Internal Revenue Bulletin 2018-45 (PDF rendition): IRS Revenue Rulings

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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. 2018–54, page 769.
This revenue procedure provides guidance for taxpayers that
hold investments in one or more segregated asset accounts on
which variable contracts as defined in section 817 of the
Internal Revenue Code are based. The guidance allows taxpay-
ers to elect to treat certain mortgage-backed securities as
having deemed issuers for purposes of the diversification re-
quirements of section 817(h).
Income Tax
Notice 2018-84, page 768.
Notice 2018–84 provides interim guidance clarifying how the
suspension of the personal exemption deduction in § 151(d)(5)
of the Tax Cuts and Jobs Act applies to certain rules under
§§ 36B and 6011 relating to the premium tax credit, and under
§ 5000A relating to the individual shared responsibility provi-
sion. The notice also announces that the Treasury Department
and IRS intend to amend the regulations under §§ 36B and
6011 to clarify the application of § 151(d)(5), and that until
further guidance is issued the guidance in the notice applies.
REV. PROC. 2018–54, page 769.
This revenue procedure provides guidance for taxpayers that
hold investments in one or more segregated asset accounts on
which variable contracts as defined in section 817 of the
Internal Revenue Code are based. The guidance allows taxpay-
ers to elect to treat certain mortgage-backed securities as
having deemed issuers for purposes of the diversification re-
quirements of section 817(h).
REV. RUL. 2018–28, page 764.
Federal rates; adjusted federal rates; adjusted federal long-
term rate, the long-term exempt rate, and the blended annual
rate. For purposes of sections 382, 1274, 1288, 7872 and
other sections of the Code, tables set forth the rates for
November 2018.
REV. RUL. 2018–29, page 765.
This revenue ruling addresses questions on the application to
real property of the “original use” requirement in section
1400Z–2(d)(2)(D)(i)(II) and the “substantial improvement” re-
quirement in section 1400Z–2(d)(2)(D)(i)(II) and 1400Z–
2(d)(2)(D)(ii). In addition, this revenue ruling provides guidance
on the substantial-improvement requirement with respect to a
purchased building located in a qualified opportunity zone.
Finding Lists begin on page ii.
Bulletin No. 2018–45
November 5, 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.
November 5, 2018Bulletin No. 2018–45

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.—Determination of Issue Price in the
Case of Certain Debt Instruments Issued for Property.
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7872.)
Rev. Rul. 2018–28
This revenue ruling provides various
prescribed rates for federal income tax
purposes for November 2018 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-
term, mid-term, and long-term adjusted
applicable federal rates (adjusted AFR)
for the current month for purposes of sec-
tion 1288(b). Table 3 sets forth the ad-
justed federal long-term rate and the long-
term tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage for non-federally subsidized new
buildings placed in service after July 30,
2008, shall not be less than 9%. Finally,
Table 5 contains the federal rate for de-
termining the present value of an annuity,
an interest for life or for a term of years, or
a remainder or a reversionary interest for
purposes of section 7520.
REV. RUL. 2018–28 TABLE 1
Applicable Federal Rates (AFR) for November 2018
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR2.70%2.68%2.67%2.67%
110% AFR2.97%2.95%2.94%2.93%
120% AFR3.25%3.22%3.21%3.20%
130% AFR3.51%3.48%3.46%3.46%
Mid-term
AFR3.04%3.02%3.01%3.00%
110% AFR3.35%3.32%3.31%3.30%
120% AFR3.65%3.62%3.60%3.59%
130% AFR3.97%3.93%3.91%3.90%
150% AFR4.58%4.53%4.50%4.49%
175% AFR5.36%5.29%5.26%5.23%
Long-term
AFR3.22%3.19%3.18%3.17%
110% AFR3.54%3.51%3.49%3.48%
120% AFR3.87%3.83%3.81%3.80%
130% AFR4.19%4.15%4.13%4.11%
REV. RUL. 2018–28 TABLE 2
Adjusted AFR for November 2018
Period for Compounding
AnnualvSemiannualQuarterlyMonthly
Short-term adjusted AFR2.04%2.03%2.02%2.02%
Mid-term adjusted AFR2.30%2.29%2.28%2.28%
Long-term adjusted AFR2.43%2.42%2.41%2.41%
November 5, 2018Bulletin No. 2018–45
764

REV. RUL. 2018–28 TABLE 3
Rates Under Section 382 for November 2018
Adjusted federal long-term rate for the current month2.43%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the
adjusted federal long-term rates for the current month and the prior two months.)
2.43%
REV. RUL. 2018–28 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for November 2018
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings
placed in service after July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.72%
Appropriate percentage for the 30% present value low-income housing credit3.31%
REV. RUL. 2018–28 TABLE 5
Rate Under Section 7520 for November 2018
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
3.6%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of November 2018. See Rev.
Rul. 2018 –28, page 764.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month of
November 2018. See Rev. Rul. 2018 –28, page 764.
Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of No-
vember 2018. See Rev. Rul. 2018 –28, page 764.
Section 1400Z-2.—Special Rules for Capital Gains
Invested in Opportunity Zones
Rev. Rul. 2018–29
ISSUES
(1) If a qualified opportunity fund
(QOF), as defined in § 1400Z–2(d)(1) of
the Internal Revenue Code (Code), pur-
chases an existing building located on
land that is wholly within a qualified op-
portunity zone (QOZ), as defined in
§ 1400Z–1, can the original use of the
building or the land in the QOZ be con-
sidered to have commenced with the
QOF?
