Internal Revenue Bulletin 2014-49 (PDF rendition): IRS Revenue Rulings

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

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.
SPECIAL ANNOUNCEMENT
Announcement 2014–33, page 916.
IRS will no longer publish an index to the IRB starting with IRB
2015– 01, due to the availability of electronic search tools, In
addition, the following section will be eliminated from the IRB;
“INTERNAL REVENUE BULLETINS ON CD-ROM” and “CUMULA-
TIVE BULLETINS.” Effective date: January 5, 2015.
INCOME TAX
Rev. Rul. 2014–30, page 910.
Section 1274A–inflation adjusted numbers for 2015. This rul-
ing provides the dollar amounts, increased by the 2012 infla-
tion adjustment, for section 1274A of the Code. Revenue
Ruling 2013–23 supplemented and superseded.
Notice 2014–71, page 912.
Eligibility for Minimum Essential Coverage Under Pregnancy-
Based Medicaid and CHIP Programs. This notice provides
guidance on eligibility for minimum essential coverage for
purposes of the premium tax credit under § 36B of the Code
for pregnancy-related Medicaid and Children’s Health Insurance
Program (CHIP) programs.
T.D. 9701, page 908.
Final Regulations providing guidance on the recovery of over-
payments of arbitrage rebate on tax-exempt bonds and other
tax-advantaged bonds. These Final Regulations provide the
deadline for filing a claim for an arbitrage rebate overpayment
and certain other rules.
EMPLOYEE PLANS
Notice 2014–73, page 912.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for October
2014 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for November 2014, and the 30-year
Treasury rates. These rates reflect the application of
§ 430(h)(2)(C)(iv), which was added by the Moving Ahead for
Progress in the 21st Century Act, Public Law 112–141 (MAP–
21) and amended by section 2003 of the Highway and Trans-
portation Funding Act of 2014 (HATFA).
Finding Lists begin on page ii.
Bulletin No. 2014–49
December 1, 2014

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
December 1, 2014Bulletin No. 2014–49

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
26 CFR 1.148 –3(i): Guidance on the recovery of
overpayments of arbitrage rebate on tax-exempt and
other tax-advantaged bonds.
T.D. 9701
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Arbitrage Rebate Overpayments
on Tax-Exempt Bonds
AGENCY:Internal Revenue Service (IRS),
Treasury.
ACTION: Final regulations.
SUMMARY: This document contains fi-
nal regulations that provide guidance on
the recovery of overpayments of arbitrage
rebate on tax-exempt bonds and other tax-
advantaged bonds. These final regulations
provide the deadline for filing a claim for an
arbitrage rebate overpayment and certain
other rules. These final regulations affect
issuers of tax-exempt and tax-advantaged
bonds.
DATES:Effective date: These regulations
are effective on November 13, 2014.
Applicability date: For dates of appli-
cability, see § 1.148–11(l)(4).
FOR FURTHER INFORMATION
CONTACT: Timothy Jones at (202) 317-
6980 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
On September 16, 2013, the IRS pub-
lished a Notice of Proposed Rulemaking
(REG–148812–11) in theFederal Regis-
ter(78 FR 56841) (the “Proposed Regu-
lations”). A public hearing was scheduled
for February 5, 2014, but later was can-
celled because no one requested to speak.
However, two comments responding to
the Proposed Regulations were received.
After consideration of these comments,
the Proposed Regulations are adopted as
revised by this Treasury decision.
Explanation of Provisions and
Summary of Comments
The finalregulations amend the Income
Tax Regulations (26 CFR part 1) on the
arbitrage investment restrictions on tax-
exempt bonds and other tax-advantaged
bonds under section 148 of the Internal Rev-
enue Code (Code). Section 1.148–3(i) of
the existing Income Tax Regulations pro-
vides that an issuer may recover an over-
payment of arbitrage rebate and similar pay-
ments on an issue oftax-exempt bonds if the
issuer establishes to the satisfaction of the
Commissioner that the overpayment occurred.
