Internal Revenue Bulletin 2021-15 (PDF rendition): IRS Announcements

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Bulletin No. 2021–15
April 12, 2021
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.
ADMINISTRATIVE
Announcement 2021-6, page 1011.
This Announcement is issued pursuant to § 521(b) of Pub.
L. 106-170, the Ticket to Work and Work Incentives Im-
provement Act of 1999, which requires the Secretary of the
Treasury to report annually to the public concerning advance
pricing agreements (APAs) and the Advance Pricing and Mu-
tual Agreement Program (APMA Program), formerly known
as the Advance Pricing Agreement Program (APA Program).
This twenty-second report describes the experience, struc-
ture, and activities of the APMA Program during calendar
year 2020.
Notice 2021-21, page 986.
This notice provides additional tax relief under section 7508A
of the Code for taxpayers affected by the Coronavirus Dis-
ease (COVID-19) emergency. Specified Federal income tax
filings and payments due on April 15, 2021, are postponed
to May 17, 2021. The filing and furnishing of specified
Forms 5498 are also postponed to June 30, 2021. Claims
for Federal income tax credit or refund that are expiring on
or after April 15, 2021, and before May 17, 2021, are also
postponed to May 17, 2021. This notice also postpones the
application date to participate in the Annual Filing Season
Program.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2021-17, page 991.
This revenue procedure provides issuers of qualified mort-
gage bonds, as defined in § 143(a) of the Internal Revenue
Code (Code), and issuers of mortgage credit certificates, as
defined in § 25(c), with (1) the nationwide average purchase
price for residences located in the United States, and (2) av-
erage area purchase price safe harbors for residences locat-
ed in statistical areas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands, American Samoa,
the Virgin Islands, and Guam.
EMPLOYEE PLANS
Notice 2021-22, page 987.
This notice sets forth updates on the corporate bond month-
ly yield curve, the corresponding spot segment rates for
March 2021 used under § 417(e)(3)(D), the 24-month av-
erage segment rates applicable for March 2021, and the
30-year Treasury rates, as reflected by the application of §
430(h)(2)(C)(iv).
INCOME TAX
Action On Decision 2021-1, page 985.
Nonacquiescence to the holding that an interest in a defined
benefit pension plan is not an asset for purposes of applying
the insolvency exclusion in I.R.C. § 108.
Announcement 2021-7, page 1061.
Announcement 2021-7 notifies taxpayers that amounts paid
for personal protective equipment for the primary purpose of
preventing the spread of the Coronavirus Disease 2019 are
amounts treated as paid for medical care under § 213(d) of
the Internal Revenue Code. As a result, these amounts are
qualified medical expenses eligible to be paid or reimbursed
without being included in gross income under health flexible
spending arrangements (health FSAs), Archer medical sav-
ings accounts (Archer MSAs), health reimbursement arrange-
ments (HRAs), or health savings accounts (HSAs). In addition,
the announcement notifies administrators of group health
plans regarding the ability to make certain plan amendments
pursuant to the announcement.
Rev. Proc. 2021-18, page 1007.
Revenue Procedure 2021-18 provides an automatic proce-
dure for a State or local government in which an empower-
ment zone is located to extend the empowerment zone des-
ignation made under section 1391(a) of the Internal Revenue
Code (Code). Specifically, this revenue procedure provides
that a State or local government that nominated an empow-
Finding Lists begin on page ii.

erment zone is deemed to extend until December 31, 2025,
the termination date designated by that State or local gov-
ernment in its empowerment zone nomination (designated
termination date), as described in section 1391(d)(1)(B). This
revenue procedure further provides the procedure for such
State or local government to decline this deemed extension
of its designated termination date.
Rev. Proc. 2021-19, page 1008.
This revenue procedure provides guidance with respect to
the United States and area median gross income figures for
use by issuers of qualified mortgage bonds under § 143(a)
of the Internal Revenue Code and issuers of mortgage credit
certificates under § 25(c) (collectively, “issuers”) in comput-
ing the income requirements under § 143(f). This revenue
procedure provides that issuers must use either (1) the in-
come figures the Department of Housing and Urban Devel-
opment (“HUD”) released most recently or (2) the income
figures HUD released immediately prior to the income figures
HUD released most recently, determined as of the date a
mortgage loan or mortgage credit certificate is committed
to a mortgagor. This revenue procedure also provides a 90-
day transition period, following the release of the HUD in-
come figures in a current calendar year, for issuers to use
the income figures HUD released during the second calendar
year prior to the current calendar year..

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 of-
ficial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, 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 sub-
stantive 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 inter-
nal management are 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 rul-
ings 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,
Legislation 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
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (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.
April 12, 2021 Bulletin No. 2021–15

Actions Relating to Court
Decisions
It is the policy of the Internal Reve­
nue Service to announce at an early date
whether it will follow the holdings in cer­
tain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on un­
appealed issues decided adverse to the
government. Generally, an Action on De­
cision is issued where its guidance would
be helpful to Service personnel working
with the same or similar issues. Unlike a
Treasury Regulation or a Revenue Ruling,
an Action on Decision is not an affirma­
tive statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclu­
sions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be
exercised in extending the recommenda­
tion of the Action on Decision to similar
cases where the facts are different. More­
over, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions.
Prior to 1991, the Service published
acquiescence or nonacquiescence only in
certain regular Tax Court opinions. The
Service has expanded its acquiescence
program to include other civil tax cases
where guidance is determined to be help­
ful. Accordingly, the Service now may
acquiesce or nonacquiesce in the holdings
of memorandum Tax Court opinions, as
well as those of the United States District
Courts, Claims Court, and Circuit Courts
of Appeal. Regardless of the court decid­
ing the case, the recommendation of any
Action on Decision will be published in
the Internal Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as ac­
quiescence, acquiescence in result only,
or nonacquiescence. Both “acquiescence”
and “acquiescence in result only” mean
that the Service accepts the holding of the
court in a case and that the Service will fol­
low it in disposing of cases with the same
controlling facts. However, “acqui escence”
indicates neither approval nor disapprov­
al of the reasons assigned by the court for
its conclusions; whereas, “acqui escence
in result only” indicates disagree ment or
concern with some or all of those reasons.
“Nonacquiescence” signifies that, although
no further review was sought, the Service
does not agree with the hold ing of the court
and, generally, will not follow the decision
in disposing of cases involving other tax­
payers. In reference to an opinion of a cir­
cuit court of appeals, a “nonacquiescence”
indicates that the Ser vice will not follow
the holding on a na tionwide basis. Howev­
er, the Service will recognize the preceden­
tial impact of the opinion on cases arising
within the venue of the deciding circuit.
The Commissioner does NOT ACQUI­
ESCE in the following decision:
Schieber v. Commissioner, T.C. Memo.
2017-32, T.C. Docket No. 21690-14.
1

1
Nonacquiescence to the holding that an interest in a defined benefit pension plan is not an asset for purposes of applying the insolvency exclusion in I.R.C. § 108.
Bulletin No. 2021–15 985 April 12, 2021

Part III
RELIEF FOR FORM 1040
FILERS AFFECTED BY
ONGOING CORONAVIRUS
DISEASE 2019 PANDEMIC
Notice 2021-21
I. PURPOSE
On March 13, 2020, the President of
the United States issued an emergency
declaration under the Robert T. Stafford
Disaster Relief and Emergency Assistance
Act in response to the ongoing Coronavi­
rus Disease 2019 (COVID­19) pandemic
(Emergency Declaration). The Emergen­
cy Declaration instructed the Secretary of
the Treasury “to provide relief from tax
deadlines to Americans who have been
adversely affected by the COVID­19
emergency, as appropriate, pursuant to 26
U.S.C. 7508A(a).” Pursuant to the Emer­
gency Declaration, this notice provides
relief under section 7508A of the Internal
Revenue Code (Code) for the persons de­
scribed in section III.A of this notice that
the Secretary of the Treasury has deter­
mined to be affected by the COVID­19
emergency.
II. BACKGROUND
Section 7508A provides the Secretary
of the Treasury or her delegate (Secretary)
with authority to postpone the time for
performing certain acts under the internal
revenue laws for a taxpayer determined by
the Secretary to be affected by a Federal­
ly declared disaster as defined in section
165(i)(5)(A) of the Code. Pursuant to sec­
tion 7508A(a), a period of up to one year
may be disregarded in determining wheth­
er the performance of certain acts is timely
under the internal revenue laws.
III. GRANT OF RELIEF
A. Taxpayers Affected by COVID-19
Emergency
The Secretary has determined that any
person with a Federal income tax return
filed on Form 1040, Form 1040­SR, Form
1040­NR, Form 1040­PR, Form 1040­SS,
or Form 1040(SP) (Form 1040 series), or
a Federal income tax payment reported on
one of these forms, that absent this notice
would be due April 15, 2021, is affected
by the COVID­19 emergency for purpos­
es of the relief described in this section III
(Affected Taxpayer). In addition, persons
who are required to file and furnish Form
5498, IRA Contribution Information,
Form 5498­ESA, Coverdell ESA Contri­
bution Information, and Form 5498­SA,
HSA, Archer MSA, or Medicare Advan­
tage MSA Information (Form 5498 series)
that absent this notice would generally be
due June 1, 2021, are Affected Taxpayers.
The Secretary has also determined that
any individual with a period of limitations
to file a claim for credit or refund of Feder­
al income tax that absent this notice would
expire on or after April 15, 2021, and be­
fore May 17, 2021 (for example, certain
individual taxpayers with claims for credit
or refund in respect of their 2017 taxable
years), is an Affected Taxpayer.
B. Postponement of Due Dates with
Respect to Certain Federal Tax
Returns and Federal Tax Payments
For an Affected Taxpayer, the due date
for filing Federal income tax returns in
the Form 1040 series and making Federal
income tax payments in connection with
one of these forms having an original due
date of April 15, 2021, is automatical­
ly postponed to May 17, 2021. Affected
Taxpayers do not have to file any form,
including Form 4868, Application for Au­
tomatic Extension of Time to File U.S.
Individual Income Tax Return, to obtain
this relief. This relief includes the filing of
all schedules, returns, and other forms that
are filed as attachments to the Form 1040
series or are required to be filed by the due
date of the Form 1040 series, including,
for example, Schedule H and Schedule
SE, as well as Forms 965­A, 3520, 5329,
5471, 8621, 8858, 8865, 8915­E, and
8938. Finally, elections that are made or
required to be made on a timely filed Form
1040 series (or attachment to such form)
will be timely made if filed on such form
or attachment, as appropriate, on or before
May 17, 2021.
As a result of the postponement of
the due date for Affected Taxpayers to
file Federal income tax returns and make
Federal income tax payments from April
15, 2021, to May 17, 2021, the period be­
ginning on April 15, 2021, and ending on
May 17, 2021, will be disregarded in the
calculation of any interest, penalty, or ad­
dition to tax for failure to file the Federal
income tax returns or to pay the Federal
income taxes postponed by this notice. In­
terest, penalties, and additions to tax with
respect to such postponed Federal income
tax filings and payments will begin to ac­
crue on May 18, 2021.
The postponement of the due date for
filing these Federal income tax returns to
May 17, 2021, also automatically post­
pones to the same date the time for Affect­
ed Taxpayers to make 2020 contributions
to their individual retirement arrangements
(IRAs and Roth IRAs), health savings ac­
counts (HSAs), Archer Medical Savings
Accounts (Archer MSAs), and Coverdell
education savings accounts (Coverdell
ESAs). This postponement also automati­
cally postpones to May 17, 2021, the time
for reporting and payment of the 10­per­
cent additional tax on amounts includible
in gross income from 2020 distributions
from IRAs or workplace­based retirement
plans.
Forms in the Form 5498 series must be
filed with the IRS and furnished to partic­
ipants and beneficiaries by the due date
specified in General Instructions for Cer­
tain Information Returns (Forms 1096,
1097, 1098, 1099, 3921, 3922, 5498, and
W­2G). Because filers of Form 5498 se­
ries are Affected Taxpayers, the due date
for filing and furnishing the Form 5498
series is postponed to June 30, 2021. The
period beginning on the original due date
of those forms and ending on June 30,
2021, will be disregarded in the calcula­
tion of any penalty for failure to file those
forms. Penalties with respect to such a
postponed filing will begin to accrue on
July 1, 2021.
The relief provided in this section III.B
for filing Federal income tax returns and
paying Federal income taxes is available
April 12, 2021 986 Bulletin No. 2021–15

Bulletin No. 2021–15 987 April 12, 2021
solely with respect to the Form 1040 se­
ries returns having an original due date of
April 15, 2021, in respect of an Affected
Taxpayer’s 2020 taxable year, and the
Form 5498 series returns that are due as
described above. Businesses and any other
type of taxpayer who file Federal income
tax returns on forms outside of the Form
1040 series are not Affected Taxpayers for
purposes of the relief described in this sec­
tion III.B.
No extension is provided in this notice
for the payment or deposit of any other
type of Federal tax, including Federal es­
timated income tax payments, or for the
filing of any Federal return other than the
Form 1040 series and the Form 5498 se­
ries for the 2020 taxable year.
C. Relief with Respect to Certain
Claims for Refund
Individuals with a period of limitations
to file a claim for credit or refund of Fed­
eral income tax expiring on or after April
15, 2021, and before May 17, 2021, have
until May 17, 2021, to file those claims
for credit or refund. This postponement is
limited to claims for credit or refund prop­
erly filed on the Form 1040 series or on a
Form 1040­X.
As a result of the postponement of the
time for individuals to file claims for cred­
it or refund of Federal income tax where
the period to file that claim expires on or
after April 15, 2021, and before May 17,
2021, the period beginning on April 15,
2021, and ending on May 17, 2021, will
be disregarded in determining whether the
filing of those claims is timely.
IV. Extension of Time to Participate in
the Annual Filing Season Program
Revenue Procedure 2014­42, 2014­
29 IRB 192, created a voluntary Annual
Filing Season Program to encourage tax
return preparers who do not have creden­
tials as practitioners under Treasury De­
partment Circular No. 230 (Regulations
Governing Practice before the Internal
Revenue Service) to complete continuing
education courses for the purpose of in­
creasing their knowledge of the law rel­
evant to Federal tax returns. Tax return
preparers who complete the requirements
in Rev. Proc. 2014­42 receive an annual
Record of Completion. Under Rev. Proc.
2014­42, applications to participate in the
Annual Filing Season Program for the
2021 calendar year must be received by
April 15, 2021. In light of the relief grant­
ed in section III of this notice, the 2021
calendar year application deadline is post­
poned to May 17, 2021.
V. CONTACT INFORMATION
The principal author of this notice is
Jennifer Auchterlonie of the Office of
Associate Chief Counsel, Procedure and
Administration. For further information
regarding this notice, you may call (202)
317­5436 (not a toll­free number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2021-22
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24­month aver­
age segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30­year 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).
This notice does not provide 24­month
average segment rates determined under
§ 430(h)(2)(C)(iv) of the Code reflecting
the modifications made by § 9706(a) of
the American Rescue Plan Act of 2021,
Pub. L. No. 117­2 (ARPA), which was en­
acted on March 11, 2021. Those rates will
be provided in future guidance.
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to sin­
gle­employer plans (except for CSEC
plans under § 414(y)) pursuant to § 412.
Section 430(h)(2) specifies the inter­
est rates that must be used to determine
a plan’s target normal cost and funding
target. Under this provision, present val­
ue is generally determined using three
24­month average interest rates (“segment
rates”), each of which applies to cash
flows during specified periods. To the ex­
tent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the ap­
plicable percentage of the 25­year average
segment rates for the period ending Sep­
tember 30 of the year preceding the cal­
endar year in which the plan year begins.
1

However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates.
Notice 2007­81, 2007­44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24­month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Con­
sistent with the methodology specified in
Notice 2007­81, the monthly corporate
bond yield curve derived from February
2021 data is in Table 2021­2 at the end
of this notice. The spot first, second, and
third segment rates for the month of Feb­
ruary 2021 are, respectively, 0.51, 2.54,
and 3.45.
The 24­month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to §
430(h)(2)(C)(iv) to be within the applica­
ble minimum and maximum percentages
of the corresponding 25­year average seg­
ment rates. The 25­year average segment
rates for plan years beginning in 2020,
and 2021 were published Notice 2019­51,
2019­41 I.R.B. 866, and Notice 2020­72,
2020­40 I.R.B. 789, respectively.
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).

April 12, 2021 988 Bulletin No. 2021–15
24­MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24­month average corporate
bond segment rates applicable for March
2021 without adjustment for the 25­year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable Month First Segment Second Segment Third Segment
March 2021 1.54 2.89 3.55
AMERICAN RESCUE PLAN ACT
25­YEAR AVERAGE SEGMENT
RATES
Section 9706(a) of ARPA changes the
25­year average segment rates and the
applicable minimum and maximum per­
centages used under § 430(h)(3)(C)(iv)
of the Code to adjust the 24­month av­
erage segment rates. Prior to this change,
the applicable minimum and maximum
percentages were 90% and 110% for a
plan year beginning in 2020, and 85%
and 115% for a plan year beginning in
2021, respectively. After this change, the
applicable minimum and maximum per­
centages are 95% and 105% for a plan
year beginning in 2020 or 2021. In addi­
tion, pursuant to this change, any 25­year
average segment rate that is less than 5%
is deemed to be 5%.
Pursuant to § 9706(c)(1) of ARPA,
these changes apply with respect to plan
years beginning on or after January 1,
2020. However, § 9706(c)(2) of ARPA
provides that a plan sponsor may elect
not to have these changes apply to any
plan year beginning before January 1,
2022.
2

The rates set forth in this notice do not
reflect the changes to § 430(h)(2)(C)(iv)
of the Code made by § 9706(a) of ARPA.
Accordingly, the adjusted 24­month aver­
age segment rates set forth in this notice
apply only for plan years for which an
election under § 9706(c)(2) of ARPA is
in effect. For a plan year for which such
an election applies, the 24­month aver­
ages applicable for March 2021, adjusted
to be within the applicable minimum and
maximum percentages of the correspond­
ing 25­year average segment rates in ac­
cordance with § 430(h)(2)(C)(iv) of the
Code, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning In
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2020March 20213.645.215.94
2021March 20213.324.795.47
30­YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to multi­
employer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full­funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) pro­
vides that the interest rate used to calcu­
late current liability for this purpose must
be no more than 5 percent above and no
more than 10 percent below the weighted
average of the rates of interest on 30­year
Treasury securities during the four­year
period ending on the last day before the
beginning of the plan year. Notice 88­73,
1988­2 C.B. 383, provides guidelines for
determining the weighted average interest
rate. The rate of interest on 30­year Trea­
sury securities for February 2021 is 2.04
percent. The Service determined this rate
as the average of the daily determinations
of yield on the 30­year Treasury bond ma­
turing in November 2050 determined each
day through February 10, 2021, and the
yield on the 30­year Treasury bond ma­
turing in February 2051 determined each
day for the balance of the month . For
plan years beginning in March 2021, the
weighted average of the rates of interest
on 30­year Treasury securities and the
permissible range of rates used to calcu­
late current liability are as follows:
Treasury Weighted Average Rates
For Plan Years
Beginning In
30-Year Treasury
Weighted Average
Permissible Range
90% to 105%
March 20212.252.03 to 2.37
2
This election may be made either for all purposes for which the amendments under § 9706 of ARPA apply or solely for purposes of determining the adjusted funding target attainment
percentage under § 436 of the Code for the plan year.

Bulletin No. 2021–15 989 April 12, 2021
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24­month
average. Notice 2007­81 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 February 2021
are as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
February 2021 0.51 2.54 3.45
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Asso­
ciate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202­317­6700 or Paul Stern at 202­317­
8702 (not toll­free numbers).

April 12, 2021 990 Bulletin No. 2021–15
Table 2021-2
Monthly Yield Curve for February 2021
Derived from February 2021 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.50.1820.53.2240.53.4860.53.5880.53.63
1.00.2321.03.2341.03.4961.03.5881.03.63
1.50.2821.53.2441.53.4961.53.5881.53.63
2.00.3522.03.2542.03.4962.03.5882.03.63
2.50.4222.53.2642.53.5062.53.5882.53.63
3.00.5123.03.2743.03.5063.03.5983.03.63
3.50.6123.53.2843.53.5063.53.5983.53.63
4.00.7224.03.2944.03.5064.03.5984.03.63
4.50.8524.53.3044.53.5164.53.5984.53.63
5.00.9825.03.3145.03.5165.03.5985.03.63
5.51.1225.53.3145.53.5165.53.5985.53.64
6.01.2626.03.3246.03.5266.03.5986.03.64
6.51.4126.53.3346.53.5266.53.6086.53.64
7.01.5627.03.3447.03.5267.03.6087.03.64
7.51.7027.53.3447.53.5267.53.6087.53.64
8.01.8428.03.3548.03.5368.03.6088.03.64
8.51.9728.53.3648.53.5368.53.6088.53.64
9.02.0929.03.3749.03.5369.03.6089.03.64
9.52.2129.53.3749.53.5369.53.6089.53.64
10.02.3230.03.3850.03.5470.03.6090.03.64
10.52.4230.53.3950.53.5470.53.6190.53.64
11.02.5131.03.3951.03.5471.03.6191.03.64
11.52.6031.53.4051.53.5471.53.6191.53.64
12.02.6732.03.4052.03.5572.03.6192.03.65
12.52.7432.53.4152.53.5572.53.6192.53.65
13.02.8033.03.4253.03.5573.03.6193.03.65
13.52.8633.53.4253.53.5573.53.6193.53.65
14.02.9034.03.4354.03.5574.03.6194.03.65
14.52.9534.53.4354.53.5674.53.6194.53.65
15.02.9935.03.4455.03.5675.03.6295.03.65
15.53.0235.53.4455.53.5675.53.6295.53.65
16.03.0536.03.4556.03.5676.03.6296.03.65
16.53.0836.53.4556.53.5676.53.6296.53.65
17.03.1037.03.4557.03.5777.03.6297.03.65
17.53.1237.53.4657.53.5777.53.6297.53.65
18.03.1438.03.4658.03.5778.03.6298.03.65
18.53.1638.53.4758.53.5778.53.6298.53.65
19.03.1839.03.4759.03.5779.03.6299.03.65
19.53.1939.53.4759.53.5779.53.6299.53.65
20.03.2040.03.4860.03.5880.03.63100.03.66

Bulletin No. 2021–15 991 April 12, 2021
26 CFR 601.601: Rules and Regulations
(Also Part 1, §§ 25, 143, 6a.103A-1(b)(4),
6a.103A-2(f)(5)).
Rev. Proc. 2021-17
SECTION 1. PURPOSE
This revenue procedure provides is­
suers of qualified mortgage bonds, as de­
fined in § 143(a) of the Internal Revenue
Code (Code), and issuers of mortgage
credit certificates, as defined in § 25(c),
with (1) the nationwide average purchase
price for residences located in the United
States, and (2) average area purchase price
safe harbors for residences located in sta­
tistical areas in each state, the District of
Columbia, Puerto Rico, the Northern Mar­
iana Islands, American Samoa, the Virgin
Islands, and Guam.
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, ex­
cept as provided in § 103(b), gross income
does not include interest on any State or
local bond. Section 103(b)(1) provides
that § 103(a) shall not apply to any pri­
vate activity bond that is not a “quali­
fied bond” within the meaning of § 141.
Section 141(e) provides, in part, that the
term “qualified bond” means any private
activity bond if such bond (1) is a quali­
fied mortgage bond under § 143, (2) meets
the volume cap requirements under § 146,
and (3) meets the applicable requirements
under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a qualified
mortgage issue. Section 143(a)(2)(A) pro­
vides that the term “qualified mortgage is­
sue” means an issue of one or more bonds
by a State or political subdivision thereof,
but only if: (i) all proceeds of the issue
(exclusive of issuance costs and a reason­
ably required reserve) are to be used to fi­
nance owner­occupied residences; (ii) the
issue meets the requirements of subsec­
tions (c), (d), (e), (f), (g), (h), (i), and (m)
(7) of § 143; (iii) the issue does not meet
the private business tests of paragraphs (1)
and (2) of § 141(b); and (iv) with respect
to amounts received more than 10 years
after the date of issuance, repayments of
$250,000 or more of principal on mort­
gage financing provided by the issue are
used by the close of the first semiannual
period beginning after the date the prepay­
ment (or complete repayment) is received
to redeem bonds that are part of the issue.
Average Area Purchase Price
.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of § 143(e) if the acquisi­
tion cost of each residence financed by
the issue does not exceed 90 percent of
the average area purchase price applicable
to such residence. Section 143(e)(5) pro­
vides that, in the case of a targeted area
residence (as defined in § 143(j)), § 143(e)
(1) shall be applied by substituting 110
percent for 90 percent.
.04 Section 143(e)(2) provides that
the term “average area purchase price”
means, with respect to any residence, the
average purchase price of single­family
residences (in the statistical area in which
the residence is located) that were pur­
chased during the most recent 12­month
period for which sufficient statistical in­
formation is available. Under §§ 143(e)(3)
and (4), respectively, separate determina­
tions of average area purchase price are to
be made for new and existing residences,
and for two­, three­, and four­family res­
idences.
.05 Section 143(e)(2) also provides that
the determination of the average area pur­
chase price shall be made as of the date
on which the commitment to provide the
financing is made or, if earlier, the date of
the purchase of the residence.
.06 Section 143(k)(2)(A) provides that
the term “statistical area” means (i) a met­
ropolitan statistical area (MSA), and (ii)
any county (or the portion thereof) that is
not within an MSA. Section 143(k)(2)(C)
further provides that if sufficient recent
statistical information with respect to a
county (or portion thereof) is unavailable,
the Secretary may substitute another area
for which there is sufficient recent statis­
tical information for such county (or por­
tion thereof). In the case of any portion
of a State which is not within a county, §
143(k)(2)(D) provides that the Secretary
may designate an area that is the equiva­
lent of a county. Section 6a.103A­1(b)(4)
(i) of the Income Tax Regulations (issued
under § 103A of the Internal Revenue
Code of 1954, the predecessor of § 143 of
the Code) provides that the term “State”
includes a possession of the United States
and the District of Columbia.
.07 Section 6a.103A­2(f)(5)(i) pro­
vides that an issuer may rely upon the
average area purchase price safe harbors
published by the Department of the Trea­
sury (Treasury Department) for the statis­
tical area in which a residence is located.
Section 6a.103A­2(f)(5)(i) further pro­
vides that an issuer may use an average
area purchase price limitation different
from the published safe harbor if the issu­
er has more accurate and comprehensive
data for the statistical area.
Qualified Mortgage Credit Certificate
Program
.08 Section 25(c) permits a State or
political subdivision thereof to establish
a qualified mortgage credit certificate
program. In general, a qualified mortgage
credit certificate program is a program
under which the issuing authority elects
not to issue an amount of private activity
bonds that it may otherwise issue during
the calendar year under § 146, and in its
place, issues mortgage credit certificates
to taxpayers in connection with the acqui­
sition of their principal residences. Sec­
tion 25(a)(1) provides, in general, that the
holder of a mortgage credit certificate may
claim a federal income tax credit equal to
the product of the credit rate specified in
the certificate and the interest paid or ac­
crued during the tax year on the remaining
principal of the indebtedness incurred to
acquire the residence. Section 25(c)(2)(A)
(iii)(III) generally provides that residenc­
es acquired in connection with the issu­
ance of mortgage credit certificates must
meet the purchase price requirements of §
143(e).
Income Limitations for Qualified
Mortgage Bonds and Mortgage Credit
Certificates
.09 Section 143(f) imposes limitations
on the income of mortgagors for whom
financing may be provided by qualified
mortgage bonds. In addition, § 25(c)(2)(A)
(iii)(IV) provides that holders of mortgage
credit certificates must meet the income
requirement of § 143(f). Generally, under

