Internal Revenue Bulletin 2019-15 (PDF rendition): IRS Revenue Procedures

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

# INTERNAL REVENUE BULLETIN

IRS

Bulletin No. 2019-15
April 08, 2019

## 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 2019-03, page 965.

This Announcement is issued pursuant to § 521(b) of Pub. L.
106-170, the Ticket to Work and Work Incentives Improve-
ment Act of 1999, which requires the Secretary of the Trea-
sury to report annually to the public concerning advance pric-
ing agreements (APAs) and the Advance Pricing and Mutual
Agreement Program (APMA Program), formerly known as the
Advance Pricing Agreement Program (APA Program). This
twentieth report describes the experience, structure, and ac-
tivities of the APMA Program during calendar year 2018.

### Notice 2019-25, page 942.

This notice modifies and supersedes the guidance in Notice
2019-11, which announced the waiver of the addition to tax
for underpayment of estimated income tax for certain individ-
uals for the 2018 tax year. This notice increases the availability
of the waiver of the addition to tax by expanding the waiver to
individuals whose total withholding and estimated tax payments
equal or exceed eighty percent of the tax shown on the return
for the 2018 taxable year. The notice updates procedures for
requesting the waiver of the addition to tax. Additionally, the
notice provides procedures for taxpayers who paid additions to
tax for underpayment of estimated tax for tax year 2018 but
who qualify for relief under this notice to request a refund of the
addition to tax.

### Rev. Proc. 2019-14, page 948.

This procedure provides issuers of qualified mortgage bonds
(QMBs) and qualified mortgage certificates (MCCs) with aver-
age area purchase price safe harbors for statistical areas in
the United States and with a nationwide average purchase
price for residences in the United States for purposes of QMB
rules under section 143 of the Code and the MCC rules under
section 25.

## EMPLOYEE PLANS

### Notice 2019-26, page 943.

This notice sets forth the updated mortality improvement rates
and static mortality tables that are used for purposes of deter-
mining minimum funding requirements under § 430(h)(3) for
2020 and minimum present value under § 417(e)(3) for distri-
butions with annuity starting dates that occur during stability
periods beginning in the 2020 calendar year.

## INCOME TAX

### Notice 2019-23, page 941.

ITG is updating the appendix to Notice 2013-1. The appendix
lists the tribes that have resolved claims against the United
States regarding trust assets. The list includes seven new
tribes.

### Notice 2019-25, page 942.

This notice modifies and supersedes the guidance in Notice
2019-11, which announced the waiver of the addition to tax
for underpayment of estimated income tax for certain individ-
uals for the 2018 tax year. This notice increases the availability
of the waiver of the addition to tax by expanding the waiver to
individuals whose total withholding and estimated tax payments
equal or exceed eighty percent of the tax shown on the return
for the 2018 taxable year. The notice updates procedures for
requesting the waiver of the addition to tax. Additionally, the
notice provides procedures for taxpayers who paid additions to
tax for underpayment of estimated tax for tax year 2018 but
who qualify for relief under this notice to request a refund of the
addition to tax.

Finding Lists begin on page ii.

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## 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.

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### Part III. Administrative, Procedural, and Miscellaneous

Per Capita Payments from
Proceeds of Settlements of
Indian Tribal Trust Cases

#### Notice 2019-23

##### BACKGROUND

Notice 2013-1, 2013-3 IRB 281, pro-
vides guidance on the federal tax treat-
ment of per capita payments that members
of Indian tribes receive from proceeds of
certain settlements of tribal trust cases be-
tween the United States and those Indian
tribes. Additional tribes have settled tribal
trust cases against the United States since
publication of Notice 2013-1. This notice
provides an updated Appendix that re-
flects the additional settlement agree-
ments.

#### EFFECT ON OTHER DOCUMENTS

Notice 2013-1 Appendix is modified
and superseded.

#### FURTHER INFORMATION

For further information regarding this
notice, please contact Carmen Zucker at
phone number (212) 436-1441 (not a toll-
free number).

##### Appendix

###### Tribes That Have Entered into Settlement Agreements of Tribal Trust Cases

. 1. Assiniboine and Sioux Tribes of
the Fort Peck Reservation

. 2. Bad River Band of Lake Superior
Chippewa Indians

. 3. Blackfeet Tribe of the Blackfeet
Indian Reservation

. 4. Bois Forte Band of Chippewa

· 5. Cachil Dehe Band of Wintun In-
dians of the Colusa Rancheria

. 6. Chippewa Cree Tribe of the Rocky
Boy's Reservation

. 7. Coeur d'Alene Tribe

· 8. Confederated Salish and Kootenai
Tribes

· 9. Confederated Tribes of Siletz In-
dians

· 10. Confederated Tribes of the
Colville Reservation

. 11. Confederated Tribes of the Gos-
hute Reservation

. 12. Crow Creek Sioux Tribe

· 13. Eastern Shawnee Tribe of Okla-
homa

· 14. Hualapai Indian Tribe

· 15. Iowa Tribe of Kansas and Ne-
braska

. 16. Kaibab Band of Paiute Indians of
Arizona

· 17. Kickapoo Tribe of Kansas

. 18. Lac Courte Oreilles Band of Lake
Superior Chippewa Indians

· 19. Lac du Flambeau Band of Lake
Superior Chippewa Indians

. 20. Leech Lake Band of Ojibwe

. 21. Lower Brule Sioux Tribe

. 22. Makah Indian Tribe of the Makah

Reservation

· 23. Mescalero Apache Tribe

· 24. Minnesota Chippewa Tribe

· 25. Nez Perce Tribe

. 26. Nooksack Indian Tribe

· 27. Northern Cheyenne Tribe of In-
dians

· 28. Omaha Tribe of Nebraska

. 29. Passamaquoddy Tribe of Maine

· 30. Pawnee Nation

· 31. Prairie Band of Potawatomi Na-
tion

· 32. Pueblo of Zia

. 33. Quechan Tribe of the Fort Yuma
Reservation

. 34. Red Cliff Band of Lake Superior
Chippewa Indians

· 35. Rincon Luiseño Band of Indians

. 36. Rosebud Sioux Tribe

. 37. Round Valley Indian Tribes

· 38. Salt River Pima-Maricopa Indian
Community

· 39. Santee Sioux Tribe of Nebraska

. 40. Sault Ste. Marie Tribe

. 41. Shoshone-Bannock Tribes of the
Fort Hall Reservation

· 42. Soboba Band of Luiseno Indians

· 43. Spirit Lake Dakotah Nation

. 44. Spokane Tribe of Indians

. 45. Standing Rock Sioux Tribe

. 46. Stillaguamish Tribe of Indians

. 47. Summit Lake Paiute Tribe

· 48. Swinomish Indian Tribal Com-
munity

· 49. Te-Moak Tribe of Western Sho-
shone Indians

· 50. Tohono O'odham Nation

. 51. Tulalip Tribes

. 52. Tule River Indian Tribe

· 53. Ute Indian Tribe of the Uintah
and Ouray Reservation

· 54. Ute Mountain Ute Tribe

· 55. Winnebago Tribe of Nebraska

· 56. Qawalangin Tribe of Unalaska

· 57. Tlingit & Haida Tribes of Alaska

. 58. Northwestern Band of Shoshone
Indians

. 59. Hoopa Valley Tribe

· 60. Ak-Chin Indian Community

· 61. Oglala Sioux Tribe

. 62. Yoruk Tribe

. 63. Cheyenne River Sioux Tribe

. 64. Paiute-Shoshone Indians of the
Bishop Community of the Bishop Colony

· 65. Seminole Nation of Oklahoma

· 66. Otoe-Missouria Tribe of Okla-
homa

· 67. Samish Indian Nation

· 68. Tonkawa Tribe of Indians of
Oklahoma

· 69. Yakama Nation

· 70. Miami Tribe of Oklahoma

. 71. Shoshone Indian Tribe and the
Northern Arapahoe Indian Tribe of the
Wind River Reservation

· 72. Pueblo of Laguna

· 73. Navajo Nation

· 74. Caddo Nation of Oklahoma

· 75. Gros Ventre and Assiniboine
Tribes of the Fort Belknap Indian Reser-
vation

· 76. Chickasaw Nation

. 77. Choctaw Nation

. 78. Klamath Tribe

· 79. Skokomish Indian Tribe

· 80. Quinault Indian Nation

. 81. Southern Ute Indian Tribe

· 82. Confederated Tribes of the Uma-

tilla Indian Reservation

· 83. White Earth Nation

· 84. Kickapoo Tribe of Oklahoma

. 85. Sisseton Wahpeton Oyate of the
Lake Traverse Reservation

. 86. Grand Traverse Band of Ottawa
and Chippewa Indians

· 87. Muscogee (Creek) Nation of
Oklahoma

. 88. Gila River Indian Community

. 89. Aleut Community of St. Paul
Island

. 90. San Carlos Apache Tribe

. 91. Comanche Nation

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. 92. Colorado River Indian Tribes

. 93. Jicarilla Apache Nation

· 94. Pueblo of Acoma

· 95. Penobscot Indian Nation

· 96. Seminole Tribe of Florida

. 97. San Luis Rey Indian Water Au-
thority

· 98. Pechanga Band of Luiseno Mis-
sion Indians

· 99. Cheyenne-Arapaho Tribes

. 100. Delaware Tribe of Indians

· 101. Kaw Nation of Oklahoma

· 102. Native Village of Atka

· 103. Ute Tribe of Uintah and Ouray
Reservation

### Relief from Addition to Tax for Underpayment of Estimated Income Tax by an Individual

#### Notice 2019-25

##### SECTION 1. PURPOSE

This notice modifies and supersedes
the guidance in Notice 2019-11, which
provided for the waiver of the addition
to tax under section 6654 of the Internal
Revenue Code (Code) for the underpay-
ment of estimated income tax for certain
individuals who would otherwise be re-
quired to make tax year 2018 estimated
income tax payments on or before Jan-
uary 15, 2019.

This notice makes the following changes to
the guidance provided in Notice 2019-11:

a. It increases the availability of the
waiver of the addition to tax under
section 6654 by expanding the waiver
to certain individuals whose total
withholding and estimated tax pay-
ments equal or exceed eighty percent
(reduced from eighty-five percent
threshold provided in Notice 2019-
11) of the tax shown on the return for
the 2018 taxable year.

b. It updates procedures for requesting
the waiver of the addition to tax
under section 6654 for failure to
make estimated income tax pay-
ments for the 2018 taxable year oth-
erwise required to be made on or
before January 15, 2019.

c. It provides procedures for taxpayers
who paid additions to tax under sec-

tion 6654 for tax year 2018 but who
qualify for relief under Notice
2019-25 to request a refund of the
addition to tax.

This notice provides a waiver of the
addition to tax under section 6654 of the
Code for the underpayment of estimated
income tax for certain individuals who
would otherwise be required to make tax
year 2018 estimated income tax payments
on or before January 15, 2019. This
waiver is limited to individuals whose to-
tal withholding and estimated tax pay-
ments equal or exceed eighty percent of
the tax shown on the return for the 2018
taxable year.

## SECTION 2. BACKGROUND

Generally, the Code requires taxpayers
to pay federal income taxes as they earn
income. To the extent these taxes are not
withheld, a taxpayer must pay estimated
income tax on a quarterly basis.

Section 6654 provides that, in the case
of an individual, estimated income tax is
required to be paid in four installments
and the amount of any required install-
ment is 25 percent of the required annual
payment. Generally, under section 6654(d)
(1)(B), the required annual payment is the
lesser of (i) 90 percent of the tax shown on
the return for the taxable year or (ii) 100
percent of the tax shown on the taxpayer's
return for the preceding taxable year (110
percent if the individual's adjusted gross
income on the previous year's return ex-
ceeded $150,000), so long as the preceding
taxable year was a full twelve months long.
However, an individual may not use the tax
for the preceding taxable year to calculate
the required estimated tax payments if
that taxable year was not 12 months
long, or the individual did not file a
return for that preceding taxable year.
Under section 6654(d)(2), the amount of
the required installment is the annualized
income installment for those taxpayers who
establish that such amount is lower than 25
percent of the required annual payment de-
termined under section 6654(d)(1). Pursuant
to section 6654(g), income taxes withheld
from wages are deemed to be paid evenly
throughout the tax year, unless the taxpayer
establishes the dates on which the amounts
were actually withheld. Section 6654(a) im-
poses an addition to tax for failure to make

a sufficient and timely payment of estimated
income tax.

An individual taxpayer will not be
subject to the addition to tax if an ex-
ception or waiver provision applies. Un-
der section 6654(e)(1), an addition to
tax will not be imposed on an individual
taxpayer if the taxpayer owes less than
$1,000 in tax, after subtracting tax withheld
on wages. Under section 6654(e)(2), an in-
dividual will not be subject to an addition to
tax if the individual did not have any tax
liability for the previous year, the preceding
taxable year was 12 months, and the indi-
vidual was a citizen or resident of the United
States throughout the preceding tax year. In
addition, the Secretary is authorized by sec-
tion 6654(e)(3)(A) to waive the addition to
tax if he "determines that by reason of ca-
sualty, disaster, or other unusual circum-
stances the imposition of such addition to
tax would be against equity and good con-
science."

The December 22, 2017, enactment of
Public Law 115-97, commonly referred to
as the "Tax Cuts and Jobs Act" or "TCJA,"
included a broad array of changes to the
Code affecting millions of individual tax-
payers. On February 28, 2018, the Internal
Revenue Service (IRS) released an updated
Withholding Calculator on IRS.gov and a
new version of Form W-4 to help individ-
ual taxpayers determine their appropriate
amount of 2018 tax withholding. Despite
the release of the updated Withholding Cal-
culator and new Form W-4, some individ-
ual taxpayers may have been unable to ac-
curately calculate the amount of their
required estimated income tax payments for
the 2018 tax year. Accordingly, the IRS is
providing additional relief to individual tax-
payers by waiving certain penalties if the
requirements set forth in section 3 of this
notice are satisfied.

## SECTION 3. WAIVER FOR UNDERPAYMENT OF ESTIMATED INCOME TAX

Pursuant to the authority in section
6654(e)(3)(A), the addition to tax under
section 6654 for failure to make estimated
income tax payments for the 2018 taxable
year otherwise required to be made on or
before January 15, 2019, is waived for any
individual whose total withholding and
estimated tax payments made on or before
January 15, 2019, equal or exceed eighty

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percent of the tax shown on that individ-
ual's return for the 2018 taxable year.

To request this waiver, an individual
must file Form 2210, Underpayment of
Estimated Tax by Individuals, Estates,
and Trusts, with his or her 2018 income
tax return. The form can be filed with a
return filed electronically or on paper.
Taxpayers should complete Part I of Form
2210 and the worksheet included in the
form instructions to determine if the
waiver in this notice applies. If the waiver
applies, check the waiver box (Part II,
Box A), include the statement "80%
Waiver" next to Box A, and file page 1 of
Form 2210 with the return. Forms, in-
structions, and other tax assistance are
available on IRS.gov. The IRS toll-free
number for general tax questions is 1-800-
829-1040. This waiver is in addition to
any other exception that section 6654 pro-
vides to the underpayment of estimated
income tax.

## SECTION 4. CLAIMING REFUND OF AMOUNTS PAID AS ADDITIONS TO TAX

Taxpayers who qualify for relief un-
der Notice 2019-25 may have already
paid additions to tax under section 6654
for tax year 2018. If the waiver under
this notice applies to a taxpayer and the
taxpayer has already paid additions to
tax under section 6654 for the 2018 tax
year, to claim a refund of the additions
to tax under section 6654 for the 2018
tax year, the taxpayer should file Form
843, Claim for Refund and Request for
Abatement. Taxpayers should complete
the form and include the statement
"80% Waiver of estimated tax penalty"
on Line 7.

## SECTION 5. IF WAIVER DOES NOT APPLY

If neither the waiver provided by this
notice nor any other exception applies to
an individual taxpayer, the amount of
any addition to tax is determined by
applying the underpayment interest rate
established under section 6621 of the
Code to each required installment of
estimated tax that was underpaid for the
period that the installment is underpaid.
The period of the underpayment runs
from the due date for the installment to

the earlier of April 15, 2019, or the date
on which the underpayment is paid. This
notice has no effect on determining the
amount of each required installment for
an individual whose total withholding
and estimated tax payments do not equal
or exceed eighty percent of the tax
shown on that individual's return for the
2018 taxable year.

