Internal Revenue Bulletin 2017-48 (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
Notice 2017–70, page 543.
This notice provides that the IRS will not assert that cash
payments an employer makes to § 170(c) organizations (in
exchange for vacation, sick, or personal leave that its employ-
ees elect to forgo) constitute gross income or wages of the
employees under certain circumstances relating to the Califor-
nia Wildfires that began on October 8, 2017.
Rev. Proc. 2017–59, page 543.
This revenue procedure modifies Rev. Proc. 2015–13,
2015–5 I.R.B. 419, as clarified and modified by Rev. Proc.
2015–33, 2015–24 I.R.B. 1067, and as modified by Rev.
Proc. 2016 –1, 2016 –1 I.R.B. 1. Rev. Proc. 2015–13 provides
procedures for obtaining the consent of the Commissioner of
Internal Revenue to change a method of accounting for federal
income tax purposes. With respect to elections under § 404A
of the Internal Revenue Code, which are treated as changes in
method of accounting for purposes of § 481, this revenue
procedure specifies the § 481 adjustment period.
EXEMPT ORGANIZATIONS
Announcement 2017–18, page 545.
Serves notice to potential donors of a stipulated decision by
the United States Tax Court in declaratory judgment proceed-
ings under Section 7428.
EMPLOYEE PLANS
Notice 2017– 69, page 540.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for Novem-
ber 2017 used under § 417(e)(3)(D), the 24-month average
segment rates applicable for November 2017, and the 30-year
Treasury rates. These rates reflect the application of
§ 430(h)(2)(C)(iv), which was added by the Moving Ahead for
Progress in the 21st Century Act, Public Law 112–141 (MAP-
21) and amended by section 2003 of the Highway and Trans-
portation Funding Act of 2014 (HATFA).
Rev. Rul. 2017–22, page 536.
This revenue ruling provides tables of covered compensation
under § 401(l)(5)(E) of the Internal Revenue Code and the
Income Tax Regulations thereunder, effective January 1, 2018.
Finding Lists begin on page ii.
Bulletin No. 2017– 48
November 27, 2017

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.
November 27, 2017Bulletin No. 2017– 48

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 401.— Qualified
Pension, Profit-Sharing,
and Stock Bonus Plans
26 CFR 1.401(l)–1: Permitted disparity in employer-
provided contributions or benefits
Rev. Rul. 2017–22
This revenue ruling provides tables of
covered compensation under § 401(l)(5)(E)
of the Internal Revenue Code and the In-
come Tax Regulations thereunder, for the
2018 plan year.
Section 401(l)(5)(E)(i) defines covered
compensation with respect to an employee
as the average of the contribution and
benefit bases in effect under section 230
of the Social Security Act (the “Act”) for
each year in the 35-year period ending
with the year in which the employee at-
tains social security retirement age.
Section 401(l)(5)(E)(ii) states that the
determination for any year preceding the
year in which the employee attains social
security retirement age shall be made by
assuming that there is no increase in cov-
ered compensation after the determination
year and before the employee attains so-
cial security retirement age.
Section 1.401(l)–1(c)(34) of the In-
come Tax Regulations defines the taxable
wage base as the contribution and benefit
base under section 230 of the Act.
Section 1.401(l)–1(c)(7)(i) defines cov-
ered compensation for an employee as the
average (without indexing) of the taxable
wage bases in effect for each calendar
year during the 35-year period ending
with the last day of the calendar year in
which the employee attains (or will attain)
social security retirement age. A 35-year
period is used for all individuals regard-
less of the year of birth of the individual.
In determining an employee’s covered
compensation for a plan year, the taxable
wage base for all calendar years beginning
after the first day of the plan year is as-
sumed to be the same as the taxable wage
base in effect as of the beginning of the
plan year. An employee’s covered com-
pensation for a plan year beginning after
the 35-year period applicable under
§ 1.401(l)–1(c)(7)(i) is the employee’s
covered compensation for a plan year dur-
ing which the 35-year period ends. An
employee’s covered compensation for a
plan year beginning before the 35-year
period applicable under § 1.401(l)–
1(c)(7)(i) is the taxable wage base in ef-
fect as of the beginning of the plan year.
Section 1.401(l)–1(c)(7)(ii) provides
that, for purposes of determining the
amount of an employee’s covered com-
pensation under § 1.401(l)–1(c)(7)(i), a
plan may use tables, provided by the
Commissioner, that are developed by
rounding the actual amounts of covered
compensation for different years of birth.
For purposes of determining covered
compensation for the 2018 year, the tax-
able wage base is $128,700.
The following tables provide covered
compensation for 2018.
ATTACHMENT I
2018 COVERED COMPENSATION TABLE
CALENDAR YEAR OF BIRTH
CALENDAR YEAR OF SOCIAL
SECURITY RETIREMENT AGE
2018 COVERED
COMPENSATION TABLE II
19071972$ 4,488
190819734,704
190919745,004
191019755,316
191119765,664
191219776,060
191319786,480
191419797,044
191519807,692
191619818,460
191719829,300
1918198310,236
1919198411,232
1920198512,276
1921198613,368
1922198714,520
1923198815,708
November 27, 2017Bulletin No. 2017– 48
536