April 12, 2021 992 Bulletin No. 2021–15
§§ 143(f)(1) and 25(c)(2)(A)(iii)(IV), the
income requirement is met only if all own­
er­financing under a qualified mortgage
bond and all mortgage credit certificates
issued under a qualified mortgage credit
certificate program are provided to mort­
gagors whose family income is 115 percent
or less of the applicable median family in­
come. Section 143(f)(5), however, general­
ly provides for an upward adjustment to the
percentage limitation in high housing cost
areas. High housing cost areas are defined
in § 143(f)(5)(C) as any statistical area for
which the housing cost/income ratio is
greater than 1.2.
.10 Under § 143(f)(5)(D), the hous­
ing cost/income ratio with respect to any
statistical area is determined by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area me­
dian gross income for such area bears to
the median gross income for the United
States. The applicable housing price ratio
is the new housing price ratio (new hous­
ing average area purchase price divided
by the new housing average purchase
price for the United States) or the existing
housing price ratio (existing housing av­
erage area purchase price divided by the
existing housing average purchase price
for the United States), whichever results
in the housing cost/income ratio being
closer to 1.
Average Area and Nationwide Purchase
Price Limitations
.11 Average area purchase price safe
harbors for each state, the District of Co­
lumbia, Puerto Rico, the Northern Mari­
ana Islands, American Samoa, the Virgin
Islands, and Guam were last published in
Rev. Proc. 2020­18, I.R.B. 2020­15, 592.
.12 The nationwide average purchase
price limitation was last published in sec­
tion 4.02 of Rev. Proc. 2020­18. Guidance
with respect to the United States and area
median gross income figures that are used
in computing the housing cost/income ra­
tio described in § 143(f)(5) was published
in Rev. Proc. 2021­19, I.R.B. 2021­15 (re­
leased on March 25, 2021).
.13 This revenue procedure uses Fed­
eral Housing Administration (FHA) loan
limits for a given statistical area to calcu­
late the average area purchase price safe
harbor for that area. FHA sets limits on the
dollar value of loans it will insure based on
median home prices and conforming loan
limits established by the Federal Home
Loan Mortgage Corporation. In particular,
FHA sets an area’s loan limit at 95 per­
cent of the median home sales price for
the area, subject to certain floors and caps
measured against conforming loan limits.
.14 To calculate the average area pur­
chase price safe harbors in this revenue
procedure, the FHA loan limits are ad­
justed to take into account the differenc­
es between average and median purchase
prices. Because FHA loan limits do not
differentiate between new and existing
residences, this revenue procedure con­
tains a single average area purchase price
safe harbor for both new and existing res­
idences in a statistical area. The Treasury
Department and the Internal Revenue Ser­
vice (IRS) have determined that FHA loan
limits provide a reasonable basis for deter­
mining average area purchase price safe
harbors. If the Treasury Department and
the IRS become aware of other sources
of average purchase price data, including
data that differentiate between new and
existing residences, consideration will be
given as to whether such data provide a
more accurate method for calculating av­
erage area purchase price safe harbors.
.15 The average area purchase price
safe harbors listed in section 4.01 of this
revenue procedure are based on FHA loan
limits released December 2, 2020. FHA
loan limits are available for statistical ar­
eas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Islands,
American Samoa, the Virgin Islands, and
Guam. See section 3.03 of this revenue
procedure with respect to FHA loan limits
revised after December 2, 2020.
.16 OMB Bulletin No. 03­04, dated
and effective June 6, 2003, revised the
definitions of the nation’s metropolitan
areas and recognized 49 new metropoli­
tan statistical areas. The OMB bulletin no
longer includes primary metropolitan sta­
tistical areas.
SECTION 3. APPLICATION
Average Area Purchase Price Safe
Harbors
.01 Average area purchase price safe
harbors for statistical areas in each state,
the District of Columbia, Puerto Rico,
the Northern Mariana Islands, American
Samoa, the Virgin Islands, and Guam are
set forth in section 4.01 of this revenue
procedure. Average area purchase price
safe harbors are provided for single­fam­
ily and two to four­family residences.
For each type of residence, section 4.01
of this revenue procedure contains a sin­
gle safe harbor that may be used for both
new and existing residences. Issuers of
qualified mortgage bonds and issuers of
mortgage credit certificates may rely on
these safe harbors to satisfy the require­
ments of §§ 143(e) and (f). Section 4.01
of this revenue procedure provides safe
harbors for MSAs and for certain coun­
ties and county equivalents. If no pur­
chase price safe harbor is available for a
statistical area, the safe harbor for “ALL
OTHER AREAS” may be used for that
statistical area.
.02 If a residence is in an MSA, the
safe harbor applicable to it is the limita­
tion of that MSA. If an MSA falls in more
than one state, the MSA is listed in sec­
tion 4.01 of this revenue procedure under
each state.
.03 If the FHA revises the FHA loan
limit for any statistical area after Decem­
ber 2, 2020, an issuer of qualified mort­
gage bonds or mortgage credit certificates
may use the revised FHA loan limit for
that statistical area to compute (as provid­
ed in the next sentence) a revised average
area purchase price safe harbor for the sta­
tistical area provided that the issuer main­
tains records evidencing the revised FHA
loan limit. The revised average area pur­
chase price safe harbor for that statistical
area is computed by dividing the revised
FHA loan limit by 1.03.
.04 If, pursuant to § 6a.103A­2(f)
(5)(i), an issuer uses more accurate and
comprehensive data to determine the av­
erage area purchase price for a statistical
area, the issuer must make separate av­
erage area purchase price determinations
for new and existing residences. More­
over, when computing the average area
purchase price for a statistical area that
is an MSA, as defined in OMB Bulletin
No. 03­04, the issuer must make the com­
putation for the entire applicable MSA.
When computing the average area pur­
chase price for a statistical area that is not
an MSA, the issuer must make the com­

Bulletin No. 2021–15 993 April 12, 2021
putation for the entire statistical area and
may not combine statistical areas. Thus,
for example, the issuer may not combine
two or more counties.
.05 If an issuer receives a ruling per­
mitting it to rely on an average area pur­
chase price limitation that is higher than
the applicable safe harbor in this revenue
procedure, the issuer may rely on that
higher limitation for the purpose of satis­
fying the requirements of §§ 143(e) and
(f) for bonds sold, and mortgage cred­
it certificates issued, not more than 30
months following the termination date of
the 12­month period used by the issuer to
compute the limitation.
Nationwide Average Purchase Price
.06 Section 4.02 of this revenue pro­
cedure sets forth a single nationwide
average purchase price for purposes of
computing the housing cost/income ratio
under § 143(f)(5).
.07 Issuers must use the nationwide
average purchase price set forth in section
4.02 of this revenue procedure when com­
puting the housing cost/income ratio un­
der § 143(f)(5) regardless of whether they
are relying on the average area purchase
price safe harbors contained in this reve­
nue procedure or using more accurate and
comprehensive data to determine average
area purchase prices for new and existing
residences for a statistical area that are dif­
ferent from the published safe harbors in
this revenue procedure.
.08 If, pursuant to section 6.02 of this
revenue procedure, an issuer relies on the
average area purchase price safe harbors
contained in Rev. Proc. 2020­18, the issuer
must use the nationwide average purchase
price set forth in section 4.02 of Rev. Proc.
2020­18 in computing the housing cost/
income ratio under § 143(f)(5). Likewise,
if, pursuant to section 6.04 of this revenue
procedure, an issuer relies on the nation­
wide average purchase price published in
Rev. Proc. 2020­18, the issuer must use
the average area purchase price safe har­
bors set forth in section 4.01 of Rev. Proc.
2020­18 in computing the housing cost/
income ratio under § 143(f)(5).
SECTION 4. AVERAGE AREA AND
NATIONWIDE AVERAGE PURCHASE
PRICES
.01 Average area purchase prices for
single­family and two to four­family resi­
dences in MSAs, and for certain counties
and county equivalents are set forth be­
low. The safe harbor for “ALL OTHER
AREAS” (found at the end of the table
below) may be used for a statistical area
that is not listed below.
2021 Average Area Purchase Prices for Mortgage Revenue Bonds
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
ALEUTIANS WESTAK$530,235$678,770$820,497$1,019,712
ANCHORAGE MUNICAK$406,066$519,826$628,334$780,907
JUNEAU CITY ANDAK$469,828$601,438$727,018$903,519
KETCHIKAN GATEWAK$395,998$506,938$612,771$761,550
KODIAK ISLAND BAK$406,066$519,826$628,334$780,907
MATANUSKA­SUSITAK$406,066$519,826$628,334$780,907
NOME CENSUS AREAK$428,438$548,473$662,963$823,901
SITKA CITY ANDAK$473,184$605,767$732,222$909,988
SKAGWAY MUNICIPAK$403,828$516,957$624,881$776,578
YAKUTAT CITY ANAK$409,422$524,106$633,538$787,375
COCONINOAZ$379,218$485,440$586,799$729,255
MARICOPAAZ$357,964$458,253$553,921$688,400
PINALAZ$357,964$458,253$553,921$688,400
ALAMEDACA$799,948$1,024,284$1,238,041$1,538,614
ALPINECA$450,811$577,120$697,593$866,945
AMADORCA$354,608$453,973$548,716$681,932
CALAVERASCA$363,557$465,402$562,578$699,149
CONTRA COSTACA$799,948$1,024,284$1,238,041$1,538,614
EL DORADOCA$581,692$744,673$900,115$1,118,638
HUMBOLDTCA$346,778$443,905$536,606$666,854
INYOCA$363,557$465,402$562,578$699,149

April 12, 2021 994 Bulletin No. 2021–15
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
LOS ANGELESCA$799,948$1,024,284$1,238,041$1,538,614
MARINCA$799,948$1,024,284$1,238,041$1,538,614
MENDOCINOCA$430,676$551,343$666,417$828,230
MONOCA$514,574$658,732$796,276$989,557
MONTEREYCA$719,284$920,834$1,113,045$1,383,269
NAPACA$794,233$1,016,745$1,229,043$1,527,379
NEVADACA$512,336$655,863$792,823$985,277
ORANGECA$799,948$1,024,284$1,238,041$1,538,614
PLACERCA$581,692$744,673$900,115$1,118,638
RIVERSIDECA$464,235$594,289$718,360$892,771
SACRAMENTOCA$581,692$744,673$900,115$1,118,638
SAN BENITOCA$799,948$1,024,284$1,238,041$1,538,614
SAN BERNARDINOCA$464,235$594,289$718,360$892,771
SAN DIEGOCA$732,708$938,003$1,133,813$1,409,095
SAN FRANCISCOCA$799,948$1,024,284$1,238,041$1,538,614
SAN JOAQUINCA$469,828$601,438$727,018$903,519
SAN LUIS OBISPOCA$682,369$873,559$1,055,946$1,312,260
SAN MATEOCA$799,948$1,024,284$1,238,041$1,538,614
SANTA BARBARACA$642,098$822,005$993,594$1,234,831
SANTA CLARACA$799,948$1,024,284$1,238,041$1,538,614
SANTA CRUZCA$799,948$1,024,284$1,238,041$1,538,614
SOLANOCA$535,828$685,968$829,154$1,030,460
SONOMACA$687,963$880,709$1,064,603$1,323,009
STANISLAUSCA$385,930$494,049$597,207$742,192
SUTTERCA$363,557$465,402$562,578$699,149
VENTURACA$719,284$920,834$1,113,045$1,383,269
YOLOCA$581,692$744,673$900,115$1,118,638
YUBACA$363,557$465,402$562,578$699,149
ADAMSCO$580,573$743,214$898,413$1,116,498
ARAPAHOECO$580,573$743,214$898,413$1,116,498
BOULDERCO$636,505$814,855$984,937$1,224,082
BROOMFIELDCO$580,573$743,214$898,413$1,116,498
CHAFFEECO$380,337$486,900$588,550$731,395
CLEAR CREEKCO$580,573$743,214$898,413$1,116,498
DENVERCO$580,573$743,214$898,413$1,116,498
DOUGLASCO$580,573$743,214$898,413$1,116,498
EAGLECO$799,826$1,023,943$1,237,700$1,538,176
EL PASOCO$382,574$489,769$592,003$735,724
ELBERTCO$580,573$743,214$898,413$1,116,498
GARFIELDCO$799,948$1,024,284$1,238,041$1,538,614
GILPINCO$580,573$743,214$898,413$1,116,498
GRANDCO$514,574$658,732$796,276$989,557

Bulletin No. 2021–15 995 April 12, 2021
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
GUNNISONCO$397,117$508,348$614,522$763,690
HINSDALECO$416,133$532,715$643,947$800,264
JEFFERSONCO$580,573$743,214$898,413$1,116,498
LA PLATACO$436,269$558,492$675,074$838,979
LARIMERCO$451,930$578,531$699,344$869,085
MONTROSECO$413,896$529,845$640,493$795,936
OURAYCO$413,896$529,845$640,493$795,936
PARKCO$580,573$743,214$898,413$1,116,498
PITKINCO$799,948$1,024,284$1,238,041$1,538,614
ROUTTCO$659,997$844,912$1,021,317$1,269,265
SAN MIGUELCO$799,948$1,024,284$1,238,041$1,538,614
SUMMITCO$799,948$1,024,284$1,238,041$1,538,614
TELLERCO$382,574$489,769$592,003$735,724
WELDCO$417,252$534,125$645,649$802,404
FAIRFIELDCT$585,048$748,953$905,319$1,125,107
LITCHFIELDCT$347,897$445,364$538,357$669,043
WINDHAMCT$354,608$453,973$548,716$681,932
DISTRICT OF COLDC$799,948$1,024,284$1,238,041$1,538,614
NEW CASTLEDE$419,489$536,995$649,151$806,733
BAKERFL$378,100$484,030$585,096$727,115
BROWARDFL$391,523$501,199$605,864$752,941
CLAYFL$378,100$484,030$585,096$727,115
COLLIERFL$447,455$572,791$692,389$860,476
DUVALFL$378,100$484,030$585,096$727,115
MARTINFL$371,388$475,421$574,688$714,226
MIAMI­DADEFL$391,523$501,199$605,864$752,941
MONROEFL$591,760$757,561$915,727$1,137,996
NASSAUFL$378,100$484,030$585,096$727,115
OKALOOSAFL$429,557$549,884$664,714$826,090
PALM BEACHFL$391,523$501,199$605,864$752,941
ST. JOHNSFL$378,100$484,030$585,096$727,115
ST. LUCIEFL$371,388$475,421$574,688$714,226
WALTONFL$429,557$549,884$664,714$826,090
BARROWGA$401,591$514,087$621,428$772,298
BARTOWGA$401,591$514,087$621,428$772,298
BUTTSGA$401,591$514,087$621,428$772,298
CARROLLGA$401,591$514,087$621,428$772,298
CHEROKEEGA$401,591$514,087$621,428$772,298

April 12, 2021 996 Bulletin No. 2021–15
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
CLARKEGA$380,337$486,900$588,550$731,395
CLAYTONGA$401,591$514,087$621,428$772,298
COBBGA$401,591$514,087$621,428$772,298
COWETAGA$401,591$514,087$621,428$772,298
DAWSONGA$401,591$514,087$621,428$772,298
DEKALBGA$401,591$514,087$621,428$772,298
DOUGLASGA$401,591$514,087$621,428$772,298
FAYETTEGA$401,591$514,087$621,428$772,298
FORSYTHGA$401,591$514,087$621,428$772,298
FULTONGA$401,591$514,087$621,428$772,298
GREENEGA$501,150$641,563$775,508$963,780
GWINNETTGA$401,591$514,087$621,428$772,298
HARALSONGA$401,591$514,087$621,428$772,298
HEARDGA$401,591$514,087$621,428$772,298
HENRYGA$401,591$514,087$621,428$772,298
JASPERGA$401,591$514,087$621,428$772,298
LAMARGA$401,591$514,087$621,428$772,298
MADISONGA$380,337$486,900$588,550$731,395
MERIWETHERGA$401,591$514,087$621,428$772,298
MORGANGA$401,591$514,087$621,428$772,298
NEWTONGA$401,591$514,087$621,428$772,298
OCONEEGA$380,337$486,900$588,550$731,395
OGLETHORPEGA$380,337$486,900$588,550$731,395
PAULDINGGA$401,591$514,087$621,428$772,298
PICKENSGA$401,591$514,087$621,428$772,298
PIKEGA$401,591$514,087$621,428$772,298
ROCKDALEGA$401,591$514,087$621,428$772,298
SPALDINGGA$401,591$514,087$621,428$772,298
WALTONGA$401,591$514,087$621,428$772,298
HAWAIIHI$397,117$508,348$614,522$763,690
HONOLULUHI$701,386$897,878$1,085,371$1,348,835
KALAWAOHI$703,624$900,747$1,088,824$1,353,163
KAUAIHI$700,268$896,467$1,083,620$1,346,695
MAUIHI$703,624$900,747$1,088,824$1,353,163
ADAID$403,828$516,957$624,881$776,578
BLAINEID$628,675$804,836$972,826$1,209,005
BOISEID$403,828$516,957$624,881$776,578
CAMASID$628,675$804,836$972,826$1,209,005
CANYONID$403,828$516,957$624,881$776,578
GEMID$403,828$516,957$624,881$776,578
KOOTENAIID$378,100$484,030$585,096$727,115

Bulletin No. 2021–15 997 April 12, 2021
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
OWYHEEID$403,828$516,957$624,881$776,578
TETONID$799,948$1,024,284$1,238,041$1,538,614
VALLEYID$369,151$472,552$571,235$709,898
COOKIL$369,151$472,552$571,235$709,898
DEKALBIL$369,151$472,552$571,235$709,898
DUPAGEIL$369,151$472,552$571,235$709,898
GRUNDYIL$369,151$472,552$571,235$709,898
KANEIL$369,151$472,552$571,235$709,898
KENDALLIL$369,151$472,552$571,235$709,898
LAKEIL$369,151$472,552$571,235$709,898
MCHENRYIL$369,151$472,552$571,235$709,898
WILLIL$369,151$472,552$571,235$709,898
BOONEIN$369,151$472,552$571,235$709,898
BROWNIN$369,151$472,552$571,235$709,898
HAMILTONIN$369,151$472,552$571,235$709,898
HANCOCKIN$369,151$472,552$571,235$709,898
HENDRICKSIN$369,151$472,552$571,235$709,898
JASPERIN$369,151$472,552$571,235$709,898
JOHNSONIN$369,151$472,552$571,235$709,898
LAKEIN$369,151$472,552$571,235$709,898
MADISONIN$369,151$472,552$571,235$709,898
MARIONIN$369,151$472,552$571,235$709,898
MORGANIN$369,151$472,552$571,235$709,898
NEWTONIN$369,151$472,552$571,235$709,898
PORTERIN$369,151$472,552$571,235$709,898
PUTNAMIN$369,151$472,552$571,235$709,898
SHELBYIN$369,151$472,552$571,235$709,898
JOHNSONKS$379,218$485,440$586,799$729,255
LEAVENWORTHKS$379,218$485,440$586,799$729,255
LINNKS$379,218$485,440$586,799$729,255
MIAMIKS$379,218$485,440$586,799$729,255
WYANDOTTEKS$379,218$485,440$586,799$729,255
BARNSTABLEMA$492,201$630,085$761,647$946,563
BRISTOLMA$492,201$630,085$761,647$946,563
DUKESMA$799,948$1,024,284$1,238,041$1,538,614
ESSEXMA$704,742$902,206$1,090,575$1,355,303
MIDDLESEXMA$704,742$902,206$1,090,575$1,355,303
NANTUCKETMA$799,948$1,024,284$1,238,041$1,538,614
NORFOLKMA$704,742$902,206$1,090,575$1,355,303

April 12, 2021 998 Bulletin No. 2021–15
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
PLYMOUTHMA$704,742$902,206$1,090,575$1,355,303
SUFFOLKMA$704,742$902,206$1,090,575$1,355,303
WORCESTERMA$354,608$453,973$548,716$681,932
ANNE ARUNDELMD$523,523$670,210$810,137$1,006,775
BALTIMOREMD$523,523$670,210$810,137$1,006,775
BALTIMORE CITYMD$523,523$670,210$810,137$1,006,775
CALVERTMD$799,948$1,024,284$1,238,041$1,538,614
CARROLLMD$523,523$670,210$810,137$1,006,775
CECILMD$419,489$536,995$649,151$806,733
CHARLESMD$799,948$1,024,284$1,238,041$1,538,614
FREDERICKMD$799,948$1,024,284$1,238,041$1,538,614
HARFORDMD$523,523$670,210$810,137$1,006,775
HOWARDMD$523,523$670,210$810,137$1,006,775
MONTGOMERYMD$799,948$1,024,284$1,238,041$1,538,614
PRINCE GEORGE’SMD$799,948$1,024,284$1,238,041$1,538,614
QUEEN ANNE’SMD$523,523$670,210$810,137$1,006,775
TALBOTMD$397,117$508,348$614,522$763,690
CUMBERLANDME$392,642$502,658$607,567$755,081
SAGADAHOCME$392,642$502,658$607,567$755,081
YORKME$392,642$502,658$607,567$755,081
ANOKAMN$391,523$501,199$605,864$752,941
CARVERMN$391,523$501,199$605,864$752,941
CHISAGOMN$391,523$501,199$605,864$752,941
DAKOTAMN$391,523$501,199$605,864$752,941
HENNEPINMN$391,523$501,199$605,864$752,941
ISANTIMN$391,523$501,199$605,864$752,941
LE SUEURMN$391,523$501,199$605,864$752,941
MILLE LACSMN$391,523$501,199$605,864$752,941
RAMSEYMN$391,523$501,199$605,864$752,941
SCOTTMN$391,523$501,199$605,864$752,941
SHERBURNEMN$391,523$501,199$605,864$752,941
WASHINGTONMN$391,523$501,199$605,864$752,941
WRIGHTMN$391,523$501,199$605,864$752,941
BATESMO$379,218$485,440$586,799$729,255
CALDWELLMO$379,218$485,440$586,799$729,255
CASSMO$379,218$485,440$586,799$729,255
CLAYMO$379,218$485,440$586,799$729,255
CLINTONMO$379,218$485,440$586,799$729,255
JACKSONMO$379,218$485,440$586,799$729,255

Bulletin No. 2021–15 999 April 12, 2021
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
LAFAYETTEMO$379,218$485,440$586,799$729,255
PLATTEMO$379,218$485,440$586,799$729,255
R AYMO$379,218$485,440$586,799$729,255
FLATHEADMT$368,032$471,141$569,484$707,758
GALLATINMT$465,354$595,748$720,111$894,911
MISSOULAMT$378,100$484,030$585,096$727,115
PARKMT$366,913$469,682$567,782$705,618
RICHLANDMT$346,778$443,905$536,606$666,854
CAMDENNC$446,337$571,381$690,686$858,336
CHATHAMNC$425,083$544,193$657,759$817,481
CURRITUCKNC$446,337$571,381$690,686$858,336
DARENC$385,930$494,049$597,207$742,192
DURHAMNC$425,083$544,193$657,759$817,481
FRANKLINNC$361,320$462,533$559,125$694,869
GATESNC$446,337$571,381$690,686$858,336
GRANVILLENC$425,083$544,193$657,759$817,481
HYDENC$469,828$601,438$727,018$903,519
JOHNSTONNC$361,320$462,533$559,125$694,869
ORANGENC$425,083$544,193$657,759$817,481
PASQUOTANKNC$783,047$1,002,446$1,211,729$1,505,882
PERQUIMANSNC$783,047$1,002,446$1,211,729$1,505,882
PERSONNC$425,083$544,193$657,759$817,481
WAKENC$361,320$462,533$559,125$694,869
LINCOLNNE$421,727$539,865$652,604$811,013
LOGANNE$421,727$539,865$652,604$811,013
MCPHERSONNE$421,727$539,865$652,604$811,013
HILLSBOROUGHNH$363,557$465,402$562,578$699,149
ROCKINGHAMNH$704,742$902,206$1,090,575$1,355,303
STRAFFORDNH$704,742$902,206$1,090,575$1,355,303
BERGENNJ$799,948$1,024,284$1,238,041$1,538,614
BURLINGTONNJ$419,489$536,995$649,151$806,733
CAMDENNJ$419,489$536,995$649,151$806,733
CAPE MAYNJ$419,489$536,995$649,151$806,733
ESSEXNJ$799,948$1,024,284$1,238,041$1,538,614
GLOUCESTERNJ$419,489$536,995$649,151$806,733
HUDSONNJ$799,948$1,024,284$1,238,041$1,538,614
HUNTERDONNJ$799,948$1,024,284$1,238,041$1,538,614
MIDDLESEXNJ$799,948$1,024,284$1,238,041$1,538,614

April 12, 2021 1000 Bulletin No. 2021–15
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
MONMOUTHNJ$799,948$1,024,284$1,238,041$1,538,614
MORRISNJ$799,948$1,024,284$1,238,041$1,538,614
OCEANNJ$799,948$1,024,284$1,238,041$1,538,614
PASSAICNJ$799,948$1,024,284$1,238,041$1,538,614
SALEMNJ$419,489$536,995$649,151$806,733
SOMERSETNJ$799,948$1,024,284$1,238,041$1,538,614
SUSSEXNJ$799,948$1,024,284$1,238,041$1,538,614
UNIONNJ$799,948$1,024,284$1,238,041$1,538,614
WARRENNJ$362,439$463,992$560,827$697,009
CATRONNM$390,405$499,788$604,113$750,801
LOS ALAMOSNM$482,133$617,197$746,083$927,205
SANTA FENM$402,710$515,546$623,179$774,438
CARSON CITYNV$369,151$472,552$571,235$709,898
CLARKNV$352,371$451,103$545,263$677,652
DOUGLASNV$486,608$622,936$752,990$935,814
STOREYNV$447,455$572,791$692,389$860,476
WASHOENV$447,455$572,791$692,389$860,476
BRONXNY$799,948$1,024,284$1,238,041$1,538,614
DUTCHESSNY$346,778$443,905$536,606$666,854
KINGSNY$799,948$1,024,284$1,238,041$1,538,614
NASSAUNY$799,948$1,024,284$1,238,041$1,538,614
NEW YORKNY$799,948$1,024,284$1,238,041$1,538,614
ORANGENY$346,778$443,905$536,606$666,854
PUTNAMNY$799,948$1,024,284$1,238,041$1,538,614
QUEENSNY$799,948$1,024,284$1,238,041$1,538,614
RICHMONDNY$799,948$1,024,284$1,238,041$1,538,614
ROCKLANDNY$799,948$1,024,284$1,238,041$1,538,614
SUFFOLKNY$799,948$1,024,284$1,238,041$1,538,614
WESTCHESTERNY$799,948$1,024,284$1,238,041$1,538,614
DELAWAREOH$387,049$495,460$598,909$744,332
FAIRFIELDOH$387,049$495,460$598,909$744,332
FRANKLINOH$387,049$495,460$598,909$744,332
HOCKINGOH$387,049$495,460$598,909$744,332
LICKINGOH$387,049$495,460$598,909$744,332
MADISONOH$387,049$495,460$598,909$744,332
MORROWOH$387,049$495,460$598,909$744,332
PERRYOH$387,049$495,460$598,909$744,332
PICKAWAYOH$387,049$495,460$598,909$744,332
UNIONOH$387,049$495,460$598,909$744,332