## SECTION 6. EFFECT ON OTHER DOCUMENTS

Notice 2019-11 is modified and super-
seded.

## SECTION 7. CONTACT INFORMATION

The principal author of this notice is
Michael A. Franklin of the Office of the
Associate Chief Counsel (Procedure and
Administration). For further information,
please contact Mr. Franklin at (202) 317-
6844 (not a toll-free number).

## Updated Mortality Improvement Rates and Static Mortality Tables for Defined Benefit Pension Plans for 2020

## Notice 2019-26 PURPOSE

This notice specifies updated mortality
improvement rates and static mortality ta-
bles to be used for defined benefit pension
plans under § 430(h)(3)(A) of the Internal
Revenue Code (Code) and section 303(h)
(3)(A) of the Employee Retirement Income
Security Act of 1974, Pub. L. No. 93-406,
as amended (ERISA). These updated mor-
tality improvement rates and static tables,
which are being issued pursuant to the reg-
ulations under § 430(h)(3)(A), apply for
purposes of calculating the funding target
and other items for valuation dates occur-
ring during the 2020 calendar year.

This notice also includes a modified
unisex version of the mortality tables for
use in determining minimum present
value under § 417(e)(3) of the Code and
section 205(g)(3) of ERISA for distribu-
tions with annuity starting dates that occur

during stability periods beginning in the
2020 calendar year.

## BACKGROUND

Section 412 of the Code provides min-
imum funding requirements that generally
apply for defined benefit plans. Section
412(a)(2) provides that § 430 specifies the
minimum funding requirements that gen-
erally apply to defined benefit plans that
are not multiemployer plans. Section
430(a) defines the minimum required con-
tribution for such a plan by reference to
the plan's funding target for the plan year.
Under § 430(d)(1), a plan's funding target
for a plan year generally is the present
value of all benefits accrued or earned
under the plan as of the first day of that
plan year.

Section 430(h)(3) provides rules regard-
ing the mortality tables that generally are
used under § 430. Under § 430(h)(3)(A),
except as provided in § 430(h)(3)(C) or (D),
the Secretary is to prescribe by regulation
mortality tables to be used in determining
any present value or making any computa-
tion under § 430. Those tables are to be
based on the actual experience of pension
plans and projected trends in that experi-
ence. Section 430(h)(3)(B) requires the Sec-
retary to revise any table in effect under
§ 430(h)(3)(A) at least every 10 years to
reflect the actual experience of pension
plans and projected trends in that experi-
ence.

Section 430(h)(3)(C) provides that, upon
request by a plan sponsor and approval by
the Secretary, substitute mortality tables that
meet the applicable requirements may be
used in lieu of the standard mortality tables
provided under § 430(h)(3)(A). Section
430(h)(3)(D) provides for the use of sepa-
rate mortality tables with respect to certain
individuals who are entitled to benefits on
account of disability.

### Mortality Tables for Purposes of § 430

Section 1.430(h)(3)-1 provides rules
regarding the mortality tables used under
§ 430(h)(3)(A) for plan years beginning
on or after January 1, 2018. The mortality
tables used under § 430(h)(3)(A) are
based on the tables in the RP-2014 Mor-

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tality Tables Report,1 adjusted for mortal-
ity improvement. Section 1.430(h)(3)-
1(d) sets forth base mortality tables with a
base year of 2006.

Section 1.430(h)(3)-1(a) permits plan
sponsors to apply the projection of mor-
tality improvement in either of two ways:
through use of static tables that are up-
dated annually to reflect expected im-
provements in mortality, or through use of
generational tables. Section 1.430(h)(3)-
1(a)(2)(i)(C) provides that, for valuation
dates occurring in years after 2018, up-
dated mortality improvement rates that
take into account new data for mortality
improvement trends of the general popu-
lation, along with static mortality tables
that reflect those updated mortality im-
provement rates, will be provided through
guidance published in the Internal Reve-
nue Bulletin. Notice 2018-2, 2018-2
I.R.B. 281, provides mortality improve-
ment rates and static mortality tables that
apply for valuation dates occurring during
2019.

Section 1.430(h)(3)-2 provides rules
for the use of substitute mortality tables
that are based on the mortality experience
of the plan. Pursuant to § 1.430(h)(3)-
2(c)(3)(ii), substitute mortality tables are
developed using the mortality improve-
ment rates used under § 1.430(h)(3)-1.

### Application of These Tables for Other Funding Rules

Section 1.431(c)(6)-1 provides that
the same mortality assumptions that ap-
ply for purposes of § 430(h)(3)(A) and
§ 1.430(h)(3)-1(a)(2) are used to deter-
mine a multiemployer plan's current li-
ability for purposes of applying the full-
funding rules of § 431(c)(6). For this
purpose, a multiemployer plan may ap-
ply either the static mortality tables or
the generational mortality tables (as
updated pursuant to § 1.430(h)(3)-
1(a)(2)(i)(C) and (a)(3)).

Section 433 provides the minimum fund-
ing standards for CSEC plans, which are
described in § 414(y). Section 433(h)(3)
(B)(i) provides that the Secretary may by
regulation prescribe mortality tables to be
used in determining current liability for
purposes of § 433(c)(7)(C). Section

1.433(h)(3)-1(a) provides that the mor-
tality tables described in § 430(h)(3)(A)
are to be used to determine current lia-
bility under § 433(c)(7)(C).

### Application of Mortality Tables for Minimum Present Value Requirements under § 417(e)(3)

Section 417(e)(3) generally provides
that the present value of certain acceler-
ated forms of benefit under a qualified
pension plan (including single-sum distri-
butions) must not be less than the present
value of the accrued benefit using appli-
cable interest rates and the applicable
mortality table. Section 417(e)(3)(B) de-
fines the term "applicable mortality table"
as the mortality table specified for the plan
year under § 430(h)(3)(A) (without regard
to § 430(h)(3)(C) or (D)), modified as
appropriate by the Secretary.

Rev. Rul. 2007-67, 2007-2 CB 1047,
provides that, except as otherwise stated
in future guidance, the applicable mortal-
ity table under § 417(e)(3) is a static mor-
tality table set forth in published guidance
that is developed based on a fixed blend of
50 percent of the static male combined
mortality rates and 50 percent of the static
female combined mortality rates used un-
der § 1.430(h)(3)-1. Rev. Rul. 2007-67
also provides that the applicable mortality
table for a calendar year applies to distri-
butions with annuity starting dates that
occur during stability periods that begin
during that calendar year.

## MORTALITY IMPROVEMENT RATES FOR 2020

The mortality improvement rates for
valuation dates occurring during 2020 are
the mortality improvement rates in the
Mortality Improvement Scale MP-2018
Report (issued by the Retirement Plans
Experience Committee (RPEC) of the So-
ciety of Actuaries and available at https://
www.soa.org/Files/resources/experience-
studies/2018/mortality-improvement-scale-
mp-2018.pdf).

## STATIC MORTALITY TABLES FOR 2020

The static mortality tables that apply
under § 430(h)(3)(A) for valuation dates

occurring during 2020 are set forth in the
appendix to this notice. The mortality
rates in these tables have been developed
from the methodology and base mortality
rates set forth in § 1.430(h)(3)-1(c) and
(d) using the mortality improvement rates
specified in the previous section of this
notice.

The static mortality table that applies
under § 417(e)(3) for distributions with
annuity starting dates occurring during sta-
bility periods beginning in 2020 is set forth
in the appendix to this notice in the column
labeled "Unisex." The mortality rates in this
table are derived from the mortality tables
specified under § 430(h)(3)(A) for 2020 in
accordance with the procedures set forth in
Rev. Rul. 2007-67.

## COMMENTS REQUESTED

In section 4 of the Mortality Improve-
ment Scale MP-2018 Report, RPEC dis-
cusses an alternative model for develop-
ing mortality improvement rates from
historical U.S. population mortality rates.
The alternative model is identical to the
current model except that a different ap-
proach is used to graduate (that is,
smooth) the historical mortality rates. In
particular, the finite difference operators
used in the smoothness components of the
Whittaker-Henderson objective function
are of order 2, rather than order 3. RPEC's
back-testing of the alternative model
showed improved stability of mortality
improvement rates from year to year;
however, the alternative approach did not
generate as tight of a fit of the graduated
mortality improvement rates to the un-
graduated historical mortality improve-
ment rates. The Department of the Trea-
sury (Treasury Department) and the
Internal Revenue Service (IRS) request
comments about whether or not to use this
alternative model to determine the mortal-
ity improvement rates that apply under
§ 430(h)(3)(A) for future years.

Additionally, in the preamble to
§ 1.430(h)(3)-1, the Treasury Depart-
ment and the IRS stated that the mortal-
ity improvement rates used under
§ 1.430(h)(3)-1 may not be updated for
a year if changes to the mortality im-
provement rates for the year would be

1The RP-2014 Mortality Tables Report, as revised November 2014, is available at https://www.soa.org/Files/Research/Exp-Study/research-2014-rp-report.pdf.

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minimal. The Treasury Department and
the IRS request comments about
whether future updates to the mortality
improvement rates used under
§ 1.430(h)(3)-1 should be delayed until
the cumulative changes to expected
mortality improvement rates reach a
particular magnitude. Commenters re-
questing that changes to mortality im-
provement rates be made less frequently

than annually should specify how the
magnitude of cumulative changes
should be measured and what level of
cumulative changes should support an
update of mortality improvement rates.

### Drafting Information

The principal authors of this notice are
Arslan Malik and Linda S. F. Marshall of
the Office of the Associate Chief Counsel

(Employee Benefits, Exempt Organiza-
tions, and Employment Taxes). For fur-
ther information regarding this notice,
contact Arslan Malik or Linda Marshall at
(202) 317-6700 (not a toll-free number).

# APPENDIX

Mortality Tables for 2020 Valuation Dates Occurring During 2020 and Distributions Subject to § 417(e)(3) with Annuity Starting Dates During Stability Periods Beginning in 2020

Age

Male 2020 Non-Annuitant Table

Male 2020 Annuitant Table

Male 2020 Optional Combined Table for Small Plans

Female 2020 Non-Annuitant Table

Female 2020 Annuitant Table

Female 2020 Optional Combined Table for Small Plans

Unisex 2020 Table for Distributions Subject to § 417(e)(3)

0

0.003251

0.003251

0.003251

0.002883

0.002883

0.002883

0.003067

1

0.000191

0.000191

0.000191

0.000180

0.000180

0.000180

0.000186

2

0.000130

0.000130

0.000130

0.000119

0.000119

0.000119

0.000125

3

0.000109

0.000109

0.000109

0.000090

0.000090

0.000090

0.000100

4

0.000086

0.000086

0.000086

0.000068

0.000068

0.000068

0.000077

5

0.000076

0.000076

0.000076

0.000062

0.000062

0.000062

0.000069

6

0.000069

0.000069

0.000069

0.000058

0.000058

0.000058

0.000064

7

0.000061

0.000061

0.000061

0.000054

0.000054

0.000054

0.000058

8

0.000052

0.000052

0.000052

0.000050

0.000050

0.000050

0.000051

9

0.000043

0.000043

0.000043

0.000047

0.000047

0.000047

0.000045

10

0.000036

0.000036

0.000036

0.000045

0.000045

0.000045

0.000041

11

0.000039

0.000039

0.000039

0.000046

0.000046

0.000046

0.000043

12

0.000059

0.000059

0.000059

0.000054

0.000054

0.000054

0.000057

13

0.000078

0.000078

0.000078

0.000062

0.000062

0.000062

0.000070

14

0.000097

0.000097

0.000097

0.000069

0.000069

0.000069

0.000083

15

0.000117

0.000117

0.000117

0.000076

0.000076

0.000076

0.000097

16

0.000137

0.000137

0.000137

0.000082

0.000082

0.000082

0.000110

17

0.000158

0.000158

0.000158

0.000088

0.000088

0.000088

0.000123

18

0.000181

0.000181

0.000181

0.000093

0.000093

0.000093

0.000137

19

0.000205

0.000205

0.000205

0.000097

0.000097

0.000097

0.000151

20

0.000228

0.000228

0.000228

0.000098

0.000098

0.000098

0.000163

21

0.000259

0.000259

0.000259

0.000101

0.000101

0.000101

0.000180

22

0.000289

0.000289

0.000289

0.000103

0.000103

0.000103

0.000196

23

0.000311

0.000311

0.000311

0.000107

0.000107

0.000107

0.000209

24

0.000325

0.000325

0.000325

0.000112

0.000112

0.000112

0.000219

25

0.000315

0.000315

0.000315

0.000116

0.000116

0.000116

0.000216

26

0.000310

0.000310

0.000310

0.000121

0.000121

0.000121

0.000216

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Age

Male

Male

Male 2020 Optional

Female

Female

Female 2020 Optional Combined Table for Small Plans

Unisex 2020

2020

2020

Combined

2020

2020

Table for Distributions Subject to § 417(e)(3)

Non-Annuitant Table

Annuitant Table

Table for Small Plans

Non-Annuitant Table

Annuitant Table

27

0.000311

0.000311

0.000311

0.000127

0.000127

0.000127

0.000219

28

0.000318

0.000318

0.000318

0.000134

0.000134

0.000134

0.000226

29

0.000330

0.000330

0.000330

0.000143

0.000143

0.000143

0.000237

30

0.000345

0.000345

0.000345

0.000154

0.000154

0.000154

0.000250

31

0.000364

0.000364

0.000364

0.000167

0.000167

0.000167

0.000266

32

0.000385

0.000385

0.000385

0.000182

0.000182

0.000182

0.000284

33

0.000407

0.000407

0.000407

0.000198

0.000198

0.000198

0.000303

34

0.000426

0.000426

0.000426

0.000215

0.000215

0.000215

0.000321

35

0.000444

0.000444

0.000444

0.000231

0.000231

0.000231

0.000338

36

0.000459

0.000459

0.000459

0.000246

0.000246

0.000246

0.000353

37

0.000475

0.000475

0.000475

0.000265

0.000265

0.000265

0.000370

38

0.000492

0.000492

0.000492

0.000284

0.000284

0.000284

0.000388

39

0.000513

0.000513

0.000513

0.000305

0.000305

0.000305

0.000409

40

0.000538

0.000538

0.000538

0.000327

0.000327

0.000327

0.000433

41

0.000566

0.000572

0.000566

0.000351

0.000349

0.000351

0.000459

42

0.000600

0.000653

0.000600

0.000378

0.000400

0.000378

0.000489

43

0.000644

0.000779

0.000646

0.000410

0.000479

0.000410

0.000528

44

0.000697

0.000948

0.000702

0.000445

0.000587

0.000445

0.000574

45

0.000760

0.001162

0.000769

0.000485

0.000724

0.000487

0.000628

46

0.000834

0.001421

0.000850

0.000532

0.000892

0.000538

0.000694

47

0.000919

0.001728

0.000945

0.000585

0.001096

0.000598

0.000772

48

0.001015

0.002089

0.001054

0.000643

0.001340

0.000666

0.000860

49

0.001123

0.002511

0.001179

0.000707

0.001627

0.000746

0.000963

50

0.001244

0.003000

0.001324

0.000780

0.001960

0.000839

0.001082

51

0.001380

0.003233

0.001472

0.000862

0.002077

0.000933

0.001203

52

0.001534

0.003486

0.001668

0.000955

0.002220

0.001049

0.001359

53

0.001695

0.003733

0.001889

0.001060

0.002393

0.001186

0.001538

54

0.001876

0.003997

0.002149

0.001178

0.002595

0.001346

0.001748

55

0.002082

0.004282

0.002537

0.001307

0.002830

0.001596

0.002067

56

0.002322

0.004598

0.003044

0.001449

0.003096

0.001920

0.002482

57

0.002605

0.004953

0.003493

0.001602

0.003398

0.002213

0.002853

58

0.002941

0.005351

0.004002

0.001764

0.003732

0.002527

0.003265

59

0.003337

0.005798

0.004564

0.001936

0.004100

0.002880

0.003722

60

0.003799

0.006297

0.005206

0.002117

0.004500

0.003298

0.004252

61

0.004335

0.006852

0.005930

0.002309

0.004933

0.003832

0.004881

62

0.004946

0.007463

0.006734

0.002511

0.005398

0.004416

0.005575

63

0.005631

0.008127

0.007603

0.002730

0.005897

0.005112

0.006358

64

0.006400

0.008857

0.008453

0.002967

0.006437

0.005758

0.007106

65

0.007255

0.009653

0.009373

0.003225

0.007022

0.006472

0.007923

66

0.008103

0.010523

0.010359

0.003578

0.007672

0.007311

0.008835

67

0.009031

0.011481

0.011361

0.003970

0.008397

0.008117

0.009739

68

0.010052

0.012541

0.012451

0.004414

0.009214

0.008985

0.010718

69

0.011189

0.013736

0.013663

0.004913

0.010133

0.009938

0.011801

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Age

Male

Male

Male 2020 Optional

Female

Female

Female 2020 Optional

Unisex 2020

2020

2020

Combined

2020

2020 Annuitant Table

Combined Table for Small Plans

Table for Distributions Subject to § 417(e)(3)

