Internal Revenue Bulletin 2015-17 (PDF rendition): IRS Notices

us-irs-notices-irb-2015-17-pdfInternal Revenue Bulletin 2015-17 (PDF rendition): IRS NoticesGuidance

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
SPECIAL ANNOUNCEMENT
Notice 2015–30, page 928.
This Notice provides penalty relief for taxpayers who received
a Form 1095–A, Health Insurance Marketplace Statement, that
was incorrect or delayed and who timely filed their 2014
income tax return, including extensions.
INCOME TAX
Notice 2015–30, page 928.
This Notice provides penalty relief for taxpayers who received
a Form 1095–A, Health Insurance Marketplace Statement, that
was incorrect or delayed and who timely filed their 2014
income tax return, including extensions.
EMPLOYEE PLANS
Notice 2015–31, page 929.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for March
2015 used under § 417(e)(3)(D), the 24-month average
segment rates applicable for March 2015, and the 30-year
Treasury rates. These rates reflect the application of
§ 430(h)(2)(C)(iv), which was added by the Moving Ahead for
Progress in the 21st Century Act, Public Law 112–141 (MAP–
21) and amended by section 2003 of the Highway and Trans-
portation Funding Act of 2014 (HATFA).
Finding Lists begin on page ii.
Bulletin No. 2015–17
April 27, 2015

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
April 27, 2015Bulletin No. 2015–17