Rev.Proc. 2008–37 (2008–2 CB 137)
provides procedures for filing claims for the
refund of arbitrage rebate and similar pay-
ments and imposes a deadline for filing such
claims. In particular, a claim for a refund
must be filed no later than two years after
the final arbitrage computation date for the
issue from which the claim arose. A transi-
tion rule applies to issues with a final com-
putation date on or before June 24, 2008.
Like the Proposed Regulations, the final
regulations include this two-year limitation
on filing claims as well as the transition rule.
The final regulations also adopt the
rule in the Proposed Regulations that the
Commissioner may request additional in-
formation to support a claim, specify a
date for a return of that information, and
deny the claim if the information is not
returned by the date specified in the Com-
missioner’s request or, if the Commis-
sioner grants the issuer an extension to
provide the information, by the extension
date. Under both the Proposed Regula-
tions and final regulations, if the Commis-
sioner denies a claim because the Com-
missioner asserts that it was filed after the
two-year deadline or that the information
requested by the Commissioner was not
received by the date specified in the re-
quest for such additional information, the
issuer may appeal the denial to the Office
of Appeals. If the Office of Appeals con-
cludes that the claim was timely filed or
the requested information was timely sub-
mitted, as applicable, the case will be re-
turned to the Commissioner for further
consideration of the merits of the claim.
The final regulations amend the Pro-
posed Regulations to take into account a
comment received suggesting that the
Proposed Regulations be revised to pro-
vide a minimum time period for issuers to
respond to any request by the Commis-
sioner for additional information. In re-
sponse to this request, the final regulations
revise the Proposed Regulations to pro-
vide that issuers will be given at least 21
calendar days to respond to a request for
additional information. The 21 day period is
consistent with the time period provided by
the IRS in other instances for submitting
additional information. See, for example,
section 8.05 of Rev. Proc. 2014–1, 2014–1
IRB 1, 31 (providing taxpayers with 21 days
to submit additional information requested
by the IRS in connection with the evaluation
of a letter ruling request).
Another commenter questioned the
Commissioner’s authority to impose the
two-year limitation on filing of claims for
recovery of an overpayment of arbitrage
rebate. The commenter also expressed a
concern that an issuer’s right to proceed to
court could expire while the issuer’s claim
awaits review by the Commissioner.
Treasury and the IRS believe that the
Commissioner’s authority to impose the
two-year limitation arises from the broad
grant of authority to prescribe regulations
under section 148(i). In addition, an issuer’s
right to proceed to court cannot expire in the
manner suggested by the commenter be-
cause sections 6532 and 7422 apply to the
recovery of arbitrage rebate overpayments.
Under section 7422, a claim for the recovery
of an alleged arbitrage overpayment cannot
be filed in any court until a claim for such
amount has been filed with the Secretary.
Under section 6532, a proceeding to recover
an alleged overpayment ofarbitrage gener-
ally may not begin before the expiration of six
months from the date the claim required by
section 7422 has been filed with the Secretary,
nor after the expiration of two years from the
date the taxpayer is notified of the claim de-
nial. Thus, the final regulations adopt the two-
year limitation without change.
Certain changes made by the final reg-
ulations to the procedures for processing
arbitrage rebate overpayment claims are
December 1, 2014Bulletin No. 2014–49
908

not reflected in Rev. Proc. 2008–37. As a
result, the Treasury Department and the
IRS intend to publish guidance updating
Rev. Proc. 2008–37 to take into account
changes made by the final regulations.
Comments are requested on whether other
changes should be made to the procedures
as part of that guidance.
Effective/Applicability Date
In accordance with section 7805(b)(1)(C)
and Rev. Proc. 2008–37, § 1.148–3(i)(3)(i) of
the final regulations applies to refund
claims arising from an issue of bonds to
which § 1.148–3(i) applies and for which
the final computation date is after June 24,
2008. For purposes of applying § 1.148–
3(i)(3)(i), issues for which the actual final
computation date is on or before June 24,
2008, are deemed to have a final compu-
tation date of July 1, 2008. Section 1.148–
3(i)(3)(ii) and (iii) of the final regulations
apply to refund claims arising from an
issue of bonds to which § 1.148–3(i) ap-
plies and for which the final computation
date is after September 16, 2013.
