Internal Revenue Bulletin 2016-24 (PDF rendition): IRS Announcements

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
EXEMPT ORGANIZATIONS
Announcement 2016–22, page 1028.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
Finding Lists begin on page ii.
Bulletin No. 2016–24
June 13, 2016

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
June 13, 2016Bulletin No. 2016–24

Part IV. Items of General Interest
Announcement 2016–22
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section 170
of the Code
Table of Contents
The Internal Revenue Service has re-
voked its determination that the organiza-
tions listed below qualify as organizations
described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date of
announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on June 6, 2016 and
would end on the date the court first de-
termines the organization is not described
in section 170(c)(2) as more particularly
set for in section 7428(c)(1). For individ-
ual contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This ben-
efit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.
NAME OF ORGANIZATION
Effective Date of
RevocationLOCATION
Bureau of Indigenous Muslim AffairsMay 15, 2014Elizabeth, NJ
Operation Reach, Inc.January 1, 2012New Orleans, LA
Texas Highway Patrol MuseumJanuary 1, 2015Austin, TX
June 13, 2016Bulletin No. 2016–24
1028

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2016–24June 13, 2016
i

Numerical Finding List
1
Bulletins 2016–1 through 2016–24
Announcements:
2016-1, 2016-3 I.R.B.283
2016-2, 2016-3 I.R.B.283
2016-3, 2016-4 I.R.B.294
2016-4, 2016-6 I.R.B.313
2016-5, 2016-8 I.R.B.356
2016-6, 2016-10 I.R.B.409
2016-7, 2016-8 I.R.B.356
2016-8, 2016-9 I.R.B.367
2016-9, 2016-9 I.R.B.367
2016-10, 2016-9 I.R.B.367
2016-11, 2016-10 I.R.B.411
2016-12, 2016-16 I.R.B.589
2016-13, 2016-13 I.R.B.514
2016-14, 2016-14 I.R.B.535
2016-15, 2016-17 I.R.B.636
2016-16, 2016-18 I.R.B.697
2016-17, 2016-20 I.R.B.854
2016-18, 2016-19 I.R.B.741
2016-19, 2016-19 I.R.B.741
2016-20, 2016-21 I.R.B.991
2016-22, 2016-24 I.R.B.1028
Notices:
2016-1, 2016-2 I.R.B.265
2016-2, 2016-2 I.R.B.265
2016-3, 2016-3 I.R.B.278
2016-4, 2016-3 I.R.B.279
2016-5, 2016-6 I.R.B.302
2016-6, 2016-4 I.R.B.287
2016-7, 2016-5 I.R.B.296
2016-8, 2016-6 I.R.B.304
2016-9, 2016-6 I.R.B.306
2016-10, 2016-6 I.R.B.307
2016-11, 2016-6 I.R.B.312
2016-12, 2016-6 I.R.B.312
2016-13, 2016-7 I.R.B.314
2016-14, 2016-7 I.R.B.315
2016-15, 2016-13 I.R.B.486
2016-16, 2016-7 I.R.B.318
2016-17, 2016-9 I.R.B.358
2016-18, 2016-9 I.R.B.359
2016-19, 2016-9 I.R.B.362
2016-20, 2016-9 I.R.B.362
2016-21, 2016-12 I.R.B.465
2016-22, 2016-13 I.R.B.488
2016-23, 2016-13 I.R.B.490
2016-24, 2016-13 I.R.B.492