Non-Annuitant Table

Annuitant Table

Table for Small Plans

Non-Annuitant Table

70

0.012455

0.015076

0.015008

0.005479

0.011174

0.010981

0.012995

71

0.013866

0.016580

0.016516

0.006118

0.012348

0.012158

0.014337

72

0.015449

0.018278

0.018219

0.006842

0.013674

0.013489

0.015854

73

0.017224

0.020197

0.020143

0.007667

0.015175

0.014997

0.017570

74

0.019218

0.022366

0.022317

0.008599

0.016865

0.016697

0.019507

75

0.021460

0.024826

0.024782

0.009664

0.018790

0.018635

0.021709

76

0.023964

0.027604

0.027566

0.010871

0.020973

0.020836

0.024201

77

0.026782

0.030769

0.030738

0.012254

0.023481

0.023366

0.027052

78

0.029919

0.034345

0.034322

0.013828

0.026356

0.026271

0.030297

79

0.033447

0.038433

0.038420

0.015621

0.029666

0.029618

0.034019

80

0.037375

0.043067

0.043067

0.017662

0.033484

0.033484

0.038276

81

0.039222

0.048107

0.048107

0.019406

0.037669

0.037669

0.042888

82

0.042758

0.053854

0.053854

0.022765

0.042446

0.042446

0.048150

83

0.048014

0.060386

0.060386

0.027776

0.047923

0.047923

0.054155

84

0.055042

0.067838

0.067838

0.034475

0.054174

0.054174

0.061006

85

0.063877

0.076254

0.076254

0.042895

0.061258

0.061258

0.068756

86

0.074636

0.085831

0.085831

0.053064

0.069265

0.069265

0.077548

87

0.087303

0.096623

0.096623

0.065024

0.078287

0.078287

0.087455

88

0.101920

0.108696

0.108696

0.078818

0.088357

0.088357

0.098527

89

0.118510

0.122153

0.122153

0.094441

0.099512

0.099512

0.110833

90

0.137096

0.137096

0.137096

0.111838

0.111838

0.111838

0.124467

91

0.152921

0.152921

0.152921

0.125228

0.125228

0.125228

0.139075

92

0.169221

0.169221

0.169221

0.139416

0.139416

0.139416

0.154319

93

0.185598

0.185598

0.185598

0.154186

0.154186

0.154186

0.169892

94

0.202075

0.202075

0.202075

0.169467

0.169467

0.169467

0.185771

95

0.218344

0.218344

0.218344

0.185284

0.185284

0.185284

0.201814

96

0.236813

0.236813

0.236813

0.202710

0.202710

0.202710

0.219762

97

0.255790

0.255790

0.255790

0.220973

0.220973

0.220973

0.238382

98

0.275485

0.275485

0.275485

0.239976

0.239976

0.239976

0.257731

99

0.295730

0.295730

0.295730

0.259633

0.259633

0.259633

0.277682

100

0.316409

0.316409

0.316409

0.279942

0.279942

0.279942

0.298176

101

0.337278

0.337278

0.337278

0.300567

0.300567

0.300567

0.318923

102

0.357950

0.357950

0.357950

0.321243

0.321243

0.321243

0.339597

103

0.378379

0.378379

0.378379

0.341842

0.341842

0.341842

0.360111

104

0.398131

0.398131

0.398131

0.362350

0.362350

0.362350

0.380241

105

0.416748

0.416748

0.416748

0.382270

0.382270

0.382270

0.399509

106

0.434806

0.434806

0.434806

0.401814

0.401814

0.401814

0.418310

107

0.451779

0.451779

0.451779

0.420312

0.420312

0.420312

0.436046

108

0.467748

0.467748

0.467748

0.437663

0.437663

0.437663

0.452706

109

0.482853

0.482853

0.482853

0.454199

0.454199

0.454199

0.468526

110

0.496822

0.496822

0.496822

0.469667

0.469667

0.469667

0.483245

111

0.501965

0.501965

0.501965

0.483967

0.483967

0.483967

0.492966

112

0.501458

0.501458

0.501458

0.497408

0.497408

0.497408

0.499433

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Age

Male 2020 Non-Annuitant Table

Male 2020 Annuitant Table

Male 2020 Optional Combined Table for Small Plans

Female 2020 Non-Annuitant Table

Female 2020 Annuitant Table

Female 2020 Optional Combined Table for Small Plans

Unisex 2020 Table for Distributions Subject to § 417(e)(3)

113

0.501004

0.501004

0.501004

0.502965

0.502965

0.502965

0.501985

114

0.500451

0.500451

0.500451

0.501253

0.501253

0.501253

0.500852

115

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

116

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

117

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

118

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

119

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

0.500000

120

1.000000

1.000000

1.000000

1.000000

1.000000

1.000000

1.000000

## 26 CFR 6a.103A-2: Qualified mortgage bond Rev. Proc. 2019-14 SECTION 1. PURPOSE

This revenue procedure provides issu-
ers of qualified mortgage bonds, as de-
fined in section 143(a) of the Internal
Revenue Code (Code), and issuers of
mortgage credit certificates, as defined
in section 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 statistical areas
in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Is-
lands, American Samoa, the Virgin Is-
lands, and Guam.

## SECTION 2. BACKGROUND

.01 Section 103(a) provides that, ex-
cept as provided in section 103(b), gross
income does not include interest on any
state or local bond. Section 103(b)(1) pro-
vides that section 103(a) shall not apply to
any private activity bond that is not a
"qualified bond" within the meaning of
section 141. Section 141(e) provides, in
part, that the term "qualified bond" means
any private activity bond if such bond (1)
is a qualified mortgage bond under section
143, (2) meets the volume cap require-
ments under section 146, and (3) meets
the applicable requirements under section
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
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 owner-occupied residenc-
es; (ii) the issue meets the requirements of
subsections (c), (d), (e), (f), (g), (h), (i),
and (m)(7) of section 143; (iii) the issue
does not meet the private business tests of
paragraphs (1) and (2) of section 141(b);
and (iv) with respect to amounts received
more than 10 years after the date of issu-
ance, repayments of $250,000 or more of
principal on mortgage financing provided
by the issue are used by 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.

### Average Area Purchase Price

.03 Section 143(e)(1) provides that an
issue of bonds meets the purchase price
requirements of section 143(e) if the ac-
quisition 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 section 143(j)),
section 143(e)(1) shall be applied by sub-
stituting 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 single-family
residences (in the statistical area in which
the residence is located) that were pur-
chased during the most recent 12-month
period for which sufficient statistical in-
formation is available. Under sections
143(e)(3) and (4), respectively, separate
determinations are to be made for new and
existing residences, and for two-, three-,
and four-family residences.

.05 Section 143(e)(2) provides that the
determination of the average area pur-
chase price for a statistical area shall be
made as of the date on which the commit-
ment 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, sec-
tion 143(k)(2)(D) provides that the Secre-
tary may designate as a county any area
that is the equivalent of a county. Section
6a.103A-1(b)(4)(i) of the Income Tax
Regulations (issued under section 103A of
the Internal Revenue Code of 1954, the
predecessor of section 143 of the Code)

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provides that the term "State" includes a
possession of the United States and the
District of Columbia.

.07 Section 6a.103A-2(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.103A-2(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 is-
suer has more accurate and comprehen-
sive data for the statistical area.

### Qualified Mortgage Credit Certificate Program

.08 Section 25(c) permits a state or
political subdivision to establish a quali-
fied mortgage credit certificate program. In
general, a qualified mortgage credit certifi-
cate 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 un-
der section 146, and in their place, issues
mortgage credit certificates to taxpayers in
connection with the acquisition of their prin-
cipal residences. Section 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 inter-
est paid or accrued 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
residences acquired in connection with the
issuance of mortgage credit certificates must
meet the purchase price requirements of sec-
tion 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, section
25(c)(2)(A)(iii)(IV) provides that holders
of mortgage credit certificates must meet
the income requirement of section 143(f).
Generally, under sections 143(f)(1) and
25(c)(2)(A)(iii)(IV), the income require-
ment is met only if all owner-financing

under a qualified mortgage bond and all
mortgage credit certificates issued under a
qualified mortgage credit certificate pro-
gram are provided to mortgagors whose
family income is 115 percent or less of the
applicable median family income. Section
143(f)(5), however, generally provides for
an upward adjustment to the percentage
limitation in high housing cost areas. High
housing cost areas are defined in section
143(f)(5)(C) as any statistical area for
which the housing cost/income ratio is
greater than 1.2.

.10 Under section 143(f)(5)(D), the
housing cost/income ratio with respect to
any statistical area is determined by divid-
ing (a) the applicable housing price ratio
for such area by (b) the ratio that the area
median 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. 2018-28, 2018-20 I.R.B. 592.

.12 The nationwide average purchase
price limitation was last published in sec-
tion 4.02 of Rev. Proc. 2018-28. Guidance
with respect to the United States and area
median gross income figures that are to be
used in computing the housing cost/income
ratio described in section 143(f)(5) was last
published in Rev. Proc. 2018-33, 2018-22
I.R.B. 734.

.13 This revenue procedure uses FHA
loan limits for a given statistical area to
calculate 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 con-
forming loan limits established by the
Federal Home Loan Mortgage Corpora-

tion. In particular, FHA sets an area's loan
limit at 95 percent of the median home
sales price for the area, subject to certain
floors and caps measured against con-
forming 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 differences
between average and median purchase
prices. Because FHA loan limits do not
differentiate between new and existing
residences, this revenue procedure contains
a single average area purchase price safe
harbor for both new and existing residences
in a statistical area. The Treasury Depart-
ment and the Internal Revenue Service
(IRS) have determined that FHA loan limits
provide a reasonable basis for determining
average area purchase price safe harbors. If
the Treasury Department and the IRS be-
come aware of other sources of average
purchase price data, including data that dif-
ferentiate between new and existing resi-
dences, consideration will be given as to
whether such data provide a more accurate
method for calculating average area pur-
chase 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 14, 2018. FHA
loan limits are available for statistical ar-
eas in each state, the District of Columbia,
Puerto Rico, the Northern Mariana Is-
lands, American Samoa, the Virgin Is-
lands, and Guam. See section 3.03 of this
revenue procedure with respect to FHA
loan limits revised after December 14,
2018.

.16 OMB Bulletin No. 03-04, dated
and effective June 6, 2003, revised the
definitions of the nation's metropolitan ar-
eas and recognized 49 new metropolitan
statistical areas. The OMB bulletin no lon-
ger includes primary metropolitan statisti-
cal 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 Sa-
moa, the Virgin Islands, and Guam are set

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forth in section 4.01 of this revenue pro-
cedure. Average area purchase price safe
harbors are provided for single-family and
two to four-family residences. For each
type of residence, section 4.01 of this rev-
enue procedure contains a single safe harbor
that may be used for both new and existing
residences. Issuers of qualified mortgage
bonds and issuers of mortgage credit certif-
icates may rely on these safe harbors to
satisfy the requirements of sections 143(e)
and (f). Section 4.01 of this revenue proce-
dure provides safe harbors for MSAs and
for certain counties and county equivalents.
If no purchase 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 limitation of
that MSA. If an MSA falls in more than one
state, the MSA is listed in section 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 14, 2018, 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 pro-
vided in the next sentence) a revised av-
erage area purchase price safe harbor for
the statistical area provided that the issuer
maintains records evidencing the revised
FHA loan limit. The revised average area
purchase price safe harbor for that statis-
tical area is computed by dividing the
revised FHA loan limit by .9999.

.04 If, pursuant to section 6a.103A-
2(f)(5)(i), an issuer uses more accurate

and comprehensive data to determine the
average area purchase price for a statisti-
cal area, the issuer must make separate
average area purchase price determina-
tions for new and existing residences.
Moreover, when computing the average
area purchase price for a statistical area
that is an MSA, as defined in OMB Bul-
letin No. 03-04, the issuer must make the
computation for the entire applicable
MSA. When computing the average area
purchase price for a statistical area that is
not an MSA, the issuer must make the
computation 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 section 143(e)
and (f) for bonds sold, and mortgage
credit certificates issued, not more than 30
months following the termination date of
the 12-month period used by the issuer to
compute the limitation.

### Nationwide Average Purchase Price

.06 Section 4.02 of this revenue proce-
dure sets forth a single nationwide aver-
age purchase price for purposes of com-
puting the housing cost/income ratio
under section 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 section 143(f)(5) regardless of
whether they are relying on the average
area purchase price safe harbors contained
in this revenue procedure or using more
accurate and comprehensive data to deter-
mine average area purchase prices for new
and existing residences for a statistical
area that are different 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. 2018-28, the is-
suer must use the nationwide average pur-
chase price set forth in section 4.02 of
Rev. Proc. 2018-28 in computing the
housing cost/income ratio under section
143(f)(5). Likewise, if, pursuant to section
6.04 of this revenue procedure, an issuer
relies on the nationwide average purchase
price published in Rev. Proc. 2018-28,
the issuer may not rely on the average area
purchase price safe harbors published in
this revenue procedure.

## SECTION 4. AVERAGE AREA AND NATIONWIDE AVERAGE PURCHASE PRICES

.01 Average area purchase prices for
single-family and two to four-family res-
idences 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.