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
determined that section 553(b) of the Ad-
ministrative Procedure Act (5 U.S.C.
chapter 5) does not apply to these regula-
tions. It is hereby certified that these reg-
ulations will not have a significant eco-
nomic impact on a substantial number of
small entities. Therefore, a Regulatory
Flexibility Analysis under the Regulatory
Flexibility Act (5 U.S.C. chapter 6) is not
required. The final regulations reaffirm or
clarify filing deadlines previously pub-
lished in other administrative guidance.
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 Administration for com-
ment on its impact on small business, and
no comments were received.
Drafting Information
The principal author of these regula-
tions is Timothy Jones, Office of Associ-
ate Chief Counsel (Financial Institutions
and Products), IRS. However, other per-
sonnel from the IRS and the Treasury
Department participated in their develop-
ment.
*****
Adoption of Amendments to the
Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by revising the entry for
§§ 1.148–0 through 1.148–11 to read in
part as follows:
Authority: 26 U.S.C. 7805***
Section 1.148–0 through 1.148–11
also issued under 26 U.S.C. 148(i).***
Par. 2. Section 1.148–0 is amended by
adding entries to paragraph (c) Table of
contents for §§ 1.148–3(i)(3) and 1.148–
11(k) and (l), and revising § 1.148–11
section heading to read as follows:
§ 1.148 – 0 Scope and table of contents.
*****
(c)***
*****
§ 1.148 –3 General arbitrage rebate
rules.
*****
(i)***
(3) Time and manner for requesting
refund.
*****
§ 1.148 –11 Effective/applicability dates.
*****
(k) [Reserved]
(l) Additional arbitrage guidance up-
dates.
(1) [Reserved]
(2) [Reserved]
(3) [Reserved]
(4) Application.
Par. 3. Section 1.148–3 is amended by
adding paragraph (i)(3) to read as follows:
§ 1.148 –3 General arbitrage rebate
rules.
*****
(i)***
(3)Time and manner for requesting
refund. (i) An issuer must request a refund
of an overpayment (claim) no later than
the date that is two years after the final
computation date for the issue to which
the overpayment relates (the filing dead-
line). The claim must be made using the
form provided by the Commissioner for
this purpose.
(ii) The Commissioner may request ad-
ditional information to support a claim.
The issuer must file the additional infor-
mation by the date specified in the Com-
missioner’s request, which date may be
extended by the Commissioner if unusual
circumstances warrant. An issuer will be
given at least 21 calendar days to respond
to a request for additional information.
(iii) A claim described in either para-
graph (i)(3)(iii)(A) or (B) of this section
that has been denied by the Commissioner
may be appealed to the Office of Appeals
under this paragraph (i)(3)(iii). Upon a de-
termination in favor of the issuer, the Office
of Appeals must return the undeveloped
case to the Commissioner for further con-
sideration of the substance of the claim.
(A) A claim is described in this para-
graph (i)(3)(iii)(A) if the Commissioner
asserts that the claim was filed after the
filing deadline.
(B) A claim is described in this para-
graph (i)(3)(iii)(B) if the Commissioner
asserts that additional information to sup-
port the claim was not submitted within
the time specified in the request for infor-
mation or in any extension of such spec-
ified time period.
*****
Par. 4. Section 1.148–11 is amended
by revising the section heading and add-
ing reserved paragraph (k) and paragraph
(l) to read as follows:
§ 1.148 –11 Effective/applicability dates.
*****
(k) [Reserved]
(l)Additional arbitrage guidance up-
dates.
(1) [Reserved]
(2) [Reserved]
Bulletin No. 2014–49December 1, 2014
909

(3) [Reserved]
(4)Application. (i) Section 1.148–
3(i)(3)(i) applies to claims arising from an
issue of bonds to which § 1.148–3(i) ap-
plies and for which the final computation
date is after June 24, 2008. For purposes
of this paragraph (l)(4), issues for which
the actual final computation date is on or
before June 24, 2008, are deemed to have a
final computation date of July 1, 2008 for
purposes of applying § 1.148–3(i)(3)(i).