2018 COVERED COMPENSATION TABLE
CALENDAR YEAR OF BIRTH
CALENDAR YEAR OF SOCIAL
SECURITY RETIREMENT AGE
2018 COVERED
COMPENSATION TABLE II
1924198916,968
1925199018,312
1926199119,728
1927199221,192
1928199322,716
1929199424,312
1930199525,920
1931199627,576
1932199729,304
1933199831,128
1934199933,060
1935200035,100
1936200137,212
1937200239,444
1938200443,992
1939200546,344
1940200648,816
1941200751,348
1942200853,952
1943200956,628
1944201059,268
1945201161,884
1946201264,560
1947201367,308
1948201469,996
1949201572,636
1950201675,180
1951201777,880
1952201880,544
1953201983,136
1954202085,680
1955202290,588
1956202392,976
1957202495,280
1958202597,500
1959202699,648
19602027101,736
19612028103,764
19622029105,720
19632030107,640
19642031109,524
19652032111,336
19662033113,064
19672034114,660
19682035116,160
Bulletin No. 2017– 48November 27, 2017
537

2018 COVERED COMPENSATION TABLE
CALENDAR YEAR OF BIRTH
CALENDAR YEAR OF SOCIAL
SECURITY RETIREMENT AGE
2018 COVERED
COMPENSATION TABLE II
19692036117,540
19702037118,800
19712038119,988
19722039121,152
19732040122,256
19742041123,240
19752042124,140
19762043124,896
19772044125,520
19782045126,144
19792046126,780
19802047127,308
19812048127,740
19822049128,064
19832050128,364
19842051128,652
1985 and Later2052 and Later128,700
ATTACHMENT II
2018 ROUNDED COVERED COMPENSATION TABLE
CALENDAR YEAR OF BIRTH
2018 COVERED COMPENSATION
ROUNDED
1937$ 39,000
1938–193945,000
194048,000
194151,000
194254,000
194357,000
194460,000
194563,000
1946–194766,000
194869,000
194972,000
195075,000
195178,000
195281,000
195384,000
195487,000
195590,000
195693,000
195796,000
1958–195999,000
1960102,000
1961–1962105,000
November 27, 2017Bulletin No. 2017– 48
538

2018 ROUNDED COVERED COMPENSATION TABLE
CALENDAR YEAR OF BIRTH
2018 COVERED COMPENSATION
ROUNDED
1963108,000
1964–1965111,000
1966–1967114,000
1968–1969117,000
1970–1972120,000
1973–1975123,000
1976–1980126,000
1981 and Later128,700
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-6700 or Michael
Spaid at 206-946-3480 (not toll-free
numbers).
Bulletin No. 2017– 48November 27, 2017
539