(2) If a QOF purchases an existing
building in a QOZ and the land upon
Bulletin No. 2018–45November 5, 2018
765

which the building is located in a QOZ, is
a substantial improvement to the building
measured by additions to the adjusted ba-
sis in the building or is it measured by
additions to the adjusted basis in the
building and the land?
(3) If a substantial improvement to the
building is measured by additions to the
QOF’s adjusted basis in the building, does
§ 1400Z–2(d) require the QOF to sepa-
rately substantially improve the land?
FACTS
In September 2018, QOF A purchases
for $800x Property X, which is located
wholly within the boundaries of a QOZ.
Property X consists of a building previ-
ously used as a factory erected prior to
2018 and land on which the factory build-
ing is located. QOF A intends to convert
the factory building to residential rental
property. Sixty percent ($480x) of the
$800x purchase price for Property X is
attributable to the value of the land and
forty percent ($320x) is attributable to the
value of the building. Within 24 months
after the date of QOF A’s acquisition of
Property X, QOF A invests an additional
$400x in converting the building to resi-
dential rental property.
LAW AND ANALYSIS
Pursuant to § 1400Z–1(b)(1)(A) of the
Code, the Chief Executive Officer of each
State nominated a limited number of pop-
ulation census tracts to be designated as
QOZs for purposes of §§ 1400Z–1 and
1400Z–2.
Under § 1400Z–2(d)(1), the term “qual-
ified opportunity fund” (QOF) means any
investment vehicle organized as a corpora-
tion or a partnership for the purpose of in-
vesting in qualified opportunity zone prop-
erty (Zone Property) (other than another
QOF) that holds at least 90 percent of its
assets in Zone Property.
Under § 1400Z–2(d)(2)(A), Zone Prop-
erty means property that is either qualified
opportunity zone stock (Zone Stock), qual-
ified opportunity zone partnership interest
(Zone Partnership Interest), or qualified op-
portunity zone business property (Zone
Business Property).
Zone Business Property is defined in
§ 1400Z–2(d)(2)(D). Section 1400Z–
2(d)(2)(D)(i) provides that Zone Business
Property is tangible property used in a
trade or business of the QOF if (a) such
tangible property is purchased by the QOF
after December 31, 2017, (b) the original
use of such tangible property commences
with the QOF or the QOF substantially
improves the tangible property, and (c)
during substantially all of the QOF’s hold-
ing period for such tangible property, sub-
stantially all of the use of such tangible
property is in a QOZ.
Under § 1400Z–2(d)(2)(D)(ii), tangible
property used in a QOF’s trade or busi-
ness is treated as substantially improved
by the QOF only if, during any 30-month
period beginning after the date of acqui-
sition of such tangible property, additions
to basis with respect to such tangible
property in the hands of the QOF exceed
an amount equal to the adjusted basis of
such tangible property at the beginning of
such 30-month period in the hands of the
QOF.
Questions have arisen as to whether for
purposes of § 1400Z–2(d)(2)(D)(i) the
original use of land in the QOZ can ever
be considered to have commenced with a
QOF and, therefore, constitute Zone Busi-
ness Property. In addition, if the original
use of land in the QOZ cannot commence
with a QOF and if land is treated as prop-
erty separate from a building for purposes
of § 1400Z–2(d), must land be substan-
tially improved in order to qualify as Zone
Business Property?
Given the permanence of land, land
can never have its original use in a QOZ
commencing with a QOF. Section
1400Z–2 seeks to encourage economic
growth and investment in the designated
QOZs by providing Federal income tax
benefits to taxpayers who newly invest
in businesses located within these eco-
nomically distressed communities. Con-
sistent with this intent, a building lo-
cated on land within a QOZ is treated as
substantially improved within the mean-
ing of § 1400Z–2(d)(2)(D)(ii) if, during
any 30-month period beginning after the
date of acquisition of the building, ad-
ditions to the taxpayer’s basis in the
building exceed an amount equal to the
taxpayer’s adjusted basis of the building
at the beginning of such 30-month pe-
riod. Further, the fact that the cost of the
land within the QOZ upon which
the building is located is not included in
the taxpayer’s adjusted basis in the
building does not mean that the taxpayer
is required to separately substantially
improve such land for it to qualify as
Zone Business Property.
Under the facts of this revenue ruling,
QOF A purchased Property X, a factory
building and the land on which was lo-
cated (both wholly within a QOZ), for
$800x with the intent to convert the build-
ing into residential rental property. Sixty
percent ($480x) of the purchase price for
Property X was attributable to the value of
the land and forty percent ($320x) was
attributable to the value of the building.
Section1400Z–2(d)(2)(D)(ii) does not
apply to the land on which the factory
building is located, but does apply to the
building. Because the factory building
existed on land within the QOZ prior to
QOF A’s purchase of Property X, the
building’s original use within the QOZ
did not commence with QOF A. How-
ever, under § 1400Z–2(d)(2)(D)(ii) QOF
A substantially improved Property X be-
cause during the 30-month period begin-
ning after the date of QOF A’s acquisi-
tion of Property X QOF A’s additions to
the basis of the factory building ($400x)
exceed an amount equal to QOF A’s
adjusted basis of the building at the be-
ginning of the 30-month period ($320x).
The fact that the cost of the land on
which the building is located is not in-
cluded in QOF A’s adjusted basis of the
building does not mean that QOF A is
required to separately substantially im-
prove the land.
