Internal Revenue Bulletin 2013-29 (PDF rendition): IRS Notices

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 201
3-29
July 15, 2013
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.
INCOME TAX
Notice 2013–41, page 60.
Eligibility for Minimum Essential Coverage for Purposes of the
Premium Tax Credit. This notice provides guidance on whether
or when, for purposes of the premium tax credit under § 36B
of the Code, an individual is eligible for minimum essential cov-
erage under certain government-sponsored health programs
or other coverage designated as minimum essential coverage.
Comments requested by August 26, 2013.
Notice 2013–42, page 61.
This notice provides relief from the § 5000A shared responsi-
bility payment for specified individuals who are eligible to enroll
in certain eligible employer-sponsored health plans with a plan
year other than a calendar year (non-calendar year plans) if the
plan year begins in 2013 and ends in 2014.
ADMINISTRATIVE
Notice 2013–44, page 62.
This notice announces that the IRS and Treasury will amend
section 301.7701–2(b)(8) effective July 1, 2013, to include a
Croatian entity (thedionicko drustvo) on the list of entities al-
ways treated as corporations under section 7701 of the Code.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th 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 poli
cy of the Service to publish in the Bulletin all sub-
stantive ru
lings necessary to promote a uniform application of
the tax laws
, including all rulings that supersede, revoke, mod-
ify, or amen
d any of those previously published in the Bulletin.
All publish
ed rulings apply retroactively unless otherwise indi-
cated. Pro
cedures relating solely to matters of internal man-
agement ar
e not published; however, statements of internal
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, identifying 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, Leg-
islation 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 Secre-
tary (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 cont
ents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
July 15, 20132013–29 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
Eligibility for Minimum
Essential Coverage for
Purposes of the Premium Tax
Credit
Notice 2013–41
PURPOSE
This notice provides guidance on
whetherorwhen,forpurposesofthepre-
mium tax credit under § 36B of the Internal
Revenue Code, an individual is eligible for
minimum essential coverage under certain
government-sponsored health programs
or other coverage designated as minimum
essential coverage.
BACKGROUND
Beginning in 2014, eligible individu-
als who purchase coverage under a qual-
ified health plan through an Affordable In-
surance Exchange are allowed a premium
tax credit under § 36B. Under § 36B and
§ 1.36B–2 of the Income Tax Regulations,
in general, an individual (who may be the
taxpayer claiming the premium tax credit
or a member of the taxpayer’s family) may
receive health insurance coverage subsi-
dized by the premium tax credit only for
months the individual is enrolled in a qual-
ified health plan through an Exchange and
is not eligible for other minimum essential
coverage. Section 5000A(f)(1)(A) pro-
vides that minimum essential coverage in-
cludes coverage under government-spon-
sored programs such as the Medicare pro-
gram under part A of title XVIII of the So-
cial Security Act, the Medicaid program
under title XIX of the Social Security Act,
the Children’s Health Insurance Program
(CHIP) under title XXI of the Social Secu-
rity Act, and the TRICARE program under
chapter 55 of title 10 U.S. Code.
Under § 5000A(f)(1)(E), the Secretary
of Health and Human Services, in coor-
dination with the Secretary of the Trea-
sury, may designate health benefits cov-
erage not specified in § 5000A as mini-
mum essential coverage. In final regula-
tions filed at the Federal Register on June
26, 2013, the Secretary of Health and Hu-
man Services (HHS) designated state high
risk pools and self-funded health coverage
offered to students by universities as min-
imum essential coverage for a 1-year tran-
sitional period in 2014 (for plan or policy
years beginning before January 1, 2015).
See 45 CFR § 156.602(a) and (e). Start-
ing with plan years beginning on or af-
ter January 1, 2015, sponsors of state high
risk pools and individual self-funded stu-
dent health plans may apply to HHS to be
recognized as minimum essential coverage
through the process outlined in 45 CFR
§ 156.604. Thus, after 2014, the provi-
sionsofthisnoticerelatingtostatehigh
risk pools and individual self-funded stu-
dent health plans apply only to the extent
specific coverage is recognized as mini-
mum essential coverage.
