Part IV. Items of General Interest

US-Belgium Agreement on Pension Plans under Treaty Article 17

Announcement 2010–27

The following is a copy of the Competent Authority Agreement entered into by the competent authorities of the United States of America and Belgium with respect to the types of pension plans established in either Contracting State that will be deemed to generally correspond to a pension plan recognized for tax purposes in the other Contracting State as required by paragraphs 7 and 9 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of the Convention Between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Brussels on November 27, 2006.

The text of the Competent Authority Agreement is as follows:

COMPETENT AUTHORITY

AGREEMENT

The competent authorities of the United States and Belgium hereby enter into the following agreement (the “Agreement”) regarding the types of pension plans established in either Contracting State that will be deemed to generally correspond to a pension plan recognized for tax purposes in the other Contracting State as required by paragraphs 7 and 9 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of the Convention Between the Government of the United States of America and the Gov

ernment of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income signed at Brussels on November 27, 2006 (the “Treaty”). The Agreement is entered into under paragraph 3 of Article 24 (Mutual Agreement Procedure).

The competent authorities agree as follows:

1. Belgian Pensions For purposes of paragraphs 7 and 9 of Article 17, the following types of pension plans established in Belgium will be deemed to generally correspond to a pension plan recognized for tax purposes in the United States: a. a qualified complementary retirement benefit arrangement for purposes of Article 52, 3°, b, of the Code of Income Taxes (Code des Impôts sur les revenues 1992), b. a qualified complementary retirement benefit arrangement for purposes of Article 52, 7° bis, of the Code on Income taxes (Code des Impôts sur les revenues 1992), c. a qualified complementary retirement benefit arrangement for purposes of Article 59, of the Code of Income Taxes (Code des Impôts sur les revenues 1992), d. a qualified complementary retirement benefit arrangement for purposes of Article 145–1, 1°, of the Code of Income Taxes (Code des Impôts sur les revenues 1992), and e. a qualified complementary retirement benefit arrangement for purposes of Article 145–3, of the Code of Income Taxes (Code des Impôts sur les revenues 1992).

2. US Pensions For purposes of paragraphs 7 and 9 of Article 17, the following types of pension plans established in the United States will be deemed to generally correspond to a pension plan recognized for tax purposes in Belgium: a. a qualified plan under section 401(a) of the Internal Revenue Code (including a Code section 401(k) arrangement), b. an individual retirement plan (including an individual retirement plan that is part of a simplified employee pension plan that satisfies Code section 408(k)), an individual retirement account, an individual retirement annuity, a Code section 408(p) account, and a Roth IRA under Code section c. a Code section 403(a) qualified annuity plan, d. a Code section 403(b) plan, e. a Code section 457(b) plan, and f. the Thrift Savings Plan (Code section 7701(j)).

The listing above is not intended to be exclusive. Any U.S. or Belgian pension plan of a type not mentioned above, including any type of plan established pursuant to legislation enacted after the date of signature of this Agreement, or any participant in a type of plan not mentioned above, may ask the competent authority of the other Contracting State for a determination that the plan generally corresponds to a pension plan recognized for tax purposes in that other State.

Agreed to by the undersigned competent authorities on January 14, 2010:

/s/ 1-14-2010 /s/ 11-20-2009

Douglas W. O’Donnell Date U.S. Competent Authority

Sandra Knaepen Date Belgian Competent Authority

2010–18 I.R.B. 657 May 3, 2010

Furnishing Identifying Number of Tax Return Preparer; Hearing

Announcement 2010–33

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of public hearing on proposed rulemaking.

SUMMARY: This document provides notice of public hearing on a notice of proposed rulemaking (REG–134235–08, 2010–16 I.R.B. 596) providing guidance to tax return preparers on furnishing an identifying number on tax returns and claims for refund of tax that they prepare.

DATES: The public hearing is being held on Thursday, May 6, 2010, at 1:30 p.m. The IRS must receive outlines of the topics to be discussed at the hearing by Thursday, April 29, 2010.

ADDRESSES: The public hearing is being held in room 2615, Internal Revenue Building, 1111 Constitution Avenue, NW, Washington, DC. Send submissions to: CC:PA:LPD:PR (REG–134235–08), room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washing

ton, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–134235–08), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW, Washington, DC. Alternatively, taxpayers may submit electronic outlines of oral comments via the Federal eRulemaking Portal at http://www.regulations.gov .

FOR FURTHER INFORMATION CONTACT: Concerning the regulations, Stuart Murray at (202) 622–4940 (not a toll-free number); concerning submissions of comments, the hearing, and/or to be placed on the building access list to attend the hearing, Richard A. Hurst at Richard.A.Hurst@irscounsel.treas.gov .

SUPPLEMENTARY INFORMATION: The subject of the public hearing is the notice of proposed rulemaking (REG–134235–08) that was published in the Federal Register on Friday, March 26, 2010 (75 FR 14539).

Persons, who wish to present oral comments at the hearing that submitted written comments, must submit an outline of the topics to be discussed and the amount of time to be devoted to each topic (signed original and eight (8) copies) by Thursday, April 29, 2010.

A period of 10 minutes is allotted to each person for presenting oral comments. After the deadline for receiving outlines has passed, the IRS will prepare an agenda containing the schedule of speakers. Copies of the agenda will be made available, free of charge, at the hearing or in the Freedom of Information Reading Room (FOIA RR) (Room 1621) which is located at the 11th and Pennsylvania Avenue NW entrance, 1111 Constitution Avenue, NW, Washington, DC.

Because of access restrictions, the IRS will not admit visitors beyond the immediate entrance area more than 30 minutes before the hearing starts. For information about having your name placed on the building access list to attend the hearing, see the FOR FURTHER INFORMATION CONTACT section of this document.

Approved February 18, 2010.

LaNita Van Dyke, Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration).

(Filed by the Office of the Federal Register on April 21, 2010, 8:45 a.m., and published in the issue of the Federal Register for April 22, 2010, 75 F.R. 20941)

May 3, 2010 658 2010–18 I.R.B.