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2017– 69
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der section 104 of the Pension Protection
Act of 2006 and CSEC plans under
§ 414(y), § 430 of the Code specifies the
minimum funding requirements that apply
to single-employer plans pursuant to
§ 412. Section 430(h)(2) specifies the in-
terest rates that must be used to determine
a plan’s target normal cost and funding
target. Under this provision, present value
is generally determined using three 24-
month average interest rates (“segment
rates”), each of which applies to cash
flows during specified periods. To the ex-
tent 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.
1
However, an election may be made
under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from October
2017 data is in Table 2017–10 at the end
of this notice. The spot first, second, and
third segment rates for the month of Oc-
tober 2017 are, respectively, 2.05, 3.61,
and 4.27.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant
to § 430(h)(2)(C)(iv) to be within the
applicable minimum and maximum per-
centages of the corresponding 25-year
average segment rates. For plan years
beginning before 2021, the applicable
minimum percentage is 90% and the
applicablemaximumpercentageis
110%. The 25-year average segment
rates for plan years beginning in 2016,
2017, and 2018 were published in No-
tice 2015– 61, 2015–39 I.R.B. 408, No-
tice 2016 – 64, 2016 – 40 I.R.B. 429, and
Notice 2017–50, 2017– 41 I.R.B. 280,
respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for Novem-
ber 2017 without adjustment for the 25-
year average segment rate limits are as
follows:
24-Month Average Segment Rates Without 25-year Average Adjustment
Applicable Month
First
Segment
Second
Segment
Third
Segment
November 20171.773.734.60
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for November
2017, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning inApplicable Month
First
Segment
Second
Segment
Third
Segment
2016November 20174.435.916.65
2017November 20174.165.726.48
2018November 20173.925.526.29
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
November 27, 2017Bulletin No. 2017– 48
540

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 § 431(c)(6)(A), based on the
plan’s current liability. Section 431(c)(6)
(E)(ii)(I) provides that the interest rate
used to calculate current liability for this
purpose must be no more than 5 percent
above and no more than 10 percent below
the weighted average of the rates of inter-
est on 30-year Treasury securities during
the four-year period ending on the last day
before the beginning of the plan year.
Notice 88 –73, 1988 –2 C.B. 383, provides
guidelines for determining the weighted
average interest rate. The rate of interest
on 30-year Treasury securities for October
2017 is 2.88 percent. The Service deter-
mined this rate as the average of the daily
determinations of yield on the 30-year
Treasury bond maturing in August 2047.
For plan years beginning in November
2017, the weighted average of the rates of
interest on 30-year Treasury securities and
the permissible range of rates used to cal-
culate current liability are as follows:
Treasury Weighted Average Rates
For Plan Years
Beginning in
30-Year Treasury
Weighted Average
Permissible Range
90% to 105%
November 20172.872.58 to 3.01
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 October 2017
are as follows:
Minimum Present Value Segment Rates
MonthFirst SegmentSecond SegmentThird Segment
October 20172.053.614.27
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-6700 or Tony
Montanaro at 202-317-8698 (not toll-free
numbers).
Bulletin No. 2017– 48November 27, 2017
541