Bulletin No. 2021–15 1001 April 12, 2021
One-Unit Two-Unit Three-Unit Four-Unit
County NameStateLimitLimitLimitLimit
BENTONOR$418,371$535,585$647,400$804,544
CLACKAMASOR$503,387$644,433$778,961$968,060
CLATSOPOR$369,151$472,552$571,235$709,898
COLUMBIAOR$503,387$644,433$778,961$968,060
DESCHUTESOR$447,455$572,791$692,389$860,476
HOOD RIVEROR$464,235$594,289$718,360$892,771
JACKSONOR$346,778$443,905$536,606$666,854
MARIONOR$357,964$458,253$553,921$688,400
MULTNOMAHOR$503,387$644,433$778,961$968,060
POLKOR$357,964$458,253$553,921$688,400
WASHINGTONOR$503,387$644,433$778,961$968,060
YAMHILLOR$503,387$644,433$778,961$968,060
BUCKSPA$419,489$536,995$649,151$806,733
CARBONPA$362,439$463,992$560,827$697,009
CHESTERPA$419,489$536,995$649,151$806,733
DELAWAREPA$419,489$536,995$649,151$806,733
LEHIGHPA$362,439$463,992$560,827$697,009
MONTGOMERYPA$419,489$536,995$649,151$806,733
NORTHAMPTONPA$362,439$463,992$560,827$697,009
PHILADELPHIAPA$419,489$536,995$649,151$806,733
PIKEPA$799,948$1,024,284
$1,238,041$1,538,614
BRISTOLRI$492,201$630,085$761,647$946,563
KENTRI$492,201$630,085$761,647$946,563
NEWPORTRI$492,201$630,085$761,647$946,563
PROVIDENCERI$492,201$630,085$761,647$946,563
WASHINGTONRI$492,201$630,085$761,647$946,563
BEAUFORTSC$369,151$472,552$571,235$709,898
BERKELEYSC$402,710$515,546$623,179$774,438
CHARLESTONSC$402,710$515,546$623,179$774,438
DORCHESTERSC$402,710$515,546$623,179$774,438
JASPERSC$369,151$472,552$571,235$709,898
CANNONTN$570,506$730,325$882,800$1,097,141
CHEATHAMTN$570,506$730,325$882,800$1,097,141
DAVIDSONTN$570,506$730,325$882,800$1,097,141
DICKSONTN$570,506$730,325$882,800$1,097,141
MACONTN$570,506$730,325$882,800$1,097,141
MAURYTN$570,506$730,325$882,800$1,097,141
ROBERTSONTN$570,506$730,325$882,800$1,097,141
RUTHERFORDTN$570,506$730,325$882,800$1,097,141

April 12, 2021 1002 Bulletin No. 2021–15
County NameState
One-Unit
Limit
Two-Unit
Limit
Three-Unit
Limit
Four-Unit
Limit
SMITHTN$570,506$730,325$882,800$1,097,141
SUMNERTN$570,506$730,325$882,800$1,097,141
TROUSDALETN$570,506$730,325$882,800$1,097,141
WILLIAMSONTN$570,506$730,325$882,800$1,097,141
WILSONTN$570,506$730,325$882,800$1,097,141
ATASCOSATX$392,642$502,658$607,567$755,081
BANDERATX$392,642$502,658$607,567$755,081
BASTROPTX$404,947$518,416$626,632$778,767
BEXARTX$392,642$502,658$607,567$755,081
CALDWELLTX$404,947$518,416$626,632$778,767
COLLINTX$400,473$512,677$619,677$770,158
COMALTX$392,642$502,658$607,567$755,081
DALLASTX$400,473$512,677$619,677$770,158
DENTONTX$400,473$512,677$619,677$770,158
ELLISTX$400,473$512,677$619,677$770,158
GUADALUPETX$392,642$502,658$607,567$755,081
HAYSTX$404,947$518,416$626,632$778,767
HUNTTX$400,473$512,677$619,677$770,158
JOHNSONTX$400,473$512,677$619,677$770,158
KAUFMANTX$400,473$512,677$619,677$770,158
KENDALLTX$392,642$502,658$607,567$755,081
MEDINATX$392,642$502,658$607,567$755,081
PARKERTX$400,473$512,677$619,677$770,158
ROCKWALLTX$400,473$512,677$619,677$770,158
TARRANTTX$400,473$512,677$619,677$770,158
TRAVISTX$404,947$518,416$626,632$778,767
WILLIAMSONTX$404,947$518,416$626,632$778,767
WILSONTX$392,642$502,658$607,567$755,081
WISETX$400,473$512,677$619,677$770,158
BOX ELDERUT$628,675$804,836$972,826$1,209,005
DAVISUT$628,675$804,836$972,826$1,209,005
JUABUT$427,320$547,014$661,261$821,761
MORGANUT$628,675$804,836$972,826$1,209,005
RICHUT$364,676$466,861$564,329$701,289
SALT LAKEUT$440,744$564,231$682,029$847,587
SUMMITUT$795,352$1,018,204$1,230,745$1,529,568
TOOELEUT$440,744$564,231$682,029$847,587
UTAHUT$427,320$547,014$661,261$821,761
WASATCHUT$795,352$1,018,204$1,230,745$1,529,568
WASHINGTONUT$402,710$515,546$623,179$774,438
WEBERUT$628,675$804,836$972,826$1,209,005

Bulletin No. 2021–15 1003 April 12, 2021
One-Unit Two-Unit Three-Unit Four-Unit
County NameStateLimitLimitLimitLimit
ALBEMARLEVA$425,083$544,193$657,759$817,481
ALEXANDRIA CITYVA$799,948$1,024,284$1,238,041$1,538,614
AMELIAVA$521,285$667,341$806,636$1,002,495
ARLINGTONVA$799,948$1,024,284$1,238,041$1,538,614
CHARLES CITYVA$521,285$667,341$806,636$1,002,495
CHARLOTTESVILLEVA$425,083$544,193$657,759$817,481
CHESAPEAKE CITYVA$446,337$571,381$690,686$858,336
CHESTERFIELDVA$521,285$667,341$806,636$1,002,495
CLARKEVA$799,948$1,024,284$1,238,041$1,538,614
COLONIAL HEIGHTVA$521,285$667,341$806,636$1,002,495
CULPEPERVA$799,948$1,024,284$1,238,041$1,538,614
DINWIDDIEVA$521,285$667,341$806,636$1,002,495
FAIRFAXVA$799,948$1,024,284$1,238,041$1,538,614
FAIRFAX CITYVA$799,948$1,024,284$1,238,041$1,538,614
FALLS CHURCH CIVA$799,948$1,024,284$1,238,041$1,538,614
FAUQUIERVA$799,948$1,024,284$1,238,041$1,538,614
FLUVANNAVA$425,083$544,193$657,759$817,481
FRANKLIN CITYVA$446,337$571,381$690,686$858,336
FREDERICKSBURGVA$799,948$1,024,284$1,238,041$1,538,614
GLOUCESTERVA$446,337$571,381$690,686$858,336
GOOCHLANDVA$521,285$667,341
$806,636$1,002,495
GREENEVA$425,083$544,193$657,759$817,481
HAMPTON CITYVA$446,337$571,381$690,686$858,336
HANOVERVA$521,285$667,341$806,636$1,002,495
HENRICOVA$521,285$667,341$806,636$1,002,495
HOPEWELL CITYVA$521,285$667,341$806,636$1,002,495
ISLE OF WIGHTVA$446,337$571,381$690,686$858,336
JAMES CITYVA$446,337$571,381$690,686$858,336
KING AND QUEENVA$521,285$667,341$806,636$1,002,495
KING GEORGEVA$349,015$446,774$540,059$671,183
KING WILLIAMVA$521,285$667,341$806,636$1,002,495
LANCASTERVA$430,676$551,343$666,417$828,230
LOUDOUNVA$799,948$1,024,284$1,238,041$1,538,614
MADISONVA$799,948$1,024,284$1,238,041$1,538,614
MANASSAS CITYVA$799,948$1,024,284$1,238,041$1,538,614
MANASSAS PARK CVA$799,948$1,024,284$1,238,041$1,538,614
MATHEWSVA$446,337$571,381$690,686$858,336
NELSONVA$425,083$544,193$657,759$817,481
NEW KENTVA$521,285$667,341$806,636$1,002,495
NEWPORT NEWS CIVA$446,337$571,381$690,686$858,336
NORFOLK CITYVA$446,337$571,381$690,686$858,336
PETERSBURG CITYVA$521,285$667,341$806,636$1,002,495
POQUOSON CITYVA$446,337$571,381$690,686$858,336

April 12, 2021 1004 Bulletin No. 2021–15
One-Unit Two-Unit Three-Unit Four-Unit
County NameStateLimitLimitLimitLimit
PORTSMOUTH CITYVA$446,337$571,381$690,686$858,336
POWHATANVA$521,285$667,341$806,636$1,002,495
PRINCE GEORGEVA$521,285$667,341$806,636$1,002,495
PRINCE WILLIAMVA$799,948$1,024,284$1,238,041$1,538,614
RAPPAHANNOCKVA$799,948$1,024,284$1,238,041$1,538,614
RICHMOND CITYVA$521,285$667,341$806,636$1,002,495
SOUTHAMPTONVA$446,337$571,381$690,686$858,336
SPOTSYLVANIAVA$799,948$1,024,284$1,238,041$1,538,614
STAFFORDVA$799,948$1,024,284$1,238,041$1,538,614
SUFFOLK CITYVA$446,337$571,381$690,686$858,336
SUSSEXVA$521,285$667,341$806,636$1,002,495
VIRGINIA BEACHVA$446,337$571,381$690,686$858,336
WARRENVA$799,948$1,024,284$1,238,041$1,538,614
WILLIAMSBURG CIVA$446,337$571,381$690,686$858,336
YORKVA$446,337$571,381$690,686$858,336
CHITTENDENVT$369,151$472,552$571,235$709,898
FRANKLINVT$369,151$472,552$571,235$709,898
GRAND ISLEVT$369,151$472,552$571,235$709,898
CHELANWA$361,320$462,533$559,125$694,869
CLALLAMWA$373,625$478,291$578,141$718,506
CLARKWA$503,387$644,433
$778,961$968,060
DOUGLASWA$361,320$462,533$559,125$694,869
ISLANDWA$419,489$536,995$649,151$806,733
KINGWA$755,081$966,649$1,168,442$1,452,090
KITSAPWA$423,964$542,734$656,057$815,341
PIERCEWA$755,081$966,649$1,168,442$1,452,090
SAN JUANWA$484,370$620,066$749,536$931,485
SKAGITWA$394,879$505,527$611,068$759,361
SKAMANIAWA$503,387$644,433$778,961$968,060
SNOHOMISHWA$755,081$966,649$1,168,442$1,452,090
THURSTONWA$394,879$505,527$611,068$759,361
WHATCOMWA$430,676$551,343$666,417$828,230
KENOSHAWI$369,151$472,552$571,235$709,898
MILWAUKEEWI$352,371$451,103$545,263$677,652
OZAUKEEWI$352,371$451,103$545,263$677,652
PIERCEWI$391,523$501,199$605,864$752,941
ST. CROIXWI$391,523$501,199$605,864$752,941
WASHINGTONWI$352,371$451,103$545,263$677,652
WAUKESHAWI$352,371$451,103$545,263$677,652

Bulletin No. 2021–15 1005 April 12, 2021
One-Unit Two-Unit Three-Unit Four-Unit
County NameStateLimitLimitLimitLimit
JEFFERSONWV$799,948$1,024,284$1,238,041$1,538,614
SHERIDANWY$476,540$610,047$737,426$916,408
TETONWY$799,948$1,024,284$1,238,041$1,538,614
GUAMGU$548,133$701,727$848,220$1,054,098
NORTHERN ISLANDMP$510,099$652,993$789,321$980,949
ROTAMP$399,354$511,218$617,975$767,970
SAIPANMP$514,574$658,732$796,276$989,557
TINIANMP$517,930$663,061$801,480$996,026
AGUAS BUENASPR$374,744$479,750$579,892$720,646
AIBONITOPR$374,744$479,750$579,892$720,646
BARCELONETAPR$374,744$479,750$579,892$720,646
BARRANQUITASPR$374,744$479,750$579,892$720,646
BAYAMONPR$374,744$479,750$579,892$720,646
CAGUASPR$374,744$479,750$579,892$720,646
CANOVANASPR$374,744$479,750$579,892$720,646
CAROLINAPR$374,744$479,750$579,892$720,646
CATANOPR$374,744$479,750$579,892$720,646
CAYEYPR$374,744$479,750$579,892$720,646
CEIBAPR$374,744$479,750$579,892$720,646
CIALESPR$374,744$479,750$579,892$720,646
CIDRAPR$374,744$479,750
$579,892$720,646
COMERIOPR$374,744$479,750$579,892$720,646
COROZALPR$374,744$479,750$579,892$720,646
DORADOPR$374,744$479,750$579,892$720,646
FAJARDOPR$374,744$479,750$579,892$720,646
FLORIDAPR$374,744$479,750$579,892$720,646
GUAYNABOPR$374,744$479,750$579,892$720,646
GURABOPR$374,744$479,750$579,892$720,646
HUMACAOPR$374,744$479,750$579,892$720,646
JUNCOSPR$374,744$479,750$579,892$720,646
LAS PIEDRASPR$374,744$479,750$579,892$720,646
LOIZAPR$374,744$479,750$579,892$720,646
LUQUILLOPR$374,744$479,750$579,892$720,646
MANATIPR$374,744$479,750$579,892$720,646
MAUNABOPR$374,744$479,750$579,892$720,646
MOROVISPR$374,744$479,750$579,892$720,646
NAGUABOPR$374,744$479,750$579,892$720,646
NARANJITOPR$374,744$479,750$579,892$720,646
OROCOVISPR$374,744$479,750$579,892$720,646

April 12, 2021 1006 Bulletin No. 2021–15
One-Unit Two-Unit Three-Unit Four-Unit
County NameStateLimitLimitLimitLimit
RIO GRANDEPR$374,744$479,750$579,892$720,646
SAN JUANPR$374,744$479,750$579,892$720,646
SAN LORENZOPR$374,744$479,750$579,892$720,646
TOA ALTAPR$374,744$479,750$579,892$720,646
TOA BAJAPR$374,744$479,750$579,892$720,646
TRUJILLO ALTOPR$374,744$479,750$579,892$720,646
VEGA ALTAPR$374,744$479,750$579,892$720,646
VEGA BAJAPR$374,744$479,750$579,892$720,646
YABUCOAPR$374,744$479,750$579,892$720,646
ST. JOHN ISLANDVI$606,302$776,189$938,197$1,165,962
ST. THOMAS ISLAVI$434,032$555,623$671,621$834,699
All other areas
­ 2695 counties
(floor): $346,644$443,832$536,460$666,708
.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$331,900.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2020­18 is obsolete except
as provided in section 6 of this revenue
procedure.
SECTION 6. EFFECTIVE DATES
.01 Issuers may rely on this revenue
procedure to determine average area pur­
chase price safe harbors for commitments
to provide financing or issue mortgage
credit certificates that are made, or (if the
purchase precedes the commitment) for
residences that are purchased, in the pe­
riod that begins on March 25, 2021, and
ends on the date as of which the safe har­
bors contained in section 4.01 of this rev­
enue procedure are rendered obsolete by a
new revenue procedure.
.02 Notwithstanding section 5 of this
revenue procedure, issuers may continue
to rely on the average area purchase price
safe harbors contained in Rev. Proc. 2020­
18, with respect to bonds sold, or for mort­
gage credit certificates issued with respect
to bond authority exchanged, before April
24, 2021, if the commitments to provide
financing or issue mortgage credit certifi­
cates are made on or before May 24, 2021.
.03 Except as provided in section 6.04,
issuers must use the nationwide average
purchase price limitation contained in this
revenue procedure for commitments to
provide financing or issue mortgage credit
certificates that are made, or (if the pur­
chase precedes the commitment) for res­
idences that are purchased, in the period
that begins on March 25, 2021, and ends
on the date when the nationwide average
purchase price limitation is rendered ob­
solete by a new revenue procedure.
.04 Notwithstanding sections 5 and
6.03 of this revenue procedure, issuers
may continue to rely on the nationwide
average purchase price set forth in Rev.
Proc. 2020­18 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before April 24, 2021, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
May 24, 2021.
SECTION 7. PAPERWORK
REDUCTION ACT
The collection of information con­
tained in this revenue procedure has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 1545­
1877.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
OMB control number.
This revenue procedure contains a col­
lection of information requirement in sec­
tion 3.03. The purpose of the collection
of information is to verify the applicable
FHA loan limit that issuers of qualified
mortgage bonds and qualified mortgage
certificates have used to calculate the
average area purchase price for a given
metropolitan statistical area for purposes
of §§ 143(e) and 25(c). The collection of
information is required to obtain the ben­
efit of using revisions to FHA loan limits
to determine average area purchase prices.
The likely respondents are state and local
governments.
The estimated total annual reporting
and/or recordkeeping burden is: 15 hours.
The estimated annual burden per re­
spondent and/or recordkeeper: 15 min­
utes.
The estimated number of respondents
and/or recordkeepers: 60.
Books or records relating to a collec­
tion of information must be retained as

Bulletin No. 2021–15 1007 April 12, 2021
long as their contents may become mate­
rial in the administration of any internal
revenue law. Generally, tax returns and tax
return information are confidential, as re­
quired by 26 U.S.C. 6103.
SECTION 8. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Jian H. Grant and David
White of the Office of Associate Chief
Counsel (Financial Institutions & Prod­
ucts). For further information regarding
this revenue procedure contact Mr. White
at (202) 317­4562 (not a toll­free number).
26 CFR 601.105: Examination of returns and
claims for refund, credit, or abatement; determina-
tion of correct tax liability.
(Also Part I, § 1391.)
Rev. Proc. 2021-18
SECTION 1. PURPOSE
This revenue procedure provides an au­
tomatic procedure for a State or local gov­
ernment in which an empowerment zone is
located to extend the empowerment zone
designation made under section 1391(a) of
the Internal Revenue Code (Code). Specif­
ically, this revenue procedure provides that
a State or local government that nominated
an empowerment zone is deemed to extend
until December 31, 2025, the termination
date designated by that State or local gov­
ernment in its empowerment zone nom­
ination (designated termination date), as
described in section 1391(d)(1)(B). This
revenue procedure further provides the
procedure for such State or local govern­
ment to decline this deemed extension of
its designated termination date.
SECTION 2. BACKGROUND
.01 Empowerment Zones. An empow­
erment zone is an area of high poverty
and unemployment located in an urban or
rural area that is designated under section
1391(a), as appropriate, by the Secretary
of Housing and Urban Development or
the Secretary of Agriculture, each Sec­
retary an “appropriate Secretary” under
section 1393(a)(1) of the Code. See sec­
tion 1391(a); see generally section 1393.
Qualifying taxpayers and businesses lo­
cated within the boundaries of empow­
erment zones are eligible for Federal in­
come tax incentives to promote economic
development in those designated areas.
See section 1394 of the Code (regarding
tax­exempt enterprise zone facility bonds)
and section 1396 of the Code (regarding
empowerment zone employment credits).
.02 Empowerment Zone Designation
and Extensions.
(1) Initial designation. As originally
enacted in 1993, section 1391(d)(1) pro­
vided that the designation of an empow­
erment zone remained in effect during the
period beginning on the date of the desig­
nation and ending on the earliest of (i) the
close of the 10th calendar year beginning
on or after such date of designation (statu­
tory termination date), (ii) the termination
date designated by a State or local govern­
ment in its nomination (that is, the desig­
nated termination date), or (iii) the date
the appropriate Secretary revokes the des­
ignation. See section 13301(a) of the Om­
nibus Budget Reconciliation Act of 1993
(OBRA of 1993), Public Law 103­66, 107
Stat. 312 (August 10, 1993) (adding sec­
tion 1391(d)(1) to the Code).
(2) Extensions of statutory termina-
tion date and automatic extensions of
designated termination date. The statu­
tory termination date has been extended
multiple times, most recently in 2020 to
extend that date to December 31, 2025.
See section 118(a) of the Taxpayer Cer­
tainty and Disaster Tax Relief Act of 2020
(TCDTRA of 2020), enacted as part of
Title I of Division EE of the Consolidat­
ed Appropriations Act, 2021, Pub. L. No.
116­260, 134 Stat. 1182 (December 27,
2020). After each extension of the stat­
utory termination date and pursuant to
specific statutory grants of authority, the
Department of the Treasury (Treasury De­
partment) and the Internal Revenue Ser­
vice (IRS) issued guidance automatically
treating a designated termination date as
extended to the date of the amended stat­
utory termination date, unless the State or
local government declined the extension
in a written notification to the IRS. See,
for example,
section 3 of Rev. Proc. 2020­
16, 2020­27 I.R.B. 10 (deemed extension
to December 31, 2020); see also section 2
of Rev. Proc. 2020­16 (providing an over­
view of each extension of the statutory ter­
mination date).
(3) Current designated termination
date of all empowerment zones. The IRS
has received no written request from a
State or local government to decline any
extension of a designated termination
date otherwise provided in the previous
guidance described in section 2.02(2) of
this revenue procedure. Therefore, as of
March 26, 2021, all empowerment zones
have a designated termination date of
December 31, 2020, the latest statutory
termination date prior to enactment of the
TCDTRA of 2020.
.03 Statutory authority to extend cur-
rent designated termination date. Section
118(d) of the TCDTRA of 2020 provides
that, if a nomination for an empower­
ment zone includes a designated termi­
nation date of December 31, 2020, sec­
tion 1391(d)(1)(B) does not apply to the
designation if, after the date of enactment
of the TCDTRA of 2020, the State or lo­
cal government that made such nomina­
tion amends the nomination to provide a
new termination date in such manner as
may be provided by the Secretary of the
Treasury (or the Secretary’s designee).
Accordingly, section 3.01 of this revenue
procedure sets forth an automatic exten­
sion procedure to extend a designated
termination date to December 31, 2025,
and section 3.02 of this revenue proce­
dure sets forth a written declination pro­
cedure consistent with the previous guid­
ance described above.
SECTION 3. AUTOMATIC
EXTENSION OF DESIGNATED
TERMINATION DATE
.01 Automatic extension. Subject to
declination by written notification pur­
suant to section 3.02 of this revenue pro­
cedure, the designated termination date
with regard to all empowerment zones
is deemed to be extended from Decem­
ber 31, 2020, to December 31, 2025.
Accordingly, the designated termination
date is deemed to be the same date as the
date provided in section 1391(d)(1)(A)(i)

April 12, 2021 1008 Bulletin No. 2021–15
(that is, December 31, 2025). Therefore,
section 1391(d)(1)(B) does not apply and
the designation of all empowerment zones
will remain in effect until December 31,
2025 (unless terminated at an earlier date
by the appropriate Secretary under section
1391(d)(1)(C)).
.02 Declination of automatic extension.
(1) In general. Pursuant to section
3.02(2) of this revenue procedure, a State
or local government may decline the ex­
tension of a designated termination date
described in section 3.01 of this revenue
procedure.
(2) Form and manner.
(a) Deadline for written notification. To
make a declination under section 3.02(1)
of this revenue procedure, not later than
May 25, 2021, the State or local govern­
ment must provide written notification to
the IRS that affirmatively declines the De­
cember 31, 2025, designated termination
date extension under section 3.01 of this
revenue procedure.
(b) Electronic delivery. This written
notification must be sent by electronic
facsimile to Bruce Chang, CC:ITA:B07,
at facsimile number (855) 576­2341.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2020­16 is obsoleted for
taxable years beginning after 2020.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning after December
31, 2020, the effective date of the amend­
ments made by section 118 of the TC­
DTRA of 2020.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Bruce Chang of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding this revenue procedure, contact
Mr. Chang at (202) 317­4870 (not a toll­
free number).
26 CFR 601.601: Rules and Regulations.
(Also Part I, §§ 25, 143)
Rev. Proc. 2021-19
SECTION 1. PURPOSE
This revenue procedure provides guid­
ance with respect to the United States and
area median gross income figures for use
by issuers of qualified mortgage bonds, as
defined in § 143(a) of the Internal Reve­
nue Code, and issuers of mortgage credit
certificates, as defined in § 25(c), in com­
puting the income requirements described
in § 143(f).
SECTION 2. BACKGROUND
.01 Section 103(a) provides that, ex­
cept as provided in § 103(b), gross income
does not include interest on any State or
local bond. Section 103(b)(1) provides
that § 103(a) does not apply to any private
activity bond that is not a qualified bond
(within the meaning of § 141). Section
141(e) provides that the term “qualified
bond” includes any private activity bond
that (1) is a qualified mortgage bond, (2)
meets the applicable volume cap require­
ments under § 146, and (3) meets the ap­
plicable requirements under § 147.
.02 Section 143(a)(1) provides that the
term “qualified mortgage bond” means a
bond that is issued as part of a “qualified
mortgage issue”. Section 143(a)(2)(A)
provides that the term “qualified mort­
gage issue” means an issue of one or more
bonds by a State or political subdivision
thereof, but only if: (i) all proceeds of the
issue (exclusive of issuance costs and a
reasonably required reserve) are to be
used to finance owner­occupied residenc­
es; (ii) the issue meets the requirements of
subsections (c), (d), (e), (f), (g), (h), (i),
and (m)(7) of § 143; (iii) the issue does
not meet the private business tests of para­
graphs (1) and (2) of § 141(b); and (iv)
with respect to amounts received more
than 10 years after the date of issuance,
repayments of $250,000 or more of prin­
cipal on financing provided by the issue
are used not later than the close of the first
semi­annual period beginning after the
date the prepayment (or complete repay­
ment) is received to redeem bonds that are
part of the issue.
.03 Section 25(c)(1) provides that the
term “mortgage credit certificate” means
any certificate that: (1) is issued under a
qualified mortgage credit certificate pro­
gram by the State or political subdivision
having the authority to issue a qualified
mortgage bond to provide financing on the
principal residence of the taxpayer; (2) is
issued to the taxpayer in connection with
the acquisition, qualified rehabilitation, or
qualified home improvement of the tax­
payer’s principal residence; (3) specifies
the certificate credit rate and the certified
indebtedness amount; and (4) is in such
form as the Secretary of the Treasury or
the Secretary’s delegate (Secretary) may
prescribe.
.04 Section 25(c)(2) provides that the
term “qualified mortgage credit certifi­
cate program” means any program under
which, among other requirements, the
indebtedness certified by mortgage cred­
it certificates meets the requirements of
§ 143(f). See § 25(c)(2)(A)(iii)(IV).
.05 Section 143(f) imposes eligibility
requirements concerning the maximum
income of mortgagors for whom financ­
ing may be provided by qualified mort­
gage bonds. Generally, under §§ 143(f)
(1) and 25(c)(2)(A)(iii)(IV), these income
requirements are met only if all owner­fi­
nancing under a qualified mortgage bond
and all certified indebtedness amounts un­
der a mortgage credit certificate program
are provided to mortgagors whose family
income is 115 percent or less of the ap­
plicable median family income. Under
§ 143(f)(3), in the case of targeted area res­
idences, the income limitation of § 143(a)
applies to 2/3 of the owner financing and
is treated as satisfied if the family income
of the mortgagor is 140 percent or less
of the applicable median family income.
Under § 143(f)(6), if there are fewer than
three individuals in the family of the mort­
gagor, the income limitation of § 143(a) is
reduced to 100 percent of the applicable
median family income and, in the case of
targeted area residences, the income lim­
itation of § 143(a) is satisfied if the family
income of the mortgagor is 120 percent or
less of the applicable median family in­
come.
.06 Section 143(f)(2) provides that, for
purposes of § 143(f), the family income
of mortgagors, and area median gross
income, are determined by the Secretary

