Internal Revenue Bulletin 2019-20 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2019–20
May 13, 2019
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE, SPECIAL
ANNOUNCEMENT
NOT 2019-30, page 1180.
This notice solicits public comments recommending guid-
ance projects that should be included in the 2019-2020 Pri-
ority Guidance Plan.
EMPLOYEE PLANS
REV PROC 2019-20, page 1182.
This revenue procedure provides for a limited expansion of
the determination letter program with respect to individually
designed plans. This revenue procedure also provides for a
limited extension of the remedial amendment period under §
401(b) of the Internal Revenue Code and Rev. Proc. 2016-
37 under specified circumstances, and for special sanction
structures that apply to certain plan document failures dis-
covered by the IRS during the review of a plan submitted for
a determination letter pursuant to this revenue procedure.
INCOME TAX
REV RUL 2019-13, page 1179.
This revenue ruling provides guidance on the application of
subchapters C and S of chapter 1 of subtitle A of the In-
ternal Revenue Code (Code) to cash distributions made in
redemption of the stock of C corporations formerly classified
as S corporations and during the post-termination transition
period as defined under section 1377(b) of the Code. Specif-
ically, the revenue ruling holds that to the extent a corpora-
tion makes such a cash distribution that is subject to section
301 of the Code by reason of section 302(d) of the Code,
the cash distribution should reduce the corporation’s accu-
mulated adjustments account (within the meaning of section
1368(e) of the Code) to the extent of the proceeds of the
redemption pursuant to section 1368 of the Code.
NOT 2019-31, page 1181.
The notice publishes the inflation adjustment factor for the car-
bon oxide sequestration credit under § 45Q for calendar year
2019. Also, the notice includes a statement of the amount of
qualified carbon oxide that has been taken into account by tax-
payers filing an annual report pursuant to section 6 of Notice
2009-83, 2009-2 C.B. 588.
Finding Lists begin on page ii.

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 of-
ficial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, 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 sub-
stantive 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 inter-
nal management are not published; however, statements of
internal 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 rul-
ings to taxpayers or technical advice to Service field offices,
identifying 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,
Legislation 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
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (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.
May 13, 2019 Bulletin No. 2019–20

Part I.
Section 1368.—
Distributions
26 CFR 1.1368-1: Distributions by S corporations
(Also: §§ 301, 302, 1362, 1367, 1371, 1377, 26 CFR
1.1368-2)
Rev. Rul. 2019-13
ISSUE
If, during a former S corporation’s
post-termination transition period, the
corporation distributes cash in redemption
of a shareholder’s stock and the distribu-
tion is characterized as a distribution un-
der § 301 of the Internal Revenue Code
(Code), should the corporation reduce its
accumulated adjustments account (AAA)
pursuant to § 1368 of the Code?
FACTS
X is a corporation that once was a C cor-
poration and later elected to be an S corpo-
ration under § 1362(a) of the Code. X’s S
election terminated under § 1362(d), such
that it is now a C corporation. A, an indi-
vidual, owns all 100 shares of the outstand-
ing stock of X. X is a calendar-year tax-
payer. At the time of its conversion to an
S corporation, X had accumulated earnings
and profits (E&P) of $600x and no current
E&P. At the time of the termination of its
S election, X’s AAA was $800x and its ac-
cumulated E&P was still $600x. During
X’s post-termination transition period, X
redeems 50 of A’s 100 shares of X stock
for $1,000x. X makes no other distribu-
tions during the post-termination transition
period. Pursuant to § 302(d) of the Code,
the redemption is characterized as a dis-
tribution subject to § 301. For the taxable
period that includes the redemption, X has
current E&P of $400x.
LAW AND ANALYSIS
Section 1371(e) of the Code provides
that, in general, any distribution of cash
by a former S corporation with respect to
its stock during the post-termination tran-
sition period (as defined in § 1377(b) of
the Code) is applied against and reduces
the adjusted basis of the stock to the ex-
tent the distribution does not exceed the
corporation’s AAA (within the meaning
of § 1368(e)). Section 1368(e) defines
the AAA as an account of the S corpora-
tion, which is adjusted for the S period
in a manner similar to the adjustments
under § 1367 of the Code (except that no
adjustment is made for income (and relat-
ed expenses) that is exempt from tax un-
der the Code; the phrase “(but not below
zero)” is disregarded in § 1367(a)(2)); and
no adjustment is made for Federal taxes
attributable to any taxable year in which
the corporation was a C corporation. The
term “S period” is defined in § 1368(e)
(2) as the most recent continuous period
during which the corporation has been an
S corporation.
HOLDING
If, during a former S corporation’s
post-termination transition period, the cor-
poration distributes cash in redemption of
a shareholder’s stock, which is character-
ized as a distribution subject to § 301, the
corporation should reduce its AAA to the
extent of the proceeds of the redemption
pursuant to § 1368. The redemption of 50
of A’s 100 shares of X stock for $1,000x is
characterized as a reduction of X’s $800x
of AAA with the remaining $200x char-
acterized as a dividend under § 301(c)(1).
DRAFTING INFORMATION
The principal author of this revenue
ruling is Margaret Burow of the Office of
Associate Chief Counsel (Passthroughs
and Special Industries). For further infor-
mation regarding this revenue ruling, con-
tact Margaret Burow at (202) 317-5279
(not a toll-free number).
Bulletin No. 2019–20 1179 May 13, 2019