Part III. Administrative, Procedural, and Miscellaneous
PENALTY RELIEF RELATED
TO INCORRECT OR
DELAYED FORMS 1095–A
Notice 2015–30
Purpose
This Notice provides penalty relief for
taxpayers who received a Form 1095–A,
Health Insurance Marketplace Statement,
that was delayed or that the taxpayer be-
lieves to be incorrect and who timely filed
their 2014 income tax return, including
extensions. Specifically, this Notice pro-
vides relief from the penalty under section
6651(a)(2) of the Internal Revenue Code
for late payment of a balance due, the
penalty under section 6651(a)(3) for fail-
ure to pay an amount due upon notice and
demand, the penalty under section 6654(a)
for underpayment of estimated tax, and
the accuracy-related penalty under section
6662. This relief applies only for the 2014
taxable year.
Background
Section 6651(a)(2) imposes a penalty
for a failure to pay (on or before the due
date for payment) an amount shown as tax
on any return. However, the section
6651(a)(2) penalty is not imposed if the
taxpayer shows that the failure was due to
reasonable cause and not willful neglect.
In general, individuals must pay the tax
shown on the return by April 15.
Section 6651(a)(3) imposes a penalty
for failure to pay an amount of tax re-
quired to be shown on a return that is not
shown on the return within 21 days from
the date of notice and demand. The sec-
tion 6651(a)(3) penalty is not imposed if
the taxpayer shows that the failure to pay
was due to reasonable cause and not will-
ful neglect.
Section 6654(a) imposes a penalty in
the case of an underpayment of estimated
tax by an individual. Generally, taxpayers
are required to make tax payments on
non-wage income in quarterly install-
ments. An underpayment of estimated tax
is the excess of the required quarterly es-
timated tax payment over the amount ac-
tually paid on or before the due date for
the payment. Most taxpayers will avoid
this penalty if they owe less than $1,000 in
tax on their 2014 income tax return after
subtracting their withholding, or if their
withholding and estimated taxes total at
least 90% of the tax for taxable year 2014,
or 100% of the tax shown on their 2013
taxable year return. Additionally, section
6654(e)(3) authorizes the Internal Reve-
nue Service (the Service) to waive the
section 6654(a) penalty for underpay-
ments of estimated tax in unusual circum-
stances to the extent its imposition would
be against equity and good conscience.
Section 6662(a) imposes a penalty on
any portion of an underpayment of tax
required to be shown on a return that is
attributable to one of the items listed in
section 6662(b). Section 6662(b) includes,
among other items, underpayments attrib-
utable to any substantial understatement
of income tax. However, under section
6664(c), the section 6662 penalty is not
imposed with respect to any portion of an
underpayment if the taxpayer shows that
there was reasonable cause for that por-
tion and that the taxpayer acted in good
faith with respect to such portion.
On February 20, 2015, the Centers for
Medicare and Medicaid Services (CMS)
announced that about 800,000 tax filers
who purchased health insurance from the
Federally-facilitated Marketplace during
2014 received a Form 1095–A that con-
tained an error related to the premium for
the second lowest cost Silver plan (often
referred to as the benchmark plan). On
March 20, 2015, CMS further announced
additional issues with the data used to
populate the Form 1095–A that could re-
sult in incorrect information on and delays
in additional Forms 1095–A. The Service
is also aware that some state-based Mar-
ketplaces had issues with the generation
of the Forms 1095–A.
Penalty Relief for 2014
Taxpayers affected by errors or delays
in their Forms 1095–A may be unable to
file a return accurately reflecting their tax
liability by the April 15 deadline. They
may need to seek extensions of time to file
an accurate return and may also be unable
to determine the amount of tax they
should pay at the time of their extension
request in order to avoid liability for a
section 6651(a)(2) failure to pay penalty.
Therefore, in consideration of these fac-
tors and consistent with the authority in
sections 6651(a)(2), 6651(a)(3), 6654(e)(3),
and 6664(c) to provide relief from penal-
ties for taxpayers, this Notice provides
relief from the penalties under sections
6651(a)(2), 6651(a)(3), 6654(a), and 6662(a)
for taxpayers who satisfy the requirements
in this Notice.
Pursuant to this Notice, the Service
will abate for taxable year 2014 the sec-
tion 6651(a)(2) penalty and the section
6651(a)(3) penalty, and waive the section
6654(a) penalty for taxpayers who re-
ceived a delayed Form 1095–A or a Form
1095–A that the taxpayer believes to be
incorrect if the taxpayer timely files their
2014 Federal income tax return, including
extensions. In other words, a taxpayer
must either (1) file a return by April 15, or
(2) request an extension by April 15 and
file a return by October 15.
The Service also will not impose the
accuracy-related penalty under section
6662 on any portion of an underpayment
resulting from the receipt of an incorrect
or delayed Form 1095–A. Taxpayers may
still be liable for a penalty under section
6662 for an underpayment that is unre-
lated to the receipt of an incorrect or de-
layed Form 1095–A.
Additionally, to be eligible for the pre-
mium tax credit, taxpayers must be en-
rolled in a qualifying health care plan.
Some taxpayers who were not enrolled in
a qualifying plan during 2014 erroneously
received a Form 1095–A and may have
used it to file their return. To be eligible
for the relief in this notice, these individ-
uals must amend their 2014 income tax
return by April 15, 2016 to reflect that
they were not eligible to claim the pre-
mium tax credit, and pay any additional
tax liability due.
Taxpayers should be aware that this
Notice does not extend the time to file a
return. To obtain an automatic extension
of time to file, a taxpayer should file Form
4868, Application for Automatic Exten-
sion of Time to File U.S. Individual In-
come Tax Return, on or before April 15,
2015. Requesting an extension of the time
April 27, 2015Bulletin No. 2015–17
928