Table 2017–10
Monthly Yield Curve for October 2017
Derived from October 2017 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.51.5020.54.0940.54.2960.54.3680.54.40
1.01.6621.04.1041.04.2961.04.3681.04.40
1.51.8021.54.1141.54.3061.54.3681.54.40
2.01.9322.04.1242.04.3062.04.3782.04.40
2.52.0422.54.1342.54.3062.54.3782.54.40
3.02.1323.04.1343.04.3063.04.3783.04.40
3.52.2223.54.1443.54.3163.54.3783.54.40
4.02.3224.04.1544.04.3164.04.3784.04.40
4.52.4124.54.1544.54.3164.54.3784.54.40
5.02.5125.04.1645.04.3165.04.3785.04.40
5.52.6125.54.1745.54.3165.54.3785.54.40
6.02.7126.04.1746.04.3266.04.3786.04.40
6.52.8226.54.1846.54.3266.54.3786.54.40
7.02.9227.04.1847.04.3267.04.3887.04.41
7.53.0227.54.1947.54.3267.54.3887.54.41
8.03.1228.04.1948.04.3268.04.3888.04.41
8.53.2128.54.2048.54.3368.54.3888.54.41
9.03.3029.04.2049.04.3369.04.3889.04.41
9.53.3829.54.2149.54.3369.54.3889.54.41
10.03.4530.04.2150.04.3370.04.3890.04.41
10.53.5230.54.2250.54.3370.54.3890.54.41
11.03.5931.04.2251.04.3371.04.3891.04.41
11.53.6531.54.2351.54.3471.54.3891.54.41
12.03.7032.04.2352.04.3472.04.3892.04.41
12.53.7532.54.2452.54.3472.54.3992.54.41
13.03.7933.04.2453.04.3473.04.3993.04.41
13.53.8333.54.2553.54.3473.54.3993.54.41
14.03.8734.04.2554.04.3474.04.3994.04.41
14.53.9034.54.2554.54.3574.54.3994.54.41
15.03.9235.04.2655.04.3575.04.3995.04.41
15.53.9535.54.2655.54.3575.54.3995.54.41
16.03.9736.04.2656.04.3576.04.3996.04.41
16.53.9936.54.2756.54.3576.54.3996.54.42
17.04.0137.04.2757.04.3577.04.3997.04.42
17.54.0237.54.2757.54.3577.54.3997.54.42
18.04.0438.04.2858.04.3678.04.3998.04.42
18.54.0538.54.2858.54.3678.54.3998.54.42
19.04.0639.04.2859.04.3679.04.4099.04.42
19.54.0739.54.2859.54.3679.54.4099.54.42
20.04.0840.04.2960.04.3680.04.40100.04.42
November 27, 2017Bulletin No. 2017– 48
542