Part III.
Public Comment Invited
on Recommendations
for 2019-2020 Priority
Guidance Plan
Notice 2019-30
The Department of the Treasury (Trea-
sury Department) and the Internal Reve-
nue Service (Service) invite public com-
ment on recommendations for items that
should be included on the 2019-2020 Pri-
ority Guidance Plan.
The Treasury Department’s Office of
Tax Policy and the Service use the Pri-
ority Guidance Plan each year to identify
and prioritize the tax issues that should
be addressed through regulations, reve-
nue rulings, revenue procedures, notices,
and other published administrative guid-
ance. The 2019-2020 Priority Guidance
Plan will identify guidance projects that
the Treasury Department and the Ser-
vice intend to actively work on as prior-
ities during the period from July 1, 2019,
through June 30, 2020.
The Treasury Department and the Ser-
vice recognize the importance of public
input in formulating a Priority Guidance
Plan that focuses resources on guidance
items that are most important to taxpayers
and tax administration. Published guid-
ance plays an important role in increasing
voluntary compliance by helping to clar-
ify ambiguous areas of the tax law. The
published guidance process is most suc-
cessful if the Treasury Department and the
Service have the benefit of the experience
and knowledge of taxpayers and practi-
tioners who must apply the rules imple-
menting the tax laws.
On December 22, 2017, P.L. 115-97,
“An Act to provide for the reconciliation
pursuant to titles II and V of the concur-
rent resolution on the budget for fiscal
year 2018,” commonly referred to as the
Tax Cuts and Jobs Act (TCJA), was enact-
ed. Since that time, the Treasury Depart-
ment and the Service have focused their
efforts on guidance projects necessary to
implement the TCJA and published 111
items, including 30 regularly scheduled
items, during the first two quarters of the
2018-2019 plan year.
The Treasury Department and the Ser-
vice expect to continue to prioritize guid-
ance implementing the TCJA during the
2019-2020 plan year and that the plan will
reflect this priority. The Treasury Depart-
ment and the Service expect that, even
though many important projects not relat-
ed to the TCJA were published during the
2018-2019 plan year, a number of other
non-TCJA guidance projects on the 2018-
2019 Priority Guidance Plan will not be
completed by June 30, 2019. These proj-
ects may be carried over to the 2019-2020
Priority Guidance Plan. Due to resource
limitations, the Treasury Department and
the Service also expect that not all of
the uncompleted projects will be carried
over to the 2019-2020 Priority Guidance
Plan, and only a limited number of new
non-TCJA guidance projects will be add-
ed to the plan.
In reviewing recommendations and se-
lecting additional projects for inclusion on
the 2019-2020 Priority Guidance Plan, the
Treasury Department and the Service will
consider the following:
1. Whether the recommended guidance
resolves significant issues relevant to
many taxpayers;
2. Whether the recommended guidance
reduces controversy and lessens the
burden on taxpayers or the Service;
3. Whether the recommendation involves
existing regulations or other guidance
that is outdated, unnecessary, ineffec-
tive, insufficient, or unnecessarily bur-
densome and that should be modified,
streamlined, expanded, replaced, or
withdrawn;
4. Whether the recommended guidance
would be in accordance with Execu-
tive Order 13771 (82 FR 9339), Exec-
utive Order 13777 (82 FR 12285), Ex-
ecutive Order 13789 (82 FR 19317), or
other executive orders.
5. Whether the recommended guidance
promotes sound tax administration;
6. Whether the Service can administer the
recommended guidance on a uniform
basis; and
7. Whether the recommended guidance
can be drafted in a manner that will en-
able taxpayers to easily understand and
apply the guidance.
Please submit recommendations by
Friday, June 7, 2019, for possible inclu-
sion on the original 2019-2020 Priority
Guidance Plan. Taxpayers may, however,
submit recommendations for guidance at
any time during the year. The Treasury
Department and the Service will update
the 2019-2020 Priority Guidance Plan
periodically to reflect additional guidance
that the Treasury Department and the Ser-
vice intend to publish during the plan year.
The periodic updates allow the Treasury
Department and the Service to respond in
a timely manner to the need for addition-
al guidance that may arise during the plan
year.
Taxpayers are not required to submit
recommendations for guidance in any
particular format. Taxpayers should,
however, briefly describe the recom-
mended guidance and explain the need
for the guidance. In addition, taxpayers
may include an analysis of how the issue
should be resolved. For recommenda-
tions to modify, streamline, or withdraw
existing regulations or other guidance,
taxpayers should explain how the chang-
es would reduce taxpayer cost and/or
burden or benefit tax administration. It
would be helpful if taxpayers suggesting
more than one guidance project priori-
tize the projects by order of importance.
If a large number of projects are being
suggested, it would be helpful if the
projects were grouped by subject mat-
ter and then in terms of high, medium,
or low priority. Requests for guidance
in the form of petitions for rulemaking
will be considered with other recom-
mendations for guidance in accordance
with the considerations described in this
notice.
Taxpayers may submit comments elec-
tronically via the Federal eRulemaking
Portal at www.regulations.gov (type IRS-
2019-0019 in the search field on the reg-
ulations.gov homepage to find this notice
and submit comments).
May 13, 2019 1180 Bulletin No. 2019–20

Bulletin No. 2019–20 1181 May 13, 2019
Alternatively, taxpayers may mail
comments to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2019-
30) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
All recommendations for guidance
submitted by the public in response to
this notice will be available for public in-
spection and copying in their entirety. For
further information regarding this notice,
contact Emily M. Lesniak of the Office of
the Associate Chief Counsel (Procedure
and Administration) at (202) 317-3400
(not a toll-free number).

