Internal Revenue Bulletin 2018-9 (PDF rendition): IRS Notices

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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.
ADMINISTRATIVE
Rev. Proc. 2018–16, page 383.
Thisrevenue procedure provides guidance to the Chief Executive
Officers (CEOs) of any State, about how certain population census
tracts may be designated as Qualified Opportunity Zones for
purposes of §§ 1400Z–1 and 1400Z–2 of the Internal Revenue
Code. Specifically, this revenue procedure clarifies the nomination
process under § 1400Z–1 by informing the CEOs of each State
which census tracts in their jurisdictions are eligible to be nomi-
nated to be Qualified Opportunity Zones and by providing the
requirements and due dates for the nomination, certification, and
designation of the zones. Additionally, this revenue procedure
provides a safe harbor for applying the 25 percent limitation to the
number of population census tracts in a state that may be desig-
nated as Qualified Opportunity Zones.
EXEMPT ORGANIZATIONS
Announcement 2018–01, page 387.
Serves notice to potential donors of a stipulated decision by
the United States Tax Court in declaratory judgment proceed-
ings under Section 7428.
Announcement 2018–02, page 387.
Serves notice to potential donors of a stipulated decision by
the United States Tax Court in declaratory judgment proceed-
ings under Section 7428.
Announcement 2018–03, page 387.
Serves notice to potential donors of a stipulated decision by
the United States Tax Court in declaratory judgment proceed-
ings under Section 7428.
Rev. Proc. 2018–15, page 379.
The IRS generally will not require a new exemption application
from a domestic section 501(c) organization that changes its
form or place of organization. Rev. Rul. 67–390 and Rev. Rul.
77–469 are obsoleted.
INCOME TAX
Notice 2018–15, page 376.
This Notice withdraws the solicitations in Notice 2015–12,
2015–10 I.R.B. 700, and Notice 2017–66, 2017–45 I.R.B. 487,
for applications for the remaining unused national limitation of
authority to issue new clean renewable energy bonds (New
CREBs) under § 54C of the Internal Revenue Code (the Code).
Section 54C of the Code was repealed by section 13404 of Public
Law No. 115–97, 131 Stat 2138 (2017) (Public Law No. 115–
97), effective for bonds issued after December 31, 2017.
Notice 2018–17, page 376.
In response to the devastation caused by Hurricane Maria to
the Commonwealth of Puerto Rico, this notice expands the
relief provided in Rev. Proc. 2014–49, 2014–37 I.R.B. 535,
and Rev. Proc. 2014–50, 2014–37 I.R.B. 540. The expanded
relief in this notice is limited to the Hurricane Maria PR Major
Disaster (as defined in the notice). This notice also solicits
public comment regarding any desirable amendments to Rev.
Proc. 2014–49 and Rev. Proc. 2014–50.
Rev. Proc. 2018–14, page 378.
This procedure modifies Rev. Proc. 2017–60, 2017–50 I.R.B.
559, to extend the time under the safe harbor for an individual
to pay to repair damage to his or her personal residence
resulting from deteriorating concrete foundations containing
the mineral pyrrhotite.
Rev. Proc. 2018–17, page 384.
This revenue procedure amends Rev. Proc. 2002–39, 2002–22
I.R.B. 1046, and Rev. Proc. 2006–45, 2006–45 I.R.B. 451, so
as to prohibit specified foreign corporations (for purposes of
section 965) with taxable years that end on December 31, 2017
from changing their annual accounting periods.
Finding Lists begin on page ii.
Bulletin No. 2018–9
February 26, 2018

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.
February 26, 2018Bulletin No. 2018–9

Part III. Administrative, Procedural, and Miscellaneous
New Clean Renewable
Energy Bonds
Notice 2018–15
SECTION 1. PURPOSE
This Notice withdraws the solicitations
in Notice 2015–12, 2015–10 I.R.B. 700,
and Notice 2017– 66, 2017– 45 I.R.B. 487,
for applications for the remaining unused
national limitation of authority to issue
new clean renewable energy bonds (New
CREBs) under § 54C of the Internal Rev-
enue Code (the Code). Section 54C of the
Code was repealed by section 13404 of
Public Law No. 115–97, 131 Stat 2138
(2017) (Public Law No. 115–97), effec-
tive for bonds issued after December 31,
2017.
SECTION 2. BACKGROUND
Section 54C of the Code authorized the
issuance of up to $2.4 billion (volume
cap) of New CREBs for qualified renew-
able energy facilities (as defined in
§ 54C(d)(1)) (projects). Section 54C(c)(2)
provided that up to 1/3 of the volume cap
is to be allocated to projects to be owned
by public power providers, governmental
bodies, and cooperative electric compa-
nies, respectively.
Notice 2015–12 solicits applications for
allocations of the remaining available vol-
ume cap of New CREBs for projects to be
owned by public power providers, govern-
mental bodies, and cooperative electric
companies. Section 4.c. of Notice 2015–12
provides that applications for projects to be
owned by governmental bodies or coopera-
tive electric companies may be submitted
beginning on March 5, 2015. Section 5.a.(ii)
of Notice 2015–12 provides that, except as
otherwise provided by section 5 of Notice
2015–12, the Internal Revenue Service
(IRS) will allocate the remaining available
volume cap designated for projects to be
owned by governmental bodies or coopera-
tive electric companies, respectively, on a
first-come, first-served basis by order of
submission date (as defined in section 4.a. of
Notice 2015–12). Notice 2015–12 provides
no deadline for applications for projects to
be owned by governmental bodies or coop-
erative electric companies. Under section
4.b. of Notice 2015–12, the deadline for
applications for projects to be owned by
public power providers is June 3, 2015.
The IRS later identified $379,549,691.35
of remaining available volume cap desig-
nated for projects to be owned by public
power providers. Notice 2017– 66 solicits
applications from qualified issuers of New
CREBs for projects to be owned by public
power providers, and sets forth June 19,
2018, as the due date for submitting appli-
cations.SeeSection 3 of Notice 2017– 66.
SECTION 3. STATUS OF
ALLOCATIONS AND THE
APPLICATION PROCESS
Section 13404(a) of Public Law No.
115–97 provides, in part, that part IV of
subchapter A of chapter 1 of the Code is
amended by striking subpart I, which con-
tained § 54C of the Code. Section
13404(d) of Public Law No. 115–97 pro-
vides that the amendments made by sec-
tion 13404 shall apply to bonds issued
after December 31, 2017. Accordingly, no
bond issued after December 31, 2017, un-
der any allocation of volume cap issued
by the IRS under Notice 2015–12, may be
treated as a New CREB. In addition, the
IRS will not be processing applications
for, or issuing allocations of, New CREBs
volume cap under Notice 2015–12 or No-
tice 2017– 66.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
This Notice obsoletes Notice 2015–12
in part by withdrawing the solicitation of
applications for, and discontinuing the al-
location of, New CREBs volume cap un-
der sections 3, 4, and 5 of Notice 2015–
12. All other provisions of Notice
2015–12 remain in effect for bonds issued
on or prior to December 31, 2017.
This Notice obsoletes Notice 2017– 66.
SECTION 5. DRAFTING
INFORMATION
The principal author of this Notice is
Zoran Stojanovic of the Office of Associ-
ate Chief Counsel (Financial Institutions
and Products). For further information re-
garding this Notice, contact Mr. Sto-
janovic at 202-317-6980 (not a toll-free
number).
Low-Income Housing Credit
Disaster Relief for the
Commonwealth of Puerto
Rico
Notice 2018–17
I.PURPOSE
In response to the devastation caused
by Hurricane Maria to the Commonwealth
of Puerto Rico (hereinafter, Puerto Rico),
this notice expands the relief that is pro-
vided in Rev. Proc. 2014 – 49, 2014 –37
I.R.B. 535, and Rev. Proc. 2014 –50,
2014 –37 I.R.B. 540. The expanded relief
in this notice is limited to the Hurricane
Maria PR Major Disaster, as defined be-
low. Except as expressly provided in this
notice, all provisions of Rev. Procs.
2014 – 49 and 2014 –50 apply to the Hur-
ricane Maria PR Major Disaster without
modification.
This notice also solicits public com-
ment regarding any desirable modifica-
tions to Rev. Procs. 2014 – 49 and 2014 –
50.
II.BACKGROUND
Rev. Procs. 2014 – 49 and 2014 –50
provide temporary relief from certain re-
quirements of §§ 42 and 142(d) of the
Internal Revenue Code in the context of a
major disaster. Rev. Proc. 2014 – 49 pro-
vides guidance and relief to the owners of
qualified low-income housing projects
(each such project,a§42Project) and to
Agencies (as defined in section 5.01 of
Rev. Proc. 2014 – 49) that are responsible
for those § 42 Projects. Rev. Proc.
2014 –50 provides guidance to issuers of
exempt facility bonds financing qualified
residential rental projects under § 142(d)
(each such issuer, an Issuer; each such
project, a § 142(d) Project) and to opera-
tors of those § 142(d) Projects. Various
aspects of these revenue procedures apply
with respect to § 42 Projects and § 142(d)
Projects both inside and outside of the
area in which the major disaster occurs.
February 26, 2018Bulletin No. 2018–9
376

