Internal Revenue Bulletin 2013-28 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 201
3-28
July 8, 2013
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2013–15, page 47.
Federal rates; adjusted federalrates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, and other sections of the
Code, tables set forth the rates for July 2013.
Rev. Proc. 2013–32, page 55.
This revenue procedure restricts the scope of letter rulings
that address issues with respect to transactions under sec-
tions 332, 351, 355, and 1036, and reorganizations within
the meaning of section 368 of the Code. Pursuant to this rev-
enue procedure, the Service will no longer rule on whether a
transaction qualifies for nonrecognition treatment under sec-
tion 332, 351, 355, or 1036, or on whether a transaction con-
stitutes a reorganization within the meaning of section 368, or
on the various tax consequences resulting from the application
of those Code sections. The Service will, however, rule on sig-
nificant issues (defined in this revenue procedure) presented in
transactions described in those Code sections. Rev. Procs.
2013–1 and 2013–3 are amplified and modified. Rev. Procs.
81-60, 83-59, 86-42, 90-52, and 96-30 are modified. Rev.
Proc. 2003–48 is obsolete in part and superseded in part.
The Rev. Proc. 2009–25 pilot program is discontinued.
EXCISE TAX
T.D. 9621, page 49.
These final regulations provide guidance on the excise tax im-
posed on sales of indoor tanning services.
Finding Lists begin on page ii.

The IRS Mission
Provide Americ
a’s taxpayers top-quality service by helping
them understa
nd and meet their tax responsibilities and en-
force the law wi
th 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 poli
cy of the Service to publish in the Bulletin all sub-
stantive ru
lings necessary to promote a uniform application of
the tax laws
, including all rulings that supersede, revoke, mod-
ify, or amen
d any of those previously published in the Bulletin.
All publish
ed rulings apply retroactively unless otherwise indi-
cated. Pro
cedures relating solely to matters of internal man-
agement ar
e 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 rulings 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, Leg-
islation 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 Secre-
tary (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 cont
ents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
July 8, 20132013–28 I.R.B.

Part I. Rulings
and Decisions Under the Internal Revenue Code
of 1986
Section 42.—L
ow-Income
Housing Credi
t
The adjusted a
pplicable federal short-term, mid-
term, and long
-term rates are set forth for the month
of July 2013. S
ee Rev. Rul. 2013-15, page 47.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term rates
are set forth for the month of July 2013. See Rev.
Rul. 2013-15, page 47.
Section 382.—Limitation
on Net Operating Loss
Carryforwa
rds and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of July 2013. See Rev. Rul.
2013-15, page 47.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
Section 468.—Special
Rules for Mining and Solid
Waste
Reclamation and
Closi
ng Costs
The ad
justed applicable federal short-term, mid-
term,
and long-term rates are set forth for the month
of Jul
y 2013. See Rev. Rul. 2013-15, page 47.
Section 482.—
Allocation
of Income and D
eductions
Among Taxpaye
rs
Federal short
-term, mid-term, and long-term rates
are set forth f
or the month of July 2013. See Rev.
Rul. 2013-15
,page47.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term rates
are set forth for the month of July 2013. See Rev.
Rul. 2013-15, page 47.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
Section 1274.—Determi-
nation of Issue Price in the
Case of Certain Debt Instru-
ments Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Federal rates; adjusted federal rates; ad-
justed federal long-term rate and the long-
term exempt rate. For purposes of sections
382, 642, 1274
, 1288, and other sections of
the Code, tabl
es set forth the rates for July
2013.
Rev. Rul. 2013
–15
This revenue
ruling provides vari-
ous prescrib
ed rates for federal income
tax purposes
for July 2013 (the current
month). Tabl
e 1 contains the short-term,
mid-term, an
d long-term applicable fed-
eral rates (
AFR) for the current month
for purpose
s of section 1274(d) of the
Internal Re
venue Code. Table 2 contains
the short-t
erm, mid-term, and long-term
adjusted a
pplicable federal rates (adjusted
AFR) for th
e current month for purposes
of section
1288(b). Table 3 sets forth the
adjusted f
ederal long-term rate and the
long-ter
m tax-exempt rate described in
section 3
82(f). Table 4 contains the ap-
propriat
e percentages for determining the
low-inco
me housing credit described in
section 4
2(b)(1) for buildings placed in
service
during the current month. How-
ever, un
der section 42(b)(2), the applicable
percent
age for non-federally subsidized
new buil
dings placed in service after July
30, 2008
, with respect to housing credit
dollar
amount allocations made before
Januar
y 1, 2014, shall not be less than 9%.
Table 5
contains the federal rate for deter-
mining
the present value of an annuity, an
intere
st for life or for a term of years, or
arema
inder or a reversionary interest for
purpo
ses of section 7520. Finally, Table 6
conta
ins the blended annual rate for 2013
for pu
rposes of section 7872.
2013–28 I.R.B.47July 8, 2013

REV. RUL. 2013–15 TABLE 1
Applicable Federal Rates (AFR) for July 2013
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.23%.23%.23%.23%
110% AFR
.25%.25%.25%.25%
120% AFR.28%.28%.28%.28%
130% AFR.30%.30%.30%.30%
Mid-term
AFR1.22%1.22%1.22%1.22%
110% AFR1.34%1.34%1.34%1.34%
120% AFR1.47%1.46%1.46%1.46%
130% AFR1.60%
1.59%1.59%1.58%
150% AFR
1.84%1.83%1.83%1.82%
175% AFR2.15%
2.14%2.13%2.13%
Long-term
AFR2.80%2.78%2.77%2.76%
110% AFR3.08%3.06%
3.05%
3.04%
120% AFR3.37%3.34%3.33%3.32%
130% AFR3.64%3.61%
3.59%3.58%
REV. RUL. 2013–15 TABLE 2
Adjusted AFR for July 2013
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted
AFR
.23%.23%.23%.23%
Mid-term adjusted AFR1.21%1.21%1.21%1.21%
Long-term adjusted
AFR
2.80%2.78%2.77%2.76%
REV. RUL. 2013–15 TABLE 3
Rates Under Section 382 for July 2013
Adjusted federal long-term rate for the current month2.80%
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.)2.80%
REV. RUL. 2013–15 TABLE 4
Appropriate Percentages UnderSection 42(b)(1) for July 2013
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July
30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2014, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.46%
Appropriate percentage for the 30% present value low-income housing credit3.20%
July 8, 2013482013–28 I.R.B.

REV. RUL. 2013–15 TABLE 5
Rate Under Section 7520 for July 2013
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 interest1.4%
REV. RUL. 2013–15 TABLE 6
Blended Annual Rate for 2013
Section 7872(e)(2) blended annual rate for 2013.22%
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 July 2013. See Rev. Rul. 2013-15, page 47.
Section 5000B.—Imposition
of a Tax on Indoor Tanning
Services
TD 9621
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Parts 40, 49, and 602
Indoor Tanning Services;
Excise Taxes
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations and removal
of temporary regulations.
SUMMARY: This document contains final
regulations on the indoor tanning services
excise tax imposed by the Patient Protec-
tion and Affordable Care Act. These fi-
nal regulations affect persons that use, pro-
vide, or pay for indoor tanning services.
DATES:Effective Date:These regulations
are effective on June 11, 2013.
Applicability Date:For dates of appli-
cability, see §§40.0–1(d), 40.6302(c)–1(f),
and 49.5000B–1(h).
FOR FURTHER INFORMATION
CONTACT: Michael H. Beker or
Natalie A. Payne, at (202) 622–3130 (not
a toll-free number).
SUPPLEMENTARY INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in these final regulations has been
reviewed and approved by the Office of
Management and Budget under control
number 1545–2177. The collection of
information in these final regulations is in
§49.5000B–1. The information is required
to be maintained by the provider of indoor
tanning services to accurately calculate the
tax on indoor tanning services when those
services are offered with other goods and
services.
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 displays a valid
control number.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by 26 U.S.C. 6103.
Background
This document amends the Excise Tax
Procedural Regulations (26 CFR part 40)
and the Facilities and Services Excise Tax
Regulations (26 CFR part 49) under sec-
tion 5000B of the Internal Revenue Code
(Code). Section 5000B was added to the
Code by section 10907 of the Patient Pro-
tection and Affordable Care Act, Public
Law 111–148 (124 Stat. 119 (2010)), to
impose an excise tax on indoor tanning
services. On June 15, 2010, temporary
regulations relating to this topic and a
notice of proposed rulemaking cross-ref-
erencing the temporary regulations were
published in theFederal Register(TD
9486, 75 FR 33683; REG–112841–10, 75
FR 33740) (2010 regulations). Written
and electronic comments were received
and a public hearing was held on October
11, 2011. All comments were considered
and are available for public inspection at
http://www.regulations.gov. After consid-
ering the written comments and comments
made at the public hearing, the proposed
regulations are adopted as final regula-
tions by this Treasurydecision and the
corresponding temporary regulations are
removed.
Public comments on the 2010 regula-
tions identified two issues that the IRS and
the Treasury Department will study fur-
ther and on which the IRS and the Trea-
sury Department request additional com-
ments. Those issues, the treatment of bun-
dled services and undesignated payment
cards, are discussed later in this pream-
ble. Comments on those issues should be
submitted in writing by October 9, 2013,
and can be mailed to the Office of As-
sociate Chief Counsel (Passthroughs and
Special Industries), Re: REG–112841–10,
CC:PSI:B7, Room 5314, 1111 Constitu-
tion Avenue NW., Washington, DC 20224.
All comments received will be available
for public inspection athttp://www.regula-
tions.gov (IRS REG–112841–10).
Summary of Comments
Qualified Physical Fitness Facilities.
Commenters questioned the exception
for Qualified Physical Fitness Facilities
(QPFFs) in the 2010 regulations.
The 2010 regulations exempt from the
tax any membership fee paid to a QPFF
that includes access to indoor tanning ser-
vices. In a QPFF, taking into consideration
2013–28 I.R.B.49July 8, 2013

