Internal Revenue Bulletin 2015-30 (PDF rendition): IRS Notices

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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.
INCOME TAX
Notice 2015– 47, page 76.
The Listing Notice applies to a type of structured financial
transaction in which a taxpayer attempts to defer and treat
ordinary income and short-term capital gain as long-term cap-
ital gain. The contract is denominated as an option contract
that references a basket of actively traded personal property
(i.e., securities). The contract allows the taxpayer to trade the
securities referenced in the contract while the contract pur-
portedly remains open, and the taxpayer does so. Conse-
quently, option treatment is not warranted, and the income
deferral and conversion to long-term capital gain is improper.
The transaction described in the Listing Notice is similar to a
transaction described in a companion Transaction of Interest
Notice (Notice 2015–48); each of the Notices makes it clear
that if a transaction is identified by both Notices, it is treated as
a Listed Transaction.
Notice 2015– 48, page 77.
The Transaction of Interest Notice applies to a type of struc-
tured financial transaction in which a taxpayer attempts to
defer and treat ordinary income and short-term capital gain as
long-term capital gain. The transaction may be denominated as
an option, notional principal contract, or forward contract. The
contract may reference assets that are not actively traded,
such as interests in hedge funds, and the taxpayer has the right
to change the assets in the referenced basket. The taxpayer’s
ability to control the assets in the basket raises the issue of
whether the form of the transaction should be respected, and,
thus, whether the income deferral and conversion to long-term
capital gain is improper. The transaction described in the
notice is similar to a transaction described in a companion
Listing Notice (Notice 2015–47); each of the Notices makes it
clear that if a transaction is identified by both Notices, it is
treated as a Listed Transaction.
EMPLOYEE PLANS
Notice 2015– 49, page 79.
This notice informs taxpayers that the Treasury Department
and the IRS intend to amend the required minimum distribution
regulations under § 401(a)(9) of the Internal Revenue Code to
address the use of lump sum payments to replace annuity
payments being paid by a qualified defined benefit pension
plan. The regulations, as amended, will provide that qualified
defined benefit plans generally are not permitted to replace any
joint and survivor, single life, or other annuity currently being
paid with a lump sum payment or other accelerated form of
distribution. The Treasury Department and the IRS intend that
these amendments to the regulations will apply as of July 9,
2015, except with respect to certain accelerations of annuity
payments described in the notice.
Notice 2015–50, page 81.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for July
2015 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for July 2015, and the 30-year Treasury
rates. These rates reflect the application of § 430(h)(2)(C)(iv),
which was added by the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP–21) and amended by
section 2003 of the Highway and Transportation Funding Act of
2014 (HATFA).
Finding Lists begin on page ii.
Bulletin No. 2015–30
July 27, 2015

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.
July 27, 2015Bulletin No. 2015–30

Part III. Administrative, Procedural, and Miscellaneous
Listing Notice – Basket
Option Contracts
Notice 2015– 47
The Treasury Department and the In-
ternal Revenue Service (the “IRS”) are
aware of a type of structured financial
transaction, described below, in which a
taxpayer attempts to defer income recog-
nition and convert short-term capital gain
and ordinary income to long-term capital
gain using a contract denominated as an
option contract. The Treasury Department
and the IRS believe this transaction (the
“basket option contract”) is a tax avoid-
ance transaction. This notice identifies the
basket option contract and substantially
similar transactions as listed transactions
for purposes of § 1.6011– 4(b)(2) of the
Income Tax Regulations and §§ 6111 and
6112 of the Internal Revenue Code (“the
Code”). This notice also alerts persons
involved in these transactions about cer-
tain responsibilities that may arise from
their involvement with the basket option
contract.
SECTION 1. BACKGROUND
In a basket option contract, a taxpayer
(“T”), typically a hedge fund or a high
net-worth individual, enters into a contract
that is denominated as an option with a
counterparty (“C”), typically a bank, to
receive a return based on the performance
of a notional basket of referenced actively
traded personal property (the “reference
basket”). T or a designee named by T will
either determine the assets that comprise
the reference basket or design or select a
trading algorithm that determines the as-
sets. While the basket option contract re-
mains open, T
1
has the right to request
changes in the assets in the reference bas-
ket or the specified trading algorithm.
2
The terms of the basket option contract
also permit C to reject certain changes
requested by T to the assets in the refer-
ence basket. C, however, generally ac-
cepts all or nearly all of the changes re-
quested by T.
When the basket option contract is en-
tered into, T typically makes an upfront
cash payment to C of between 10 and 40
percent of the value of the assets in the
reference basket. To manage its risk under
the basket option contract, C typically ac-
quires substantially all of the assets in the
reference basket at the inception of the
contract and acquires and disposes of as-
sets during the term of the contract ei-
ther when T changes the assets in the
reference basket or the trading algo-
rithm provides for such changes. C gen-
erally supplies the additional cash re-
quired to purchase the assets in the
reference basket. The assets in the ref-
erence basket would typically generate
ordinary income if held directly by T,
and short-term trading gains and losses
if purchases and sales of the assets were
carried out directly by T.