Treatment of Amounts Paid
to Section 170(c)
Organizations under
Employer Leave-Based
Donation Programs to Aid
Victims of the California
Wildfires that Began on
October 8, 2017
Notice 2017–70
This notice provides guidance on the
treatment of leave-based donation pro-
grams to aid victims of the California
Wildfires that began on October 8, 2017
(2017 California Wildfires).
TREATMENT OF LEAVE-BASED
DONATION PAYMENTS
In response to the extreme need for
charitable relief for victims of the 2017
California Wildfires, employers may
have adopted or may be considering
adopting leave-based donation pro-
grams. Under leave-based donation pro-
grams, employees can elect to forgo va-
cation, sick, or personal leave in
exchange for cash payments that the em-
ployer makes to charitable organizations
described in § 170(c) of the Internal
Revenue Code (§ 170(c) organizations).
This notice provides guidance for in-
come and employment tax purposes on
the treatment of cash payments made by
employers under leave-based donation
programs for the relief of victims of the
2017 California Wildfires.
The Internal Revenue Service (the
Service) will not assert that cash pay-
ments an employer makes to § 170(c)
organizations in exchange for vacation,
sick, or personal leave that its employ-
ees elect to forgo constitute gross in-
come or wages of the employees if the
payments are: (1) made to the § 170(c)
organizations for the relief of victims of
the 2017 California Wildfires; and (2)
paid to the § 170(c) organizations before
January 1, 2019.
Similarly, the Service will not assert
that the opportunity to make such an
election results in constructive receipt of
gross income or wages for employees.
Electing employees may not claim a
charitable contribution deduction under
§ 170 with respect to the value of for-
gone leave excluded from compensation
and wages.
The Service will not assert that an em-
ployer is permitted to deduct these cash
payments exclusively under the rules of
§ 170 rather than the rules of § 162. Cash
payments to which this guidance applies
need not be included in Box 1, 3 (if ap-
plicable), or 5 of the Form W-2.
For further information, please contact
Sheldon Iskow of the Office of Associate
Chief Counsel (Income Tax and Account-
ing) at (202) 317-4718 (not a toll-free
number).
26 CFR 601.204: Changes in accounting periods
and in methods of accounting. (Also Part I, §§ 404A,
446, 481; 1.446 –1, 1.481–1, 1.481– 4.)
Rev. Proc. 2017–59
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 2015–13, 2015–5 I.R.B. 419, as
clarified and modified by Rev. Proc.
2015–33, 2015–24 I.R.B. 1067, and as
modified by Rev. Proc. 2016 –1, 2016 –1
I.R.B. 1. Rev. Proc. 2015–13 provides
procedures for obtaining the consent of
the Commissioner of Internal Revenue
(Commissioner) to change a method of
accounting for federal income tax pur-
poses. With respect to elections under
§ 404A of the Internal Revenue Code
(Code), which are treated as changes in
method of accounting for purposes of
§ 481, this revenue procedure specifies the
§ 481 adjustment period.
SECTION 2. BACKGROUND
.01 Rev. Proc. 2015–13 contains pro-
cedures under § 446(e) and § 1.446 –1(e)
of the Income Tax Regulations to obtain
the consent of the Commissioner to
change an accounting method for fed-
eral income tax purposes. Rev. Proc.
2015–13 provides both the procedures
to obtain the non-automatic consent of
the Commissioner to change a method
of accounting and the procedures to ob-
tain the automatic consent of the Com-
missioner to change a method of ac-
counting described in Rev. Proc. 2017–
30, 2017–18 I.R.B. 1131, (or successor)
(List of Automatic Changes).
.02 Section 7.01 of Rev. Proc. 2015–13
generally provides that a change in
method of accounting must be imple-
mented pursuant to the terms and condi-
tions provided in that revenue procedure
and either the List of Automatic Changes
(in the case of an automatic change) or the
letter ruling for the change in method of
accounting (in the case of a non-automatic
change).
.03 Section 7.02 of Rev. Proc. 2015–13
generally provides that a taxpayer making
a change in method of accounting must
compute an adjustment as required by
§ 481(a) and take into account this
§ 481(a) adjustment in the manner pro-
vided in section 7.03 of Rev. Proc. 2015–
13.
.04 Section 7.03(1) of Rev. Proc.
2015–13 generally provides that except as
otherwise provided in that revenue proce-
dure, the List of Automatic Changes (in
the case of an automatic change), a letter
ruling to the taxpayer (in the case of a
non-automatic change), or other guidance
published in the Internal Revenue Bulle-
tin, the § 481(a) adjustment period is one
taxable year (year of change) when the
§ 481(a) adjustment is negative and four
taxable years (year of change and next
three taxable years) when the § 481(a)
adjustment is positive. Section 7.03 also
provides additional rules regarding a
§ 481(a) adjustment period, such as when
there is a shortened or accelerated adjust-
ment period.
.05 Section 404A(g)(5) provides that,
for purposes of § 481, an election under
§ 404A is treated as a change in method of
accounting; an election under § 404A is
made under § 404A(e)(3), and, if applica-
ble, § 404A(f)(2). Section 404A(g)(5) fur-
ther provides that, in applying § 481 with
respect to any such election, the period for
taking into account any increase or de-
crease in accumulated profits, earnings
and profits, or taxable income resulting
from the application of § 481(a)(2) shall
be the year for which the election is made
and the fourteen succeeding years. Ac-
cordingly, this revenue procedure modi-
fies Rev. Proc. 2015–13 to specify that the
§ 481 adjustment period with respect to an
election under § 404A is fifteen taxable
years for a positive § 481(a) adjustment
and fifteen taxable years for a negative
§ 481(a) adjustment.
Bulletin No. 2017– 48November 27, 2017
543