HOLDING
(1) If a QOF purchases an existing
building located on land that is wholly
within a QOZ, the original use of the
building in the QOZ is not considered to
have commenced with the QOF for pur-
poses of § 1400Z–2(d)(2)(D)(i), and the
requirement under § 1400Z–2(d)(2)(D)(i)
that the original use of tangible property
in the QOZ commence with a QOF is not
applicable to the land on which the build-
ing is located.
(2) If a QOF purchases a building
wholly within a QOZ, under § 1400Z–
2(d)(2)(D)(ii) a substantial improvement
to the building is measured by the QOF’s
additions to the adjusted basis of the
building.
November 5, 2018Bulletin No. 2018–45
766

(3) Under § 1400Z–2(d), measuring a
substantial improvement to the building
by additions to the QOF’s adjusted basis
of the building does not require the QOF
to separately substantially improve the
land upon which the building is located.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Erika C. Reigle of the Office of
Associate Chief Counsel Income Tax &
Accounting. For further information re-
garding this revenue ruling, contact Erika
C. Reigle at (202) 317-7006 (not a toll-
free number).
Bulletin No. 2018–45November 5, 2018
767

Part III. Administrative, Procedural, and Miscellaneous
Guidance under §§ 36B,
5000A, and 6011 on the
suspension of personal
exemption deductions
Notice 2018–84
PURPOSE
Section 11041 of the Tax Cuts and
Jobs Act, Pub. L. No. 115–97, 131 Stat.
2054, 2082 (the Act), added § 151(d)(5) to
the Internal Revenue Code (Code). Sec-
tion 151(d)(5) reduces the amount of the
personal exemption deduction to zero for
taxable yearsbeginning after December 31,
2017, and before January 1, 2026. This no-
tice provides interim guidance clarifying
how the reduction of the personal exemp-
tion deduction to zero in § 151(d)(5) applies
for purposes of certain rules under §§ 36B
and 6011 relating to the premium tax credit
and under § 5000A relating to the individual
shared responsibility provision. This notice
also announces that the Department of the
Treasury (Treasury Department) and the
Internal Revenue Service (IRS) intend to
amend the regulations under §§ 36B and
6011 to clarify the application of § 151(d)
(5). Until further guidance is issued, the
interim guidance described in this notice
applies for purposes of the regulations under
§§ 36B and 5000A and for purposes of
§ 1.6011– 8(a).
BACKGROUND
Section 151 generally allows a tax-
payer to claim a personal exemption de-
duction for the taxpayer, the taxpayer’s
spouse, and any dependents, based on the
exemption amount defined in § 151(d).
For tax years prior to 2018, a taxpayer
claimed a personal exemption deduction
for an individual by putting the individu-
al’s name and taxpayer identification
number (TIN) on the taxpayer’s income
tax return, multiplying the number of al-
lowed exemptions by the exemption
amount, and entering that amount on the
tax return.
Section 11041 of the Act added § 151(d)
(5) to the Code. Section 151(d)(5)(A) provides
that, for taxable years beginning after De-
cember 31, 2017, and before January 1,
2026, the term “exemption amount” means
zero. Section 151(d)(5)(B) provides that the
reduction of the exemption amount to zero
“shall not be taken into account in determin-
ing whether a [personal exemption] deduc-
tion is allowed or allowable, or whether a
taxpayer is entitled to a deduction under this
section.” Thus, even though the amount of
the personal exemption deduction is re-
duced to zero, taxpayers are still allowed
personal exemption deductions under § 151
for purposes of other provisions of the
Code.SeeH.R. Rep. No. 115– 466 at 203
n.16 (Conf. Rep.) (2017) (“The provision
[amendments to § 151] also clarifies that,
for purposes of taxable years in which the
personal exemption is reduced to zero, this
should not alter the operation of those pro-
visions of the Code which refer to a tax-
payer allowed a deduction (or an individual
with respect to whom a taxpayer is allowed
a deduction) under section 151.”).
Section 36B allows a premium tax
credit to eligible individuals who enroll
themselves, their spouse, or any depen-
dent (as defined in § 152) in a qualified
health plan through an Exchange, and
§ 6011provides general rules related to
income tax return filing requirements. The
regulations under §§ 36B and 6011 include
rules that apply based on whether a taxpayer
claims or claimed a personal exemption de-
duction under § 151 for an individual. These
rules affect eligibility for the premium tax
credit, computation of the premium tax
credit, reconciliation of advance payments
of the premium tax credit, and income tax
return filing requirements related to the pre-
mium tax credit. Specifically, references
such as “claim apersonal exemption de-
duction,” “claims a personal exemption
deduction,” or “claimed as a personal
exemption deduction,” are included in
§§ 1.36B–1(d); 1.36B–2(c)(4); 1.36B–
4(a)(1)(ii)(B)(1), (a)(1)(ii)(B)(2), (a)(1)
(ii)(C), and (a)(4); and § 1.6011– 8(a).
The Treasury Department and the IRS
intend to amend the regulations under
§§ 36B and 6011 to clarify the meaning
of claiming a personal exemption de-
duction for the taxable years for which
the exemption amount is reduced to
zero.