Section 1.36B–2(c)(2)(i) provides that
the Commissioner may define eligibility
for specific government-sponsored pro-
grams in additional published guidance.
This notice provides rules for determining
whether or when certain individuals are
eligible for minimum essential coverage
under the Medicaid, Medicare, CHIP, or
TRICARE programs for purposes of the
premium tax credit. For convenience, this
notice also provides rules for eligibility
for minimum essential coverage through
self-funded student health plans and state
high risk pools.
GUIDANCE
The following rules apply for purposes
of determining whether an individual is el-
igible for coverage in a qualified health
plan subsidized by the premium tax credit
under § 36B.
A.Disenrollment from CHIP or Medicaid
for Non-payment of Premiums
In some states, an individual who loses
CHIP coverage due to a failure to pay
premiums may not re-enroll in CHIP for
a certain period of time (lockout period).
Such an individual is treated as eligible
for CHIP and is not eligible for qualified
health plan coverage subsidized by the pre-
mium tax credit during the lockout pe-
riod. This treatment is consistent with the
treatment that would be accorded to an
employee who fails to pay the premiums
for employer-sponsored coverage and may
not re-enroll in the employer coverage un-
til the open season for the next benefit year.
An individual who is terminated from
Medicaid or CHIP for failure to pay pre-
miums is treated as eligible for Medicaid
or CHIP during any period for which the
individual would be eligible for Medicaid
or CHIP except for the failure to pay pre-
miums. See § 1.36B–2(c)(2)(ii), which re-
quires an individual who meets the crite-
ria for coverage under a government-spon-
sored program to complete the administra-
tive requirements for the coverage.
B.CHIP Waiting Period
An individual who may not enroll in
CHIP during a pre-enrollment waiting pe-
riod is treated as not eligible for CHIP cov-
erage during the waiting period. Accord-
ingly, the individual may be eligible for
qualified health plan coverage subsidized
by the premium tax credit during this pe-
riod. This rule is consistent with the rule in
§ 1.36B–2(c)(2)(i) that, for purposes of the
premium tax credit, an individual is not el-
igible for minimum essential coverage un-
der a government-sponsored program un-
til the first day of the first full month the
individual may receivebenefits under the
program. Therulealsoisconsistentwith
the rule in § 1.36B–2(c)(3)(iii)(B) allow-
ing an employee in a waiting period for
employer-sponsored coverage to receive
qualified health plan coverage subsidized
by the premium tax credit during the wait-
ing period.
C.Eligibility Based on Agency
Determination
Comments were received in response to
proposed regulations under § 36B request-
ing guidance on when individuals are eligi-
ble for a government-sponsored program if
eligibility requires a determination of dis-
ability or diagnosis of a particular disease.
These individuals are unable to determine
their eligibility for a program on the ba-
sis of readily ascertainable criteria such
as turning age 65. Final regulations (77
FR 30377, 30379) advised that the Inter-
nal Revenue Service and Treasury Depart-
ment would publish additional guidance
clarifying eligibility for government-spon-
sored programs as the result of a disease
2013–29 I.R.B.60July 15, 2013

or illness. Accordingly, this notice clari-
fies that, for purposes of the premium tax
credit, an individual is eligible for mini-
mum essential coverage under Medicaid or
Medicare in the circumstances described
below only upon a favorable determination
of eligibility by the responsible agency:
1. Medicaid coverage requiring a find-
ing of disability or blindness.
2. Medicare coverage based solely on a
finding of disability or illness.
D.Eligibility Based on Enrollment
An individual is eligible for minimum
essential coverage under the following
programs for purposes of the premium tax
credit only if the individual is enrolled
in the coverage. These programs present
administrative difficulties in determining
who is eligible for coverage. Some of
these programs, such as Medicare part A
coverage requiring payment of premiums,
receive a lower or no government subsidy,
disadvantaging individuals who could en-
roll in the coverage only at high cost and
would be forced to forgo subsidized qual-
ified health plan coverage.