to file a return does not extend the time to
pay any tax liability due. Additionally,
section 6601 imposes interest on amounts
of tax not paid by the due date, determined
without regard to an extension of time for
payment. Taxpayers will be required to
pay interest on the balance due from the
original deadline to pay, which is April
15, 2015, even if they qualify for penalty
relief under this Notice.
Procedure for Claiming Penalty Relief
Requesting relief from the failure to pay
penalty under section 6651(a)(2) and
6651(a)(3)
Generally, the Service automatically
assesses the section 6651(a)(2) penalty
and the section 6651(a)(3) penalty against
taxpayers and sends a notice demanding
payment. When responding to such a no-
tice, taxpayers should submit a letter to
the address listed in the notice that con-
tains the statement: “I am eligible for the
relief granted under Notice 2015–30 be-
cause I received an incorrect or delayed
Form 1095–A.”
Requesting relief from the estimated tax
penalty under section 6654(a)
To request a waiver of the section
6654(a) penalty as provided in this Notice,
taxpayers should check box A in Part II of
Form 2210, complete page 1 of the form,
and include the form with their return,
along with the statement: “Received an
incorrect or delayed Form 1095–A.” Tax-
payers do not need to attach documenta-
tion from the Marketplace, explain the
circumstances under which they received
an incorrect or delayed Form 1095–A, or
complete any page other than page 1 of
the Form 2210. Taxpayers also do not
need to figure the amount of penalty for
the penalty to be waived.
Requesting relief from the accuracy-
related penalty under section 6662
Generally, the Service will not impose
the section 6662(a) penalty against tax-
payers who are eligible for the relief in
this Notice. However, if a section 6662(a)
penalty is proposed on examination on a
liability resulting from the receipt of an
incorrect or delayed Form 1095–A, the
taxpayer should notify the examiner of his
or her eligibility for this relief. Also, if a
taxpayer receives a letter asserting the
section 6662 penalty on a liability result-
ing from the receipt of an incorrect or
delayed Form 1095–A, the taxpayer
should submit a letter to the address listed
in the letter that contains the statement: “I
am eligible for the relief granted under
Notice 2015–30 because I received an in-
correct or delayed Form 1095–A.”
Contact Information
The principal author of this Notice is
David Bergman of the Office of Associate
Chief Counsel (Procedure & Administra-
tion). For further information regarding
this Notice, call 202-317-3400 (not a toll-
free number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2015–31
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I). The rates in this
noticereflecttheapplicationof
§ 430(h)(2)(C)(iv), which was added by
the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP–
21) and amended by section 2003 of the
Highway and Transportation Funding Act
of 2014, Public Law 113–159 (HATFA).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods. To
the extent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the
applicable percentage of the 25-year aver-
age segment rates for the period ending
September 30 of the year preceding the
calendar year in which the plan year be-
gins. However, an election may be made
under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from March
2015 data is in Table I at the end of this
notice. The spot first, second, and third
segment rates for the month of March
2015 are, respectively, 1.38, 3.58, and
4.50.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i) through
(iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) by the applicable per-
centage of the corresponding 25-year av-
erage segment rates. Section 2003(a) of
HATFA amended the applicable percent-
ages under § 430(h)(2)(C)(iv). This
change generally applies to plan years be-
ginning on or after January 1, 2013. How-
ever, pursuant to section 2003(e)(2) of
HATFA, a plan sponsor can elect not to
have the amendments made to the appli-
cable percentages by section 2003 of
HATFA apply to any plan year beginning
in 2013. These elections can be made ei-
ther for all purposes or, alternatively, for
purposes of determining the adjusted
funding target attainment percentage un-
der § 436. The25-year average segment
rates for plan years beginning in 2012,
2013, 2014 and 2015 were published in
Notice 2012–55, 2012–36 I.R.B. 332,
Notice 2013–11, 2013–11 I.R.B. 610,
Notice 2013–58, 2013– 40 I.R.B. 294,
Bulletin No. 2015–17April 27, 2015
929