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

HALE

AL

$331,206

$424,007

$512,509

$636,911

PICKENS

AL

$331,206

$424,007

$512,509

$636,911

TUSCALOOSA

AL

$331,206

$424,007

$512,509

$636,911

ALEUTIANS WEST

AK

$385,256

$493,208

$596,160

$740,862

ANCHORAGE MUNIC

AK

$401,357

$513,809

$621,060

$771,863

JUNEAU CITY AND

AK

$455,408

$583,010

$704,712

$875,765

KETCHIKAN GATEW

AK

$369,156

$472,558

$571,260

$709,912

KODIAK ISLAND B

AK

$407,107

$521,159

$629,961

$782,913

MATANUSKA-SUSIT

AK

$401,357

$513,809

$621,060

$771,863

NOME CENSUS ARE

AK

$391,007

$500,558

$605,060

$751,913

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

NORTH SLOPE BOR

AK

$332,356

$425,457

$514,309

$639,161

PETERSBURG CENS

AK

$332,356

$425,457

$514,309

$639,161

SITKA CITY AND

AK

$486,458

$622,760

$752,763

$935,516

SKAGWAY MUNICIP

AK

$415,157

$531,459

$642,411

$798,363

WRANGELL CITY A

AK

$332,356

$425,457

$514,309

$639,161

YAKUTAT CITY AN

AK

$420,907

$538,809

$651,311

$809,464

COCONINO

AZ

$362,256

$463,758

$560,559

$696,662

ALAMEDA

CA

$726,537

$930,316

$1,124,494

$1,397,423

ALPINE

CA

$463,458

$593,310

$717,162

$891,265

AMADOR

CA

$350,756

$449,008

$542,759

$674,511

CALAVERAS

CA

$373,756

$478,458

$578,360

$718,762

CONTRA COSTA

CA

$726,537

$930,316

$1,124,494

$1,397,423

EL DORADO

CA

$552,009

$706,662

$854,214

$1,061,568

HUMBOLDT

CA

$333,506

$426,957

$516,059

$641,361

INYO

CA

$369,156

$472,558

$571,260

$709,912

LOS ANGELES

CA

$726,537

$930,316

$1,124,494

$1,397,423

MARIN

CA

$726,537

$930,316

$1,124,494

$1,397,423

MARIPOSA

CA

$322,005

$412,207

$498,258

$619,260

MENDOCINO

CA

$409,407

$524,109

$633,511

$787,313

MONO

CA

$529,009

$677,211

$818,614

$1,017,317

MONTEREY

CA

$652,061

$834,764

$1,009,017

$1,253,971

NAPA

CA

$726,537

$930,316

$1,124,494

$1,397,423

NEVADA

CA

$486,458

$622,760

$752,763

$935,516

ORANGE

CA

$726,537

$930,316

$1,124,494

$1,397,423

PLACER

CA

$552,009

$706,662

$854,214

$1,061,568

PLUMAS

CA

$336,956

$431,357

$521,409

$648,011

RIVERSIDE

CA

$431,257

$552,059

$667,361

$829,364

SACRAMENTO

CA

$552,009

$706,662

$854,214

$1,061,568

SAN BENITO

CA

$726,537

$930,316

$1,124,494

$1,397,423

SAN BERNARDINO

CA

$431,257

$552,059

$667,361

$829,364

SAN DIEGO

CA

$690,012

$883,315

$1,067,768

$1,326,972

SAN FRANCISCO

CA

$726,537

$930,316

$1,124,494

$1,397,423

SAN JOAQUIN

CA

$425,507

$544,709

$658,461

$818,264

SAN LUIS OBISPO

CA

$667,011

$853,914

$1,032,167

$1,282,722

SAN MATEO

CA

$726,537

$930,316

$1,124,494

$1,397,423

SANTA BARBARA

CA

$653,211

$836,214

$1,010,817

$1,256,171

SANTA CLARA

CA

$726,537

$930,316

$1,124,494

$1,397,423

SANTA CRUZ

CA

$726,537

$930,316

$1,124,494

$1,397,423

SOLANO

CA

$494,508

$633,061

$765,213

$950,966

SONOMA

CA

$704,962

$902,465

$1,090,868

$1,355,723

STANISLAUS

CA

$350,756

$449,008

$542,759

$674,511

SUTTER

CA

$324,305

$415,157

$501,808

$623,660

TUOLUMNE

CA

$331,206

$424,007

$512,509

$636,911

VENTURA

CA

$713,012

$912,765

$1,103,369

$1,371,173

YOLO

CA

$552,009

$706,662

$854,214

$1,061,568

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

YUBA

CA

$324,305

$415,157

$501,808

$623,660

ADAMS

CO

$561,209

$718,462

$868,415

$1,079,268

ARAPAHOE

CO

$561,209

$718,462

$868,415

$1,079,268

BOULDER

CO

$626,761

$802,363

$969,866

$1,205,320

BROOMFIELD

CO

$561,209

$718,462

$868,415

$1,079,268

CHAFFEE

CO

$333,506

$426,957

$516,059

$641,361

CLEAR CREEK

CO

$561,209

$718,462

$868,415

$1,079,268

DENVER

CO

$561,209

$718,462

$868,415

$1,079,268

DOUGLAS

CO

$561,209

$718,462

$868,415

$1,079,268

EAGLE

CO

$726,537

$930,316

$1,124,494

$1,397,423

EL PASO

CO

$339,256

$434,307

$524,959

$652,411

ELBERT

CO

$561,209

$718,462

$868,415

$1,079,268

GARFIELD

CO

$726,537

$930,316

$1,124,494

$1,397,423

GILPIN

CO

$561,209

$718,462

$868,415

$1,079,268

GRAND

CO

$402,507

$515,259

$622,860

$774,063

GUNNISON

CO

$357,656

$457,858

$553,459

$687,812

HINSDALE

CO

$427,807

$547,659

$662,011

$822,714

JEFFERSON

CO

$561,209

$718,462

$868,415

$1,079,268

LA PLATA

CO

$419,757

$537,359

$649,561

$807,214

LARIMER

CO

$437,007

$559,459

$676,211

$840,414

OURAY

CO

$425,507

$544,709

$658,461

$818,264

PARK

CO

$561,209

$718,462

$868,415

$1,079,268

PITKIN

CO

$726,537

$930,316

$1,124,494

$1,397,423

ROUTT

CO

$634,811

$812,664

$982,316

$1,220,820

SAN MIGUEL

CO

$726,537

$930,316

$1,124,494

$1,397,423

SUMMIT

CO

$722,212

$924,566

$1,117,569

$1,388,873

TELLER

CO

$339,256

$434,307

$524,959

$652,411

WELD

CO

$385,256

$493,208

$596,160

$740,862

FAIRFIELD

CT

$601,460

$769,963

$930,716

$1,156,669

HARTFORD

CT

$353,056

$451,958

$546,309

$678,961

LITCHFIELD

CT

$357,656

$457,858

$553,459

$687,812

MIDDLESEX

CT

$353,056

$451,958

$546,309

$678,961

TOLLAND

CT

$353,056

$451,958

$546,309

$678,961

WINDHAM

CT

$327,755

$419,557

$507,159

$630,311

DISTRICT OF COL

DC

$726,537

$930,316

$1,124,494

$1,397,423

NEW CASTLE

DE

$402,507

$515,259

$622,860

$774,063

SUSSEX

DE

$336,956

$431,357

$521,409

$648,011

BAKER

FL

$358,806

$459,308

$555,209

$690,012

BROWARD

FL

$356,506

$456,358

$551,659

$685,561

CLAY

FL

$358,806

$459,308

$555,209

$690,012

COLLIER

FL

$450,808

$577,110

$697,612

$866,965

DUVAL

FL

$358,806

$459,308

$555,209

$690,012

MANATEE

FL

$320,855

$410,757

$496,508

$617,010

MARTIN

FL

$327,755

$419,557

$507,159

$630,311

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

MIAMI-DADE

FL

$356,506

$456,358

$551,659

$685,561

MONROE

FL

$529,009

$677,211

$818,614

$1,017,317

NASSAU

FL

$358,806

$459,308

$555,209

$690,012

OKALOOSA

FL

$370,306

$474,058

$573,010

$712,112

PALM BEACH

FL

$356,506

$456,358

$551,659

$685,561

SARASOTA

FL

$320,855

$410,757

$496,508

$617,010

ST. JOHNS

FL

$358,806

$459,308

$555,209

$690,012

ST. LUCIE

FL

$327,755

$419,557

$507,159

$630,311

WALTON

FL

$370,306

$474,058

$573,010

$712,112

BARROW

GA

$379,506

$485,808

$587,260

$729,812

BARTOW

GA

$379,506

$485,808

$587,260

$729,812

BUTTS

GA

$379,506

$485,808

$587,260

$729,812

CARROLL

GA

$379,506

$485,808

$587,260

$729,812

CHEROKEE

GA

$379,506

$485,808

$587,260

$729,812

CLARKE

GA

$341,556

$437,257

$528,509

$656,811

CLAYTON

GA

$379,506

$485,808

$587,260

$729,812

COBB

GA

$379,506

$485,808

$587,260

$729,812

COWETA

GA

$379,506

$485,808

$587,260

$729,812

DAWSON

GA

$379,506

$485,808

$587,260

$729,812

DEKALB

GA

$379,506

$485,808

$587,260

$729,812

DOUGLAS

GA

$379,506

$485,808

$587,260

$729,812

FAYETTE

GA

$379,506

$485,808

$587,260

$729,812

FORSYTH

GA

$379,506

$485,808

$587,260

$729,812

FULTON

GA

$379,506

$485,808

$587,260

$729,812

GREENE

GA

$515,209

$659,561

$797,263

$990,817

GWINNETT

GA

$379,506

$485,808

$587,260

$729,812

HARALSON

GA

$379,506

$485,808

$587,260

$729,812

HEARD

GA

$379,506

$485,808

$587,260

$729,812

HENRY

GA

$379,506

$485,808

$587,260

$729,812

JASPER

GA

$379,506

$485,808

$587,260

$729,812

LAMAR

GA

$379,506

$485,808

$587,260

$729,812

MADISON

GA

$341,556

$437,257

$528,509

$656,811

MERIWETHER

GA

$379,506

$485,808

$587,260

$729,812

MORGAN

GA

$379,506

$485,808

$587,260

$729,812

NEWTON

GA

$379,506

$485,808

$587,260

$729,812

OCONEE

GA

$341,556

$437,257

$528,509

$656,811

OGLETHORPE

GA

$341,556

$437,257

$528,509

$656,811

PAULDING

GA

$379,506

$485,808

$587,260

$729,812

PICKENS

GA

$379,506

$485,808

$587,260

$729,812

PIKE

GA

$379,506

$485,808

$587,260

$729,812

ROCKDALE

GA

$379,506

$485,808

$587,260

$729,812

SPALDING

GA

$379,506

$485,808

$587,260

$729,812

WALTON

GA

$379,506

$485,808

$587,260

$729,812

HAWAII

HI

$387,556

$496,108

$599,710

$745,312

HONOLULU

HI

$721,062

$923,065

$1,115,819

$1,386,673

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

KALAWAO

HI

$678,511

$868,615

$1,049,968

$1,304,872

KAUAI

HI

$713,012

$912,765

$1,103,369

$1,371,173

MAUI

HI

$678,511

$868,615

$1,049,968

$1,304,872

ADA

ID

$331,206

$424,007

$512,509

$636,911

BLAINE

ID

$646,311

$827,414

$1,000,117

$1,242,921

BOISE

ID

$331,206

$424,007

$512,509

$636,911

CAMAS

ID

$646,311

$827,414

$1,000,117

$1,242,921

CANYON

ID

$331,206

$424,007

$512,509

$636,911

GEM

ID

$331,206

$424,007

$512,509

$636,911

LINCOLN

ID

$646,311

$827,414

$1,000,117

$1,242,921

OWYHEE

ID

$331,206

$424,007

$512,509

$636,911

TETON

ID

$726,537

$930,316

$1,124,494

$1,397,423

BOONE

IL

$339,256

$434,307

$524,959

$652,411

COOK

IL

$368,006

$471,108

$569,460

$707,712

DEKALB

IL

$368,006

$471,108

$569,460

$707,712

DUPAGE

IL

$368,006

$471,108

$569,460

$707,712

GRUNDY

IL

$368,006

$471,108

$569,460

$707,712

KANE

IL

$368,006

$471,108

$569,460

$707,712

KENDALL

IL

$368,006

$471,108

$569,460

$707,712

LAKE

IL

$368,006

$471,108

$569,460

$707,712

MCHENRY

IL

$368,006

$471,108

$569,460

$707,712

WILL

IL

$368,006

$471,108

$569,460

$707,712

WINNEBAGO

IL

$339,256

$434,307

$524,959

$652,411

BOONE

IN

$343,856

$440,207

$532,109

$661,261

BROWN

IN

$343,856

$440,207

$532,109

$661,261

CLARK

IN

$316,255

$404,857

$489,358

$608,160

FLOYD

IN

$316,255

$404,857

$489,358

$608,160

HAMILTON

IN

$343,856

$440,207

$532,109

$661,261

HANCOCK

IN

$343,856

$440,207

$532,109

$661,261

HARRISON

IN

$316,255

$404,857

$489,358

$608,160

HENDRICKS

IN

$343,856

$440,207

$532,109

$661,261

JASPER

IN

$368,006

$471,108

$569,460

$707,712

JOHNSON

IN

$343,856

$440,207

$532,109

$661,261

LAKE

IN

$368,006

$471,108

$569,460

$707,712

MADISON

IN

$343,856

$440,207

$532,109

$661,261

MARION

IN

$343,856

$440,207

$532,109

$661,261

MORGAN

IN

$343,856

$440,207

$532,109

$661,261

NEWTON

IN

$368,006

$471,108

$569,460

$707,712

PORTER

IN

$368,006

$471,108

$569,460

$707,712

PUTNAM

IN

$343,856

$440,207

$532,109

$661,261

SCOTT

IN

$316,255

$404,857

$489,358

$608,160

SHELBY

IN

$343,856

$440,207

$532,109

$661,261

WASHINGTON

IN

$316,255

$404,857

$489,358

$608,160

JOHNSON

KS

$336,956

$431,357

$521,409

$648,011

LEAVENWORTH

KS

$336,956

$431,357

$521,409

$648,011

<!-- PageFooter="April 08, 2019" -->

<!-- PageFooter="Bulletin No. 2019-15" -->
<!-- PageBreak -->

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

LINN

KS

$336,956

$431,357

$521,409

$648,011

MIAMI

KS

$336,956

$431,357

$521,409

$648,011

WYANDOTTE

KS

$336,956

$431,357

$521,409

$648,011

BULLITT

KY

$316,255

$404,857

$489,358

$608,160

HENRY

KY

$316,255

$404,857

$489,358

$608,160

JEFFERSON

KY

$316,255

$404,857

$489,358

$608,160

OLDHAM

KY

$316,255

$404,857

$489,358

$608,160

SHELBY

KY

$316,255

$404,857

$489,358

$608,160

SPENCER

KY

$316,255

$404,857

$489,358

$608,160

TRIMBLE

KY

$316,255

$404,857

$489,358

$608,160

BARNSTABLE

MA

$458,858

$587,410

$710,062

$882,415

BRISTOL

MA

$454,258

$581,510

$702,912

$873,565

DUKES

MA

$726,537

$930,316

$1,124,494

$1,397,423

ESSEX

MA

$688,862

$881,865

$1,065,968

$1,324,772

HAMPDEN

MA

$318,555

$407,807

$492,958

$612,610

HAMPSHIRE

MA

$318,555

$407,807

$492,958

$612,610

MIDDLESEX

MA

$688,862

$881,865

$1,065,968

$1,324,772

NANTUCKET

MA

$726,537

$930,316

$1,124,494

$1,397,423

NORFOLK

MA

$688,862

$881,865

$1,065,968

$1,324,772

PLYMOUTH

MA

$688,862

$881,865

$1,065,968

$1,324,772

SUFFOLK

MA

$688,862

$881,865

$1,065,968

$1,324,772

WORCESTER

MA

$327,755

$419,557

$507,159

$630,311

ANNE ARUNDEL

MD

$517,509

$662,511

$800,813

$995,217

BALTIMORE

MD

$517,509

$662,511

$800,813

$995,217

BALTIMORE CITY

MD

$517,509

$662,511

$800,813

$995,217

CALVERT

MD

$726,537

$930,316

$1,124,494

$1,397,423

CARROLL

MD

$517,509

$662,511

$800,813

$995,217

CECIL

MD

$402,507

$515,259

$622,860

$774,063

CHARLES

MD

$726,537

$930,316

$1,124,494

$1,397,423

FREDERICK

MD

$726,537

$930,316

$1,124,494

$1,397,423

HARFORD

MD

$517,509

$662,511

$800,813

$995,217

HOWARD

MD

$517,509

$662,511

$800,813

$995,217

MONTGOMERY

MD

$726,537

$930,316

$1,124,494

$1,397,423

PRINCE GEORGE'S

MD

$726,537

$930,316

$1,124,494

$1,397,423

QUEEN ANNE'S

MD

$517,509

$662,511

$800,813

$995,217

SOMERSET

MD

$336,956

$431,357

$521,409

$648,011

ST. MARY'S

MD

$347,306

$444,607

$537,409

$667,911

TALBOT

MD

$382,956

$490,258

$592,610

$736,462

WICOMICO

MD

$336,956

$431,357

$521,409

$648,011

WORCESTER

MD

$336,956

$431,357

$521,409

$648,011

CUMBERLAND

ME

$351,906

$450,508

$544,559

$676,761

SAGADAHOC

ME

$351,906

$450,508

$544,559

$676,761

YORK

ME

$351,906

$450,508

$544,559

$676,761

BENZIE

MI

$316,255

$404,857

$489,358

$608,160

<!-- PageFooter="Bulletin No. 2019-15" -->