2016-25, 2016-13 I.R.B.493
2016-26, 2016-14 I.R.B.533
2016-27, 2016-15 I.R.B.576
2016-28, 2016-15 I.R.B.576
2016-29, 2016-18 I.R.B.673
2016-30, 2016-18 I.R.B.676
Notices:—Continued
2016-31, 2016-23 I.R.B.1025
2016-32, 2016-21 I.R.B.878
2016-33, 2016-22 I.R.B.1013
2016-34, 2016-22 I.R.B.1016
Proposed Regulations:
REG-103380-05, 2016-16 I.R.B.614
REG-118867-10, 2016-10 I.R.B.411
REG-147310-12, 2016-7 I.R.B.336
REG-150349-12, 2016-11 I.R.B.440
REG-138344-13, 2016-4 I.R.B.294
REG-123867-14, 2016-12 I.R.B.484
REG-125761-14, 2016-7 I.R.B.322
REG-135734-14, 2016-18 I.R.B.712
REG-135734-14, 2016-20 I.R.B.854
REG-100861-15, 2016-8 I.R.B.356
REG-108060-15, 2016-17 I.R.B.636
REG-109822-15, 2016-14 I.R.B.535
REG-114307-15, 2016-21 I.R.B.1006
REG-127199-15, 2016-21 I.R.B.1007
REG-127561-15, 2016-21 I.R.B.991
REG-127923-15, 2016-12 I.R.B.473
REG-129067-15, 2016-10 I.R.B.421
REG-133673-15, 2016-18 I.R.B.697
REG-134122-15, 2016-7 I.R.B.334
REG-101701-16, 2016-9 I.R.B.368
Revenue Procedures:
2016-1, 2016-1 I.R.B.1
2016-2, 2016-1 I.R.B.102
2016-3, 2016-1 I.R.B.126
2016-4, 2016-1 I.R.B.142
2016-5, 2016-1 I.R.B.188
2016-6, 2016-1 I.R.B.200
2016-7, 2016-1 I.R.B.239
2016-8, 2016-1 I.R.B.243
2016-10, 2016-2 I.R.B.270
2016-11, 2016-2 I.R.B.274
2016-13, 2016-4 I.R.B.290
2016-14, 2016-9 I.R.B.365
2016-15, 2016-11 I.R.B.435
2016-16, 2016-10 I.R.B.394
2016-17, 2016-11 I.R.B.436
2016-18, 2016-17 I.R.B.635
2016-19, 2016-13 I.R.B.497
2016-20, 2016-13 I.R.B.499
2016-21, 2016-14 I.R.B.533
2016-22, 2016-15 I.R.B.577
2016-23, 2016-16 I.R.B.581
2016-24, 2016-18 I.R.B.677
2016-25, 2016-18 I.R.B.678
2016-26, 2016-22 I.R.B.1018
2016-27, 2016-19 I.R.B.725
2016-28, 2016-20 I.R.B.853
2016-29, 2016-21 I.R.B.880
2016-30, 2016-21 I.R.B.981
2016-31, 2016-21 I.R.B.988
2016-32, 2016-22 I.R.B.1019
Revenue Rulings:
2016-1, 2016-2 I.R.B.262
2016-2, 2016-4 I.R.B.284
2016-3, 2016-3 I.R.B.282
2016-4, 2016-6 I.R.B.299
2016-5, 2016-8 I.R.B.344
2016-6, 2016-14 I.R.B.519
2016-7, 2016-10 I.R.B.391
2016-8, 2016-11 I.R.B.426
2016-9, 2016-14 I.R.B.530
2016-10, 2016-15 I.R.B.545
2016-11, 2016-19 I.R.B.717
2016-13, 2016-23 I.R.B.1022
Treasury Decisions:
9745, 2016-2 I.R.B.256
9746, 2016-14 I.R.B.515
9748, 2016-8 I.R.B.347
9749, 2016-10 I.R.B.373
9750, 2016-10 I.R.B.374
9751, 2016-10 I.R.B.379
9752, 2016-10 I.R.B.385
9753, 2016-11 I.R.B.426
9754, 2016-11 I.R.B.432
9755, 2016-12 I.R.B.442
9756, 2016-12 I.R.B.450
9757, 2016-12 I.R.B.462
9759, 2016-15 I.R.B.545
9760, 2016-15 I.R.B.564
9761, 2016-20 I.R.B.743
9762, 2016-19 I.R.B.718
9763, 2016-20 I.R.B.800
9764, 2016-20 I.R.B.803
9765, 2016-20 I.R.B.814
9766, 2016-21 I.R.B.855
9767, 2016-21 I.R.B.857
9768, 2016-21 I.R.B.862
9769, 2016-23 I.R.B.1020