and Notice 2014 –50, 2014 – 40 I.R.B.
590, respectively.
For plan years beginning in years
2012 through 2017, pursuant to the
changes made by HATFA, the applica-
ble minimum percentage is 90% and the
applicablemaximumpercentageis
110%. These applicable percentages are
referred to as HATFA applicable per-
centages. As described in the preceding
paragraph, a special election is available
for any plan year beginning in 2013
under which this change made by
HATFA can be disregarded for all pur-
poses or for limited purposes. To the
extent such an election is made, the ap-
plicable minimum percentage for a plan
year beginning in 2013 is 85% and the
applicable maximum percentage for that
plan year is 115%. These applicable per-
centages are referred to as MAP–21 ap-
plicable percentages.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for April
2015 without adjustment for the 25-year
average segment rate limits are as follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
April 20151.264.075.13
Basedon§430(h)(2)(C)(iv)as
amended by section 2003 of HATFA, the
24-month averages applicable for April
2015 adjusted for the HATFA applicable
percentages of the corresponding 25-year
average segment rates, are as follows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates, Based on the HATFA
Applicable Percentage of
25-Year Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2014April20154.996.326.99
2015April20154.726.116.81
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount for
the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I)provides
that the interest rate used to calculate cur-
rent liability for this purpose must be no
more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year
Treasury securities during the four-year
period ending on the last day before the
beginning of the plan year. Notice 88 –73,
1988 –2 C.B. 383, provides guidelines for
determining the weighted average interest
rate. The rate of interest on 30-year Trea-
sury securities for March 2015 is 2.63
percent. The Service determined this rate
as the average of the daily determinations
of yield on the 30-year Treasury bond
maturing in February 2045. For plan years
beginning in the month shown below, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rate used to calculate
current liability are as follows:
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
April20153.242.913.40
April 27, 2015Bulletin No. 2015–17
930

MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for March 2015 are
as follows:
First
Segment
Second
Segment
Third
Segment
1.383.584.50
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-8719 or Tony
Montanaro at 202-317-8698 (not toll-free
numbers).
Bulletin No. 2015–17April 27, 2015
931

Table I
Monthly Yield Curve for March 2015
Derived from March 2015 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.50.3220.54.2240.54.5360.54.6480.54.70
1.00.6321.04.2341.04.5361.04.6481.04.70
1.50.9121.54.2541.54.5461.54.6481.54.70
2.01.1622.04.2642.04.5462.04.6582.04.70
2.51.3722.54.2742.54.5562.54.6582.54.70
3.01.5623.04.2843.04.5563.04.6583.04.70
3.51.7223.54.2943.54.5563.54.6583.54.70
4.01.8824.04.3144.04.5664.04.6584.04.70
4.52.0324.54.3244.54.5664.54.6584.54.70
5.02.1725.04.3345.04.5665.04.6685.04.71
5.52.3225.54.3445.54.5765.54.6685.54.71
6.02.4526.04.3546.04.5766.04.6686.04.71
6.52.5926.54.3646.54.5766.54.6686.54.71
7.02.7227.04.3647.04.5867.04.6687.04.71
7.52.8527.54.3747.54.5867.54.6687.54.71
8.02.9728.04.3848.04.5868.04.6788.04.71
8.53.0828.54.3948.54.5968.54.6788.54.71
9.03.1829.04.4049.04.5969.04.6789.04.71
9.53.2829.54.4149.54.5969.54.6789.54.71
10.03.3830.04.4150.04.5970.04.6790.04.71
10.53.4630.54.4250.54.6070.54.6790.54.71
11.03.5431.04.4351.04.6071.04.6791.04.72
11.53.6131.54.4451.54.6071.54.6891.54.72
12.03.6832.04.4452.04.6072.04.6892.04.72
12.53.7432.54.4552.54.6172.54.6892.54.72
13.03.7933.04.4653.04.6173.04.6893.04.72
13.53.8433.54.4653.54.6173.54.6893.54.72
14.03.8934.04.4754.04.6174.04.6894.04.72
14.53.9334.54.4754.54.6274.54.6894.54.72
15.03.9735.04.4855.04.6275.04.6895.04.72
15.54.0035.54.4855.54.6275.54.6995.54.72
16.04.0336.04.4956.04.6276.04.6996.04.72
16.54.0636.54.4956.54.6376.54.6996.54.72
17.04.0837.04.5057.04.6377.04.6997.04.72
17.54.1137.54.5057.54.6377.54.6997.54.73
18.04.1338.04.5158.04.6378.04.6998.04.73
18.54.1538.54.5158.54.6378.54.6998.54.73
19.04.1739.04.5259.04.6479.04.6999.04.73
19.54.1839.54.5259.54.6479.54.6999.54.73
20.04.2040.04.5360.04.6480.04.70100.04.73
April 27, 2015Bulletin No. 2015–17
932