1.Medicare part A coverage requiring
payment of premiums. Coverage offered
under Medicare for which the individual
must pay a premium for Medicare part A
coverage under § 1818 of the Social Secu-
rity Act.
2.State high risk pools. Health cov-
erage offered by a state under a qualified
high risk pool as defined in § 2744(c)(2) of
the Public Health Service Act, to the extent
the program is covered by a designation by
HHS as minimum essential coverage.
3.Student health plans. Self-funded
health coverage offered by a college or uni-
versity to its students, to the extent the plan
is covered by a designation by HHS as
minimum essential coverage.
4.TRICARE programs. Coverage un-
der the following TRICARE programs:
(a) The Continued Health Care Benefit
Program (10 U.S.C. 1078);
(b) Retired Reserve (10 U.S.C. 1076e);
(c) Young Adult (10 U.S.C. 1110b); and
(d) Reserve Select (10 U.S.C. 1076d).
REQUEST FOR COMMENTS
Comments are requested on the guid-
ance provided in this notice. Comments
may be submitted in writing on or be-
fore August 26, 2013. Comments should
be submitted to Internal Revenue Ser-
vice, CC:PA:LPD:PR (Notice 2013–41),
Room 5203, P.O. Box 7604, Ben Franklin
Station, Washington, DC 20044, or elec-
tronically toNotice.Comments@irscoun-
sel.treas.gov. Please include “Notice
2013–41” in the subject line of any elec-
tronic communications. Alternatively,
comments may be hand delivered between
the hours of 8:00 a.m. and 4:00 p.m. Mon-
day to Friday to CC:PA:LPD:PR (Notice
2013–41), Courier’s Desk, Internal Rev-
enue Service, 1111 Constitution Avenue
NW, Washington, D.C. All comments
will be available for public inspection and
copying.
EFFECTIVE DATE
This notice applies for taxable years
ending after December 31, 2013.
DRAFTING INFORMATION
The principal author of this notice is
Arvind Ravichandran of the Office of
the Associate Chief Counsel (Income
Tax and Accounting).For further
information regarding this notice, contact
Mr. Ravichandran at (202) 622–4920 (not
a toll-free call).
Transition Relief for
Employees and Related
Individuals Eligible to Enroll in
Eligible Employer-Sponsored
Health Plans for Non-Calendar
Plan Years that Begin in 2013
and End in 2014
Notice 2013–42
PURPOSE
This notice provides relief from the
§ 5000A shared responsibility payment for
specified individualswhoareeligibleto
enroll in certain eligible employer-spon-
sored health plans with a plan year other
than a calendar year (non-calendar year
plans) if the plan year begins in 2013 and
ends in 2014.
BACKGROUND
For each month beginning after Decem-
ber 31, 2013, § 5000A requires individuals
whoarenotexempttoeither maintain min-
imum essential coverage for themselves
and any nonexempt family members or in-
clude an individual shared responsibility
payment with their Federal income tax re-
turn. A taxpayer is liable under § 5000A
for any nonexempt individual whom the
taxpayer may claim as a dependent.
Under § 5000A(f)(2), minimum es-
sential coverage includes coverage under
an eligible employer-sponsored plan. On
February 1, 2013, the Treasury Depart-
ment and the Internal Revenue Service
(IRS) published proposed regulations un-
der § 5000A that provide that an eligible
employer-sponsored plan means, with
respect to an employee, a group health
plan (whether an insured group health
plan or a self-insured group health plan)
or group health insurance coverage of-
feredbyanemployertotheemployee
that is (i) a governmental plan (within
the meaning of section 2791(d)(8) of the
Public Health Service Act (42 U.S.C.
300gg–91(d)(8))), (ii) any other plan or
coverage offered in the small or large
group market within a State (including for
this purpose a self-insured group health
plan), or (iii) a grandfathered health plan
offeredinagroupmarket.SeeProp. Reg.