all of the facts and circumstances, the pre-
dominant business or activity of the facil-
ity is to serve as a physical fitness facility.
The 2010 regulations limit the definition of
a QPFF to a business that does not charge
separately for indoor tanning services, of-
fer such services to the general public, or
offer different membership fee rates based
on access to indoor tanning services.
Commenters stated that an exception
for QPFFs does not appear in section
5000B and suggested that there is no
compelling reason to differentiate these
facilities from other indoor tanning ser-
vice facilities. Commenters argued that
while other providers of bundled ser-
vices must use a complicated method of
determining the amount attributable to
indoor tanning services (as described in
§49.5000B–1T(d)(3) of the 2010 regula-
tions), QPFFs are exempt from the tax
even though they provide the same indoor
tanning services. Thus, these commenters
suggested, the exception for QPFFs cre-
ates an unfair competitive advantage for
some providers of indoor tanning services
over others, and should not be included in
the final regulations.
The final regulations do not adopt this
suggestion. Access to indoor tanning ser-
vices is incidental to a QPFF’s predom-
inant business or activity. Customers of
a QPFF typically pay a monthly fee in
exchange for access to all equipment in
the QPFF, including any indoor tanning
equipment. Requiring a QPFF to allo-
cate its customers’ monthly membership
fees among tanning and non-tanning ser-
vices under such an arrangement would
be burdensome and difficult to administer.
In contrast, non-QPFF providers of bun-
dled goods and services typically offer in-
door tanning services to customers as part
of the purchase of a package of specific
goods or services. This generally allows
the provider to determine the portion of the
purchase price that relates to the use of in-
door tanning services by the customer and
allocate the appropriate portion of the pur-
chase price to those services.
Free indoor tanning services; bonus
points. Commenters requested guidance
on the application of the tax to free indoor
tanning services and indoor tanning ser-
vices that are sold at reduced rates.
The final regulations provide that the
section 5000B tax only applies if an
amount is paid for indoor tanning services.
If services are provided at a reduced rate,
the tax applies to the amount actually paid
for the services. See Rev. Rul. 84–12
(1984–1 CB 211) and the rulings cited
therein. Also consistent with Rev. Rul.
84–12, the final regulations do not apply
the tax to indoor tanning services that are
obtained by redemption of “bonus points”
through a loyalty program or similar pro-
gram. In the case of promotions that
entitle a customer to a “free” tan with the
purchase of a certain number of tans, the
amount paid for the purchased tans reflects
a reduced price for all of the tans rather
than a package of tans at full price coupled
with a “free” purchased tan. Thus, the tax
is imposed on the purchase of the package
of tans rather than on the redemption of
the additional tan.
Bundled goods and services.Ifa
provider (other than a QPFF) sells bundled
services in which access to indoor tan-
ning services (in a specified or unlimited
amount) over a period of time is bundled
with other goods and services, the 2010
regulations set out a formula to determine
the amount reasonably attributable to in-
door tanning services.
Commenters noted that there are no
commercially available point-of-sale soft-
ware programs that automatically calcu-
late the tax on the sale of indoor tanning
services that are bundled with other goods
and services. Thus, providers must man-
ually calculate the tax on these types of
sales, a process that the commenters said
is time consuming, expensive, and prone
to error.
The final regulations do not change the
rules for bundled goods and services. The
statute imposes the tax on indoor tanning
services; if those services are bundled with
other goods and services, the provider
must determine the amount of the pay-
ment for the bundled goods and services
that is reasonably attributable to indoor
tanning services. The 2010 regulations
set forth a reasonable method for mak-
ing this determination, which is retained
with minor clarifications in the final reg-
ulations. However, the final regulations
also authorize the Treasury Department
and the IRS to issue future guidance to
provide additional options for making this
determination. The Treasury Department
and the IRS request comments on other
reasonable methods for determining the
amount of a payment for bundled goods
and services that is reasonably attributable
to indoor tanning services.
Undesignated payment cards.The
2010 regulations define anundesignated
payment cardas a gift certificate, gift card,
or similar item that can be redeemed for
goods or services that may, but do not nec-
essarily, include indoor tanning services.
Under the 2010 regulations, the tax is not
imposed on the purchase of these cards;
rather, the tax is imposed only when the
card is redeemed specifically to pay for
indoor tanning service.
Commenters noted that, in practice, a
provider can collect the tax only when the
card is bought and not when the card is re-
deemed for indoor tanning service. Thus,
the commenters suggested that the tax be
imposed on the purchase of an undesig-
nated payment card. Providers could ei-
ther estimate how much of the card will be
used for indoor tanning service in the fu-
ture or collect tax on the entire purchase
price.
The final regulations do not adopt this
suggestion. However, the Treasury De-
partment and the IRS welcome comments
on this issue. The final regulations au-
thorize the Treasury Department and the
IRS to issue future guidance to provide
additional options for administering the
tax with respect to undesignated payment
cards.
Form 720. The temporary regulations
require the tax to be reported and paid
quarterlyonForm720,Quarterly Federal
Excise Tax Return. Commenters suggested
that Form 720 is too complex or burden-
some for the average provider to complete
and file. These commenters request that
the IRS issue a special tax return form
specifically and exclusively for reporting
the section 5000B tax.
The final regulations do not adopt this
suggestion. Form 720 is the standard form
used to report many excise taxes, includ-
ing the other types of excise taxes col-
lected from a customer upon the purchase
of services, such as the taxes on com-
munications services and transportation of
persons and property by air. In addition,
the Treasury Department and the IRS be-
lieve that creating a new form would add
unnecessary complexity. For more infor-
mation about reporting requirements, see
§40.6011(a)–1(a).
July 8, 2013502013–28 I.R.B.

