Internal Revenue Bulletin 2015-9 (PDF rendition): IRS Announcements

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Proc. 2015–20, page 694.
Revenue Procedure 2015–20 permits small business taxpay-
ers to make certain tangible property changes in methods of
accounting with an adjustment under § 481(a) of the Internal
Revenue Code that takes into account only amounts paid or
incurred, and dispositions, in taxable years beginning on or
after January 1, 2014. In addition, for their first taxable year
that begins on or after January 1, 2014, small business tax-
payers are permitted to make certain tangible property
changes without filing a Form 3115. This revenue procedure
also requests written comments by April 21, 2015, on whether
it is appropriate to increase the de minimis safe harbor limit
provided in § 1.263(a)–1(f)(1)(ii)(D) of the Income Tax Regula-
tions for a taxpayer without an applicable financial statement to
an amount greater than $500, and, if so, what amount.
EMPLOYEE PLANS
Notice 2015–19, page 690.
This notice provides guidance on the corporate bond monthly
yield curve, the corresponding spot segment rates used under
§ 417(e)(3), and the 24-month average segment rates under
§ 430(h)(2) of the Internal Revenue Code. In addition, this
notice provides guidance as to the interest rate on 30-year
Treasury securities under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the 30-year Treasury
weighted average rate under § 431(c)(6)(E)(ii)(I). The rates in
this notice reflect the application of § 430(h)(2)(C)(iv), which
was added by the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP-21) and amended by
section 2003 of the Highway and Transportation Funding Act of
2014, Public Law 113–159 (HATFA).
EMPLOYMENT TAX
Announcement 2015–8, page 698.
The Announcement addresses the application of the govern-
ment’s win in United States v. Quality Stores, Inc., 134 S.Ct.
1395 (2014), to claims for refund of employment taxes. The
primary intent of the Announcement is to inform taxpayers that
the Service will take no further action on appeal requests that
were suspended pending the resolution of Quality Stores. The
Announcement tells taxpayers who to contact if the appeal
request included an additional or different basis for the claim
for refund, or if the claim for refund concerned payments that
satisfied Revenue Ruling 90 –72. The Announcement also in-
forms taxpayers that the Service will continue to disallow
claims for refund of Federal Insurance Contributions Act (FICA),
Railroad Retirement Tax Act (RRTA), and Federal Unemploy-
ment Tax Act (FUTA) taxes paid with respect to severance
payments that are not otherwise excluded from such taxes
pursuant to Revenue Ruling 90 –72.
Notice 2015–15, page 687.
This notice contains a proposed revenue procedure providing
guidance to employers on employee consents used to support
a claim for refund under § 6402 of the Internal Revenue Code
and § 31.6402(a)–2 of the Employment Tax Regulations for
overpaid taxes under the Federal Insurance Contributions Act
(FICA) and the Railroad Retirement Tax Act (RRTA).
Finding Lists begin on page ii.
Bulletin No. 2015–9
March 2, 2015

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
March 2, 2015Bulletin No. 2015–9

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 162.—Trade or
business expenses
Procedures are provided permitting small busi-
ness taxpayers to make certain tangible property
changes in methods of accounting with an adjust-
ment under § 481(a) of the Internal Revenue Code
that takes into account only amounts paid or in-
curred, and dispositions, in taxable years beginning
on or after January 1, 2014. In addition, for their first
taxable year that begins on or after January 1, 2014,
small business taxpayers are permitted to make cer-
tain tangible property changes without filing a Form
3115. See Rev. Proc. 2015–20, page 694.
Section 263.—Capital
expenditures
Procedures are provided permitting small busi-
ness taxpayers to make certain tangible property
changes in methods of accounting with an adjust-
ment under § 481(a) of the Internal Revenue Code
that takes into account only amounts paid or in-
curred, and dispositions, in taxable years beginning
on or after January 1, 2014. In addition, for their first
taxable year that begins on or after January 1, 2014,
small business taxpayers are permitted to make cer-
tain tangible property changes without filing a Form
3115. See Rev. Proc. 2015–20, page 694.
Section 263A.—
Capitalization and inclusion
in inventory costs of
certain expenses
Procedures are provided permitting small busi-
ness taxpayers to make certain tangible property
changes in methods of accounting with an adjust-
ment under § 481(a) of the Internal Revenue Code
that takes into account only amounts paid or in-
curred, and dispositions, in taxable years beginning
on or after January 1, 2014. In addition, for their first
taxable year that begins on or after January 1, 2014,
small business taxpayers are permitted to make cer-
tain tangible property changes without filing a Form
3115. See Rev. Proc. 2015–20, page 694.
Section 481.—Adjustments
required by changes in
method of accounting
Procedures are provided permitting small busi-
ness taxpayers to make certain tangible property
changes in methods of accounting with an adjust-
ment under § 481(a) of the Internal Revenue Code
that takes into account only amounts paid or in-
curred, and dispositions, in taxable years beginning
on or after January 1, 2014. In addition, for their first
taxable year that begins on or after January 1, 2014,
small business taxpayers are permitted to make cer-
tain tangible property changes without filing a Form
3115. See Rev. Proc. 2015–20, page 694.
March 2, 2015Bulletin No. 2015–9
686

Part III. Administrative, Procedural, and Miscellaneous
Employee Consents
Notice 2015–15
PURPOSE AND SCOPE
This notice contains a proposed reve-
nue procedure providing guidance to em-
ployers on employee consents used to
support a claim for refund under § 6402 of
the Internal Revenue Code and § 31.6402(a)–2
of the Employment Tax Regulations for
overpaid taxes under the Federal Insur-
ance Contributions Act (FICA) and the
Railroad Retirement Tax Act (RRTA).
Questions have arisen concerning what
information must be provided in an em-
ployee consent and whether an employee
consent may be requested, furnished, and
retained in an electronic format. The pro-
posed revenue procedure clarifies that, in
addition to providing the relevant name,
address, and taxpayer identification num-
ber, a valid employee consent must iden-
tify the basis of the claim for refund and
be signed by the employee under penalties
of perjury. The proposed revenue proce-
dure also provides guidance as to what
constitutes “reasonable efforts” to secure
an employee consent when a consent is
not obtained.
The proposed revenue procedure per-
mits, but does not require, the employee
consent to be requested, furnished, and
retained in an electronic format, as an
alternative to a paper format. The pro-
posed revenue procedure is not intended
to require employers to solicit new em-
ployee consents for those requested prior
to the date of publication of the final rev-
enue procedure in the Internal Revenue
Bulletin. However, an employer may rely
on this proposed revenue procedure for
employee consents requested before the
date that the final revenue procedure is
published.
REQUEST FOR COMMENTS
The IRS requests comments on this
revenue procedure. In particular, the IRS
requests comments regarding the specific
requirements for a request for a consent
and for the employee consent itself, the
requirements for electronic employee con-
sents, and the steps that will constitute
“reasonable efforts” to obtain an em-
ployee consent. In particular, comments
are requested on ways to formulate re-
quirements that advance the goal of mak-
ing the process more efficient while pro-
tecting the interests of employees.
Comments may be submitted on or be-
fore May 31, 2015 to: Internal Revenue
Service, CC:PA:LPD:PR (Notice 2015–
15), Room 5203, P.O. Box 7604, Ben
Franklin Station, Washington, DC 20224.
Comments may also be hand-delivered
Monday through Friday between the hours
of 8:00 a.m. to 4:00 p.m. to the Courier’s
Desk, Internal Revenue Service, 1111 Con-
stitution Avenue, NW, Washington, DC.
Attn: CC:PA:LPD:PR (Notice 2015–15).
Comments may also be submitted elec-
tronically via the following email address:
Notice.Comments@irscounsel.treas.gov.
Please include “Notice 2015–15” in the
subject line of any electronic submission.
DRAFTING INFORMATION
For further information regarding this
notice contact Cynthia McGreevy of the
Office of the Associate Chief Counsel
(Tax Exempt and Government Entities).
Mrs. McGreevy may be contacted at 202-
317-4774 (not a toll-free call).
PROPOSED REVENUE PROCEDURE
SECTION 1. PURPOSE
.01 The purpose of this revenue proce-
dure is to provide guidance to employers
on the requirements for employee con-
sents used by an employer to support a
claim for refund of overpaid taxes under
the Federal Insurance Contributions Act
(FICA) and the Railroad Retirement Tax
Act (RRTA) pursuant to § 6402 of the
Internal Revenue Code and § 31.6402(a)–2
of the Employment Tax Regulations.
FICA taxes include the old-age, survivors,
and disability insurance taxes imposed on
employees under § 3101(a) and on em-
ployers under § 3111(a), also known as
social security taxes, and the hospital in-
surance tax imposed on employees under
§ 3101(b) and on employers under § 3111(b),
also known as Medicare taxes. Under
RRTA, railroad employment is subject to
a system of taxes separate and distinct
from the taxes imposed under FICA,
which covers most other employees. Tier
1 RRTA taxes, imposed under §§ 3201(a),
3211(a), and 3221(a), provide benefits
equivalent to social security and Medicare
benefits.
.02 This revenue procedure clarifies the
basic requirements for a request for a con-
sent and for the employee consent itself,
including the requirement that an em-
ployee consent must include the basis for
the claim for refund and be signed by the
employee under penalties of perjury. In
addition, this revenue procedure permits
an employee consent to be requested, fur-
nished, and retained in an electronic for-
mat as an alternative to a paper format. It
also contains guidance concerning what
constitutes “reasonable efforts” if an em-
ployee consent is not secured in order to
permit the employer to claim a refund of
the employer share of overpaid FICA or
RRTA taxes.
SECTION 2. SCOPE
.01 This revenue procedure applies to
employee consents that are used by an
employer to support a claim for refund of
overpaid FICA or RRTA taxes. Section
31.6402(a)–2 provides rules under which
a refund claim for an overpayment of
FICA or RRTA tax may be made. For
ease of reading, the remainder of the rev-
enue procedure will discuss FICA taxes
but this revenue procedure applies equally
to RRTA taxes.
.02 Any references to Medicare tax or
FICA tax in this revenue procedure do not
include Additional Medicare Tax imposed
by § 3101(b)(2). Under § 3102(f), an em-
ployer is responsible for withholding the
0.9% Additional Medicare Tax from the
wages it pays to an employee in excess of
$200,000 in a calendar year. However,
under § 31.6402(a)–2(a)(1)(iii), employ-
ers may claim a refund of overpaid Addi-
tional Medicare Tax only if the employer
did not withhold the overpaid Additional
Medicare Tax from the employee’s
wages. An employee may claim a refund
of overpaid Additional Medicare Tax on
Form 1040, U.S. Individual Income Tax
Return, or, if the employee has filed Form
1040, on Form 1040X, Amended U.S. In-
Bulletin No. 2015–9March 2, 2015
687

