ITB 11-30: Extension of Interim Guidance on Modification of Section 833 for Blue Cross Blue Shield and Other Organizations

Insurance Tax Bulletin

The IRS recently released Notice 2011-51, which extends previously issued interim guidance (Notice 2010 -79) on the interpretation and application of tax code section 833(c)(5). Section 833(c)(5) was enacted under Section 9016 of the Patient Protection and Affordable Care Act ("PPACA") and is applicable to any taxable year beginning in 2010. Notice 2011-51 extends the interim guidance it provided in Notice 2010-79 for an additional tax year - the first tax year beginning after December 31, 2010.

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