The basket option contract has a stated
term of more than one year but contains
provisions that in effect allow either party to
terminate the contract at any time with
proper notice. The amount that T receives
upon settlement of the basket option con-
tract is based on the performance of the
assets in the reference basket. A common
payout formula on the basket option con-
tract entitles T to a return equal to its upfront
payment, plus net basket gain or minus net
basket loss. The net basket gain or net bas-
ket loss includes net changes in the values of
the assets in the reference basket, together
with interest, dividend, and other periodic
income on the assets, reduced by a fee paid
to compensate C for participating in and
financing the transaction. The basket option
contract typically includes a provision auto-
matically terminating the contract if the
value of the reference basket approaches the
amount of the upfront payment. Thebasket
option contract also may permit or require T to
provide additional collateral or otherwise re-
duce risk in the reference basket if the refer-
ence basket reaches a specified level of risk.
The basket option contract typically
contains other safeguards to minimize the
economic risk to C. For example, C may
terminate the basket option contract if T
violates investment guidelines that are
part of the contract. C typically holds
rights associated with the legal title to the
assets and positions in the reference bas-
ket, including voting rights and the rights
to commingle, lend, or otherwise use
those assets without notice to T.
T takes the position that short-term gains
and interest,dividend, and other ordinary
periodic income from the performance
of the reference basket are deferred until
the basket option contract terminates
and, if the basket option contract is held
for more than one year, that the entire
gain is treated as long-term capital gain.
The Treasury Department and the IRS
are concerned that taxpayers are using
basket option contracts to inappropriately
defer income recognition and convert or-
dinary income and short-term capital gain
into long-term capital gain. In some cases,
taxpayers are mischaracterizing a transac-
tion as an option to avoid application of
§ 1260, U.S. tax liability under §§ 871 and
881, and withholding and reporting obliga-
tions under Chapters 3 and 4 of the Code.
Therefore, the Treasury Department and the
IRS are identifying basket option contracts
and substantially similar transactions as
listed transactions.
The IRS may assert one or more argu-
ments to challenge the parties’ tax char-
acterization of a basket option contract,
including: (1) that C, in substance, holds
the assets in the reference basket as an
agent of T and that T is the beneficial
owner of the assets for tax purposes; (2)
that the basket option contract is not an
option for tax purposes; (3) that changes
to the assets in the reference basket during
the year materiallymodify the basket op-
tion contract and result in taxable disposi-
tions of the contract under § 1001 through-
out the term of the contract; and (4) that T
actually owns separate contractualrights
with respect to each asset in the refer-
ence basket such that each change to the
assets in the basket results in a taxable dis-
position of a contractual right under § 1001
1
When used in this sentence and subsequently with respect to identifying the assets in the reference basket or the trading algorithm, references to “T”include T’s designee.
2
For purposes of this Notice, a change in the assets in the reference basket as a result of events outside of the control of T (such as a change in the notional securities in the reference basket
due to a stock split or a merger of existing companies) is not treated as a change requested by T.
July 27, 2015Bulletin No. 2015–30
76

with respect to the asset affected by the
change. The IRS may assert other argu-
ments supporting the conclusion that T is
the beneficial owner of the assets in the
reference basket for tax purposes.
SECTION 2. LISTED TRANSACTIONS
.01Transactions Identified as Listed
Transactions
A transaction is the same as, or sub-
stantially similar to, the transaction iden-
tified in this notice if (1) the transaction is
denominated as an option contract; (2)
substantially all of the assets in the refer-
ence basket primarily consist of actively
traded personal property as defined under
§ 1.1092(d)–1(a); (3) the purchaser of the
option or the purchaser’s designee either
have the right to (a) determine the assets in
the reference basket both at the inception of
the transaction and periodically over the
term of the transaction or (b) select or use a
specified trading algorithm under its control
to determine the assets in the reference bas-
ket; and (4) the purchaser of the option, the
purchaser’s designee, or the specified trad-
ing algorithm actually changes one or more
of the assets in the reference basket during
the term of the basket option contract.
.02Effective Date
Transactions in effect on or after January
1, 2011, that are the same as, or substantially
similar to, the transaction described in this
notice are identified as “listed transactions”
for purposes of § 1.6011– 4(b)(2) and
§§ 6111 and 6112 effective July 8, 2015.
Persons engaged in transactions in ef-
fect on or after January 1, 2011, must
disclose the transactions as described in
§ 1.6011– 4 for each taxable year in which
the taxpayer participated in the transac-
tions, provided that the period of limita-
tions for assessment of tax had not ended
on or before July 8, 2015. Material advi-
sors who make a tax statement on or after
January 1, 2011, with respect to transac-
tions in effect on or after January 1, 2011,
have disclosure and list maintenance ob-
ligations under §§ 6111 and 6112. See
§§ 301.6111–3, 301.6112–1.
Independent of their classification as
listed transactions, transactions that are the
same as, or substantially similar to, the
transaction described in this notice may al-
ready be subject to the requirements of
§§ 6011, 6111, or 6112, or the regulations
thereunder. If a transaction is identified as a
listed transaction under section 2.01 of this
notice and as a transaction of interest in
Notice 2015– 48, the transaction is identified
as a listed transaction. Persons satisfying the
disclosure requirements for a listed transac-
tion under this notice are deemed to have
satisfied the disclosure requirements under
Notice 2015– 48.