Additional Clarification of 2010
Regulations
Membership and enrollment fees.The
final regulations clarifythatthetaxis
imposed on amounts paid for prepaid
monthly membership and enrollment fees
to a provider of indoor tanning services,
other than a QPFF, even if a member does
not use any indoor tanning services during
the period to which the fee relates.
Some providers offer monthly member-
ship programs through which customers
receive a number of tanning sessions at
a lower cost than would be charged for
each session individually. Some of these
providers charge customers an enrollment
fee when the customers join a membership
program. Typically, the customer pays
the enrollment fee before paying the first
monthly membership charge.
Some providers also impose fees on
their customers to allow the customer to
skip one or more months of membership
dues without being charged an enrollment
fee when the customer restarts the monthly
membership. Amounts paid to a provider
that temporarily suspend a periodic mem-
bership program are amounts paid for in-
door tanning services. Because payment
of these fees allows the customer to receive
indoor tanning services at reduced prices,
the final regulations clarify that these fees
are subject to the section 5000B tax as
amounts paid for indoor tanning services.
Availability of IRS Documents
The IRS revenue ruling cited in this pre-
amble is published in the Internal Revenue
Cumulative Bulletin and is available from
the Superintendent of Documents, P.O.
Box 371954, Pittsburgh PA, 15250–7954.
Special Analyses
It has been determined that this Trea-
sury decision is not a significant regula-
tory action as defined in Executive Order
12866, as supplemented by Executive Or-
der 13563. Therefore, a regulatory assess-
ment is not required. It also has been de-
termined that section 553(b) of the Admin-
istrative Procedure Act (5 U.S.C. chapter
5) does not apply to these regulations. It
is hereby certified that these regulations
will not have a significant economic im-
pact on a substantial number of small en-
tities. This certification is based on the
fact that these regulations are designed to
accommodate the recordkeeping methods
currently used by small entities that pro-
vide indoor tanning services. The regu-
lations merely implement the tax imposed
by section 5000B of the Code, and section
6001 of the Code already requires taxpay-
ers to keep books and records sufficient to
show whether or not they are liable for tax.
The information necessary to prepare these
records is readily available to providers,
and this recordkeeping will take little ad-
ditional time to complete. Accordingly, a
Regulatory Flexibility Analysis under the
Regulatory Flexibility Act (5 U.S.C. chap-
ter 6) is not required. Pursuant to section
7805(f) of the Code, the notice of proposed
rulemaking that preceded these regulations
was submitted to the Chief Counsel for
Advocacy of the Small Business Adminis-
tration for comment on its impact on small
business, and no comments were received.
Drafting Information
The principal author of these regula-
tions is Michael H. Beker, Office of the
Associate Chief Counsel (Passthroughs
and Special Industries). However, other
personnel from the IRS and the Treasury
Department participated in their develop-
ment.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR parts 40, 49, and
602 are amended as follows:
PART 40—EXCISE TAX
PROCEDURAL REGULATIONS
Paragraph 1. The authority citation for
part 40 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
Par. 2. Section 40.0–1 is amended as
follows:
1. Paragraph (a), second sentence, is
amended by removing the language “and
39” and adding “39, and 49” in its place.
2. Paragraph (a), third sentence, is
amended by removing the language “and
chapter 39 to taxes imposed on regis-
tration-required obligations” and adding
“chapter 39 to taxes imposed on regis-
tration-required obligations; and chapter
49 to taxes imposed on indoor tanning
services” in its place.
3. Paragraph (d) is revised.
4. Paragraphs (e) and (f) are removed.
The revision reads as follows:
§40.0–1 Introduction.
*****
(d)Effective/applicability date.This
part applies to returns that relate to periods
beginning after March 31, 2013. For rules
that apply before that date, see 26 CFR part
40 (revised as of April 1, 2013).
§40.0–1T [Removed]
Par. 3. Section 40.0–1T is removed.
Par. 4. Section 40.6302(c)–1 is
amended as follows:
1. Paragraph (a)(1) is amended by
removing the language “by statute, by
§40.6302(c)–1T(g),” and adding “by
statute” in its place.
2. Paragraph (e)(1)(iii) is amended by
removing the language “chemicals); and”
and adding “chemicals);” in its place.
3. Paragraph (e)(1)(iv) is amended
by removing the language “plans).” and
adding “plans); and” in its place.
4. Paragraph (e)(1)(v) is added.
5. Paragraph (f) is revised.
6. Paragraph (g) is removed.
The addition and revision read as fol-
lows:
§40.6302(c)–1 Deposits.
*****
(e) * * *
(1) * * *
(v) Section 5000B (relating to indoor
tanning services).
*****
(f)Effective/applicability date.This
section applies to deposits and payments
made after March 31, 2013. For rules that
apply before that date, see 26 CFR part 40
(revised as of April 1, 2013).
§40.6302(c)–1T [Removed]
Par. 5. Section 40.6302(c)–1T is re-
moved.
PART 49—FACILITIES AND
SERVICES EXCISE TAX
Par. 6. The authority citation for part
49 continues to read in part as follows:
Authority: 26 U.S.C. 7805. * * *
2013–28 I.R.B.51July 8, 2013

Par. 7. Section 49.0–1 is revised to read
as follows:
§49.0–1 Introduction.
The regulations in this part 49 are des-
ignated “Facilities and Services Excise Tax
Regulations.” The regulations relate to the
taxes on communications and transporta-
tion by air imposed by chapter 33 of the
Internal Revenue Code and the taxes on in-
door tanning services imposed by section
5000B. See part 40 of this chapter for reg-
ulations relating to returns, payments, and
deposits of these taxes.
§49.0–3T [Removed]
Par. 8. Section 49.0–3T is removed.
Par. 9. Subpart G is revised to read as
follows:
Subpart G—Indoor Tanning Services
§49.5000B–1 Indoor tanning services.
(a)Overview. This section provides
rules for the tax imposed by section 5000B
on any indoor tanning service.
(b)Imposition of tax—(1)General rule.
Tax is imposed by section 5000B at the
time of payment for any indoor tanning
service.
(2)Undesignated payment cards—In
general. Payment for indoor tanning
services is made when an undesignated
payment card is redeemed, in whole or
in part, to pay for indoor tanning services
(and not when a payment is made to pur-
chase the undesignated payment card).
(c)Definitions—(1) The termindoor
tanning servicemeans a service employing
any electronic product designed to incor-
porate one or more ultraviolet lamps and
intended for the irradiation of an individual
by ultraviolet radiation, with wavelengths
in air between 200 and 400 nanometers, to
induce skin tanning. The term does not in-
clude phototherapy service performed by,
and on the premises of, a licensed medical
professional (such as a dermatologist, psy-
chologist, or registered nurse).
(2) The termother goods and services
includes, but is not limited to, protective
eyewear, footwear, towels, and tanning lo-
tions; manicures, pedicures, and other cos-
metic or spa treatments; and access to sport
or exercise facilities.
(3) The termphototherapy service
means a service that exposes an individual
to specific wavelengths of light for the
treatment of—
(i) Dermatological conditions (such as
acne, psoriasis, and eczema);
(ii) Sleep disorders;
(iii) Seasonal affective disorder or other
psychiatric disorder;
(iv) Neonatal jaundice;
(v) Wound healing; or
(vi) Other medical condition deter-
mined by a licensed medical professional
to be treatable by exposing the individual
to specific wavelengths of light.
(4) The termprovidermeans a person
that provides an indoor tanning service as
defined in paragraph (c)(1) of this section.
(5) The termqualified physical fitness
facilitymeans a facility—
(i) In which the predominant business
or activity is providing equipment and ser-
vices to its members for purposes of ex-
ercise and physical fitness (determined by
taking into consideration all of the facts
and circumstances, such as the cost of the
equipment, variety of services offered, ac-
tual usage of services by customers, rev-
enue generated by different services, and
how the entity holds itself out to the public
through advertising or other means);
(ii) In which providing indoor tanning
services is not a substantial part of the busi-
ness or activity; and
(iii) That does not sell indoor tanning
services for a fee to the public or otherwise
offer different pricing options to its mem-
bers based in whole or in part on access to
indoor tanning services.
(6) The termundesignated payment
cardmeans a gift certificate, gift card,
or similar item that can be redeemed for
goods or services that may, but do not nec-
essarily, include indoortanning services.
(d)Application of tax—(1)Tax on to-
tal amount paid for indoor tanning ser-
vices—(i)In general. The tax is imposed
on the total amount paid for indoor tan-
ning services, including any amount paid
by insurance. The total amount paid is pre-
sumed to include the tax if the tax is not
separately stated.
(ii)Free services and reduced rates.
The tax does not apply to indoor tanning
services that are provided free of charge.
Indoor tanning services are provided free
of charge if no one pays anything of value
to the provider of the service for the indoor
tanning service. Thus, for example, tax is
not imposed on the redemption of a promo-
tional coupon for indoor tanning services if
the coupon is provided at no cost and at no
obligation to purchase anything. If indoor
tanning services are provided at a reduced
rate, the tax applies to the amount actually
paid for the services.
(iii)Bonus points. The redemption of
benefits such as “bonus points” under a
loyalty program or similar program or pro-
motion is not a payment for indoor tanning
services. Thus, for example, in a promo-
tion that entitles a customer to a “free” tan
with the purchase of four tans, tax is not
imposed on the redemption of the fifth tan
because the amount paid for the four tans
included a reduced price for the fifth tan.
(iv)Other fees. Fees for starting, join-
ing, registering, enrolling, and similar
fees paid to a provider to join a monthly
(or other periodic) membership program
that provides indoor tanning services are
amounts paid for indoor tanning services.
Similarly, amounts paidtoaproviderthat
temporarily suspend a periodic member-
ship program are amounts paid for indoor
tanning services.
(2)Charges for other goods and ser-
vices; tanning services separately stated.
If a payment covers charges for indoor tan-
ning services as well as other goods and
services, the chargesfor other goods and
services may be excluded in computing
the tax payable on the amount paid, if the
charges—
(i) Are separable (regardless of the
manner of invoicing the charges);
(ii) Do not exceed the fair market value
of such other goods and services; and
(iii) Are shown in the exact amounts
in the provider’s records pertaining to the
indoor tanning services charge.
(3)Charges for other goods and ser-
vices; tanning services bundled.This
paragraph (d)(3) applies if paragraph
(d)(2) of this section does not apply.
If a provider offers indoor tanning ser-
vices (whether of a specified or unlimited
amount, including “free” or reduced-rate
indoor tanning services) bundled with
other goods and services, the payment for
the bundled servicesincludes an amount
paid for indoor tanning services. The tax
applies to that portion of the amount paid
to the provider that is reasonably attrib-
utable to indoor tanning services. The
July 8, 2013522013–28 I.R.B.