Section 5000A provides that if a tax-
payer, or dependent of the taxpayer who is
an applicable individual for whom the tax-
payer is liable, is without minimum essen-
tial coverage or a coverage exemption for
one or more months in a taxable year, the
taxpayer must include an individual
shared responsibility payment when filing
his or her federal income tax return. The
regulations under § 5000A include rules
that apply based on whether a taxpayer
claims orclaimed a personal exemption
deduction under § 151 for an individual.
Specifically, § 1.5000A–1(d)(4) refers to a
taxpayer who “claims a deduction for a per-
sonal exemption,” and § 1.5000A-3(e)(3)
(ii)(B) refers to “an individual for whom a
personal exemption deduction...is
claimed.”
Section 11081 of the Act reduced the
amount of the shared responsibility pay-
ment to zero for months beginning after
December 31, 2018. Accordingly, al-
though this notice provides interim guid-
ance related to § 5000A, the Treasury
Department and the IRS do not intend to
propose regulations under § 5000A.
INTERIM GUIDANCE
Because the Act reduces the exemption
amount to zero, taxpayers will no longer
claim a personal exemption deduction on
their individual income tax returns by list-
ing an individual’s name and TIN, multi-
plying the number of allowed exemptions
by the exemption amount, and entering
that amount on their tax return. Accord-
ingly, taxpayers may have questions about
what it means to claim a personal exemp-
tion deduction for purposes of the pre-
mium tax credit and the individual shared
responsibility provision. Until further
guidance is issued, the following rules
apply for purposes of the regulations un-
der §§ 36B and 5000A and for purposes of
§ 1.6011– 8(a):
(1) A taxpayer is considered to have
claimed a personal exemption de-
duction for himself or herself for a
taxable year if the taxpayer files an
income tax return for the year and
does not qualify as a dependent of
another taxpayer under § 152 for
the year;
(2) A taxpayer is considered to have
claimed a personal exemption de-
November 5, 2018Bulletin No. 2018–45
768

duction for anindividual other than
the taxpayer if the taxpayer is allowed
a personal exemption deduction for
the individual (taking into account
§ 151(d)(5)(B)) and lists the individ-
ual’s name and TIN on the Form
1040, U.S. Individual Income Tax
Return, or Form 1040NR, U.S. Non-
resident Alien Income Tax Return,
the taxpayer files for the year.
INFERENCE
No inference should be drawn from
any provision of this notice concerning
any other provision of the Act or any other
section of the Code.
EFFECTIVE/APPLICABILITY
DATE
This notice applies to taxable years be-
ginning in 2018.
DRAFTING INFORMATION
The principal author of this notice is
Lisa Mojiri-Azad of the Office of Chief
Counsel (Income Tax and Accounting).
For further information regarding this no-
tice, contact Ms. Mojiri-Azad or Steve
Toomey at 202-317-4718 (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 I, §§ 817; 1.817–5)
Rev. Proc. 2018–54
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance and procedural rules for taxpayers
that hold investments in one or moreseg-
regated asset accounts on which variable
contracts are based. The guidance and
rules allow these taxpayers to elect to
treat certain mortgage-backed securities
as having deemed issuers for purposes
of the diversification requirements of
§ 817(h) of the Internal Revenue Code.
SECTION 2. BACKGROUND
.01 Under the direction of the Federal
Housing Finance Agency (FHFA), the
Federal Home Loan Mortgage Corpora-
tion (Freddie Mac) and the Federal Na-
tional Mortgage Association (Fannie Mae,
and together with Freddie Mac, the GSEs)
will develop a common mortgage-backed
security (the Single Security Initiative).
As part of the Single Security Initiative,
key features and terms of Freddie Mac’s
securities will be aligned with those of
Fannie Mae’s securities to create new
Uniform Mortgage Backed Securities
(UMBS). UMBS will be issued by both
GSEs with substantially similar terms.
UMBS would trade primarily in the “To-
Be-Announced” (TBA) market.
.02 Freddie Mac currently issues
mortgage-backed securities, called Partic-
ipation Certificates (PC), to the market.
Fannie Mae currently issues similar secu-
rities, called Mortgage-Backed Securities
(MBS), to the market. PC and MBS are
issued under trust agreements and repre-
sent undivided beneficial ownership inter-
ests in pools of mortgages and related
assets held by those trusts (Mortgage
Pools). Mortgage servicers perform cer-
tain servicing functions for each Mortgage
Pool on behalf of the GSE issuer for a fee.
Each GSE acts as master servicer and
guarantor of the mortgages for a periodic
fee.
.03 Today, PC and MBS differ in their
respective remittance cycles. Although
the remittance cycle for PC is 45 days, the
remittance cycle for MBS is 55 days,
meaning that an MBS holder receives
payments 10 days later than a PC holder.
.04 As part of the Single Security Ini-
tiative, the GSEs will combine their fixed-
rate PC and MBSprograms into a new
single mortgage-backed security pro-
gram in which both GSEs will issue
UMBS having substantially similar fea-
tures and terms, including identical re-
mittance cycles.
.05 Most trading of PC and MBS oc-
curs in the TBA market, which is a for-
ward market in mortgage-backed securi-
ties. Today, when counterparties enter
into an “unstipulated” TBA trade, they
enter into a forward contract that specifies
six criteria that the security delivered must
satisfy. These six criteria are the coupon,
maturity, settlement date, face value,
price, and issuer (that is, Freddie Mac or
Fannie Mae). Investors may enter into
“stipulated” TBA trades to require addi-
tional attributes of the security delivered,
such as the geographical location of the
underlying mortgages. Once UMBS begin
trading in the TBA market, the parameters
for unstipulated TBA trades in UMBS
will exclude specification of the issuer. As
a result, investors that acquire UMBS in
unstipulated TBA trades will not know the
issuer until the security to be delivered is
identified 48 hours prior to settlement.