<!-- PageFooter="April 08, 2019" -->
<!-- PageBreak -->

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

GRAND TRAVERSE

MI

$316,255

$404,857

$489,358

$608,160

KALKASKA

MI

$316,255

$404,857

$489,358

$608,160

LEELANAU

MI

$316,255

$404,857

$489,358

$608,160

ANOKA

MN

$366,856

$469,608

$567,660

$705,512

CARVER

MN

$366,856

$469,608

$567,660

$705,512

CHISAGO

MN

$366,856

$469,608

$567,660

$705,512

DAKOTA

MN

$366,856

$469,608

$567,660

$705,512

HENNEPIN

MN

$366,856

$469,608

$567,660

$705,512

ISANTI

MN

$366,856

$469,608

$567,660

$705,512

LE SUEUR

MN

$366,856

$469,608

$567,660

$705,512

MILLE LACS

MN

$366,856

$469,608

$567,660

$705,512

RAMSEY

MN

$366,856

$469,608

$567,660

$705,512

SCOTT

MN

$366,856

$469,608

$567,660

$705,512

SHERBURNE

MN

$366,856

$469,608

$567,660

$705,512

SIBLEY

MN

$366,856

$469,608

$567,660

$705,512

WASHINGTON

MN

$366,856

$469,608

$567,660

$705,512

WRIGHT

MN

$366,856

$469,608

$567,660

$705,512

BATES

MO

$336,956

$431,357

$521,409

$648,011

CALDWELL

MO

$336,956

$431,357

$521,409

$648,011

CASS

MO

$336,956

$431,357

$521,409

$648,011

CLAY

MO

$336,956

$431,357

$521,409

$648,011

CLINTON

MO

$336,956

$431,357

$521,409

$648,011

JACKSON

MO

$336,956

$431,357

$521,409

$648,011

LAFAYETTE

MO

$336,956

$431,357

$521,409

$648,011

PLATTE

MO

$336,956

$431,357

$521,409

$648,011

RAY

MO

$336,956

$431,357

$521,409

$648,011

FLATHEAD

MT

$318,555

$407,807

$492,958

$612,610

GALLATIN

MT

$412,857

$528,509

$638,861

$793,963

JEFFERSON

MT

$316,255

$404,857

$489,358

$608,160

LEWIS AND CLARK

MT

$316,255

$404,857

$489,358

$608,160

MADISON

MT

$325,455

$416,607

$503,608

$625,860

MISSOULA

MT

$334,656

$428,407

$517,859

$643,561

CABARRUS

NC

$317,405

$406,307

$491,158

$610,410

CAMDEN

NC

$726,537

$930,316

$1,124,494

$1,397,423

CHATHAM

NC

$403,657

$516,759

$624,610

$776,263

CURRITUCK

NC

$458,858

$587,410

$710,062

$882,415

DARE

NC

$391,007

$500,558

$605,060

$751,913

DURHAM

NC

$403,657

$516,759

$624,610

$776,263

FRANKLIN

NC

$339,256

$434,307

$524,959

$652,411

GASTON

NC

$317,405

$406,307

$491,158

$610,410

GATES

NC

$458,858

$587,410

$710,062

$882,415

HYDE

NC

$483,008

$618,310

$747,413

$928,866

IREDELL

NC

$317,405

$406,307

$491,158

$610,410

JOHNSTON

NC

$339,256

$434,307

$524,959

$652,411

LINCOLN

NC

$317,405

$406,307

$491,158

$610,410

<!-- PageFooter="April 08, 2019" -->

<!-- PageFooter="Bulletin No. 2019-15" -->
<!-- PageBreak -->

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

MECKLENBURG

NC

$317,405

$406,307

$491,158

$610,410

ORANGE

NC

$403,657

$516,759

$624,610

$776,263

PASQUOTANK

NC

$726,537

$930,316

$1,124,494

$1,397,423

PERQUIMANS

NC

$726,537

$930,316

$1,124,494

$1,397,423

PERSON

NC

$403,657

$516,759

$624,610

$776,263

ROWAN

NC

$317,405

$406,307

$491,158

$610,410

TYRRELL

NC

$391,007

$500,558

$605,060

$751,913

UNION

NC

$317,405

$406,307

$491,158

$610,410

WAKE

NC

$339,256

$434,307

$524,959

$652,411

BILLINGS

ND

$339,256

$434,307

$524,959

$652,411

WILLIAMS

ND

$330,056

$422,507

$510,709

$634,711

LINCOLN

NE

$433,557

$555,009

$670,911

$833,764

LOGAN

NE

$433,557

$555,009

$670,911

$833,764

MCPHERSON

NE

$433,557

$555,009

$670,911

$833,764

HILLSBOROUGH

NH

$322,005

$412,207

$498,258

$619,260

ROCKINGHAM

NH

$688,862

$881,865

$1,065,968

$1,324,772

STRAFFORD

NH

$688,862

$881,865

$1,065,968

$1,324,772

ATLANTIC

NJ

$316,255

$404,857

$489,358

$608,160

BERGEN

NJ

$726,537

$930,316

$1,124,494

$1,397,423

BURLINGTON

NJ

$402,507

$515,259

$622,860

$774,063

CAMDEN

NJ

$402,507

$515,259

$622,860

$774,063

CAPE MAY

NJ

$414,007

$530,009

$640,661

$796,163

ESSEX

NJ

$726,537

$930,316

$1,124,494

$1,397,423

GLOUCESTER

NJ

$402,507

$515,259

$622,860

$774,063

HUDSON

NJ

$726,537

$930,316

$1,124,494

$1,397,423

HUNTERDON

NJ

$726,537

$930,316

$1,124,494

$1,397,423

MERCER

NJ

$345,006

$441,657

$533,859

$663,461

MIDDLESEX

NJ

$726,537

$930,316

$1,124,494

$1,397,423

MONMOUTH

NJ

$726,537

$930,316

$1,124,494

$1,397,423

MORRIS

NJ

$726,537

$930,316

$1,124,494

$1,397,423

OCEAN

NJ

$726,537

$930,316

$1,124,494

$1,397,423

PASSAIC

NJ

$726,537

$930,316

$1,124,494

$1,397,423

SALEM

NJ

$402,507

$515,259

$622,860

$774,063

SOMERSET

NJ

$726,537

$930,316

$1,124,494

$1,397,423

SUSSEX

NJ

$726,537

$930,316

$1,124,494

$1,397,423

UNION

NJ

$726,537

$930,316

$1,124,494

$1,397,423

WARREN

NJ

$372,606

$477,008

$576,560

$716,562

CATRON

NM

$401,357

$513,809

$621,060

$771,863

LOS ALAMOS

NM

$410,557

$525,559

$635,311

$789,513

SANTA FE

NM

$368,006

$471,108

$569,460

$707,712

CARSON CITY

NV

$318,555

$407,807

$492,958

$612,610

CLARK

NV

$322,005

$412,207

$498,258

$619,260

DOUGLAS

NV

$423,207

$541,759

$654,861

$813,864

STOREY

NV

$412,857

$528,509

$638,861

$793,963

<!-- PageFooter="Bulletin No. 2019-15" -->

<!-- PageFooter="April 08, 2019" -->
<!-- PageBreak -->

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

WASHOE

NV

$412,857

$528,509

$638,861

$793,963

ALBANY

NY

$315,105

$403,357

$487,608

$605,960

BRONX

NY

$726,537

$930,316

$1,124,494

$1,397,423

DUTCHESS

NY

$726,537

$930,316

$1,124,494

$1,397,423

KINGS

NY

$726,537

$930,316

$1,124,494

$1,397,423

NASSAU

NY

$726,537

$930,316

$1,124,494

$1,397,423

NEW YORK

NY

$726,537

$930,316

$1,124,494

$1,397,423

ORANGE

NY

$726,537

$930,316

$1,124,494

$1,397,423

PUTNAM

NY

$726,537

$930,316

$1,124,494

$1,397,423

QUEENS

NY

$726,537

$930,316

$1,124,494

$1,397,423

RENSSELAER

NY

$315,105

$403,357

$487,608

$605,960

RICHMOND

NY

$726,537

$930,316

$1,124,494

$1,397,423

ROCKLAND

NY

$726,537

$930,316

$1,124,494

$1,397,423

SARATOGA

NY

$315,105

$403,357

$487,608

$605,960

SCHENECTADY

NY

$315,105

$403,357

$487,608

$605,960

SCHOHARIE

NY

$315,105

$403,357

$487,608

$605,960

SUFFOLK

NY

$726,537

$930,316

$1,124,494

$1,397,423

WESTCHESTER

NY

$726,537

$930,316

$1,124,494

$1,397,423

DELAWARE

OH

$356,506

$456,358

$551,659

$685,561

FAIRFIELD

OH

$356,506

$456,358

$551,659

$685,561

FRANKLIN

OH

$356,506

$456,358

$551,659

$685,561

HOCKING

OH

$356,506

$456,358

$551,659

$685,561

LICKING

OH

$356,506

$456,358

$551,659

$685,561

MADISON

OH

$356,506

$456,358

$551,659

$685,561

MORROW

OH

$356,506

$456,358

$551,659

$685,561

PERRY

OH

$356,506

$456,358

$551,659

$685,561

PICKAWAY

OH

$356,506

$456,358

$551,659

$685,561

UNION

OH

$356,506

$456,358

$551,659

$685,561

BENTON

OR

$385,256

$493,208

$596,160

$740,862

CLACKAMAS

OR

$474,958

$608,010

$734,962

$913,365

CLATSOP

OR

$316,255

$404,857

$489,358

$608,160

COLUMBIA

OR

$474,958

$608,010

$734,962

$913,365

CURRY

OR

$327,755

$419,557

$507,159

$630,311

DESCHUTES

OR

$409,407

$524,109

$633,511

$787,313

HOOD RIVER

OR

$477,258

$610,960

$738,512

$917,815

JACKSON

OR

$320,855

$410,757

$496,508

$617,010

MARION

OR

$322,005

$412,207

$498,258

$619,260

MULTNOMAH

OR

$474,958

$608,010

$734,962

$913,365

POLK

OR

$322,005

$412,207

$498,258

$619,260

WASHINGTON

OR

$474,958

$608,010

$734,962

$913,365

YAMHILL

OR

$474,958

$608,010

$734,962

$913,365

BUCKS

PA

$402,507

$515,259

$622,860

$774,063

CARBON

PA

$372,606

$477,008

$576,560

$716,562

CHESTER

PA

$402,507

$515,259

$622,860

$774,063

DELAWARE

PA

$402,507

$515,259

$622,860

$774,063

<!-- PageFooter="April 08, 2019" -->

<!-- PageFooter="Bulletin No. 2019-15" -->
<!-- PageBreak -->

2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

LEHIGH

PA

$372,606

$477,008

$576,560

$716,562

MONTGOMERY

PA

$402,507

$515,259

$622,860

$774,063

NORTHAMPTON

PA

$372,606

$477,008

$576,560

$716,562

PHILADELPHIA

PA

$402,507

$515,259

$622,860

$774,063

PIKE

PA

$726,537

$930,316

$1,124,494

$1,397,423

BRISTOL

RI

$454,258

$581,510

$702,912

$873,565

KENT

RI

$454,258

$581,510

$702,912

$873,565

NEWPORT

RI

$454,258

$581,510

$702,912

$873,565

PROVIDENCE

RI

$454,258

$581,510

$702,912

$873,565

WASHINGTON

RI

$454,258

$581,510

$702,912

$873,565

BEAUFORT

SC

$350,756

$449,008

$542,759

$674,511

BERKELEY

SC

$388,707

$497,608

$601,510

$747,513

CHARLESTON

SC

$388,707

$497,608

$601,510

$747,513

CHESTER

SC

$317,405

$406,307

$491,158

$610,410

DORCHESTER

SC

$388,707

$497,608

$601,510

$747,513

GEORGETOWN

SC

$327,755

$419,557

$507,159

$630,311

JASPER

SC

$350,756

$449,008

$542,759

$674,511

LANCASTER

SC

$317,405

$406,307

$491,158

$610,410

YORK

SC

$317,405

$406,307

$491,158

$610,410

CANNON

TN

$534,759

$684,561

$827,514

$1,028,367

CHEATHAM

TN

$534,759

$684,561

$827,514

$1,028,367

DAVIDSON

TN

$534,759

$684,561

$827,514

$1,028,367

DICKSON

TN

$534,759

$684,561

$827,514

$1,028,367

HICKMAN

TN

$534,759

$684,561

$827,514

$1,028,367

MACON

TN

$534,759

$684,561

$827,514

$1,028,367

MAURY

TN

$534,759

$684,561

$827,514

$1,028,367

ROBERTSON

TN

$534,759

$684,561

$827,514

$1,028,367

RUTHERFORD

TN

$534,759

$684,561

$827,514

$1,028,367

SMITH

TN

$534,759

$684,561

$827,514

$1,028,367

SUMNER

TN

$534,759

$684,561

$827,514

$1,028,367

TROUSDALE

TN

$534,759

$684,561

$827,514

$1,028,367

WILLIAMSON

TN

$534,759

$684,561

$827,514

$1,028,367

WILSON

TN

$534,759

$684,561

$827,514

$1,028,367

ATASCOSA

TX

$359,956

$460,808

$557,009

$692,212

AUSTIN

TX

$331,206

$424,007

$512,509

$636,911

BANDERA

TX

$359,956

$460,808

$557,009

$692,212

BASTROP

TX

$389,857

$499,058

$603,260

$749,713

BEXAR

TX

$359,956

$460,808

$557,009

$692,212

BRAZORIA

TX

$331,206

$424,007

$512,509

$636,911

CALDWELL

TX

$389,857

$499,058

$603,260

$749,713

CHAMBERS

TX

$331,206

$424,007

$512,509

$636,911

COLLIN

TX

$395,607

$506,458

$612,160

$760,763

COMAL

TX

$359,956

$460,808

$557,009

$692,212

DALLAS

TX

$395,607

$506,458

$612,160

$760,763

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

DENTON

TX

$395,607

$506,458

$612,160

$760,763

ELLIS

TX

$395,607

$506,458

$612,160

$760,763

FORT BEND

TX

$331,206

$424,007

$512,509

$636,911

GALVESTON

TX

$331,206

$424,007

$512,509

$636,911

GILLESPIE

TX

$324,305

$415,157

$501,808

$623,660

GUADALUPE

TX

$359,956

$460,808

$557,009

$692,212

HARRIS

TX

$331,206

$424,007

$512,509

$636,911

HAYS

TX

$389,857

$499,058

$603,260

$749,713

HOOD

TX

$395,607

$506,458

$612,160

$760,763

HUNT

TX

$395,607

$506,458

$612,160

$760,763

JOHNSON

TX

$395,607

$506,458

$612,160

$760,763

KAUFMAN

TX

$395,607

$506,458

$612,160

$760,763

KENDALL

TX

$359,956

$460,808

$557,009

$692,212

LIBERTY

TX

$331,206

$424,007

$512,509

$636,911

MARTIN

TX

$318,555

$407,807

$492,958

$612,610

MEDINA

TX

$359,956

$460,808

$557,009

$692,212

MIDLAND

TX

$318,555

$407,807

$492,958

$612,610

MONTGOMERY

TX

$331,206

$424,007

$512,509

$636,911

PARKER

TX

$395,607

$506,458

$612,160

$760,763

ROCKWALL

TX

$395,607

$506,458

$612,160

$760,763

SOMERVELL

TX

$395,607

$506,458

$612,160

$760,763

TARRANT

TX

$395,607

$506,458

$612,160

$760,763

TRAVIS

TX

$389,857

$499,058

$603,260

$749,713

WALLER

TX

$331,206

$424,007

$512,509

$636,911

WILLIAMSON

TX

$389,857

$499,058

$603,260

$749,713

WILSON

TX

$359,956

$460,808

$557,009

$692,212

WISE

TX

$395,607

$506,458

$612,160

$760,763

BOX ELDER

UT

$401,357

$513,809

$621,060

$771,863

DAVIS

UT

$401,357

$513,809

$621,060

$771,863

JUAB

UT

$377,206

$482,858

$583,710

$725,412

MORGAN

UT

$401,357

$513,809

$621,060

$771,863

SALT LAKE

UT

$388,707

$497,608

$601,510

$747,513

SUMMIT

UT

$726,537

$930,316

$1,124,494

$1,397,423

TOOELE

UT

$388,707

$497,608

$601,510

$747,513

UTAH

UT

$377,206

$482,858

$583,710

$725,412

WASATCH

UT

$462,308

$591,810

$715,412

$889,065

WASHINGTON

UT

$349,606

$447,558

$540,959

$672,311

WEBER

UT

$401,357

$513,809

$621,060

$771,863

ALBEMARLE

VA

$437,007

$559,459

$676,211

$840,414

ALEXANDRIA CITY

VA

$726,537

$930,316

$1,124,494

$1,397,423

AMELIA

VA

$535,909

$686,062

$829,264

$1,030,617

ARLINGTON

VA

$726,537

$930,316

$1,124,494

$1,397,423

BUCKINGHAM

VA

$437,007

$559,459

$676,211

$840,414

CAROLINE

VA

$535,909

$686,062

$829,264

$1,030,617

CHARLES CITY

VA

$535,909

$686,062

$829,264

$1,030,617

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

CHARLOTTESVILLE

VA

$437,007

$559,459

$676,211

$840,414

CHESAPEAKE CITY

VA

$458,858

$587,410

$710,062

$882,415

CHESTERFIELD

VA

$535,909

$686,062

$829,264

$1,030,617

CLARKE

VA

$726,537

$930,316

$1,124,494

$1,397,423

COLONIAL HEIGHT

VA

$535,909

$686,062

$829,264

$1,030,617

CULPEPER

VA

$726,537

$930,316

$1,124,494

$1,397,423

DINWIDDIE

VA

$535,909

$686,062

$829,264

$1,030,617

FAIRFAX

VA

$726,537

$930,316