amount reasonably attributable to indoor
tanning services may be determined by—
(i) Applying to the total amount paid a
ratio determined by comparing—
(A) The provider’s charge for indoor
tanning services not in bundled services
or, if the provider only charges for in-
door tanning services as part of bundled
services, the fair market value of simi-
lar indoor tanning services (based on the
amount charged by comparable providers
in the same geographic area); to
(B) The charge determined in para-
graph (d)(3)(i)(A) of this section plus the
provider’s charge for the other goods and
services in the bundled services or, if the
provider only charges for other goods and
services as part of bundled services, the
fair market value of similar goods and
services (based on the amount charged by
comparable providers in the same geo-
graphic area); or
(ii) Any other method allowed in guid-
ance published in the Internal Revenue
Bulletin.
(4)Exemption; qualified physical fit-
ness facilities. No portion of a payment to
a qualified physical fitness facility (within
the meaning of paragraph (c)(5) of this sec-
tion) that includes access to indoor tanning
services is treated as a payment for indoor
tanning services.
(e)Person liable for the tax—(1)Gen-
eral rule. The person who pays for the in-
door tanning service is deemed to be the
person on whom the service is performed
for purposes of collecting the tax. Thus,
the person paying for the indoor tanning
service is liable for the tax at the time of
payment.
(2)Undesignated payment cards—(i)
In general. In the case of a payment made
with an undesignated payment card (as de-
fined in paragraph (c)(6) of this section),
the person who redeems the card, in whole
or in part, to pay specifically for indoor
tanning services is the person who pays
for the indoor tanning services. Thus, the
person who redeems an undesignated pay-
ment card, in whole or in part, to pay
specifically for indoor tanning services is
liable for the tax at the time such payment
is made (as described in paragraph (b)(2)
of this section).
(ii)Alternative treatment. The Treasury
Department and IRS may provide addi-
tional options for the treatment of undesig-
nated payment cards in guidance published
in the Internal Revenue Bulletin.
(3)Tax not collected at time of payment.
If the person paying for the indoor tanning
services does not pay the tax to the person
receiving the payment for the services at
the time of payment for the services, the
person receiving the payment is liable for
the tax.
(f)Persons receiving payment must col-
lect tax. Every person receiving a payment
for indoor tanning services on which a tax
is imposed under this section must collect
the amount of the tax from the person mak-
ing that payment.
(g)Examples. The following examples
illustrate the application of section 5000B
and this section.
Example 1: Imposition of tax; general rule.(i)P
is a nail salon that also provides indoor tanning ser-
vice incidental to its primary business of providing
nail salon services. P advertises a price of $15.00
(exclusive of the tax imposed by section 5000B) for
one 10-minute indoor tanning service. During a pe-
riod when the tax is 10 percent of the amount paid,
P calculates the section 5000B tax on $15.00 as pro-
vided by paragraph (d)(1) of this section. Thus, the
tax is $1.50 ($15.00 X 10%). The person paying for
the service is liable for the tax when that person pays
for the services. If P does not collect the tax from the
person at the time of the payment for the services, P
is liable for the tax.
(ii) The facts are the same as in paragraph (i)
of this example except that P’s advertised price of
$15.00 includes the tanning tax. In this case, the tax
is $1.36 ($15.00 X 10%/110%) under the second sen-
tence of paragraph (d)(1) of this section.
Example 2: Charges for other goods and ser-
vices; tanning services separately stated
. P provides
indoor tanning services and other goods and services.
On July 1, 2013, A, an individual, pays P for one
10-minute indoor tanning service and one pair of pro-
tective eyewear. P charges $15.00 for the 10-minute
indoor tanning service and $2.00 for a pair of pro-
tective eyewear. The $2.00 charge for the protective
eyewear does not exceed its fair market value. The in-
voice from P is $17.00 (exclusive of the tax imposed
by section 5000B) and separately states the cost of the
protective eyewear. Because the cost of the protective
eyewear is separately stated, P calculates the section
5000B tax on $15.00 as provided by paragraph (d)(2)
of this section. A is liable for the tax when A pays
for the services. If P does not collect the tax from A
at the time A pays for the services, P is liable for the
tax.
Example 3: Charges for other goods and ser-
vices; tanning services bundled
. P provides indoor
tanning services and other goods and services and
offers bundled services. On July 1, 2013, A, an
individual, buys bundled service from P that includes
10 swimming lessons, the use of towels while on
P’s premises, one pair of protective eyewear, and 2
“free” 10-minute indoor tanning services. P charges
$252.00 (exclusive of the tax imposed by section
5000B) for the bundled services. If these services are
purchased separately, P charges (exclusive of the tax
imposed by section 5000B) $25.00 per swimming
lesson, $15.00 for a 10-minute indoor tanning ser-
vice, $2.00 for the protective eyewear, and does not
charge for the use of towels while on P’s premises.
As determined under paragraph (d)(3) of this section,
the section 5000B tax applies to the amount reason-
ably attributable to the indoor tanning service, which
is $26.81 (($30.00/$282.00) x $252.00).
Example 4: Person liable for the tax.OnJuly
1, 2013, A buys bundled services (described in
Ex-
ample 3
) from P as a gift for B. Under paragraph
(e)(1) of this section, A is deemed to be the person
on whom the indoor tanning services are performed
for purposes of collecting the tax. Therefore, under
paragraph (b)(1) of this section, A is liable for the tax
when A pays for the services. The tax will be com-
puted under the rules of paragraph (d)(3) of this sec-
tion. If A does not pay the tax at the time A pays for
the services, P is liable for the tax.
Example 5: Undesignated payment cards.(i)P
operates a spa that provides a variety of cosmetic
goods and services, including indoor tanning ser-
vices. On July 1, 2013, A buys a gift certificate in
the amount of $100.00 from P as a gift for B. The
gift certificate may be redeemed by B for B’s choice
among several services offered by P, including in-
door tanning services. On July 15, 2013, B partially
redeems the gift certificate to pay for one 10-minute
indoor tanning service.
(ii) Under paragraph (b)(2) of this section, a pay-
ment for indoor tanning services is made, and the tax
under section 5000B is imposed, on July 15, 2013,
when B partially redeems thegift certificate to pay for
one indoor tanning service. Under paragraph (e)(2)
of this section, B is the person who pays for the in-
door tanning services. Therefore, B is liable for the
tax, computed under the rules of paragraph (d) of this
section, and pays the tax by permitting P to debit the
amount of the tax from the balance of the gift certifi-
cate or by paying the amount of the tax to P in cash. If
B does not pay the tax at the time B partially redeems
the gift certificate to pay for the indoor tanning ser-
vices, P is liable for the tax.
Example 6: Charges for other goods and ser-
vices; tanning services bundled; amount attributable
to tanning services
. On July 1, 2013, A pays
$1,000.00 (exclusive of the tax imposed by section
5000B) to spa P for the right to use the following
equipment and services during the month of July:
up to four massages or facials, unlimited use of a
sauna, steam room, showers, and towel service, and
unlimited indoor tanning services. If the services are
purchased separately, P charges (exclusive of the tax
imposed by section 5000B) $150.00 for unlimited
indoor tanning services during the month of July, and
$900.00 for the other equipment and services dur-
ing the month of July, not including indoor tanning
services. Under paragraph (b) of this section, A has
made a payment for indoor tanning services and the
tax will be computed under the rules of paragraph
(d)(3) of this section. As determined under paragraph
(d)(3) of this section, the section 5000B tax applies to
the amount reasonably attributable to the indoor tan-
ning services, which is $142.86 (($150.00/$1050.00)
x $1000.00). If A does not pay the tax at the time A
pays for the bundled services, P is liable for the tax.
Example 7: Payments to qualified physical fit-
ness facilities
. P operates a full-service gym facility
that offers fitness classes, multiple exercise machines
2013–28 I.R.B.53July 8, 2013