.03Participation
Under § 1.6011– 4(c)(3)(i)(A), for each
year in which a transaction described in
this notice (basket option contract) is open,
the following parties are treated as partici-
pating in the listed transaction identified in
this notice: (i) the purchaser of the basket
option contract, (ii) if the purchaser of the
basket option contract is a partnership, any
general partner of the purchaser, (iii) if the
purchaser of the basket option contract is a
limited liability company, any managing
member of the purchaser, and (iv) the coun-
terparty to the basket option contract.
.04Time for Disclosure
For rules regarding the time for provid-
ing disclosure of a transaction described in
thisnotice,see§1.6011– 4(e)and
§ 301.6111–3(e). For purposes of the trans-
actions described in this notice, the 90-day
period provided in § 1.6011– 4(e)(2) for cer-
tain disclosures is extended to 120 days.
However, if, under § 1.6011– 4(e), a tax-
payer is required to file a disclosure state-
ment with respect to the listed transaction
described in this notice after July 8, 2015,
and prior to November 5, 2015, that disclo-
sure statement will be considered to be
timely filed if the taxpayer alternatively files
the disclosure with the Office of Tax Shelter
Analysis by November 5, 2015.
.05Material Advisor Threshold Amount
For the threshold amounts necessary to
become a material advisor to a listed
transaction, see § 301.6111–3(b)(3)(i)(B).
.06Penalties and Period of Limitations
Persons required to disclose these
transactions under § 1.6011– 4 who fail to
do so may be subject to the penalty under
§ 6707A. Persons required to disclose
these transactions under § 6111 who fail
to do so may be subject to the penalty
under § 6707(a). Persons required to
maintain lists of advisees under § 6112
who fail to do so (or who fail to provide
such lists when requested by the IRS) may
be subject to the penalty under § 6708(a).
In addition, the IRS may impose other
penalties on parties involved in these
transactions or substantially similar trans-
actions, including the accuracy-related
penalty under §§ 6662 or 6662A. Persons
required to disclose these transactions un-
der § 1.6011– 4 who fail to do so may be
subject to an extended period of limita-
tions under § 6501(c)(10).
The Treasury Department and the IRS
recognize that some taxpayers may have
filed tax returns taking the position that they
were entitled to the purported tax benefits of
the type of transaction described in this no-
tice. These taxpayers should take appropri-
ate corrective action and ensure that their
transactions are disclosed properly.
SECTION 3. DRAFTING
INFORMATION
The principal authors of this notice are
Anna H. Kim and Robert A. Martin of the
Office of Associate Chief Counsel (FIP).
For further information regarding this no-
tice, contact Ms. Kim at (202) 317-4431
or Mr. Martin at (202) 317-4455 (not a
toll-free number).
Transaction of Interest –
Basket Contracts
Notice 2015– 48
The Treasury Department and the In-
ternal Revenue Service (the “IRS”) are
aware of a type of structured financial trans-
action, described below, in which a taxpayer
attempts to defer income recognition and
may attempt to convert short-term capital
gain and ordinary income to long-term cap-
ital gain through a contract denominated as
an option, notional principal contract, for-
ward contract, or other derivative contract.
The Treasury Department and the IRS be-
lieve this transaction (the “basket contract”)
has a potential for tax avoidance or evasion
but lack enough information to determine
whether the transaction should be identified
specifically as a tax avoidance transaction.
This notice identifies the basket contract and
Bulletin No. 2015–30July 27, 2015
77

substantially similar transactions as transac-
tions of interest for purposes of § 1.6011–
4(b)(6) of the Income Tax Regulations and
§§ 6111 and 6112 of the Internal Revenue
Code (“the Code”). This notice also alerts
persons involved in these transactions about
certain responsibilities that may arise from
their involvement with these transactions.
SECTION 1. TRANSACTION OF
INTEREST
.01Description
In a basket contract, a taxpayer (“T”)
enters into a contract with a counterparty
(“C”) to receive a return based on the
performance of a notional basket of refer-
enced assets (the “reference basket”). The
assets that comprise the reference basket
may include (1) interests in entities that
trade securities, commodities, foreign cur-
rency, or similar property (“hedge fund in-
terests”), (2) securities, (3) commodities, (4)
foreign currency, or (5) similar property (or
positions in such property). T or a designee
named by T will either determine the assets
that comprise the reference basket or design
or select a trading algorithm that determines
the assets. While the basket contract re-
mains open, T
1
has the right to request
changes in the assets in the reference basket
or the specified trading algorithm.
2
The
terms of the basket contract also permit C to
reject certain changes requested by T to the
assets in the reference basket. C, however,
generally accepts all or nearly all of the
changes requested by T.
When the basket contract is entered
into, T typically makes an upfront cash
payment to C of between 10 and 40 per-
cent of the value of the assets in the ref-
erence basket. To manage its risk under
the basket contract, C typically acquires
all or substantially all of the assets in the
reference basket at the inception of the
contract and acquires and disposes of as-
sets during the term of the contract either
when T changes the assets in the reference
basket or the trading algorithm provides
for such changes. C generally supplies the
additional cash required to purchase the
assets in the reference basket. The assets
in the reference basket would typically
generate ordinary income if held directly
by T, and short-term gains and losses if
purchases and sales of the assets were
carried out directly by T.