Credit for Carbon Oxide
Sequestration
2019 Section 45Q Inflation
Adjustment Factor
Notice 2019-31
SECTION 1. PURPOSE
This notice publishes the inflation ad-
justment factor for the credit for carbon
oxide sequestration under § 45Q of the
Internal Revenue Code (§ 45Q credit)
for calendar year 2019. The inflation ad-
justment factor is used to determine the
amount of the credit allowable under §
45Q. This notice also publishes the ag-
gregate amount of qualified carbon oxide
taken into account for purposes of § 45Q.
SECTION 2. BACKGROUND
Section 45Q was enacted by § 115 of
the Energy Improvement and Extension
Act of 2008, Division B of Pub. L. No.
110-343, 122 Stat. 3765, 3829 (October 3,
2008), to provide a credit for the seques-
tration of carbon dioxide. Section 45Q
was amended by § 1131 of the American
Recovery and Reinvestment Tax Act of
2009, Division B of Pub. L. 111-5, 123
Stat 115 (February 17, 2009) and more re-
cently by section 41119 of the Bipartisan
Budget Act of 2018 (BBA), Pub. L. No.
115-123 (February 9, 2018). As a result
of the modifications made by the BBA
amendment, the credit under § 45Q now
applies to the sequestration of “qualified
carbon oxide,” a broader term than qual-
ified carbon dioxide. The amount of the
credit is also increased for carbon oxide
captured with equipment originally placed
in service on or after the date of enactment
of BBA.
Section 45Q(a)(1) allows a credit of
$20 per metric ton of qualified carbon
oxide (i) captured by the taxpayer using
carbon capture equipment which is orig-
inally placed in service at a qualified fa-
cility before the date of the enactment of
BBA, (ii) disposed of by the taxpayer in
secure geological storage, and (iii) not
used by the taxpayer as a tertiary injectant
in a qualified enhanced oil or natural gas
recovery project.
Section 45Q(a)(2) allows a credit of
$10 per metric ton of qualified carbon ox-
ide (i) captured by the taxpayer using car-
bon capture equipment which is original-
ly placed in service at a qualified facility
before the date of the enactment of BBA,
and (ii) either (I) used by the taxpayer as
a tertiary injectant in a qualified enhanced
oil or natural gas recovery project and dis-
posed of by the taxpayer in secure geolog-
ical storage or (II) utilized by the taxpayer
in a manner described in § 45Q(f)(5).
Section 45Q(a)(3) allows a credit of
the applicable dollar amount (as deter-
mined under § 45Q(b)(1)) per metric ton
of qualified carbon oxide (i) captured by
the taxpayer using carbon capture equip-
ment which is originally placed in ser-
vice at a qualified facility on or after the
date of the enactment of BBA during the
12-year period beginning on the date the
equipment was originally placed in ser-
vice, (ii) disposed of by the taxpayer in
secure geological storage, and (iii) nei-
ther used as a tertiary injectant in a qual-
ified enhanced oil or natural gas recovery
project nor utilized in a manner described
in § 45Q(f)(5).
Section 45Q(a)(4) allows credit of the
applicable dollar amount (as determined
under § 45Q(b)(1)) per metric ton of
qualified carbon oxide (i) captured by the
taxpayer using carbon capture equipment
which is originally placed in service at a
qualified facility on or after the date of the
enactment of BBA, during the 12-year pe-
riod beginning on the date the equipment
was originally placed in service, and (ii)
either (I) used by the taxpayer as a tertiary
injectant in a qualified enhanced oil or nat-
ural gas recovery project and disposed of
by the taxpayer in secure geological stor-
age or (II) utilized in a manner described
in § 45Q(f)(5).
For purposes of determining the carbon
oxide sequestration credit under § 45Q, a
taxpayer may elect under § 45Q(b)(3) to
have the dollar amounts applicable un-
der § 45Q(a)(1) or (2) apply in lieu of the
dollar amounts applicable under § 45Q(a)
(3) or (4) for each metric ton of qualified
carbon oxide which is captured by the
taxpayer using carbon capture equipment
which is originally placed in service at a
qualified facility on or after the date of the
enactment of BBA.
Section 45Q(c) defines the term “quali-
fied carbon oxide” as (i) any carbon diox-
ide which (I) is captured from an indus-
trial source by carbon capture equipment
which is originally placed in service be-
fore the date of the enactment of BBA, (II)
would otherwise be released into the at-
mosphere as industrial emission of green-
house gas or lead to such release, and (III)
is measured at the source of capture and
verified at the point of disposal, injection,
or utilization; (ii) any carbon dioxide or
other carbon oxide which (I) is captured
from an industrial source by carbon cap-
ture equipment which is originally placed
in service on or after the date of the en-
actment of BBA, (II) would otherwise be
released into the atmosphere as industrial
emission of greenhouse gas or lead to such
release, and (III) is measured at the source
of capture and verified at the point of dis-
posal, injection, or utilization; or (iii) in
the case of a direct air capture facility,
any carbon dioxide which (I) is captured
directly from the ambient air, and (II) is
measured at the source of capture and ver-
ified at the point of disposal, injection, or
utilization.
Section 45Q(d) defines the term “quali-
fied facility” as any industrial facility or di-
rect air capture facility (i) the construction
of which begins before January 1, 2024,
and (I) construction of carbon capture
equipment begins before such date, or (II)
the original planning and design for such
facility includes installation of carbon cap-