(such as treadmills, stationary bicycles, weight train-
ing machines, and free weights), and has as its pre-
dominant business providing these facilities, equip-
ment, and services to members for purposes of exer-
cise and physical fitness. P provides its members with
access to indoor tanning services, comprised of two
tanning beds that meet the definition of indoor tan-
ning services under paragraph (c)(1) of this section.
P generally charges its members a fee for monthly
usage of its facilities, equipment, and services, but
also offers short-term or free trial memberships and
allows non-members to purchase individual or a se-
ries of exercise classes. P does not charge any fee for
the indoor tanning services, does not offer indoor tan-
ning services separately from its other services, and
has no membership tier or category that differs from
others based on access to the indoor tanning services.
P holds itself out to the public through advertising
and marketing as providing equipment and services
to improve physical fitness. On July 1, 2013, A pays
a membership fee to P in return for use of P’s facility
during the month of July. Under paragraph (d)(4) of
this section, no portion of A’s membership fee pay-
ment is treated as a payment made for indoor tanning
services, because A is a qualified physical fitness fa-
cility under paragraph (c)(5) of this section. There-
fore, no liability for tax arises under section 5000B.
(h)Effective/applicability date.This
section applies to amounts paid on or after
June 10, 2013. For rules that apply before
that date, see 26 CFR part 49 (revised as of
April 1, 2013).
PART 602—OMB CONTROL
NUMBERS UNDER THE PAPERWORK
REDUCTION ACT
Par. 10. The authority citation for part
602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 11. In §602.101, paragraph (b)
is amended by removing the entry for
§1.5000B–1 and adding an entry for
49.5000B–1 in numerical order to the ta-
ble to read as follows:
§602.101 OMB Control numbers.
*****
(b) * * *
CFR part or section where
Identified and described
Current OMB
control No.
*****
49.5000B–1
...........................................................
1545–2177
*****
Beth Tucker,
Acting Deputy Commissioner
for Services and Enforcement.
Approved May 31, 2013
Mark J. Mazur,
Assistant Secretary
oftheTreasury(TaxPolicy).
(Filed by the Office of the Federal Register on June 10, 2013,
8:45 a.m., a
nd published in the issue of the Federal Register
for June 11, 2013, 78 FR 34874)
Section 752
0.—Valuation
Tables
The adjuste
d applicable federal short-term, mid-
term, and lo
ng-term rates are set forth for the month
of July 2013
. See Rev. Rul. 2013-15, page 47.
Section 7872.—Treatment
of Loans With Below-Market
Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of July 2013. See Rev. Rul. 2013-15, page 47.
July 8, 2013542013–28 I.R.B.

Part III. Administrative, Procedural, and Miscellaneous
26 CFR 601.201: Rulings and determination letters
(Also: Part 1, §§ 332, 351, 355, 368, and 1036)
Rev. Proc. 2013–32
SECTION 1. PURPOSE
To conserve Internal Revenue Service
(Service) resources, this revenue proce-
dure restricts the scope of letter rulings that
address issues with respect to transactions
under sections 332, 351, 355, and 1036,
and reorganizations within the meaning of
section 368 of the Internal Revenue Code
(Code).
SECTION 2. CHANGES
.01 Section 5.01 of this revenue proce-
dure modifies and amplifies section 6.03,
section 6.11, Appendix C, and Appendix
E of Rev. Proc. 2013–1, 2013–1 I.R.B.
1 (explaining procedures for requesting
letter rulings generally), and section 5.02
of this revenue procedure modifies and
amplifies sections 3.01(41), 4.02(2), and
4.02(9) of Rev. Proc. 2013–3, 2013–1
I.R.B. 113 (listing areas of the Code un-
der the jurisdiction of the Associate Chief
Counsel (Corporate) on which the Service
will not issue letter rulings), by modifying
the scope of, and procedures for request-
ing, letter rulings issued by the Service
under section 332, 351, 355, 368, or 1036,
and certain related Code sections. As
explained in section 4.01 of this revenue
procedure, the Service will no longer rule
on whether a transaction qualifies for non-
recognition treatment under section 332,
351, 355, or 1036, or on whether a trans-
action constitutes a reorganization within
the meaning of section 368. The Service
will instead rule only on significant issues
(described in section 4.02 of this revenue
procedure) under section 332, 351, 355,
368, or 1036. In addition, as explained
in section 4.03 of this revenue procedure,
the Service will rule only on significant
issues under related Code sections that
address the tax consequences (such as
nonrecognition and basis) that result from
the application of section 332, 351, 355,
368, or 1036. Finally, section 5.01 of
this revenue procedure discontinues the
pilot program announced in Rev. Proc.
2009–25, 2009–24 I.R.B.1088, for letter
rulings on certain issues arising in the
context of a section 355 distribution.
.02 Section 5.03 of this revenue proce-
dure modifies the following revenue pro-
cedures, which describe some of the infor-
mation and representations to be submitted
with a letter ruling request for rulings on
transactions described in section 332, 351,
355, or 368, by providing that such infor-
mation and representations should be in-
cluded in letter ruling requests with respect
to one or more significant issues under
such Code sections only to the extent that
they relate to the significant issues: Rev.
Proc. 81–60, 1981–2 C.B. 680 (section
368(a)(1)(E)); Rev. Proc. 83–59, 1983–2
C.B. 575 (section 351); Rev. Proc. 86–42,
1986–2 C.B. 722 (section 368(a)(1)(A),
(B), (C), (D) (acquisitive reorganizations),
and (F)); Rev. Proc. 90–52, 1990–2 C.B.
626 (section 332); and Rev. Proc. 96–30,
1996–1 C.B. 696, amplified and modified
by Rev. Proc. 2003–48, 2003–2 C.B. 86
(section 355).
.03 Additionally, section 5.04 of this
revenue procedure supersedes section 4.06
of Rev. Proc. 2003–48, 2003–2 C.B. 86
(relating to supplemental letter rulings)
and obsoletes all other sections of Rev.
Proc. 2003–48 (relating to procedures
for requesting letter rulings under section
355).
SECTION 3. BACKGROUND
.01 Letter Rulings, In General
Ordinarily, the Service will not issue a
letter ruling on only part of an integrated
transaction. If, however, part of an inte-
grated transaction falls under an area of
the Code, including those under the ju-
risdiction of the Associate Chief Coun-
sel (Corporate), on which the Service will
not issue letter rulings (“no-rule issue” or
“no-rule area”), the Service may issue a
letter ruling on other parts of the transac-
tion. Section 6.03 of Rev. Proc. 2013–1,
2013–1 I.R.B. 15, and section 4.02(2) of
Rev. Proc. 2013–3, 2013–1 I.R.B. 122.
If it is impossible for the Service to de-
termine the tax consequences of a larger
transaction without resolving a no-rule is-
sue then the taxpayer must state in its rul-
ing request to its best knowledge and be-
lief the tax consequences of the no-rule is-
sue. The Service’s letter ruling will state
that the Service did not consider, and no
opinion is expressed upon, the no-rule is-
sue. In appropriatecases, notwithstanding
the taxpayer’s representation, the Service
may decline to issue a letter ruling on such
larger transactions due to the relevance of
the no-rule issue. Section 2.03 of Rev.
Proc. 2013–3, 2013–1 I.R.B 114.
In addition, the Service ordinarily will
not issue letter rulings with respect to an
issue that is clearly and adequately ad-
dressed by statute, regulations, decision of
a court, or authority published in the In-
ternal Revenue Bulletin (i.e., comfort rul-
ings). However, the Service may in its dis-
cretion decide to issue a letter ruling on
such an issue if the Service is otherwise
issuing a letter ruling to the taxpayer on
another issue arising in the same transac-
tion. Section 6.11 of Rev. Proc. 2013–1,
2013–1 I.R.B. 17, and section 4.02(9) of
Rev. Proc. 2013–3, 2013–1 I.R.B. 123.
.02 Certain Letter Rulings under the Ju-
risdiction of the Associate Chief Counsel
(Corporate)
Prior to the effective date of this rev-
enue procedure, the Service would not
issue a letter ruling on whether a trans-
action qualified for nonrecognition treat-
ment under section 332, 351 (except
for certain transfers undertaken before
section 355 distributions), or 1036, or
whether a transaction constituted a reor-
ganization within the meaning of section
368(a)(1)(A) (including a transaction that
qualified under section 368(a)(1)(A) by
reason of section 368(a)(2)(D) or section
368(a)(2)(E)), section 368(a)(1)(B), sec-
tion 368(a)(1)(C), section 368(a)(1)(E),
or section 368(a)(1)(F), or the tax con-
sequences (such as nonrecognition and
basis) that resulted from the application
of such Code sections, unless the Service
determined that there was a significant
issue. If the Service determined that there
was a significant issue, and to the extent
thetransactionwasnotdescribedinan-
other no-rule area, the Service would rule
on the entire transaction and not just the
significant issue. Section 3.01(41) of Rev.
Proc. 2013–3, 2013–1 I.R.B. 116.
In Rev. Proc. 2009–25, 2009–24 I.R.B.
1088, the Service announced a pilot pro-
gram for letter rulings on issues arising
in the context of section 355 distributions.
Under this program, a taxpayer could re-
2013–28 I.R.B.55July 8, 2013