.06 Section 817(h) provides that for
purposes of subchapter L (§§ 801 through
848), § 72 (relating to annuities), and
§ 7702(a) (relating to the definition of life
insurance contract), a variable contract
(other than a pension plan contract, as
defined in § 818(a)) that is otherwise de-
scribed in § 817 and that is based on a
segregated asset account is not treated as
an annuity, endowment, or life insurance
contract for any period (and any subse-
quent period) for which the investments
made by the account are not adequately
diversified (in accordance with regula-
tions prescribed by the Secretary).See
also§ 1.817–5(a)(1) of the Income Tax
Regulations.
.07 As defined in § 1.817–5(e), a seg-
regated asset account consists of all assets
the investment return and market value of
each of which must be allocated in an
identical manner to any variable contract
invested in any of such assets.See also
§ 1.817–5(g) (providing examples illus-
trating the application of the segregated
asset account definition).
.08 In current commercial practice, the
policyholder of a variable contract may
usually select among various investment
strategies, each of which results in invest-
ment in different portfolios of assets. Each
of these portfolios may be a segregated
asset account within the meaning of
§ 1.817–5(e).See, e.g., Rev. Rul. 81–225,
1981–2 C.B. 12, modified by Rev. Proc.
99 – 44, 1999 –2 C.B. 598, clarified and
amplified by Rev. Rul. 2007–7, 2007–1
C.B. 468. Each segregated asset account
must be adequately diversified within the
meaning of § 817(h).
.09 (1) Section 1.817–5(b)(1)(i) pro-
vides that the investments of a segregated
asset account are considered adequately
diversified for purposes of § 1.817–5 and
§ 817(h) only if no more than—
(A) 55 percent of the value of the total
assets of the account is represented by any
one investment;
Bulletin No. 2018–45November 5, 2018
769

(B) 70 percent of the value of the total
assets of the account is represented by any
two investments;
(C) 80 percent of the value of the total
assets of the account is represented by any
three investments; and
(D) 90 percent of the value of the total
assets of the account is represented by any
four investments.
(2) Section 1.817–5(b)(1)(ii)(A) pro-
vides that all securities of the same issuer
are treated as a single investment.
(3) Under § 1.817–5(c)(1), an account
is treated as adequately diversified for a
calendar quarter if it satisfies the require-
ments of § 1.817–5(b) on the last day of
the calendar quarter or within 30 days
after that last day.
.10 Section 1.817–5(f)(1) provides a
look-through rule for assets held through
certain investment companies, partner-
ships, or trusts. For this purpose, the term
“investment company, partnership, or
trust” refers to a regulated investment
company, a real estate investment trust, a
partnership, or a trust that is treated under
§§ 671 through 679 as owned by the
grantor or another person.
(1) The look-through rule applies to an
investment company, partnership, or trust
that meets the requirements described in
§ 1.817–5(f)(2). Section 1.817–5(f)(2)
generally requires that all the beneficial
interests in such an entity be held by one
or more segregated accounts and that pub-
lic access to such an entity be available
exclusively through the purchase of a
variable contract.
(2) Section 1.817–5(f)(3) provides lim-
ited exceptions to § 1.817–5(f)(2).
.11 If the look-through rule applies, a
beneficial interest in an investment com-
pany, partnership, or trust is not treated as
a single investment of a segregated asset
account. Instead, a pro rata portion of each
asset of the investment company, partner-
ship, or trust is treated as an asset of the
segregated asset account. For purposes of
that treatment, the ratable interest of a
partner in a partnership’s assets is deter-
mined in accordance with the partner’s
capital interest in the partnership.
.12Section1.817–5(h)(1)defines
“government security” as any security is-
sued or guaranteed or insured by the
United States or an instrumentality of the
United States or any certificate of deposit
for any of the foregoing. (This definition
is similar to the language used to define
“government security” in § 2(a)(16) of the
Investment Company Act of 1940.) For
purposes of § 1.817–5(h)(1), “an instru-
mentality of the United States” means any
person that is treated for purposes of 15
U.S.C. 80a–2(16), as amended, as a per-
son controlled or supervised by and acting
as an instrumentality of the Government
of the United States pursuant to authority
granted by the Congress of the United
States. Under § 817(h)(6), for purposes of
determining whether a segregated asset
account is adequately diversified, each
United States Government agency or in-
strumentality is treated as a separate is-
suer.See also§ 1.817–5(b)(1)(ii)(B).
.13 When a market participant enters
into an unstipulated TBA trade to acquire
UMBS, it will not know the issuer (Fannie
Mae or Freddie Mac) until 48 hours prior
to delivery. Thus, suppose that an insur-
ance company enters into unstipulated
TBA trades to acquire GSE securities for
inclusion in a segregated asset account on
which one or more contracts issued by the
company are based. Once the Single Se-
curity Initiative is effective, such a com-
pany will not know until 48 hours before
settlement the issuers of the UMBS to be
delivered to it under the contract. If the
account is already heavily invested in se-
curities issued by one of the GSEs, the
TBA contract may require acceptance of
additional securities of that issuer—an ac-
ceptance that may jeopardize the segre-
gated asset account’s satisfaction of the
diversification requirements of § 817(h)
and the regulations thereunder.
