Bulletin No. 2011-18 May 2, 2011

a network asset maintenance allowance method or a units of property method. This procedure also provides procedures for obtaining automatic consent to change to either safe harbor method. A companion revenue procedure (Rev. Proc. 2011–27) provides similar safe harbor approaches that may be used for wireline network assets. Rev. Proc. 2011–14 modified.

Rev. Proc. 2011–29, page 746. This procedure provides a safe harbor election for allocating success-based fees paid in business acquisitions or reorganizations described in regulations section 1.263(a)–5(e)(3). In lieu of maintaining the documentation required by section 1.263(a)–5(f), this safe harbor permits electing taxpayers to treat 70 percent of the success-based fee as an amount that does not facilitate the transaction. The remaining portion of the fee must be capitalized as an amount that facilitates the transaction.

Announcement 2011–28, page 748. This announcement provides notice of a public hearing on proposed regulations relating to the payment of rewards under section 7623(a) of the Code and awards under section 7623(b). The guidance is necessary to clarify the definition of proceeds of amounts collected and collected proceeds under section 7623. This regulation provides needed guidance to the general public as well as officers and employees of the IRS who review claims under section 7623. A public hearing is scheduled for May 11, 2011.

(Continued on the next page)