Sections 12 through 14 of Rev. Proc.
2014 – 49 and sections 5 through 7 of Rev.
Proc. 2014 –50 facilitate emergency hous-
ing relief for Displaced Individuals (as
defined in section 5.02 of Rev. Proc.
2014 – 49 and in section 4.02 of Rev. Proc.
2014 –50). To achieve this end, these sec-
tions give owners of § 42 Projects and
operators of § 142(d) Projects the option
to apply certain modifications to the rules
of §§ 42 and 142(d), provided that the
relevant Agency or Issuer authorizes the
owner or operator to do so. Among these
modifications is the ability to disregard
the actual income of a Displaced Individ-
ual housed ina§42Project or a § 142(d)
Project, even if the Displaced Individual’s
income exceeds the limitations on income
provided in §§ 42 or 142(d). The option to
apply these modified rules is limited to a
period defined in the revenue procedures
as the Temporary Housing Period.See
section 5.08 of Rev. Proc. 2014 – 49 and
section 4.13 of Rev. Proc. 2014 –50. The
Temporary Housing Period begins on the
first day of the incident period, as deter-
mined by the Federal Emergency Man-
agement Agency (FEMA), and ends on a
date determined by the Agency or Issuer.
Both revenue procedures provide a date
beyond which the Temporary Housing Pe-
riod may not extend.Seesection 12.02(1)
of Rev. Proc. 2014 – 49 and section
5.02(1) of Rev. Proc. 2014 –50.
On September 20, 2017, the President
of the United States issued major disaster
and emergency declarations with respect
to Hurricane Maria under the authority of
the Robert T. Stafford Disaster Relief and
Emergency Assistance Act, 42 U.S.C.
§§ 5121–5206 (the Stafford Act), and
FEMA determined certain areas within
Puerto Rico to be eligible for Public As-
sistance or Public Assistance and Individ-
ual Assistance under the Stafford Act (the
Hurricane Maria PR Major Disaster).See
82 Fed. Reg. 46820 (2017). The incident
period for the Hurricane Maria PR Major
Disaster began on September 17, 2017,
and closed on November 15, 2017.See82
Fed. Reg. 61768 (2017).
Agencies must periodically review
§ 42 Projects for compliance with the af-
fordability and habitability requirements
of § 42. See §§ 42(m)(1)(B)(iii) and
142(d)(7); also see §§ 1.42–5 and 1.42–5T
of the Income Tax Regulations. Under
section 9 of Rev. Proc. 2014 – 49, an
Agency may extend the due date for its
scheduled compliance reviews for up to
one calendar year from the date of a low-
income building’s restoration and place-
ment again into service. That revenue pro-
cedure does not delay the compliance
review due dates of buildings that do not
require restoration and replacement into
service.
Ordinarily, even though an owner has
received a carryover allocation of housing
credit dollar amount for a building, the
benefit of that allocation may be lost if the
owner does not timely meet certain prog-
ress benchmarks with respect to the build-
ing. First, not later than the due date in
§ 42(h)(1)(E)(ii), the owner’s basis in the
§ 42 Project containing the building must
be more than 10 percent of the owner’s
reasonably expected eventual basis in the
project. Second, the building must be
placed in service not later than the due
date in § 42(h)(1)(E)(i). However, in
the case of certain buildings located in
major disaster areas, sections 6 and 7 of
Rev. Proc. 2014 – 49 authorize the Agency
responsible for a building to extend these
deadlines for limited periods.
III.EMERGENCY HOUSING
RELIEF
Solely in connection with the Hurri-
cane Maria PR Major Disaster, the second
sentence of section 12.02(1) in Rev. Proc.
2014 – 49 and the second sentence of sec-
tion 5.02(1) in Rev. Proc. 2014 –50 are
revised to read: “The Temporary Housing
Period cannot extend beyond the end of
May 2019.”
IV.COMPLIANCE MONITORING
RELIEF
Under this notice, the Puerto Rico
Housing Finance Authority (PRHFA)
may extend the date for its compliance
review of low-income buildings located in
Puerto Rico notwithstanding section 9 of
Rev. Proc. 2014 – 49. For any such build-
ing, this extension may not last beyond
one calendar year from the later of—
•November 15, 2017; or
•In the case of a building that has suf-
fered a casualty loss due to Hurricane
Maria or has been taken out of service
due to that hurricane, the date of the
building’s restoration and placement
again in service.
This extension of dates for compliance
review by the PRHFA does not, however,
extend the compliance monitoring dead-
lines for owners. If the PRHFA learns that
an owner or operator has failed to comply
with the rules of § 42, as applicable, the
noncompliance must be reported timely to
the Internal Revenue Service (Service),
along with a description of whether and
how Hurricane Maria contributed to the
noncompliance.
V.CARRYOVER ALLOCATION
RELIEF
Notwithstanding the limitations in sec-
tions 6 and 7 of Rev. Proc. 2014 – 49, under
this notice the PRHFA may grant extensions
of the due date in § 42(h)(1)(E)(ii) (regard-
ing basis) for up to 12 months after the later
of—
•The due date prior to any extension; or
•November 15, 2017.
Similarly, the PRHFA may grant ex-
tensions of the due date in § 42(h)(1)(E)(i)
(regarding placement into service) up to
December 31 of the first calendar year
following the calendar year containing the
due date in § 42(h)(1)(E)(ii), taking into
account any extension granted under the
preceding paragraph.
Except for the ability to extend these
two due dates for longer periods, all other
procedures and limitations in sections 6
and 7 continue to apply to buildings af-
fected by the Hurricane Maria PR Major
Disaster. As is the case for extensions
under those sections, if an owner satisfies
an extended due date prescribed by the
PRHFA under this notice, the Service will
not assert that the owner fails to satisfy
§ 42(h)(1)(E)(i) or (ii), as applicable.
VI.REQUEST FOR COMMENTS
REGARDING POSSIBLE
IMPROVEMENTS TO REVENUE
PROCEDURES 2014–49 AND 2014–50
The Department of the Treasury and the
Service are considering whether to make
any changes to Rev. Procs. 2014 – 49 and
2014 –50, and, in that regard, request com-
ments from the public regarding possible
changes to the two revenue procedures.
Comments should be submitted by April 12,
2018. Comments may be mailed to:
Bulletin No. 2018–9February 26, 2018
377

Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2018 –17)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
or hand delivered Monday through Friday
between the hours of 8 a.m. and 4 p.m. to:
Courier’s Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2018 –17)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
Alternatively, persons may submit com-
ments electronically via e-mail to the fol-
lowing address:
Notice.Comments@irscounsel.treas.gov.
Persons should include “Notice 2018 –
17” in the subject line. All comments sub-
mitted by the public will be available for
public inspection and copying in their en-
tirety.
VII.DRAFTING INFORMATION
The principal author of this notice is
James W. Rider of the Office of Associate
Chief Counsel (Passthroughs & Special
Industries). For further information re-
garding this notice contact Mr. Rider at
(202) 317-4137 (not a toll-free number).
26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of
correct tax liability.
(Also Part 1, §§ 165; 1.165–7(a)(2); 1.165–7(b).)
Rev. Proc. 2018–14
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 2017– 60, 2017–50 I.R.B. 559, to
extend the time for individuals to pay to
repair damage to their personal resi-
dences resulting from deteriorating con-
crete foundations caused by the pres-
ence of the mineral pyrrhotite.
SECTION 2. BACKGROUND
.01 Revenue Procedure 2017– 60 pro-
vides a safe harbor method that allows a
taxpayer who pays to repair damage to
that taxpayer’s personal residence result-
ing from a deteriorating concrete founda-
tion that contains the mineral pyrrhotite to
treat the amount paid as a casualty loss in
the year of payment.
.02 The safe harbor is available to a
taxpayer who has obtained a written eval-
uation from a licensed engineer indicating
that the foundation was made with defec-
tive concrete, and has requested and re-
ceived a reassessment report that shows
the reduced reassessed value of the resi-
dential property based on the written eval-
uation from the engineer and an inspec-
tion pursuant to Connecticut Public Act
No. 16 – 45. The safe harbor also is avail-
able to a taxpayer whose personal resi-
dence is either in Connecticut or outside
of Connecticut, provided the taxpayer has
obtained a written evaluation from a li-
censed engineer indicating that the foun-
dation was made with defective concrete
containing the mineral pyrrhotite.
03. To claim a casualty loss under the
safe harbor in Rev. Proc. 2017– 60, a tax-
payer generally must have paid to repair
damage caused by a deteriorating concrete
foundation before January 1, 2018.
04. In view of the unique hardships
caused by the extensive repairs necessary
to remedy the deteriorating concrete foun-
dations and the comments received ex-
pressing concern that taxpayers need ad-
ditional time to make the repairs, the
Department of the Treasury and the Inter-
nal Revenue Service have determined that
it is appropriate to modify the safe harbor
in Rev. Proc. 2017– 60 to extend the time
for individual taxpayers to pay to repair
the damage to their personal residences.
SECTION 3. MODIFICATION TO
REV. PROC. 2017–60
Section 4.01 of Rev. Proc. 2017– 60, is
modified and as modified, this section
reads in its entirety as follows:
.01 If a taxpayer pays to repair damage
to that taxpayer’s personal residence
caused by a deteriorating concrete foun-
dation during the taxpayer’s 2016 taxable
year or earlier, the taxpayer may treat the
amount paid as a casualty loss on a timely
Amended U.S. Individual Income Tax Re-
turn (Form 1040X) for the taxable year of
payment. If a taxpayer pays to repair the
damage during the taxpayer’s 2017 tax-
ableyear or prior to a timely filed (including
extensions) original U.S. Individual Income
Tax Return (Form 1040, 1040A or 1040EZ)
for the 2017 taxable year, the taxpayer may
treat the amount paid as a casualty loss on
the taxpayer’s original 2017 income tax re-
turn (or a timely filed Form 1040X for the
2017 taxable year). If a taxpayer pays to
repair the damage after filing an original
2017 income tax return and prior to the last
day for filing a timely Form 1040X for the
2017 taxable year, the taxpayer may treat
the amount paid as a casualty loss on a
timely filed Form 1040X for the 2017 tax-
able year. For purposes of this revenue pro-
cedure, the term “deteriorating concrete
foundation” means a concrete foundation
that is damaged as a result of the presence of
the mineral pyrrhotite in the concrete mix-
ture used before January 1, 2018, in pouring
the foundation. The safe harbor under this
revenue procedure is available to a tax-
payer who has obtained a written eval-
uation from a licensed engineer indicat-
ing that the foundation was made with
defective concrete, and has requested
and received a reassessment report that
shows the reduced reassessed value of
the residential property based on the
written evaluation from the engineer and
an inspection pursuant to Connecticut
Public Act No. 16 – 45 (Act). The safe
harbor also is available to a taxpayer
whose personal residence is either in
Connecticut or outside of Connecticut,
provided the taxpayer has obtained a
written evaluation from a licensed engi-
neer indicating that the foundation was
made with defective concrete containing
the mineral pyrrhotite.
SECTION 4. EFFECTIVE DATE
This modification in this revenue pro-
cedure will be treated as in effect as of the
effective date of Rev. Proc. 2017– 60,
which is for federal income tax returns
(including amended federal income tax
returns) filed after November 21, 2017.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2017– 60 is modified.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Susie K. Bird of the Office of
Associate Chief Counsel (Income Tax &
Accounting). For further information re-
garding this revenue procedure contact
February 26, 2018Bulletin No. 2018–9
378

Susie K. Bird on (202) 317-5100 (not a
toll-free number).
26 CFR 1.501(a)–1: Exemption from taxation
(Also: 26 CFR 1.505(c)–1T: Notification require-
ment; 26 CFR 1.506 –1T: Notification requirement;
26 CFR 1.508 –1: Notices; 26 CFR 601.201: Rulings
and determination letters)
Rev. Proc. 2018–15
The IRS generally will not require a new
exemption application from a domestic sec-
tion 501(c) organization that changes its
form or place of organization. Rev. Rul.
67–390 and Rev. Rul. 77– 469 are obso-
leted.
SECTION 1. PURPOSE
This revenue procedure reduces com-
pliance burdens on certain exempt organi-
zations by providing the circumstances
under which the Internal Revenue Service
(IRS) generally will not require domestic
business entities to file a new exemption
application when they change their form
or state of organization. This revenue pro-
cedure obsoletes Rev. Rul. 67–390 and
Rev. Rul. 77– 469.
SECTION 2. BACKGROUND AND
ANALYSIS
Section 501(a) of the Internal Revenue
Code (Code) provides that an organization
described in section 501(c) shall be ex-
empt from taxation under Subtitle A of the
Code.
Section 1.501(a)–1(a)(2) of the Trea-
sury Regulations provides that it is neces-
sary for an organization to file an applica-
tion in order to establish its exemption.
Section 1.501(a)–1(a)(3) of the Trea-
sury Regulations provides that an organi-
zation claiming exemption under section
501(a) and described in section 501(c)
shall file the form of application pre-
scribed by the Commissioner.
Section 505 of the Code generally pro-
vides that an organization shall not be
treated as described in paragraph (9), (17),
or (20) of section 501(c) unless it has
given notice to the Secretary that it is
applying for recognition of exemption.
Section 506 of the Code generally pro-
vides that an organization described in
section 501(c)(4) shall, not less than 60
days after the organization is established,
notify the Secretary that it is operating as
such.
Section 508 of the Code generally pro-
vides that an organization organized after
October 9, 1969 shall not be treated as
described in section 501(c)(3) unless it
has given notice to the Secretary that it is
applying for recognition of exemption.
Section 1.508 –1(a)(2) of the Treasury
Regulations provides that an organization
seeking exemption under section 501(c)(3)
files the notice described in section 508(a)
by submitting a properly completed and ex-
ecuted Form 1023 (or, if applicable, Form
1023–EZ) exemption application.
Section 6109(a) of the Code generally
provides that any person required to make
a return, statement or other document un-
der subtitle A shall include its identifying
number.
Section 6109(c) of the Code provides
that the Secretary or his delegate is autho-
rized to require such information as may
be necessary to assign an identifying num-
ber to any person.
Section 301.6109 –1(a)(1)(ii)(C) of the
Treasury Regulations provides that any per-
son other than an individual that is required
to furnish a taxpayer identifying number
must use a federal Employer Identification
Number (EIN). Section 301.6109 –1(h)(1)
of the Treasury Regulations generally pro-
vides that any entity with an EIN will retain
that EIN if its federal tax classification
changes under § 301.7701–3 of the Trea-
sury Regulations. For special EIN rules, see
§ 301.6109 –1(h)(2) of the Treasury Regu-
lations (entities disregarded as separate from
their owners) and (i) (qualified subchapter S
subsidiaries).
Section 301.7701–2(a) of the Treasury
Regulations provides that a business en-
tity is any entity recognized for federal tax
purposes(including an entity with a sin-
gle owner that may be disregarded as an
entity separate from its owner under
§ 301.7701–3 of the Treasury Regula-
tions) that is not properly classified as a
trust under § 301.7701– 4 of the Trea-
sury Regulations or otherwise subject to
special treatment under the Code. It fur-
ther provides that a business entity with
two or more members is classified for
federal tax purposes as either a corpora-
tion or a partnership, and a business
entity with only one owner is classified
as a corporation or is disregarded.
Section 301.7701–2(b)(1) of the Trea-
sury Regulations provides that a business
entity organized under a federal or state
statute is a corporation if the statute de-
scribes or refers to the entity as incorpo-
rated or as a corporation, body corporate,
or body politic.
Section 301.7701–2(b)(2) of the Trea-
sury Regulations provides that an associ-
ation as determined in § 301.7701–3 of
the Treasury Regulations is a corporation.
Section 301.7701–3(a) of the Treasury
Regulations provides that a business en-
tity that is not classified as a corporation
under § 301.7701–2(b)(1), (3), (4), (5),
(6), (7), or (8) (an “eligible entity”) can
elect its classification for federal tax pur-
poses. An eligible entity with at least two
members can elect to be classified as ei-
ther an association (and thus a corporation
under § 301–7701–2(b)(2) of the Treasury
Regulations) or a partnership, and an eli-
gible entity with a single owner can elect
to be classified as an association or to be
disregarded as an entity separate from its
owner. Section 301.7701–3(c)(1)(v)(A) of
the Treasury Regulations provides that an
eligible entity that has been determined to
be, or claims to be, exempt from taxation
under section 501(a) is treated as having
made an election to be classified as an
association (and thus a corporation under
§ 301.7701–2(b)(2) of the Treasury Reg-
ulations).
Rev. Proc. 2018 –5, 2018 –1 I.R.B. 233,
as modified by Rev. Proc. 2018 –10,
2018 –7 I.R.B. 355, sets forth procedures
for issuing determination letters on ex-
empt status (in response to applications
for recognition of exemption from federal
income tax under section 501) under the
jurisdiction of the Director, Exempt Orga-
nizations (EO) Rulings and Agreements.
Section 3.01 of Rev. Proc. 2018 –5 pro-
vides that EO Determinations issues de-
termination letters on initial qualification
for exempt status of organizations de-
scribed in section 501, and updated ex-
empt status letters (affirmation letters) to
reflect changes to an organization’s name
or address. Section 3.02 of Rev. Proc.
2018 –5 provides that EO Determinations
will not issue a determination letter if an
organization currently recognized as ex-
empt under section 501(c) seeks a new
determination letter confirming that the
organization is still recognized under the
Bulletin No. 2018–9February 26, 2018
379