dividual Income Tax Return. Thus, the
rules for employee consents are not appli-
cable to overpayments of Additional
Medicare Tax.
SECTION 3. TERMS
For purposes of this revenue procedure–
.01 “Written statement” means a state-
ment required by § 31.6402(a)–2(a)(2)(ii)
with respect to amounts collected in a year
prior to the calendar year in which the
credit or refund is claimed, certifying that
the employee has not made any previous
claims (or the claims were rejected) and
will not make any future claims for refund
or credit of the amount of the overcollec-
tion.
.02 “Email address” refers to any em-
ployeeemailaddressonasecure
employer-provided email network pro-
vided to its employee in the regular course
of business. To the extent that a personal
email address is used in lieu of, or in
addition to, an employee email address, an
email address includes only the most re-
cent personal email address provided by
the employee to the employer that is
maintained in an employer’s personnel re-
cords in the regular course of business. It
does not include an email address ob-
tained from a third-party source other than
one obtained from an authorized represen-
tative of the employee.
.03 “Employee” includes both current
and former employees.
.04 “Last known address” means the
employee’s address of record in the em-
ployer’s personnel records, or as updated
by any notification of change of address
from the United States Postal Service.
.05 “Signature” includes an original,
facsimile (fax), or other electronic signa-
ture. A fax signature may be transmitted
either online or telephonically (i.e., deliv-
ered via traditional fax machine). An elec-
tronic signature must meet the require-
ments stated in section 6 of this revenue
procedure, as modified by any subse-
quently published guidance.
SECTION 4. BACKGROUND
.01 In general, employers may choose
to correct FICA tax overpayment errors
by either making an interest-free adjust-
ment or filing a claim for refund. Section
31.6402(a)–2 provides rules under which
a refund claim for an overpayment of
FICA tax may be made. The claim must
be filed on the form prescribed by the IRS
and must designate the return period to
which the claim relates, explain in detail
the grounds and facts relied upon to sup-
port the claim, and set forth such other
information as may be required by
§ 31.6402(a)–2 and by the instructions
relating to the form used to make the
claim. Employers use the employment tax
“X” form (e.g., Form 941–X, Adjusted
Employer’s QUARTERLY Federal Tax
Return or Claim for Refund) correspond-
ing to the employment tax return filed
(e.g., Form 941, Employer’s QUAR-
TERLY Federal Tax Return) to claim re-
funds. For examples showing how the
claim for refund process operates, see
Rev. Rul. 2009 –39, 2009 –52 I.R.B. 951,
which applies the regulations to different
situations.
.02 An employer may not receive a
refund of the employer share of overpaid
FICA tax without making reasonable ef-
forts to protect its employee’s interests.
See§ 31.6402(a)–2; Rev. Rul. 81–310,
1981–2 C.B. 241;Atlantic Department
Stores, Inc. v. United States, 557 F.2d 957
(2d Cir. 1977). An employer has a duty to
make reasonable efforts to protect its em-
ployees’ interests in any employee share
oftherefund.Section31.6402(a)–
2(a)(1)(ii) specifically provides that no re-
fund for the employer share of the over-
paid FICA taxes will be allowed unless
the employer has first repaid or reim-
bursed its employee or has secured the
employee’s consent to the allowance of
the claim for refund and includes a claim
for the refund of such employee tax. Sec-
tion 31.6402(a)–2(a)(2) generally requires
the employer to certify, as part of the
claim process, that the employer has re-
paid or reimbursed the employee share of
the overpayment of FICA tax to the em-
ployee or has secured the written consent
of the employee to allowance of the re-
fund or credit. For refund claims for em-
ployee tax overcollected in prior years, the
employer must also certify that it has ob-
tained the employee’s written statement
confirming that the employee has not
made any previous claims (or the claims
were rejected) and will not make any fu-
ture claims for refund or credit of the
amount of the overcollection. However,
these requirements do not apply to the
extent that the taxes were not withheld
from the employee. Nor do these require-
ments apply if, after the employer’s rea-
sonable efforts to obtain the employee’s
consent (including any required written
statement), the employer cannot locate the
employee or the employee does not fur-
nish either the employee consent or a re-
sponse indicating that the employee is not
authorizing the employer to claim a re-
fund of FICA taxes on his or her behalf. In
these cases, the employer may claim a
refund of the overpaid employer share of
the tax but may not obtain a refund of the
employee share. UnderChicago Milwau-
kee Corp. v. United States, 40 F.3d 373,
375 (Fed. Cir. 1994), an employer need
not repay or reimburse its employees or
obtain the employees’ consents for the
filing of a refund claim prior to filing the
claim in order for the claim to be valid.
However, the employer must repay or re-
imburse its employees or obtain the em-
ployees’ consents before the IRS can
grant the claim.
.03 If an employer files a claim for
refund based on a certification that con-
sents were secured from the employees,
and the IRS grants the refund, the IRS will
refund the taxes (including any applicable
interest paid pursuant to § 6611) to the
employer, which will then give each em-
ployee his or her share.
.04 Under § 31.6402(a)–2(a)(2)(i), the
employer must retain the employee con-
sent (including any required written state-
ment) as part of the employer’s records.
.05 Section 6061 provides that any re-
turn, statement, or other document re-
quired to be made under any provision of
the Code or regulations be signed in ac-
cordance with forms or regulations pre-
scribed by the Secretary. Section 6065
requires that, except as otherwise pro-
vided by the Secretary, any such docu-
ment must contain or be verified by a
written declaration that it is made under
the penalties of perjury. To facilitate tax-
payers’ compliance with the verification
requirement of § 6065, the IRS has long
provided that an acceptable “penalties of
perjury statement” should be located im-
mediately above the required signature
and include substantially the following
language: “I declare, under penalties of
perjury, that I have examined the above
March 2, 2015Bulletin No. 2015–9
688