§ 1.5000A–2(c)(1) (78 FR 7314, 7325).
The proposed regulations provide that
an individual has minimum essential cov-
erage for a month in which the individual is
enrolled in and entitled to receive benefits
under a program or plan identified as min-
imum essential coverage.SeeProp. Reg.
§ 1.5000A–1(b)(1) (78 FR 7314, 7324).
Many employer-sponsored plans have a
non-calendar plan year. Generally, eligible
employer-sponsored plans do not permit
employees to enroll in the plan after the be-
ginning of a plan year (as defined in Prop.
Reg. § 54.4980H–1(a)(30), 78 FR 242)
unless certain triggering events occur, such
as a change in employment status. Without
transition relief, therefore, many individu-
als eligible to enroll in non-calendar year
eligible employer-sponsored plans would
need to enroll in eligible employer-spon-
sored plans in 2013, when § 5000A does
not yet apply, in order to maintain cover-
age under an eligible employer-sponsored
plan for months in 2014, when § 5000A
applies.
On December 28, 2012, the Treasury
Department and the IRS issued proposed
regulations under § 4980H addressing the
July 15, 2013612013–29 I.R.B.

shared responsibility of certain employers
to provide minimum essential coverage to
their full-time employees. The preamble
to the § 4980H proposed regulations pro-
vides transition relief to certain employers
that maintain non-calendar year plans as
of December 27, 2012 (the day before the
proposed regulations were issued).
1
See
Prop. Reg. § 54.4980H pmbl. (78 FR
218, 236). In general, if an applicable large
employer offers to an employee coverage
that is affordable and provides minimum
value for the first non-calendar year plan
year beginning in 2014 (2014–2015 plan
year), the employer will not be liable for a
§ 4980H assessable payment with respect
to that employee for the period prior to the
first day of the 2014–2015 plan year if the
employee was eligible to participate in the
plan as of December 27, 2012. Similar re-
lief may also be available for certain em-
ployers with respect to employees not el-
igible to participate in the plan as of De-
cember 27, 2012.
In addition, the preamble to the
§ 4980H proposed regulations provides
transition relief from the election rules
proposed in § 1.125–2 with respect to
salary reduction elections under a cafeteria
plan for an employer-provided accident
and health plan witha non-calendar year
beginning in 2013 (2013–2014 plan year).
Under that relief, employers may per-
mit employees enrolled in a plan with a
2013–2014 plan year to make new cafe-
teria plan elections for 2014. That relief
reflects the concern that an employee’s
preferences may change due to the imple-
mentation of the Affordable Care Act.See
Prop. Reg. § 54.4980H pmbl. (78 FR 218,
237).
DISCUSSION
In order to provide transition relief
during the first yearthat § 5000A applies
to individual taxpayers, an employee,
or an individual having a relationship
to the employee, who is eligible to en-
roll in a non-calendar year eligible em-
ployer-sponsored plan with a plan year
beginning in 2013 and ending in 2014
(the 2013–2014 plan year) will not be li-
able for the § 5000A shared responsibility
payment for certain months in 2014. The
transition relief begins in January 2014
and continues through the month in which
the 2013–2014 plan year ends.
The relief provided by this notice ap-
plies only for determining a taxpayer’s
§ 5000A shared responsibility payment
for not maintaining minimum essential
coverage. Any month in 2014 for which
an individual is eligible for the transition
relief provided by this notice will not be
counted in determining a continuous pe-
riod of less than 3 months for purposes
of the short coverage gap exemption de-
scribed in § 5000A(e)(4).
EXAMPLES
Example 1.Eligible for Enrollment in a Non-Cal-
endar Year Plan for the 2013–2014 Plan Year.
Tax-
payer B is unmarried and has a 5-year-old daugh-
ter, D. B and D are eligible to enroll in a non-cal-
endar year eligible employer-sponsored plan offered
by B’s employer, X, whose plan year begins on Au-
gust 1, 2013 and ends on July 31, 2014. Neither B
nor D enrolls in X’s employer-sponsored plan for the
2013–2014 plan year. Both B and D are eligible for
the transition relief provided in this notice for January
2014 through July 2014.