quest a letter ruling on part of a larger
transaction or on a particular issue under a
Code section that a transaction presented.
The Service, in turn, would issue a letter
ruling on the particular issue raised in the
letter ruling request and not on any other
issue (including, in some cases, qualifica-
tion of the distribution under section 355)
or on any other aspect of the transaction.
Prior to the effective date of this rev-
enue procedure, a taxpayer requesting a
letter ruling on the qualification of a trans-
action under section 332, 351, 355, or
1036, or whether a transaction constituted
a reorganization within the meaning of sec-
tion 368, was required to provide infor-
mation and representations described in
other applicable revenue procedures (i.e.,
Rev. Proc. 81–60, 1981–2 C.B. 680;
Rev. Proc. 83–59, 1983–2 C.B. 575;
Rev. Proc. 86–42, 1986–2 C.B. 722; Rev.
Proc. 90–52, 1990–2 C.B. 626; Rev. Proc.
96–30, 1996–1 C.B. 696; and Rev. Proc.
2003–48, 2003–2 C.B. 86, as applicable)
as well as other information and represen-
tations that were requested as part of the
Associate Chief Counsel (Corporate)’s rul-
ing policy.
SECTION 4. EXPLANATION OF NEW
PROCEDURES
.01 New Procedures for Certain Letter
Rulings under the Jurisdiction of the As-
sociate Chief Counsel (Corporate)
(1) The Service will no longer rule on
whether a transaction qualifies for non-
recognition treatment under section 332,
351, 355, or 1036, or on whether a trans-
action constitutes a reorganization within
the meaning of section 368 (collectively,
the “Nonrecognition Provisions”), regard-
less of whether the transaction presents a
significant issue and regardless of whether
the transaction is an integral part of a larger
transaction that involves other issues upon
which the Service will rule.
The Service will rule, however, on one
or more issues under the Nonrecognition
Provisions to the extent that such issue or
issues are significant. For example, the
Service will issue a letter ruling addressing
significant issues presented by the applica-
tion of sections 1.368–1(d) and 1.368–2(k)
of the Income Tax Regulations.
(2) This revenue procedure does not
limit the number of significant issues that
may be the subject of a single letter ruling.
The Service reserves the right to rule on
any other issue in, or part of, the transac-
tion (including ruling adversely) if the Ser-
vice believes that it is in the best interests
of tax administration.Cf. section2.01of
Rev. Proc 2013–3, 2013–1 I.R.B. 113.
(3) For purposes of this revenue proce-
dure, a significant issue is an issue of law
the resolution of which is not essentially
free from doubt and that is germane to
determining the tax consequences of the
transaction. An issue the resolution of
which is not essentially free from doubt
under one Code section may nevertheless
not be germane to determining the tax
consequences of the transaction if, for
instance, another Code section provides
the same consequences as the first Code
section. For example, the Service may
decline to rule on an issue under section
368 with respect to an upstream merger of
a wholly owned subsidiary into its share-
holder if qualification of the transaction
under section 332 is essentially free from
doubt and it is essentially free from doubt
that the tax consequences of section 332
qualification would be the same as the
tax consequences that would result if the
transaction constituted a reorganization
within the meaning of section 368. In such
an overlap case, the taxpayer must explain
why the issue is germane to determining
its tax consequences.
(4) In addition, the Service will only
rule on the tax consequences (such as non-
recognition and basis) that result from the
application of the Nonrecognition Provi-
sions to the extent that a significant issue
is presented under the related Code sec-
tion that addresses such tax consequences.
For example, a section 351 exchange that
does not present any significant issues un-
der section 351 may present a significant
issue regarding the application of section
358 to the transferor in the exchange. In
such a case, the Service will rule only on
the significant issue under section 358.
(5) Before submitting a letter ruling
request on a significant issue under this
revenue procedure, a taxpayer is encour-
aged to call the Office of Associate Chief
Counsel (Corporate) at (202) 622–7700 to
discuss whether the Service will entertain
such a letter ruling request. Letter ruling
requests submitted under this revenue pro-
cedure must comply with the requirements
set forth in section 6.03 of Rev. Proc.
2013–1, 2013–1 I.R.B. 15, as modified
by this revenue procedure, as well as Rev.
Proc. 2013–1, in general. All pertinent
no-rule policies described in Rev. Proc.
2013–3, 2013–1 I.R.B. 113, governing the
Service’s letter ruling practice will govern
requests for letter rulings made pursuant to
this revenue procedure.See, for example,
section 3.01(43) of Rev. Proc. 2013–3,
2013–1 I.R.B. 116 (no-rule policy regard-
ing business purpose and device issues
under section 355 and section 355(e) plan
issues).
In preparing a letter ruling request
under this revenue procedure, taxpayers
should continue to consult other applica-
ble revenue procedures (e.g., Rev. Proc.
81–60, 1981–2 C.B. 680; Rev. Proc.
83–59, 1983–2 C.B. 575; Rev. Proc.
86–42, 1986–2 C.B. 722; Rev. Proc.
90–52, 1990–2 C.B. 626; and Rev. Proc.
96–30, 1996–1 C.B. 696) and include in
the letter ruling request the information
and representations described in such rev-
enue procedures (as appropriate) only to
the extent that they relate to the significant
issues.
.02 Supplemental Letter Rulings
The Associate Chief Counsel (Corpo-
rate) will apply the same no-rule policy de-
scribed above to supplemental letter ruling
requests. A change of circumstances aris-
ing after a transaction has been completed
ordinarily will not present a significant is-
sue with respect to the transaction. In ad-
dition, an issue of fact (as opposed to an
issue of law) does not present a significant
issue. Before submitting a supplemental
letter ruling request, ataxpayer is encour-
aged to call the Office of Associate Chief
Counsel (Corporate) at (202) 622–7700 to
discuss whether the Service will entertain a
supplemental letter ruling request. All per-
tinent no-rule policies governing the Ser-
vice’s letter ruling practice will govern re-
quests for supplemental letter rulings.
SECTION 5. PROCEDURE
.01 Rev. Proc. 2013–1 is modified and
amplified as follows:
(1) Delete the text of all paragraphs af-
ter the first paragraph of section 6.03 and
add the following text after the first para-
graph of section 6.03:
In addition, the Service will not rule
on the qualification of any transaction un-
der section 332, 351, 355, or 1036, or on
whether a transaction constitutes a reor-
July 8, 2013562013–28 I.R.B.