statements and information and to the best
of my knowledge and belief they are true,
correct, and complete.”
.06 Under § 31.6001–1 and § 31.6001–2,
an employer that claims a refund must
retain a complete and detailed record with
respect to the tax to which the claim re-
lates, including a copy of any statement or
other documents, for as long as the con-
tents may become material in the admin-
istration of any internal revenue law, but
not less than four years after the date the
claim is filed.
SECTION 5. REQUIREMENTS FOR A
REQUEST FOR A CONSENT AND
REQUIREMENTS FOR AN
EMPLOYEE CONSENT
.01 In general, a request for a consent
may be solicited on paper or in an elec-
tronic format. The request must clearly
inform the employee of the purpose of the
employee consent. It must provide a name
and contact information for any questions
by the employee and must give a reason-
able period of time to respond, which pe-
riod shall not be less than 45 days from
the date of the request. A request for a
consent may include an express presump-
tion that if an employee’s response has not
been received by the employer during this
time period, the employee will be consid-
ered to have refused to provide the em-
ployee consent. In no case, however, may
a failure to respond be deemed consent. A
request for consent may also include a
request that the employee keep the em-
ployer informed about any change in
mailing address or email address. Finally,
it must clearly state that the employee will
be repaid or reimbursed the employee
share of the overpayment (plus any inter-
est allocable to the employee share) to the
extent it is refunded by the IRS.
.02 The employer may furnish a paper
request for a consent by personal delivery
or by mail to the employee’s last known
address by the United States Postal Ser-
vice or a designated delivery service un-
der § 7502(f) . An electronic request for a
consent may be sent to the employee’s
email address in accordance with section
6 of this revenue procedure.
.03 An employee consent must meet
the following requirements:
(1) Contain the name, address, and so-
cial security number of the employee;
(2) Contain the name, address, and em-
ployer identification number of the em-
ployer;
(3) Contain the tax period(s), type of
tax (e.g., social security and Medicare
taxes), and the amount of tax for which
the employee consent is provided;
(4) Affirmatively state that the em-
ployee authorizes the employer to claim a
refund for the overpayment of the em-
ployee share of tax;
(5) For amounts collected in a prior
year, include the employee’s written state-
ment;
(6) Identify the basis of the claim (e.g.,
request for refund of the social security
and Medicare taxes withheld with regard
to excess transit benefits provided in 2014
due to a retroactive legislative change);
and
(7) Be dated and contain the employ-
ee’s signature under penalties of perjury.
The penalties of perjury statement should
be located immediately above the required
signature.
.04 The request for a consent and the
employee consent itself (including any re-
quired written statement), or the employ-
ee’s response indicating that the employee
does not authorize the employer to claim a
refund of FICA taxes on his or her behalf,
must be retained as long as their contents
may be material in the administration of
any internal revenue law, but not less than
four years after the date the claim is filed.
Copies must be submitted to the IRS if
requested.
SECTION 6. ELECTRONIC
COMMUNICATIONS, EMPLOYEE
CONSENTS, AND RECORD
RETENTION PERMITTED
.01 This revenue procedure permits an
employer to establish an electronic system
to request, furnish, and retain employee
consents, including permitting employees
to submit an employee consent by fax. It
also permits the retention in an electronic
format of requests and employee consents
submitted in a paper format. The rules for
furnishing and retaining employee con-
sents also apply to an employee’s re-
sponse indicating that the employee does
not authorize the employer to claim a re-
fund of FICA taxes on his or her behalf.
Electronic information obtained under this
revenue procedure is subject to the basic
requirements that the IRS considers to be
essential for record retention set forth in
Rev. Proc. 97–22, 1997–1 C.B. 652, Rev.
Proc. 98 –25,1998 –1 C.B. 689, and any
subsequently published guidance.
.02 The electronic system must be rea-
sonably accessible to the employee and
must be reasonably designed to preclude
anyone other than the employee from giv-
ing the employee consent. It must provide
the electronic request for a consent to the
employee in a manner no less understand-
able than a written paper document.
.03 Electronic records and signatures
are given the same legal effect as their
paper counterparts. Any signature should
be located immediately below the re-
quired penalties of perjury statement. Un-
til further guidance is published, an elec-
tronic signature is acceptable as provided
below:
(1) A person (i.e.,the signer) must use
an acceptable electronic form of signa-
ture; for purposes of this revenue proce-
dure, this includes a typed name that is
within or at the end of an electronic re-
cord, such as typed into a signature block
or other acceptable electronic form, or as
otherwise identified in IRS published
guidance, publications, forms, instruc-
tions, or on the irs.gov website;
(2) The electronic form of signature
must be executed by a person with the
intent to sign the electronic record (e.g.,to
indicate a person’s approval of the infor-
mation contained in the electronic record);
(3) The electronic form of signature
must be attached to or associated with the
electronic record being signed;
(4) There must be a means to identify
and authenticate a particular person as the
signer; and
(5) There must be a means to preserve
the integrity of the signed record.
.04 No employee may be required to
provide an employee consent in an elec-
tronic format. Thus, the employee must be
given the option to provide the employee
consent in a paper format. Upon request,
the employer must provide a paper copy
of any electronic communications to the
employee, including the request for a con-
sent.
.05 Any electronic system used for pur-
poses of obtaining employee consents
must inform the employee that he or she
must make the declaration contained in
Bulletin No. 2015–9March 2, 2015
689

the penalties of perjury statement and that
the declaration is made by signing the
employee consent.
.06 Upon request by the IRS, the em-
ployer must supply a hard copy of the
electronic employee consent or a response
indicating that the employee was not au-
thorizing the employer to claim a refund
of FICA taxes on his or her behalf. The
employer must include a statement that, to
the best of the employer’s knowledge and
belief, the electronic employee consent or
response was furnished by the named em-
ployee.
SECTION 7. REASONABLE EFFORTS
.01 Generally, if the employer has not
repaid or reimbursed an employee, a re-
fund for the employer share of the over-
paid FICA taxes will not be allowed un-
less the employer has secured the
employee’s consent and included a claim
for the refund of such employee tax. How-
ever, these requirements do not apply if,
after the employer’s reasonable efforts to
obtain the employee’s consent, the em-
ployer cannot locate the employee or the
employee does not furnish either the em-
ployee consent or a response indicating
that the employee is not authorizing the
employer to claim a refund of FICA taxes
on his or her behalf.
.02 The employer will be deemed to
have made reasonable efforts with respect
to a request for a consent if:
(1) The employer properly requests a
consent of the employee as provided in
this revenue procedure;
(2) A request for a consent sent elec-
tronically provides for an acknowledge-
ment of receipt of the email message. The
request must specifically ask the em-
ployee to acknowledge receipt of the re-
quest for a consent (e.g., by clicking on a
voting button (YES) or by sending a reply
message to the employer). A read-receipt
message is not sufficient;
(3) The employer retains a record of
mailing the request for a consent, record
of emailing the request for a consent (in-
cluding acknowledgement of receipt of
the email message), or record of personal
delivery to the employee who does not
furnish an employee consent, or a re-
sponse indicating that the employee was
not authorizing the employer to claim a
refund of FICA taxes on his or her behalf;
(4) In the event the mailing is undeliv-
erable, the employer makes an effort to
determine the employee’s current address
and, if a new address is discovered, the
employer delivers a request for a consent
in a paper format to the new address or
delivers a request for a consent by email
or by personal delivery, giving the em-
ployee not less than 45 days from the date
of the request to reply to the subsequent
request; and
(5) In the event of an email delivery
failure (e.g., the employer is notified that
the message the employer tried to send did
not reach the employee because of a prob-
lem with the email address) or in the event
that the employee does not acknowledge
receipt of the email message, the em-
ployer mails a request for a consent in a
paper format to the employee’s last
known address or provides a request for a
consent to the employee by personal de-
livery giving the employee not less than
45 days from the date of the request to
reply to the subsequent request.
SECTION 8. EFFECTIVE DATE
This revenue procedure applies to em-
ployee consents requested on or after [the
date of publication of the final revenue
procedure in the Internal Revenue Bulle-
tin]. This revenue procedure will not af-
fect the validity of any employee consent
received pursuant to a request made prior
to [the date of publication of the final
revenue procedure in the Internal Revenue
Bulletin].
SECTION 9. PAPERWORK
REDUCTION ACT
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 Office of Management and Budget
(OMB) control number. This revenue pro-
cedure does not impose any new informa-
tion collection burden. Thecollection of
information contained in this revenue
procedure is in § 31.6402(a)–2 of the
regulations which has been previously
approved by the OMB under control
number 1545-2097 and in the existing claim
forms (e.g., Forms 941–X, 941–X(PR),
943–X, 943–X(PR), 944 –X, 944 –X(PR),
944 –X(SP), and CT–1X).
The collection of information is re-
quired to obtain a refund of FICA taxes.
The likely respondents are employers and
employees. Books or records relating to a
collection of information must be retained
as long as their contents may become ma-
terial in the administration of any internal
revenue law, but, not less than four years
after the date the claim is filed. Generally,
tax returns and tax return information are
confidential, as required by § 6103.
SECTION 10. DRAFTING
INFORMATION
For further information regarding this
revenueprocedure,contactCynthia
McGreevy of the Office of the Associate
Chief Counsel (Tax Exempt and Govern-
ment Entities) at 202-317-4774 (not a toll-
free number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2015–19
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. Inaddition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate under
§ 431(c)(6)(E)(ii)(I). The rates in this notice
reflect the application of § 430(h)(2)(C)(iv),
which was added by the Moving Ahead for
Progress in the 21st Century Act, Public
Law 112–141 (MAP-21) and amended by
section 2003 of the Highway and Transpor-
tation Funding Act of 2014, Public Law
113–159 (HATFA).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
March 2, 2015Bulletin No. 2015–9
690