same Code section under the currently
extant facts. Section 4 of Rev. Proc.
2018 –5 provides that organizations seek-
ing recognition of exemption under sec-
tion 501(c)(3) must submit a completed
Form 1023 or Form 1023–EZ (if applica-
ble), organizations seeking recognition of
exemption under section 501(c)(4) must
submit a completed Form 1024 –A, orga-
nizations seeking recognition of exemp-
tion under sections 501(c)(2), (5), (6), (7),
(8), (9), (10), (12), (13), (15), (17), (19),
and (25) mustsubmit a completed Form
1024, and organizations seeking recognition
of exemption under sections 501(c)(11),
(14), (16), (18), (21), (22), (23), (26), (27),
(28), or (29), or under section 501(d) must
submit a letter application. Section 11.02 of
Rev. Proc. 2018 –5 provides that an organi-
zation may not rely on its determination
letter if there is a material change of facts,
inconsistent with exemption, in the charac-
ter, purpose, or method of operation of the
organization.
Rev. Rul. 67–390, 1967–2 C.B. 179,
holds that a new exemption application is
required in four cases where an organiza-
tion previously recognized as exempt
from federal income tax under section
501(a) makes certain changes in its struc-
ture. The four structural changes are: (1)
incorporation of a trust; (2) incorporation
of an association; (3) reincorporation by
an Act of Congress; and (4) reincorpora-
tion under the laws of another state. The
ruling states that each of these cases cre-
ates a new legal entity and, accordingly,
each new organization must file an appli-
cation for exemption to establish that the
new entity qualifies for exemption under
the Code and applicable regulations.
Rev. Rul. 77– 469, 1977–2 C.B. 196,
holds that an unincorporated association
which incorporated after the enactment
of section 508 is a new legal entity and
therefore is required to file an applica-
tion to be recognized as exempt under
section 501(c)(3).
Accordingly, the IRS in the past has
specified in forms and publications that a
new exemption application is required if
an exempt organization changes its legal
structure, such as from a trust to a corpo-
ration, or it dissolves in one state and
incorporates in another.See, e.g., Publica-
tion 557, Tax Exempt Status for Your
Organization (Rev. Jan. 2018) and 2017
Instructions for Form 990 Return of Or-
ganization Exempt from Income Tax (Jan.
18, 2018). These IRS forms and publica-
tions also specify that organizations are
required to report new significant program
services or significant changes in how
they conduct program services, and sig-
nificant changes to their organizational
documents, on their Forms 990 rather than
in letters to EO Determinations.Id.
However, other rules generally provide
that in many of these circumstances a new
EIN is not required for federal tax pur-
poses. For example, when one corporation
merges into another corporation under
state law and the latter corporation sur-
vives, a new EIN is not required for the
surviving corporation. Similarly, a new
EIN is not required if a corporation incor-
porated under the laws of one state rein-
corporates as a corporation incorporated
under the laws of another state.SeeRev.
Rul. 73–526, 1973–2 C.B. 404.
Publication 1635, Employer Identifica-
tion Number, Understanding your EIN
(February 2014), provides further instruc-
tion regarding when a new EIN is neces-
sary. Specifically, Publication 1635 spec-
ifies that a new EIN is not required in the
following cases:
•After a corporate merger, the surviving
corporation uses its existing EIN.
•After a corporate reorganization, a cor-
poration only changes its identity,
form, or place of organization.
Publication 1635 also specifies that a
new EIN is required in the following
cases:
•A corporation creates a new corpora-
tion after a statutory merger.
•A trust changes to an estate or other
non-trust.
In 2015, the Department of the Trea-
sury (Treasury Department) and the IRS
announced they are studying how to as-
sign (or reassign) EINs to taxpayers fol-
lowing a reorganization under section
368(a)(1)(F) of the Code, including in
cases in which the transferor corporation
remains in existence as a disregarded en-
tity, and requested public comments. T.D.
9739, 80 F.R. 56904, 56911 (Sept. 21,
2015).
The IRS rules for new exemption ap-
plications generally are more burdensome
than the rules for new EINs described
above. Specifically, Rev. Ruls. 67–390
and 77– 469 require new exemption appli-
cations in the following cases in which
IRS rules generally do not require a new
EIN:
•Incorporation of an exempt associa-
tion.
•Reincorporation under an Act of Con-
gress.
•Reincorporation of an exempt corpo-
ration in a different state.
Moreover, the Treasury Department
and the IRS have not published guidance
on whether a new exemption application
is required in the following circumstances
in which the IRS may not require a new
EIN:
•Continuation of a surviving corpora-
tion after a statutory merger of exempt
organizations.
•Filing articles of domestication in a
different state by an exempt organiza-
tion.
Requiring a new exemption application
after a corporate restructuring often is un-
necessary and duplicative, because the
IRS requires exempt organizations to re-
port significant organizational changes on
their annual Forms 990. Moreover, any
possible exemption issues with a corpo-
rate restructuring are less burdensome for
the IRS to administer when the surviving
organization can continue to use the same
EIN on its Form 990 as the restructuring
organization. Accordingly, this revenue
procedure generally eliminates the re-
quirement for domestic business entities
classified as corporations for federal tax
purposes to file a new exemption applica-
tion after a corporate restructuring, if cer-
tain conditions are met, to better align the
requirements for new exemption applica-
tions with the requirements for obtaining
new EINs in common restructuring situa-
tions.
In light of the pending Treasury De-
partment and IRS study on assigning and
reassigning EINs in certain reorganiza-
tions under section 368(a)(1)(F), and the
lack of published guidance explaining
how exemption requirements apply to
limited liability companies organized un-
der various state laws, this revenue proce-
dure does not apply to corporate restruc-
turing transactions with limited liability
companies or foreign business entities.
February 26, 2018Bulletin No. 2018–9
380