The basket contract has a stated term of
more than one year or overlaps two of T’s
taxable years but contains provisions that in
effect allow either party to terminate the
contract at any time during the stated con-
tract term with proper notice. The amount
that T receives upon settlement of the basket
contract is based on the performance of the
assets in the basket. A common payout for-
mula on the basket contract entitles T to
receive back its upfront payment, plus net
basket gain or minus net basket loss. The
net basket gain or net basket loss includes
net changes in the values of the assets in the
basket, together with interest, dividend, and
other periodic income on the assets, reduced
by C’s fee for its participation in the trans-
action. The basket contract typically in-
cludes a provision automatically terminating
the contract if the amount of the net basket
loss reaches the amount of the upfront pay-
ment, giving T a cash settlement amount of
zero. The basket contract also may permit or
require T to provide additional collateral or
otherwise reduce risk in the basket if a spec-
ified level of risk is reached.
The basket contract typically contains
other safeguards to minimize the economic
risk to C. For example, C may terminate the
basket contract if T violates investment
guidelines that are part of the contract. C
typically holds the rights associated with the
legal title to the assets and positions in the
basket, including voting rights and the rights
to commingle, lend, or otherwise use the
assets in the basket without notice to T.
T takes the position that T’s short-term
trading gains and interest, dividend, and
other ordinary periodic income from the
performance of the basket are deferred until
the basket contract terminates and, if the
basket contract is held for more than one
year, that the entire gain is treated as long-
term capital gain.
The Treasury Department and the IRS
are concerned that taxpayers may be using
a basket contract to inappropriately defer
income recognition and convert ordinary
income and short-term capital gain into
long-term capital gain. In some cases, tax-
payers also may be mischaracterizing the
form of the transaction to avoid applica-
tion of § 1260, to avoid U.S. tax liability
under §§ 871, 881, and882, to avoid tax or
reporting obligations associated with invest-
ments in passive foreign investment compa-
nies, and to avoid withholding and reporting
obligations under Chapters 3 and 4 of the
Code. Therefore, the Treasury Department
and the IRS are identifying the basket con-
tract and substantially similar transactions as
transactions of interest. The Treasury De-
partmentandtheIRSbelievethat
the use of a basket contract to claim the tax
treatment specified herein may be improper.
.02Effective Date
Transactions entered into on or after
November 2, 2006, that are the same as, or
substantially similar to, the transactions
described in this notice, and in effect on or
after January 1, 2011, are identified as
transactions of interest for purposes of
§ 1.6011– 4(b)(6) and §§ 6111 and 6112
effective July 8, 2015. Persons engaged in
transactions entered into on or after No-
vember 2, 2006, and in effect on or after
January 1, 2011, must disclose the trans-
actions as described in § 1.6011– 4 for
each taxable year in which the taxpayer
participated in the transactions, provided
that the period of limitations for assess-
ment of tax had not ended on or before
July 8, 2015. Material advisors who
make a tax statement on or after January
1, 2011, with respect to transactions in
effect on or after January 1, 2011, have
disclosure and list maintenance obliga-
tions under §§ 6111 and 6112. See
§§ 301.6111–3, 301.6112–1.
Independent of their classification as
transactions of interest, transactions that are
the same as, or substantially similar to, the
transaction described in this notice may al-
ready be subject to the requirements of
§§ 6011, 6111, or 6112, or the regulations
thereunder. If a transaction is identified as a
listed transaction under section 2.01 of No-
tice 2015– 47, and as a transaction of interest
under this notice, the transaction is identi-
fied as a listed transaction. Persons satisfy-
ing the disclosure requirements for a listed
1
When used in this sentence and subsequently with respect to identifying the assets in the reference basket or the trading algorithm, references to “T”include T’s designee.
2
For purposes of this Notice, a change in the assets in the reference basket as a result of events outside of the control of T (such as a change in the notional securities in the reference basket
due to a stock split or a merger of existing companies) is not treated as a change requested by T.
July 27, 2015Bulletin No. 2015–30
78

transaction under Notice 2015– 47 are
deemed to have satisfied the disclosure re-
quirements under this notice.
When the Treasury Department and the
IRS have gathered enough information to
make an informed decision as to whether
these transactions are a tax avoidance type
of transaction, the Treasury Department
and the IRS may take one or more admin-
istrative actions, including removing the
transactions from the transactions of inter-
est category in published guidance, desig-
nating the transactions as a listed transac-
tion, or providing a new category of
reportable transactions. In the interim, in
appropriate situations, the IRS may chal-
lenge the taxpayer’s position taken as part
of these transactions under §§ 1260, 1001,
or other provisions of the Code or under judi-
cial doctrines, such as substance over form.
.03Participation
Under § 1.6011– 4(c)(3)(i)(E), for each
year in which a transaction described in this
notice (basket contract) is open, the follow-
ing parties are treated as participating in the
transaction of interest identified in this no-
tice: (i) the purchaser of the basket contract,
(ii) if the purchaser of the basket contract is
a partnership, any general partner of the
purchaser, (iii) if the purchaser of the basket
contract is a limited liability company,
any managing member of the purchaser, and
(iv) the counterparty to the basket contract.