that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods. To
the extent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the
applicable percentage of the 25-year aver-
age segment rates for the period ending
September 30 of the year preceding the
calendar year in which the plan year be-
gins. However, an election may be made
under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. In accor-
dance with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from January
2015 data is in Table I at the end of this
notice. Thespot first, second, and third seg-
ment rates for the month of January 2015
are, respectively, 1.33, 3.46, and 4.40.
The 24-month average segment rates
determinedunder§430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) by the applicable per-
centage of the corresponding 25-year av-
erage segment rates. Section 2003(a) of
HATFA amended the applicable percent-
ages under § 430(h)(2)(C)(iv). This
change generally applies to plan years be-
ginning on or after January 1, 2013. How-
ever, pursuant to section 2003(e)(2) of
HATFA, a plan sponsor can elect not to
have the amendments made to the appli-
cable percentages by section 2003 of
HATFA apply to any plan year beginning
in 2013. These elections can be made ei-
ther for all purposes or, alternatively, for
purposes of determining the adjusted
funding target attainment percentage un-
der § 436. The 25-year average segment
rates for plan years beginning in 2012,
2013, 2014 and 2015 were published in
Notice 2012–55, 2012–36 I.R.B. 332, No-
tice 2013–11, 2013–11 I.R.B. 610, Notice
2013–58, 2013– 40 I.R.B. 294, and Notice
2014 –50, 2014 – 40 I.R.B. 590, respec-
tively.
For plan years beginning in years 2012
through 2017, pursuant to the changes
made by HATFA, the applicable mini-
mum percentage is 90% and the applica-
ble maximum percentage is 110%. These
applicable percentages are referred to as
HATFA applicable percentages. As de-
scribed in the preceding paragraph, a spe-
cial election is available for any plan year
beginning in 2013 under which this
change made by HATFA can be disre-
garded for all purposes or for limited pur-
poses. To the extent such an election is
made, the applicable minimum percentage
for a plan year beginning in 2013 is 85%
and the applicable maximum percentage
for that plan year is 115%. These applica-
ble percentages are referred to as MAP-21
applicable percentages.
The three 24-month average corporate
bond segment rates applicable for Febru-
ary 2015 without adjustment for the 25-
year average segment rate limits are as
follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
February 20151.234.105.18
Based on § 430(h)(2)(C)(iv) as amended
by section 2003 of HATFA, the 24-month
averages applicable for February 2015 ad-
justed for the HATFA applicable percent-
ages of the corresponding 25-year average
segment rates, are as follows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates, Based on the HATFA
Applicable Percentage of 25-Year
Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2014February20154.996.326.99
2015February20154.726.116.81
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation de-
scribed in section 431(c)(6)(A), based on
theplan’scurrentliability.Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 per-
cent below the weighted average of the
rates of interest on 30-year Treasury se-
curities during the four-year period ending
on the last day before the beginning of the
plan year. Notice 88 –73, 1988 –2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for January 2015 is 2.46 percent.
The Service has determined this rate as
Bulletin No. 2015–9March 2, 2015
691

the average of the daily determinations of
yield on the 30-year Treasury bond ma-
turing in November 2044. The following
rates were determined for plan years be-
ginning in the month shown below.
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
February20153.312.983.47
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for January 2015
are as follows:
First
Segment
Second
Segment
Third
Segment
1.333.464.40
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
March 2, 2015Bulletin No. 2015–9
692

Table I
Monthly Yield Curve for January 2015
Derived from January 2015 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.50.3120.54.1040.54.4460.54.5680.54.61
1.00.6121.04.1141.04.4461.04.5681.04.62
1.50.8821.54.1341.54.4561.54.5681.54.62
2.01.1222.04.1442.04.4562.04.5682.04.62
2.51.3322.54.1642.54.4562.54.5682.54.62
3.01.5123.04.1743.04.4663.04.5683.04.62
3.51.6723.54.1843.54.4663.54.5783.54.62
4.01.8324.04.2044.04.4764.04.5784.04.62
4.51.9724.54.2144.54.4764.54.5784.54.62
5.02.1125.04.2245.04.4765.04.5785.04.62
5.52.2525.54.2345.54.4865.54.5785.54.63
6.02.3826.04.2446.04.4866.04.5886.04.63
6.52.5126.54.2546.54.4866.54.5886.54.63
7.02.6427.04.2647.04.4967.04.5887.04.63
7.52.7627.54.2747.54.4967.54.5887.54.63
8.02.8728.04.2848.04.4968.04.5888.04.63
8.52.9828.54.2948.54.5068.54.5888.54.63
9.03.0829.04.3049.04.5069.04.5889.04.63
9.53.1729.54.3149.54.5069.54.5989.54.63
10.03.2630.04.3150.04.5170.04.5990.04.63
10.53.3430.54.3250.54.5170.54.5990.54.63
11.03.4231.04.3351.04.5171.04.5991.04.64
11.53.4831.54.3451.54.5171.54.5991.54.64
12.03.5532.04.3452.04.5272.04.5992.04.64
12.53.6132.54.3552.54.5272.54.5992.54.64
13.03.6633.04.3653.04.5273.04.6093.04.64
13.53.7133.54.3653.54.5273.54.6093.54.64
14.03.7634.04.3754.04.5374.04.6094.04.64
14.53.8034.54.3854.54.5374.54.6094.54.64
15.03.8335.04.3855.04.5375.04.6095.04.64
15.53.8735.54.3955.54.5375.54.6095.54.64
16.03.9036.04.3956.04.5476.04.6096.04.64
16.53.9336.54.4056.54.5476.54.6196.54.64
17.03.9637.04.4057.04.5477.04.6197.04.65
17.53.9837.54.4157.54.5477.54.6197.54.65
18.04.0038.04.4158.04.5578.04.6198.04.65
18.54.0238.54.4258.54.5578.54.6198.54.65
19.04.0439.04.4259.04.5579.04.6199.04.65
19.54.0639.54.4359.54.5579.54.6199.54.65
20.04.0840.04.4360.04.5580.04.61100.04.65
Bulletin No. 2015–9March 2, 2015
693

