INCOME TAX

REG–109564–10, page 852. Proposed regulations under section 704 of the Code remove section 1.704–1(b)(iii)(e) (the de minimis partner rule) because the rule may have resulted in unintended tax consequences.

Notice 2011–99, page 847. The notice provides a proposed revenue procedure in which the Service will allow a taxpayer to use a simplified proportional method of accounting for original issue discount (“OID”) on pools of credit card receivables under section 1272(a)(6) of the Code. The proportional method allocates to an accrual period an amount of unaccrued OID that is proportional to the amount of pool principal that is paid by cardholders during the period.