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–27 through 2015–52 is in Internal Revenue Bulletin
2015–52, dated December 28, 2015.
June 13, 2016Bulletin No. 2016–24
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2016–1 through 2016–24
Announcements:
2007-21
Modified by
Ann. 2016-1, 2016-3 I.R.B.283
Notices:
2005-50
Modified by
Notice 2016-2, 2016-2 I.R.B.265
2007-59
Revoked by
Notice 2016-16, 2016-7 I.R.B.318
2013-29
Clarified by
Notice 2016-31, 2016-23 I.R.B.1025
2013-46
Clarified by
Notice 2016-31, 2016-23 I.R.B.1025
2013-54
Supplemented by
Notice 2016-17, 2016-9 I.R.B.358
2014-79
Superseded by
Notice 2016-1, 2016-2 I.R.B.265
2015-25
Modified by
Notice 2016-31, 2016-23 I.R.B.1025
2015-52
Supplemented by
Notice 2016-17, 2016-9 I.R.B.358
2015-87
Supplemented by
Notice 2016-17, 2016-9 I.R.B.358
2016-60
Modified by
Notice 2016-31, 2016-23 I.R.B.1025
Revenue Procedures:
1987-24
Superseded by
Rev. Proc. 2016-22, 2016-15 I.R.B.577
2003-36
Superseded by
Rev. Proc. 2016-19, 2016-13 I.R.B.497
Revenue Procedures:—Continued
2009-14
Modified by
Rev. Proc. 2016-30, 2016-21 I.R.B.981
2009-14
Superseded by
Rev. Proc. 2016-30, 2016-21 I.R.B.981
2014-56
Superseded by
Rev. Proc. 2016-20, 2016-13 I.R.B.499
2014-64
Supplemented by
Rev. Proc. 2016-18, 2016-17 I.R.B.635
2015-1
Superseded by
Rev. Proc. 2016-2, 2016-1 I.R.B.1
2015-2
Superseded by
Rev. Proc. 2016-2, 2016-1 I.R.B.102
2015-3
Superseded by
Rev. Proc. 2016-3, 2016-1 I.R.B.126
2015-5
Superseded by
Rev. Proc. 2016-5, 2016-1 I.R.B.142
2015-7
Superseded by
Rev. Proc. 2016-7, 2016-1 I.R.B.188
2015-8
Superseded by
Rev. Proc. 2016-8, 2016-1 I.R.B.200
2015-9
Superseded by
Rev. Proc. 2016-5, 2016-1 I.R.B.239
2015-10
Superseded by
Rev. Proc. 2016-10, 2016-2 I.R.B.270
2015-14
Amplified by
Rev. Proc. 2016-29, 2016-21 I.R.B.880
2015-14
Modified by
Rev. Proc. 2016-29, 2016-21 I.R.B.880
2015-19
Amplified by
Rev. Proc. 2016-23, 2016-16 I.R.B.581
Revenue Procedures:—Continued
2015-19
Modified by
Rev. Proc. 2016-23, 2016-16 I.R.B.581
2015-22
Superseded by
Rev. Proc. 2016-8, 2016-01 I.R.B.243
2015-34
Modified by
Rev. Proc. 2016-27, 2016-19 I.R.B.725
2015-34
Supplemented by
Rev. Proc. 2016-27, 2016-19 I.R.B.725
2015-50
Supplemented by
Rev. Proc. 2016-18, 2016-17 I.R.B.635
2015-53
Modified by
Rev. Proc. 2016-11, 2016-2 I.R.B.274
2016-1
Modified by
Rev. Proc. 2016-30, 2016-21 I.R.B.981
Revenue Rulings:
2005-3
Modified by
Rev. Rul. 2016-8, 2016-11 I.R.B.426
2008-15
Revoked by
Rev. Rul. 2016-3, 2016-3 I.R.B.282
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–27 through 2015–52 is in Internal Revenue Bulletin
2015–52, dated December 28, 2015.
Bulletin No. 2016–24June 13, 2016
iii

INTERNAL REVENUE BULLETIN
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