SECTION 3. DEFINITIONS
Solely for purposes of this revenue
procedure—
.01 The term “taxpayer” means—
(1) An insurance company that is-
sues variable contracts within
the meaning of § 817(d); and
(2) An investment company, partner-
ship, or trust, as defined in section
2.10 of this revenue procedure,
that qualifies for “look-through”
treatment under § 1.817–5(f).
.02 The term “electing taxpayer”
means a taxpayer subject to a deemed-
issuance-ratio election as described in this
revenue procedure.
.03 The term “generic GSE security”
means a TBA-eligible GSE security that a
buyer acquires by taking delivery pursu-
ant to a TBA trade in which, at the time
that the buyer entered into the TBA con-
tract, the buyer had no way of knowing
the actual issuer(s) of the securities to be
delivered under the contract.
.04 For purposes of determining
whether a security is a generic GSE secu-
rity, the term “buyer” includes a taxpayer
that is either of the following:
(1) An assignee of a buyer (taking into
account this section 3.04), provided
that—
a. There is a legal transfer to the
assignee of rights and obligations
under the assignor’s TBA con-
tract for the acquisition of a ge-
neric GSE security; and
b. This transfer occurs at a time
when neither the assignor nor the
assignee has any way of knowing
the actual issuer(s) of the securi-
ties to be delivered under the
contract.
(2) A successor entity to a buyer (tak-
ing into account this section 3.04), pro-
vided that—
a. The successor entity succeeds to
attributes of the buyer in a trans-
action to which § 381(a) applies;
b. The buyer to which the successor
entity succeeds is an electing tax-
payer; and
c. The successor entity either al-
ready is an electing taxpayer or
makes a deemed-issuance-ratio
election for the first taxable year
in which that entity becomes a
successor to the buyer.
.05 For purposes of the operation of
these definitions, the following rules ap-
ply:
(1) The term “generic GSE security”
applies to those securities only with
respect to a buyer who acquired
them in the manner described in
section 3.03 or section 3.04 of this
revenue procedure. That is, they
are not generic GSE securities with
respect to any other person.
(2) The term does not include securities
acquired in specified pool trades,
stipulated trades in which the issuer
is stipulated, or any other trade in
which the issuer of the security can
November 5, 2018Bulletin No. 2018–45
770

be known when the TBA contract is
initiated.
SECTION 4. SCOPE
This revenue procedure applies to—
.01 Any taxpayer as defined in section
3.01 of this revenue procedure; and
.02 Any generic GSE security, as de-
fined in section 3.03 of this revenue pro-
cedure, with respect to which such a tax-
payer is a buyer.
SECTION 5. APPLICATION—
ABILITY TO MAKE A DEEMED-
ISSUANCE-RATIO ELECTION
A taxpayer may make a deemed-
issuance-ratio election with respect to its
generic GSE securities. The consequences
of a deemed-issuance-ratio election are
described in section 6 of this revenue pro-
cedure. The required time and manner for
making a deemed-issuance-ratio election
are described in section 7 of this revenue
procedure.
SECTION 6. APPLICATION—
CONSEQUENCES OF A DEEMED-
ISSUANCE-RATIO ELECTION
.01 For purposes of applying § 817(h)
and the regulations thereunder, the conse-
quencesdescribedinsections6.02
through 6.05 of this revenue procedure
apply to the extent that an electing taxpay-
er’s generic GSE securities either—
(1) Are held in a segregated asset ac-
count on which a variable contract
issued by the taxpayer is based; or
(2) Are treated under § 1.817–5(f) as
being held in a segregated asset ac-
count on which a variable contract
issued by some other person is
based.
.02 (1) If an electing taxpayer holds a
generic GSE security, that security
is deemed to be issued in part by
Fannie Mae and in part by Freddie
Mac. Except to the extent provided
in section 6.02(2) of this revenue
procedure, the portions deemed is-
sued by each are determined by the
deemed-issuance ratio that was ap-
plicable to the year in which the
taxpayer entered into the TBA con-
tract under which the generic GSE
security was to be delivered. See
section 6.05 of this revenue proce-
dure. It is irrelevant which GSE is
the actual issuer of the generic
GSE securities that are delivered
under the TBA contract.
(2) In the case of a taxpayer that is a
buyer by virtue of section 3.04(2)
of this revenue procedure (concern-
ing successor entities), if such a
taxpayer acquired a generic GSE
security in the succession transac-
tion, then the security retains the
same deemed-issuance ratio in that
taxpayer’s hands that it had in the
hands of the predecessor.
(3)Example. Assume that an electing
taxpayer entered into a TBA con-
tract to acquire $100xin generic
GSE securities to be held in a seg-
regated asset account on which a
variable contract issued by the
electing taxpayer is based. On the
date when the contract was entered,
the applicable deemed-issuance ra-
tio (as described in section 6.05 of
this revenue procedure) was 60-to-
40, Fannie Mae to Freddie Mac.
Accordingly, for purposes of ap-
plying § 817(h) and the regulations
thereunder, any generic GSE secu-
rity that was delivered under the
contract is deemed to have been
issued 60 percent by Fannie Mae
and 40 percent by Freddie Mac. In
the aggregate, therefore, when
those generic GSE securities are
first acquired, they are treated as
$60xFannie Mae securities and
$40xFreddie Mac securities, re-
gardless of which GSE is the actual
issuer of the generic GSE securities
that are delivered under the TBA
contract.
