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Introduction

Part I. Rulings and Decisions Under the Internal Revenue Code of 1986

Internal Revenue Bulletin 2011-5 · 2026-10-03 edition · updated 2026-10-04 · United States

Section 451.—General Rule for Taxable Year of Inclusion

Guidance is provided allowing taxpayers to defer recognizing in gross income advance payments received from the sale of gift cards that are redeemable for goods or services of the taxpayer or a third party. See Rev. Proc. 2011-18, page 443.

Section 1001.—Determi- nation of Amount of and Recognition of Gain or Loss

26 CFR 1.1001–3: Modifications of debt instruments.

This revenue procedure provides a safe harbor to real estate investment trusts (REITs) with respect to how interest on certain loans secured by real estate

that have been modified in response to default or reasonably foreseeable default will be treated for purposes of the income tests under sections 856(c)(2) and (3) of the Internal Revenue Code. The revenue procedure also provides a safe harbor regarding the treatment of certain mortgage loans for purposes of the 75 percent asset test under section 856(c)(4)(A). See Rev. Proc. 2011-16, page 440.

2011–5 I.R.B. 436 January 31, 2011

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▸Contents — Internal Revenue Bulletin 2011-5
Internal Revenue Bulletin 2011-5

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