$1,124,494

$1,397,423

FAIRFAX CITY

VA

$726,537

$930,316

$1,124,494

$1,397,423

FALLS CHURCH CI

VA

$726,537

$930,316

$1,124,494

$1,397,423

FAUQUIER

VA

$726,537

$930,316

$1,124,494

$1,397,423

FLUVANNA

VA

$437,007

$559,459

$676,211

$840,414

FREDERICKSBURG

VA

$726,537

$930,316

$1,124,494

$1,397,423

GLOUCESTER

VA

$458,858

$587,410

$710,062

$882,415

GOOCHLAND

VA

$535,909

$686,062

$829,264

$1,030,617

GREENE

VA

$437,007

$559,459

$676,211

$840,414

HAMPTON CITY

VA

$458,858

$587,410

$710,062

$882,415

HANOVER

VA

$535,909

$686,062

$829,264

$1,030,617

HENRICO

VA

$535,909

$686,062

$829,264

$1,030,617

HOPEWELL CITY

VA

$535,909

$686,062

$829,264

$1,030,617

ISLE OF WIGHT

VA

$458,858

$587,410

$710,062

$882,415

JAMES CITY

VA

$458,858

$587,410

$710,062

$882,415

KING GEORGE

VA

$350,756

$449,008

$542,759

$674,511

KING WILLIAM

VA

$535,909

$686,062

$829,264

$1,030,617

LANCASTER

VA

$442,757

$566,810

$685,111

$851,464

LEXINGTON CITY

VA

$354,206

$453,458

$548,109

$681,161

LOUDOUN

VA

$726,537

$930,316

$1,124,494

$1,397,423

MANASSAS CITY

VA

$726,537

$930,316

$1,124,494

$1,397,423

MANASSAS PARK C

VA

$726,537

$930,316

$1,124,494

$1,397,423

MATHEWS

VA

$458,858

$587,410

$710,062

$882,415

NELSON

VA

$437,007

$559,459

$676,211

$840,414

NEW KENT

VA

$535,909

$686,062

$829,264

$1,030,617

NEWPORT NEWS CI

VA

$458,858

$587,410

$710,062

$882,415

NORFOLK CITY

VA

$458,858

$587,410

$710,062

$882,415

NORTHUMBERLAND

VA

$318,555

$407,807

$492,958

$612,610

PETERSBURG CITY

VA

$535,909

$686,062

$829,264

$1,030,617

POQUOSON CITY

VA

$458,858

$587,410

$710,062

$882,415

PORTSMOUTH CITY

VA

$458,858

$587,410

$710,062

$882,415

POWHATAN

VA

$535,909

$686,062

$829,264

$1,030,617

PRINCE GEORGE

VA

$535,909

$686,062

$829,264

$1,030,617

PRINCE WILLIAM

VA

$726,537

$930,316

$1,124,494

$1,397,423

RAPPAHANNOCK

VA

$726,537

$930,316

$1,124,494

$1,397,423

RICHMOND CITY

VA

$535,909

$686,062

$829,264

$1,030,617

SPOTSYLVANIA

VA

$726,537

$930,316

$1,124,494

$1,397,423

STAFFORD

VA

$726,537

$930,316

$1,124,494

$1,397,423

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

SUFFOLK CITY

VA

$458,858

$587,410

$710,062

$882,415

SUSSEX

VA

$535,909

$686,062

$829,264

$1,030,617

VIRGINIA BEACH

VA

$458,858

$587,410

$710,062

$882,415

WARREN

VA

$726,537

$930,316

$1,124,494

$1,397,423

WILLIAMSBURG CI

VA

$458,858

$587,410

$710,062

$882,415

YORK

VA

$458,858

$587,410

$710,062

$882,415

CHITTENDEN

VT

$351,906

$450,508

$544,559

$676,761

FRANKLIN

VT

$351,906

$450,508

$544,559

$676,761

GRAND ISLE

VT

$351,906

$450,508

$544,559

$676,761

CHELAN

WA

$342,706

$438,707

$530,309

$659,061

CLALLAM

WA

$384,106

$491,708

$594,360

$738,662

CLARK

WA

$474,958

$608,010

$734,962

$913,365

DOUGLAS

WA

$342,706

$438,707

$530,309

$659,061

ISLAND

WA

$379,506

$485,808

$587,260

$729,812

JEFFERSON

WA

$322,005

$412,207

$498,258

$619,260

KING

WA

$726,537

$930,316

$1,124,494

$1,397,423

KITSAP

WA

$363,406

$465,208

$562,359

$698,862

PIERCE

WA

$726,537

$930,316

$1,124,494

$1,397,423

SAN JUAN

WA

$483,008

$618,310

$747,413

$928,866

SKAGIT

WA

$339,256

$434,307

$524,959

$652,411

SKAMANIA

WA

$474,958

$608,010

$734,962

$913,365

SNOHOMISH

WA

$726,537

$930,316

$1,124,494

$1,397,423

THURSTON

WA

$336,956

$431,357

$521,409

$648,011

WHATCOM

WA

$381,806

$488,758

$590,810

$734,262

JEFFERSON

WV

$726,537

$930,316

$1,124,494

$1,397,423

COLUMBIA

WI

$316,255

$404,857

$489,358

$608,160

DANE

WI

$316,255

$404,857

$489,358

$608,160

GREEN

WI

$316,255

$404,857

$489,358

$608,160

IOWA

WI

$316,255

$404,857

$489,358

$608,160

KENOSHA

WI

$368,006

$471,108

$569,460

$707,712

MILWAUKEE

WI

$327,755

$419,557

$507,159

$630,311

OZAUKEE

WI

$327,755

$419,557

$507,159

$630,311

PIERCE

WI

$366,856

$469,608

$567,660

$705,512

ST. CROIX

WI

$366,856

$469,608

$567,660

$705,512

WASHINGTON

WI

$327,755

$419,557

$507,159

$630,311

WAUKESHA

WI

$327,755

$419,557

$507,159

$630,311

SWEETWATER

WY

$316,255

$404,857

$489,358

$608,160

TETON

WY

$726,537

$930,316

$1,124,494

$1,397,423

GUAM

GU

$563,509

$721,412

$872,015

$1,083,668

NORTHERN ISLAND

MP

$524,409

$671,311

$811,464

$1,008,467

ROTA

MP

$410,557

$525,559

$635,311

$789,513

SAIPAN

MP

$529,009

$677,211

$818,614

$1,017,317

TINIAN

MP

$532,459

$681,661

$823,964

$1,023,967

AGUAS BUENAS

PR

$385,256

$493,208

$596,160

$740,862

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2019 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

State

One-Unit Limit

Two-Unit Limit

Three-Unit Limit

Four-Unit Limit

AIBONITO

PR

$385,256

$493,208

$596,160

$740,862

BARCELONETA

PR

$385,256

$493,208

$596,160

$740,862

BARRANQUITAS

PR

$385,256

$493,208

$596,160

$740,862

BAYAMON

PR

$385,256

$493,208

$596,160

$740,862

CAGUAS

PR

$385,256

$493,208

$596,160

$740,862

CANOVANAS

PR

$385,256

$493,208

$596,160

$740,862

CAROLINA

PR

$385,256

$493,208

$596,160

$740,862

CATANO

PR

$385,256

$493,208

$596,160

$740,862

CAYEY

PR

$385,256

$493,208

$596,160

$740,862

CEIBA

PR

$385,256

$493,208

$596,160

$740,862

CIALES

PR

$385,256

$493,208

$596,160

$740,862

CIDRA

PR

$385,256

$493,208

$596,160

$740,862

COMERIO

PR

$385,256

$493,208

$596,160

$740,862

COROZAL

PR

$385,256

$493,208

$596,160

$740,862

DORADO

PR

$385,256

$493,208

$596,160

$740,862

FAJARDO

PR

$385,256

$493,208

$596,160

$740,862

FLORIDA

PR

$385,256

$493,208

$596,160

$740,862

GUAYNABO

PR

$385,256

$493,208

$596,160

$740,862

GURABO

PR

$385,256

$493,208

$596,160

$740,862

HUMACAO

PR

$385,256

$493,208

$596,160

$740,862

JUNCOS

PR

$385,256

$493,208

$596,160

$740,862

LAS PIEDRAS

PR

$385,256

$493,208

$596,160

$740,862

LOIZA

PR

$385,256

$493,208

$596,160

$740,862

LUQUILLO

PR

$385,256

$493,208

$596,160

$740,862

MANATI

PR

$385,256

$493,208

$596,160

$740,862

MAUNABO

PR

$385,256

$493,208

$596,160

$740,862

MOROVIS

PR

$385,256

$493,208

$596,160

$740,862

NAGUABO

PR

$385,256

$493,208

$596,160

$740,862

NARANJITO

PR

$385,256

$493,208

$596,160

$740,862

OROCOVIS

PR

$385,256

$493,208

$596,160

$740,862

RIO GRANDE

PR

$385,256

$493,208

$596,160

$740,862

SAN JUAN

PR

$385,256

$493,208

$596,160

$740,862

SAN LORENZO

PR

$385,256

$493,208

$596,160

$740,862

TOA ALTA

PR

$385,256

$493,208

$596,160

$740,862

TOA BAJA

PR

$385,256

$493,208

$596,160

$740,862

TRUJILLO ALTO

PR

$385,256

$493,208

$596,160

$740,862

VEGA ALTA

PR

$385,256

$493,208

$596,160

$740,862

VEGA BAJA

PR

$385,256

$493,208

$596,160

$740,862

YABUCOA

PR

$385,256

$493,208

$596,160

$740,862

ST. CROIX ISLAN

VI

$327,755

$419,557

$507,159

$630,311

ST. JOHN ISLAND

VI

$623,310

$797,963

$964,516

$1,198,670

ST. THOMAS ISLA

VI

$446,207

$571,210

$690,462

$858,114

All other areas - 2647 counties (floor):

$314,832

$403,132

$487,258

$605,535

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.02 The nationwide average purchase
price (for use in the housing cost/income
ratio for new and existing residences) is
$298,000.

## SECTION 5. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 2018-28 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 20, 2019, and
ends on the date as of which the safe
harbors contained in section 4.01 of this
revenue 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.
2018-28, with respect to bonds sold, or
for mortgage credit certificates issued
with respect to bond authority exchanged,
before April 19, 2019, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
May 19, 2019.

.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 resi-
dences that are purchased, in the period
that begins on March 20, 2019, 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. 2018-28 with respect to bonds sold,
or for mortgage credit certificates issued
with respect to bond authority exchanged,
before April 19, 2019, if the commitments
to provide financing or issue mortgage
credit certificates are made on or before
May 19, 2019.

## 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 spon-
sor, and a person is not required to re-
spond to, a collection of information un-
less 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 av-
erage area purchase price for a given met-
ropolitan statistical area for purposes of
sections 143(e) and 25(c). The collection
of information is required to obtain the
benefit 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
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 David White and Timothy
Jones of the Office of Associate Chief
Counsel (Financial Institutions & Prod-
ucts). For further information regarding
this revenue procedure contact David
White on (202) 317-4562 (not a toll free
number).

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# Part IV. Items of General Interest

## Announcement and Report Concerning Advance Pricing Agreements

### Announcement 2019-03

This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, 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 2017 separately. This twentieth report describes the experience, structure, and activities of the APMA Program during
calendar year 2018. 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
statistical data; and Part III includes general descriptions of various elements of the APAs executed in 2018, including types of
transactions covered, transfer pricing methods used, and completion time.

John C. C. Hughes
Director, Advance Pricing and Mutual Agreement Program

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# 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
Operations1 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 22, 2018, the APMA Program
included 56 team leaders, 12 economists, 6 managers and 3 assistant directors. Each assistant director oversees 2 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 a
significant presence in San Francisco and the Los Angeles area.

On August 31, 2015, new revenue procedures governing requests under the mutual agreement procedure (MAP) and APA
applications were published in 2015-35 I.R.B. on pages 236 and 263, respectively. Revenue Procedure (Rev. Proc.) 2015-41
provides guidance and instructions on filing APA requests as well as guidance and information on the administration of APAs. Rev.

Proc. 2015-41 updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B.
1133, which is also superseded. Rev. Proc. 2015-40 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. 2015-40 updates and supersedes
Rev. Proc. 2006-54, 2006-2 C.B. 1035.

The 2009 and 2015 Model APAs appear in this report as Appendix 1 and Appendix 2, respectively. The 2015 Model APA was
finalized in May 2018. The new model does not contain any major revisions from the draft revision that was released for public
comment in the fall of 2017. A list of primary APMA contacts is available at https://www.irs.gov/businesses/corporations/apma-
contacts.

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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

Multilateral

Total

Filed 1991-19992

401

Filed 2000-2017

570

1,364

11

1,945

Filed in 2018

35

161

7

203

Total Filed 1991-2018

2,549

Applications Filed 2009-2018

250

200

150

100

50

0

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Bilateral APAs Filed by Country 2018

Italy
4%

All Other Countries
13%

Mexico
6%

Japan
34%

Korea
6%

Germany
7%

Canada
9%

India
21%

The charts above illustrate the number of complete applications filed per year and the bilateral requests received in 2018 by foreign
country. As of December 31, 2018, APMA had also received 71 user fee filings that were not yet accompanied by substantially
complete APA applications, in addition to the 203 complete APA applications.

2The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

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Table 2: Executed and Pending APAs
§ 521(b)(2)(C)(ii-vi)

Unilateral

Bilateral

Multilateral

Total

Total Executed 1991-2017

590

1,108

15

1,713

Total Executed in 2018

24

81

2

107

Total Executed 1991-2018

614

1,189

17

1,820

Total Pending as of 12/31/2018

58

387

13

458

Renewals Executed in 20183

15

45

2

62

Renewals Pending4

36

158

1

195

APAs Executed 2009-2018

150

100

50

0

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

Bilateral APAs Executed by Country 2018

All Other Countries
13%

Japan
39%

UK
4%

Switzerland
4%

Netherlands
4%

Mexico
6%

Korea
10%

Canada
20%

Consistent with prior years, roughly 40 percent of the APAs executed in 2018 were new APAs (i.e., not a renewal of a prior APA).
The charts above illustrate the total number of APAs executed per year and the countries involved in the executed bilateral APAs.
Over half of the bilateral APAs executed in 2018 involved mutual agreements with either Japan or Canada.