Bulletin No. 2021–15 1009 April 12, 2021
after taking into account the regulations
prescribed under section 8 of the United
States Housing Act of 1937 (if terminated,
a successor program) (Housing Act).
.07 Section 143(f)(4) provides that the
term “applicable median family income”
means, with respect to a residence, the
greater of (A) the area median gross in­
come for the area in which the residence is
located, or (B) the statewide median gross
income for the state in which the residence
is located.
.08 Section 143(f)(5) provides for an
upward adjustment of the income limita­
tions in certain high housing cost areas.
Under § 143(f)(5)(C), a high housing
cost area is a statistical area for which
the housing cost/income ratio is greater
than 1.2. The housing cost/income ratio
with respect to any statistical area is de­
termined under § 143(f)(5)(D) by dividing
(a) the applicable housing price ratio for
such area by (b) the ratio that the area me­
dian gross income for such area bears to
the median gross income for the United
States. The applicable housing price ratio
for any area is the new housing price ratio
(new housing average purchase price for
the area divided by the new housing aver­
age purchase price for the United States)
or the existing housing price ratio (exist­
ing housing average purchase price for the
area divided by the existing housing aver­
age purchase price for the United States),
whichever results in the housing cost/in­
come ratio being closer to 1.
.09 The Department of Housing and Ur­
ban Development (HUD) annually com­
putes the median gross income (adjust­
ed by family size) for the United States,
the states, and statistical areas within the
states. HUD releases the annually updated
income figures to its regional offices in a
notice. The most recent income figures are
generally available by calling the HUD
reference service at 1­800­245­2691, or at
HUD’s website, http://www.huduser.gov/
portal/datasets/il.html (including a menu
from which the year and type of data of
interest may be selected).
.10 Rev. Rul. 86­124, 1986­2 C.B. 27,
provides the manner in which the income
limits under § 143(f) applicable to quali­
fied mortgage bonds and mortgage credit
certificates are determined. In particular,
the revenue ruling provides that, for pur­
poses of § 143(f)(4), to determine the area
median gross income for an area or state
in a manner consistent with the determi­
nation of “median gross income” for the
area or state under section 8 of the Hous­
ing Act, issuers must use the income limits
released by HUD for Lower Income and
Very Low Income under the Housing Act.
Further, Rev. Rul. 86­124 provides the
manner in which issuers must apply these
income limits. See generally, Rev. Rul.
86­124, Guidelines.
.11 The Internal Revenue Service (IRS)
has published a revenue procedure in the
Internal Revenue Bulletin annually, pro­
viding guidance with respect to the Unit­
ed States and area median gross income
figures that are to be used by issuers of
qualified mortgage bonds and issuers of
mortgage credit certificates for purposes
of computing the income requirements
under § 143(f). See, e.g., Rev. Proc. 2020­
33, 2020­25 I.R.B. 956.
.12 The IRS has also published a rev­
enue procedure in the Internal Revenue
Bulletin annually, providing the most re­
cent nationwide average purchase prices
and average area purchase price safe har­
bor limitations for purposes of § 143(f)
(5). See, e.g., Rev. Proc. 2020­18, 2020­15
I.R.B. 592.
.13 The Department of the Treasury
(Treasury Department) and the IRS re­
quested public comments on whether, in­
stead of publishing a revenue procedure
annually, such as Rev. Proc. 2020­33, the
IRS should publish permanent guidance
that would allow issuers to rely on the
HUD income figures immediately upon
release. See Rev. Proc. 2020­33, Section
6. The Treasury Department and the IRS
also requested public comments on the
two­year convention with respect to the
issuers’ reliance on the HUD income fig­
ures, as provided in section 3.01 of Rev.
Proc. 2020­33, and a transition period, if
necessary. See Rev. Proc. 2020­33, Sec­
tion 6. Comments received consistently
favored publication of permanent guid­
ance, retention of the two­year conven­
tion, and provision of a transition period,
such as a period of 90 days following the
release of the HUD income figures. As a
result, the Treasury Department and the
IRS have decided to publish this revenue
procedure as permanent guidance consis­
tent with comments received and to cease
publishing annual revenue procedures
providing income figures for purposes of
computing the income requirements of
§ 143(f).
SECTION 3. SCOPE
This revenue procedure applies to
mortgage loans financed with qualified
mortgage bonds and to mortgage credit
certificates.
SECTION 4. APPLICATION
.01 Applicable Income Figures. Except
as provided in section 4.02 of this revenue
procedure, for purposes of computing the
income requirements of § 143(f), issuers
of qualified mortgage bonds or mortgage
credit certificates must use either (1) the
income figures HUD released most recent­
ly (Most Recent HUD Figures) or (2) the
income figures HUD released immediate­
ly prior to the Most Recent HUD Figures
(Immediately Prior HUD Figures), deter­
mined as of the date a mortgage loan or
mortgage credit certificate is committed to
a mortgagor.
.02 Transition Period. For mortgage
loans and mortgage credit certificates
committed to mortgagors no later than 90
days after the date on which HUD releas­
es updated income figures for the calendar
year, issuers of qualified mortgage bonds
or mortgage credit certificates may contin­
ue to use the income figures HUD released
during the second preceding calendar year
for purposes of computing the income re­
quirements of § 143(f).
.03 Consistency Requirement. If an is­
suer uses the Most Recent HUD Figures
to compute the housing cost/income ratio
under § 143(f)(5), the issuer must use the
Most Recent HUD Figures for all purpos­
es under § 143(f). Likewise, if an issuer
uses the Immediately Prior HUD Figures
to compute the housing cost/income ratio
under § 143(f)(5), the issuer must use the
Immediately Prior HUD Figures for all
purposes under § 143(f). For example, if
an issuer uses the income figures HUD
released in 2021 to compute the housing
cost/income ratio under § 143(f)(5), the
issuer must use the income figures HUD
released in 2021 for all purposes under
§ 143(f). Likewise, if an issuer uses the
income figures HUD released in 2020 to
compute the housing cost/income ratio

April 12, 2021 1010 Bulletin No. 2021–15
under § 143(f)(5), the issuer must use the
income figures HUD released in 2020 for
all purposes under § 143(f).
SECTION 5. EFFECT ON OTHER
DOCUMENTS
.01 This revenue procedure obsoletes
Rev. Proc. 2020­33.
.02 This revenue procedure amplifies
Rev. Rul. 86­124.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective for
mortgage loans and mortgage credit cer­
tificates committed on or after March 25,
2021.
DRAFTING INFORMATION
The principal authors of this revenue
procedure are Jian H. Grant and David
White of the Office of Associate Chief
Counsel (Financial Institutions & Prod­
ucts). For further information regarding
this revenue procedure contact Mr. White
at (202) 317­6980 (not a toll­free number).

Bulletin No. 2021–15 1011 April 12, 2021
Part IV
Announcement And RepoRt
conceRning
AdvAnce pRicing AgReements
March 23, 2021
Announcement 2021-6
This Announcement is issued pursuant to § 521(b) of Pub. L. 106­170, the Ticket to Work and Work Incentives Improvement Act of
1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs)
and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement
Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year
2000 through 2019 separately. This twenty­second report describes the experience, structure, and activities of the APMA Program
during calendar year 2020. It does not provide guidance regarding the application of the arm’s length standard.
Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents statisti­
cal data; and Part III includes general descriptions of various elements of the APAs executed in 2020, including types of transactions
covered, transfer pricing methods used, and completion time.
John C. C. Hughes
Director, Advance Pricing and Mutual Agreement Program

April 12, 2021 1012 Bulletin No. 2021–15
Part I. The APMA Program – Structure, Composition, and Operation
[Pub. L. 106-170 § 521(b)(2)(A)]
In February 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations
1

within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff responsible
for transfer pricing cases, thereby forming the APMA Program.
In September 2018, APMA restructured its management and realigned its teams. As of December 31, 2020, the APMA Program com­
prised 64 team leaders, 21 economists, 9 managers, and 3 assistant directors. Each assistant director oversees 3 managers who lead
teams comprised of both team leaders and economists. The APMA Program’s main office is in Washington, DC, and it also has offices
in northern California (San Francisco and San Jose), southern California (Los Angeles and Laguna Niguel), Chicago, and New York.
On August 31, 2015, new revenue procedures governing requests under the mutual agreement procedure (MAP) and APA appli­
cations were published in 2015­35 I.R.B. on pages 236 and 263, respectively. Revenue Procedure (Rev. Proc.) 2015­41 provides
guidance and instructions on filing APA requests as well as guidance and information on the administration of APAs. Rev. Proc.
2015­41 updates and supersedes Rev. Proc. 2006­9, 2006­1 C.B. 278, as modified by Rev. Proc. 2008­31, 2008­1 C.B. 1133, which is
also superseded. Rev. Proc. 2015­40 provides procedures and guidance on requesting assistance from the U.S. Competent Authority
where the taxpayer believes that the actions of the United States or a treaty country result or will result in the taxpayer being subject
to taxation not in accordance with the applicable U.S. tax treaty. Rev. Proc. 2015­40 updates and supersedes Rev. Proc. 2006­54,
2006­2 C.B. 1035.
Model APAs appear as appendices to this report. Appendix 1 is the model for APAs covered by Rev. Proc. 2006­9. Appendix 2 is the
current model APA for APAs covered by Rev. Proc. 2015­41. A list of primary APMA contacts is available at https://www.irs.gov/
businesses/corporations/apma­contacts.
1
In 2017, Transfer Pricing Operations became Treaty & Transfer Pricing Operations.

Bulletin No. 2021–15 1013 April 12, 2021
Part II. APMA Program Statistical Data
[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]
Table 1: APA Applications Filed
§ 521(b)(2)(C)(i)
2
Unilateral Bilateral MultilateralTotal
Filed 1991­1999
2
401
Filed 2000­20196221,621262,269
Filed in 2020151033121
Total Filed 1991-2020 2,791
3
Part II. APMA Program Statistical Data
[Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]
Table 1: APA Applications Filed
§ 521(b)(2)(C)(i)
Unilateral Bilateral MultilateralTotal
Filed 1991­1999
2
401
Filed 2000­20196221,621262,269
Filed in 2020151033121
Total Filed 1991-20202,791
The charts above illustrate the number of complete applications filed per year and the bilateral
requests received in 2020 by foreign country. As of December 31, 2020, APMA had also
received 25 user fee filings that were not yet accompanied by substantially complete APA
applications, in addition to the 121 complete APA applications.

2
The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number
of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
0
50
100
150
200
250
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
APA Applications Filed
2011-2020
Japan
41%
India
11%
Canada
10%
Germany
7%
Switzerland
5%
Korea
4%
United Kingdom
4%
18%
A
ll Other Countries
Bilateral APA Applications Filed
by Country
The charts above illustrate the number of complete applications fi led per year and the bilateral requests received in 2020 by foreign
country. As of December 31, 2020, APMA had also received 25 user fee fi lings that were not yet accompanied by substantially com­
plete APA applications, in addition to the 121 complete APA applications.
2
The fi rst APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals
cannot be reported in that manner.

April 12, 2021 1014 Bulletin No. 2021–15
Table 2: Executed
3
and Pending APAs
§ 521(b)(2)(C)(ii-vi)45
Unilateral Bilateral MultilateralTotal
Total Executed 1991­20196431,280171,940
Total Executed in 2020191053127
Total Executed 1991-20206621,385202,067
Total Pending as of 12/31/20204338421448
Renewals Executed in 2020
4
1164075
Renewals Pending
5
as of 12/31/2020251548187
4
Table 2: Executed
3
§ 521(b)(2)(C)(ii-vi)
and Pending APAs
Unilateral Bilateral Multilateral
Total
Total Executed 1991­20196431,280171,940
Total Executed in 2020191053127
Total Executed 1991-20206621,385202,067
Total Pending as of 12/31/20204338421448
Renewals Executed in 2020
4
1164075
Renewals Pending
5
25as of 12/31/20201548187
In 2020, the percentage of renewals executed remained fairly consistent (59 percent in 2020
versus 57 percent in 2019). The charts above illustrate the total number of APAs executed per

3
Executed APAs refer to all APAs finalized or renewed.
4
The number of renewals executed is included in the total number of APAs executed during the year.
5
The number of renewals still pending as of year­end is also included in the total number of pending APAs.
Executed APAs
2011-2020
0
50
100
150
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Executed Bilateral APAs
by Country
Japan
52%
India
11%
Canada
8%
United Kingdom
7%
Denmark
4%
All Other Countries
18%
In 2020, the percentage of renewals executed remained fairly consistent (59 percent in 2020 versus 57 percent in 2019). The charts
above illustrate the total number of APAs executed per year and the countries involved in the executed bilateral APAs.
3
Executed APAs refer to all APAs fi nalized or renewed.
4
The number of renewals executed is included in the total number of APAs executed during the year.
5
The number of renewals still pending as of year­end is also included in the total number of pending APAs.

Bulletin No. 2021–15 1015 April 12, 2021
5
year and the countries involved in the executed bilateral APAs.
As the top chart illustrates, the number of pending requests decreased slightly relative to
December 31,2019. As of December 31, 2020, over half of the pending bilateral APA requests
involved either Japan, India, or Canada.
Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)
Unilateral Bilateral Multilateral
Total
Revoked or Cancelled in 20200000
Total Revoked or Cancelled 1991-2020
6
11
Applications Withdrawn in 20202507
Total Applications Withdrawn 1991-2020
7
272

6
The first APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number
of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.
7
See supranote 6.
Pending APAs
2011-2020
0
100
200
300
400
500
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Pending Bilateral APAs
by Country
All Other Countries
Japan
United Kingdom
16%
25%
4%
Italy
4%
Mexico
5%
Korea
India
5%
20%
Germany
Canada
10%
11%
As the top chart illustrates, the number of pending requests decreased slightly relative to December 31, 2019. As of December 31,
2020, over half of the pending bilateral APA requests involved either Japan, India, or Canada.
Table 3: APAs Revoked or Cancelled and Applications Withdrawn
§ 521(b)(2)(C)(vii)
67
Unilateral Bilateral MultilateralTotal
Revoked or Cancelled in 20200000
Total Revoked or Cancelled 1991-2020
6
11
Applications Withdrawn in 20202507
Total Applications Withdrawn 1991-2020
7
272
6
The fi rst APA Statutory Report, which compiled APA data from 1991­1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals
cannot be reported in that manner.
7
See supra note 6.

April 12, 2021 1016 Bulletin No. 2021–15
Table 4: APAs Executed in 2020 by Industry
§ 521(b)(2)(C)(viii)
Industry
Manufacturing43
Wholesale/Retail Trade40
Services22
Finance, Insurance, and Real Estate11
Management9
All Other Industries2
6
Table 4: APAs Executed in 2020 by Industry
§ 521(b)(2)(C)(viii)
Industry
Manufacturing43
Wholesale/Retail Trade40
Services22
Finance, Insurance, and Real Estate11
Management9
All Other Industries2
Table 4a: Manufacturing APAs Executed in 2020
Manufacturing
Chemical Manufacturing8
Transportation Equipment Manufacturing8
Miscellaneous Manufacturing7
Food Manufacturing6
Computer and Electronic Product Manufacturing5
Machinery Manufacturing3
Plastics and Rubber Products Manufacturing3
All Other Manufacturing3
Manufacturing
34%
Wholesale/Retail
Trade
31%
Services
17%
Finance, Insurance
and Real Estate
9%
Management
7%
All Other Industries
2%
APAs Executed
in 2020 by Industry
Table 4a: Manufacturing APAs Executed in 2020
Manufacturing
Chemical Manufacturing8
Transportation Equipment Manufacturing8
Miscellaneous Manufacturing7
Food Manufacturing6
Computer and Electronic Product Manufacturing5
Machinery Manufacturing3
Plastics and Rubber Products Manufacturing3
All Other Manufacturing3
7
Table 4b: Wholesale/Retail Trade APAs Executed in 2020
Wholesale/Retail Trade
Merchant Wholesalers, Durable Goods 24
Merchant Wholesalers, Nondurable Goods
8
Electronics and Appliance Stores
5
All Other Wholesalers
3
Chemical
Manufacturing
19%
Transportation
Equipment
Manufacturing
19%
Miscellaneous
Manufacturing
16%
Food Manufacturing
14%
Computer and
Electronic Product
Manufacturing
11%
Machinery
Manufacturing
7%
Plastics and Rubber
Products
Manufacturing
7%
All Other
Manufacturing
7%
Manufacturing APAs
Executed in 2020
Merchant
Wholesalers, Durable
Goods
60%
Merchant
Wholesalers,
Nondurable Goods
20%
Electronics and
Appliance Stores
12%
All Other
Wholesalers
8%
Wholesale/Retail Trade APAs
Executed in 2020

Bulletin No. 2021–15 1017 April 12, 2021
Table 4b: Wholesale/Retail Trade APAs Executed in 2020
Wholesale/Retail Trade
Merchant Wholesalers, Durable Goods 24
Merchant Wholesalers, Nondurable Goods8
Electronics and Appliance Stores5
All Other Wholesalers3
7
Table 4b: Wholesale/Retail Trade APAs Executed in 2020
Wholesale/Retail Trade
Merchant Wholesalers, Durable Goods 24
Merchant Wholesalers, Nondurable Goods
8
Electronics and Appliance Stores
5
All Other Wholesalers
3
Chemical
Manufacturing
19%
Transportation
Equipment
Manufacturing
19%
Miscellaneous
Manufacturing
16%
Food Manufacturing
14%
Computer and
Electronic Product
Manufacturing
11%
Machinery
Manufacturing
7%
Plastics and Rubber
Products
Manufacturing
7%
All Other
Manufacturing
7%
Manufacturing APAs
Executed in 2020
Merchant
Wholesalers, Durable
Goods
60%
Merchant
Wholesalers,
Nondurable Goods
20%
Electronics and
Appliance Stores
12%
All Other
Wholesalers
8%
Wholesale/Retail Trade APAs
Executed in 2020
Part III. General Descriptions of APAs Executed in 2020
[Pub. L. 106-170 § 521(b)(2)(D) and (E)]
Nature of the Relationships
§ 521(b)(2)(D)(i)
Non­U.S. Parent &
U.S. Subsidiary
61%
U.S. Parent & Non­
U.S. Subsidiary
27%
Sister Companies
11%
All Other
Relationships
1%
Relationships between
Controlled Parties
8
Part III. General Descriptions of APAs Executed in 2020
[Pub. L. 106-170 § 521(b)(2)(D) and (E)]
Nature of the Relationships
§ 521(b)(2)(D)(i)
As in prior years, more than half of the APAs executed in 2020 involved transactions between
non­U.S. parents and U.S. subsidiaries.
Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)
Although most of the transactions
8

8
APAs often cover more than one type of transaction.
covered in APAs executed in 2020 involve the sale of
tangible goods or the provision of services, approximately 25 percent of transactions covered in
APAs executed in 2020 involve the use of intangible property, which can be among the most
challenging transactions in APMA’s inventory.
Sale of Tangible
Property into the U.S.
25%
Provision of Services
by a U.S. Entity
19%
Provision of Services
by a Non­U.S. Entity
19%
Use of Intangible
Property by a U.S.
Entity
18%
Sale of Tangible
Property from the
U.S.
10%
Use of Intangible
Property by a Non­
U.S. Entity
6%
All Other Types of
Transactions
3%
Types of Covered Transactions
As in prior years, more than half of the APAs executed in 2020 involved transactions between non­U.S. parents and U.S. subsidiaries.

April 12, 2021 1018 Bulletin No. 2021–15
Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)
8
Part III. General Descriptions of APAs Executed in 2020
[Pub. L. 106-170 § 521(b)(2)(D) and (E)]
Nature of the Relationships
§ 521(b)(2)(D)(i)
As in prior years, more than half of the APAs executed in 2020 involved transactions between
non­U.S. parents and U.S. subsidiaries.
Covered Transactions, Functions and Risks, and Tested Parties
§ 521(b)(2)(D)(ii-iii)
Although most of the transactions
8

8
APAs often cover more than one type of transaction.
covered in APAs executed in 2020 involve the sale of
tangible goods or the provision of services, approximately 25 percent of transactions covered in
APAs executed in 2020 involve the use of intangible property, which can be among the most
challenging transactions in APMA’s inventory.
Non­U.S. Parent &
U.S. Subsidiary
61%
U.S. Parent & Non­
U.S. Subsidiary
27%
Sister Companies
11%
All Other
Relationships
1%
Relationships between
Controlled Parties
Sale of Tangible
Property into the U.S.
25%
Provision of Services
by a U.S. Entity
19%
Provision of Services
by a Non­U.S. Entity
19%
Use of Intangible
Property by a U.S.
Entity
18%
Sale of Tangible
Property from the
U.S.
10%
Use of Intangible
Property by a Non­
U.S. Entity
6%
All Other Types of
Transactions
3%
Types of Covered Transactions
Although most of the transactions
8
covered in APAs executed in 2020 involve the sale of tangible goods or the provision of services,
approximately 25 percent of transactions covered in APAs executed in 2020 involve the use of intangible property, which can be
among the most challenging transactions in APMA’s inventory.
In the majority of APAs, the covered transactions involve numerous business functions and risks. For instance, with respect to func­
tions, APAs involving manufactured products typically involve a controlled group that conducts research and development (R&D),
engages in product design and engineering, manufactures the product, markets and distributes the product, and performs support
functions such as legal, fi nance, and human resources. Regarding risks, the controlled group may assume a variety of risks, including
market risks, R&D risks, fi nancial risks, credit and collection risks, product liability risks, and general business risks. In the APA eval­
uation process, a signifi cant amount of time and effort is devoted to understanding how the functions and risks are allocated amongst
the controlled group of companies that are party to the covered transactions. For methods requiring selection of a tested party, the
tested party that is chosen generally will be the least complex of the controlled taxpayers.
9
In the majority of APAs, the covered transactions involve numerous business functions and risks.
For instance, with respect to functions, APAs involving manufactured products typically involve
a controlled group that conducts research and development (R&D), engages in product design
and engineering, manufactures the product, markets and distributes the product, and performs
support functions such as legal, finance, and human resources. Regarding risks, the controlled
group may assume a variety of risks, including market risks, R&D risks, financial risks, credit
and collection risks, product liability risks, and general business risks. In the APA evaluation
process, a significant amount of time and effort is devoted to understanding how the functions
and risks are allocated amongst the controlled group of companies that are party to the covered
transactions. For methods requiring selection of a tested party, the tested party that is chosen
generally will be the least complex of the controlled taxpayers.
Consistent with prior years, a majority of tested parties
9
in 2020were U.S. distributors, U.S.
manufacturers, or U.S. service providers.
Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)
In 2020, the most commonly used transfer pricing method (TPM) for both the sale of tangible
property and the use of intangible property continued to be the comparable profits
method/transactional net margin method (CPM/TNMM). The CPM/TNMM was used for 84
percent of transfers of tangible and intangible property.
For covered transfers of tangible and intangible property that used the CPM/TNMM, the
operating margin (OM) is still the most common profit level indicator (PLI) used to benchmark
results. It was used 69 percent of the time. Other PLIs, such as the Berry Ratio and net cost plus,
made up the other 31 percent. As used here, “OM” is defined as the ratio of operating profit to
sales,
10
and “Berry Ratio” is defined as the ratio of gross profit to operating expenses.
11

9
Not all the executed APAs involve a tested party.
Most
10
SeeTreas. Reg. § 1.482­5(b)(4)(ii)(A).
11
SeeTreas. Reg. § 1.482­5(b)(4)(ii)(B).
U.S. Distributor
41%
U.S. Service Provider
17%
Non­U.S. Service
Provider
16%
U.S. Manufacturer
15%
Non­U.S. Distributor
10%
All Othey Types of
Tested Parties
1%
Types of Tested Parties
Consistent with prior years, a majority of tested parties
9
in 2020 were U.S. distributors, U.S. manufacturers, or U.S. service providers.
8
APAs often cover more than one type of transaction.
9
Not all the executed APAs involve a tested party.

Bulletin No. 2021–15 1019 April 12, 2021
Transfer Pricing Methods Used
§ 521(b)(2)(D)(iv)
In 2020, the most commonly used transfer pricing method (TPM) for both the sale of tangible property and the use of intangible
property continued to be the comparable profits method/transactional net margin method (CPM/TNMM). The CPM/TNMM was used
for 84 percent of transfers of tangible and intangible property.
For covered transfers of tangible and intangible property that used the CPM/TNMM, the operating margin (OM) is still the most com­
mon profit level indicator (PLI) used to benchmark results. It was used 69 percent of the time. Other PLIs, such as the Berry Ratio and
net cost plus, made up the other 31 percent. As used here, “OM” is defined as the ratio of operating profit to sales,
10
and “Berry Ratio”
is defined as the ratio of gross profit to operating expenses.
11
Most services transactions (85 percent) also used the CPM/TNMM with
the OM and operating profit to operating expense being the most common PLIs (used 57 percent of the time).
12
Sources of Comparables, Comparables Selection Criteria, and Nature of Adjustments to Comparables or Tested Party Data
§ 521(b)(2)(D)(v-vii)
For the APAs executed in 2020 that involved CPM/TNMM with a North American tested party, the most widely used data source for
comparables was Standard and Poor’s Compustat/Capital IQ database. Different sources were used in other cases (e.g., where the
tested party was not a U.S. or Canadian entity or where transaction­based methods were applied). The other most commonly used
databases are listed in the table below.
Table 5: Sources of Comparable Data
Avention (formerly known as OneSource)Mergent
BloombergOrbis
Bureau van Dijk (BvD)Prowess
Global VantageRoyaltySource
ktMINERoyaltyStat
LoanConnectorWorldscope
In making comparability adjustments, typical balance sheet adjustments, as identified in Treas. Reg. §§ 1.482­1(d)(2) and 1.482­5(c)
(2)(iv), were made in most cases, including adjustments for differing amounts of payables, receivables, and inventory. Where appro­
priate, adjustments for different accounting practices were made to convert from LIFO to FIFO inventory accounting, and a small
number of cases also involved the accounting reclassification of expenses, e.g., from COGS to operating expenses.
Ranges, Goals, and Adjustment Mechanisms
§ 521(b)(2)(D)(viii-ix)
Most transactions covered in APAs target an interquartile range as described in Treas. Reg. § 1.482­1(e)(2)(iii)(C). Where the trans­
action involves a royalty payment for the use of intangible property, both specific royalty rates and ranges have been used. Where the
covered transaction is the sale or license of intangible property, and the payment for such transfer would be a royalty based solely on
external comparable uncontrolled transactions, a secondary or confirming method, e.g., a test of the post­royalty operating margin
or cost­plus mark­up, has sometimes also been used. The testing periods of the APAs executed in 2020 were either a single year, the
term of the APA only, or the term of the APA plus rollback years.
APAs executed in 2020 included several mechanisms for making adjustments to the tested party results when the results fall outside
the range or do not match the point required by the APA. Examples of the mechanisms used are an adjustment bringing the tested
party’s results to the closer edge of the range applied to the results of a single year, an adjustment to the closer edge of the range
applied to the results over the APA term, an adjustment to the specified point or royalty rate, or an adjustment to the median of the
range for a single year.
10
See Treas. Reg. § 1.482­5(b)(4)(ii)(A).
11
See Treas. Reg. § 1.482­5(b)(4)(ii)(B).
12
The majority of APAs that covered services transactions also included tangible/intangible transactions and are not tested under a separate PLI.