.04Time for Disclosure
For rules regarding the time for provid-
ing disclosure of a transaction described in
thisnotice,see§1.6011– 4(e)and
§ 301.6111–3(e). For purposes of the trans-
actions described in this notice, the 90-day
period provided in § 1.6011– 4(e)(2) for cer-
tain disclosures is extended to 120 days.
However, if, under § 1.6011– 4(e), a tax-
payer is required to file a disclosure state-
ment with respect to the transaction of in-
terest described in this notice after July 8,
2015, and prior to November 5, 2015, that
disclosure statement will be considered to
be timely filed if the taxpayer alternatively
files the disclosure with the Office of Tax
Shelter Analysis by November 5, 2015.
.05Material Advisor Threshold Amount
The threshold amounts are the same
as those for listed transactions. See
§ 301.6111–3(b)(3)(i)(B).
.06Penalties
Persons required to disclose these trans-
actions under § 1.6011– 4 who fail to do so
may be subject to the penalty under
§ 6707A. Persons required to disclose these
transactions under § 6111 who fail to do so
may be subject to the penalty under
§ 6707(a). Persons required to maintain
lists of advisees under § 6112 who fail
to do so (or who fail to provide such
lists when requested by the IRS) may be
subject to the penalty under § 6708(a).
In addition, the IRS may impose other
penalties on parties involved in these
transactions or substantially similar
transactions, including the accuracy-
related penalty under §§ 6662 or 6662A.
The Treasury Department and the IRS
recognize that some taxpayers may have
filed tax returns taking the position that they
were entitled to the purported tax benefits of
the type of transaction described in this no-
tice. These taxpayers should take appropri-
ate corrective action and ensure that their
transactions are disclosed properly.
SECTION 2. DRAFTING
INFORMATION
The principal authors of this notice are
Anna H. Kim and Robert A. Martin of the
Office of Associate Chief Counsel (FIP).
For further information regarding this no-
tice, contact Ms. Kim at (202) 317-4431
or Mr. Martin at (202) 317-4455 (not a
toll-free number).
Use of Lump Sum
Payments to Replace
Lifetime Income Being
Received By Retirees
Under Defined Benefit
Pension
Notice 2015– 49
I. PURPOSE
This notice informs taxpayers that the
Treasury Department and the IRS intend to
amend the required minimum distribution
regulations under § 401(a)(9) of the Internal
Revenue Code to address the use of lump
sum payments to replace annuity payments
being paid by a qualified defined benefit
pension plan. The regulations, as amended,
will provide that qualified defined benefit
plans generally are not permitted to replace
any joint and survivor, single life, or other
annuity currently being paid with a lump
sum payment or other accelerated form of
distribution. The Treasury Department and
the IRS intend that these amendments to the
regulations will apply as of July 9, 2015,
except with respect to certain accelerations
of annuity payments described in section IV
of this notice.
II. BACKGROUND
Section 401(a)(9) prescribes required
minimum distribution rules for a qualified
plan under § 401(a). In general, under
these rules, distribution of each employ-
ee’s entire interest must begin by the re-
quired beginning date. The required be-
ginning date generally is April 1 of the
calendar year following the later of (1) the
calendar year in which the employee at-
tains age 70
1
⁄2or (2) the calendar year in
which the employee retires. However, the
ability to delay distribution until the cal-
endar year in which an employee retires
does not apply in the case of a 5-percent
owner (as defined in § 416).
If the entire interest of the employee is
not distributed by the required beginning
date, § 401(a)(9)(A) provides that the en-
tire interest of the employee must be dis-
tributed, beginning not later than the re-
quired beginning date, in accordance with
regulations, over the life of the employee
or lives of the employee and a designated
beneficiary (or over a period not extend-
ing beyond the life expectancy of the em-
ployee or the life expectancy of the em-
ployee and a designated beneficiary).
Section 401(a)(9)(B) prescribes required
minimum distribution rules that apply af-
ter the death of the employee.
Section 1.401(a)(9)– 6, A–1(a) pro-
vides that absent an applicable exception,
in order to satisfy § 401(a)(9), distributions
of an employee’s entire interest must be
paid in the form of periodic annuity pay-
ments for the employee’s or beneficiary’s
life (or the joint lives of the employee and
beneficiary) or over a period certain that is
Bulletin No. 2015–30July 27, 2015
79

no longer than a period permitted under
§ 1.401(a)(9)– 6, A–3 or A–10, as applicable
(which is approximately equal to the joint
and last survivor life expectancy of the em-
ployee and an assumed beneficiary who is
10 years younger than the employee, with
a longer period if the sole beneficiary is
the employee’s spouse and the spouse is
more than 10 years younger). The regu-
lations prohibit anychange in the period
or form of the distribution after it has com-
menced,exceptinaccordancewith
§ 1.401(a)(9)– 6, A–13. If certain conditions
are met, § 1.401(a)(9)– 6, A–13(a) permits
changes to thepayment period after pay-
ments have commenced in association
with an annuity payment increase de-
scribed in § 1.401(a)(9)– 6, A–14.