.03 As long as the electing taxpayer
continues to hold a generic GSE security,
the security’s deemed-issuance ratio re-
mains constant. Thus—
(1) As an electing taxpayer’s generic
GSE securities pay down, the re-
maining balance of each retains its
deemed-issuance ratio, regardless of
any pre-payments or foreclosures
made on the generic GSE securities
and the actual issuers of remaining
generic GSE securities.
(2) If the electing taxpayer disposes of
some of its generic GSE securities,
the deemed-issuance ratio of each
remaining generic GSE security
does not vary.
.04 If a generic GSE security held by
an electing taxpayer is aggregated into a
pool of mortgage-backed securities as part
of a GSE resecuritization program and
new securities are issued, then the issuer
of the new security is the known GSE that
issued the resecuritization security, and
the deemed-issuance ratio no longer ap-
plies to the old security in its role as a
component of the resecuritization pool. To
the extent a new resecuritization security
is delivered into a generic TBA trade
(with the issuer unknown by the taxpayer
at the trade date), a taxpayer that has made
a deemed-issuance-ratio election treats the
resecuritization security consistent with
the deemed-issuance rule.
.05 At least three weeks prior to the
start of each calendar year, FHFA will
determine and publicize the deemed-
issuance ratio that electing taxpayers are
to use for TBA contracts entered into dur-
ing that calendar year.
(1) FHFA will determine this ratio
based on the ratio of TBA-eligible
securities issued by Fannie Mae and
Freddie Mac during a 24-month pe-
riod ending not earlier than October
31 immediately preceding the year
to which the new ratio will apply.
The ratio must be two whole num-
bers. FHFA may round the observed
ratio in the data to whatever extent
FHFA considers appropriate, pro-
vided that the rounded ratio to be
used is further from 50-50 than the
actual observed data.
(2)Example. At least three weeks prior
to the start of 2019, FHFA will de-
termine and publicize the deemed-
issuance ratio that electing taxpayers
are to use for TBA contracts to ac-
quire generic GSE securities entered
into during 2019. FHFA will deter-
mine this ratio based on the ratio of
TBA-eligible securities issued by
Fannie Mae and Freddie Mac during
the 24-month period ending not ear-
lier than October 31, 2018. If the
percent of aggregate TBA-eligible
securities issued by Fannie Mae and
Freddie Mac during the 24-month
period ending on October 31, 2018,
was 59 percent and 41 percent re-
spectively, then FHFA might deter-
Bulletin No. 2018–45November 5, 2018
771

mine a deemed-issuance ratio of 60-
to-40, Fannie Mae-to-Freddie Mac.
If it did so, then solely for purposes
of determining whether electing tax-
payers’ segregated asset accounts
meet the diversification require-
ments of § 817(h), that deemed-
issuance ratio would apply to any
generic GSE security delivered un-
der a TBA contract that is entered
into during 2019, regardless of the
actual issuers of the delivered secu-
rities.
SECTION 7.
PROCEDURE—MAKING THE
ELECTION
.01 A deemed-issuance-ratio election
must be made in a statement attached to
the taxpayer’s income tax return for the
first taxable year for which the taxpayer
wants the election to apply. The statement
must be titled “Section 817(h) Deemed-
Issuance-Ratio Election.” The statement
must indicate that the taxpayer elects the
deemed-issuance-ratio election (as de-
scribed in this revenue procedure) and
must include the taxpayer’s name, ad-
dress, and TIN. If the common parent (or
agent within the meaning of § 1.1502–77)
of a group of corporations filing a consol-
idated return is making the election on
behalf of one or more members of the
consolidated group, the parent must indi-
cate the name, address, and taxpayer iden-
tification number of each consolidated
group member for which the election is
being made.
.02 A deemed-issuance-ratio election is
applicable to all of the electing taxpayer’s
generic GSE securities acquired under
TBA contracts that were entered into for
quarters ending in the year specified in the
election and for quarters ending in all sub-
sequent taxable years for which the elec-
tion is effective.
.03 A deemed-issuance-ratio election is
revocable only with the prior written con-
sent of the Commissioner of Internal Rev-
enue. To request the Commissioner’s con-
sent, the electing taxpayer (or successor)
must submit a request for a private letter
ruling in accordance with the provisions
of Rev. Proc. 2018 –1, 2018 –1 I.R.B. 1 (or
its then-applicable successor).
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective for
elections with respect to quarters ending
on or after the date on which investors can
first enter into TBA contracts that do not
specify the issuer of the GSE securities
that may be delivered under it.
SECTION 9. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
approved by the Office of Management
and Budget (OMB) under OMB control
number 1545– 0123 in accordance with
the Paperwork Reduction Act (44 U.S.C.
3507). An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless the collection of information dis-
plays a valid OMB control number.
This revenue procedure contains a col-
lection of information requirement in sec-
tion 7. The purpose of the collection of
information is to verify the taxpayer’s
deemed-issuance-ratio election. The col-
lection of information is required to obtain
the benefit of using the election. The
likely respondents are taxpayers (as de-
fined in section 3.01 of this revenue pro-
cedure) that hold investments in one or
more segregated asset accounts on which
variable contracts are based.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally tax returns and tax
return information are confidential, as re-
quired by 26 U.S.C. 6103.
SECTION 10. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Katherine A. Hossofsky of
the Office of the Associate Chief Counsel
(Financial Institutions and Products). For
further information regarding this revenue
procedure, please contact Katherine A.