April 12, 2021 1020 Bulletin No. 2021–15
Critical Assumptions
§ 521(b)(2)(D)(v)
The model APAs used by the IRS (included as Appendix 1 of this report) include standard critical assumptions that there will be no
material changes to the taxpayer’s business or to its tax or financial accounting practices during the APA term. A few bilateral cases
have also included critical assumptions tied to the taxpayer’s profitability in a certain year or over the term of the APA. Pursuant to
§ 7.06(3) of Rev. Proc. 2015­41, APMA will cancel an APA in the event of a failure of a critical assumption unless the parties agree
to revise the APA.
Term Lengths of APAs Executed in 2020
§ 521(b)(2)(D)(x)
Table 6: Term Lengths of APAs Executed in 2020
Term Length
(years)
Number of
APAs
11
22
33
44
562
615
724
811
94
141
Average6
As described in § 3.03(1) of Rev. Proc. 2015­41, taxpayers should request an APA term that would cover at least five prospective
years and may also request that the APA be “rolled back” to cover one or more earlier taxable years, although the appropriate
APA term is decided on a case­by­case basis. Of the APAs executed in 2020, 11 percent included rollback years. A substantial number
of those APAs with terms of greater than five years were submitted as a request for a five­year term, and the additional years were
agreed to between the taxpayer and the IRS (or, in the case of a bilateral APA, between the IRS and the foreign government upon the
taxpayer’s request) to ensure a reasonable amount of prospectivity in the APA term.
Amount of Time Taken to Complete New and Renewal APAs
§ 521(b)(2)(E)
Table 7: Months to Complete New and Renewal APAs Executed in 2020

Unilateral Bilateral Unilateral & Bilateral
AverageMedianAverageMedianAverageMedian
New 36.235.350.843.748.943.7
Renewal 25.421.034.130.332.829.6
New & Renewal29.024.040.136.338.532.7

Bulletin No. 2021–15 1021 April 12, 2021
Months to Complete New and Renewal APAs Executed in 2020
0.0
10.0
20.0
30.0
40.0
50.0
60.0
AverageMedianAverageMedianAverageMedian
Unilateral Bilateral Unilateral &
Bilateral
Months to Complete
Type of APA
New
Renewal
New &
Renewal
12
Amount of Time Taken to Complete New and Renewal APAs
§ 521(b)(2)(E)
Table 7: Months to Complete New and Renewal APAs Executed in 2020
Unilateral Bilateral
Unilateral & Bilateral
AverageMedianAverageMedian
AverageMedian
New36.235.350.843.7
48.943.7
Renewal 25.421.034.130.3
32.829.6
New & Renewal29.024.040.136.338.532.7
Months to Complete New and Renewal APAs Executed in 2020
The median time required to complete an APA continued to decrease in 2020 to 32.7 months
(from 38.8 months in 2019 and 40.2 months in 2018).
Efforts to Ensure Compliance with APAs
§ 521(b)(2)(F)
As described in § 7.02(1) of Rev. Proc. 2015­41, taxpayers are required to file annual reports to
demonstrate compliance with the terms and conditions of their APAs. The filing and review of
these annual reports are critical parts of the APA process. Through annual report review, the
APMA Program monitors taxpayer compliance with APAs on a contemporaneous basis. Annual
report review also provides current information on the success or problems associated with the
various TPMs adopted in the APA process.
The median time required to complete an APA continued to decrease in 2020 to 32.7 months (from 38.8 months in 2019 and 40.2
months in 2018).
Efforts to Ensure Compliance with APAs
§ 521(b)(2)(F)
As described in § 7.02(1) of Rev. Proc. 2015­41, taxpayers are required to fi le annual reports to demonstrate compliance with the
terms and conditions of their APAs. The fi ling and review of these annual reports are critical parts of the APA process. Through annual
report review, the APMA Program monitors taxpayer compliance with APAs on a contemporaneous basis. Annual report review also
provides current information on the success or problems associated with the various TPMs adopted in the APA process.
Nature of Documentation Required in Annual Report
§ 521(b)(2)(D)(xi)
APAs require taxpayers to fi le timely and complete annual reports describing their operations and demonstrating compliance with the
APA’s terms and conditions. Not every annual report will include each of the items listed in the following table
13
; they are required
where the facts demonstrate a need for such documentation.
Statement regarding all material differences between Taxpayer’s business operations during APA year and description of
1.
Taxpayer’s business operations contained in Taxpayer’s APA request. If there are no material differences, a statement to
that effect.
Statement concerning all material changes in Taxpayer’s accounting methods and classifi cations, and methods of estima­
2.
tion, from those described or used in Taxpayer’s request for the APA. If there has been no material change in accounting
methods and classifi cations or methods of estimation, a statement to that effect.
3.
Any change to the Taxpayer notice information.
4.
Description of any failure to meet critical assumptions. If there has been none, a statement to that effect.
Statement identifying whether any material information submitted while the APA request was pending is discovered to be
5.
false, incorrect, or incomplete.
The amount, reason for, and fi nancial analysis of any compensating adjustment, for the APA year, including but not limited
to the amounts paid or received by each affected entity; the character (such as capital or ordinary expense) and country
6
source of the funds transferred, and the specifi c line item(s) of any affected U.S. tax return; and any change to any entity
classifi cation for federal income tax purposes of any member of Taxpayer’s group that is relevant to the APA.
The amounts, description, reason for, and fi nancial analysis of any book­tax difference relevant to the TPM for the APA
7.
year, as refl ected on Schedule M­1 or Schedule M­3 of the U.S. return for the APA year.
8.
Statement regarding whether Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.
13
The source of this list is the 2009 Model APA and requirements remain largely unchanged in the 2015 Model APA.

April 12, 2021 1022 Bulletin No. 2021–15
Financial statements and any necessary account detail to show compliance with the TPM, with a copy of the opinion from
9.
an independent certified public accountant or other documentation required by paragraph 5(f) of the APA.
10.
Financial analysis demonstrating Taxpayer’s compliance with TPM.
11.
Organizational chart.
12.
A copy of the APA and any amendment.
13.
A penalty of perjury statement.
Approaches for Sharing of Currency or Other Risks
§ 521(b)(2)(D)(xii)
In appropriate cases, APAs may provide specific approaches for dealing with risks, including currency risk, such as adjustment mech­
anisms and/or critical assumptions.

Bulletin No. 2021–15 1023 April 12, 2021
APPENDIX 1– Model APA (based on Rev. Proc. 2006-9)
ADVANCE PRICING AGREEMENT
between
[Insert Taxpayer’s Name]
and
THE INTERNAL REVENUE SERVICE
PARTIES
The Parties to this Advance Pricing Agreement (APA) are the Internal Revenue Service (IRS) and [Insert Taxpayer’s Name], EIN
________.
RECITALS
[Insert Taxpayer Name] is the common parent of an affiliated group filing consolidated U.S. tax returns (collectively referred to as
“Taxpayer”), and is entering into this APA on behalf of itself and other members of its consolidated group.
Taxpayer’s principal place of business is [City, State]. [Insert general description of taxpayer and other relevant parties].
This APA contains the Parties’ agreement on the best method for determining arm’s­length prices of the Covered Transactions
under I.R.C. section 482, the Treasury Regulations thereunder, and any applicable tax treaties.
{If renewal, add} [Taxpayer and IRS previously entered into an APA covering taxable years ending _____ to ______, executed on
________.]
AGREEMENT
The Parties agree as follows:
1. Covered Transactions. This APA applies to the Covered Transactions, as defined in Appendix A.
2. Transfer Pricing Method. Appendix A sets forth the Transfer Pricing Method (TPM) for the Covered Transactions.
3. Term. This APA applies to the APA Term, as defined in Appendix A.
4. Operation.
a. Revenue Procedure 2006­9 governs the interpretation, legal effect, and administration of this APA.
b. Nonfactual oral and written representations, within the meaning of sections 10.04 and 10.05 of Revenue Procedure 2006­9
(including any proposals to use particular TPMs), made in conjunction with the APA Request constitute statements made in
compromise negotiations within the meaning of Rule 408 of the Federal Rules of Evidence.
5. Compliance.
a. Taxpayer must report its taxable income in an amount that is consistent with Appendix A and all other requirements of this
APA on its timely filed U.S. Return. However, if Taxpayer’s timely filed U.S. Return for any taxable year covered by this
APA (APA Year) is filed prior to, or no later than 60 days after, the effective date of this APA, then Taxpayer must report its
taxable income for that APA Year in an amount that is consistent with Appendix A and all other requirements of this APA
either on the original U.S. Return or on an amended U.S. Return filed no later than 120 days after the effective date of this
APA, or through such other means as may be specified herein.
b. {Use or edit the following when U.S. Group or Foreign Group contains more than one member.} [This APA addresses the
arm’s­length nature of prices charged or received in the aggregate between Taxpayer and Foreign Participants with respect
to the Covered Transactions. Except as explicitly provided, this APA does not address and does not bind the IRS with respect
to prices charged or received, or the relative amounts of income or loss realized, by particular legal entities that are members
of U.S. Group or that are members of Foreign Group.]

April 12, 2021 1024 Bulletin No. 2021–15
c. For each APA Year, if Taxpayer complies with the terms and conditions of this APA, then the IRS will not make or propose
any allocation or adjustment under I.R.C. section 482 to the amounts charged in the aggregate between Taxpayer and For­
eign Participant[s] with respect to the Covered Transactions.
d. If Taxpayer does not comply with the terms and conditions of this APA, then the IRS may:
i. enforce the terms and conditions of this APA and make or propose allocations or adjustments under I.R.C. section 482
consistent with this APA;
ii. cancel or revoke this APA under section 11.06 of Revenue Procedure 2006­9; or
iii. revise this APA, if the Parties agree.
e. Taxpayer must timely file an Annual Report (an original and four copies) for each APA Year in accordance with Appendix C
and section 11.01 of Revenue Procedure 2006­9. Taxpayer must file the Annual Report for all APA Years through the APA
Year ending [insert year] by [insert date]. Taxpayer must file the Annual Report for each subsequent APA Year by [insert
month and day] immediately following the close of that APA Year. (If any date falls on a weekend or holiday, the Annual
Report shall be due on the next date that is not a weekend or holiday.) The IRS may request additional information reason­
ably necessary to clarify or complete the Annual Report. Taxpayer will provide such requested information within 30 days.
Additional time may be allowed for good cause.
f. The IRS will determine whether Taxpayer has complied with this APA based on Taxpayer’s U.S. Returns, the Financial
Statements, and other APA Records, for the APA Term and any other year necessary to verify compliance. For Taxpayer
to comply with this APA, {use the following or an alternative} an independent certified public accountant must render an
opinion that Taxpayer’s Financial Statements present fairly, in all material respects, Taxpayer’s financial position under U.S.
GAAP.
g. In accordance with section 11.04 of Revenue Procedure 2006­9, Taxpayer will (1) maintain the APA Records, and (2) make
them available to the IRS in connection with an examination under section 11.03. Compliance with this subparagraph consti­
tutes compliance with the record­maintenance provisions of I.R.C. sections 6038A and 6038C for the Covered Transactions
for any taxable year during the APA Term.
h. The True Taxable Income within the meaning of Treasury Regulations sections 1.482­1(a)(1) and (i)(9) of a member of an
affiliated group filing a U.S. consolidated return will be determined under the I.R.C. section 1502 Treasury Regulations.
i. {Optional for US Parent Signatories} To the extent that Taxpayer’s compliance with this APA depends on certain acts of
Foreign Group members, Taxpayer will ensure that each Foreign Group member will perform such acts.
6. Critical Assumptions. This APA’s critical assumptions, within the meaning of Revenue Procedure 2006­9, section 4.05, appear in
Appendix B. If any critical assumption has not been met, then Revenue Procedure 2006­9, section 11.06, governs.
7. Disclosure. This APA, and any background information related to this APA or the APA Request, are: (1) considered “return in­
formation” under I.R.C. section 6103(b)(2)(C); and (2) not subject to public inspection as a “written determination” under I.R.C.
section 6110(b)(1). Section 521(b) of Pub. L. 106­170 provides that the Secretary of the Treasury must prepare a report for public
disclosure that includes certain specifically designated information concerning all APAs, including this APA, in a form that does
not reveal taxpayers’ identities, trade secrets, and proprietary or confidential business or financial information.
8. Disputes. If a dispute arises concerning the interpretation of this APA, the Parties will seek a resolution by the Director of the
Advance Pricing and Mutual Agreement Program, to the extent reasonably practicable, before seeking alternative remedies.
9. Materiality. In this APA the terms “material” and “materially” will be interpreted consistently with the definition of “material
facts” in Revenue Procedure 2006­9, section 11.06(4).
10. Section Captions. This APA’s section captions, which appear in italics, are for convenience and reference only. The captions do
not affect in any way the interpretation or application of this APA.
11. Terms and Definitions. Unless otherwise specified, terms in the plural include the singular and vice versa. Appendix D contains
definitions for capitalized terms not elsewhere defined in this APA.
12. Entire Agreement and Severability. This APA is the complete statement of the Parties’ agreement. The Parties will sever, delete,
or reform any invalid or unenforceable provision in this APA to approximate the Parties’ intent as nearly as possible.
13. Successor in Interest. This APA binds, and inures to the benefit of, any successor in interest to Taxpayer.
14. Notice. Any notices required by this APA or Revenue Procedure 2006­9 must be in writing. Taxpayer will send notices to the IRS
at the address and in the manner set forth in Revenue Procedure 2006­9, section 4.11. The IRS will send notices to:
Taxpayer Corporation
Attn: Jane Doe, Sr. Vice President (Taxes)
1000 Any Road
Any City, USA 10000
(phone: _________)

Bulletin No. 2021–15 1025 April 12, 2021
15. Effective Date and Counterparts. This APA is effective starting on the date, or later date of the dates, upon which all Parties
execute this APA. The Parties may execute this APA in counterparts, with each counterpart constituting an original.
WITNESS,
The Parties have executed this APA on the dates below.
[Taxpayer Name in all caps]
By: ___________________________ Date: ___________________, 201___
Jane Doe
Sr. Vice President (Taxes)
IRS
By: ___________________________ Date: ___________________, 201___
John C. C. Hughes
Director, Advance Pricing and Mutual Agreement Program

April 12, 2021 1026 Bulletin No. 2021–15
APPENDIX A
COVERED TRANSACTIONS AND TRANSFER PRICING METHOD (TPM)
1. Covered Transactions.
[Define the Covered Transactions.]
2. APA Term.
This APA applies to Taxpayer’s taxable years ending __________ through ________ (APA Term).
3. TPM.
{Note: If appropriate, adapt language from the following examples.}
[The Tested Party is __________.]
• CUP Method
The TPM is the comparable uncontrolled price (CUP) method. The Arm’s Length Range of the price charged for _________
is between _______ and ___________ per unit.
• CUT Method
The TPM is the CUT Method. The Arm’s Length Range of the royalty charged for the license of ______is between ____%
and ___ % of [Taxpayer’s, Foreign Participants’, or other specified party’s] Net Sales Revenue. [Insert definition of net sales
revenue or other royalty base.]
• Resale Price Method (RPM)
The TPM is the resale price method (RPM). The Tested Party’s Gross Margin for any APA Year is defined as follows: the
Tested Party’s gross profit divided by its sales revenue (as those terms are defined in Treasury Regulations sections 1.482­
5(d)(1) and (2)) for that APA Year. The Arm’s Length Range is between ____% and ___ %, and the Median of the Arm’s
Length Range is ___%.
• Cost Plus Method
The TPM is the cost plus method. The Tested Party’s Cost Plus Markup is defined as follows for any APA Year: the Tested
Party’s ratio of gross profit to production costs (as those terms are defined in Treasury Regulations sections 1.482­3(d)(1)
and (2)) for that APA Year. The Arm’s Length Range is between ___% and ___%, and the Median of the Arm’s Length Range
is ___%.
• CPM with Berry Ratio PLI
The TPM is the comparable profits method (CPM). The profit level indicator is a Berry Ratio. The Tested Party’s Berry Ratio
is defined as follows for any APA Year: the Tested Party’s gross profit divided by its operating expenses (as those terms are
defined in Treasury Regulations sections 1.482­5(d)(2) and (3)) for that APA Year. The Arm’s Length Range is between ____
and ___, and the Median of the Arm’s Length Range is ___.
• CPM using an Operating Margin PLI
The TPM is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested Party’s
Operating Margin is defined as follows for any APA Year: the Tested Party’s operating profit divided by its sales revenue (as

Bulletin No. 2021–15 1027 April 12, 2021
those terms are defined in Treasury Regulations section 1.482­5(d)(1) and (4)) for that APA Year. The Arm’s Length Range
is between ____% and ___ %, and the Median of the Arm’s Length Range is ___%.
• CPM using a Three-year Rolling Average Operating Margin PLI
The TPM is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested Party’s
Three­Year Rolling Average operating margin is defined as follows for any APA Year: the sum of the Tested Party’s operat­
ing profit (within the meaning of Treasury Regulation section 1.482­5(d)(4) for that APA Year and the two preceding years,
divided by the sum of its sales revenue (within the meaning of Treasury Regulation section 1.482­5(d)(1)) for that APA Year
and the two preceding years. The Arm’s Length Range is between ____% and ____%, and the Median of the Arm’s Length
Range is ___%.
• Residual Profit Split Method
The TPM is the residual profit split method. [Insert description of routine profit level determinations and residual profit-split
mechanism].
[Insert additional provisions as needed.]
4. Application of TPM.
For any APA Year, if the results of Taxpayer’s actual transactions produce a [price per unit, royalty rate for the Covered Transactions]
[or] [Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin, Three­Year Rolling Average Operating Margin for the Tested
Party] within the Arm’s Length Range, then the amounts reported on Taxpayer’s U.S. Return must clearly reflect such results.
For any APA year, if the results of Taxpayer’s actual transactions produce a [price per unit, royalty rate] [or] [Gross Margin, Cost
Plus Markup, Berry Ratio, Operating Margin, Three­Year Rolling Average Operating Margin for the Tested Party] outside the Arm’s
Length Range, then amounts reported on Taxpayer’s U.S. Return must clearly reflect an adjustment that brings the [price per unit,
royalty rate] [or] [Tested Party’s Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin, Three­Year Rolling Average Op­
erating Margin] to the Median.
For purposes of this Appendix A, the “results of Taxpayer’s actual transactions” means the results reflected in Taxpayer’s and Tested
Party’s books and records as computed under U.S. GAAP [insert another relevant accounting standard if applicable], with the fol­
lowing adjustments:
(a) [The fair value of stock­based compensation as disclosed in the Tested Party’s audited financial statements shall be treated as an
operating expense]; and
(b) To the extent that the results in any prior APA Year are relevant (for example, to compute a multi­year average), such results shall
be adjusted to reflect the amount of any adjustment made for that prior APA Year under this Appendix A.
5. APA Revenue Procedure Treatment
If Taxpayer makes an adjustment under paragraph 4 of this Appendix A (a “primary adjustment”), Taxpayer and its related foreign
entity may elect APA Revenue Procedure Treatment in accordance with section 11.02(3) of Revenue Procedure 2006­9 and avoid the
possible adverse tax consequences of a secondary adjustment that would otherwise follow the primary adjustment.
[Insert additional provisions as needed.]

April 12, 2021 1028 Bulletin No. 2021–15
APPENDIX B
CRITICAL ASSUMPTIONS
This APA’s critical assumptions are:
1. The business activities, functions performed, risks assumed, assets employed, and financial and tax accounting methods and
classifications [and methods of estimation] of Taxpayer in relation to the Covered Transactions will remain materially the same as
described or used in Taxpayer’s APA Request. A mere change in business results will not be a material change.
[Insert additional provisions as needed.]

Bulletin No. 2021–15 1029 April 12, 2021
APPENDIX C
APA RECORDS AND ANNUAL REPORT
APA RECORDS
The APA Records will consist of all documents listed below for inclusion in the Annual Report, as well as all documents, notes,
work papers, records, or other writings that support the information provided in such documents.
ANNUAL REPORT
The Annual Report (and each of the four copies required by paragraph 5(e) of this APA) will include:
1. Two copies of a properly completed APA Annual Report Summary in the form of Appendix E to this APA, one copy of the form
bound with, and one copy provided separately from, the rest of the Annual Report.
2. A table of contents, organized as follows:
3. Statements that fully identify, describe, analyze, and explain:
a. All material differences between the U.S. Group’s business operations (including functions, risks assumed, markets, con­
tractual terms, economic conditions, property, services, and assets employed) during the APA Year from the business oper­
ations described in the APA Request. If there have been no material differences, the Annual Report will include a statement
to that effect.
b. All material differences between the U.S. Group’s accounting methods and classifications, and methods of estimation used
during the APA Year, from those described or used in the APA Request. If any change was made to conform to changes in
U.S. GAAP (or other relevant accounting standards) Taxpayer will specifically identify the change. If there has been no ma­
terial change in accounting methods and classifications or methods of estimation, the Annual Report will include a statement
to that effect.
c. Any change to the Taxpayer notice information in paragraph 14 of this APA.
d. Any failure to meet any critical assumption. If there has been no failure, the Annual Report will include a statement to that
effect.
e. Whether or not material information submitted while the APA Request was pending is discovered to be false, incorrect, or
incomplete.
f. Any change to any entity classification for federal income tax purposes (including any change that causes an entity to be
disregarded for federal income tax purposes) of any Worldwide Group member that is a party to the Covered Transactions
or is otherwise relevant to the TPM.
g. The amount, reason for, and financial analysis of (1) any primary adjustments made under Appendix A for the APA Year; and
(2) any (a) secondary adjustments that follow such primary adjustments or (b) accounts receivable that Taxpayer establishes,
in lieu of secondary adjustments, by electing APA Revenue Procedure Treatment pursuant to paragraph 5 of Appendix A and
Revenue Procedure 2006­9, section 11.02(3), for the APA Year, including but not limited to:
i. the amounts due or owed, and paid or received by each affected entity;
ii. the character (such as capital, ordinary, income, expense) and country source of the funds transferred, and the specific
affected line item(s) of any affected U.S. Return;
iii. the date(s) and means by which the payments are or will be made; and

April 12, 2021 1030 Bulletin No. 2021–15
iv. whether or not APA Revenue Procedure Treatment was elected pursuant to paragraph 5 of Appendix A and Revenue
Procedure 2006­9, section 11.02(3).
h. The amounts, description, reason for, and financial analysis of any book­tax difference relevant to the TPM for the APA Year,
as reflected on Schedule M­1 or Schedule M­3 of the U.S. Return for the APA Year.
i. Whether Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.
4. The Financial Statements, and any necessary account detail to show compliance with the TPM, including consolidating financial
statements, segmented financial data, records from the general ledger, or similar information if the assets, liabilities, income, or
expenses relevant to showing compliance with the TPM are a subset of the assets, liabilities, income, or expenses presented in
the Financial Statements.
5. {Use the following or the alternative prescribed by paragraph 5(f) of this APA:} A copy of the independent certified public ac­
countant’s opinion required by paragraph 5(f) of this APA.
6. A financial analysis that reflects Taxpayer’s TPM calculations for the APA Year. The calculations must reconcile with and refer­
ence the information required under item 4 above in sufficient account detail to allow the IRS to determine whether Taxpayer has
complied with the TPM.
7. An organizational chart for the Worldwide Group, revised annually to reflect all ownership or structural changes of entities that
are parties to the Covered Transactions or are otherwise relevant to the TPM.
8. A copy of the APA and any amendment.
9. A penalty of perjury statement, executed in accordance with Revenue Procedure 2006­9, section 11.01(6) and (7).

Bulletin No. 2021–15 1031 April 12, 2021
APPENDIX D
DEFINITIONS
The following definitions control for all purposes of this APA. The definitions appear alphabetically below:
TermDefinition
Annual ReportA report within the meaning of Revenue Procedure 2006­9, section 11.01.
A PAThis Advance Pricing Agreement, which is an “advance pricing agreement” within the meaning of
Revenue Procedure 2006­9, section 2.04.
APA RecordsThe records specified in Appendix C.
APA RequestTaxpayer’s request for this APA dated _________, including any amendments or supplemental or
additional information thereto.
APA YearThis term is defined in paragraph 5(a) of this APA.
Covered Transaction(s)This term is defined in Appendix A.
Financial StatementsFinancial statements prepared in accordance with U.S. GAAP and stated in U.S. dollars.
Foreign GroupWorldwide Group members that are not U.S. persons.
Foreign Participants[name the foreign entities involved in Covered Transactions].
I.R.C.The Internal Revenue Code of 1986, 26 U.S.C., as amended.
Pub. L. 106­170The Ticket to Work and Work Incentives Improvement Act of 1999.
Revenue Procedure 2006­9Rev. Proc. 2006­9, 2006­1 C.B. 278.
Transfer Pricing Method
(TPM)
A transfer pricing method within the meaning of Treasury Regulation section 1.482­1(b) and Reve­
nue Procedure 2006­9, section 2.04.
U.S. GAAPU.S. generally­accepted accounting principles.
U.S. GroupWorldwide Group members that are U.S. persons.
U.S. ReturnFor each taxable year, the “returns with respect to income taxes under subtitle A” that Taxpayer
must “make” in accordance with I.R.C. section 6012. {Or substitute for partnership: For each tax­
able year, the “return” that Taxpayer must “make” in accordance with I.R.C. section 6031.}
Worldwide GroupTaxpayer and all organizations, trades, businesses, entities, or branches (whether or not incorpo­
rated, organized in the United States, or affiliated) owned or controlled directly or indirectly by the
same interests.

April 12, 2021 1032 Bulletin No. 2021–15
APPENDIX E
APA ANNUAL REPORT SUMMARY FORM
The APA Annual Report Summary on the next page is a required APA Record. The APA Team Leader supplies some of the infor­
mation requested on the form. Taxpayer is to supply the remaining information requested by the form and submit the form as part of
its Annual Report.