26 CFR 601.204 Changes in accounting periods and
in methods of accounting.
(Also Part I, §§ 162, 263(a), 263A, 446, 481; 1.446 –1.)
Rev. Proc. 2015–20
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 2015–14, 2015–5 I.R.B 450, to per-
mit a small business taxpayer, defined as a
business with total assets of less than $10
million or average annual gross receipts of
$10 million or less for the prior three
taxable years, to make certain tangible
property changes in methods of account-
ing with an adjustment under § 481(a) of
the Internal Revenue Code (the Code) that
takes into account only amounts paid or
incurred, and dispositions, in taxable
years beginning on or after January 1,
2014. In addition, for their first taxable
year that begins on or after January 1,
2014, small business taxpayers are permit-
ted to make certain tangible property
changes without filing a Form 3115. This
revenue procedure also requests com-
ments on whether it is appropriate to in-
crease the de minimis safe harbor limit
provided in § 1.263(a)–1(f)(1)(ii)(D) of
the Income Tax Regulations for a tax-
payer without an applicable financial
statement (AFS) to an amount greater than
$500, and, if so, what amount should be
used and the justification for considering
that amount appropriate.
SECTION 2. BACKGROUND
.01 The Treasury Department and the
Internal Revenue Service (IRS) recently
issued final regulations under §§ 1.162–3,
1.162– 4, 1.168(i)–1, 1.168(i)–7, 1.168(i)– 8,
1.263(a)–1, 1.263(a)–2, and 1.263(a)–3
(T.D. 9636, 2013– 43 I.R.B. 331, 78 Fed.
Reg. 57686; T.D. 9689, 2014 –36 I.R.B.
456, 79 Fed. Reg. 48661) (the final tangi-
ble property regulations), along with cor-
responding revenue procedures on related
changes in method of accounting.See
Rev. Proc. 2014 –16, 2014 –9 I.R.B. 606;
Rev. Proc. 2014 –54, 2014 – 41 I.R.B. 675,
(amplified, clarified, or modified by sec-
tions 6.37, 6.38, 6.39, and 10.11 of Rev.
Proc. 2015–14). The final tangible prop-
erty regulations generally apply to taxable
years beginning on or after January 1,
2014, but also permit a taxpayer to choose
to apply them to taxable years beginning
on or after January 1, 2012.
.02 Since the final tangible property
regulations and the accompanying method
change procedures were published, the
Treasury Department and the IRS have
received numerous requests to further
simplify the process for small businesses
to start applying the final tangible prop-
erty regulations. Inparticular, the Treasury
Department and the IRS have been asked to
permit small businesses to make changes in
methods of accounting using a cut-off basis
and without filing a Form 3115.
.03 Except as otherwise expressly pro-
vided in the Code and the regulations
thereunder, § 446(e) and § 1.446 –1(e)(2)
require a taxpayer to secure the consent of
the Commissioner before changing a
method of accounting for federal tax pur-
poses. Section 1.446 –1(e)(3)(ii) autho-
rizes the Commissioner to prescribe ad-
ministrative procedures setting forth the
limitations, terms, and conditions neces-
sary for a taxpayer to obtain consent to
change a method of accounting. A tax-
payer that changes a method of account-
ing must apply the provisions of § 481,
which accounts for how the taxpayer
treated the items being changed in prior
years to avoid duplication of deductions
or omission of income. Toavoid duplica-
tion or omission, taxpayers must follow the
rules of § 446(e) and § 481 when applying
the final tangible property regulations.
.04 The final tangible property regula-
tions and the method change procedures
were issued following a lengthy develop-
ment process that considered and ad-
dressed the prior concerns communicated
by small businesses and their representa-
tives. In particular, to simplify the transi-
tion to the final tangible property regula-
tions, the Treasury Department and the
IRS provided taxpayers with automatic
consent to change their methods of ac-
counting to utilize the final tangible prop-
erty regulations and reduced filing re-
quirements for small taxpayers. The final
tangible property regulations also contain
several simplifying provisions that are
elective and prospective in application
(for example, the election to apply the de
minimis safe harbor in § 1.263(a)–1(f);
the election to utilize the safe harbor for
small taxpayers in § 1.263(a)–3(h); and
the election to capitalize repair and main-
tenance costs in § 1.263(a)–3(n)). These
annual elections do not require a taxpayer
to change its method of accounting.
.05 To further ease the administrative
burden faced by small business taxpayers
in prospectively applying the final tangi-
ble property regulations beginning in
2014, this revenue procedure modifies
certain procedures provided in Rev. Proc.
2015–14 to permit small business taxpay-
ers to make changes in methods of ac-
counting with a § 481(a) adjustment that
takes into account only amounts paid or
incurred, and dispositions, in taxable
years beginning on or after January 1,
2014. This modification means that, effec-
tively, small business taxpayers making
these changes in method of accounting for
the first taxable year that begins on or
after January 1, 2014, may elect to make
the change on a cut-off basis.
.06 While some small business taxpay-
ers may choose to file a Form 3115 in
order to retain a clear record of a change
in method of accounting or to make per-
missible concurrent automatic changes on
the same form, other small business tax-
payers may prefer the administrative con-
venience of being able to comply with the
final tangible property regulations in their
first taxable year that begins on or after
January 1, 2014, solely through the filing
of a federal tax return. Accordingly, for
the first taxable year that begins on or
after January 1, 2014, small business tax-
payers that choose to prospectively apply
the tangible property regulations to
amounts paid or incurred, and disposi-
tions, in taxable years beginning on or
after January 1, 2014, have the option of
making certain tangible property changes
in method of accounting on the federal tax
return without including a separate Form
3115 or separate statement.
.07 Under section 6.02 of Rev. Proc.
2015–13, 2015–5 I.R.B. 419, ordinarily a
taxpayer must submit a separate Form
3115 for each automatic change. In some
cases, however, Rev. Proc. 2015–14 de-
scribes particular changes in method of
accounting that a taxpayer is required or
permitted to request on a single Form
3115 (concurrent changes). If, as provided
by this revenue procedure, a taxpayer
chooses to make certain tangible property
changes in method of accounting on a
federal tax return without filing a Form
March 2, 2015Bulletin No. 2015–9
694