May 13, 2019 1182 Bulletin No. 2019–20
ture equipment; and (ii) which captures (I)
in the case of a facility which emits not
more than 500,000 metric tons of car-
bon oxide into the atmosphere during the
taxable year, not less than 25,000 metric
tons of qualified carbon oxide during the
taxable year which is utilized in a manner
described in § 45Q(f)(5), (II) in the case of
an electricity generating facility which is
not described in § 45Q(d)(2)(A), not less
than 500,000 metric tons of qualified car-
bon oxide during the taxable year, or (III)
in the case of a direct air capture facility
or any facility not described in § 45Q(d)
(2)(A) or (B), not less than 100,000 metric
tons of qualified carbon oxide during the
taxable year.
Under § 45Q(f)(7), for taxable years
beginning in a calendar year after 2009,
the dollar amounts contained in § 45Q(a)
(1) and (2) must be adjusted for inflation
by multiplying such dollar amount by the
inflation adjustment factor for such calen-
dar year determined under § 43(b)(3)(B),
determined by substituting “2008” for
“1990.”
Section 43(b)(3)(B) defines the term
“inflation adjustment factor” as, with re-
spect to any calendar year, a fraction the
numerator of which is the GNP implicit
price deflator for the preceding calendar
year and the denominator of which is the
GNP implicit price deflator for 1990. For
purposes of § 45Q(f)(7), for the 2019 cal-
endar year, the inflation adjustment factor
is a fraction the numerator of which is
the GNP implicit price deflator for 2018
(110.308) and the denominator of which
is the GNP implicit price deflator for 2008
(94.268).
Section 45Q(g) provides that in the
case of any carbon capture equipment
placed in service before the date of the
enactment of BBA, the credit under §
45Q shall apply with respect to qualified
carbon oxide captured using such equip-
ment before the end of the calendar year
in which the Secretary, in consultation
with the Administrator of the Environ-
mental Protection Agency, certifies that,
during the period beginning after Octo-
ber 3, 2008, a total of 75,000,000 metric
tons of qualified carbon oxide have been
taken into account in accordance with (i)
§ 45Q(a), as in effect on the day before
the date of the enactment of BBA, and
(ii) § 45Q(a)(1) and (2).
SECTION 3. INFLATION
ADJUSTMENT FACTOR
The inflation adjustment factor for
calendar year 2019 is 1.1702. The § 45Q
credit for calendar year 2019 is $23.40 per
metric ton of qualified carbon oxide under
§ 45Q(a)(1) and $11.70 per metric ton of
qualified carbon oxide under § 45Q(a)(2).
SECTION 4. TAX CREDIT
UTILIZATION
Section 6 of Notice 2009-83 requires
taxpayers to file annual reports that pro-
vide (among other information) the
amounts (in metric tons) of qualified
carbon oxide for the taxable year that
has been taken into account for purposes
of claiming the § 45Q credit. The annu-
al reports must be filed with the Service
not later than the last day of the second
calendar month following the month
during which the tax return on which the
§ 45Q credit is claimed was due (includ-
ing extensions).
Based on the most recent annual reports
filed with the Internal Revenue Service,
the aggregate amount of qualified carbon
oxide taken into account for purposes of
§ 45Q is 62,740,171 metric tons.
SECTION 5. DRAFTING
INFORMATION
The principal author of this notice
is Maggie Stehn of the Office of Associate
Chief Counsel (Passthroughs & Special
Industries). For further information re-
garding this notice contact Maggie Stehn
at (202) 317-6853 (not a toll-free number).

Rev. Proc. 2019-20
SECTION 1. PURPOSE
This revenue procedure, consistent with
the process described in Rev. Proc. 2016-
37, 2016-29 I.R.B. 136, provides for a
limited expansion of the determination
letter program with respect to individu-
ally designed plans. Under this limited
expansion, the Internal Revenue Service
(IRS) will accept determination letter
applications for (i) individually designed
statutory hybrid plans during a 12-month
period beginning September 1, 2019, and
(ii) individually designed Merged Plans
(as defined in section 5.01(2) of this rev-
enue procedure) on an ongoing basis. As
provided by Rev. Proc. 2016-37, a plan
sponsor continues to be permitted to sub-
mit a determination letter application for
initial plan qualification and for qualifica-
tion upon plan termination. This revenue
procedure also provides for a limited ex-
tension of the remedial amendment period
under § 401(b) of the Internal Revenue
Code (Code) and Rev. Proc. 2016-37 un-
der specified circumstances, and for spe-
cial sanction structures that apply to cer-
tain plan document failures discovered by
the IRS during the review of a plan sub-
mitted for a determination letter pursuant
to this revenue procedure.
SECTION 2. BACKGROUND
.01 Effective January 1, 2017, Rev.
Proc. 2016-37 provides the circumstanc-
es under which plan sponsors may submit
determination letter applications to the
IRS. In general, a sponsor of an individ-
ually designed plan may submit a deter-
mination letter application only for initial
plan qualification and for qualification
upon plan termination. However, as de-
scribed in section 4.03(3) of Rev. Proc.
2016-37, the Department of the Treasury
(Treasury Department) and the IRS will
consider each year whether to accept de-
termination letter applications for individ-
ually designed plans in specified circum-
stances other than for initial qualification
and qualification upon plan termination.
.02 In Notice 2018-24, 2018-17 I.R.B.
507, the Treasury Department and the IRS
requested comments on the potential ex-
pansion of the scope of the determination
letter program for individually designed
plans.
.03 Section 401(b) of the Code and the
regulations thereunder provide a remedi-
al amendment period during which a plan
may be amended retroactively to comply
with the Code’s qualification require-
ments. Section 1.401(b)-1(e)(3) provides,
in part, that the submission of a determina-
tion letter application extends the remedi-
al amendment period until the expiration
of 91 days after the date a determination