SECTION 3. SCOPE
This revenue procedure applies to cor-
porate restructurings of domestic business
entities that are classified as corporations
under § 301.7701–2(b)(1) or (2) of the
Treasury Regulations and are recognized
as exempt under section 501(a) as organi-
zations described in section 501(c).
SECTION 4. DEFINITIONS.
The following definitions apply for
purposes of this revenue procedure.
.01Business entityhas the meaning
specified in § 301.7701–2(a) of the Trea-
sury Regulations.
.02Corporate restructuringmeans in-
corporation under the laws of a state, re-
incorporation of a corporation incorpo-
rated under the laws of one state under the
laws of a different state, filing articles of
domestication for a corporation incorpo-
rated under the laws of one state under the
laws of a different state, or a statutory
merger of one corporation with and into
another corporation.
.03Disregarded Entityis an entity that
is disregarded as an entity separate from
its owner described in § 301.7701–2(c)
(2)(i) of the Treasury Regulations.
.04Domestic business entityis a
business entity that is domestic under
§ 301.7701–5(a) of the Treasury Regu-
lations.
.05Domestic trustis a trust that is
domestic under § 301.7701–7(a)(1) of the
Treasury Regulations.
.06Eligible entityhas the meaning
specified in § 301.7701–3(a) of the Trea-
sury Regulations.
.07Employer identification numberhas
the meaning specified in § 301.7701–12 of
the Treasury Regulations.
.08Exemption Applicationmeans
Form 1023, Form 1023–EZ, Form 1024,
Form 1024 –A, or letter application, as
applicable.
.09Foreign business entityis a business
entity that is foreign under § 301.7701–5(a)
of the Treasury Regulations.
.10Limited liability companymeans an
entity formed under a state limited liabil-
ity company act.
.11Restructuring organizationmeans
any organization exempt under section
501(a) as an organization described in
section 501(c) that enters into a corporate
restructuring.
.12Surviving organizationmeans a
surviving or resulting entity of a corporate
restructuring.
SECTION 5. EXEMPTION
APPLICATION REQUIREMENTS
FOR SURVIVING
ORGANIZATIONS OF
CORPORATE RESTRUCTURINGS
.01 In general
Subject to the requirements and limita-
tions in section 5.02, 5.03 and 5.04 of this
revenue procedure, in the case of a corpo-
rate restructuring of a domestic business
entity that is classified as a corporation
under § 301.7701–2(b)(1) or (2) of the
Treasury Regulations and is recognized as
exempt under section 501(a) as an orga-
nization described in section 501(c), the
surviving organization will not be re-
quired to file a new exemption application
to be exempt under section 501(a) as an
organization described in the same para-
graph of section 501(c) if such surviving
organization is—
(1) a domestic business entity;
(2) classified as a corporation under
§ 301.7701–2(b)(1) or (2) of the Treasury
Regulations; and
(3) carrying out the same purposes as
the exempt organization that engaged in
the corporate restructuring.
.02 Good standing requirement
For purposes of this section 5, the re-
structuring organization (or all restructur-
ing organizations in the case of a statutory
merger) must be in good standing with the
state in which it was incorporated (or
formed in the case of unincorporated as-
sociations).
.03 Additional requirement for section
501(c)(3) organizations
For purposes of this section 5, if the
restructuring organization is exempt under
section 501(a) as an organization de-
scribed in section 501(c)(3), the articles of
organization of the surviving organization
must continue to meet the organizational
test of § 1.501(c)(3)–1(b) of the Treasury
Regulations, including § 1.501(c)(3)–
1(b)(4) (regarding dedication of assets to
exempt purposes).
.04 Excluded corporate restructurings
Section 5 of this revenue procedure
does not apply to any corporate restruc-
turing in which (1) the restructuring orga-
nization or the surviving organization is a
disregarded entity, limited liability com-
pany, partnership, or foreign business en-
tity; or (2) the surviving organization ob-
tains a new EIN.
.05 Exemption application procedures
for organizations not meeting
requirements of section 5 of this
revenue procedure.
Surviving organizations that do not
meet the requirements of section 5 of this
revenue procedure and that want to be
recognized as exempt under section
501(a) should refer to Rev. Proc. 2018 –5
for the procedures to apply for a determi-
nation letter.
SECTION 6. REPORTING
REQUIREMENTS
The surviving organization must report
the corporate restructuring on any required
Form 990 for the applicable taxable year. In
the case of a domestication or reincorpora-
tion in a different state, the surviving orga-
nization must also report a change of ad-
dress as prescribed by the Commissioner.
SeeForm 8822–B; Form 990;https://www.
irs.gov/charities-non-profits/other-non-profits/
change-of-address-exempt-organizations.
SECTION 7. EXAMPLES
The application of this revenue proce-
dure is demonstrated in the following ex-
amples. In the examples, each restructur-
ing organization is recognized as exempt
under section 501(a) and is in good stand-
ing in its state of incorporation or forma-
tion, the surviving organization continues
to carry out the same purposes as the
restructuring organization, and (for sec-
tion 501(c)(3) organizations) the articles
of incorporation of the surviving organi-
zation continue to meet the organizational
test of § 1.501(c)(3)–1(b) of the Treasury
Regulations, including § 1.501(c)(3)–
1(b)(4) (regarding dedication of assets to
exempt purposes).
Bulletin No. 2018–9February 26, 2018
381

.01 Incorporation of an association
A is an unincorporated nonprofit orga-
nization that was formed on Date 1 under
the laws of State M. On Date 2, the IRS
recognized A as exempt under section
501(c)(3). A is a domestic business entity
and is treated under § 301.7701–3(c)(1)
(v)(A) as having made an election to be
classified as anassociation (and thus a
corporation under § 301.7701–2(b)(2)).
On Date 3, A incorporates in State M,
and is classified as a corporation under
§ 301.7701–2(b)(1).Because A, as both
the restructuring organization and the sur-
viving organization, is a domestic business
entity classified as a corporation, pursuant to
section 5.01 of this revenue procedure, A
continues to be recognized as exempt under
section 501(c)(3) and is not required to file a
new Form 1023.
.02 Incorporation of a trust
B is a charitable trust that was formed
on Date 1 under the laws of State N. B is
a domestic trust. B is not a business entity.
On Date 2, the IRS recognized B as ex-
empt under section 501(c)(3). On Date 3,
B incorporates in State N. Because the
restructuring organization B is not a busi-
ness entity, pursuant to section 5.01 of this
revenue procedure, B is required to file a
new Form 1023 to be recognized as ex-
empt under section 501(c)(3).SeeRev.
Proc. 2018 –5, § 3.01(1).
.03 Reincorporation in a different state
C is a corporation formed on Date 1
under the laws of State O. C is a domestic
business entity classified as a corporation
under § 301.7701–2(b)(1). On Date 2, the
IRS recognized C as exempt under section
501(c)(4). On Date 3, C reincorporates in
State P. Because C, as both the restructur-
ing organization and the surviving organi-
zation, is a domestic business entity clas-
sified as a corporation, pursuant to section
5.01 of this revenue procedure, C contin-
ues to be recognized as exempt under sec-
tion 501(c)(4) without filing a new appli-
cation for recognition of exemption.
.04 Domestication
D is a corporation formed on Date 1
under the laws of State Q. D is a domestic
business entity classified as a corporation
under § 301.7701–2(b)(1). On Date 2, the
IRS recognized D as exempt under section
501(c)(3). On Date 3, D files articles of
domestication with the corporation gov-
erning agency of State R and a certificate
of conversion with the corporation gov-
erning agency of State Q. Under the laws
of State Q and State R, D continues to
exist as the same corporation. Because D,
as both the restructuring organization and
the surviving organization, is a domestic
business entity classified as a corporation,
pursuant to section 5.01 of this revenue
procedure, D continues to be recognized
as exempt under section 501(c)(3) and is
not required to file a new Form 1023.
.05 Restructuring as a limited liability
company
E is a corporation formed on Date 1
under the laws of State S. E is a domestic
business entity classified as a corporation
under § 301.7701–2(b)(1). On Date 2, the
IRS recognized E as exempt under section
501(c)(3). On Date 3, E converts into a
limited liability company under the laws
of State T.Because the surviving organiza-
tion E is a limitedliability company, pur-
suant to section 5.04 of this revenue
procedure, E is required to file a new
Form 1023 to be recognized as exempt
under section 501(c)(3).SeeRev. Proc.
2018 –5, § 3.01(1).
.06 Reincorporation of a foreign entity
F is a corporation formed on Date 1
under the laws of Country U. F is a for-
eign business entity classified as a corpo-
ration under § 301.7701–2(b)(8). On Date
2, the IRS recognized F as exempt under
section 501(c)(3). On Date 3, F reincor-
porates in State V. Because the restructur-
ing organization F is a foreign business
entity, pursuant to section 5.04 of this
revenue procedure, F is required to file a
new Form 1023 to be recognized as ex-
empt under section 501(c)(3).SeeRev.
Proc. 2018 –5, § 3.01(1).
.07 Merger into an existing corporation
G is a corporation formed on Date 1
under the laws of State W. G is a domestic
business entity classified as a corporation
under § 301.7701–2(b)(1). On Date 2, the
IRS recognized G as exempt under section
501(c)(3). H is a corporation formed on
Date 1 under the laws of State X. H is a
domestic business entity classified as a
corporation under § 301.7701–2(b)(1). On
Date 3, the IRS recognized H as exempt
under section 501(c)(3). On Date 4, G
merged into H in accordance with the
applicable state merger statutes and H was
the surviving organization. After the cor-
porate restructuring, H carries out the
same purposes that G and H carried out
prior to the corporate restructuring. Be-
cause both G and H are domestic business
entities classified as corporations, pursu-
ant to section 5.01 of this revenue proce-
dure, H continues to be recognized as
exempt under section 501(c)(3) and is not
required to file a new Form 1023.
.08 Merger into a disregarded entity
I is a corporation formed on Date 1
under the laws of State Y. I is a domestic
business entity classified as a corporation
under § 301.7701–2(b)(1). On Date 2, the
IRS recognized I as exempt under section
501(c)(3). On Date 3, J is formed as a
State Z corporation. J is a domestic busi-
ness entity classified as a corporation un-
der § 301.7701–2(b)(1). On Date 4, the
IRS recognized J as exempt under section
501(c)(3). On Date 5, J forms a new State
Z limited liability company K that is a
disregarded entity. On Date 6, I merges
into K under the applicable state laws.
After the corporate restructuring, J, di-
rectly and through K, carries out the same
purposes that I and J carried out prior to
the corporate restructuring. Because K is a
limited liability company, section 5 of this
revenue procedure does not apply. K is
required to file a new Form 1023 if it
wants to be recognized as exempt under
section 501(c)(3).SeeRev. Proc. 2018 –5,
§ 3.01(1). J should not file a new Form
1023.SeeRev. Proc. 2018 –5, § 3.02(6).
SECTION 8. APPLICABILITY
.01This revenue procedure specifies the
circumstances under which organizations
recognized as exempt under section 501(c)
are not required to file new exemption ap-
plications under the same subsection of sec-
tion 501(c) for federal income tax purposes
after a corporate restructuring.
.02For purposes of section 508, a sur-
viving section 501(c)(3) organization that
meets the requirements of sections 5.01
February 26, 2018Bulletin No. 2018–9
382