ganization within the meaning of section
368, regardless of whether such transac-
tion is part of an integrated transaction (see
section 3.01(41) of Rev. Proc. 2013–3,
2013–1 I.R.B. 116, as modified by Rev.
Proc. 2013–32 in I.R.B. 2013–28). In-
stead, the Associate Chief Counsel (Cor-
porate) will only issue a letter ruling on
significant issues (within the meaning of
section 3.01(41) of Rev. Proc. 2013–3,
as modified by Rev. Proc. 2013–32) pre-
sented in a transaction described in sec-
tion 332, 351, 355, 368, or 1036. For
example, the Service may rule on signifi-
cant issues under section 1.368–1(d) (con-
tinuity of business enterprise) and section
1.368–1(e) (continuity of interest). Letter
rulings requested under this section 6.03
are subject to the no-rule policies of Rev.
Proc. 2013–3. In addition, the Service will
not rule on the tax consequences that result
from the application of section 332, 351,
355, 368 or 1036 (including nonrecogni-
tion and basis) except to the extent of a sig-
nificant issue and only to the extent consis-
tent with the no-rule policies of Rev. Proc.
2013–3.
Before preparing a letter ruling request
under this section involving significant is-
sues presented in a transaction described
in section 332, 351, 355, 368, or 1036, a
taxpayer is encouraged to call the Office
of Associate Chief Counsel (Corporate) at
the telephone number provided in section
10.07(1)(a) of this revenue procedure to
discuss whether the Service will entertain
a letter ruling request under this section
6.03. The Service reserves the right to rule
on any other aspect of the transaction (in-
cluding ruling adversely) to the extent the
Service believes it is in the best interests
of tax administration.Cf. section 2.01 of
Rev. Proc. 2013–3.
Taxpayers may request rulings on one
or more significant issues in a single letter
ruling request. Letter ruling requests un-
der this section 6.03 must include for each
significant issue:
(1) A narrative description of the trans-
action that puts the issue in context;
(2) A statement identifying the issue;
(3) An analysis of the relevant law,
which should set forth the authorities most
closely related to the issue and explain
why these authorities do not resolve the
issue, and an explanation concerning why
the issue is significant within the meaning
of section 3.01(41) of Rev. Proc. 2013–3,
as modified by Rev. Proc. 2013–32;
(4) Information and representations rel-
evant to the issue. Taxpayers should con-
sult other published authorities (see,for
example, Exhibit E of this revenue proce-
dure, which identifiescertain checklist and
guideline revenue procedures), including
those modified by Rev. Proc. 2013–32
(e.g., Rev. Proc. 96–30, 1996–1 C.B.
696), and other authorities (e.g.,Rev.Rul.
73–234, 1973–1 C.B. 180 (applying sec-
tion 355(b) to the activities performed by
employees of a corporation engaged in a
farming business)), to identify information
or representations but only to the extent
that they relate to the issue; and
(5) The precise ruling(s) requested.
If the Service issuesa letter ruling on a
significant issue underthis procedure, then
the letter ruling will state that no opinion is
expressed as to any issue or step not specif-
ically addressed by the letter. In addition,
letter rulings issued under this procedure
will contain the following (or similar) lan-
guage:
This Office expresses no opinion as
to the overall tax consequences of the
transaction(s) described in this letter,
including qualification of the trans-
action under [section 332, 351, 355,
368, or 1036, as appropriate].
(2) Delete the text of section 6.11 and
add the following text in its place:
A letter ruling will not be issued with
respect to an issue that is clearly and ad-
equately addressed by statute, regulations,
decision of a court, revenue rulings, rev-
enue procedures, notices, or other author-
ity published in the Internal Revenue Bul-
letin (Comfort Ruling). However, except
with respect to issues under section 332,
351, 355, 368, or 1036 and the tax conse-
quences resulting from the application of
such Code sections (seegenerally section
6.03, as modified by Rev. Proc. 2013–32
in I.R.B. 2013–28), the Associate office
may in its discretion decide to issue a Com-
fort Ruling if the Associate office is other-
wise issuing a letter ruling to the taxpayer
on another issue arising in the same trans-
action.
(3) Add a new question after question 7
in Appendix C as follows:
(a) Are you requesting a letter ruling un-
der the jurisdictionof the Associate Chief
Counsel (Corporate) on a significant issue
(within the meaning of section 3.01(41) of
Rev. Proc. 2013–3, 2013–1 I.R.B. 116, as
modified by Rev. Proc. 2013–32 in I.R.B.
2013–28) with respect to a transaction de-
scribed in section 332, 351, 355, or 1036
or a reorganization within the meaning of
section 368?Seesection 6.03;
(b) Include a “Yes No” answer; and
(c) Include a space to indicate the rele-
vant page number; and
(4) Modify the text in section .01 of
Appendix E as follows:
(a) Under the subheading “Subchapter
C—Corporate Distributions, Adjustments,
Transfers, and Reorganizations” delete the
text and add the following text in its place:
Rev. Proc. 77–37, 1977–2 C.B. 568,
as modified by Rev. Proc. 89–30, 1989–1
C.B. 895, and as amplified by Rev. Proc.
77–41, 1977–2 C.B. 574, Rev. Proc.
83–81, 1983–2 C.B. 598 (see alsoRev.
Proc. 2013–3, 2013–1 I.R.B. 113, as mod-
ifiedbyRev. Proc. 2013–32inI.R.B.
2013–28), Rev. Proc. 84–42, 1984–1 C.B.
521 (superseded, in part, as to no-rule ar-
eas by Rev. Proc. 2013–3, 2013–1 I.R.B.
113), Rev. Proc. 86–42, 1986–2 C.B. 722,
and Rev. Proc. 89–50, 1989–2 C.B. 631.
But seesection 3.01 of Rev. Proc. 2013–3,
as modified by Rev. Proc. 2013–32, which
states that the Service will not issue a letter
ruling as to whether a transaction consti-
tutes a reorganizationwithinthemeaning
of section 368. However, the Service will
issue a letter ruling addressing significant
issues (within the meaning of section 3.01
of Rev. Proc. 2013–3, as modified by Rev.
Proc. 2013–32) presented in a reorgani-
zation within the meaning of section 368.
The information and representations de-
scribed in these revenue procedures should
be included in a letter ruling request only
to the extent that they relate to the signifi-
cant issues with respect to which the letter
ruling is requested.Seesection 6.03(4), as
modified by Rev. Proc. 2013–32.
(b) Under the subheading “332 Check-
list Questionnaire” delete the text and add
the following text in its place:
Seesection 3.01 of Rev. Proc. 2013–3,
2013–1 I.R.B. 113, as modified by Rev.
Proc. 2013–32 in I.R.B. 2013–28, which
states that the Service will not issue a letter
ruling on whether a corporate distribution
qualifies for nonrecognition treatment un-
der section 332. However, the Service will
issue a letter ruling addressing significant
issues (within the meaning of section 3.01
of Rev. Proc. 2013–3, as modified by Rev.
2013–28 I.R.B.57July 8, 2013

Proc. 2013–32) presented in a transaction
described in section332. The informa-
tion and representations described in Rev.
Proc. 90–52, 1990–2 C.B. 626, should be
included in a letter ruling request only to
the extent that they relate to the significant
issues with respect to which the letter rul-
ing is requested.Seesection 6.03(4), as
modified by Rev. Proc. 2013–32.
(c) Under the subheading “351 Check-
list Questionnaire” delete the text and add
the following text in its place:
Seesection 3.01 of Rev. Proc. 2013–3,
2013–1 I.R.B. 113, as modified by Rev.
Proc. 2013–32 in I.R.B. 2013–28, which
states that the Service will not issue a
letter ruling on whether certain trans-
fers to controlled corporations qualify for
nonrecognition treatment under section
351. However, the Service will issue a
letter ruling addressing significant issues
(within the meaning of section 3.01 of
Rev. Proc. 2013–3, as modified by Rev.
Proc. 2013–32) presented in a transaction
described in section351. The informa-
tion and representations described in Rev.
Proc. 83–59, 1983–2 C.B. 575, should be
included in a letter ruling request only to
the extent that they relate to the signifi-
cant issues with respect to which the letter
ruling is requested.Seesection 6.03(4), as
modified by Rev. Proc. 2013–32.
(d) Under the subheading “355 Check-
list Questionnaire” delete the text and add
the following text in its place:
Seesection 3.01 of Rev. Proc. 2013–3,
2013–1 I.R.B. 113, as modified by Rev.
Proc. 2013–32 in I.R.B. 2013–28, which
states that the Service will not issue a letter
ruling on whether certain distributions of
controlled corporation stock qualify for
nonrecognition treatment under section
355. However, the Service will issue a
letter ruling addressing significant issues
(within the meaning of section 3.01 of
Rev. Proc. 2013–3, as modified by Rev.
Proc. 2013–32) presented in a transaction
described in section355. The informa-
tion and representations described in Rev.
Proc. 96–30, 1996–1 C.B. 696, should be
included in a letter ruling request only to
the extent that they relate to the signifi-
cant issues with respect to which the letter
ruling is requested.Seesection 6.03(4), as
modified by Rev. Proc. 2013–32.
(e) Under the subheading “368(a)(1)(E)
Checklist Questionnaire” delete the text
and add the following text in its place:
Seesection 3.01 of Rev. Proc. 2013–3,
2013–1 I.R.B. 113, as modified by Rev.
Proc. 2013–32 in I.R.B. 2013–28, which
states that the Service will not issue a letter
ruling as to whether a transaction consti-
tutes a reorganization, including a recap-
italization within the meaning of section
368(a)(1)(E) (or a transaction that quali-
fies under section 1036). However, the
Service will issue a letter ruling address-
ing significant issues (within the meaning
of section 3.01 of Rev. Proc. 2013–3, as
modified by Rev. Proc. 2013–32) pre-
sented in a transaction described in sec-
tion 368(a)(1)(E) (or in a transaction de-
scribed in section 1036). The informa-
tion and representations described in Rev.
Proc. 81–60, 1981–2 C.B. 680, should be
included in a letter ruling request only to
the extent that they relate to the significant
issues.Seesection 6.03(4), as modified by
Rev. Proc. 2013–32.
.02 Rev. Proc. 2013–3 is modified and
amplified as follows:
(1) Delete the text of section 3.01(41)
and add the following text in its place:
Sections 332, 351, 355, 368, and
1036.—Complete Liquidations of Sub-
sidiaries; Transferto Corporation Con-
trolled by Transferor; Distribution of
Stock and Securities of a Controlled Cor-
poration; Reorganization; Stock for Stock
of Same Corporation.—Whether a trans-
action qualifies under section 332, 351,
355, or 1036 for nonrecognition treat-
ment or whether it constitutes a corporate
reorganization within the meaning of
section 368, and whether various tax con-
sequences (such as nonrecognition and
basis) result from the application of that
section. The Service will instead rule only
on significant issues presented in a trans-
action described in section 332, 351, 355,
368, or 1036. Additionally, the Service
will rule on one or more significant issues
under the Code sections that address the
tax consequences (such as nonrecognition
and basis) that result from the qualification
of a transaction under section 332, 351,
355, 368, or 1036.Seesection 6.03 of
Rev. Proc. 2013–1, 2013–1 I.R.B. 15, as
modified by Rev. Proc. 2013–32 in I.R.B.
2013–28).
SIGNIFICANT ISSUE: A significant
issue is an issue of law the resolution of
which is not essentially free from doubt
and that is germane to determining the tax
consequences of the transaction. A change
of circumstances arising after a transaction
ordinarily does not present a significant is-
sue with respect to the transaction.
OBTAINING A LETTER RULING:
To obtain a letter ruling on a significant
issue presented in a transaction, the tax-
payer in its letter ruling request must
comply with all the requirements set forth
in section 6.03 of Rev. Proc. 2013–1, as
modified by Rev. Proc. 2013–32, as well
as Rev. Proc. 2013–1, in general.
(2) Delete the text of the second para-
graph of section 4.02(2) and add the fol-
lowing text in its place:
Notwithstanding the previous para-
graph, in connection with transactions
described in section 332, 351, 355, or
1036 and reorganizations within the mean-
ing of section 368, the Associate Chief
Counsel (Corporate) may issue a letter
ruling on part of an integrated transaction
if and to the extent that the transaction
presents a significant issue (within the
meaning of section 3.01(41), as modi-
fied by Rev. Proc. 2013–32 in I.R.B.
2013–28).Seesection 6.03 of Rev. Proc.
2013–1, 2013–1 I.R.B. 15, as modified by
Rev. Proc. 2013–32.
(3) Delete the text of section 4.02(9)
and add the following text in its place:
A letter ruling will not be issued with
respect to an issue that is clearly and ad-
equately addressed by statute, regulations,
decision of a court, revenue rulings, rev-
enue procedures, notices, or other author-
ity published in the Internal Revenue Bul-
letin (Comfort Ruling). However, except
with respect to issuesunder sections 332,
351, 355, 368, and 1036 and the tax con-
sequences resulting from the application of
such Code sections (seegenerally section
6.03 of Rev. Proc. 2013–1, 2013–1 I.R.B.
15, as modified by Rev. Proc. 2013–32 in
I.R.B. 2013–28), the Associate office may
in its discretion issue a Comfort Ruling if
the Associate office is otherwise ruling on
another issue arising in the same transac-
tion.
.03 Rev. Proc. 81–60, 1981–2 C.B.
680, Rev. Proc. 83–59, 1983–2 C.B. 575,
Rev. Proc. 86–42, 1986–2 C.B. 722, Rev.
Proc. 90–52, 1990–2 C.B. 626, and Rev.
Proc. 96–30, 1996–1 C.B. 696, are modi-
fied as follows.
The inclusion of all the information and
representations described in these revenue
procedures is not required in all requests
for letter rulings under sections 332, 351,
July 8, 2013582013–28 I.R.B.