3115, concurrent automatic changes, other
than those specifically addressed in sec-
tion 5 of this revenue procedure, are not
permitted to be made without completing
a Form 3115.
.08 A small business taxpayer choosing
the option of calculating a § 481(a) adjust-
ment that takes into account only amounts
paid or incurred, and dispositions, in tax-
able years beginning on or after January 1,
2014, does not receive audit protection
under section 8.01 of Rev. Proc. 2015–13
(or any successor) for taxable years begin-
ning prior to January 1, 2014.
.09 Section 5.02 of this revenue proce-
dure provides small business taxpayers
with the option of choosing to make a
change to a tangible property method of
accounting specified in Rev. Proc. 2015–
14, section 10.11(3)(a), with a § 481(a)
adjustment that does not take into account
amounts paid or incurred in taxable years
beginning before January 1, 2014. If a
small business taxpayer chooses to make a
§ 481(a) adjustment that does not take into
account amounts paid or incurred in tax-
able years beginning before January 1,
2014, then the taxpayer also must choose
to make a § 481(a) adjustment that does
not take into account dispositions in tax-
able years beginning before January 1,
2014, for certain changes made under sec-
tions 6.37, 6.38, and 6.39 of Rev. Proc.
2015–14. Because taxable years begin-
ning before January 1, 2014, are not taken
into account by a small business taxpayer
choosing this option, audit protection as
provided in section 8 of Rev. Proc.
2015–13 (or any successor) applies only
to amounts subject to a change made un-
der section 10.11(3)(a) of Rev. Proc.
2015–14 that are paid or incurred (and
dispositions subject to a change made un-
der sections 6.37, 6.38, and 6.39 of Rev.
Proc. 2015–14) in taxable years beginning
on or after January 1, 2014.
.10 Sections 5.03 through 5.05 of this
revenue procedure provide a similar op-
tion for dispositions, permitting small
business taxpayers to choose to make cer-
tain tangible property disposition changes
with a § 481(a) adjustment that does not
take into account dispositions in taxable
years beginning before January 1, 2014.
Specifically, sections 5.03 through 5.05 of
this revenue procedure modify sections
6.37, 6.38, and 6.39 of Rev. Proc.
2015–14 and provide that if a small busi-
ness taxpayer chooses to make a § 481(a)
adjustment that does not take into account
dispositions in taxable years beginning
before January 1, 2014, then the taxpayer
must consistently apply this treatment to
all dispositions (other than dispositions of
assets in general asset accounts) covered
by sections 6.37– 6.39 of Rev. Proc.
2015–14. In addition, the taxpayer also
must choose to make a § 481(a) adjust-
ment that does not take into account
amounts paid or incurred in taxable years
beginning before January 1, 2014, for any
change made under section 10.11(3)(a) of
Rev. Proc. 2015–14. Further, because tax-
able years beginning before January 1,
2014, are not taken into account by a
taxpayer choosing this option, audit pro-
tection as provided in section 8 of Rev.
Proc. 2015–13 (or any successor) applies
only to dispositions subject to a change
made under sections 6.37, 6.38, and 6.39
of Rev. Proc. 2015–14 (and amounts sub-
ject to a change made under section
10.11(3)(a) of Rev. Proc. 2015–14 that are
paid or incurred) in taxable years begin-
ning on or after January 1, 2014.
.11 For a small business taxpayer that
chooses to make a tangible property dis-
position change that only takes into ac-
count dispositions in 2014 and succeeding
taxable years, it is unnecessary and inap-
propriate to permit a late partial disposi-
tion election, which would permit partial
dispositions for taxable years beginning
prior to January 1, 2014. Accordingly,
section 5.06 of this revenue procedure
provides that the late partial disposition
election in section 6.33 of Rev. Proc.
2015–14 is inapplicable to a small busi-
ness taxpayer that, under the provisions of
this revenue procedure, changed to a
method of accounting and calculated a
§ 481(a) adjustment that took into account
only dispositions in taxable years begin-
ning on or after January 1, 2014.
.12 Section 8 of this revenue procedure
provides a transition rule for a taxpayer
within the scope of this revenue procedure
that has previously filed its federal tax
return for its first taxable year beginning
on or after January 1, 2014, permitting
withdrawal of the filed Form 3115
through the filing of an amended return on
or before the due date of the taxpayer’s
timely filed (including any extension)
original federal income tax return for the
requested year of change.
SECTION 3. REQUEST FOR
COMMENT ON DE MINIMIS SAFE
HARBOR LIMIT
.01 Under § 1.263(a)–1(f)(3)(iv), an
amount paid for property to which a tax-
payer properly applies the de minimis safe
harbor is not treated as a capital expendi-
ture or material or supply and may be
deducted under § 162, provided the
amount otherwise constitutes an ordinary
and necessary business expense. Under
§ 1.263(a)–1(f)(1)(ii)(D), a taxpayer with-
out an AFS may elect to apply the de
minimis safe harbor if, among other
things, the amount paid for the property
subject to the de minimis safe harbor does
not exceed $500 per invoice (or per item
as substantiated by the invoice) or other
amount as identified in published guid-
ance issued by the Treasury Department
and the IRS.
.02 The de minimis safe harbor pro-
vided in the final tangible property regu-
lations is intended as a new administrative
convenience whereby taxpayers are per-
mitted to deduct small dollar expenditures
for the acquisition or production of new
property or for the improvement of exist-
ing property, which otherwise must be
capitalized under the Code. The de mini-
mis safe harbor does not limit a taxpayer’s
ability to deduct otherwise deductible re-
pair or maintenance costs that exceed the
amount subject to the safe harbor. The
safe harbor merely establishes a minimum
threshold below which all qualifying
amounts are considered deductible. Con-
sistent with longstanding law, a taxpayer
may continue to deduct all otherwise de-
ductible repair or maintenance costs, re-
gardless of amount. In addition, the exis-
tence of the de minimis safe harbor does
not mean that a taxpayer cannot establish
a de minimis deduction threshold in ex-
cess of the safe harbor amount, provided
the taxpayer can demonstrate that a higher
threshold clearly reflects the taxpayer’s
income. In conjunction with section 179,
which also allows small business taxpay-
ers to immediately expense certain other-
wise capital expenditures, the de minimis
safe harbor provides significant tax sim-
plification to small businesses.
Bulletin No. 2015–9March 2, 2015
695

.03 The Treasury Department and the
IRS request written comments by April
21, 2015 on whether it is appropriate to
increase the de minimis safe harbor limit
provided in § 1.263(a)–1(f)(1)(ii)(D) for a
taxpayer without an AFS to an amount
greater than $500, and, if so, what amount
should be used and what is the justifica-
tion for that amount. Comments should
refer to Rev. Proc. 2015–20, and should
be submitted to:
Internal Revenue Service
Attn: CC:PA:LPD:PR
(Rev. Proc. 2015–20), Room 5203
P. O. Box 7604
Ben Franklin Station
Washington, DC 20044
Comments also may be hand delivered
Monday through Friday between the
hours of 8 am and 4 pm to CC:PA:LP-
D:PR (Rev. Proc. 2015–20) Courier’s
Desk, Internal Revenue Service, 1111
Constitution Avenue, N.W. Washington,
D.C. Alternatively, comments may be
submitted electronically directly to the
IRS via the following e-mail address:
Notice.Comments@irscounsel.treas.gov.
Please include “Rev. Proc. 2015–20”
in the subject line of any electronic com-
munication. All comments will be avail-
able for public inspection and copying.
SECTION 4. SCOPE
.01Applicability. This revenue proce-
dure applies to a taxpayer with one or
more separate and distinct trade(s) or
business(es), within the meaning of
§ 1.446 –1(d) that has—
(a) total assets of less than $10 million
as of the first day of the taxable year for
which a change in method of accounting
under the final tangible property regula-
tions and corresponding procedures re-
garding related changes in method of ac-
counting is effective; or
(b) average annual gross receipts of $10
million or less for the prior three taxable
years, as determined under § 1.263(a)–
3(h)(3) (substituting “separate and distinct
trade or business” for “taxpayer”).
.02Inapplicability. This revenue pro-
cedure does not apply to a taxpayer’s sep-
arate and distinct trade or business if that
trade or business does not meet one (or
both) of the criteria in section 4.01(a) and
(b) of this revenue procedure.
SECTION 5. PROCEDURE
.01 A taxpayer with a separate and dis-
tinct trade or business that meets the appli-
cability requirements of section 4.01 of this
revenue procedure (“taxpayer”) may change
a method of accounting for that trade or
business to an accountingmethod described
in section 6.37(3)(a)(iv), (a)(v), (a)(vii),
(a)(viii), 6.38, 6.39, or 10.11(3)(a) of Rev.
Proc. 2015–14, as modified by this revenue
procedure, with an adjustment under section
§ 481(a) that takes into account only amounts
paid or incurred, and dispositions, by that trade
or business in taxable years beginning on or
after January 1, 2014. If the taxpayer calcu-
lates the § 481(a) adjustment in such manner
for that applicable trade or business, the re-
quirement in section 6.03(1) of Rev. Proc.
2015–13 (or any successor) to complete and
file a Form 3115 for the applicable trade or
business is waived for the taxpayer’s first tax-
able year beginning on or after January 1,
2014, for a change in method of accounting
made under section 6.37(3)(a)(iv), (a)(v),
(a)(vii), (a)(viii), 6.38, 6.39, or 10.11(3)(a) of
Rev. Proc. 2015–14, as modified by this rev-
enue procedure. Accordingly, the taxpayer is
permitted to make these changes on its federal
tax return for such taxable year without includ-
ing a separate Form 3115 or separate state-
ment for its applicable trades or businesses.
.02 Section 10.11 of Rev. Proc.
2015–14 is modified by adding a new
paragraph (6)(b)(iii) to read as follows:
(iii)Small business exception. A tax-
payer meeting the scope requirements of
Rev. Proc. 2015–20, 2015– 09 I.R.B. 694,
and changing its method of accounting
under this section 10.11(3)(a) may calcu-
late a § 481(a) adjustment as of the first
day of the taxpayer’s year of change that
takes into account only amounts paid or
incurred in taxable years beginning on or
after January 1, 2014. However, a tax-
payer using this option must also calculate
the § 481(a) adjustment as of the first day
of the taxpayer’s year of change that takes
into account only dispositions in taxable
years beginning on or after January 1,
2014, for any change made under section
6.37(3)(a)(iv), (a)(v), (a)(vii), or (a)(viii),
section 6.38, or section 6.39 of this reve-
nue procedure. In addition, a taxpayer cal-
culating a § 481(a) adjustment under this
paragraph (6)(b)(iii) that takes into ac-
count only amounts paid or incurred in
taxable years beginning on or after Janu-
ary 1, 2014, does not receive audit protec-
tion under section 8.01 of Rev. Proc.
2015–13 for amounts subject to a change
under this section 10.11(3)(a) that are paid
or incurred in taxable years beginning be-
fore January 1, 2014. Therequirement in
section 6.03(1) of Rev. Proc. 2015–13 to
complete and file a Form 3115 is waived for
a taxpayer’s first taxable year that begins on
or after January 1, 2014, for a change in
method of accounting made under this sec-
tion 10.11(3)(a) if the taxpayer calculates a
§ 481(a) adjustment under this paragraph
(6)(b)(iii) that takes into account only
amounts paid or incurred in taxable years
beginning on or after January 1, 2014.
.03 Section 6.37 of Rev. Proc. 2015–14 is
modified by adding a new paragraph (4)(f):
(f) A taxpayer meeting the scope re-
quirements of Rev. Proc. 2015–20,
2015– 09 I.R.B. 694, and changing its
method of accounting under this section
6.37(3)(a)(iv), (a)(v), (a)(vii), or (a)(viii)
may calculate a § 481(a) adjustment as of
the first day of the taxpayer’s year of
change that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014. However, a tax-
payer using this option must also use sec-
tions 6.38(7)(b) and 6.39(6)(b) of this rev-
enue procedure to calculate a § 481(a)
adjustment for any change made under
section 6.38 or 6.39 of this revenue proce-
dure and must use section 10.11(6)(b)(iii) of
this revenue procedure to calculate a
§ 481(a) adjustment for any change made
under section 10.11(3)(a) of this revenue
procedure. In addition, a taxpayer calcu-
lating a § 481(a) adjustment under this
paragraph (4)(f) that takes into account
only dispositions in taxable years begin-
ning on or after January 1, 2014, does not
receive audit protection under section 8.01
of Rev. Proc. 2015–13 (or any successor)
for dispositions subject to a change under
this section 6.37(3)(a)(iv), (a)(v), (a)(vii),
or (a)(viii) in taxable years beginning be-
fore January 1, 2014. The requirement in
section 6.03(1) of Rev. Proc. 2015–13 (or
any successor) to complete and file a
Form 3115 is waived for a taxpayer’s first
taxable year that begins on or after Janu-
ary 1, 2014, for a change in method of
accounting made under this section
6.37(3)(a)(iv), (a)(v), (a)(vii), or (a)(viii)
if the taxpayer calculates a § 481(a) ad-
March 2, 2015Bulletin No. 2015–9
696

