SECTION 10. REQUEST FOR

COMMENTS

The Treasury Department and the IRS request comments regarding the provisions described above, including, in particular, the need, if any, for guidance regarding such provisions. Comments are specifically requested regarding:

1. Any special factors the IRS should consider when establishing the procedures for applying for recognition of tax-exempt status under § 501(c)(29);

2. The proposed effective date of a Qualified Issuer’s tax exemption, as described in section 7 of this notice; and

3. Any special considerations regarding the application to Qualified Issuers of the prohibition on private inurement in § 501(c)(29)(B)(ii), the limitation on lobbying activities in § 501(c)(29)(B)(iii), the prohibition on political activities in 501(c)(29)(B)(iv), the taxation of excess benefit transactions under § 4958, and the taxation of unrelated business taxable income under § 511.

Comments should be submitted in writing on or before May 27, 2011. Please include “Notice 2011–23” on the cover page. Comments should be sent to the following address:

Internal Revenue Service CC:PA:LPD:PR (Notice 2011–23) Room 5203 P.O. Box 7604 Ben Franklin Station Washington, DC 20044

Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to:

Internal Revenue Service Courier’s Desk 1111 Constitution Ave., N.W. Washington, DC 20224 Attn: CC:PA:LPD:PR

(Notice 2011–23)

Submissions may also be sent electronically to the following e-mail address:

Notice.Comments@irscounsel.treas.gov

Please include “Notice 2011–23” in the subject line.

All comments will be available for public inspection and copying.

3. No part of the organization’s net earnings inure to the benefit of any private shareholder or individual, except as provided in § 1322(c)(4) of the Affordable Care Act (which requires profits to be used to lower premiums, improve benefits, or for other programs intended to improve the quality of health care delivered to the organization’s members);

4. No substantial part of the organization’s activities consist of carrying on propaganda, or otherwise attempting, to influence legislation; and

5. The organization does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office.