SECTION 4. EFFECTIVE DATE

.01 General Rule . Except as provided in section 4.02, this revenue procedure applies to taxable years beginning in 2010.

.02 Calendar Year Rule . This revenue procedure applies to transactions or events occurring in calendar year 2010 for purposes of sections 3.07 (rehabilitation expenditures treated as separate new property), 3.08 (low-income housing credit), 3.10 (transportation mainline pipeline construction industry optional expense substantiation rules for payments to employees under accountable plans), 3.15 (private activity bonds volume cap), 3.16 (loan limits on agricultural bonds), 3.17 (general arbitrage rebate rules), 3.18 (safe harbor rules for broker commissions on guaranteed investment contracts or investments purchased for a yield restricted defeasance escrow), 3.26 (expatriation to avoid tax), 3.29 (valuation of qualified real property in decedent’s gross estate), 3.30 (annual exclusion for gifts), 3.31 (tax on arrow shafts), 3.34 (persons against whom a federal tax lien is not valid), 3.35 (property exempt from levy), 3.36 (interest on a certain portion of the estate tax payable in installments), 3.37 (attorney fee awards), and 3.38 (periodic payments received under qualified long-term care insurance contracts or under certain life insurance contracts).

.24 Treatment of Dues Paid to Agricul- tural or Horticultural Organizations . For taxable years beginning in 2010, the limitation under § 512(d)(1), regarding the exemption of annual dues required to be paid by a member to an agricultural or horticultural organization, is $146.

.25 Insubstantial Benefit Limitations for Contributions Associated with Chari- table Fund-Raising Campaigns .

(1) Low cost article . For taxable years beginning in 2010, the unrelated business income of certain exempt organizations under § 513(h)(2) does not include a “low cost article” of $9.60 or less.

(2) Other insubstantial benefits . For taxable years beginning in 2010, the $5, $25, and $50 guidelines in section 3 of Rev. Proc. 90–12, 1990–1 C.B. 471 (as amplified by Rev. Proc. 92–49, 1992–1 C.B. 987, and modified by Rev. Proc. 92–102, 1992–2 C.B. 579), for disregarding the value of insubstantial benefits received by a donor in return for a fully deductible charitable contribution under § 170, are $9.60, $48, and $96, respectively.

.26 Expatriation to Avoid Tax . For calendar year 2010, an individual with “average annual net income tax” of more than $145,000 for the five taxable years ending before the date of the loss of United States citizenship under § 877(a)(2)(A) is a covered expatriate for purposes of § 877A(g)(1).

.27 Tax Responsibilities of Expatria- tion . For taxable years beginning in 2010, the amount that would be includible in the gross income of a covered expatriate by reason of § 877A(a)(1) is reduced (but not below zero) by $627,000.

.28 Foreign Earned Income Exclusion . For taxable years beginning in 2010, the foreign earned income exclusion amount under § 911(b)(2)(D)(i) is $91,500.

.29 Valuation of Qualified Real Prop- erty in Decedent’s Gross Estate . For an estate of a decedent dying in calendar year 2010, if the executor elects to use the special use valuation method under § 2032A for qualified real property, the aggregate decrease in the value of qualified real property resulting from electing to use § 2032A for purposes of the estate tax cannot exceed $1,000,000.

.30 Annual Exclusion for Gifts . (1) For calendar year 2010, the first $13,000 of gifts to any person (other than

gifts of future interests in property) are not included in the total amount of taxable gifts under § 2503 made during that year.

(2) For calendar year 2010, the first $134,000 of gifts to a spouse who is not a citizen of the United States (other than gifts of future interests in property) are not included in the total amount of taxable gifts under §§ 2503 and 2523(i)(2) made during that year.

.31 Tax on Arrow Shafts . For calendar year 2010, the tax imposed under § 4161(b)(2)(A) on the first sale by the manufacturer, producer, or importer of any shaft of a type used in the manufacture of certain arrows is $0.45 per shaft.

.32 Reporting Exception for Certain Exempt Organizations with Nondeductible Lobbying Expenditures . For taxable years beginning in 2010, the annual per person, family, or entity dues limitation to qualify for the reporting exception under § 6033(e)(3) (and section 5.05 of Rev. Proc. 98–19, 1998–1 C.B. 547), regarding certain exempt organizations with nondeductible lobbying expenditures, is $101 or less.

.33 Notice of Large Gifts Received from Foreign Persons . For taxable years beginning in 2010, recipients of gifts from certain foreign persons may be required to report these gifts under § 6039F if the aggregate value of gifts received in a taxable year exceeds $14,165.

.34 Persons Against Whom a Federal Tax Lien Is Not Valid . For calendar year 2010, a federal tax lien is not valid against (1) certain purchasers under § 6323(b)(4) who purchased personal property in a casual sale for less than $1,380, or (2) a mechanic’s lienor under § 6323(b)(7) that repaired or improved certain residential property if the contract price with the owner is not more than $6,890.

.35 Property Exempt from Levy . For calendar year 2010, the value of property exempt from levy under § 6334(a)(2) (fuel, provisions, furniture, and other household personal effects, as well as arms for personal use, livestock, and poultry) cannot exceed $8,250. The value of property exempt from levy under § 6334(a)(3) (books and tools necessary for the trade, business, or profession of the taxpayer) cannot exceed $4,120.

.36 Interest on a Certain Portion of the Estate Tax Payable in Installments . For an estate of a decedent dying in calendar year

November 9, 2009 624 2009–45 I.R.B.

Spanish-language returns or returns for U.S. possessions.

.07 For provisions relating to the time and place for filing returns, see Treas. Reg. §§ 31.6071(a)–1 and 31.6091–1, respectively.