3The number of renewals executed is included in the total number of APAs executed during the year.

4The number of renewals still pending as of year-end is also included in the total number of pending APAs.

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Pending APAs
2009-2018

Bilateral APAs Pending by Country 2018

500

400

300

200

100

0

2009

2010 2011 2012 2013 2014 2015 2016 2017 2018

Italy
4%

All Other Countries
14%

Japan
31%

UK
4%

Mexico
5%

Korea
5%

Germany
8%

Canada
9%

India
20%

As the top chart illustrates, the number of pending requests continues to rise due largely to the increase in number of requests filed.
As of December 31, 2018, over half of the pending bilateral APA requests involved either Japan or India.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)

Unilateral

Bilateral

Multilateral

Total

Revoked or Cancelled in 2018

0

0

0

0

Total Revoked or Cancelled 1991-20185

11

Applications Withdrawn in 2018

7

14

0

21

Total Applications Withdrawn 1991-20186

253

5The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

6The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

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Table 4: APAs Executed7 by Industry
§ 521(b)(2)(C)(viii)

Industry

Manufacturing

48

Wholesale/Retail Trade

35

Management

8

Services

7

Finance, Insurance, and Real Estate

4

All Other Industries

5

APAs by Industry Executed in 2018

Manufacturing
45%

Wholesale/Retail
Trade
33%

All Other Industries
5%

Finance, Insurance
and Real Estate
4%

Services
6%

Management
7%

7APAs executed include APAs that were renewed.

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Table 4a: Manufacturing APAs Executed in 2018

Manufacturing

Miscellaneous Manufacturing8

10

Transportation Equipment

9

Computer and Electronic Products

6

Machinery

6

Chemical

5

All Other Types of Manufacturing

12

Manufacturing APAs Executed in 2018

Miscellaneous
Manufacturing
21%

Transportation
Equipment
19%

Computer and
Electronic
Products
13%

All Other
Manufacturing
24%

Machinery
13%

Chemical
10%

Table 4b: Wholesale/Retail Trade APAs Executed in 2018

Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods

24

All Other Types of Other Wholesale/Retail Trade

11

Wholesale/Retail Trade APAs
Executed in 2018

All Other
Wholesalers
31%

Merchant
Wholesalers, Durable
Goods
69%

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# Part III. General Descriptions of APAs Executed in 2018 [Pub. L. 106-170 § 521(b)(2)(D) and (E)]

## Nature of the Relationships § 521(b)(2)(D)(i)

Relationships between Controlled Parties in 2018

U.S. Parent & Non-
U.S. Subsidiary
22%

Sister Companies
24%

Non-U.S. Parent &
U.S. Subsidiary
52%

All Other
Relationships
2%

As in prior years, more than half of the APAs executed in 2018 involved transactions between non-U.S. parents and U.S. subsidiaries.

## Covered Transactions, Functions and Risks, and Tested Parties

§ 521(b)(2)(D)(ii-iii)

Types of Covered Transactions in 2018

Sale of Tangible
Property into the U.S.
28%

Sale of Tangible
Property from the
U.S.
16%

Provision of Services
by a Non-U.S. Entity
16%

Use of Intangible
Property by a U.S.
Entity
14%

Provision of Services
by a U.S. Entity
19%

Use of Intangible
Property by a Non-
U.S. Entity
7%

Although most of the transactions9 covered in APAs executed in 2018 involve the sale of tangible goods or the provision of services,
over 20% covered the use of intangible property, which can be among the most challenging in APMA's inventory. The IRS continues
to seek opportunities to work with taxpayers and treaty partners to provide prospective certainty, wherever appropriate, for
transactions involving the use of intangible property.

9 APAs often cover more than one type of transaction.

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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.

Types of Tested Parties in 2018

U.S. Distributor
32%

Non-U.S. Distributor
7%

Non-U.S. Service
Provider
4%

U.S. Manufacturer
21%

U.S. Service Provider
28%

Non-U.S.
Manufacturer
8%

Consistent with prior years, over 80 percent of the tested parties in 201810 were U.S. distributors, U.S. manufacturers, or U.S. service
providers.

## Transfer Pricing Methods Used

### § 521(b)(2)(D)(iv)

Consistent with prior years, in 2018, the primary transfer pricing method (TPM) used for both the sale of tangible property and the
use of intangible property was the comparable profits method/transactional net margin method (CPM/TNMM). The CPM/TNMM
was used for 86 percent of transfers of tangible and intangible property while all other methods combined accounted for the other
14 percent of such transactions.

For covered transfers of tangible and intangible property that used the CPM/TNMM, the operating margin (OM) continues to be the
most common profit level indicator (PLI) used to benchmark results. It was used 68 percent of the time. Other PLIs, such as the Berry
Ratio and mark up on total cost, made up the other 32 percent. As used here, OM means the ratio of operating profits to sales,11 and
"Berry Ratio" means the ratio of gross profit to operating expenses.12 Most services transactions (86 percent) also used the
CPM/TNMM with the OM and mark up on total costs being the most common PLIs (used 76 percent of the time). 13

## 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 2018 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 transaction-based methods were applied). The other more commonly used
databases are listed in the table below.

10Not all APAs executed in 2018 involved a tested party.

11 See Treas. Reg. § 1.482-5(b)(4)(ii)(A).

12See Treas. Reg. § 1.482-5(b)(4)(ii)(B).

13In 2018, the majority of the APAs that covered services transactions also included tangible/intangible transactions, which were not tested under a separate PLI.

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Table 5: Sources of Comparable Data

Avention (formerly known as OneSource)

Mergent

Bloomberg

Orbis

Disclosure

Recap

Global Vantage

RoyaltySource

ktMINE

RoyaltyStat

LoanConnector

Worldscope

In making comparability adjustments, the standard balance sheet adjustments identified in Treas. Reg. § 1.482-1(d) and § 1.482-5(c),
including adjustments for differing amounts of payables, receivables, and inventory, were made in most cases. Where appropriate,
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, Targets, and Adjustment Mechanisms

## § 521(b)(2)(D)(viii-ix)

Most transactions covered in APAs target an interquartile range as described in Treas. Reg. § 1.482-1(e)(2)(iii)(C). Where the
transaction 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 payment of a royalty based solely on external royalty agreements, a secondary method, e.g.,
a test of the post-royalty operating margin or cost-plus mark-up, has been used. The testing periods of the APAs executed in 2018
were either: (1) a single year, (2) the term of the APA only, or (3) the term of the APA plus rollback years.

APAs executed in 2018 included several mechanisms for making adjustments to tested party results when the results fall outside the
range or do not match the point required by the APA. The following are examples of the mechanisms used: 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.

# Critical Assumptions

## § 521(b)(2)(D)(v)

The model APAs used by the IRS (included as Appendix 1 and Appendix 2 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 either to the taxpayer's profitability in a certain year or over the term
of the APA, or to the amount of non-covered transactions as a percentage of the taxpayer's revenue. Pursuant to § 7.06(3) of Rev.
Proc. 2015-41, APMA will cancel an APA in the event of a failure of a critical assumption unless the parties agree to revise the
APA.

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# Term Lengths of APAs Executed in 2018 § 521(b)(2)(D)(x)

Table 6: Term Lengths of APAs Executed in 2018

Term Length (years)

Number of APAs

1

2

2

2

3

2

4

2

5

36

6

15

7

12

8

10

9

9

10

8

11

3

12

4

15

2

Average

7

Term Length of APAs Executed in 2018

40

Number of APAs

30

20

10

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

Number of Years (Including Rollback)

As described in § 3.03(1) of Rev. Proc. 2015-41, 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 case- by-case basis. Of the APAs executed in 2018, almost 20 percent included rollback years. A substantial
number of those APAs with terms of greater than five years were submitted as a request for a five-year 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.

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# 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 2018

Unilateral

Bilateral

Unilateral &amp; Bilateral

Average

Median

Average

Median

Average

Median

New

35.4

30.7

47.8

43.2

45.5

41.7

Renewal

32.4

36.3

43.9

42.0

40.8

40.1

New &amp; Renewal

33.4

33.5

45.6

42.1

42.8

40.2

Months to Complete New and Renewal APAs Executed in 2018

50.0

Months to Complete

40.0

New

30.0

Renewal

20.0

New &
Renewal

10.0

0.0

Average
Unilateral

Median

Average

Median

Median
Unilateral &
Bilateral

Average

Bilateral

Type of APA

The median time required to complete an APA in 2018 increased to 40.2 months (from 33.8 months in 2017). This increase is mainly
due to the completion of longstanding APAs as well as challenges coordinating negotiating schedules with treaty partners.

# Efforts to Ensure Compliance with APAS § 521(b)(2)(F)

As described in § 7.02(1) of Rev. Proc. 2015-41, 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.

# Nature of Documentation Required in Annual Report § 521(b)(2)(D)(xi)

APAs require taxpayers to file timely and complete annual reports describing their operations and demonstrating compliance with
the APAs' terms and conditions. Not every annual report will include each of the items listed in the following table14; they are
required where the facts demonstrate a need for such documentation.

14The source of this list is the 2009 Model APA and requirements remain largely unchanged in the 2015 Model APA.

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1.

Statement regarding all material differences between Taxpayer's business operations during APA year and description of Taxpayer's business operations contained in Taxpayer's APA request. If there are no material differences, a statement to that effect.

2.

Statement concerning all material changes in Taxpayer's accounting methods and classifications, and methods of estimation, from those described or used in Taxpayer's request for the APA. If there has been no material change in accounting methods and classifications 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.

5.

Statement identifying whether or not any material information submitted while the APA request was pending is discovered to be false, incorrect, or incomplete.

6.

The amount, reason for, and financial 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 ordi- nary expense) and country source of the funds transferred, and the specific line item(s) of any affected U.S. tax return; and any change to any entity classification for federal income tax purposes of any member of Tax- payer's group that is relevant to the APA.

7.

The amounts, description, reason for, and financial analysis of any book-tax difference relevant to the TPM for the APA year, as reflected on Schedule M-1 or Schedule M-3 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.

9.

Financial statements and any necessary account detail to show compliance with the TPM, with a copy of the opinion from 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
mechanisms and/or critical assumptions.

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<!-- PageHeader="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's-length 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 2006-9 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 2006-9
(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's-length 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.]

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 Foreign
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;

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ii. cancel or revoke this APA under section 11.06 of Revenue Procedure 2006-9; 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 2006-9. 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 reasonably 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 2006-9, 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
constitutes compliance with the record-maintenance provisions of I.R.C. sections 6038A and 6038C for the Covered Trans-
actions for any taxable year during the APA Term.

h. The True Taxable Income within the meaning of Treasury Regulations sections 1.482-1(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 2006-9, section 4.05, appear
in Appendix B. If any critical assumption has not been met, then Revenue Procedure 2006-9, section 11.06, governs.

7\. Disclosure. This APA, and any background information related to this APA or the APA Request, are: (1) considered "return
information" 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. 106-170 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 2006-9, 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 2006-9 must be in writing. Taxpayer will send notices to the
IRS at the address and in the manner set forth in Revenue Procedure 2006-9, 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:
)

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.

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### WITNESS,

The Parties have executed this APA on the dates below.

[Taxpayer Name in all caps]

By:
Jane Doe
Sr. Vice President (Taxes)

IRS
By:

John C. C. Hughes
Director, Advance Pricing and Mutual
Agreement Program

Date:

201

Date:

201

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# 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 1.482-3(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 1.482-5(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 those terms are defined in Treasury Regulations section 1.482-5(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
Three-Year Rolling Average operating margin is defined as follows for any APA Year: the sum of the Tested Party's
operating profit (within the meaning of Treasury Regulation section 1.482-5(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 1.482-5(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.]

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## 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, Three-Year 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, Three-Year 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, Three-Year Rolling Average
Operating 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
following adjustments:

(a) [The fair value of stock-based 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 multi-year 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 2006-9 and avoid
the possible adverse tax consequences of a secondary adjustment that would otherwise follow the primary adjustment.

[Insert additional provisions as needed.]

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# 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.]

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# 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, contractual terms,
economic conditions, property, services, and assets employed) during the APA Year from the business operations 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 material 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 2006-9, 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

iv. whether or not APA Revenue Procedure Treatment was elected pursuant to paragraph 5 of Appendix A and Revenue
Procedure 2006-9, section 11.02(3).

h. The amounts, description, reason for, and financial analysis of any book-tax difference relevant to the TPM for the APA Year,
as reflected on Schedule M-1 or Schedule M-3 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
accountant'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
reference 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 2006-9, section 11.01(6) and (7).

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# APPENDIX D DEFINITIONS

The following definitions control for all purposes of this APA. The definitions appear alphabetically below:

Term

Definition

Annual Report

A report within the meaning of Revenue Procedure 2006-9, section 11.01.

APA

This Advance Pricing Agreement, which is an "advance pricing agreement" within the meaning of Revenue Procedure 2006-9, section 2.04.

APA Records

The records specified in Appendix C.

APA Request

Taxpayer's request for this APA dated including any amendments or supplemental or additional information thereto.

APA Year

This term is defined in paragraph 5(a) of this APA.

Covered Transaction(s)

This term is defined in Appendix A.

Financial Statements

Financial statements prepared in accordance with U.S. GAAP and stated in U.S. dollars.

Foreign Group

Worldwide 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. 106-170

The Ticket to Work and Work Incentives Improvement Act of 1999.

Revenue Procedure 2006-9

Rev. Proc. 2006-9, 2006-1 C.B. 278.

Transfer Pricing Method (TPM)

A transfer pricing method within the meaning of Treasury Regulation section 1.482-1(b) and Revenue Procedure 2006-9, section 2.04.

U.S. GAAP

U.S. generally-accepted accounting principles.

U.S. Group

Worldwide Group members that are U.S. persons.

U.S. Return

For 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 taxable year, the "return" that Taxpayer must "make" in accordance with I.R.C. section 6031.}

Worldwide Group

Taxpayer 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.

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# 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
information 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.

APA Annual Report SUMMARY

Department of the Treasury- Internal Revenue Service Large Business and International Division 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] Principal foreign country(ies) involved in covered transaction(s): ☒ Type of APA: [ ] unilateral [ ] bilateral with Tested party is [ ] US [ ] foreign [ ] both

immediately following the close of the APA Year

Approximate dollar volume of covered transactions (on an annual basis) involving tangible goods and services:

[] N/A [ ] &lt;$50 million [] $50-100 million [] $100-250 ☒ APA tests on (check all that apply): ☒ [ ] annual basis [ ] multi-year 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

million [] $250-500 million []&gt;$500 million

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APA Annual Report
Information

APA date executed:

201

This APA Annual Report Summary is for APA Year(s) ending in 200_ and
was filed on
201

(to be completed
by the Taxpayer)

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?
Taxpayer's current US principal place of business: (City, State)

yes
no

APA Annual Report
Checklist of
Key Contents
(to be completed
by the Taxpayer)

Financial analysis reflecting TPM calculations

[ ] yes [ ] no ☐

Financial statements showing compliance with TPM(s)

yes ☐ no

Schedule M-1 or M-3 book-tax differences

yes ☐ no

Current organizational chart of relevant portion of world-wide group

yes ☐ no

Attach copy of APA

yes no

Other APA records and documents included:

Contact Information

Authorized Representative

Phone Number

Affiliation and Address

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## 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 2015-41, 2015-35 I.R.B.
263 ("Rev. Proc. 2015-41"). 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. 2015-41 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. 2015-41. 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 options-based format for selecting from terms presented in certain
sections 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 language 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
justification for the selection in the APA request. See section 1.02, Part 5, of the Appendix to Rev. Proc. 2015-41.

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 conventions:

· 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. 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:

[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
propose additional critical assumptions to address specific regulatory contingencies or conditions the taxpayer is expected to face

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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 facilitate 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 asterisk15 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 Issue
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 1-3".

· Any interaction between different covered methods should be adequately explained in the text, and in an appropriate manner.
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 1.482-5(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 1.482-5(b)(2).

15 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.