Section 1.401(a)(9)– 6, A–1(a) also
provides that the payments must be non-
increasing or may increase only as other-
wise provided, such as permitted increases
described in § 1.401(a)(9)– 6, A–14. Sec-
tion 1.401(a)(9)– 6,A–14(a)(4) permits an-
nuity payments to increase “[t]o pay in-
creased benefits that result from a plan
amendment.” In addition, § 1.401(a)(9)– 6,
A–14(a)(5) permits annuity payments to in-
crease “to allow a beneficiary to convert the
survivor portion of a joint and survivor an-
nuity into a lump sum upon the employee’s
death,” but no similar rule is provided with
respect to conversion of an employee’s an-
nuity benefit during an employee’s life or
conversion of a beneficiary’s annuity other
than upon the employee’s death.
The § 401(a)(9) provisions and related
regulations regarding pensionplan annui-
ties were crafted to provide an administrable
way to ensure that a distribution of the em-
ployee’s benefit will not be unduly tax-
deferred. For example, a pension plan can-
not permit an employee who has passed the
required beginning date to defer distribution
of the bulk of the employee’s benefit (and
thus defer the tax) until later in life, while
taking relatively small periodic benefits in
the interim. In addition, under the regula-
tions, a defined benefit pension plan cannot
permit a current annuitant to commute an-
nuity payments to a lump sum or otherwise
accelerate those payments, except in a nar-
row set of circumstances specified in the
regulations, such as in the case of retire-
ment, death, or plan termination. See
§ 1.401(a)(9)– 6, A–13(a) and (b). If a par-
ticipant has the ability to accelerate distribu-
tions at any time, then the actuarial cost
associated with that acceleration right would
result in smaller initial benefits, which con-
travenes the purpose of § 401(a)(9).
A number of sponsors of defined ben-
efit plans have amended their plans to
provide a limited period during which
certain retirees who are currently receiv-
ing joint and survivor, single life, or
other life annuity payments from those
plans may elect to convert that annuity
into a lump sum that is payable imme-
diately.
1
These arrangements are some-
times referred to as lump sum risk-
transferring programs because longevity
risk and investment risk are transferred
from the plan to the retirees. For pur-
poses of compliance with the require-
ments of § 401(a)(9), the addition of
such a right to convert a current annuity
into an immediate lump sum payment
has been treated in some instances as an
increase in benefits that is described in
§ 1.401(a)(9)– 6, A–14(a)(4) (with the
result that the annuity payment period
would be permitted to change under
§ 1.401(a)(9)– 6, A–13(a)).
III. ANTICIPATED AMENDMENTS
TO THE REGULATIONS UNDER
SECTION 401(a)(9)
The Treasury Department and the IRS
intend to amend the regulations under
§ 401(a)(9) that address the distribution of
an employee’s interest after the required
beginning date. Those regulations reflect
an intent, among other things, to prohibit,
in most cases, changes to the annuity pay-
ment period for ongoing annuity pay-
ments from a defined benefit plan, includ-
ing changes accelerating (or providing
an option to accelerate) ongoing annuity
payments. The Treasury Department
and the IRS have concluded that a broad
exception for increased benefits in
§ 1.401(a)(9)– 6, A–14(a)(4) that would
permit lump sum payments to replace
rights to ongoing annuity payments
would undermine that intent. Accord-
ingly, the Treasury Department and the
IRS intend to propose amendments to
§ 1.401(a)(9)– 6, A–14(a)(4) to provide
that the types of permitted benefit in-
creases described in that paragraph
include only those that increase the on-
going annuity payments, and do not in-
clude those that accelerate the annuity
payments. The exception for changes to
the annuity payment period provided in
§ 1.401(a)(9)– 6, A–13 (as intended to
be amended) would not permit acceler-
ation of annuity payments to which an
individual receiving annuity payments
was entitled before the amendment,
even if the plan amendment also in-
creases annuity payments.
This notice does not provide guidance
with respect to the federal tax conse-
quences of a lump sum risk-transferring
program under § 401(a)(4), 411, 415, 417,
or 436, or any other section of the Code
except for § 401(a)(9).
IV. EFFECTIVE DATE
The Treasury Department and the IRS
intend that the amendments to the regula-
tions under § 1.401(a)(9)– 6 described in
this notice will apply as of July 9, 2015.
However, the Treasury Department and
the IRS anticipate that the amendments to
the regulations will not apply to an accel-
eration of ongoing annuity payments that
is in association with a plan amendment
specifically providing for implementation
of a lump sum risk-transferring program:
(1) adopted (or specifically authorized by
a board, committee, or similar body with
authority to amend the plan) prior to July 9,
2015; (2) with respect to which a private
letter ruling or determination letter was is-
sued by the IRS prior to July 9, 2015; (3)
with respect to which a written communica-
tion to affected plan participants stating an
explicit and definite intent to implement the
lump sum risk-transferring program was re-
ceived by those participants prior to July 9,
2015; or (4) adopted pursuant to an agree-
ment between the plan sponsor and an em-
ployee representative (with which the plan
sponsor has entered into a collective bar-
gaining agreement) specifically authorizing
implementation of such a program that was
1
SeeUnited States Government Accountability Office, “PRIVATE PENSIONS Participants Need Better Information When Offered Lump Sums That Replace Their Lifetime Benefits,”
GAO-15-74, http://www.gao.gov/products/GAO-15-74; Advisory Council on Employee Welfare and Pension Benefit Plans, “Private Sector Pension De-risking and Participant Protections,”
available at http://www.dol.gov/ebsa/pdf/2013ACreport2.pdf.