Bulletin No. 2019–20 1183 May 13, 2019
letter is issued. Section 1.401(b)-(1)(f)
provides that the Commissioner also may
extend the remedial amendment period.
.04 Rev. Proc. 2016-37 extended the
remedial amendment period that would
otherwise apply under § 1.401(b)-1 for
certain disqualifying provisions, as de-
scribed in § 1.401(b)-1(b) and Rev.
Proc. 2016-37. Section 5.05(3) of Rev.
Proc. 2016-37 provides that the remedi-
al amendment period for a disqualifying
provision with respect to a change in
qualification requirements (a statutory
change or a change in the requirements
provided in regulations or other guidance,
as noted in section 5.04 of that revenue
procedure) is extended to the end of the
second calendar year that begins after the
issuance of the Required Amendments
List in which the change in qualification
requirements appears. A later date may
apply to a governmental plan (as defined
in § 414(d)), as provided in section 5.06
of Rev. Proc. 2016-37. As provided in
Rev. Proc. 2016-37, the Treasury Depart-
ment and the IRS intend to publish a Re-
quired Amendments List annually. Sec-
tion 5.05(2) of Rev. Proc. 2016-37 also
provides that the remedial amendment
period for a disqualifying provision with
respect to an amendment to an existing
plan (other than a disqualifying provision
with respect to a change in qualification
requirements) is extended to the end of
the second calendar year following the
calendar year in which the amendment is
adopted or effective, whichever is later.
.05 Notice 2017-72, 2017-52 I.R.B.
601, sets forth the 2017 Required
Amendments List. The 2017 Required
Amendments List provides that Decem-
ber 31, 2019, is generally the last day of
the remedial amendment period with re-
spect to a disqualifying provision arising
as a result of a change in qualification re-
quirements that appears on the 2017 Re-
quired Amendments List. December 31,
2019, is also generally the plan amend-
ment deadline for a disqualifying provi-
sion arising as a result of a change in qual-
ification requirements that appears on the
2017 Required Amendments List. A later
date may apply to a governmental plan (as
defined in § 414(d)).
1
.06 Prior to the issuance of Rev. Proc.
2016-37, an annual Cumulative List of
Changes in Retirement Plan Qualification
Requirements (Cumulative List) was is-
sued to identify changes in the qualifica-
tion requirements resulting from changes
in statutes, or from regulations or other
guidance published in the Internal Reve-
nue Bulletin, that were required to be tak-
en into account in a written plan document
submitted for a determination letter.
.07 Section 411(a)(13)(C)(i) defines
the term “applicable defined benefit plan”
as a defined benefit plan under which the
accrued benefit (or any portion thereof) is
calculated as the balance of a hypotheti-
cal account maintained for the participant
or as an accumulated percentage of the
participant’s final average compensation.
Section 411(a)(13)(C)(ii) provides that the
Secretary shall issue regulations which in-
clude in the definition of an applicable de-
fined benefit plan any defined benefit plan
(or any portion of such a plan) which has
an effect similar to an applicable defined
benefit plan. Notice 2007-6, 2007-1 C.B.
272, refers to a plan described in either
§ 411(a)(13)(C)(i) or in regulations or oth-
er guidance issued pursuant to § 411(a)
(13)(C)(ii) as a statutory hybrid plan. Sec-
tion 1.411(a)(13)-1(d)(5) defines a “statu-
tory hybrid plan” as a defined benefit plan
that contains a statutory hybrid benefit
formula.
.08 Section 411(b)(5)(B)(i)(I) pro-
vides, in part, that an applicable defined
benefit plan shall be treated as failing to
meet the requirements of § 411(b)(1)(H)
(which provides that the rate of an em-
ployee’s benefit accrual must not be re-
duced because of the attainment of any
age) unless the terms of the plan provide
that any interest credit (or an equivalent
amount) for any plan year shall be at a rate
that is not greater than a market rate of re-
turn. Final regulations providing rules re-
garding statutory hybrid retirement plans
and transitional amendments to satisfy
the market rate of return rules for statu-
tory hybrid retirement plans were issued
in 2010 (75 Fed. Reg. 64123), 2014 (79
Fed. Reg. 56442), and 2015 (80 Fed. Reg.
70680), herein referred to individually
and collectively as “final hybrid plan reg-
ulations.” The 2014 and 2015 final hybrid
plan regulations appear on the 2017 Re-
quired Amendments List.
.09 Section 411(d)(6) provides, in part,
that a plan does not satisfy § 411 if an
amendment to the plan decreases a partic-
ipant’s accrued benefit.
.10 Notwithstanding the requirements
of § 411(d)(6), § 1.411(b)(5)-1(e)(3)(vi)
permits a plan with an interest crediting
rate that does not comply with the 2010
and 2014 final hybrid plan regulations (a
noncompliant interest crediting rate) to be
amended with respect to benefits that have
already accrued so that its interest crediting
rate complies with the market rate of return
rules of § 411(b)(5)(B)(i) and § 1.411(b)
(5)-1(d). Pursuant to § 1.411(b)(5)-1(e)
(3)(vi)(B)(3), in order to qualify for this
treatment, the amendment had to be adopt-
ed prior to, and effective no later than, the
applicability date of the regulatory market
rate of return rules (generally, the first day
of the first plan year that began on or after
January 1, 2017, with a delayed applicabil-
ity date for collectively bargained plans).
SECTION 3. EXPANSION OF
DETERMINATION LETTER
PROGRAM
The Treasury Department and the IRS
received numerous comments in response
to the request for comments in Notice
2018-24. After consideration of the com-
ments, the Treasury Department and the
IRS have determined that the determina-
tion letter program will be expanded to
permit plan sponsors to submit (i) deter-
mination letter applications for individ-
ually designed statutory hybrid plans, as
defined in § 1.411(a)(13)-1(d)(5), during
the 12-month period beginning Septem-
ber 1, 2019, and ending August 31, 2020,
and (ii) determination letter applications
for certain individually designed Merged
Plans (as defined in section 5.01(2) of this
revenue procedure) on an ongoing basis.
Sections 6, 7, and 8 of this revenue pro-
cedure provide for a limited extension of
the remedial amendment period and spe-
cial sanction structures applicable to plans
submitted for a determination letter pursu-
ant to this revenue procedure.
1
Notice 2018-91, 2018-50 I.R.B. 985, sets forth the 2018 Required Amendments List. There were no changes in qualification requirements listed on the 2018 Required Amendments List.