justment pursuant to this paragraph (4)(f)
that takes into account only dispositions in
taxable years beginning on or after Janu-
ary 1, 2014.
.04 Section 6.38 of Rev. Proc. 2015–14
is modified by replacing paragraph 7 (Sec-
tion 481(a) adjustment) with the following:
(7)Section 481(a) adjustment.
(a) A taxpayer changing its method of
accounting under this section 6.38 may
use statistical sampling in determining the
§ 481(a) adjustment by following the
guidance provided in Rev. Proc. 2011– 42,
2011–37 I.R.B. 318.
(b) A taxpayer meeting the scope re-
quirements of Rev. Proc. 2015–20,
2015– 09 I.R.B. 694, and changing its
method of accounting under this section
6.38 may calculate a § 481(a) adjustment
as of the first day of the taxpayer’s year of
change that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014. However, a tax-
payer using this option must also use sec-
tions 6.37(4)(f) and 6.39(6)(b) of this rev-
enue procedure to calculate a § 481(a)
adjustment for any change made under
section 6.37(3)(a)(iv), (a)(v), (a)(vii), or
(a)(viii) or section 6.39 of this revenue
procedureandmustusesection
10.11(6)(b)(iii) of this revenue procedure
to calculate a § 481(a) adjustment for any
change made under section 10.11(3)(a) of
this revenue procedure. In addition, a tax-
payer calculating a § 481(a) adjustment
under this paragraph (7)(b) that takes into
account only dispositions in taxable years
beginning on or after January 1, 2014,
does not receive audit protection under
section 8.01 of Rev. Proc. 2015–13 for
dispositions subject to a change under this
section 6.38 in taxable years beginning
before January 1, 2014. The requirement
in section 6.03(1) of Rev. Proc. 2015–13
to complete and file a Form 3115 is
waived for a taxpayer’s first taxable year
that begins on or after January 1, 2014, for
a change in method of accounting made
under this section 6.38 if the taxpayer
calculates a § 481(a) adjustment pursuant
to this paragraph (7)(b) that takes into
account only dispositions in taxable years
beginning on or after January 1, 2014.
.05 Section 6.39 of Rev. Proc. 2015–14
is modified by replacing paragraph 6 (Sec-
tion 481(a) adjustment) with the following:
(6)Section 481(a) adjustment.
(a) A taxpayer changing its method of
accounting under this section 6.39 may
use statistical sampling in determining the
§ 481(a) adjustment by following the
guidance provided in Rev. Proc. 2011– 42,
2011–37 I.R.B. 318.
(b) A taxpayer meeting the scope re-
quirementsofRev.Proc.2015–20,
2015– 09 I.R.B. 694, and changing its
method of accounting under this section
6.39 may calculate a § 481(a) adjustment as
of the first day of the taxpayer’s year of
change that takes into account only disposi-
tions in taxable years beginning on or after
January 1, 2014. However, a taxpayer using
this option also must use sections 6.37(4)(f)
and 6.38(7)(b) of this revenue procedure to
calculate a § 481(a) adjustment for any
change made under section 6.37(3)(a)(iv),
(a)(v), (a)(vii), or (a)(viii) or section 6.38 of
this revenue procedure and must use section
10.11(6)(b)(iii) of this revenue procedure to
calculate a § 481(a) adjustment for any
change made under section 10.11(3)(a) of
this revenue procedure. In addition, a tax-
payer calculating a § 481(a) adjustment pur-
suant to this paragraph (6)(b) that takes into
account only dispositions in taxable years
beginning on or after January 1, 2014, does
not receive audit protection under section
8.01 of Rev. Proc. 2015–13 for dispositions
subject to a change under this section 6.39 in
taxable years beginning prior to January 1,
2014. The requirement in section 6.03(1) of
Rev. Proc. 2015–13 to complete and file a
Form 3115 is waived for a taxpayer’s first
taxable year that begins on or after January
1, 2014, for a change in method of account-
ing made under this section 6.39 if the tax-
payer calculates a § 481(a) adjustment pur-
suant to this paragraph (6)(b) that takes into
account only dispositions in taxable years
beginning on or after January 1, 2014.
.06 Section 6.33(1)(b) of Rev. Proc.
2015–14 is modified by deleting “or” at
the end of paragraph (iii), replacing “.”
with “;or” at the end of paragraph (iv), and
adding new paragraphs (v) and (vi):
(v) A taxpayer within the scope require-
ments of Rev. Proc. 2015–20, 2015– 09
I.R.B. 694, and that calculated a § 481(a)
adjustment as of the first day of the taxpay-
er’s year of change that took into account
only dispositions in taxable years beginning
on or after January 1, 2014, for any change
in method of accounting provided in section
6.37(3)(a)(iv), (a)(v), (a)(vii), or (a)(viii),
section 6.38, or section 6.39 of this revenue
procedure; or
(vi) A taxpayer within the scope re-
quirements of Rev. Proc. 2015–20,
2015– 09 I.R.B. 694, and that calculated a
§ 481(a) adjustment as of the first day of
the taxpayer’s year of change that took
into account only amounts paid or in-
curred in taxable years beginning on or
after January 1, 2014, for any change of
method of accounting provided in section
10.11(3)(a) of this revenue procedure.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Revenue Procedure 2015–14 is modified.
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective for
taxable years beginning on or after Janu-
ary 1, 2014.
SECTION 8. TRANSITION RULE
A taxpayer that (a) meets the scope
requirements of this revenue procedure,
(b) wants to use this revenue procedure
for its first taxable year beginning on or
after January 1, 2014, and (c) previously
filed its federal tax return for that taxable
year with a Form 3115 to change to a
method of accounting specified in this
revenue procedure may withdraw its Form
3115 by filing an amended federal tax
return using this revenue procedure. The
amended federal tax return must be filed
on or before the due date of the taxpayer’s
federal tax return for its first taxable year
beginning on or after January 1, 2014,
including extensions. The withdrawn
Form 3115 will not be taken into account
for purposes of applying section 5.05 of
Rev. Proc. 2015–13.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Merrill Feldstein of the Of-
fice of Associate Chief Counsel (Income
Tax & Accounting). For further informa-
tion regarding this revenue procedure,
contact Merrill Feldstein of the Office of
Associate Chief Counsel (Income Tax &
Accounting) at (202) 317-5100 (not a toll
free number).
Bulletin No. 2015–9March 2, 2015
697