Example 2.Married Individuals each Eligible for
Enrollment in a Non-Calendar Year Plan of an Em-
ployer for the 2013–2014 Plan Year and in a Cal-
endar Year Plan of the Other Spouse’s Employer for
2014.
F and G are married. F and G are eligible to
enroll in a non-calendar year eligible employer-spon-
sored plan offered by F’s employer, Y, whose plan
year begins on August 1, 2013 and ends on July 31,
2014. Neither F nor G enrolls in Y’s employer-spon-
sored plan for the 2013–2014 plan year. In addition,
F and G are eligible to enroll in a calendar year el-
igible employer-sponsored plan offered by G’s em-
ployer, Z, beginning on January 1, 2014. Neither F
nor G enrolls in Z’s employer-sponsored plan for the
2014 plan year. Both F and G are eligible for the tran-
sition relief provided in this notice for January 2014
through July 2014.
DRAFTING INFORMATION
The principal author of this notice is
John B. Lovelace of the Office of Asso-
ciate Chief Counsel (Income Tax & Ac-
counting). For further information regard-
ing this notice contact Mr. Lovelace at
(202) 622–4960 (not a toll-free call).
Croatian Per Se Corporation
Notice 2013–44
SECTION 1. PURPOSE
This notice announces that the In-
ternal Revenue Service (IRS) and
the Treasury Department will amend
§301.7701–2(b)(8) of the Procedure and
Administration Regulations to add the
Croatiandionicko drustvoto the list of
entities that are always treated as corpo-
rations under section 7701 of the Internal
Revenue Code.
SECTION 2. BACKGROUND
The IRS and the Treasury Department
issued final regulations concerning the
federal tax classification of entities un-
der section 7701 on December 18, 1996
(the check-the-box regulations). See TD
8697 (1997–1 C.B. 215; 61 FR 66584)
and §§301.7701–1 through 301.7701–3.
Under the check-the-box regulations, a
business entity that is not specifically
classified as a corporation can elect its
classification for federal tax purposes
under certain circumstances. Section
301.7701–2(b)(8) provides a list of certain
foreign business entities that are always
classified as corporations for federal tax
purposes. This list is known as the per se
corporation list, and the foreign business
entities on this list are referred to as per
se corporations. The IRS and the Trea-
sury Department intend to amend the per
se corporation list in light of changes in
European Union law.
On October 8, 2001, the Council of
the European Union adopted Council Reg-
ulation 2157/2001 (2001 Official Journal
of the European Communities, L 294/1)
(the EU Regulation) to provide for a new
business entity called the European pub-
lic limited liability company, which is also
known as aSocietas Europaeaor SE. This
EU Regulation entered into force on Oc-
tober 8, 2004, and provides general rules
that govern the formation and operation
of an SE. With respect to many issues,
however, the EU Regulation defers to the
laws for a public limited liability com-
pany of the country in which the SE has
its registered office. An SE must have
1
The preamble to the § 4980H regulations refers to fiscal year plans. To clarify that “fiscal year” refers to a plan, and not a taxpayer, this notice uses the term “non-calendar year plans.” In
each case, however, the term used refers to a plan with a plan year that is not the calendar year.
2013–29 I.R.B.62July 15, 2013

a registered office in one of the Member
States of the European Economic Area,
which includes Norway, Iceland, Liecht-
enstein, and every member of the Euro-
pean Union. For further background, see
TD 9197 (2005–1 C.B. 985; 70 FR 19697)
and Notice 2004–68 (2004–2 C.B. 706).