Bulletin No. 2021–15 1033 April 12, 2021
APA Annual Report
SUMMARY
Department of the Treasury—Internal Revenue Service
Large Business and International Division
Treaty and Transfer Pricing Operations
Advance Pricing and Mutual Agreement Program
APA No. _______________
Team Leader _______________________
Economist _______________________________
Intl Examiner _____________________________
APA Information
Taxpayer Name: ___________________________________________________
Taxpayer EIN:_________________ NAICS:___________________
APA Term: Taxable years ending ________ to ____________
Original APA [ ] Renewal APA [ ]
Annual Report due dates:
_________________, 201__ for all APA Years through APA Year ending in 200__; for each APA Year
thereafter, on _________________ [month and day] immediately following the close of the APA Year
Principal foreign country(ies) involved in covered transaction(s): _______________________________________
Type of APA: [ ] unilateral [ ] bilateral with ________________
Tested party is [ ] US [ ] foreign [ ] both
Approximate dollar volume of covered transactions (on an annual basis) involving tangible goods and services:
[ ] N/A [ ] <$50 million [ ] $50­100 million [ ] $100­250 million [ ] $250­500 million [ ] >$500 million
APA tests on (check all that apply):
[ ] annual basis [ ] multi­year basis [ ] term basis
APA provides (check all that apply) a:
[ ] range [ ] point [ ] floor only [ ] ceiling only [ ] other_____________
APA provides for adjustment (check all that apply) to:
[ ] nearest edge [ ] median [ ] other point
APA Annual Report
Information
(to be completed
by the Taxpayer)

APA date executed: ______________, 201__
This APA Annual Report Summary is for APA Year(s) ending in 200__ and was filed on _____________, 201__
Check here [ ] if Annual Report was filed after original due date but in accordance with extension.
Has this APA been amended or changed? [ ] yes [ ] no Effective Date: ______________________
Has Taxpayer complied with all APA terms and conditions? [ ] yes [ ] no
Were all the critical assumptions met? [ ] yes [ ] no
Has a Primary Compensating Adjustment been made in any APA Year covered by this Annual Report?
[ ] yes [ ] no If yes, which year(s): 200___
Have any necessary Secondary Compensating Adjustments been made? [ ] yes [ ] no
Did Taxpayer elect APA Revenue Procedure treatment? [ ] yes [ ] no
Any change to the entity classification of a party to the APA? [ ] yes [ ] no
Taxpayer notice information contained in the APA remains unchanged? [ ] yes [ ] no
Taxpayer’s current US principal place of business: (City, State) _____________________________________
APA Annual Report
Checklist of
Key Contents
(to be completed
by the Taxpayer)
Financial analysis reflecting TPM calculations
Financial statements showing compliance with TPM(s)
Schedule M­1 or M­3 book­tax differences
Current organizational chart of relevant portion of world­wide group
Attach copy of APA
Other APA records and documents included:
[ ] yes [ ] no
[ ] yes [ ] no
[ ] yes [ ] no
[ ] yes [ ] no
[ ] yes [ ] no
Contact Information
Authorized RepresentativePhone NumberAffiliation and Address

April 12, 2021 1034 Bulletin No. 2021–15
APPENDIX 2– Model APA (bAsed on Rev. PRoc. 2015-41)
TEMPLATE FOR
ADVANCE PRICING AGREEMENT
UNDER REVENUE PROCEDURE 2015-41
_______________
The Advance Pricing and Mutual Agreement Program (“APMA”) of the Internal Revenue Service (“IRS”) is providing this
template for use in drafting advance pricing agreements (“APAs”) issued under IRS Revenue Procedure 2015­41, 2015­35 I.R.B.
263 (“Rev. Proc. 2015­41”). This template is designed to systematize how taxpayers propose terms for their APAs and standardize
language used in executed APAs. It will improve efficiency in the APA process and enhance consistency in the administration of the
APA program.
Rev. Proc. 2015­41 requires that taxpayers include as part of a complete APA request a draft APA and a “redline” comparison of the
proposed draft APA against the current model APA. See section 2.03, exhibit 15, of the Appendix to Rev. Proc. 2015­41. This template
serves as the model APA. A taxpayer is required to produce the “redline” comparison by following the instructions below to edit this
template with tracked changes. The draft APA and “redline” comparison are then to be included in Word format in the complete APA
request. (Before editing the template with tracked changes, a taxpayer should remove this introduction and the instructions below
from the Microsoft Word file.)
The assigned APMA team will review the APA’s terms proposed in the draft APA. If the APMA team accepts the proposed terms
in light of its review of the taxpayer’s complete APA request and other information obtained during the APA process, then the text of
the draft APA, edited as needed to fill in any information not available at the time of the APA Request, will be adopted as the text of
a finally executed APA. If the APMA team does not accept the proposed terms, it will discuss modifications to the draft APA with the
taxpayer during the APA process. For bilateral and multilateral APAs, the terms of the executed APA will of necessity be consistent
with the terms of the underlying mutual agreement between the United States and one or more treaty partners.
GENERAL INSTRUCTIONS
The template is designed to minimize editing by using an options­based format for selecting from terms presented in certain sec­
tions of the model APA. The options presented are those which APMA considers standard and which it has accepted in final APAs.
These options are not binding on APMA, however. APMA reserves the right to modify the option selections, the specific option lan­
guage used, or any other terms before executing an APA with the taxpayer.
Options are indicated by square brackets (“[]”). An “x” should be inserted between the brackets to indicate the selected option
(“[x]”). Options that are not selected should not be deleted, but instead should be left in the text of the draft APA. The options to which
APMA and the taxpayer ultimately agree for the final APA will be indicated by the presence or absence of an “x”. The term associated
with the “x” will be given operative effect in the executed APA.
Certain options are flagged with an asterisk after the square brackets (“[]*”). To facilitate the APMA team’s subsequent review of
the draft APA, the asterisks should not be deleted. Taxpayers that select flagged options are required to specifically provide justifica­
tion for the selection in the APA request. See section 1.02, Part 5, of the Appendix to Rev. Proc. 2015­41.
The template contains placeholder phrases consisting of a hashtag followed by one or more words in block capital letters (e.g.,
“#COUNTRY”). Generally, the taxpayer should replace a placeholder phrase with appropriate text, subject to the following conven­
tions:
• If a placeholder phrase occurs within an option that the taxpayer has rejected, the taxpayer should change the hashtag to a
caret (e.g., change “#COUNTRY” to “^COUNTRY”) but otherwise leave the phrase intact.
14
The caret indicates that the
Taxpayer has rejected this option. For example, for a bilateral APA with Japan, the lines on the first page just below the title
would read:
14
As a result, almost all occurrences of the hashtag in the template will be replaced with a caret or other text in the taxpayer’s draft APA. The few remaining occurrences of the hashtag will
mark a placeholder phrase that cannot yet be replaced with appropriate text (see, for example, the placeholder phrase in paragraph 6(e) for a date that cannot be determined until the APA nears
execution). Searching the draft APA for the hashtag will locate all placeholder phrases that still need replacement.

Bulletin No. 2021–15 1035 April 12, 2021
[x] Bilateral with Japan
[] Multilateral with ^COUNTRIES
[] Unilateral
• The placeholder phrase “#CURRENCY” should be replaced, for example, with “U.S. dollars,” “Euros,” or “Japanese yen.”
• The placeholder phrase “#DATE” should be replaced with a date in the format of “December 31, 2020.”
The APA Term will be expressed as dates certain, e.g., “January 1, 2017 to December 31, 2022, inclusive”, rather than as particular
tax years.
Taxpayers may need to draft custom text for situations or options not included in the template. For example, a taxpayer may pro­
pose additional critical assumptions to address specific regulatory contingencies or conditions the taxpayer is expected to face during
the term of the APA. As another example, the provision titled “Limitation on Assistance” at the end of the Recitals might be modified
based on an understanding reached in the prefiling stage of the APA process. In some cases, a particular critical assumption might fa­
cilitate reaching an agreement on an APA. Taxpayers that include custom text are required to specifically provide justification for the
inclusion in the APA request, just as selecting an option with an asterisk requires justification. Any custom text must also be evident
in the “redline” comparison of the proposed draft APA.
INSTRUCTIONS ON TABLES
The template contains certain tables that the taxpayer should edit. Entries in the tables will not contain hashtags, but taxpayers
nevertheless should fill in the information and add additional rows to the tables if needed. Taxpayers also should fill in the “APA
Information” in the table in Appendix D, to the extent available or proposed.
INSTRUCTIONS ON APPENDIX A
Appendix A of this template contains the description of the APA’s covered issue(s) and covered method(s). Taxpayers should note
the following points in completing Appendix A:
• The template includes just one covered issue with one corresponding covered method. If there is more than one covered Is­
sue proposed for the APA, the taxpayer should add additional covered issues in Appendix A, section 3, with tracked changes.
• If there is more than one covered method, the taxpayer should first replicate the template’s entire text for Covered Method
1 in Appendix A, section 4, without tracked changes, to provide template text for each additional covered method, and then
edit the text for each covered method with tracked changes.
• Normally, each covered issue will have its own corresponding covered method. However, in some cases, a covered method
may apply at once to more than one covered issue. For example, covered issues may be proposed to be aggregated and tested
by a single covered method. In such cases, the heading for that covered method could read, for example, “Covered Method
for Covered Issues 1­3”.
• Any interaction between different covered methods should be adequately explained in the text, and in an appropriate man­
ner. For example, an explanation might be provided in an introduction at the start of section 4 of Appendix A, preceding the
description of the respective covered methods.
Appendix A uses the term “Tested Party.” When applied in the context of methods that consider, or test, data from only one party
to a transaction, this term is similar in concept to the term “tested party” as discussed in the OECD Guidelines at paragraphs 3.18
and 3.19, and as defined in the U.S. Treasury Regulations section 1.482­5(b)(2). However, some methods consider, or test, data from
both parties to a transaction, where there is no singular “tested” party. Even in applying such methods, however, it is typically the
case that one particular party’s results are formally tested for compliance with the method. For purposes of this template, in such
circumstances, the party whose results are formally tested in applying any particular method is the “Tested Party”, even if that party
is not strictly a “tested party” as discussed in the OECD Guidelines paragraphs 3.18 and 3.19, or as defined in the U.S. Treasury
Regulations section 1.482­5(b)(2).

April 12, 2021 1036 Bulletin No. 2021–15
ADVANCE PRICING AGREEMENT
between
#SIGNATORY
and
THE INTERNAL REVENUE SERVICE
[] Bilateral with #COUNTRY
[] Multilateral with #COUNTRIES
[] Unilateral

Term: #DATE to #DATE, inclusive

[] This APA is commonly referred to as #APA NAME.
PARTIES
The Parties to this APA are the Internal Revenue Service (“IRS”) and #NAME OF EACH NON­IRS SIGNATORY, WITH EIN.
[] #SIGNATORY will be referred to as “U.S. Taxpayer.”
[] #SIGNATORY is the common parent of an affiliated group filing consolidated U.S. tax returns and is entering into this APA
on behalf of both itself and the following members of its consolidated group: #MEMBERS OF GROUP. All members of this
consolidated group will be referred to collectively as “U.S. Taxpayer.”
RECITALS
[] This APA is a renewal of one or more prior APAs, which are listed below in reverse chronological order:
Party(ies)Execution DateTerm
Key:
• Party(ies): The signatory(ies) to the prior APA, other than the IRS, with each signatory’s taxpayer identification
number;
• Execution Date: The date, or the later of the dates, on which the prior APA was executed;
• Term: The term of the prior APA.
[] This is a bilateral APA within the meaning of Rev. Proc. 2015­41 and implements the terms of a mutual agreement reached
between the United States and #COUNTRY.
[] This is a multilateral APA within the meaning of Rev. Proc. 2015­41 and implements the terms of a mutual agreement
reached among the United States, #COUNTRIES.
[] This APA is a unilateral APA within the meaning of Rev. Proc. 2015­41 and is not based on any mutual agreement.
The Parties to this APA are defined in the ”Parties” section above. Regarding the Party(ies) to this APA other than the IRS:
[] No such Party has an immediate parent or owner that is not a U.S. entity.
[] One or more such Parties has an immediate parent or owner that is not a U.S. entity, as follows:

Bulletin No. 2021–15 1037 April 12, 2021
PartyParent’s or Owner’s Identifying
Information
Parent’s or Owner’s Contact Information
Key:
• Party: Name of the Party having an immediate parent or owner that is not a U.S. entity;
• Parent’s or Owner’s Identifying Information: Name of the immediate parent or owner of such Party, and the tax­
payer identification number of that parent or owner for income tax purposes in its country of residence;
• Parent’s or Owner’s Contact Information: The immediate parent’s or owner’s address and phone number.
The term “Worldwide Group” is defined below in paragraph 12 of this APA. The ultimate parent entity or owner of Worldwide
Group is:
#ENTITY NAME, ADDRESS, AND PHONE
U.S. Taxpayer’s principal place of business is #CITY, #STATE. #BRIEF DESCRIPTION OF U.S. TAXPAYER AND NON­U.S.
TAXPAYER (DEFINED IN SECTION 1 OF APPENDIX A), AND SPECIFICALLY OF EACH COVERED ENTITY (DEFINED
IN SECTION 1 OF APPENDIX A).
This APA contains the Parties’ agreement on the Covered Method(s) for resolving the Covered Issue(s) under Code section 482 and
any other Code sections that are identified in Appendix A to this APA, the U.S. Treasury Regulations thereunder, and (if applicable):
[] The income tax convention(s) between the United States and #COUNTRY(IES).
This APA shall not limit the authority of the IRS to (1) verify compliance with this APA as to the Covered Issue(s), or (2) audit
issues other than Covered Issue(s), including issues that arise under Code section 482 and any other Code sections identified in Ap­
pendix A to this APA, and the U.S. Treasury Regulations thereunder.
LIMITATION ON ASSISTANCE
The Covered Issue(s) may relate to one or more countries which (i) have an income tax convention with the United States, but
(ii) are not a party to a mutual agreement whose terms are implemented by this APA. U.S. Taxpayer acknowledges that the IRS may
decline to provide competent authority assistance concerning taxation by such country(ies) that relates to the Covered Issue(s). See
section 2.02(4)(d) of Rev. Proc. 2015­41.

April 12, 2021 1038 Bulletin No. 2021–15
AGREEMENT
The Parties agree as follows:
1. Covered Entities. This APA’s Covered Entities are defined in Appendix A.
2. Covered Issue(s). This APA applies to the Covered Issue(s), as defined in Appendix A.
3. Covered Method(s). Appendix A sets forth the Covered Method(s) for the Covered Issue(s).
4. Term. This APA applies to the APA Term, as defined in Appendix A.
5. Operation.
a. Rev. Proc. 2015­41 governs the interpretation, legal effect, and administration of this APA.
b. The APMA program provides a voluntary process whereby the IRS and taxpayers may resolve transfer pricing issues and is­
sues for which transfer pricing principles may be relevant in a principled and cooperative manner on a prospective basis. As
such, the APA process (as defined in Rev. Proc. 2015­41) is an alternative to dispute resolution that benefits both taxpayers
and the IRS and that is intended to promote and encourage open communication. Accordingly, the IRS and U.S. Taxpayer
agree that neither party will attempt to use nonfactual oral or written representations, within the meaning of sections 6.04 and
6.05 of IRS Revenue Procedure 2015­41 (including any proposals to use particular Covered Method(s)), made in conjunc­
tion with the APA Request in any judicial or administrative proceeding. The IRS and U.S. Taxpayer also agree that factual
representations made in conjunction with the APA Request may be used in judicial and administrative proceedings.
6. Compliance.
a. U.S. Taxpayer must report its taxable income in an amount that is consistent with Appendix A and all other requirements of
this APA. U.S. Taxpayer must so report its taxable income in the following manner:
i. For any APA Tax Year for which U.S. Taxpayer timely files its original U.S. return prior to, or no later than 60 days after,
the U.S. Effective Date, U.S. Taxpayer must so report its taxable income for that APA Tax Year in one of the following
ways:
A. on such original U.S. return;
B. on an amended U.S. return submitted no later than 120 days after the U.S. Effective Date;
C. through a means proposed by U.S. Taxpayer and accepted by the applicable IRS practice area no later than 120 days
after the U.S. Effective Date (or by such other deadline as is agreed between U.S. Taxpayer and the applicable IRS
practice area); or
D. if applicable:
[]* no later than 120 days after the U.S. Effective Date through the following means: #DESCRIPTION OF
MEANS.
ii. For all other APA Tax Years, U.S. Taxpayer must so report its taxable income on its timely filed original U.S. return.
iii. The provisions of paragraphs 6(a)(i) and 6(a)(ii) are modified by this paragraph 6(a)(iii). If a Covered Method includes
a term test (including the case of an annual test with a supplemental term test) or a subterm test, as described in section
4 of Appendix A, then the APA Covered Year as of which the term test or subterm test applies would change in the event
of an Early Termination. Specifically, while in the absence of an Early Termination a term test would apply as of the last
APA Covered Year, in the event of an Early Termination the term test would apply as of an earlier APA Covered Year.
Similarly, while in the absence of an Early Termination a subterm test would apply as of the last APA Covered Year in
the subterm, in the event of an Early Termination the subterm test might apply as of an earlier APA Covered Year. In
these situations, the Early Termination might not be established in time for U.S. Taxpayer to know to apply the term test

Bulletin No. 2021–15 1039 April 12, 2021
or subterm test as of the earlier APA Covered Year in reporting taxable income as required under paragraphs 6(a)(i) and
6(a)(ii) for the APA Tax Year corresponding to that earlier APA Covered Year. In such cases, U.S. Taxpayer may need to
correct its reporting for that APA Tax Year. Specifically, U.S. Taxpayer will need to correct its income reporting for that
APA Tax Year if the application of the term test or subterm test in that earlier APA Covered Year changes the existence
or amount of an APA Primary Adjustment for the Covered Method for that APA Tax Year. In such cases:
A) The resulting incorrectness in the prior reporting for that APA Tax Year is excused; and
B) U.S. Taxpayer must correct such prior reporting through a means listed in paragraph 6(a)(i) within 120 days of the Early
Termination being established.
b. For each Covered Issue, if any, that involves determination of pricing and/or income allocation
15
under Code section 482 (or
Code section 367(d)) as modified by any applicable income tax convention, this APA addresses the pricing and/or income
allocation between U.S. Taxpayer and Non­U.S. Taxpayer in the aggregate. Except as explicitly provided, this APA does not
address and does not bind the IRS with respect to pricing or income allocation (1) among particular legal entities that are
members of U.S. Taxpayer, or (2) among particular legal entities that are members of Non­U.S. Taxpayer. In addition, this
APA does not address pricing or income allocation between an entity that is not a Covered Entity, and any entity.
c. For each APA Tax Year, if U.S. Taxpayer complies with the terms and conditions of this APA, then, provided that this APA
remains effective for that APA Tax Year for a particular Covered Issue, the IRS will not make or propose any allocation or
adjustment that is inconsistent with the application under this APA of the applicable Covered Method to that Covered Issue.
d. If U.S. Taxpayer does not comply with the terms and conditions of this APA, then the IRS may:
i. enforce the terms and conditions of this APA and make or propose allocations or adjustments based on the application
of the Covered Method(s) to the Covered Issue(s) as provided in this APA;
ii. cancel or revoke this APA under section 7.06 of Rev. Proc. 2015­41; or
iii. revise this APA, if the Parties agree.
e. U.S. Taxpayer must timely file an Annual Report for each APA Tax Year in accordance with this paragraph 6(e), Appendix
C to this APA, and section 7.02 of Rev. Proc. 2015­41. Annual Reports for multiple APA Tax Years may be combined, pro­
vided that all required information for each APA Tax Year is clearly presented. For each Annual Report, U.S. Taxpayer must
submit an original printed version containing a signed original “penalties of perjury” declaration, one printed copy of the
contents of the original printed version, and an electronic copy of the contents of the original printed version. Any exhibits
in the printed version must be tabbed, and the electronic copy is subject to the same requirements, as to medium and format,
that are specified for APA requests in section 2 of the Appendix to Rev. Proc. 2015­41. Upon request, U.S. Taxpayer must
provide additional copies of the printed version, at addresses specified by the IRS. U.S. Taxpayer must file the Annual Report
for each APA Tax Year by the later of (i) #DATE CERTAIN, NORMALLY APPROXIMATELY 90 DAYS AFTER THE U.S.
EFFECTIVE DATE, and (ii) the fifteenth day of the twelfth month following the close of the APA Tax Year. The IRS may
by notice request additional information reasonably necessary to clarify or complete the Annual Report. (See paragraph 16,
and section 3(c) of Appendix C, regarding notices.) U.S. Taxpayer will provide such requested information within 30 days
from the date of the notice unless a later date is specified in the notice. Additional time may be allowed for good cause in the
discretion of the Director of the Advance Pricing and Mutual Agreement Program.
f. The IRS will determine whether U.S. Taxpayer has complied with this APA based on U.S. Taxpayer’s U.S. returns, the
Financial Statements and additional statements required under this paragraph 6(f), and other APA Records, for all APA Tax
Years and any other tax year necessary to verify compliance. The Financial Statements and additional statements required
for a particular tax year are:
[] For every U.S. Covered Entity, the Financial Statements together with the additional statements specified in paragraph
6(f)(i); and for every Non­U.S. Covered Entity, the Financial Statements together with the additional statements speci­
fied in paragraph 6(f)(ii).
15
As used in this APA, “income allocation” includes allocation of loss.

April 12, 2021 1040 Bulletin No. 2021–15
[]* For every U.S. Covered Entity, the Financial Statements together with the additional statements specified in paragraph
6(f)(i).
[]* For every Non­U.S. Covered Entity, the Financial Statements together with the additional statements specified in para­
graph 6(f)(ii).
i. For each U.S. Covered Entity, the additional statements consist of the following statement(s):
[] An audit opinion for that U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[]* One or more of the following, as indicated:
[] An accountant’s report for that U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[] A self­certification for that U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[] A self­certification for that U.S. Covered Entity’s Financial Statements, together with a tying certification for
that entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[] #OTHER MEANS OF VERIFYING THE RELIABILITY OF THE U.S. COVERED ENTITY’S FINAN­
CIAL STATEMENTS.
ii. For each Non­U.S. Covered Entity, the additional statements consist of the following statement(s):
[] An audit opinion for that Non­U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[]* One or more of the following, as indicated:
[] An accountant’s report for that Non­U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)
(iii).
[] A self­certification for that Non­U.S. Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[] A self­certification for that Non­U.S. Covered Entity’s Financial Statements, together with a tying certification
for that Covered Entity’s Financial Statements, as defined in paragraph 6(f)(iii).
[] #OTHER MEANS OF VERIFYING THE RELIABILITY OF THE NON­U.S. COVERED ENTITY’S FI­
NANCIAL STATEMENTS.
iii. With reference to the Financial Statements for a particular Covered Entity for a particular tax year, certain terms used
in paragraphs 6(f)(i) and 6(f)(ii) are defined as follows:
A. An audit opinion is an opinion of an independent certified public or chartered accountant who audited the Financial
Statements.
B. An accountant’s report is a report of an independent certified public or chartered accountant who is associated with
the Financial Statements.
C. A self­certification is an attestation, as defined in paragraph 6(f)(iii)(E), that the Financial Statements have been
prepared according to the Applicable Accounting Standard.
D. A tying certification consists of the following:
(1) An attestation, as defined in paragraph 6(f)(iii)(E), that the Financial Statements can be reconciled to the con­
solidated Financial Statements for that entity’s direct or indirect parent according to workpapers provided with
the attestation;

Bulletin No. 2021–15 1041 April 12, 2021
(2) The workpapers referred to in paragraph 6(f)(iii)(D)(1), which must demonstrate the consolidation of the Cov­
ered Entity’s Financial Statements into the Financial Statements of the parent referred to in paragraph 6(f)(iii)
(D)(1);
(3) The Financial Statements of the parent referred to in paragraph 6(f)(iii)(D)(1); and
(4) An audit opinion (as defined in paragraph 6(f)(iii)(A)) for the Financial Statements of the parent referred to in
paragraph 6(f)(iii)(D)(1).
E. An attestation is an affirmation by an officer of the Covered Entity in the following form:
I, [Officer’s Name and Title], of [Name of Covered Entity] affirm under penalties of perjury that the facts stated
below are true. I either have adequate first­hand knowledge to make this affirmation or have gained adequate
knowledge to make this affirmation through diligent consultation(s) with one or more individuals who have
first­hand knowledge.
[Facts attested to.]
[Signature]
g. In accordance with section 7.04 of Rev. Proc. 2015­41, U.S. Taxpayer will (1) maintain the APA Records, and (2) make
them available to the IRS in connection with an examination under section 7.03 of Rev. Proc. 2015­41. Compliance with
this subparagraph constitutes compliance with the record­maintenance provisions of Code sections 6038A and 6038C for
the Covered Issue(s) for any APA Covered Year.
h. The “true taxable income” within the meaning of U.S. Treasury Regulations sections 1.482­1(a)(1) and (i)(9) of a member
of an affiliated group filing a U.S. consolidated return will be determined under the U.S. Treasury Regulations under Code
section 1502.
i. To the extent that U.S. Taxpayer’s compliance with this APA depends on certain acts of other members of Worldwide Group,
U.S. Taxpayer will ensure that such other members will perform such acts.
7. Critical Assumptions. The Critical Assumptions, which are this APA’s critical assumptions as defined in Rev. Proc. 2015­41,
appear in Appendix B. If any Critical Assumption has not been met, then Rev. Proc. 2015­41, section 7.06, governs, as modified
by Appendix B to this APA.
8. Disclosure. This APA, and any background information related to this APA or the APA Request, are: (1) considered “return in­
formation” under Code section 6103(b)(2)(C); and (2) not subject to public inspection as a “written determination” under Code
section 6110(b)(1). Section 521(b) of Pub. L. 106­170 provides that the Secretary of the Treasury must prepare a report for public
disclosure that includes certain specifically designated information concerning all APAs, including this APA, in a form that does
not reveal taxpayers’ identities, trade secrets, and proprietary or confidential business or financial information.
9. Disputes. If a dispute arises concerning the interpretation or application of this APA, the Parties will seek a resolution by the
Director, Treaty and Transfer Pricing Operations, to the extent reasonably practicable, before seeking alternative remedies.
10. Materiality. In this APA the terms “material” and “materially” will be interpreted in a manner consistent with the description of
“material facts” in Rev. Proc. 2015­41, section 7.06(4).
11. Paragraph Captions. This APA’s paragraph captions, which appear in italic type, are for convenience and reference only. The
captions do not affect in any way the interpretation or application of this APA.
12. Terms and Definitions.
a. Unless otherwise specified, terms in the plural include the singular and vice versa.
b. Appendix A contains definitions for certain terms used in this APA’s body and appendices.

April 12, 2021 1042 Bulletin No. 2021–15
c. Certain terms used in this APA’s body and appendices are defined as follows:
TermDefinition
Annual ReportA report within the meaning of Rev. Proc. 2015­41, section 7.02.
Advance Pricing
Agreement, or “APA”
An “advance pricing agreement” within the meaning of Rev. Proc. 2015­41, section 2.02. Unless context
indicates otherwise, “this APA” or “the APA” denotes the particular APA that is executed below.
APA Records(Defined in Appendix C.)
APA RequestU.S. Taxpayer’s request for this APA, which was dated #DATE, including any amendments or supple­
mental or additional information thereto (including but not limited to any responses to due diligence
questions).
Critical Assumptions(Defined in paragraph 7.)
Financial StatementsBalance sheet, income statement, statement of cash flow, and explanatory notes, prepared in accordance
with the Applicable Accounting Standard as defined in section 7 of Appendix A.
Non­U.S. GroupIn any APA Tax Year, Worldwide Group members that are not U.S. persons.
Parties(Defined in the Recitals near the start of this APA.)
Pub. L. 106­170The Ticket to Work and Work Incentives Improvement Act of 1999.
U.S. Effective Date(Defined in paragraph 17 and in section 7 of Appendix A. Those definitions are intended to have the same
meaning. In case of conflict, the definition in paragraph 17 controls.)
U.S. GroupIn any APA Tax Year, Worldwide Group members that are U.S. persons.
Worldwide GroupIn any APA Tax Year, U.S. Taxpayer and all organizations, trades, businesses, entities, or branches (wheth­
er or not incorporated, organized in the United States, or affiliated) owned or controlled directly or indi­
rectly by the same interests.
13. Deadline References. If a deadline under this APA falls on a Saturday, Sunday, or a legal holiday in the District of Columbia, the
deadline is extended to the next succeeding day that is not a Saturday, Sunday, or legal holiday in the District of Columbia.
14. Entire Agreement and Severability. This APA is the complete statement of the Parties’ agreement. The Parties will sever, delete,
or reform any invalid or unenforceable provision in this APA to approximate the Parties’ intent as nearly as possible.
15. Successor in Interest. This APA binds, and inures to the benefit of, any successor in interest to U.S. Taxpayer.
16. Notice. Any notices required by this APA or Rev. Proc. 2015­41 must be in writing. U.S. Taxpayer will send notices to the IRS
at:
Commissioner, Large Business and International Division
Internal Revenue Service
1111 Constitution Avenue, NW
SE:LB:TTPO:APMA:NCA534­01
Washington, DC 20224
(Attention: APMA)
The IRS will send notices to:
#NAME AND ADDRESS
(phone: #PHONE)
The IRS also will send notices to, if applicable:
[] #REPRESENTATIVE’S NAME AND ADDRESS
(phone: #PHONE)
provided that a valid IRS Form 2848 “Power of Attorney and Declaration of Representative” for that person was included in the
most recent Annual Report (or, if no Annual Report has been filed, was included in the APA Request).