Part IV. Items of General Interest
Application of Quality
Stores Supreme Court
Decision to Claims for
Refund of Employment
Taxes
Announcement 2015–8
PURPOSE
The purpose of this announcement is to
provide guidance on the application of the
decision inUnited States v. Quality
Stores, Inc., 134 S. Ct. 1395 (2014), to
claims for refund of employment taxes
paid with respect to severance payments.
BACKGROUND
On March 25, 2014, inQuality Stores,
the Supreme Court held in a unanimous
8 – 0 decision that the severance payments
at issue in the case were wages subject to
FederalInsuranceContributionsAct
(FICA) tax. The United States Court of
Appeals for the Sixth Circuit had previ-
ously held that the payments were not
wages for FICA purposes.In re Quality
Stores, Inc., 693 F.3d 605, 616 (6th Cir.
2012). The Supreme Court’s decision was
consistent with the conclusion reached by
the Federal Circuit inCSX Corp. v. United
States, 518 F.3d 1328 (Fed. Cir. 2008),
which held that severance payments were
both wages for FICA tax purposes and
compensation for Railroad Retirement
Tax Act (RRTA) tax purposes.
In the years leading up to the Supreme
Court’s decision, the Internal Revenue
Service (Service) received claims for re-
fund of FICA, RRTA, and Federal Unem-
ployment Tax Act (FUTA) taxes paid
with respect to severance payments from
over 3,000 taxpayers. Consistent with its
position in the litigation, the Service dis-
allowed all such claims for refund from
taxpayers located outside of the jurisdic-
tion of the Sixth Circuit. Many of these
taxpayers submitted a request to appeal
the disallowed claim for refund to the IRS
Office of Appeals. The Service suspended
action on these appeal requests pending
the resolution of theQuality Storeslitiga-
tion. The Service also suspended action on
the claims for refund filed by taxpayers
located within the Sixth Circuit’s jurisdic-
tion pending the resolution of theQuality
Storeslitigation.
Under Revenue Ruling 90 –72, supple-
mental unemployment compensation ben-
efits that are linked to the receipt of state
unemployment compensation and satisfy
certain other requirements are excludable
from wages for FICA, FUTA, and income
tax withholding purposes, and are exclud-
able from compensation for RRTA tax
purposes. InQuality Stores, the parties
agreed that the payments at issue did not
satisfy the requirements for the narrow
exclusion from FICA tax contained in
Revenue Ruling 90 –72. Accordingly, the
Supreme Court did not address whether
the exclusion from FICA taxes set forth in
Revenue Ruling 90 –72 for certain pay-
ments linked to state unemployment ben-
efits is “consistent with the broad defini-
tion of wages under FICA.”Quality
Stores, 134 S. Ct. at 1405. Revenue Rul-
ing 90 –72 continues to be in effect.
APPLICATION OFQUALITY STORES
SUPREME COURT DECISION
Claims for refund of FICA, RRTA, or
FUTA taxes paid with respect to sever-
ance payments that do not satisfy Revenue
Ruling 90 –72.
As a result of the Supreme Court’s
holding inQuality Storesand the consis-
tent position of the Federal Circuit inCSX,
the Service will disallow all claims for
refund of FICA or RRTA taxes paid with
respect to severance payments that do not
satisfy the narrow exclusion contained in
Revenue Ruling 90 –72. This includes all
claims for refund that were held in sus-
pense pending the resolution ofQuality
Storesand claims filed by taxpayers lo-
cated within the Sixth Circuit’s jurisdic-
tion. Since the definition of wages con-
tained in section 3121(a) of the Internal
Revenue Code is generally the same as the
definition of wages in section 3306(b)
with respect to the FUTA, the Service will
also continue to disallow claims for re-
fund of FUTA taxes paid with respect to
such severance payments.
Appeal requests relating to disallowed
claims for refund of FICA, RRTA, or
FUTA taxes.
The Service will take no further action
on the appeal requests that were sus-
pended pending the resolution ofQuality
Stores. The Service fully disallowed the
claims for refund that are the subject of
these appeal requests. Following the Su-
preme Court’s unanimous ruling that the
severance payments at issue were wages
for FICA purposes, there is no basis for
taxpayers to appeal the disallowance to
the IRS Office of Appeals with respect to
that issue.
APPEAL REQUESTS RELATING TO
OTHER ISSUES
If a taxpayer’s claim for refund for
which an appeal was requested included
an additional or different basis for the
claim for refund (such as a claim for re-
fund of FICA tax paid on certain fringe
benefits) or concerned payments that sat-
isfied the requirements of Revenue Ruling
90 –72, the taxpayer should contact Laird
MacMillan at (651) 726-1473 (not a toll-
free number) for information regarding
how to proceed with the appeal request for
that portion of the disallowed claim. If the
taxpayer does not contact the Service, the
Service will take no further action on the
appeal request. As stated in the disallow-
ance letter sent to taxpayers claiming a
refund, the two-year period during which
the taxpayer may file suit in a United
States district court or the United States
Court of Federal Claims began on the date
the disallowance letter was mailed by cer-
tified or registered mail. The filing of an
appeal request did not suspend that time
period for filing suit.
DRAFTING INFORMATION
The principal author of this announce-
ment is Melissa L. Duce of the Office of
Division Counsel/Associate Chief Coun-
sel (Tax Exempt & Government Entities).
For further information regarding this an-
nouncement, contact Melissa L. Duce at
(202) 317-6798 (not a toll-free number).
March 2, 2015Bulletin No. 2015–9
698

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2015–9March 2, 2015
i

Numerical Finding List
1
Bulletin 2015–1 through 2015–9
Announcements:
2015-2, 2015-3 I.R.B.324
2015-3, 2015-3 I.R.B.328
2015-4, 2015-5 I.R.B.565
2015-5, 2015-7 I.R.B.602
2015-6, 2015-8 I.R.B.685
2015-8, 2015-9 I.R.B.698
Proposed Regulations:
REG-109187-11, 2015-2 I.R.B.277
REG-132751-14, 2015-2 I.R.B.279
REG-145878-14, 2015-2 I.R.B.290
REG-153656-3, 2015-5 I.R.B.566
Notices:
2015-1, 2015-2 I.R.B.249
2015-2, 2015-4 I.R.B.334
2015-3, 2015-6 I.R.B.583
2015-4, 2015-5 I.R.B.407
2015-5, 2015-5 I.R.B.408
2015-6, 2015-5 I.R.B.412
2015-7, 2015-6 I.R.B.585
2015-8, 2015-6 I.R.B.589
2015-9, 2015-6 I.R.B.590
2015-11, 2015-8 I.R.B.618
2015-12, 2015-8 I.R.B.619
2015-15, 2015-9 I.R.B.687
2015-19, 2015-9 I.R.B.690
Revenue Procedures:
2015-1, 2015-1 I.R.B.1
2015-2, 2015-1 I.R.B.105
2015-3, 2015-1 I.R.B.129
2015-4, 2015-1 I.R.B.144
2015-5, 2015-1 I.R.B.186
2015-6, 2015-1 I.R.B.194
2015-7, 2015-1 I.R.B.231
2015-8, 2015-1 I.R.B.235
2015-9, 2015-2 I.R.B.249
2015-10, 2015-2 I.R.B.261
2015-12, 2015-2 I.R.B.265
2015-13, 2015-5 I.R.B.419
2015-14, 2015-5 I.R.B.450
2015-15, 2015-5 I.R.B.564
2015-16, 2015-7 I.R.B.596
2015-17, 2015-7 I.R.B.599
2015-18, 2015-8 I.R.B.642
2015-19, 2015-8 I.R.B.678
2015-20, 2015-9 I.R.B.694
Revenue Rulings:
2015-1, 2015-4 I.R.B.331
2015-2, 2015-3 I.R.B.321
2015-3, 2015-6 I.R.B.580
Treasury Decisions:
9707, 2015-2 I.R.B.247
9708, 2015-5 I.R.B.337
9709, 2015-7 I.R.B.593
9710, 2015-8 I.R.B.603
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin
2014 –52, dated December 28, 2014.
March 2, 2015Bulletin No. 2015–9
ii

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

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