The IRS and the Treasury Department
stated in Notice 2004–68 that the SE is
properly classified as a per se corporation
for federal tax purposes. Consequently, the
IRS and the Treasury Department issued
regulations modifying §301.7701–2(b)(8)
to include the SE on the per se corpora-
tion list. See TD 9197 (2005–1 C.B. 985;
70 FR 19697) and TD 9235 (2006–1 C.B.
338; 70 FR 74658). The IRS and the Trea-
sury Department also believe that a pub-
lic limited liability company should be in-
cluded on the per se corporation list for ev-
ery country in which an SE may have its
registered office. Thus, those regulations
also included certain public limited liabil-
ity companies organized in Member States
that do not already appear on the per se
corporation list. More recently, the IRS
and the Treasury Department issued reg-
ulations modifying §301.7701–2(b)(8) to
add the public limited liability company of
Bulgaria to the per se corporation list, be-
cause with Bulgaria’s entry into the Euro-
pean Union, the SE could have a registered
office in Bulgaria. See TD 9433 (2008–2
C.B. 1263; 37 FR 72345).
The IRS and the Treasury Department
have identified thedionicko drustvoas the
only public limited liability company of
Croatia. As of July 1, 2013, Croatia will
become a member of the European Union.
Accordingly, as of July 1, 2013, an SE will
be eligible to have its registered office in
Croatia, and an SE with a registered office
in Croatia, to a certain extent, will be sub-
ject to the public limited liability company
laws of Croatia. As a result, and consis-
tent with TD 9235, the IRS and the Trea-
sury Department believe that it is appropri-
ate to add the Croatiandionicko drustvoto
the per se corporation list.
SECTION 3. DISCUSSION
The IRS and the Treasury Depart-
ment will issue temporary and pro-
posed regulations that will modify
§301.7701–2 to include the Croatiandion-
icko drustvoon the per se corporation list
in §301.7701–2(b)(8).
SECTION 4. EFFECTIVE DATE
The temporary and proposed regula-
tions adding the Croatiandionicko drustvo
to §301.7701–2(b)(8) generally will apply
to such entities formed on or after July
1, 2013. In addition, the regulations will
apply to an entity formed before such date
from the date after July 1, 2013, on which,
in the aggregate, a 50 percent or more
interest in such entity is owned by any
person or persons who were not owners of
the entity as of July 1, 2013. For purposes
of the preceding sentence, the terminter-
estmeans: (i) in the case of a partnership,
a capital or profits interest; and (ii) in the
case of a corporation, an equity interest
measured by vote or value.
The principal author of this notice
is Ronald M. Gootzeit of the Office of
Associate Chief Counsel (International).
For further information regarding this
notice, contact Mr. Gootzeit at (202)
622–3860 (not a toll-free call).
July 15, 2013632013–29 I.R.B.

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 ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
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 withmodi-
fied,below).
Clarifiedis used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion.
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
withamplifiedandclarified, 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
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes 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 pub-
lished 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
2013–29 I.R.B.iJuly 15, 2013

Numerical Finding List
1
Bulletins 2013–27 through 2013–29
Announcements:
2013-35, 2013-27 I.R.B.46
Notices:
2013-41, 2013-29 I.R.B.60
2013-42, 2013-29 I.R.B.61
2013-44, 2013-29 I.R.B.62
Revenue Procedures:
2013-28, 2013-27 I.R.B.28
2013-32, 2013-28 I.R.B.55
Revenue Rulings:
2013-15, 2013-28 I.R.B.47
Treasury Decisions:
9620, 2013-27 I.R.B.1
9621, 2013-28 I.R.B.49
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin
2013–26, dated June 24, 2013.
July 15, 2013ii2013–29 I.R.B.

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2013–27 through 2013–29
Revenue Procedures:
81-60
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
83-59
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
86-42
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
90-52
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
96-30
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2003-48
Obsoleted in part and superseded in part by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2009-25
Pilot program discontinued by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2012-25
Obsoleted in part by
Rev. Proc. 2013-28, 2013-27 I.R.B.
28
2013-1
Amplified and modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2013-3
Amplified and modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
Treasury Decisions:
9612
Corrected by
Ann. 2013-35, 2013-27 I.R.B.
46
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin 2013–26, dated June 24, 2013.
2013–29 I.R.B.iiiJuly 15, 2013

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