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# 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 NON-IRS 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 Date

Term

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. 2015-41 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. 2015-41 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. 2015-41 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:

Party

Parent'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 taxpayer
identification number of that parent or owner for income tax purposes in its country of residence;

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. 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 NON-U.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
Appendix 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. 2015-41.

## 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. 2015-41 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
issues 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. 2015-41) 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
2015-41 (including any proposals to use particular Covered Method(s)), made in conjunction 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

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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 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 allocation17 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 Non-U.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 Non-U.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. 2015-41; 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. 2015-41. Annual Reports for multiple APA Tax Years may be combined, provided
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. 2015-41. 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.

17 As used in this APA, "income allocation" includes allocation of loss.

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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 Non-U.S. Covered Entity, the Financial Statements together with the additional statements specified
in paragraph 6(f)(ii).

[]* For every U.S. Covered Entity, the Financial Statements together with the additional statements specified in paragraph
6(f)(i).

[]* For every Non-U.S. Covered Entity, the Financial Statements together with the additional statements specified in
paragraph 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 self-certification for that U.S. Covered Entity's Financial Statements, as defined in paragraph 6(f)(iii).

[] A self-certification 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 FINANCIAL
STATEMENTS.

ii. For each Non-U.S. Covered Entity, the additional statements consist of the following statement(s):

[] An audit opinion for that Non-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 Non-U.S. Covered Entity's Financial Statements, as defined in paragraph 6(f)(iii).

[] A self-certification for that Non-U.S. Covered Entity's Financial Statements, as defined in paragraph 6(f)(iii).

[] A self-certification for that Non-U.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 NON-U.S. COVERED ENTITY'S FINANCIAL
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 self-certification 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 consolidated
Financial Statements for that entity's direct or indirect parent according to workpapers provided with the attestation;

(2) The workpapers referred to in paragraph 6(f)(iii)(D)(1), which must demonstrate the consolidation of the Covered
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).

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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 first-hand 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 first-hand knowledge.

[Facts attested to.]

[Signature]

g. In accordance with section 7.04 of Rev. Proc. 2015-41, 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. 2015-41. Compliance with this
subparagraph constitutes compliance with the record-maintenance 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 1.482-1(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. 2015-41,
appear in Appendix B. If any Critical Assumption has not been met, then Rev. Proc. 2015-41, 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
information" 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. 106-170 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. 2015-41, 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.

c. Certain terms used in this APA's body and appendices are defined as follows:

Term

Definition

Annual Report

A report within the meaning of Rev. Proc. 2015-41, section 7.02.

Advance Pricing

An "advance pricing agreement" within the meaning of Rev. Proc. 2015-41, section 2.02.

Agreement, or "APA"

Unless context indicates otherwise, "this APA" or "the APA" denotes the particular APA that is executed below.

APA Records

(Defined in Appendix C.)

APA Request

U.S. Taxpayer's request for this APA, which was dated #DATE, including any amendments or supplemental or additional information thereto (including but not limited to any responses to due diligence questions).

Critical Assumptions

(Defined in paragraph 7.)

Financial Statements

Balance 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.

Non-U.S. Group

In any APA Tax Year, Worldwide Group members that are not U.S. persons.

Parties

(Defined in the Recitals near the start of this APA.)

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Term

Definition

Pub. L. 106-170

The 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. Group

In any APA Tax Year, Worldwide Group members that are U.S. persons.

Worldwide Group

In any APA Tax Year, U.S. Taxpayer and all organizations, trades, businesses, entities, or branches (whether or not incorporated, organized in the United States, or affiliated) owned or controlled directly or indirectly 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. 2015-41 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:NCA534-01
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).

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

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# 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
Adjustment 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
standard, 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 Non-U.S. Covered Entity(ies) are:

\# LIST OF EACH NON-U.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,
ADDRESS, AND PHONE.

The term "Non-U.S. Taxpayer" includes collectively all Non-U.S. Covered Entities and any other entities that are in a common
tax reporting group with a Non-U.S. Covered Entity.

The term "Covered Entities" includes both the U.S. Covered Entities and the Non-U.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.

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.

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Type of Method;
Results Tested

Point or
Range

Testing 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 1.482-5(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 1.482-5(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
#DESCRIPTION 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 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.

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[] 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 value-adding intra- group 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.

[] 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 development 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 certain
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 subsection
(d) below. The second is from #Y to #Z inclusive and applies to the term test described in subsection (d) below.

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[] 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 inclusiveand 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.

[] #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 Effective 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 three-year 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.

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## 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 ALLOCA-
TION 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 EXAMINATION TEAM.

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 1.482-7(b)(1)(ii)) within the meaning of U.S. Treasury
Regulations section 1.482-4. That pricing will not be subject to periodic adjustments by the IRS, during or after the APA Term,
under U.S. Treasury Regulations section 1.482-4(f)(2) or (6).

[] This Covered Method addresses the pricing for a platform contribution transaction ("PCT"). That PCT will not be treated as
☐

a Trigger PCT within the meaning of U.S. Treasury Regulations section 1.482-7(i)(6)(i) for purposes of making periodic
adjustments, during or after the APA Term, under U.S. Treasury Regulations section 1.482-7(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.
Taxpayer and Non-U.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 Issue(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 financial
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
application 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 adjustment, the
annual adjustment is considered to be zero.

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B. Next, apply paragraphs (i) and (ii) above to the Tested Party's financial results as adjusted by any nonzero annual adjustment,
under the assumption that only the term test applies to those results. Any required adjustment under this application 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 Adjustment
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
otherwise provided in Rev. Proc. 2015-41 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
associated 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
Appendix 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 1.482-1(g)(3) as amplified by Rev. Proc. 99-32 or any successor revenue
procedure. 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 #NON-U.S. ENTITY, which will be referred to
here as "U.S. Entity" and "Non- U.S. Entity", respectively. An intercompany payable will be established between U.S. Entity
and Non-U.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. federal 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.

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[] 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 1.482-2(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. 99-32 or any successor revenue procedure, 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 90-day period, such amount, on the last
day of such period, will be deemed (1) to be paid between U.S. Entity and Non-U.S. Entity in satisfaction of the payable, and (2) to be paid
(directly or indirectly, as specified below) between U.S. Entity and Non-U.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 Non-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 U.S. Entity to Non-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 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 non-U.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 non-U.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 non- U.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 non- 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 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 section
1.482-1(g) and Rev. Proc. 99-32.

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 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 ADJUSTMENT FROM THE APA
PRIMARY ADJUSTMENT (OR LACK OF ONE) FOR EACH SUCH COVERED METHOD. #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 non-interest- bearing
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 "non-interest-bearing 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.)

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Term

Definition

Arm's Length Range

With 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 Standard

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 Non-U.S. Taxpayer.

Berry ratio

The 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 Method

A 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 1.482-1(b).)

Critical Assumption fails, failure of a Critical Assumption Early Termination

A Critical assumption "fails" when the Critical Assumption has not been met. This situation is referred to as the "failure" of the Critical Assumption. A 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 conditions of this APA, (iii) a cancellation of the APA under Rev. Proc. 2015-41, 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. 2015-41, 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.

Gross profit

Sales revenue, less cost of goods sold for the relevant business activity.

Gross profit margin

gross profit, divided by sales revenue

Gross profit markup

gross profit, divided by cost of goods sold for the relevant business activity

Gross services margin

In 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 markup

In 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.

IFRS

International Financial Reporting Standards.

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Term

Definition

Invested capital

Operating assets, less non-interest-bearing liabilities used in the relevant business activity.

IRS

The Internal Revenue Service, an agency of the U.S. government.

IFRS

International Financial Reporting Standards.

Last Effective APA Covered Year

For a particular Covered Method, the last APA Covered Year for which this APA remains effective 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

For a particular Covered Method, and with reference to a particular set of APA Covered

APA

Years that is defined as a subterm, the last APA Covered Year in the subterm for which this

Subterm Covered Year

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 costs

The ratio of operating profit to total costs.

Median

With 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.

Non-U.S. Taxpayer

(Defined in section 1 of this Appendix A.)

Non-U.S. Covered Entity(ies)

(Defined in section 1 of this Appendix A.)

OECD Guidelines

Organisation for Economic Co-operation and Development, OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (July 2017).

OECD PE Report

Organisation for Economic Co-operation and Development, 2010 Report on Attribution of Profit to Permanent Establishments (July 22, 2010).

Operating assets

The 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, short-term investments, deferred tax assets, tax refunds, intangibles, investments in subsidiaries, portfolio investments.

Operating expenses

All 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 ex- penses not related to the operation of the relevant business activity. Operating expenses nor- mally include, for example, expenses associated with advertising, promotion, sales, marketing, warehousing and distribution, administration, and a reasonable allowance for depreciation. For U.S. Taxpayer, foreign income taxes are defined in U.S. Treasury Regulations section 1.902- 1(a)(7).

Operating margin

The ratio of operating profit to sales revenue.

Operating profit

Sales revenue, less cost of goods sold for the relevant business activity, less operating ex- penses.

Rev. Proc. 99-32

A revenue procedure issued by the IRS that is cited as Rev. Proc. 99- 32, 1999-2 C.B. 296.

Rev. Proc. 2015-41

A revenue procedure issued by the IRS that is cited as Rev. Proc. 2015-41, 2015-35 I.R.B 263.

Repatriable Issue

(Defined in section 6 of this Appendix A.)

Relevant Financial Data

With 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 as- sets

With 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 di- vided by the time- weighted average operating assets over the testing period.

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Term

Definition

For this purpose, the time-weighted 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 sim- ple average of the operating asset levels at the start and end of the APA Tax Year correspond- ing 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 corresponding 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 time- weighted average operating assets over the testing period is [(10+16)/2]*(183/365) + [(16+22)/2]*(366/365) = 25.5699. The return on operating assets is then 3.4/25.5699 = 13.30%.

Rollback Period

(This term, if applicable, is defined in section 2 of this Appendix A.)

Sales revenue

Total receipts from sale of goods and provision of services, less returns and allowances, for the relevant business activity.

Tax year

A 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 period

The time period over which financial results are tested (see section 4 of Appendix A to this APA).

Total costs

Cost of goods sold for the relevant business activity, plus operating expenses.

U.S. Treasury Regula- tions

Tax 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 Date

The 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. GAAP

U.S. generally accepted accounting principles.

U.S. return

Any 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.)

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# 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 theeffectiveness 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.

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# 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. 2015-41.

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
employed, contractual terms, markets, and economic conditions faced in relation to the Covered Issues during such APA
Covered 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
estimation 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. Taxpayer 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
disregarded 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;

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 established;

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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 book-tax differences, as reflected on Schedule M-1 or Schedule M-3 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
appropriate 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
Statements. The intent of this requirement is that the analysis submitted should provide a clear, complete, detailed, and
self-contained 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
objective, 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).

[]* 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. 2015-41, sections 7.02(8) and (9).

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# 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.

Internal Revenue Service

APMA Case No.

Large Business and International Division

Reviewer

Treaty &amp; Transfer Pricing Operations

Team Leader

Advance Pricing Mutual Agreement Program

Economist

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 (date-to-date, 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 Person

Name

If necessary, include a current Form 2848 for

Title

the Notice Person

Address

City/State/Zip

Phone/Fax

Email

Current Representative, if any

Name

Include a current Form 2848 for the

Title

representative

Address

City/State/Zip

Phone/Fax

Email

Date Annual Report Filed (to be filled in by APMA):

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# 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
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.

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 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.

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 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
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 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.

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
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.

F.R .- Federal Register.

FUTA-Federal Unemployment Tax Act.

FX-Foreign corporation.

G.C.M .- Chief Counsel's Memorandum.

GE-Grantee.

TFE-Transferee.

CFR-Code of Federal Regulations.

GP-General Partner.

TFR-Transferor.

CI-City.

GR-Grantor.

T.I.R .- Technical Information Release.

TP-Taxpayer.

Ct.D .- Court Decision.

I.R.B .- Internal Revenue Bulletin.

TR-Trust.

CY-County.

LE-Lessee.

TT-Trustee.

D-Decedent.

LP-Limited Partner.

U.S.C .- United States Code.

DC-Dummy Corporation.

LR-Lessor.

X-Corporation.

DE-Donee.

Del. Order-Delegation Order.

Nonacq .- Nonacquiescence.

O Organization.

DR-Donor.

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.

C-Individual.

T.D .- Treasury Decision.

C.B .- Cumulative Bulletin.

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.

BK-Bank.

B.T.A .- Board of Tax Appeals.

COOP-Cooperative.

IC-Insurance Company.

M-Minor.

Y-Corporation.

Z-Corporation.

DISC-Domestic International Sales Corporation.

E-Estate.

EE-Employee.

E.O .- Executive Order.

ER-Employer.

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## Numerical Finding List1

Bulletin 2019-15

Action on Decision:

2019-1, 2019-08 I.R.B. 569

### Announcements:

2019-1, 2019-06 I.R.B. 566
2019-2, 2019-12 I.R.B. 910
2019-3, 2019-15 I.R.B. 965

### Notices:

2019-01, 2019-02 I.R.B. 275
2019-02, 2019-02 I.R.B. 281
2019-03, 2019-03 I.R.B. 350
2019-04, 2019-02 I.R.B. 282
2019-05, 2019-02 I.R.B. 283
2019-06, 2019-03 I.R.B. 353
2019-07, 2019-09 I.R.B. 740
2019-08, 2019-03 I.R.B. 354
2019-09, 2019-04 I.R.B. 403
2019-10, 2019-13 I.R.B. 913
2019-11, 2019-05 I.R.B. 430
2019-13, 2019-08 I.R.B. 580
2019-16, 2019-10 I.R.B. 763
2019-17, 2019-12 I.R.B. 907
2019-18, 2019-13 I.R.B. 915
2019-19, 2019-12 I.R.B. 907
2019-20, 2019-14 I.R.B. 927
2019-21, 2019-14 I.R.B. 927
2019-22, 2019-14 I.R.B. 931
2019-23, 2019-15 I.R.B. 941
2019-24, 2019-14 I.R.B. 932
2019-25, 2019-15 I.R.B. 942
2019-26, 2019-15 I.R.B. 943

### Proposed Regulations:

REG-104259-18, 2019-02 I.R.B. 300
REG-104352-18, 2019-03 I.R.B. 357
REG-106089-18, 2019-05 I.R.B. 431
REG-134652-18, 2019-09 I.R.B. 747
REG-141739-08, 2019-09 I.R.B. 757

### Revenue Procedures:

2019-1, 2019-01 I.R.B. 1
2019-2, 2019-01 I.R.B. 106
2019-3, 2019-01 I.R.B. 130
2019-4, 2019-01 I.R.B. 146
2019-5, 2019-01 I.R.B. 230
2019-6, 2019-02 I.R.B. 284
2019-7, 2019-01 I.R.B. 268
2019-8, 2019-03 I.R.B. 347
2019-9, 2019-02 I.R.B. 293
2019-10, 2019-02 I.R.B. 296
2019-11, 2019-09 I.R.B. 742
2019-12, 2019-04 I.R.B. 401

Revenue Procedures :- Continued

2019-13, 2019-09 I.R.B. 744
2019-14, 2019-15 I.R.B. 948
2019-15, 2019-14 I.R.B. 939

## Revenue Rulings:

2019-03, 2019-02 I.R.B. 272
2019-04, 2019-07 I.R.B. 567
2019-05, 2019-11 I.R.B. 766
2019-06, 2019-14 I.R.B. 919
2019-07, 2019-10 I.R.B. 761
2019-08, 2019-14 I.R.B. 923
2019-09, 2019-14 I.R.B. 925

## Treasury Decisions:

9844, 2019-11 I.R.B. 781
9845, 2019-08 I.R.B. 570
9846, 2019-09 I.R.B. 583
9847, 2019-09 I.R.B. 670
9848, 2019-11 I.R.B. 897
9850, 2019-12 I.R.B. 904
9851, 2019-14 I.R.B. 917

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018-27 through 2018-52 is in Internal Revenue Bulletin
2018-52, dated December 27, 2018.

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# Finding List of Current Actions on Previously Published Items1

Bulletin 2019-15

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# Internal Revenue Service Washington, DC 20224

Official Business
Penalty for Private Use, $300

# 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 at www.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.