this revenue procedure, to a partnership return satisfying the requirements of § 1.6031(a)–1(b)(5) it files with the Service. In addition, a nonfiling foreign partnership must include in the information required in section 4.05(2)(d) and (e) of this revenue procedure the aggregate amounts for all partners as well as the aggregate amounts for all U.S. 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”).

(2) The nonfiling foreign partnership must make the election, in accordance with § 1.6031(a)–1(b)(5), by the date provided in section 4.01(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.

(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 4.07(1) of this revenue procedure. Except for this § 108(i) information, the partnership need not complete Part III of the Schedule K–1 (Form 1065). 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 4.07(2) of this revenue procedure by the date provided in section 4.01(1)(a) of this revenue proce

amount must provide this written statement to the partnership within 30 days of the date of request by the partnership. 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. If a partner provides its written statement under this section 4.07(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 4.07(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.

.08 Additional Requirements for an S Corporation Making a § 108(i) Election .

(1) Information filing on Schedule K–1 (Form 1120S) . 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., 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. 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;

come 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.

(2) Election information statement pro- vided to shareholders. 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 4.08(2). 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. A statement meets the requirements of this section 4.08(2) if the statement—

(a) Label . States “Section 108(i) Election Information Statement for Shareholders” across the top.

(b) Required information . 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 4.06 of this revenue procedure.

.09 Section 108(i) Elections Made on Behalf of Certain Foreign Corporations. 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 § 1.964–1(c)(3). Each con

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receives a statement described in sections 4.07(2) or 4.10(3) of this revenue procedure or this section 4.12(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 4.07(2)(b)(i), (ii), (iii), (iv) and (ix) of this revenue procedure. 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. 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.

(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 § 1.704–1(b)(2)(iii). 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. 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. The partnership allocates amounts described in section 4.06 of this revenue procedure under this section 4.12(3) as if the additional COD income was realized.

(4) The deferred § 752 amount for partners in a partnership making a § 108(i) election is calculated only for the partnership’s direct partners. No further adjustment to the deferred § 752 amount is made to reflect the basis or other attributes of

dure. The partnership should not attach any statement described in section 4.07(2) of this revenue procedure to the Schedules K–1 that are filed with the Service. 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.

(4) The partnership and each affected partner must satisfy the requirements of section 4.07(3) of this revenue procedure.

.11 Protective § 108(i) Election. (1) In general . 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. 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). 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. A taxpayer makes a protective election by attaching a statement satisfying the requirements of this section 4.11(1) to the taxpayer’s original federal income tax return within the period described in section 4.01(1)(a) of this revenue procedure. 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. A statement meets the requirements of this section 4.11(1) if the statement—

(a) States “Section 108(i) Protective Election” across the top;

(b) Provides the information required under section 4.05(2)(a), (b), and (c) of this revenue procedure;

(d) Provides the information described in section 4.06 of this revenue procedure.

(2) Statements provided to shareholders and partners .

(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 4.11(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 4.11(1)(d) of this revenue procedure.

(b) The partnership or S corporation should not attach the statements described in this section 4.11(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.

.12 Election-Year Reporting by Tiered Pass-Through Entities .

(1) A partnership required to file a U.S. partnership return other than under § 1.6031(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 4.07(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 4.07(1)(a) through (d) of this revenue procedure).

(2) If a partnership described in section 4.12(1) of this revenue procedure receives a statement described in sections 4.07(2) or 4.10(3) of this revenue procedure or this section 4.12(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 4.07(2)(b)(x) of this revenue procedure. If an S corporation

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.02 Contents of Statement . A statement meets the requirements of this section 5.02 if the statement—

(1) Label. States “Section 108(i) Information Statement” across the top;

(2) Required information. 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.

(3) Election attached. Includes a copy of the election statement described in section 4.05 of this revenue procedure.

.03 Additional Annual Reporting Re- quirements for Certain Partnerships. The rules of this section 5.03 apply to partnerships other than partnerships described in section 5.05 of this revenue procedure.

(1) In general . A partnership that makes an election under § 108(i) (except for a protective election under section 4.11(1) of this revenue procedure) must attach to its federal income tax returns the statements required under section 5.01 of this revenue procedure. In addition, for each taxable year in which a statement is required under section 5.01 of this revenue procedure, the partnership must report on

partners that are indirect partners in the partnership.

(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.

(6) This paragraph 4.12(6) provides the rules for Category 1 and Category 2 filers of Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partner- ships, 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 4.07(1) of this revenue procedure, or a statement described in sections 4.07(2) or 4.10(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).

(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 4.07(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 4.12(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.

(b) A Category 2 filer must include its share of the information described in section 4.07(1) on the Schedule K–1 (Form 8865) that it is required to complete. Category 2 filers also must complete a statement containing their share of the items listed on each statement received by the partnership.

(c) The Category 1 and Category 2 filers should not attach the statements described in sections 4.12(6)(a)(ii) and 4.12(6)(b) of this revenue procedure, respectively, to the Schedules K–1 that are filed with the Service. However, Category 1 filers must retain the statements they complete and each partner must retain its own statement, in their respective books and records.

(7) If as a result of § 108(i)(5)(D)(ii), a partner of a partnership described in section 4.12(1) of this revenue procedure or a shareholder of an S corporation described in section 4.12(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 4.12(1) and (2) of this revenue procedure. Similar rules apply to Category 1 and Category 2 filers (Form 8865) described in section 4.12(6) of this revenue procedure.

(8) The provisions of section 4.12(2), (3), (5) and (6) of this revenue procedure also apply to a statement received that is described in section 4.11(2) of this revenue procedure, except that the information that must be provided are those items described in section 4.11(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 4.11(1)(d) of this revenue procedure.