through 5.04 of this revenue procedure
will not be treated as a new organization.
.03For purposes of section 506, a sur-
viving section 501(c)(4) organization that
meets the requirements of sections 5.01,
5.02, and 5.04 of this revenue procedure
will not be treated as a newly established
organization.
.04For purposes of section 505, a sur-
viving section 501(c)(9), (17) or (20) or-
ganization that meets the requirements of
sections 5.01, 5.02, and 5.04 of this reve-
nue procedure will not be treated as a new
organization.
.05Even when the surviving organiza-
tion of a corporate restructuring is not
required to file a new exemption applica-
tion pursuant to section 5 of this revenue
procedure, the surviving organization may
not rely on the determination letter of the
restructuring organization if there has
been a material change of facts, inconsis-
tent with exemption, in the character, pur-
pose, or method of operation of the re-
structuring organization.SeeRev. Proc.
2018 –5, section 11.02.
.06This revenue procedure does not
apply to a corporate restructuring in which
the surviving organization seeks a deter-
mination that it is exempt under a differ-
ent paragraph of section 501(c) than its
prior determination.
.07This revenue procedure does not
affect or provide guidance on the rules for
EINs under section 6109 or the require-
ments for a reorganization under section
368(a)(1)(F).
.08This revenue procedure does not
affect any state law requirements, includ-
ing any state law reporting, filing, or no-
tice requirements for corporate restructur-
ings.
SECTION 9. EFFECT ON OTHER
DOCUMENTS
Rev. Rul. 67–390, 1967–2 C.B. 179,
and Rev. Rul. 77– 469, 1977–2 C.B. 196,
are obsoleted.
SECTION 10. EFFECTIVE DATE
This revenue procedure is effective for
tax years beginning on or after January 1,
2018.
SECTION 11. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Obinna Chukwuanu and
Don Spellmann of the Office of Associate
Chief Counsel (Tax Exempt and Govern-
ment Entities). For further information re-
garding this revenue procedure contact
Obinna Chukwuanu or Don Spellmann on
(202) 317-4086 (not a toll-free number).
26 CFR 601.601: Rules and regulations.
(Also Part 1, §§ 45D, 1400Z–1, 1400Z–2.)
Rev. Proc. 2018–16
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance to the Chief Executive Officers of
any State, any possession of the United
States, and the District of Columbia re-
garding the procedure for designating
population census tracts as Qualified
Opportunity Zones for purposes of
§§ 1400Z–1 and 1400Z–2 of the Internal
Revenue Code (Code).
SECTION 2. BACKGROUND
.01Enactment. Section 13823 of “An
Act to provide for reconciliation pursuant
to titles II and V of the concurrent reso-
lution on the budget for fiscal year 2018,”
P.L. 115–97, which was enacted on De-
cember 22, 2017, amended the Code by
adding §§ 1400Z–1 and 1400Z–2 to the
Code.
.02Tax incentives. Section 1400Z–2 of
the Code allows the temporary deferral of
inclusion in gross income for certain real-
ized gains to the extent that corresponding
amounts are timely invested in a qualified
opportunity fund. Investments in a quali-
fied opportunity fund may also be eligible
for additional tax benefits.
.03Qualified Opportunity Fund. Sec-
tion 1400Z–2(d)(1) of the Code provides
that a qualified opportunity fund is an
investment vehicle that is organized as a
partnership or a corporation for the pur-
pose of investing in Qualified Opportunity
Zone property.
.04Designations, in general. Section
1400Z–1 of the Code allows the Chief
Executive Officer (CEO) of each State to
nominate a limited number of population
census tracts to be designated as Qualified
Opportunity Zones (QOZs). For purposes
of §§ 1400Z–1 and 1400Z–2 and this rev-
enue procedure, the term “State” means
any State, any possession of the United
States, and the District of Columbia.See
§§ 1400Z–1(c)(3) and 7701(a)(10) of the
Code. Under § 1400Z–1(c)(1), a popula-
tioncensus tract is eligible for designa-
tion as a QOZ if it satisfies the definition
of “low-income community” (LIC) in
§ 45D(e) of the Code.
.05Tracts Contiguous with LICs.In
addition, under § 1400Z–1(e) of the Code,
a tract that is not an LIC is eligible for
designation if both of the following con-
ditions are met:
(1) The non-LIC tract is contiguous
with an LIC that is designated as a
QOZ (the contiguous LIC QOZ
need not be in the same State.); and
(2) The median family income of the
non-LIC tract does not exceed 125
percent of the median family in-
come of that contiguous LIC QOZ.
.06Determination Period and Exten-
sion. Pursuant to § 1400Z–1(b)(1)(A) and
(c)(2)(B) of the Code, the CEO of the
State in which a tract is located may nom-
inate the tract to be a QOZ, and any such
nomination must be made no later than
March 21, 2018. Under § 1400Z–1(b)(2),
however, the State CEO may request, and
receive, a 30-day extension of this dead-
line.
.07Consideration Period and Exten-
sion. In general, not later than the end of a
30-day period beginning on the date that
the Secretary of the Treasury (Secretary)
receives notice of a nomination, the
Secretary may certify the nomination and
designate the nominated tract as a QOZ.
Under § 1400Z–1(b)(2) of the Code, how-
ever, the State CEO may request, and re-
ceive, a 30-day extension of the Secre-
tary’s deadline.
.08Qualified Opportunity Zone. Sec-
tion 1400Z–1 of the Code defines a QOZ
as any population census tract (either a
nominated LIC or a nominated non-LIC,
contiguous census tract) that is designated
as a QOZ.
.09Number of Designations.
(1) In general, § 1400Z–1(d)(1) of the
Code provides that the number of popula-
tion census tracts in a State that may be
designated as QOZs may not exceed 25
Bulletin No. 2018–9February 26, 2018
383