SECTION 3. MODIFICATION OF
REV. PROC. 2015–13
Section 7.03 of Rev. Proc. 2015–13 is
modified to add section 7.03(5) to read as
follows:
(5)Elections under § 404A. Pursuant to
§ 404A(g)(5), the § 481(a) adjustment pe-
riod with respect to an election under
§ 404A is fifteen taxable years (year of
change and next fourteen taxable years)
for a positive § 481(a) adjustment and
fifteen taxable years (year of change and
next fourteen taxable years) for a negative
§ 481(a) adjustment.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2015–13 is modified.
SECTION 5. EFFECTIVE DATE
This revenue procedure is effective
for Forms 3115 filed under Rev. Proc.
2015–13 on or after November 13, 2017.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kari Fisher of the Office of
Associate Chief Counsel (Income Tax &
Accounting). For further information re-
lating to Rev. Proc. 2015–13, please con-
tact Ms. Fisher at (202) 317-7007 (not a
toll-free number), or for further informa-
tion relating to § 404A, contact Jeremy
Lamb of the Office of Associate Chief
Counsel (Tax Exempt and Government
Entities) at (202) 317-6799 (not a toll-free
number).
November 27, 2017Bulletin No. 2017– 48
544

Part IV. Items of General Interest
Section 7428(c)Validation
of Certain Contributions
Made During Pendency of
Declaratory Judgment
Proceedings
Announcement 2017–18
This announcement serves notice to
potential donors that the organization
listed below has recently filed a timely
declaratory judgment suit under section
7428 of the Code, challenging revocation
of its status as an eligible donee under
section 170(c)(2).
Protection under section 7428(c) of the
Code begins on the date that the notice of
revocation is published in the Internal
Revenue Bulletin and ends on the date on
which a court first determines that an or-
ganization is not described in section
170(c)(2), as more particularly set forth in
section 7428(c)(1).
In the case of individual contributors,
the maximum amount of contributions
protected during this period is limited to
$1,000.00, with a husband and wife being
treated as one contributor. This protection
is not extended to any individual who was
responsible, in whole or in part, for the
acts or omissions of the organization that
were the basis for the revocation. This
protection also applies (but without limi-
tation as to amount) to organizations de-
scribed in section 170(c)(2) which are ex-
empt from tax under section 501(a). If the
organization ultimately prevails in its de-
claratory judgment suit, deductibility of
contributions would be subject to the nor-
mal limitations set forth under section
170.
Name of OrganizationDate Suit FiledEffective Date of RevocationLocation
The Korean-American Senior Mutual
Association, Inc.
10/18/20179/6/2017Flushing, NY
Bulletin No. 2017– 48November 27, 2017
545

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
withamplifiedandclarified, 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,modifiedand
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. 2017– 48November 27, 2017
i

