Part III. — Internal Revenue Bulletin 2011-50

Proposed Method of Accounting for OID on a Pool of Credit Card Receivables

Notice 2011–99

Purpose

This notice provides a proposed revenue procedure in which the Internal Revenue Service (“IRS”) will allow a taxpayer to use a simplified method of accounting to allocate original issue discount (“OID”) on a pool of credit card receivables to an accrual period. The method generally allocates to an accrual period an amount of unaccrued OID that is proportional to the amount of the stated redemption price at maturity (“principal”) of the pool that is paid by cardholders during the period. The method is intended to reduce administrative burdens and controversy for taxpayers and the IRS in computing OID accruals on a pool of credit card receivables under § 1272(a)(6) of the Internal Revenue Code. This notice also requests comments on the proposed revenue procedure.

Request for Comments

The Treasury Department and the IRS request comments on all aspects of the proposed revenue procedure in this notice. Consideration will be given to any written public comments that are submitted on or before March 16, 2012. A signed original and eight (8) copies of public comments should be sent by mail to the IRS at CC:PA:LPD:PR (IRS Notice 2011–99), Room 5203, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington, DC 20044. Public comments also may be hand-delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to the Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC 20224, Attn: CC:PA:LPD:PR (IRS Notice 2011–99). Comments also may be transmitted electronically via the following e-mail address: Notice.Comments@irscounsel.treas.gov . Please include “Notice 2011–99” in the subject line of any electronic communications. All comments will be available for public inspection and copying.

Drafting Information

The principal author of this notice is Charles W. Culmer of the Office of Associate Chief Counsel (Financial Institutions and Products). For further information regarding this notice, contact Charles W. Culmer at (202) 622–3950 (not a toll-free call).

PROPOSED REVENUE PROCEDURE