May 13, 2019 1184 Bulletin No. 2019–20
SECTION 4. STATUTORY HYBRID
PLANS
.01 Expansion of Determination Letter
Program for Statutory Hybrid Plans.
(1) In general. The IRS will accept a de-
termination letter application for an indi-
vidually designed statutory hybrid plan, as
defined in § 1.411(a)(13)-1(d)(5), during
the 12-month period beginning Septem-
ber 1, 2019, and ending August 31, 2020
(statutory hybrid plan submission period).
(2) Applicable procedures. The proce-
dures relating to the submission of determi-
nation letter applications for individually
designed plans set forth in Rev. Proc. 2019-
4, 2019-1 I.R.B. 146 (and its annual suc-
cessors), and Rev. Proc. 2016-37 apply to
determination letter applications submitted
pursuant to this section 4, except as other-
wise provided by this revenue procedure.
(3) Scope of plan review. The IRS’s
review of individually designed statutory
hybrid plans that are submitted for a de-
termination letter pursuant to this revenue
procedure will be based on the 2017 Re-
quired Amendments List (Notice 2017-
72). The review will also take into account
all Required Amendments Lists and Cu-
mulative Lists issued prior to 2016.
SECTION 5. MERGED PLANS
.01 Definitions for Guidance Related to
Merged Plans.
(1) Plan Merger. The term “Plan Merg-
er” means a merger or consolidation, as
described in § 1.414(l)-1(b)(2), that com-
bines two or more plans maintained by
previously Unrelated Entities into a single
individually designed plan, and that oc-
curs in connection with a corporate merg-
er, acquisition, or other similar business
transaction among Unrelated Entities that
each maintained its own plan or plans pri-
or to the Plan Merger.
(2) Merged Plan. The term “Merged
Plan” means a plan that results from the
merger or consolidation of two or more
plans into a single individually designed
plan pursuant to a Plan Merger.
(3) Unrelated Entities. The term “Un-
related Entities” means entities that are
not members of the same controlled group
under § 414(b), the same set of trades or
businesses under common control under §
414(c), or members of the same affiliated
service group under § 414(m).
(4) Date of a Corporate Merger, Acqui-
sition, or Other Similar Business Trans-
action. The “Date of a Corporate Merger,
Acquisition, or Other Similar Business
Transaction” is the effective date of the
transaction as evidenced by a corporate
board resolution or written documentation
signed and dated by persons duly autho-
rized to represent the entities involved.
(5) Date of the Plan Merger. The “Date
of the Plan Merger” is the effective date
of the Plan Merger as evidenced by (a) a
corporate board resolution or written doc-
umentation signed and dated by persons
duly authorized to represent the entities
involved, or (b) a plan amendment.
.02 Expansion of Determination Letter
Program for Merged Plans.
(1) In general. Beginning Septem-
ber 1, 2019, the IRS will accept a determi-
nation letter application that satisfies the
conditions set forth in section 5.02(2) with
respect to a Merged Plan. Determination
letter applications submitted for a Merged
Plan will be accepted on an ongoing basis
and are not limited to a specific submis-
sion period.
(2) Eligible plans. A determination let-
ter application for a Merged Plan satisfies
the conditions of this section 5.02(2) if the
following requirements are satisfied:
(a) The Date of the Plan Merger occurs
no later than the last day of the first plan
year that begins after the plan year that
includes the Date of a Corporate Merger,
Acquisition, or Other Similar Business
Transaction between Unrelated Entities,
and
(b) A determination letter application
for the Merged Plan is submitted with-
in a period beginning on the Date of the
Plan Merger and ending on the last day of
the first plan year of the Merged Plan that
begins after the Date of the Plan Merger
(Merged Plan submission period).
.03 Applicable Procedures. The proce-
dures relating to the submission of deter-
mination letter applications for individu-
ally designed plans set forth in Rev. Proc.
2019-4 (and its annual successors) and
Rev. Proc. 2016-37 apply to determina-
tion letter applications submitted pursuant
to this section 5, except as otherwise pro-
vided by this revenue procedure.
.04 Scope of Plan Review. The IRS’s
review of individually designed Merged
Plans that are submitted for a determi-
nation letter pursuant to this revenue
procedure will be based on the Required
Amendments List that was issued during
the second full calendar year preceding
the submission of the determination let-
ter application. The review will also take
into account all previously issued Re-
quired Amendments Lists and Cumula-
tive Lists.
SECTION 6. EXTENSION OF THE
REMEDIAL AMENDMENT PERIOD
.01 Extension of Remedial Amendment
Period. With respect to a plan submitted
for a determination letter pursuant to this
revenue procedure, any remedial amend-
ment period that is open as of the begin-
ning of the applicable submission period
defined in section 4.01(1) or 5.02(2)(b)
of this revenue procedure is extended to
the end of such applicable submission
period. Section 1.401(b)-1(e)(3) (which
provides that the submission of a deter-
mination letter application extends the
remedial amendment period until the ex-
piration of 91 days after the date a deter-
mination letter is issued) will continue to
apply.
.02 No Relief Provided Under §
411(d)(6). Section 1.411(b)(5)-1(e)(3)
(vi) provides relief from the anti-cutback
requirements of § 411(d)(6) with respect
to the modification of a plan’s interest
crediting rate under certain circumstanc-
es. However, pursuant to § 1.411(b)(5)-
1(e)(3)(vi)(B)(3), that relief applies only
to plan amendments that were adopted
prior to, and effective no later than, the
applicability date of the regulatory mar-
ket rate of return rules (generally, the
first day of the first plan year that begins
on or after January 1, 2017, with a de-
layed applicability date for collectively
bargained plans). Although this revenue
procedure extends the remedial amend-
ment period applicable to statutory hy-
brid plans that are submitted for a deter-
mination letter pursuant to this revenue
procedure, it does not provide additional
relief from the anti-cutback requirements
of § 411(d)(6).