Numerical Finding List
1
Bulletin 2017–27 through 2017– 48
Action on Decision:
2017-5, 2017-27 I.R.B.1
2017-6, 2017-33 I.R.B.194
2017-7, 2017-42 I.R.B.311
Announcements:
2017-05, 2017-27 I.R.B.5
2017-08, 2017-28 I.R.B.9
2017-09, 2017-35 I.R.B.219
2017-10, 2017-33 I.R.B.210
2017-11, 2017-39 I.R.B.255
2017-12, 2017-38 I.R.B.238
2017-13, 2017-40 I.R.B.271
2017-15, 2017-47 I.R.B.534
2017-17, 2017-46 I.R.B.515
2017-18, 2017-48 I.R.B.545
Notices:
2017-36, 2017-33 I.R.B.208
2017-37, 2017-29 I.R.B.89
2017-38, 2017-30 I.R.B.147
2017-39, 2017-31 I.R.B.150
2017-40, 2017-32 I.R.B.190
2017-41, 2017-34 I.R.B.211
2017-42, 2017-34 I.R.B.212
2017-43, 2017-36 I.R.B.224
2017-44, 2017-36 I.R.B.226
2017-45, 2017-38 I.R.B.232
2017-46, 2017-41 I.R.B.275
2017-47, 2017-38 I.R.B.232
2017-48, 2017-39 I.R.B.254
2017-49, 2017-40 I.R.B.258
2017-50, 2017-41 I.R.B.280
2017-51, 2017-40 I.R.B.260
2017-52, 2017-40 I.R.B.262
2017-53, 2017-42 I.R.B.318
2017-54, 2017-42 I.R.B.321
2017-55, 2017-42 I.R.B.324
2017-56, 2017-43 I.R.B.365
2017-57, 2017-42 I.R.B.324
2017-58, 2017-42 I.R.B.326
2017-59, 2017-45 I.R.B.484
2017-60, 2017-43 I.R.B.365
2017-61, 2017-43 I.R.B.371
2017-62, 2017-44 I.R.B.460
2017-63, 2017-44 I.R.B.460
2017-64, 2017-45 I.R.B.486
2017-67, 2017-47 I.R.B.517
2017-68, 2017-46 I.R.B.513
2017-69, 2017-48 I.R.B.540
2017-70, 2017-48 I.R.B.543
Proposed Regulations:
REG-128841-07, 2017-42 I.R.B.327
REG-139633-08, 2017-31 I.R.B.175
REG-128483-15, 2017-32 I.R.B.191
REG-136118-15, 2017-28 I.R.B.9
REG-105004-16, 2017-41 I.R.B.295
REG-125374-16, 2017-41 I.R.B.300
REG-115615-17, 2017-44 I.R.B.463
REG-116256-17, 2017-46 I.R.B.514
REG-129631-17, 2017-44 I.R.B.464
Revenue Procedures:
2017-41, 2017-29 I.R.B.92
2017-42, 2017-29 I.R.B.124
2017-43, 2017-31 I.R.B.153
2017-44, 2017-35 I.R.B.216
2017-45, 2017-35 I.R.B.216
2017-46, 2017-43 I.R.B.372
2017-47, 2017-38 I.R.B.233
2017-48, 2017-36 I.R.B.229
2017-50, 2017-37 I.R.B.230
2017-52, 2017-41 I.R.B.283
2017-53, 2017-40 I.R.B.263
2017-54, 2017-42 I.R.B.336
2017-55, 2017-43 I.R.B.373
2017-56, 2017-44 I.R.B.465
2017-57, 2017-44 I.R.B.474
2017-58, 2017-45 I.R.B.489
2017-59, 2017-48 I.R.B.543
Revenue Rulings:
2017-14, 2017-27 I.R.B.2
2017-15, 2017-32 I.R.B.176
2017-16, 2017-35 I.R.B.215
2017-17, 2017-36 I.R.B.222
2017-18, 2017-39 I.R.B.239
2017-19, 2017-40 I.R.B.257
2017-20, 2017-41 I.R.B.273
2017-21, 2017-45 I.R.B.482
2017-22, 2017-48 I.R.B.536
Treasury Decisions:
9819, 2017-29 I.R.B.85
9820, 2017-32 I.R.B.178
9821, 2017-32 I.R.B.181
9822, 2017-33 I.R.B.195
9823, 2017-33 I.R.B.206
9824, 2017-42 I.R.B.312
9825, 2017-46 I.R.B.500
9827, 2017-44 I.R.B.382
9828, 2017-44 I.R.B.431
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017– 01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
November 27, 2017Bulletin No. 2017– 48
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2017–27 through 2017– 48
Notices:
2015-77
Amplified by
Notice 2017-40, 2017-32 I.R.B.190
2017-10
Modified by
Notice 2017-58, 2017-42 I.R.B.326
2017-29
Modified by
Notice 2017-58, 2017-42 I.R.B.326
Revenue Procedures:
2016-27
Modified by
Rev. Proc. 2017-43, 2017-31 I.R.B.153
2016-27
Superseded by
Rev. Proc. 2017-43, 2017-31 I.R.B.153
2016-48
Superseded by
Rev. Proc. 2017-48, 2017-36 I.R.B.232
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017– 01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
Bulletin No. 2017– 48November 27, 2017
iii

INTERNAL REVENUE BULLETIN
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