355, and 368, as applicable.Seesection
6.03 of Rev. Proc. 2013–1, 2013–1 I.R.B.
15, as modified by Rev. Proc. 2013–32
in I.R.B. 2013–28. Such information and
representations should be included in a let-
ter ruling request with respect to one or
more significant issues under such Code
sections only to the extent that they relate
to the significant issues.
.04 Rev. Proc. 2003–48, 2003–2 C.B.
86 is obsolete in part and superseded in
part as follows:
(1) Sections 4.01 (relating to the corpo-
rate business purpose representation), 4.02
(relating to the device representation), 4.03
(relating to the section 355(e) represen-
tations), 4.04 (regarding the inclusion of
regulatory filings with all letter ruling re-
quests under section 355), and 4.05 (relat-
ing to certain ruling requests for which the
Service previously declined to rule) are ob-
solete; and
(2) Section 4.06 (regarding supplemen-
tal rulings) is superseded.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2013–1, 2013–1 I.R.B. 1,
and Rev. Proc. 2013–3, 2013–1 I.R.B.
113, are amplified and modified. Rev.
Proc. 81–60, 1981–2 C.B. 680, Rev.
Proc. 83–59, 1983–2 C.B. 575, Rev.
Proc. 86–42, 1986–2 C.B. 722, Rev. Proc.
90–52, 1990–2 C.B. 626, and Rev. Proc.
96–30, 1996–1 C.B. 696, are modified.
Rev. Proc. 2003–48, 2003–2 C.B. 86, is
obsolete in part and superseded in part.
The pilot program announced in Rev.
Proc. 2009–25, 2009–24 I.R.B. 1088,
for rulings on certain issues arising in the
context of section 355 distributions is dis-
continued.
SECTION 7. EFFECTIVE DATE
This revenue procedure applies to all
letter ruling requests postmarked or, if not
mailed, received after August 23, 2013.
SECTION 8. PAPERWORK
REDUCTION ACT
The collections of information con-
tained in this revenue procedure have been
reviewed and approved by the Office of
Management and Budget (OMB) in accor-
dance with the Paperwork Reduction Act
(44 U.S.C. 3507) under control number
1545–1522.
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 displays a valid
OMB control number.
The collections of information in this
revenue procedure are in section 5. This
information is required and will be used to
determine whether a taxpayer would qual-
ifyforaletterrulingonpartofaninte-
grated transaction. The collections of in-
formation are required to obtain a bene-
fit. The likely respondents are business or
other for-profit institutions.
The estimated total annual burden un-
der Rev. Proc. 2013–1 is 305,540.
The estimated annual burden per re-
spondent/recordkeeper varies from 1 to
200 hours, depending on individual cir-
cumstances, with an estimated average
burden of 80 hours. The estimated num-
ber of respondents and/or recordkeepers is
3,825.
The estimated frequency of response is
on occasion.
Books or records relating to a collection
of information must be retained as long
as their contents may become material in
the administration of any internal revenue
law. Generally, tax returns and tax return
information are confidential, as required
by section 6103.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Amie Colwell Breslow of
the Office of Associate Chief Counsel
(Corporate). For further information
regarding this revenue procedure contact
Amie Colwell Breslow on (202) 622–7530
(not a toll-free call).
2013–28 I.R.B.59July 8, 2013

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 ef-
fect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is be-
ingextendedtoapplytoavariationofthe
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 withmodi-
fied,below).
Clarifiedis 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
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
beingstatedinanewruling.
Supersededdescribes a situation where
the new ruling does nothing more than re-
state the substance and situation of a previ-
ously published ruling (or rulings). Thus,
the term is used to republish under the
1986 Code and regulations the same po-
sition published under the 1939 Code and
regulations. The term is also used when
it is desired to republish in a single rul-
ing a series of situations, names, etc., that
were previously published over a period of
time in separate rulings. If the new rul-
ing does more than restate the substance
of a prior ruling, a combination of terms
is used. For example,modifiedandsu-
persededdescribes 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 pub-
lished 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 rul-
ing has been supplemented several times, a
new ruling may be published that includes
the list in the original ruling and the ad-
ditions, and supersedes all prior rulings 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 fol
lowing abbreviations in current use
and for
merly used will appear in material
publis
hedintheBulletin.
A—Individual.
Acq.—A
cquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank
.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cu
mulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Coo
perative.
Ct.D.—Court Decision.
CY—County.
D—Decede
nt.
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—Emp
loyer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduc
iary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Fo
reign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Fed
eral Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grante
e.
GP—General Partner.
GR—Grantor.
IC—Insura
nce Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited
Partner.
LR—Lessor.
M—Minor.
Nonacq.—No
nacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Persona
l Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Pa
rtnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Re
al Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsi
diary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target
Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Trans
feree.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpay
er.
TR—Trust.
TT—Trustee.
U.S.C.—Uni
ted States Code.
X—Corporation.
Y—Corporation.
Z—Corporat
ion.
July 8, 2013i2013–28 I.R.B.

Numerical Finding List
1
Bulletins 2013–27 through 2013–28
Announcements:
2013-35, 2013-27 I.R.B.46
Revenue Procedures:
2013-28, 2013-27 I.R.B.28
2013-32, 2013-28 I.R.B.55
Revenue Rulings:
2013-15, 2013-28 I.R.B.47
Treasury Decisions:
9620, 2013-27 I.R.B.1
9621, 2013-28 I.R.B.49
1
A cumulative list of all revenue rulings, revenueprocedures, Treasury decisions, etc., publishedin Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin
2013–26, dated June 24, 2013.
2013–28 I.R.B.iiJuly 8, 2013

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2013–27 through 2013–28
Revenue Procedures:
81-60
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
83-59
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
86-42
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
90-52
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
96-30
Modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2003-48
Obsoleted in part and superseded in part by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2009-25
Pilot program discontinued by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2012-25
Obsoleted in part by
Rev. Proc. 2013-28, 2013-27 I.R.B.
28
2013-1
Amplified and modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
2013-3
Amplified and modified by
Rev. Proc. 2013-32, 2013-28 I.R.B.
55
Treasury Decisions:
9612
Corrected by
Ann. 2013-35, 2013-27 I.R.B.
46
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin 2013–26, dated June 24, 2013.
July 8, 2013iii2013–28 I.R.B.

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