Bulletin No. 2019–20 1185 May 13, 2019
SECTION 7. APPLICABLE
SANCTIONS – STATUTORY
HYBRID PLANS
.01 In General. A plan sponsor that has
applied for a determination letter pursuant
to this revenue procedure with respect to a
statutory hybrid plan that has a plan docu-
ment failure, as defined in section 5.01(2)
(a) of Rev. Proc. 2019-19, 2019-19 I.R.B.
1086, (which includes the failure to adopt
an amendment to correct a disqualifying
provision within the applicable remedial
amendment period), must amend the plan
to comply with applicable qualification
requirements. In addition, except as pro-
vided in section 7.02 of this revenue pro-
cedure, the plan sponsor must pay the ap-
plicable sanction described in section 7.03
or 7.04 of this revenue procedure, and en-
ter into a closing agreement with the IRS.
.02 No Sanctions for Plan Document
Failures Related to Final Hybrid Plan
Regulations. The Treasury Department
and the IRS are mindful that the IRS’s
scope of review during a statutory hybrid
plan’s most recent remedial amendment
cycle did not include all the provisions re-
lated to the final hybrid plan regulations
under § 1.411(a)(13)-1 and § 1.411(b)(5)-
1. As a result, plan sponsors of statutory
hybrid plans did not have the opportunity
to have their plans reviewed for all provi-
sions related to those regulations. Accord-
ingly, the IRS will not impose a sanction
for any plan document failure with re-
spect to a plan provision required to meet
the requirements of § 1.411(a)(13)-1 and
§ 1.411(b)(5)-1 that is discovered by the
IRS in its review of a plan submitted for a
determination letter pursuant to this reve-
nue procedure.
.03 Special Sanction Structure for Plan
Document Failures Unrelated to Final
Hybrid Plan Regulations. This section
7.03 sets forth a sanction structure that ap-
plies to a statutory hybrid plan submitted
for a determination letter pursuant to this
revenue procedure that has a plan docu-
ment failure other than a plan document
failure with respect to a plan provision
that is required to meet the requirements
of § 1.411(a)(13)-1 or § 1.411(b)(5)-1,
provided the conditions in section 7.03(1)
(a) or (b) of this revenue procedure are
satisfied. The amount of the sanction is
equal to the applicable Employee Plans
Voluntary Compliance Resolution System
(EPCRS) Voluntary Correction Program
user fee that would have applied had the
plan sponsor identified the failure and
submitted the plan for consideration under
the Voluntary Correction Program.
(1) Conditions for special sanction
structure.
(a) The amendment that creates the
failure (without regard to whether that
amendment was required to be adopted)
was adopted timely and in good faith with
the intent of maintaining the qualified sta-
tus of the plan; or
(b) In the case of an amendment re-
quired because of a change in qualifica-
tion requirements, the plan sponsor rea-
sonably and in good faith determined that
no amendment was required because the
qualification change does not impact pro-
visions of the written plan document.
(2) Other rules for special sanction
structure.
(a) The IRS will make the final determi-
nation in all cases as to whether an amend-
ment was adopted in good faith with the
intent of maintaining the qualified status
of the plan, or whether a plan sponsor rea-
sonably and in good faith determined that
no amendment was required.
(b) If the conditions of section 7.03(1)
(a) or (b) of this revenue procedure are not
satisfied, the sanction set forth in section
7.04 will apply.
.04 General Sanction Structure Un-
der EPCRS. This section 7.04 sets forth
a general sanction structure that applies
to a statutory hybrid plan submitted for a
determination letter pursuant to this rev-
enue procedure that (1) has a plan docu-
ment failure other than a plan document
failure with respect to a plan provision
that is required to meet § 1.411(a)(13)-1
or § 1.411(b)(5)-1 and (2) does not satis-
fy the conditions of section 7.03(1)(a) or
(b) of this revenue procedure. The amount
of the sanction is equal to the applicable
sanction amount set forth in section 14.04
of Rev. Proc. 2019-19. Section 14.04 of
Rev. Proc. 2019-19 provides for a sanction
for certain plan document failures that are
discovered by the IRS during the determi-
nation letter process that is equal to 150%
or 250% (depending on the duration of
the failure) of the applicable user fee that
would apply to the plan had it been sub-
mitted under the EPCRS Voluntary Cor-
rection Program. See Appendix A of Rev.
Proc. 2019-4 (and its annual successors)
for the applicable Voluntary Correction
Program user fee.
SECTION 8. APPLICABLE
SANCTIONS – MERGED PLANS
.01 In General. A plan sponsor that has
applied for a determination letter pursuant
to this revenue procedure with respect to
a Merged Plan that has a plan document
failure, as defined in section 5.01(2)(a) of
Rev. Proc. 2019-19 (which includes the
failure to adopt an amendment to correct
a disqualifying provision within the appli-
cable remedial amendment period), must
amend the plan to comply with applicable
qualification requirements. In addition,
except as provided in section 8.02 of this
revenue procedure, the plan sponsor must
pay the applicable sanction as described in
section 8.03 or 8.04 of this revenue proce-
dure, and enter into a closing agreement
with the IRS.
.02 No Sanctions for Plan Provisions
Included to Effectuate the Plan Merger.
For Merged Plans submitted for a determi-
nation letter pursuant to this revenue pro-
cedure, the IRS will not impose a sanction
for any plan document failure with respect
to a plan provision included to effectuate
the Plan Merger.
.03 Special Sanction Structure for Plan
Provisions Other Than Those Included to
Effectuate the Plan Merger. This section
8.03 sets forth a sanction structure that
applies to a Merged Plan submitted for a
determination letter pursuant to this rev-
enue procedure that has a plan document
failure other than a plan document failure
with respect to a plan provision included
to effectuate the Plan Merger, provided
the conditions in section 8.03(1)(a) or (b)
of this revenue procedure are satisfied.
The amount of the sanction is equal to the
applicable EPCRS Voluntary Correction
Program user fee that would have applied
had the plan sponsor identified the failure
and submitted the plan for consideration
under the Voluntary Correction Program.
(1) Conditions for special sanction
structure.
(a) The amendment that creates the
failure (without regard to whether that
amendment was required to be adopted)
was adopted timely and in good faith with

May 13, 2019 1186 Bulletin No. 2019–20
the intent of maintaining the qualified sta-
tus of the plan; or
(b) In the case of an amendment re-
quired because of a change in qualifica-
tion requirements, the plan sponsor rea-
sonably and in good faith determined that
no amendment was required because the
qualification change does not impact pro-
visions of the written plan document.
(2) Other rules for special sanction
structure.
(a) The IRS will make the final determi-
nation in all cases as to whether an amend-
ment was adopted in good faith with the
intent of maintaining the qualified status
of the plan, or whether a plan sponsor rea-
sonably and in good faith determined that
no amendment was required.
(b) If the conditions of section 8.03(1)
(a) or (b) of this revenue procedure are not
satisfied, the sanction set forth in section
8.04 will apply.
.04 General Sanction Structure Un-
der EPCRS. This section 8.04 sets forth a
general sanction structure that applies to
a Merged Plan submitted for a determina-
tion letter pursuant to this revenue proce-
dure that (1) has a plan document failure
other than a plan document failure with
respect to a plan provision included to ef-
fectuate the Plan Merger and (2) does not
satisfy the conditions of section 8.03(1)
(a) or (b) of this revenue procedure. The
amount of the sanction is equal to the ap-
plicable sanction amount set forth in sec-
tion 14.04 of Rev. Proc. 2019-19. Section
14.04 of Rev. Proc. 2019-19 provides for
a sanction for certain plan document fail-
ures that are discovered by the IRS during
the determination letter process that is
equal to 150% or 250% (depending on the
duration of the failure) of the applicable
user fee that would apply to the plan had
it been submitted under the EPCRS Vol-
untary Correction Program. See Appendix
A of Rev. Proc. 2019-4 (and its annual
successors) for the applicable Voluntary
Correction Program user fee.
SECTION 9. CONTINUED
CONSIDERATION OF COMMENTS
The Treasury Department and the IRS
will continue to consider comments re-
ceived in response to Notice 2018-24 and
any other comments received regarding
additional situations in which the submis-
sion of a determination letter application
may be appropriate. Also, the Treasury
Department and the IRS will continue to
request, on a periodic basis, comments on
additional situations in which the submis-
sion of a determination letter application
may be appropriate.
SECTION 10. EFFECT ON OTHER
DOCUMENTS
This revenue procedure amplifies and
modifies Rev. Proc. 2016-37.
SECTION 11. EFFECTIVE DATE
This revenue procedure is effective
September 1, 2019.
SECTION 12. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Angelique Carrington of the
Office of Associate Chief Counsel (Em-
ployee Benefits, Exempt Organizations,
and Employment Taxes). For further in-
formation regarding this revenue proce-
dure, contact Ms. Carrington at (202) 317-
4148 (not a toll-free number).