Bulletin No. 2021–15 1043 April 12, 2021
17. U.S. Effective Date and Counterparts. This APA is effective starting on the date, or later date of the dates, upon which all Parties
execute this APA (“U.S. Effective Date”). The Parties may execute this APA in counterparts, with each counterpart constituting
an original.
WITNESS,
The Parties have executed this APA on the dates below.
#SIGNATORY NAME IN BOLD FACE BLOCK CAPITAL LETTERS
By: __________________________Date: _________________, 20____
#NAME
#TITLE
INTERNAL REVENUE SERVICE
By: __________________________Date: _________________, 20____
John C. C. Hughes
Director, Advance Pricing and Mutual Agreement Program

April 12, 2021 1044 Bulletin No. 2021–15
APPENDIX A
COVERED ENTITIES, TERM, COVERED ISSUE(S), COVERED METHOD(S),
INCOME REPORTING,
CONFORMING ADJUSTMENTS AND REPATRITION OF FUNDS,
CERTAIN SUBSEQUENT ADJUSTMENTS,
AND DEFINITIONS
Section 1 of this Appendix lists the Covered Entities. Section 2 defines the APA Term, APA Tax Years, and APA Covered Years.
Section 3 describes the Covered Issue(s). Section 4 describes the Covered Method applicable to each Covered Issue.
Section 5 describes the application of the Covered Method(s) to income reporting and the possible need for an APA Primary Ad­
justment under one or more Covered Methods. Section 6 addresses conforming adjustments and repatriation of funds following APA
Primary Adjustments.
Section 7 provides definitions that apply both to this Appendix and to the APA as a whole. The definitions table is based on a stan­
dard, inclusive model, and thus may include terms not used in this APA.
1. Covered Entities
The U.S. Covered Entity(ies) are:
#LIST OF EACH U.S. ENTITY INVOLVED IN ONE OR MORE COVERED ISSUE(S), AND ALSO (LISTED FIRST)
ANY CONSOLIDATED RETURN PARENT FOR ANY SUCH ENTITY. FOR EACH ENTITY, NAME, ADDRESS,
PHONE, AND EIN.
The term “U.S. Taxpayer” includes collectively all U.S. Covered Entities and any other entities that are in a consolidated return group
with a U.S. Covered Entity.
The Non­U.S. Covered Entity(ies) are:
# LIST OF EACH NON­U.S. ENTITY INVOLVED IN ONE OR MORE COVERED ISSUE(S), AND ALSO (LISTED
FIRST) ANY COMMON TAX REPORTING PARENT FOR ANY SUCH ENTITY. FOR EACH ENTITY, NAME, AD­
DRESS, AND PHONE.
The term “Non­U.S. Taxpayer” includes collectively all Non­U.S. Covered Entities and any other entities that are in a common tax
reporting group with a Non­U.S. Covered Entity.
The term “Covered Entities” includes both the U.S. Covered Entities and the Non­U.S. Covered Entities.
2. APA Term, APA Tax Years, and APA Covered Years
The APA applies to the period from #DATE to #DATE, inclusive (the “APA Term”).
[] The APA Term does not include a Rollback.
[] The APA Term includes a Rollback, which covers from #DATE to #DATE, inclusive (the “Rollback Period”).
A tax year of U.S. Taxpayer that is wholly or partly contained in the APA Term is called an “APA Tax Year.” For a particular APA
Tax Year, the portion of such APA Tax Year that is contained in the APA Term is called an “APA Covered Year.” Such APA Tax Year
and APA Covered Year are said to “correspond” to each other or to be “corresponding.”
3. Covered Issue(s)
The Covered Issue(s) are as described below.

Bulletin No. 2021–15 1045 April 12, 2021
Covered Issue 1:
#DESCRIPTION OF COVERED ISSUE.
4. Covered Method(s)
Each Covered Method applies to one or more Covered Issues. A Covered Method and the Covered Issue(s) to which the Covered
Method applies are said to “correspond,” or to be “corresponding”.
The Covered Methods are summarized in the following table and are described in detail below. In case of conflict with this table,
the detailed descriptions of the Covered Methods below, and the descriptions in section 3 above of the Covered Issues, control.
Covered Method
Number
Applies to Covered
Issues Number(s)
Summary
Description of
Corresponding
Covered Issues
Type of Method;
Results Tested
Point or RangeTesting Frequency
and Periods
1
This Appendix A uses the term “Tested Party.” When applied in the context of methods that consider, or test, data from only
one party to a transaction, this term is similar in concept to the term “tested party” as discussed in the OECD Guidelines paragraphs
3.18 and 3.19, and as defined in the U.S. Treasury Regulations section 1.482­5(b)(2). However, some methods consider, or test, data
from both parties to a transaction, where there is no singular “tested” party. Even in applying such methods, however, it is typically
the case that one particular party’s results are formally tested for compliance with the method. For purposes of this template, in such
circumstances, the party whose results are formally tested in applying any particular method is the “Tested Party”, even if that party
is not strictly a “tested party” as discussed in the OECD Guidelines paragraphs 3.18 and 3.19, or as defined in the U.S. Treasury
Regulations section 1.482­5(b)(2).
Covered Method for Covered Issue 1:
a. Tested Party
The Tested Party is #TESTED PARTY.
b. Financial Results Tested (Type of Method)
[] The Covered Method is an implementation of the comparable uncontrolled price method under the OECD Guidelines and
of the comparable uncontrolled price method under the U.S. Treasury Regulations. The Tested Party’s financial results to be
tested are:
[] per unit price paid, defined as the total amount paid for #DESCRIPTION OF GOODS divided by the number of #DE­
SCRIPTION OF A UNIT OF GOODS purchased.
[] per unit price received, defined as the total amount received for #DESCRIPTION OF GOODS divided by the number
of #DESCRIPTION OF A UNIT OF GOODS sold.
[] The Covered Method is an implementation of the comparable uncontrolled price method under the OECD Guidelines and of
the comparable uncontrolled services price method under the U.S. Treasury Regulations. The Tested Party’s financial results
to be tested are:
[] per unit price paid, defined as the total amount paid for #DESCRIPTION OF SERVICES divided by the number of
#DESCRIPTION OF A UNIT OF SERVICES received.
[] per unit price received, defined as the total amount received for #DESCRIPTION OF SERVICES divided by the number
of #DESCRIPTION OF A UNIT OF SERVICES provided.
[] The Covered Method is an implementation of the comparable uncontrolled price method under the OECD Guidelines and
of the comparable uncontrolled transaction method under the U.S. Treasury Regulations. The Tested Party’s financial results

April 12, 2021 1046 Bulletin No. 2021–15
to be tested are the royalty paid for the license of #DESCRIPTION OF LICENSED INTANGIBLE PROPERTY divided by
the Tested Party’s:
[] sales revenue from sales of #DESCRIPTION OF GOODS/SERVICES.
[] #OTHER ROYALTY BASE.
[] The Covered Method is an implementation of the comparable uncontrolled price method under the OECD Guidelines and
of the acquisition price method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are
described in subsection (c) below.
[] The Covered Method is an implementation of the comparable uncontrolled price method under the OECD Guidelines and
of the market capitalization method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are
described in subsection (c) below.
[] The Covered Method is an implementation of the resale price method under the OECD Guidelines and of the resale price
method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are the gross profit margin from
the sale of #DESCRIPTION OF GOODS.
[] The Covered Method is an implementation of the resale price method under the OECD Guidelines and of the gross services
margin method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are the gross services
margin from the provision of #DESCRIPTION OF SERVICES.
[] The Covered Method is an implementation of the cost plus method under the OECD Guidelines and of the cost plus method
under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are the gross profit markup.
[] The Covered Method is an implementation of the cost plus method under the OECD Guidelines and of the cost of services
plus method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are the gross services
profit markup from the provision of #DESCRIPTION OF SERVICES.
[] The Covered Method is based on the principles of the low value­adding intra­group services approach under the OECD
Guidelines and of the services cost method under the U.S. Treasury Regulations. The Tested Party’s financial results to be
tested are the markup on total costs for providing #DESCRIPTION OF SERVICES.
[] The Covered Method is an implementation of the transactional net margin method under the OECD Guidelines and of the
comparable profits method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested, as reflected
in its net profit indicator (per OECD Guidelines) or profit level indicator (per U.S. Treasury Regulations), are its:
[] operating margin.
[] markup on total costs.
[] Berry ratio.
[] return on operating assets.
[] return on invested capital.
[]* #OTHER NET PROFIT INDICATOR OR PROFIT LEVEL INDICATOR, WITH DEFINITION.
[] The Covered Method is an implementation of the profit split (residual analysis) method under the OECD Guidelines and
of the residual profit split method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested are
described in subsection (c) below.
[] The Covered Method is an implementation of the profit split (contribution analysis) method under the OECD Guidelines and
of the comparable profit split method under the U.S. Treasury Regulations. The Tested Party’s financial results to be tested
are described in subsection (c) below.

Bulletin No. 2021–15 1047 April 12, 2021
[] The Covered Method is an implementation of an income based valuation technique as referenced in paragraph 6.153 of the
OECD Guidelines and of the income method under the U.S. Treasury Regulations. The Tested Party’s financial results to be
tested are described in subsection (c) below.
[] The Covered Method is an implementation of (i) a sharing of the cost of current contributions in proportion to overall
expected benefits, within a cost contribution arrangement under the OECD Guidelines, and (ii) a sharing of intangible de­
velopment costs in proportion to reasonably anticipated benefits, within a cost sharing arrangement under the U.S. Treasury
Regulations. The Tested Party’s financial results to be tested are described in subsection (c) below.
[] The Covered Method is a method that is not specified under the OECD Guidelines and not specified under the U.S. Treasury
Regulations. The Tested Party’s financial results to be tested are described in subsection (c) below.
Such financial results are determined according to the Applicable Accounting Standard, with the proviso that in determining such
results, accounting principles and conventions that are generally accepted in the trade or industry must be used.
Such financial results are tested against a point or range as described below. The test is carried out with a frequency, and for cer­
tain time periods, as described below. If and when these financial results do not satisfy the test, they must be adjusted as described in
section 5 of this Appendix A.
c. Testing of Financial Results Against a Point or Range
The Tested Party’s financial results are tested as follows:
[] The financial results must equal #X.
[] The financial results must be within an Arm’s Length Range.
[] The Arm’s Length Range is from #X to #Y inclusive.
[] This Arm’s Length Range has an associated Median value of #Z.
[] This Arm’s Length Range has no associated Median value.
[] Two Arm’s Length Ranges apply. The first is from #W to #X inclusive and applies to the annual test described in subsec­
tion (d) below. The second is from #Y to #Z inclusive and applies to the term test described in subsection (d) below.
[] The first Arm’s Length Range has an associated Median value of #P, and the second Arm’s Length Range has
an associated Median value of #Q.
[] These Arm’s Length Ranges have no associated Median value.
[] Two Arm’s Length Ranges apply. The first is from #W to #X inclusive and applies to the subterm test described in
subsection (d) below. The second is from #Y to #Z inclusive and applies to the annual test described in subsection
(d) below.
[] The first Arm’s Length Range has an associated Median value of #P, and the second Arm’s Length Range has
an associated Median value of #Q.
[] These Arm’s Length Ranges have no associated Median value.
[] Two Arm’s Length Ranges apply. The first is from #W to #X inclusive and applies to the test for the first subterm
described in subsection (d) below. The second is from #Y to #Z inclusive and applies to the test for the second
subterm described in subsection (d) below.
[] The first Arm’s Length Range has an associated Median value of #P, and the second Arm’s Length Range has
an associated Median value of #Q.
[] These Arm’s Length Ranges have no associated Median value.

April 12, 2021 1048 Bulletin No. 2021–15
[] #OTHER DESCRIPTION, FOR EXAMPLE THE EVALUATION AND TESTING MECHANICS FOR A PROFIT
SPLIT, AN INCOME METHOD, AN UNSPECIFIED METHOD, OR A SHARING OF COSTS UNDER A COST
CONTRIBUTION ARRANGMENT/COST SHARING ARRANGEMENT.
d. Testing Frequency and Testing Periods
The Tested Party’s financial results are tested as of certain APA Covered Years, and for certain time periods, as follows:
[] The results are tested annually, meaning that they are tested as of each APA Covered Year, for a period consisting of that
APA Covered Year.
[] There is no additional term test.
[] There is an additional term test. For this test, the results are tested as of the Last Effective APA Covered Year, for
the period consisting of the Last Effective APA Covered Year and all prior APA Covered Years.
The application of the annual test and the application of the additional term test are coordinated as described in
section 5 of this Appendix A.
[]* The results are tested on a term basis, meaning that they are tested only once, as of the Last Effective APA Covered Year,
for a period consisting of the Last Effective APA Covered Year and all prior APA Covered Years.
[]* The results are tested on the basis of two subterms. For this purpose, the APA Term is divided into two subterms. The
first subterm consists of all APA Covered Years ending on or before #DATE, and the second subterm consists of all other
APA Covered Years. For each subterm, the results are tested as of the Last Effective APA Subterm Covered Year, for a
period consisting of the Last Effective APA Subterm Covered Year and all prior APA Covered Years in the subterm.
[]* The results are tested on a subterm basis for all APA Covered Years ending on or before #DATE (the “subterm”), and
are tested annually for each other APA Covered Year, as follows:
The results are tested as of the Last Effective APA Subterm Covered Year, for a period consisting of the Last Effec­
tive APA Subterm Covered Year and all prior APA Covered Years in the subterm.
The results are tested as of each APA Covered Year that is not in the subterm, for a period consisting of that APA
Covered Year.
[]* The results are tested on a cumulative basis, meaning that (except as provided in the following sentence) they are not
tested as of the first APA Covered Year but they are tested as of each other particular APA Covered Year for a period
consisting of such particular APA Covered Year and all prior APA Covered Years. However, if the Last Effective APA
Covered Year is the first APA Covered Year, then the results are tested as of the first APA Covered Year, for a period
consisting of such APA Covered Year.
[]* The results are tested on a three­year rolling average basis, meaning that the results are tested as of each APA Covered
Year, for a period consisting of the APA Tax Year corresponding to the APA Covered Year (but excluding any portion of
that APA Tax Year that is after the APA Term), and the Tested Party’s two preceding tax years.
e. Other Provisions
The Tested Party’s financial results, to be tested as described above, are for:
[] The Tested Party as a whole.
[] Only a segment of the Tested Party’s activity. #DETAILED DESCRIPTION OF THE SEGMENT AND OF THE AL­
LOCATION AND APPORTIONMENT METHODS USED, INCLUDING ANY APPLICABLE FORMULAS AND
DEFINITIONS OF QUANTITIES USED IN THOSE FORMULAS. THIS DESCRIPTION SHOULD BE DETAILED
ENOUGH TO ENABLE A STRAIGHTFORWARD VERIFICATION OF COMPLIANCE BY THE IRS EXAMINA­
TION TEAM.

Bulletin No. 2021–15 1049 April 12, 2021
When the Tested Party’s financial results are tested as of a given APA Covered Year, those results shall reflect, to the extent
relevant, any APA Primary Adjustment for this Covered Method made under section 5 of this Appendix A for the APA Tax
Year corresponding to any prior APA Covered Year.
For this Covered Method, if applicable:
[]* For APA Covered Years ending on or before #DATE, it is agreed that this Covered Method, yields financial results as
shown below, and that any APA Primary Adjustments under section 5 of this Appendix A are as shown below.
#TEXT AND/OR TABLES SHOWING THE FINANCIAL RESULTS, THE TESTING OF THOSE FINANCIAL
RESULTS UNDER THE COVERED METHOD, AND ANY RESULTING APA PRIMARY ADJUSTMENTS.
For this Covered Method, if applicable:
[] This Covered Method addresses the pricing for a transfer of intangible property (which does not constitute a platform
contribution transaction as defined in U.S. Treasury Regulations section 1.482­7(b)(1)(ii)) within the meaning of U.S.
Treasury Regulations section 1.482­4. That pricing will not be subject to periodic adjustments by the IRS, during or
after the APA Term, under U.S. Treasury Regulations section 1.482­4(f)(2) or (6).
[] This Covered Method addresses the pricing for a platform contribution transaction (“PCT”). That PCT will not be treat­
ed as a Trigger PCT within the meaning of U.S. Treasury Regulations section 1.482­7(i)(6)(i) for purposes of making
periodic adjustments, during or after the APA Term, under U.S. Treasury Regulations section 1.482­7(i)(6).
5. Application of Covered Method(s) to Income Reporting
For each APA Tax Year, and for each Covered Method and corresponding Covered Issue(s), the amounts reported by U.S. Tax­
payer and Non­U.S. Taxpayer for income tax purposes under the laws of the United States and #COUNTRY(IES) must clearly
reflect the Tested Party’s actual transactions, allocations, and/or recordkeeping, as applicable, that relate to such Covered Is­
sue(s), adjusted as necessary to conform with section 4 of this Appendix A. Accordingly, for each particular APA Tax Year and
corresponding APA Covered Year, and for each such Covered Method:
i. If the Tested Party’s financial results are tested as of such APA Covered Year and do not conform with section 4 of this
Appendix A, then the tax reporting for such APA Tax Year must clearly reflect an adjustment that brings such results into
conformance (an “APA Primary Adjustment”). If section 4 of this Appendix A specifies conformance to an Arm’s Length
Range, then the adjustment shall be to:
[] the Median.
[]* the near edge of the Arm’s Length Range.
[]* the Median for Covered Issues #SPECIFY WHICH ONES, and the near edge of the Arm’s Length Range for Covered
Issues #SPECIFY WHICH ONES.
ii. If an adjustment is not required under paragraph (i) above, then the tax reporting must clearly reflect the Tested Party’s fi­
nancial results, with no adjustment. In this case there is no APA Primary Adjustment.
iii. If both an annual test and an additional term test apply under such Covered Method, and such APA Covered Year is the Last
Effective APA Covered Year, so that as of such APA Covered Year the Tested Party’s financial results are tested under both the
annual test and the term test, then paragraphs (i) and (ii) above are modified by this paragraph (iii), which coordinates the ap­
plication of both tests. As explained in more detail below, the annual test is applied first, followed by the term test. Specifically,
the need for and amount of any APA Primary Adjustment for such APA Covered Year will be determined as follows:
A. First apply paragraphs (i) and (ii) above under the assumption that only the annual test applies. Any required adjustment
will be referred to as the “annual adjustment” rather than an “APA Primary Adjustment.” If there is no required adjust­
ment, the annual adjustment is considered to be zero.

April 12, 2021 1050 Bulletin No. 2021–15
B. Next, apply paragraphs (i) and (ii) above to the Tested Party’s financial results as adjusted by any nonzero annual adjust­
ment, under the assumption that only the term test applies to those results. Any required adjustment under this applica­
tion of paragraphs (i) and (ii) will be referred to as the “term adjustment” rather than an “APA Primary Adjustment.” If
there is no such required adjustment, the term adjustment is considered to be zero.
C. Add the annual adjustment and term adjustment, taking account of the magnitude and (if nonzero) direction of each. If
this sum is zero, there is no APA Primary Adjustment for such APA Covered Year. If this sum is nonzero, this sum gives
the magnitude and direction of the APA Primary Adjustment for such APA Covered Year. Any APA Primary Adjustment,
or the lack of an APA Primary Adjustment, must be clearly reflected in the tax reporting for such APA Tax Year (see
paragraphs (i) and (ii) above).
iv. If this APA is unilateral and such APA Covered Year is within the Rollback Period, then:
[] Paragraphs (i)­(iii) above notwithstanding, an APA Primary Adjustment will not be made if that APA Primary Adjust­
ment would decrease the income of U.S. Taxpayer for such APA Tax Year.
[]* Paragraphs (i)­(iii) above apply without modification.
If indicated, the above provisions on APA Primary Adjustments are modified as follows:
[]* Any APA Primary Adjustment that would be made under the above provisions for an APA Tax Year ending before
#DATE will instead be made for the APA Tax Year ending #THE SAME DATE (the “Telescoping Year”). For each
particular Covered Method, all APA Primary Adjustments that are made for the Telescoping Year (including any APA
Primary Adjustments that are moved to the Telescoping Year as just described, as well as any APA Primary Adjustment
originally made for the Telescoping Year) are netted.
[] The foregoing provision applies without modification.
[] The foregoing provision applies with the following modification. An APA Primary Adjustment that is thus moved
from a particular APA Tax Year (the “Original Year”) to the Telescoping Year shall be increased in amount to reflect
the time value of money. That increase will consist of multiplication by a factor that is an annual rate raised to a
power. The annual rate is 1.#XY. The power is the quotient of (i) the average of the number of months by which the
end of the Telescoping Year is later than the end of the Original Year, and the number of months by which the start
of the Telescoping Year is later than the start of the Original Year (with any fractions of months rounded to whole
months), (ii) divided by twelve.
For U.S. tax purposes, the generally applicable Code rules will apply with respect to APA Primary Adjustments, except as other­
wise provided in Rev. Proc. 2015­41 or in this APA.
6. Conforming Adjustments and Repatriation of Funds
The provisions in this section 6 apply to “Repatriable Issues,” which are Covered Issues that concern transactions between as­
sociated enterprises that fall under Article 9 of the OECD Model Tax Convention. Such transactions correspond to transactions
that under U.S. law are subject to application of Code section 482, as modified by any applicable treaty provision.
If the application of a Covered Method to a Repatriable Issue requires an APA Primary Adjustment under section 5 of this Ap­
pendix A for a given APA Tax Year, then for U.S. tax purposes there generally must be a corresponding conforming adjustment
as specified in U.S. Treasury Regulations section 1.482­1(g)(3) as amplified by Rev. Proc. 99­32 or any successor revenue proce­
dure. However, for this purpose, all APA Primary Adjustments for such APA Tax Year arising from the application of a Covered
Method to a Repatriable Issue are first netted to yield a net APA Primary Adjustment for such APA Tax Year. Only if the net APA
Primary Adjustment is nonzero is a conforming adjustment required.
For each APA Tax Year with a nonzero net APA Primary Adjustment, for U.S. tax purposes the conforming adjustment will be
accomplished in the following steps:
i. The conforming adjustment will be accomplished between #U.S. ENTITY and #NON­U.S. ENTITY, which will be referred
to here as “U.S. Entity” and “Non­U.S. Entity”, respectively. An intercompany payable will be established between U.S.