Hossofsky at (202) 317-6995 (not a toll-
free number).
Section 817—Treatment of
variable contracts
26 CFR 1.817–5: Diversification requirements
for variable annuity, endowment, and life insurance
contracts.
This revenue procedure provides guidance for tax-
payers that hold investments in one or more segre-
gated asset accounts on which variable contracts as
defined in section 817of the Internal Revenue Code.
The guidance allows taxpayers to elect to treat cer-
tain mortgage-backed securities as having deemed
issuers for purposes of the diversification require-
ments of section 817(h). See Rev. Proc. 2018 –54,
page 769.
November 5, 2018Bulletin No. 2018–45
772

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. 2018–45November 5, 2018
i

Numerical Finding List
1
Bulletin 2018 –27 through 2018 – 45
Announcements:
2018-09, 2018-28 I.R.B.206
2018-12, 2018-30 I.R.B.232
2018-13, 2018-43 I.R.B.232
Notices:
2018-48, 2018-28 I.R.B.9
2018-56, 2018-27 I.R.B.3
2018-58, 2018-33 I.R.B.305
2018-59, 2018-28 I.R.B.196
2018-60, 2018-31 I.R.B.275
2018-61, 2018-31 I.R.B.278
2018-62, 2018-34 I.R.B.316
2018-63, 2018-34 I.R.B.318
2018-64, 2018-35 I.R.B.347
2018-65, 2018-35 I.R.B.350
2018-67, 2018-36 I.R.B.409
2018-68, 2018-36 I.R.B.418
2018-69, 2018-37 I.R.B.426
2018-70, 2018-38 I.R.B.441
2018-71, 2018-41 I.R.B.548
2018-72, 2018-40 I.R.B.522
2018-73, 2018-40 I.R.B.526
2018-74, 2018-40 I.R.B.529
2018-75, 2018-41 I.R.B.556
2018-76, 2018-42 I.R.B.599
2018-77, 2018-42 I.R.B.601
2018-78, 2018-42 I.R.B.604
2018-79, 2018-42 I.R.B.606
2018-80, 2018-42 I.R.B.609
2018-81, 2018-43 I.R.B.666
2018-82, 2018-44 I.R.B.718
2018-84, 2018-45 I.R.B.768
Proposed Regulations:
REG-130244-17, 2018-41 I.R.B.593
REG-103474-18, 2018-32 I.R.B.284
REG-104390-18, 2018-43 I.R.B.671
REG-104397-18, 2018-41 I.R.B.560
REG-104872-18, 2018-44 I.R.B.762
REG-106977-18, 2018-27 I.R.B.6
REG-107892-18, 2018-35 I.R.B.353
REG-112176-18, 2018-37 I.R.B.430
Revenue Procedures:
2018-35, 2018-28 I.R.B.204
2018-36, 2018-38 I.R.B.442
2018-37, 2018-29 I.R.B.210
2018-38, 2018-31 I.R.B.280
2018-39, 2018-34 I.R.B.319
2018-40, 2018-34 I.R.B.320
2018-42, 2018-36 I.R.B.424
2018-43, 2018-36 I.R.B.425
Revenue Procedures:—Continued
2018-44, 2018-37 I.R.B.426
2018-45, 2018-37 I.R.B.428
2018-46, 2018-39 I.R.B.460
2018-47, 2018-39 I.R.B.518
2018-48, 2018-40 I.R.B.521
2018-49, 2018-41 I.R.B.548
2018-50, 2018-42 I.R.B.610
2018-51, 2018-44 I.R.B.721
2018-52, 2018-42 I.R.B.611
2018-53, 2018-43 I.R.B.667
2018-54, 2018-45 I.R.B.769
Revenue Rulings:
2018-19, 2018-27 I.R.B.1
2018-20, 2018-28 I.R.B.8
2018-21, 2018-32 I.R.B.282
2018-22, 2018-34 I.R.B.308
2018-23, 2018-36 I.R.B.405
2018-24, 2018-36 I.R.B.407
2018-25, 2018-39 I.R.B.445
2018-26, 2018-40 I.R.B.520
2018-27, 2018-41 I.R.B.546
2018-28, 2018-45 I.R.B.764
2018-29, 2018-45 I.R.B.765
Treasury Decisions:
9834, 2018-31 I.R.B.233
9835, 2018-33 I.R.B.288
9836, 2018-33 I.R.B.291
9838, 2018-34 I.R.B.309
9839, 2018-35 I.R.B.325
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018 – 01 through 2018 –26 is in Internal Revenue Bulletin
2018 –26, dated June 27, 2018.
November 5, 2018Bulletin No. 2018–45
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2018 –27 through 2018 – 45
Notices:
2014-5
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2015-28
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2016-57
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2017-45
Modified by
Notice 2018-69, 2018-37 I.R.B.426
Revenue Procedures:
2015-27
Amplified by
Rev. Proc. 2018-39, 2018-34 I.R.B.319
2017-24
Amplified by
Rev. Proc. 2018-39, 2018-34 I.R.B.319
2018-31
Modified by
Rev. Proc. 2018-44, 2018-37 I.R.B.426
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018 – 01 through 2018 –26 is in Internal Revenue Bulletin
2018 –26, dated June 27, 2018.
Bulletin No. 2018–45November 5, 2018
iii

INTERNAL REVENUE BULLETIN
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