Bulletin No. 2019–20 i May 13, 2019
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion. It
is not used where a position in a prior rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cas-
es in litigation, or the outcome of a Ser-
vice study.
Abbreviations
The following abbreviations in current use
and formerly used will appear in material
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.

May 13, 2019 ii Bulletin No. 2019–20
Numerical Finding List
1
Bulletin 2019–17
Action on Decision:
2019-1, 2019-08 I.R.B. 569
Announcements:
2019-1, 2019-06 I.R.B. 566
2019-2, 2019-12 I.R.B. 910
2019-3, 2019-15 I.R.B. 965
Notices:
2019-01, 2019-02 I.R.B. 275
2019-02, 2019-02 I.R.B. 281
2019-03, 2019-03 I.R.B. 350
2019-04, 2019-02 I.R.B. 282
2019-05, 2019-02 I.R.B. 283
2019-06, 2019-03 I.R.B. 353
2019-07, 2019-09 I.R.B. 740
2019-08, 2019-03 I.R.B. 354
2019-09, 2019-04 I.R.B. 403
2019-10, 2019-13 I.R.B. 913
2019-11, 2019-05 I.R.B. 430
2019-13, 2019-08 I.R.B. 580
2019-16, 2019-10 I.R.B. 763
2019-17, 2019-12 I.R.B. 907
2019-18, 2019-13 I.R.B. 915
2019-19, 2019-12 I.R.B. 907
2019-20, 2019-14 I.R.B. 927
2019-21, 2019-14 I.R.B. 927
2019-22, 2019-14 I.R.B. 931
2019-23, 2019-15 I.R.B. 941
2019-24, 2019-14 I.R.B. 932
2019-25, 2019-15 I.R.B. 942
2019-26, 2019-15 I.R.B. 943
2019-28, 2019-18 I.R.B. 1077
2019-30, 2019-20 I.R.B. 1180
2019-31, 2019-20 I.R.B. 1181
Proposed Regulations:
REG-104259-18, 2019-02 I.R.B. 300
REG-104352-18, 2019-03 I.R.B. 357
REG-106089-18, 2019-05 I.R.B. 431
REG-134652-18, 2019-09 I.R.B. 747
REG-141739-08, 2019-09 I.R.B. 757
REG-121694-16, 2019-16 I.R.B. 1032
REG-135671-17, 2019-16 I.R.B. 1035
REG-103083-18, 2019-17 I.R.B. 1046
REG-113943-17, 2019-17 I.R.B. 1067
REG-143686-07, 2019-17 I.R.B. 1072
REG-124627-11, 2019-17 I.R.B. 1073
Revenue Procedures:
2019-1, 2019-01 I.R.B. 1
2019-2, 2019-01 I.R.B. 106
Revenue Procedures:—Continued
2019-3, 2019-01 I.R.B. 130
2019-4, 2019-01 I.R.B. 146
2019-5, 2019-01 I.R.B. 230
2019-6, 2019-02 I.R.B. 284
2019-7, 2019-01 I.R.B. 268
2019-8, 2019-03 I.R.B. 347
2019-9, 2019-02 I.R.B. 293
2019-10, 2019-02 I.R.B. 296
2019-11, 2019-09 I.R.B. 742
2019-12, 2019-04 I.R.B. 401
2019-13, 2019-09 I.R.B. 744
2019-14, 2019-15 I.R.B. 948
2019-15, 2019-14 I.R.B. 939
2019-17, 2019-17 I.R.B. 1045
2019-18, 2019-18 I.R.B. 1077
2019-20, 2019-20 I.R.B. 1182
Revenue Rulings:
2019-03, 2019-02 I.R.B. 272
2019-04, 2019-07 I.R.B. 567
2019-05, 2019-11 I.R.B. 766
2019-06, 2019-14 I.R.B. 919
2019-07, 2019-10 I.R.B. 761
2019-08, 2019-14 I.R.B. 923
2019-09, 2019-14 I.R.B. 925
2019-10, 2019-16 I.R.B. 1010
2019-11, 2019-17 I.R.B. 1041
2019-13, 2019-20 I.R.B. 1179
Treasury Decisions:
9844, 2019-11 I.R.B. 781
9845, 2019-08 I.R.B. 570
9846, 2019-09 I.R.B. 583
9847, 2019-09 I.R.B. 670
9848, 2019-11 I.R.B. 897
9850, 2019-12 I.R.B. 904
9852, 2019-16 I.R.B. 1010
9853, 2019-16 I.R.B. 1026
9855, 2019-17 I.R.B. 1042
9854, 2019-18 I.R.B. 1075
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018.

Bulletin No. 2019–20 iii May 13, 2019
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2019–20
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018.

Internal Revenue Service
Washington, DC 20224
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