July 27, 2015Bulletin No. 2015–30
80

entered into and was binding prior to July 9,
2015. An acceleration of ongoing annuity
payments that is in association with a plan
amendment implementing a lump sum risk-
transferring program that satisfies one of
these four conditions is referred to in this
notice as a “Pre-Notice Acceleration.”
The IRS will not challenge the treatment
of a Pre-Notice Acceleration as an increase
in benefits that is described in the current
§ 1.401(a)(9)– 6, A–14(a)(4) (which, as
noted, permits annuity payments to increase
to pay increased benefits that result from a
plan amendment). Accordingly, in the case
of a Pre-Notice Acceleration, the annuity
payment period will be permitted to be
changed under § 1.401(a)(9)– 6, A–13(a).
V. PRIVATE LETTER RULINGS
OR DETERMINATION LETTERS
In light of the pending guidance, any
private letter ruling or determination letter
issued by the IRS or the IRS Office of Chief
Counsel involving a plan that provides for a
lump sum risk-transferring program will
generally include a caveat expressing no
opinion as to the federal tax consequences
of the lump sum risk-transferring program.
However, the IRS and the IRS Office of
Chief Counsel may determine that the addi-
tion of a right to make a Pre-Notice Accel-
eration is an increase in benefits that is de-
scribed in the current § 1.401(a)(9)– 6,
A–14(a)(4). See section 6.09 of Rev. Proc.
2015–1, 2015–1 I.R.B. 1.
VI. DRAFTING INFORMATION
The principal authors of this notice are
Michael P. Brewer and Thomas C. Mor-
gan of the Office of the Associate Chief
Counsel (Tax Exempt and Government
Entities).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2015–50
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this no-
tice provides guidance as to the interest rate
on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I). The rates in
this notice reflect the application of
§ 430(h)(2)(C)(iv), which was added by
the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP–
21) and amended by section 2003 of the
Highway and Transportation Funding Act
of 2014, Public Law 113–159 (HATFA).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to deter-
mine a plan’s target normal cost and fund-
ing target. Under this provision, present
value is generally determined using three
24-month average interest rates (“segment
rates”), each of which applies to cash flows
during specified periods. To the extent pro-
vided under § 430(h)(2)(C)(iv),these seg-
ment rates are adjusted by the applicable
percentage of the 25-year average seg-
ment rates for the period ending Septem-
ber 30 of the year preceding the calendar
year in which the plan year begins. How-
ever, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly
yield curve in place of the segment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from June 2015
data is in Table I at the end of this notice.
The spot first, second, and third segment
rates for the month of June 2015 are,
respectively, 1.59, 4.13, and 5.20.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i) through
(iii)mustbeadjustedpursuantto
§ 430(h)(2)(C)(iv) by the applicable per-
centage of the corresponding 25-year aver-
age segment rates. Section 2003(a) of
HATFA amended the applicable percent-
ages under § 430(h)(2)(C)(iv). This change
generally applies to plan years beginning on
or after January 1, 2013. However, pursuant
to section 2003(e)(2) of HATFA, a plan
sponsor can elect not to have the amend-
ments made to the applicable percentages
by section 2003 of HATFA apply to any
plan year beginning in 2013. These elec-
tions can be made either for all purposes or,
alternatively, for purposes of determining
the adjusted funding target attainment per-
centage under § 436. The 25-year average
segment rates for plan years beginning in
2012, 2013, 2014 and 2015 were published
in Notice 2012–55, 2012–36 I.R.B. 332,
Notice 2013–11, 2013–11 I.R.B. 610,
Notice 2013–58, 2013– 40 I.R.B. 294,
and Notice 2014 –50, 2014 – 40 I.R.B. 590,
respectively.