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2015–17April 27, 2015
i

Numerical Finding List
1
Bulletin 2015–1 through 2015–17
Announcements:
2015-1, 2015-11 I.R.B.758
2015-2, 2015-3 I.R.B.324
2015-3, 2015-3 I.R.B.328
2015-4, 2015-5 I.R.B.565
2015-5, 2015-7 I.R.B.602
2015-6, 2015-8 I.R.B.685
2015-7, 2015-13 I.R.B.823
2015-8, 2015-9 I.R.B.698
2015-10, 2015-11 I.R.B.758
2015-11, 2015-15 I.R.B.883
2015-12, 2015-12 I.R.B.770
2015-13, 2015-15 I.R.B.908
Proposed Regulations:
REG-109187-11, 2015-2 I.R.B.277
REG-132751-14, 2015-2 I.R.B.279
REG-145878-14, 2015-2 I.R.B.290
REG-153656-3, 2015-5 I.R.B.566
REG-102648-15, 2015-10 I.R.B.745
REG-136018-13, 2015-11 I.R.B.759
REG-143416-14, 2015-11 I.R.B.757
REG-100400-14, 2015-12 I.R.B.779
REG-132253-11, 2015-12 I.R.B.771
REG-143040-11, 2015-13 I.R.B.827
REG-133489-13, 2015-16 I.R.B.926
Notices:
2015-1, 2015-2 I.R.B.249
2015-2, 2015-4 I.R.B.334
2015-3, 2015-6 I.R.B.583
2015-4, 2015-5 I.R.B.407
2015-5, 2015-5 I.R.B.408
2015-6, 2015-5 I.R.B.412
2015-7, 2015-6 I.R.B.585
2015-8, 2015-6 I.R.B.589
2015-9, 2015-6 I.R.B.590
2015-11, 2015-8 I.R.B.618
2015-15, 2015-9 I.R.B.687
2015-12, 2015-8 I.R.B.700
2015-13, 2015-10 I.R.B.722
2015-14, 2015-10 I.R.B.722
2015-16, 2015-10 I.R.B.732
2015-17, 2015-14 I.R.B.845
2015-19, 2015-9 I.R.B.690
2015-20, 2015-11 I.R.B.754
2015-18, 2015-12 I.R.B.765
2015-21, 2015-12 I.R.B.765
2015-22, 2015-12 I.R.B.768
2015-23, 2015-12 I.R.B.769
2015-24, 2015-13 I.R.B.811
2015-25, 2015-13 I.R.B.814
2015-26, 2015-13 I.R.B.814
2015-27, 2015-13 I.R.B.816
Notices:—Continued
2015-28, 2015-14 I.R.B.848
2015-29, 2015-15 I.R.B.873
2015-30, 2015-17 I.R.B.928
2015-31, 2015-17 I.R.B.929
Revenue Procedures:
2015-1, 2015-1 I.R.B.1
2015-2, 2015-1 I.R.B.105
2015-3, 2015-1 I.R.B.129
2015-4, 2015-1 I.R.B.144
2015-5, 2015-1 I.R.B.186
2015-6, 2015-1 I.R.B.194
2015-7, 2015-1 I.R.B.231
2015-8, 2015-1 I.R.B.235
2015-9, 2015-2 I.R.B.249
2015-10, 2015-2 I.R.B.261
2015-12, 2015-2 I.R.B.265
2015-13, 2015-5 I.R.B.419
2015-14, 2015-5 I.R.B.450
2015-15, 2015-5 I.R.B.564
2015-16, 2015-7 I.R.B.596
2015-17, 2015-7 I.R.B.599
2015-18, 2015-8 I.R.B.642
2015-19, 2015-8 I.R.B.678
2015-20, 2015-9 I.R.B.694
2015-21, 2015-13 I.R.B.817
2015-22, 2015-11 I.R.B.754
2015-23, 2015-13 I.R.B.820
2015-24, 2015-13 I.R.B.822
2015-25, 2015-14 I.R.B.848
2015-26, 2015-15 I.R.B.875
2015-27, 2015-16 I.R.B.914
2015-28, 2015-16 I.R.B.920
2015-29, 2015-15 I.R.B.882
Revenue Rulings:
2015-1, 2015-4 I.R.B.331
2015-2, 2015-3 I.R.B.321
2015-3, 2015-6 I.R.B.580
2015-4, 2015-10 I.R.B.743
2015-5, 2015-13 I.R.B.788
2015-6, 2015-13 I.R.B.801
2015-7, 2015-14 I.R.B.849
Treasury Decisions:
9707, 2015-2 I.R.B.247
9708, 2015-5 I.R.B.337