percent of the number of population cen-
sus tracts in the State that are LICs. If the
number of LICs in a State is not evenly
divisible by 4, the 25 percent limitation is
determined by rounding the fractional
quotient up to the next whole number. For
example, if a State contains 197 LICs, the
maximum number of designations is 50,
even though 25 percent of 197 is 49.25.
(2) Section 1400Z–1(d)(2) of the Code
further provides that, notwithstanding the
25 percent limitation, if a State contains
fewer than 100 LICs, then a total of 25
tracts may be designated.
(3) Section 1400Z–1(e)(2) of the Code
provides that not more than 5 percent of
the tracts designated in a State may be
non-LIC, contiguous tracts designated un-
der § 1400Z–1(e)(1). Thus, designations
under § 1400Z–1(d)(1) and (d)(2) may
include a limited number of non-LIC con-
tiguous tracts. If the number of designated
QOZs in a State is not evenly divisible by
20, the 5 percent limitation is determined
by rounding the fractional quotient up to
the next whole number. For example, sup-
pose that State B has 80 LICs. Under
§ 1400Z–1(d)(2), State B is allowed to
nominate 25 tracts for QOZ designation
because State B has fewer than 100 LICs.
If State B nominates all 25 of the QOZs
allowed, then of the 25 nominated tracts,
only 2 (5 percent of 25 or 1.25, rounded
up to 2) nominated tracts may be non-LIC
contiguous tracts. But if State B nomi-
nated only 18 LICs, then it could nomi-
nate only 1 (5 percent of 19 or 0.95,
rounded up to 1) additional non-LIC con-
tiguous tract.
SECTION 3. IDENTITY OF LICs
AND OF THE CONTIGUOUS
TRACTS THAT ARE ALSO
ELIGIBLE FOR DESIGNATION
AS QOZs
.01 Based on the 2011–2015 American
Community Survey (ACS) 5-Year data
from the Census Bureau, a public, on-line
resource (Information Resource) identifies
over 41,000 population census tracts that
are eligible for designation as a QOZ:
(1) 31,680 population census tracts that
are LICs eligible for designation as QOZs;
and
(2) 9,453 non-LIC population census
tracts that are eligible for designation if a
particular LIC contiguous to the non-LIC
tract is designated as a QOZ.
.02 This Information Resource in-
cludes detailed mapping, which makes it
possible to see the exact location of every
tract and to view a variety of demographic
information for each eligible tract.
.03 In the case of each tract described
in section 3.01(2) of this revenue proce-
dure, the Information Resource includes
one or more LIC tracts on whose desig-
nation as a QOZ the non-LIC tract’s eli-
gibility depends.
.04 The Information Resource can be
accessed athttps://www.cdfifund.gov/Pages/
Opportunity-Zones.aspx.
.05 In the fall of 2017, the Census
Bureau released the 2012–2016 ACS
5-Year data. Because of the March 21,
2018, deadline for State CEOs to nom-
inate tracts for designation as QOZs, the
maximum aggregate number of designa-
tions in a State is determined on the
basis of the 2011–2015 ACS, as re-
flected in the Information Resource de-
scribed above.
.06 In addition, the Information Re-
source is a “safe harbor.” That is, if the
Information Resource identifies a census
tract as being either an eligible LIC or an
eligible non-LIC contiguous tract, a State
CEO’s nomination of that tract will not
fail to be certified on the grounds that the
tract is no longer eligible under more re-
cent census data.
.07 On the other hand, in many cases, if
a tract is eligible under the most recent
available ACS 5-Year data, the tract is
eligible to be nominated for designation.
If the Information Resource, however,
does not identify the tract as eligible, the
nomination must be accompanied by an
analysis demonstrating that eligibility, in-
cluding appropriate supporting data from
that ACS.
SECTION 4. SCOPE
This revenue procedure applies to the
CEO of any State that desires to nominate
for designation as QOZs population cen-
sus tracts that are either LICs that qualify
under § 1400Z–1(c)(1) of the Code or
non-LIC contiguous tracts that qualify un-
der § 1400Z–1(e)(1) of the Code.
SECTION 5. PROCEDURE
.01 A Nomination Tool, which can be
accessed online, has been developed for
the benefit of State CEOs that are making
nominations of census tracts for designa-
tion as QOZs.
.02 Further information on the nomi-
nation process under § 1400Z–1 of the
Code, including how to access the on-
line Nomination Tool and how to re-
quest an extension of the determination
period, will be sent individually to all
State CEOs.
SECTION 6. EFFECTIVE DATE
This revenue procedure is effective on
February 8, 2018.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Erika Reigle of the Office of
Associate Chief Counsel (Income Tax and
Accounting). For further information re-
garding this revenue procedure contact
Erika Reigle at (202) 317-7006 (not a
toll-free number). For further information
regarding the Information Resource, con-
tact the CDFI Fund Help Desk at (202)
653– 0421 (not a toll-free number).
26 CFR 601.204: Changes in accounting periods
and in methods of accounting.
(Also: Part I, §§ 442, 898, 965; 1.442–1)
Rev. Proc. 2018–17
SECTION 1. PURPOSE
This revenue procedure modifies the
circumstances under which the Internal
Revenue Service (“IRS”) grants approval
of certain requests by certain foreign cor-
porations for changes in annual account-
ing periods filed under Rev. Proc. 2002–
39, 2002–22 I.R.B. 1046, and Rev. Proc.
2006 – 45, 2006 – 45 I.R.B. 851. This rev-
enue procedure is issued pursuant to sec-
tion 965(o) to prevent the avoidance of the
purposes of section 965 through changes
in the taxable years of certain specified
February 26, 2018Bulletin No. 2018–9
384

foreign corporations (within the meaning
of section 965(e)).
1
SECTION 2. BACKGROUND
.01 Section 442 and § 1.442–1(a) gen-
erally provide that a taxpayer seeking to
change its annual accounting period and
use a new taxable year must obtain the
approval of the Commissioner.
.02 In general, under § 1.442–1(b)(2), a
change in annual accounting period will
be approved when a taxpayer agrees to the
Commissioner’s prescribed terms, condi-
tions, and adjustments for effecting the
change.
.03 Section 1.442–1(b)(3) provides that
the Commissioner will prescribe the ad-
ministrative procedures for a taxpayer to
be allowed to adopt, change, or retain an
annual accounting period.
.04 Rev. Proc. 2002–39 provides the
general procedures under section 442 and
§ 1.442–1(b) for obtaining the approval of
the Commissioner to adopt, change, or
retain an annual accounting period for
federal income tax purposes.
.05 Rev. Proc. 2006 – 45, as a successor
to Rev. Proc. 2002–37, 2002–22 I.R.B.
1030, provides the exclusive procedures
for certain corporations to obtain auto-
matic approval of the Commissioner to
change their annual accounting periods,
including a section 898 specified foreign
corporation that is changing to a one-
month deferral year or to a 52–53-week
taxable year that references the one-month
deferral year.Seesection 4.02(8) of Rev.
Proc. 2006 – 45.
.06 Section 898(a) provides that the
taxable year of any section 898 specified
foreign corporation is the required year
determined under section 898(c). In con-
trast, a foreign corporation other than a
section 898 specified foreign corporation
generally does not have a required year.
.07 In general, section 898(b) defines a
section 898 specified foreign corporation
as any controlled foreign corporation (as
defined in section 957) (“CFC”) with re-
spect to which a United States shareholder
(as defined in section 951(b), subject to
certain modifications) owns, on certain
testing days, more than 50 percent of ei-
ther the total voting power of all classes of
stock of such corporation entitled to vote
or the total value of all classes of stock of
such corporation. The rules of section
958(a) and (b) apply for purposes of de-
termining ownership. A United States
shareholder that meets this more-than-50-
percent ownership threshold is referred to
in this revenue procedure as a “majority
U.S. shareholder.”
.08 The required year determined under
section 898(c) is the majority U.S. share-
holder year (as defined in section 898(c)(3)),
or, if there is no majority U.S. shareholder
year, the taxable year prescribed under reg-
ulations. Section 898(c)(2) provides that a
section 898 specified foreign corporation
may elect, in lieu of the required year, a
taxable year beginning one month earlier
than the majority U.S. shareholder year.
.09 Section 965(a) provides that for the
last taxable year of a deferred foreign in-
come corporation (“DFIC”) that begins
before January 1, 2018, the subpart F in-
come of the corporation (as otherwise de-
termined for such taxable year under sec-
tion 952) shall be increased by the greater
of the accumulated post-1986 deferred
foreign income of such corporation deter-
mined as of November 2, 2017, or De-
cember 31, 2017 (each such date, a “mea-
surement date”).
.10 For purposes of section 965, a
DFIC is, with respect to any United States
shareholder, any section 965 specified for-
eign corporation of such United States
shareholder that has accumulated post-
1986 deferred foreign income (as of a
measurement date) greater than zero. Sec-
tion 965(d)(1). The term “section 965
specified foreign corporation” means (A)
any CFC, and (B) any foreign corporation
with respect to which one or more domes-
tic corporations is a United States share-
holder (“10-percent corporation”). Sec-
tion 965(e)(1). For purposes of sections
951 and 961, a 10-percent corporation is
treated as a CFC solely for purposes of
taking into account the subpart F income
of such corporation under section 965(a).
Section 965(e)(2). However, if a passive
foreign investment company (as defined
in section 1297) with respect to the share-
holder is not a CFC, then such corporation
is not a section 965 specified foreign cor-
poration. Section 965(e)(3).
.11 Section 965(o) provides that the
Secretary shall prescribe such regulations
or other guidance as may be necessary or
appropriate to carry out the provisions of
section 965, including regulations or other
guidance to prevent the avoidance of
the purposes of such section, including
through a reduction in earnings and prof-
its, through changes in entity classification
or accounting methods, or otherwise. The
Conference Report accompanying the Act
states, “The conferees are also aware that
certain taxpayers may have engaged in tax
strategies designed to reduce the amount
of post-1986 earnings and profits in order
to decrease the amount of the inclusion
required under this provision. Such tax
strategies may include a change in entity
classification, accounting method,and
taxable year....”H.R. Rep. No. 115–
466, at 619 (2017) (emphasis added).
.12 A section 965 specified foreign cor-
poration with a taxable year ending on
December 31, 2017, could avoid the pur-
poses of section 965 by changing its tax-
able year. For example, if a DFIC with the
calendar year as its taxable year elected,
effective for its taxable year beginning
January 1, 2017, a taxable year closing on
November 30, the election could defer by
as much as 11 months a United States
shareholder’s inclusion with respect to the
DFIC under section 965. Further, the elec-
tion could, depending on the facts, reduce
the amount of the tax liability of a United
States shareholder of the DFIC by reason
of section 965, including through the re-
duction of the post-1986 earnings and
profits of the DFIC.
SECTION 3. SCOPE
This revenue procedure applies to a
section 965 specified foreign corporation
seeking to change its taxable year that
ends on December 31, 2017. For purposes
of applying this revenue procedure, a 52–
53-week taxable year is deemed to begin
on the first day of the calendar month
nearest to the first day of the 52–53-week
taxable year, and is deemed to end or
1
The term “specified foreign corporation” is defined differently in sections 898(b) and 965(e). In order to avoid confusion, this revenue procedure refers to a specified foreign corporation
within the meaning of section 898(b) as a “section 898 specified foreign corporation” and to a specified foreign corporation within the meaning of section 965(e) as a “section 965 specified
foreign corporation.”
Bulletin No. 2018–9February 26, 2018
385