Bulletin No. 2021–15 1051 April 12, 2021
Entity and Non­U.S. Entity in the amount and direction of the net APA Primary Adjustment, as of the last day of such APA
Tax Year. This payable will be denominated in #CURRENCY. The payable will be treated as indebtedness for all U.S. fed­
eral tax purposes; provided, however, that the payable will not be treated as indebtedness for purposes of Code section 956
if the payable is satisfied within 90 days of the close of the APA Tax Year with respect to which it is established.
ii. [] The intercompany payable will bear interest at an arm’s length rate.
[] Such arm’s length rate is not specified in this APA and will be determined under applicable legal principles.
[] Such arm’s length rate is determined as follows. #DESCRIPTION OF ARM’S LENGTH RATE (FOR EXAMPLE,
FOR A U.S. DOLLAR PAYABLE, A CERTAIN APPLICABLE FEDERAL RATE UNDER U.S. TREASURY
REGULATIONS SECTION 1.482­2(a)(2)(iii)(C)).
[] This APA is bilateral or multilateral. As agreed between the United States and #COUNTRY(IES), the intercompany
payable will not bear interest.
iii. The intercompany payable must be satisfied, in a manner permitted under Rev. Proc. 99­32 or any successor revenue proce­
dure, within 90 days of the later of (1) the date for timely filing (with extensions) of the U.S. return for such APA Tax Year,
and (2) the APA’s U.S. Effective Date. If any amount of the intercompany payable is not otherwise so satisfied within that
90­day period, such amount, on the last day of such period, will be deemed (1) to be paid between U.S. Entity and Non­U.S.
Entity in satisfaction of the payable, and (2) to be paid (directly or indirectly, as specified below) between U.S. Entity and
Non­U.S. Entity in the opposite direction (that is, from the deemed recipient of the intercompany payable to the deemed
payor of the intercompany payable). These two deemed payments on the same day will cancel and thus yield no net cash
flow between these two entities. The second of these deemed payments will be referred to as the “reverse payment.” The
reverse payment will be deemed to be as follows:
A. If the net APA Primary Adjustment increases U.S. income:
[] The reverse payment will be deemed to be a contribution to capital from U.S. Entity to Non­U.S. Entity, either
directly, or indirectly through the corporate chain, as the case may be.
[] The reverse payment will be deemed to be a distribution from U.S. Entity to Non­U.S. Entity, either directly, or
indirectly through the corporate chain, as the case may be.
[] The reverse payment will be deemed to be a distribution from U.S. Entity to #COMMON PARENT, either directly,
or indirectly through the corporate chain, as the case may be, followed by a contribution by #COMMON PARENT
to non­U.S. Entity, either directly or indirectly through the corporate chain, as the case may be.
B. If the net APA Primary Adjustment decreases U.S. income:
[] The reverse payment will be deemed to be a contribution to capital from non­U.S. Entity to U.S. Entity, either
directly, or indirectly through the corporate chain, as the case may be.
[] The reverse payment will be deemed to be a distribution from non­U.S. Entity to U.S. Entity, either directly, or
indirectly through the corporate chain, as the case may be.
[] The reverse payment will be deemed to be a distribution from non­U.S. Entity to #COMMON PARENT, either
directly, or indirectly through the corporate chain, as the case may be, followed by a contribution by #COMMON
PARENT to U.S. Entity, either directly, or indirectly through the corporate chain, as the case may be.
This situation is generally described in paragraph 4.66 of the OECD Guidelines, and in U.S. Treasury Regulations sec­
tion 1.482­1(g) and Rev. Proc. 99­32.
In this APA, if applicable:
[]* For the APA Tax Year(s) ending on or before #DATE, it is agreed that the net APA Primary Adjustment(s), if any, from
the application of the Covered Methods are as follows: #FOR EACH SUCH APA TAX YEAR, DESCRIPTION OF

April 12, 2021 1052 Bulletin No. 2021–15
WHETHER THERE IS A NET APA PRIMARY ADJUSTMENT, AND IF SO THE AMOUNT AND DIRECTION. IF
THERE IS MORE THAN ONE COVERED METHOD FOR A REPATRIABLE ISSUE, ALSO PROVIDE A TABLE
SHOWING THE DERIVATION, FOR EACH SUCH APA TAX YEAR, OF THE NET APA PRIMARY ADJUST­
MENT FROM THE APA PRIMARY ADJUSTMENT (OR LACK OF ONE) FOR EACH SUCH COVERED METH­
OD. #FOR ANY SUCH NET APA PRIMARY ADJUSTMENTS, DESCRIPTION OF THE MEANS BY WHICH THE
CONFORMING ADJUSTMENT HAS BEEN OR WILL BE SATISFIED, WITH APPLICABLE DATES.
7. Definitions
The definitions in the table below apply to this APA.
The defined terms in this table include certain measures of profitability (e.g., operating profit, operating margin). Most of these
measures are ultimately defined in terms of sales revenue, operating expenses, and operating assets (defined terms), and cogs
and non­interest­bearing liabilities (undefined terms). The definitions of sales revenue, operating expenses, and operating assets
contain a limitation to the relevant business activity. Similarly, each use of the terms “cogs” and “non­interest­bearing liabilities”
is accompanied by a limitation to the relevant business activity. Therefore, the measures of profitability based on these five terms
all are defined with a limitation to the relevant business activity. (Certain other measures of profitability in this table relate to the
provision of services and are defined with reference to those services. Therefore, those measures as well contain a limitation to
the relevant business activity.)
TermDefinition
Arm’s Length RangeWith respect to a particular Covered Method, a numerical range that defines the values for which
certain financial results of the Tested Party are considered to satisfy the arm’s length standard.
(This term may be referenced in section 4 of this Appendix A.)
APA Primary Adjustment(Defined in section 5 of this Appendix A.)
APA Covered Year(Defined in section 2 of this Appendix A.)
APA Term(Defined in section 2 of this Appendix A.)
APA Tax Year(Defined in section 2 of this Appendix A.)
Applicable Accounting Stan­
dard
The Applicable Accounting Standard is #CHOOSE FROM U.S. GAAP, IFRS, ETC. for U.S.
Taxpayer and #CHOOSE FROM U.S. GAAP, IFRS, ETC. for Non­U.S. Taxpayer.
Berry ratioThe ratio of gross profit to operating expenses.
Code The U.S. Internal Revenue Code of 1986, title 26 of the United States Code, as amended.
correspond, corresponding(With regard to APA Covered Years and APA Tax Years, defined in section 2 of this Appendix A;
with regard to Covered Issues and Covered Methods, defined in section 4 of this Appendix A.)
Covered Entity(ies)(Defined in section 1 of this Appendix A.)
Covered Issue(s)(Defined in section 3 of this Appendix A.)
Covered MethodA method used to resolve one or more Covered Issues, as described in section 4 of this Appendix
A. (In some cases, this method may be a “transfer pricing method” within the meaning of chapter
II of the OECD Guidelines and U.S. Treasury Regulations section 1.482­1(b).)
Critical Assumption fails, fail­
ure of a Critical Assumption
A Critical assumption “fails” when the Critical Assumption has not been met. This situation is
referred to as the “failure” of the Critical Assumption.
Early TerminationA termination of this APA’s effectiveness, either in its entirely or only as applied to certain Covered
Issues, before the end of the APA Term. Such a termination could result from one or more of the
following circumstances: (i) a Critical Assumption failure, (ii) a violation of the terms and condi­
tions of this APA, (iii) a cancellation of the APA under Rev. Proc. 2015­41, and (iv) an amendment
of the APA. If an Early Termination so terminates this APA’s effectiveness as applied to a particular
Covered Issue, the Early Termination is said to “apply” to or for that Covered Issue.
Any such termination of effectiveness would occur as of the end of an APA Tax Year (see Rev.
Proc. 2015­41, section 7.06). Because such end of an APA Tax Year is before the end of the APA
Term, such end of an APA Tax Year is also the end of the corresponding APA Covered Year (see
the definitions of APA Tax Year and APA Covered Year in section 2 of this Appendix A). Thus, an
Early Termination always would occur as of the end of an APA Covered Year. That fact is assumed
in the definitions in this table of Last Effective APA Covered Year and Last Effective APA Subterm
Covered Year.

Bulletin No. 2021–15 1053 April 12, 2021
TermDefinition
Gross profitSales revenue, less cost of goods sold for the relevant business activity.
Gross profit margingross profit, divided by sales revenue
Gross profit markupgross profit, divided by cost of goods sold for the relevant business activity
Gross services marginIn connection with a provision of services, the ratio of gross services profit to the price paid for
the services in an uncontrolled transaction. For this purpose, gross services profit equals the
amount of such price that is retained by the Tested Party.
Gross services profit markupIn connection with a provision of services, gross services profit, divided by transactional costs.
For this purpose, gross services profit equals sales revenue less transactional costs. Also, for this
purpose, transactional costs equal costs directly attributable to providing the services. Such costs
would include, for example, all compensation attributable to employees directly involved in the
performance of such services, and costs of materials and supplies consumed or made available in
rendering the services.
IFRSInternational Financial Reporting Standards.
Invested capitalOperating assets, less non­interest­bearing liabilities used in the relevant business activity.
IRSThe Internal Revenue Service, an agency of the U.S. government.
IFRSInternational Financial Reporting Standards.
Last Effective APA Covered
Year
For a particular Covered Method, the last APA Covered Year for which this APA remains effec­
tive as to the Covered Issue(s) corresponding to that Covered Method. The Last Effective APA
Covered Year will be the last APA Covered Year unless an Early Termination applies to such
Covered Issue(s). See also the definition in this table of Early Termination.
Last Effective APA Subterm
Covered Year
For a particular Covered Method, and with reference to a particular set of APA Covered Years
that is defined as a subterm, the last APA Covered Year in the subterm for which this APA
remains effective as to the Covered Issue(s) corresponding to that Covered Method. The Last
Effective APA Subterm Covered Year will be the last APA Covered Year in the subterm unless
an Early Termination applies to such Covered Issue(s) and renders the APA ineffective as to
such Covered Issue(s) before the end of the subterm. See also the definition in this table of Early
Termination.
Markup on total costsThe ratio of operating profit to total costs.
MedianWith respect to a particular Arm’s Length Range, the median of a set of observations of market
data from which that Arm’s Length Range was determined.
Non­U.S. Taxpayer(Defined in section 1 of this Appendix A.)
Non­U.S. Covered Entity(ies)(Defined in section 1 of this Appendix A.)
OECD Guidelines
Organisation for Economic Co­operation and Development, OECD Transfer Pricing Guidelines
for Multinational Enterprises and Tax Administrations (July 2017).
OECD PE Report
Organisation for Economic Co­operation and Development, 2010 Report on Attribution of Profit
to Permanent Establishments (July 22, 2010).
Operating assetsThe value of all assets used in the relevant business activity, including fixed assets and current
assets (such as accounts receivable and inventories). The following items are excluded from
operating assets: cash, cash equivalents, short­term investments, deferred tax assets, tax refunds,
intangibles, investments in subsidiaries, portfolio investments.
Operating expensesAll expenses (including depreciation) not included in cost of goods sold except for interest
expense, domestic and foreign income taxes, amortization of intangibles, and any other expens­
es not related to the operation of the relevant business activity. Operating expenses normally
include, for example, expenses associated with advertising, promotion, sales, marketing, ware­
housing and distribution, administration, and a reasonable allowance for depreciation. For U.S.
Taxpayer, foreign income taxes are defined in U.S. Treasury Regulations section 1.902­1(a)(7).
Operating marginThe ratio of operating profit to sales revenue.
Operating profitSales revenue, less cost of goods sold for the relevant business activity, less operating expenses.
Rev. Proc. 99­32A revenue procedure issued by the IRS that is cited as Rev. Proc. 99­32, 1999­2 C.B. 296.
Rev. Proc. 2015­41A revenue procedure issued by the IRS that is cited as Rev. Proc. 2015­41, 2015­35 I.R.B 263.

April 12, 2021 1054 Bulletin No. 2021–15
TermDefinition
Repatriable Issue(Defined in section 6 of this Appendix A.)
Relevant Financial DataWith respect to a particular Covered Method, the financial results of the Tested Party that are
tested, together with any other financial data (of the Tested Party or any other party) that are
considered in determining compliance with the Covered Method.
Return on invested capital(Defined in the same way as “return on operating assets,” but with “operating assets” replaced by
“invested capital” wherever it occurs in the definition.)
Return on operating assetsWith respect to a particular Covered Method, the Tested Party for that Covered Method, and a
testing period used in that Covered Method, the operating profit over the testing period divided
by the time­weighted average operating assets over the testing period.
For this purpose, the time­weighted average operating assets over the testing period is the sum,
over all APA Covered Years in the testing period, of the following product: (i) the simple average
of the operating asset levels at the start and end of the APA Tax Year corresponding to such APA
Covered Year, multiplied by (ii) the ratio of the number of calendar days in the APA Covered Year,
to 365.
For example, suppose that (i) the testing period consists of two consecutive APA Covered Years,
the first with 183 calendar days and the second with 366 calendar days, (ii) the total operating
profit over those two years is exactly 3.4, and (iii) the operating assets levels are exactly 10 at the
start of the APA tax year corresponding to the first APA Covered Year, 16 at the end of the APA Tax
Year corresponding to the first APA Covered Year (which is also the start of the APA Tax Year cor­
responding to the second APA Covered Year), and 22 at the end of the APA Tax Year corresponding
to the second APA Covered Year. Then the time­weighted average operating assets over the testing
period is [(10+16)/2]*(183/365) + [(16+22)/2]*(366/365) = 25.5699. The return on operating as­
sets is then 3.4/25.5699 = 13.30%.
Rollback Period(This term, if applicable, is defined in section 2 of this Appendix A.)
Sales revenueTotal receipts from sale of goods and provision of services, less returns and allowances, for the
relevant business activity.
Tax yearA standard or irregular year that is used for tax reporting purposes. For U.S. Taxpayer, a tax year
is a “taxable year,” as defined in Code section 441.
Tested Party(Defined in section 4 of this Appendix A with regard to a particular Covered Method.)
Testing periodThe time period over which financial results are tested (see section 4 of Appendix A to this APA).
Total costsCost of goods sold for the relevant business activity, plus operating expenses.
U.S. Treasury RegulationsTax regulations issued by the U.S. Treasury Department, found at title 26 of the Code of Federal
Regulations.
U.S. Covered Entity(ies)(Defined in section 1 of this Appendix A.)
U.S. Effective DateThe date, or later date of the dates, upon which the APA is executed by the IRS and by or on
behalf of each U.S. Covered Entity.
U.S. GAAPU.S. generally accepted accounting principles.
U.S. returnAny of the “Returns with respect to income taxes under subtitle A” required by Code section
6012, and any “return” for a partnership required by Code section 6031.
U.S. Taxpayer(Defined in section 1 of this Appendix A.)

Bulletin No. 2021–15 1055 April 12, 2021
APPENDIX B
CRITICAL ASSUMPTIONS
The Critical Assumptions are:
1. The Covered Entities’ business activities, functions performed, risks assumed, assets employed, contractual terms, markets,
and economic conditions faced in relation to the Covered Issue(s) will remain materially the same as described in the APA
Request. For this purpose, a mere change in business results will not be a material change.
2. The Covered Entities’ financial accounting methods and classifications and methods of estimation in relation to the Covered
Issue(s) and Covered Method(s) will remain materially the same as described or used in the APA Request.
If indicated, the effect of a critical assumption failure may be limited as follows:
[] The failure of Critical Assumptions #XXX listed above will affect the effectiveness of this APA only as to Covered Issues
#YYY listed in Appendix A. Thus, as to the other Covered Issues, the APA will remain in force (except to the extent some
other condition affects the APA’s effectiveness as to those Covered Issues).
The Covered Entities will not cause a critical assumption to fail for the purpose of rendering the APA ineffective, unless they have
an independent business justification (unrelated to rendering the APA ineffective) for the action that causes the critical assumption
to fail. If one or more Covered Entities do cause a critical assumption to fail for the purpose of rendering the APA ineffective, and
without such independent business justification, then the Covered Entities will not withhold consent to an amendment to this APA
to the effect that this APA will continue in force without regard to such failure. In this case, if a Covered Entity refuses to sign such
an amendment, such an amendment may be executed without such signature and will then have the same force and effect as if the
amendment had such signature.

April 12, 2021 1056 Bulletin No. 2021–15
APPENDIX C
APA RECORDS AND ANNUAL REPORT
APA RECORDS
The APA Records will consist of all documents listed below for inclusion in the Annual Report, as well as all documents, notes,
work papers, records, or other writings that support the information provided in such documents.
ANNUAL REPORT
An Annual Report must be submitted for each APA Tax Year in accordance with paragraph 6(e) of the APA and section 7.02 of Rev.
Proc. 2015­41.
For each APA Tax Year, the Annual Report (and each copy or version as required by paragraph 6(e) of the APA) will include:
1. Two copies of a properly completed APA Annual Report Summary in the form of Appendix D to this APA, one copy of the form
bound with, and one copy provided separately from, the rest of the Annual Report. (The electronic version of the Annual Report
need have only one copy of this item.)
2. A table of contents, organized according to the additional required items listed below.
3. For such APA Tax Year and the corresponding APA Covered Year, statements that fully identify, describe, analyze, and explain:
a. All material differences between the Covered Entities’ business activities, functions performed, risks assumed, assets em­
ployed, contractual terms, markets, and economic conditions faced in relation to the Covered Issues during such APA Cov­
ered Year from those same items described in the APA Request. If there have been no such material differences, the Annual
Report will include a statement to that effect.
b. All material differences between Covered Entities’ financial accounting methods and classifications and methods of estima­
tion in relation to the Covered Issues and Covered Methods used during such APA Covered Year, from those described or
used in the APA Request. If any change was made to conform to changes in the Applicable Accounting Standard, U.S. Tax­
payer will specifically identify the change. If there have been no such material differences, the Annual Report will include a
statement to that effect.
c. Regarding notices under paragraph 16 of the APA:
i. A current statement of how the IRS should provide such notices to U.S. Taxpayer (and, if applicable, to U.S. Taxpayer’s
representative).
ii. A copy of any such notices that were submitted by U.S. Taxpayer to the IRS after the last Annual Report was submitted
(or, if there was no prior Annual Report, after the APA was executed). If there were no such notices, the Annual Report
will include a statement to that effect.
d. Any failure of any Critical Assumption. If there has been no such failure, the Annual Report will include a statement to that
effect.
e. Whether or not material information submitted while the APA Request was pending is discovered to be false, incorrect, or
incomplete, and if so a correction or completion of that information, as applicable.
f. Any change to any entity classification for federal income tax purposes (including any change that causes an entity to be dis­
regarded for federal income tax purposes) of any Worldwide Group member that is a Covered Entity or is otherwise relevant
to the Covered Issue(s) or Covered Method(s).
g. The following regarding any APA Primary Adjustments made for such APA Tax Year under Appendix A to this APA:
i. The amounts of any APA Primary Adjustments;

Bulletin No. 2021–15 1057 April 12, 2021
ii. The circumstances that led to such APA Primary Adjustments being necessary;
iii. A calculation of the net APA Primary Adjustment as defined in Appendix A to this APA; and
iv. A complete description of the means by which the conforming adjustment (see section 6 of Appendix A to this APA) is
accomplished, including:
A. a description of any accounts payable established, including the entities involved and when the payables are estab­
lished;
B. a description of any amounts paid or deemed paid (including amounts paid or deemed paid in satisfaction of an
intercompany payable established as described in section 6 of Appendix A to this APA, and including any deemed
reverse payments as described in section 6 of Appendix A to this APA), that specifies the entities involved, when
the amounts are paid or deemed paid, and by what means any amounts are actually paid; and
C. the character (such as capital, ordinary, income, expense, dividend, contribution to capital) and country source of
any payments and deemed payments, and the specific affected line item(s) of any affected U.S. return;
h. A detailed numerical explanation of how the result of the application of the Covered Methods is reflected on the U.S. return,
with reference to particular line items on the U.S. return. This explanation shall include the amounts, description, reason for,
and financial analysis of any book­tax differences, as reflected on Schedule M­1 or Schedule M­3 of the U.S. return for such
APA Tax Year, that (i) are relevant to an APA Primary Adjustment, (ii) otherwise are relevant to the book and tax treatment
of any income or expense item that is part of the Relevant Financial Data for, or is determined by, any Covered Method for
such APA Tax Year, or (iii) otherwise are relevant to the APA. U.S. Taxpayer shall not simply attach a copy of the pertinent
schedule. Rather, U.S. Taxpayer shall specifically identify the relevant items from that schedule and shall describe in appro­
priate detail the nature of those items, how they arose, and how they are accounted for.
i. Whether or not U.S. Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.
4. The Financial Statements and additional statements required under paragraph 6(f) of the APA, for such APA Tax Year and for any
other tax year whose financial data are relevant to compliance with the APA for such APA Tax Year;
5. A financial analysis that includes U.S. Taxpayer’s calculations to apply the Covered Method(s) to the Covered Issue(s) for such
APA Covered Year and supports those calculations with additional material that ties those calculations to the Financial State­
ments. The intent of this requirement is that the analysis submitted should provide a clear, complete, detailed, and self­contained
means by which the IRS can verify compliance with the Covered Method(s). This requirement is further explained as follows:
a. The additional material must support every numerical input to U.S. Taxpayer’s calculations.
b. The additional material could include, for example, consolidating financial statements, segmented financial data, and records
from the general ledger.
c. Where segmented data are used, U.S. Taxpayer must specify in detail how it accomplished the segmentation, including how
it made allocations and apportionments, including (i) the definition and calculation of any apportionment keys used, and (ii)
the calculations applying such keys. The inputs used for those various calculations must be tied to the Financial Statements.
d. The additional material must be annotated sufficiently to let the IRS easily trace U.S. Taxpayer’s entire calculations to ob­
jective, verifiable sources of data.
e. Where needed for clarity, terms must be defined.
6. The financial results pertinent to the Covered Method(s), for such APA Covered Year and all prior years, entered along with data
concerning the Covered Method(s) in an electronic results template available by contacting APMA.
7. [] An organizational chart for Worldwide Group, revised annually to reflect all ownership or structural changes of the Covered
Entities and any other entities that are relevant to the Covered Issue(s) or are otherwise relevant to the Covered Method(s).

April 12, 2021 1058 Bulletin No. 2021–15
[]* An organizational chart for a part of Worldwide Group that includes all Covered Entities and includes any other entities
relevant to the Covered Issue(s) or Covered Method(s), revised annually to reflect all ownership or structural changes of
entities that are involved in the Covered Issue(s) or are otherwise relevant to the Covered Issue(s) or Covered Method(s).
8. A valid IRS Form 2848 “Power of Attorney and Declaration of Representative” for any representative to receive notices under
paragraph 16 of this APA.
9. A copy of the APA and any amendment.
10. A penalty of perjury statement, executed in accordance with Rev. Proc. 2015­41, sections 7.02(8) and (9).

Bulletin No. 2021–15 1059 April 12, 2021
APPENDIX D
APA ANNUAL REPORT SUMMARY FORM
The APA Annual Report Summary on the next page is a required APA Record. APMA supplies some of the information requested
on the form. U.S. Taxpayer is to supply the remaining information requested by the form and submit the form as part of its Annual
Report.

April 12, 2021 1060 Bulletin No. 2021–15
Internal Revenue ServiceAPMA Case No.
Large Business and International DivisionReviewer
Treaty & Transfer Pricing OperationsTeam Leader
Advance Pricing Mutual Agreement ProgramEconomist
Other APA Team Members
APA Information
U.S. Taxpayer’s Name
U.S. Taxpayer’s EIN
U.S. Taxpayer’s NAICS
Unilateral/Bilateral/Multilateral
Original or Renewal
APA Common Name, if any
APA Request Filing Date
Date APA Executed
APA Term (date­to­date, inclusive)
Foreign Countr(y)ies Involved
Annual Report Due Dates for years ending on or before [date]:
Annual Report Due Dates for other years: [last month of tax year] 15 following close of year
Covered Methods Summary Description
(e.g., CPM, operating margin 2%­5%)
Taxpayer’s Principal Representative
APA Annual Report Information:
Year(s) covered by this Annual Report
Issues for APMA’s special attention (or “None”)
Taxpayer Notice PersonName
Title
If necessary, include a Address
current Form 2848 for theCity/State/Zip
Notice PersonPhone/Fax
Email
Current Representative, if anyName
Title
Include a current Form 2848Address
for the representativeCity/State/Zip
Phone/Fax
Email
Date Annual Report Filed (to be filled in by APMA):

Bulletin No. 2021–15 1061 April 12, 2021
Amounts Paid for Certain
Personal Protective
Equipment Treated as
Medical Expenses
Announcement 2021-7
This announcement notifies taxpayers
that amounts paid for personal protective
equipment, such as masks, hand sanitizer
and sanitizing wipes, for the primary pur­
pose of preventing the spread of the Coro­
navirus Disease 2019 (COVID­19 PPE)
are treated as amounts paid for medical
care under § 213(d) of the Internal Reve­
nue Code (Code). Therefore, amounts paid
by an individual taxpayer for COVID­19
PPE for use by the taxpayer, the taxpay­
er’s spouse, or the taxpayer’s dependent(s)
that are not compensated for by insurance
or otherwise are deductible under § 213(a)
provided that the taxpayer’s total medical
expenses exceed 7.5 percent of adjusted
gross income.
Because these amounts are expenses
for medical care under § 213(d) of the
Code, the amounts are also eligible to be
paid or reimbursed under health flexible
spending arrangements (health FSAs),
Archer medical savings accounts (Archer
MSAs), health reimbursement arrange­
ments (HRAs), or health savings accounts
(HSAs). However, if an amount is paid or
reimbursed under a health FSA, Archer
MSA, HRA, HSA or any other health
plan, it is not deductible under § 213.
Group health plans, including health
FSAs and HRAs, under the terms of which
expenses for COVID­19 PPE may not be
reimbursed, may be amended pursuant to
this announcement to provide for reim­
bursements of expenses for COVID­19
PPE incurred for any period beginning
on or after January 1, 2020, and such an
amendment will not be treated as causing
a failure of any reimbursement to be ex­
cludable from income under § 105(b) or
as causing a § 125 cafeteria plan to fail
to meet the requirements of § 125. Group
health plans may be amended pursuant to
this announcement if the amendment is
adopted not later than the last day of the
first calendar year beginning after the end
of the plan year in which the amendment
is effective, no amendment with retroac­
tive effect is adopted after December 31,
2022, and the plan is operated consistent
with the terms of the amendment, includ­
ing during the period beginning on the ef­
fective date of the amendment through the
date the amendment is adopted.
DRAFTING INFORMATION
The principal author of this announce­
ment is Amy S. Wei of the Office of As­
sociate Chief Counsel (Income Tax and
Accounting). For further information
concerning this announcement, contact
Ms. Wei at (202) 317­7011 (not a toll­free
number).

Bulletin No. 2021–15 i April 12, 2021
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:
Amplified describes 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).
Clarified is 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 rul­
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub­
lished ruling and points out an essential
difference between them.
Modified is 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 and clarified, above).
Obsoleted describes a previously pub­
lished ruling that is not considered deter­
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings 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.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes 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
period 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
superseded describes 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 previous­
ly 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.
Supplemented is 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.
Suspended is 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 cas­
es in litigation, or the outcome of a Ser­
vice study.
Abbreviations
The following abbreviations in current use
and formerly used will appear in material
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.

April 12, 2021 ii Bulletin No. 2021–15
Numerical Finding List
1
Bulletin 2021–15
AOD:
2021­1, 2021­15 I.R.B. 985
Announcements:
2021­01, 2021­04 I.R.B. 506
2021­02, 2021­08 I.R.B. 892
2021­03, 2021­08 I.R.B. 892
2021­04, 2021­09 I.R.B. 895
2021­05, 2021­13 I.R.B. 965
2021­06, 2021­15 I.R.B. 1011
2021­07, 2021­15 I.R.B. 1061
Notices:
2021­01, 2021­02 I.R.B. 315
2021­03, 2021­02 I.R.B. 316
2021­04, 2021­02 I.R.B. 319
2021­02, 2021­03 I.R.B. 478
2021­05, 2021­03 I.R.B. 479
2021­07, 2021­03 I.R.B. 482
2021­09, 2021­05 I.R.B. 678
2021­06, 2021­06 I.R.B. 822
2021­08, 2021­06 I.R.B. 823
2021­11, 2021­06 I.R.B. 827
2021­12, 2021­06 I.R.B. 828
2021­13, 2021­06 I.R.B. 832
2021­10, 2021­07 I.R.B. 888
2021­15, 2021­10 I.R.B. 898
2021­16, 2021­10 I.R.B. 907
2021­18, 2021­11 I.R.B. 911
2021­19, 2021­11 I.R.B. 920
2021­20, 2021­11 I.R.B. 922
2021­17, 2021­14 I.R.B. 984
2021­21, 2021­15 I.R.B. 986
2021­22, 2021­15 I.R.B. 987
Proposed Regulations:
REG­130081­19, 2021­02 I.R.B. 321
REG­114615­16, 2021­03 I.R.B. 489
REG­111950­20, 2021­05 I.R.B. 683
REG­115057­20, 2021­05 I.R.B. 714
Revenue Procedures:
2021­01, 2020­01 I.R.B. 1
2021­02, 2020­01 I.R.B. 116
2021­03, 2020­01 I.R.B. 140
2021­04, 2020­01 I.R.B. 157
2021­05, 2020­01 I.R.B. 250
2021­07, 2020­01 I.R.B. 290
2021­09, 2020­03 I.R.B. 485
2021­08, 2020­04 I.R.B. 502
2021­10, 2020­04 I.R.B. 503
2021­12, 2020­05 I.R.B. 681
Revenue Procedures:—Continued
2021­11, 2020­06 I.R.B. 833
2021­15, 2020­08 I.R.B. 891
2021­17, 2020­15 I.R.B. 991
2021­18, 2020­15 I.R.B. 1007
2021­19, 2020­15 I.R.B. 1008
Revenue Rulings:
2021­01, 2021­02 I.R.B. 294
2021­02, 2021­04 I.R.B. 495
2021­03, 2021­05 I.R.B. 674
2021­04, 2021­06 I.R.B. 724
2021­05, 2021­10 I.R.B. 896
2021­06, 2021­12 I.R.B. 946
2021­07, 2021­14 I.R.B. 982
Treasury Decisions:
9925, 2021­02 I.R.B. 296
9940, 2021­02 I.R.B. 311
9932, 2021­03 I.R.B. 345
9939, 2021­03 I.R.B. 376
9941, 2021­03 I.R.B. 396
9942, 2021­03 I.R.B. 450
9937, 2021­04 I.R.B. 495
9936, 2021­05 I.R.B. 508
9943, 2021­05 I.R.B. 577
9945, 2021­05 I.R.B. 627
9946, 2021­06 I.R.B. 726
9947, 2021­06 I.R.B. 748
9948, 2021­06 I.R.B. 801
9938, 2021­07 I.R.B. 838
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2020.

Bulletin No. 2021–15 iii April 12, 2021
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2021–15
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2020.

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