9709, 2015-7 I.R.B.593
9710, 2015-8 I.R.B.603
9711, 2015-11 I.R.B.748
9712, 2015-11 I.R.B.750
9713, 2015-13 I.R.B.802
9714, 2015-14 I.R.B.831
9715, 2015-15 I.R.B.851
9716, 2015-15 I.R.B.863
9717, 2015-16 I.R.B.910
9718, 2015-15 I.R.B.866
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin
2014 –52, dated December 28, 2014.
April 27, 2015Bulletin No. 2015–17
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–1 through 2015–17
Announcements:
2010-3
Amplified by
Ann. 2015-3, 2015-3 I.R.B.328
Revenue Procedures:
2014-01
Superseded by
Rev. Proc. 2015-01, 2015-01 I.R.B.1
2014-02
Superseded by
Rev. Proc. 2015-02, 2015-01 I.R.B.105
2014-03
Superseded by
Rev. Proc. 2015-03, 2015-01 I.R.B.129
2014-04
Superseded by
Rev. Proc. 2015-04, 2015-01 I.R.B.144
2014-05
Superseded by
Rev. Proc. 2015-05, 2015-01 I.R.B.186
2014-06
Superseded by
Rev. Proc. 2015-06, 2015-01 I.R.B.194
2014-07
Superseded by
Rev. Proc. 2015-07, 2015-01 I.R.B.231
2014-08
Superseded by
Rev. Proc. 2015-08, 2015-01 I.R.B.235
2014-10
Superseded by
Rev. Proc. 2015-10, 2015-2 I.R.B.261
2003-63
Superseded by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
Revenue Procedures:—Continued
2011-14
Amplified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
2011-14
Clarified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
1997-27
Clarified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
1997-27
Modified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
2012-11
Superseded by
Rev. Proc. 2015-17, 2015-7 I.R.B.599
2015-9
Modified by
Rev. Proc. 2015-17, 2015-7 I.R.B.599
2015-14
Modified by
Rev. Proc. 2015-20, 2015-9 I.R.B.694
2013-22
Modified by
Rev. Proc. 2015-22, 2015-11 I.R.B.754
2015-8
Modified by
Rev. Proc. 2015-22, 2015-11 I.R.B.754
2014-59
Modified by
Rev. Proc. 2015-24, 2015-13 I.R.B.822
2002-43
Modified by
Rev. Proc. 2015-26, 2015-15 I.R.B.875
2002-43
Obsoleted by
Rev. Proc. 2015-26, 2015-15 I.R.B.875
Revenue Rulings:
92-19
Supplemented by
Rev. Rul. 2015-02, 2015-3 I.R.B.321
Notices:
2013-01
Modified by
Notice 2015-20, 2015-11 I.R.B.754
Notices:—Continued
2013-01
Superseded by
Notice 2015-20, 2015-11 I.R.B.754
2014-24
Obsoleted by
Notice 2015-29, 2015-15 I.R.B.882
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin 2014 –52, dated December 28,
2014.
Bulletin No. 2015–17April 27, 2015
iii

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available atwww.irs.gov/irb/.
We Welcome Comments About the Internal Revenue Bulletin
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
(www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.
Internal Revenue Service
Washington, DC 20224
Official Business
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