close on the last day of the calendar month
nearest to the last day of the 52–53-week
taxable year, as the case may be.See
§ 1.441–2(c).
SECTION 4. MODIFICATIONS
.01Inapplicability of Rev. Proc. 2006 –
45. Section 4.02 of Rev. Proc. 2006 – 45 is
modified to add a new paragraph (15) to
read as follows:
“(15)Certain specified foreign corpo-
rations.Notwithstanding any other provi-
sion in this section 4, a specified foreign
corporation (as defined in section 965(e))
if each of the following conditions is sat-
isfied:
(a) The specified foreign corporation’s
taxable year (determined without regard
to the requested change) ends on Decem-
ber 31;
(b) If the requested change were per-
mitted, the first effective year of the cor-
poration would begin on January 1, 2017,
and would end on a date before December
31, 2017; and
(c) The specified foreign corporation
has one or more United States sharehold-
ers that must include an amount in gross
income under section 951(a)(1) by reason
of section 965 with respect to the specified
foreign corporation or any other specified
foreign corporation (with such amount de-
termined without regard to the requested
change).”
.02Inapplicability of Rev. Proc. 2002–
39.Section 3 of Rev. Proc. 2002–39 is
modified to add a new subsection 3.03 to
read as follows:
“.03Inapplicability for certain speci-
fied foreign corporations. Notwithstand-
ing any other provision of this revenue
procedure, a request to change the annual
accounting period of a specified foreign
corporation (as defined in section 965(e))
pursuant to this revenue procedure will
not be approved if:
(a) The specified foreign corporation’s
taxable year (determined without regard
to the requested change) ends on Decem-
ber 31;
(b) If the requested change were per-
mitted, the first effective year of the cor-
poration would begin on January 1, 2017,
and would end on a date before December
31, 2017; and
(c) The specified foreign corporation
has one or more United States sharehold-
ers that must include an amount in gross
income under section 951(a)(1) by reason
of section 965 with respect to the specified
foreign corporation or any other specified
foreign corporation (with such amount de-
termined without regard to the requested
change).”
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2002–39 and Rev. Proc.
2006 – 45 are modified.
SECTION 6. EFFECTIVE DATE
This revenue procedure applies with
respect to any request to change an annual
accounting period that ends on December
31, 2017, regardless of when such request
was filed.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Leni C. Perkins of the Office
of Associate Chief Counsel (Interna-
tional). For further information regarding
this revenue procedure, contact Ms. Per-
kins on (202) 317-6934 (not a toll-free
number).
February 26, 2018Bulletin No. 2018–9
386

Part IV. Items of General Interest
Notice of Disposition of
Declaratory Judgment
Proceedings under
Section 7428
Announcement 2018–01
This announcement serves notice to do-
nors that on September 20, 2017, the United
States Tax Court entered a stipulated deci-
sion that, as of September 19, 1980, the
organization listed below is qualified as an
organization described in section 501(c)(3),
is exempt from taxation under section
501(a),andisdescribedinsection
170(c)(2), and, as of August 31, 1990, the
organization is a private foundation.
Conservation Endowment Fund
Ojai, CA
Notice of Disposition of
Declaratory Judgment
Proceedings under
Section 7428
Announcement 2018–02
This announcement serves notice to do-
nors that on September 14, 2017, the United
States Tax Court entered a stipulated deci-
sion that, as of May 5, 1994, the organiza-
tion listed below is qualified as an organi-
zation described in section 501(c)(3), is
exempt from taxation under section 501(a),
and is described in section 170(c)(2).
International Center for Earth Concerns
Ojai, CA
Notice of Disposition of
Declaratory Judgment
Proceedings under
Section 7428
Announcement 2018–03
This announcement serves notice to
donors that, on September 13, 2017, the
United States Tax Court entered a stipu-
lated decision stating that, effective Janu-
ary 1, 2008, the organization listed below
is not qualified as an organization de-
scribed in I.R.C. § 501(c)(3), is not ex-
empt from taxation under I.R.C. § 501(a),
and is not an organization described in
I.R.C. § 170(c)(2).
Taft Foundation
Ojai, CA
Bulletin No. 2018–9February 26, 2018
387

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. 2018–9February 26, 2018
i

Numerical Finding List
1
Bulletin 2018 –1 through 2018 –9
Announcements:
2018-01, 2018-9 I.R.B.387
2018-02, 2018-9 I.R.B.387
2018-03, 2018-9 I.R.B.387
Notices:
2018-01, 2018-3 I.R.B.285
2018-02, 2018-2 I.R.B.281
2018-03, 2018-2 I.R.B.285
2018-05, 2018-6 I.R.B.341
2018-06, 2018-3 I.R.B.300
2018-07, 2018-4 I.R.B.317
2018-08, 2018-7 I.R.B.352
2018-10, 2018-8 I.R.B.359
2018-13, 2018-6 I.R.B.341
2018-14, 2018-7 I.R.B.353
2018-15, 2018-9 I.R.B.376
2018-17, 2018-9 I.R.B.376
Proposed Regulations:
REG-119514-15, 2018-04 I.R.B.325
REG-118067-17, 2018-08 I.R.B.360
Revenue Procedures:
2018-1, 2018-1 I.R.B.1
2018-2, 2018-1 I.R.B.106
2018-3, 2018-1 I.R.B.130
2018-4, 2018-1 I.R.B.146
2018-5, 2018-1 I.R.B.244
2018-7, 2018-1 I.R.B.282
2018-8, 2018-2 I.R.B.286
2018-9, 2018-2 I.R.B.290
2018-10, 2018-7 I.R.B.355
2018-11, 2018-5 I.R.B.334
2018-12, 2018-6 I.R.B.349
2018-13, 2018-7 I.R.B.356
2018-14, 2018-9 I.R.B.378
2018-15, 2018-9 I.R.B.379
2018-16, 2018-9 I.R.B.383
2018-17, 2018-9 I.R.B.384
Revenue Rulings:
2018-01, 2018-2 I.R.B.275
2018-02, 2018-2 I.R.B.277
2018-03, 2018-2 I.R.B.278
2018-04, 2018-4 I.R.B.304
2018-05, 2018-6 I.R.B.339
Treasury Decisions:
9829, 2018-04 I.R.B.308
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
February 26, 2018Bulletin No. 2018–9
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2018 –1 through 2018 –9
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
Bulletin No. 2018–9February 26, 2018
iii

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