For plan years beginning in years 2012
through 2017, pursuant to the changes
made by HATFA, the applicable mini-
mum percentage is 90% and the applica-
ble maximum percentage is 110%. These
applicable percentages are referred to as
HATFA applicable percentages. As de-
scribed in the preceding paragraph, a spe-
cial election is available for any plan year
beginning in 2013 under which this
change made by HATFA can be disre-
garded for all purposes or for limited pur-
poses. To the extent such an election is
made, the applicable minimum percentage
for a plan year beginning in 2013 is 85%
and the applicable maximum percentage
for that plan year is 115%. These applica-
ble percentages are referred to as
MAP–21 applicable percentages.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corpo-
rate bond segment rates applicable for
July 2015 without adjustment for the
25-year average segment rate limits are
as follows:
Bulletin No. 2015–30July 27, 2015
81

Applicable
Month
First
Segment
Second
Segment
Third
Segment
July 20151.314.075.10
Basedon§430(h)(2)(C)(iv)as
amended by section 2003 of HATFA, the
24-month averages applicable for July
2015 adjusted for the HATFA applicable
percentages of the corresponding 25-year
average segment rates, are as follows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates, Based on the HATFA
Applicable Percentage of 25-Year
Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2014July20154.996.326.99
2015July20154.726.116.81
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally forplan years beginning after
2007, § 431 specifies the minimum funding
requirements that apply to multiemployer
planspursuantto§412.Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) provides
that the interest rate used to calculate cur-
rent liability for this purpose must be no
more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year
Treasury securities during the four-year
period ending on the last day before the
beginning of the plan year. Notice 88 –73,
1988 –2 C.B. 383, provides guidelines for
determining the weighted average interest
rate. The rate of interest on 30-year Trea-
sury securities for June 2015 is 3.11 per-
cent. The Service determined this rate as
the average of the daily determinations of
yield on the 30-year Treasury bond ma-
turing in May 2045. For plan years begin-
ning in the month shown below, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rate used to calculate
current liability are as follows:
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
July20153.182.863.34
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for June 2015 are
as follows:
First
Segment
Second
Segment
Third
Segment
1.594.135.20
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-8719 or Tony
Montanaro at 202-317-8698 (not toll-free
calls).
July 27, 2015Bulletin No. 2015–30
82

Table I
Monthly Yield Curve for June 2015
Derived from June 2015 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturity Yield
0.50.4320.54.8740.55.2460.55.3780.55.44
1.00.7621.04.8941.05.2561.05.3881.05.44
1.51.0621.54.9041.55.2561.55.3881.55.44
2.01.3322.04.9242.05.2662.05.3882.05.44
2.51.5722.54.9342.55.2662.55.3882.55.44
3.01.7823.04.9543.05.2763.05.3883.05.45
3.51.9823.54.9643.55.2763.55.3983.55.45
4.02.1624.04.9844.05.2764.05.3984.05.45
4.52.3424.54.9944.55.2864.55.3984.55.45
5.02.5125.05.0045.05.2865.05.3985.05.45
5.52.6825.55.0145.55.2965.55.3985.55.45
6.02.8426.05.0246.05.2966.05.4086.05.45
6.53.0026.55.0446.55.2966.55.4086.55.45
7.03.1527.05.0547.05.3067.05.4087.05.45
7.53.2927.55.0647.55.3067.55.4087.55.46
8.03.4328.05.0748.05.3068.05.4088.05.46
8.53.5628.55.0848.55.3168.55.4088.55.46
9.03.6829.05.0949.05.3169.05.4189.05.46
9.53.7929.55.1049.55.3269.55.4189.55.46
10.03.9030.05.1050.05.3270.05.4190.05.46
10.53.9930.55.1150.55.3270.55.4190.55.46
11.04.0831.05.1251.05.3271.05.4191.05.46
11.54.1631.55.1351.55.3371.55.4191.55.46
12.04.2432.05.1452.05.3372.05.4292.05.46
12.54.3132.55.1552.55.3372.55.4292.55.47
13.04.3733.05.1553.05.3473.05.4293.05.47
13.54.4333.55.1653.55.3473.55.4293.55.47
14.04.4834.05.1754.05.3474.05.4294.05.47
14.54.5334.55.1754.55.3474.55.4294.55.47
15.04.5735.05.1855.05.3575.05.4395.05.47
15.54.6135.55.1955.55.3575.55.4395.55.47
16.04.6536.05.1956.05.3576.05.4396.05.47
16.54.6836.55.2056.55.3676.55.4396.55.47
17.04.7137.05.2157.05.3677.05.4397.05.47
17.54.7437.55.2157.55.3677.55.4397.55.47
18.04.7638.05.2258.05.3678.05.4398.05.48
18.54.7938.55.2258.55.3678.55.4398.55.48
19.04.8139.05.2359.05.3779.05.4499.05.48
19.54.8339.55.2359.55.3779.55.4499.55.48
20.04.8540.05.2460.05.3780.05.44100.05.48
Bulletin No. 2015–30July 27, 2015
83

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. 2015–30July 27, 2015
i

Numerical Finding List
1
Bulletin 2015–27 through 2015–30
Announcements:
2015-17, 2015-28 I.R.B.67
Notices:
2015-43, 2015-29 I.R.B.73
2015-46, 2015-28 I.R.B.64
2015-47, 2015-30 I.R.B.76
2015-48, 2015-30 I.R.B.77
2015-49, 2015-30 I.R.B.79
2015-50, 2015-30 I.R.B.81
Proposed Regulations:
REG-138526-14, 2015-28 I.R.B.67
REG-102837-15, 2015-27 I.R.B.43
Revenue Procedures:
2015-34, 2015-27 I.R.B.4
2015-36, 2015-27 I.R.B.20
Revenue Rulings:
2015-15, 2015-27 I.R.B.1
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015– 01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
July 27, 2015Bulletin No. 2015–30
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–27 through 2015–30
Revenue Procedures:
2011-49
Modified by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
2011-49
Superseded by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015– 01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
Bulletin No. 2015–30July 27, 2015
iii

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