(ii) Section 1.148–3(i)(3)(ii) and (iii)
apply to claims arising from an issue of
bonds to which § 1.148–3(i) applies and
for which the final computation date is
after September 16, 2013.
John Dalrymple,
Deputy Commissioner for
Services and Enforcement.
Approved: October 17, 2014.
Mark J. Mazur,
Assistant Secretary of the Treasury.
(Tax Policy).
(Filed by the Office of the Federal Register on November
12, 2014, 8:45 a.m., and published in the issue of the Federal
Register for November 13, 2014, 79 F.R. 67350)
Section 483.—.Interest on
Certain Deferred Payments
Thisruling provides the dollar amounts, increased
by the 2015 inflation adjustment, for section 1274A of
the Code. Rev. Rul. 2013–23 supplemented and super-
seded. See Rev. Rul. 2014–30, page 910.
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
This ruling provides the dollar amounts, in-
creased by the 2015 inflation adjustment, for section
1274A of the Code. Rev. Rul. 2013–23 supple-
mented and superseded. See Rev. Rul. 2014–30,
page 910.
Section 1274A.—Special
Rules for Certain
Transactions Where Stated
Principal Amount Does Not
Exceed $2,800,000
26 CFR 1.1274A–1: Special rules for certain trans-
actions where stated principal amount does not ex-
ceed $2,800,000. (Also §§ 483, 1274.)
Rev. Rul. 2014–30
This revenue ruling provides the dollar
amounts, increased by the 2015 inflation
adjustment, for § 1274A of the Internal
Revenue Code.
BACKGROUND
In general, §§ 483 and 1274 determine
the principal amount of a debt instrument
given in consideration for the sale or ex-
change of nonpublicly traded property. In
addition, any interest on a debt instrument
subject to § 1274 is taken into account
under the original issue discount provi-
sions of the Code. Section 1274A, how-
ever, modifies the rules under §§ 483 and
1274 for certain types of debt instruments.
In the case of a “qualified debt instru-
ment,” the discount rate used for purposes
of §§ 483 and 1274 may not exceed nine
percent, compounded semiannually. Sec-
tion 1274A(b) defines a qualified debt in-
strument as any debt instrument given in
consideration for the sale or exchange of
property (other than new § 38 property
within the meaning of § 48(b), as in effect
on the day before the date of enactment of
the Revenue Reconciliation Act of 1990)
if the stated principal amount of the in-
strument does not exceed the amount
specified in § 1274A(b). For debt instru-
ments arising out of sales or exchanges
before January 1, 1990, this amount is
$2,800,000.
In the case of a “cash method debt
instrument,” as defined in § 1274A(c), the
borrower and lender may elect to use the
cash receipts and disbursements method
of accounting. In particular, for any cash
method debt instrument, § 1274 does not
apply, and interest on the instrument is
accounted for by both the borrower and
the lender under the cash method of ac-
counting. A cash method debt instrument
is a qualified debt instrument that meets
the following additional requirements: (A)
In the case of instruments arising out of
sales or exchanges before January 1,
1990, the stated principal amount does not
exceed $2,000,000; (B) the lender does
not use an accrual method of accounting
and is not a dealer with respect to the
property sold or exchanged; (C) § 1274
would have applied to the debt instrument
but for an election under § 1274A(c); and
(D) an election under § 1274A(c) is
jointly made with respect to the debt in-
strument by the borrower and the lender.
Section 1.1274A–1(c)(1) of the Income
Tax Regulations provides rules concern-
ing the time for, and manner of, making
this election.
Section 1274A(d)(2) provides that, for
any debt instrument arising out of a sale or
exchange during any calendar year after
1989, the dollar amounts stated in
§ 1274A(b) and § 1274A(c)(2)(A) are in-
creased by the inflation adjustment for
the calendar year. Any increase due to the
inflation adjustment is rounded to the
nearest multiple of $100 (or, if the in-
crease is a multiple of $50 and not of
$100, the increase is increased to the near-
est multiple of $100). The inflation adjust-
ment for any calendar year is the percent-
age (if any) by which the CPI for the
preceding calendar year exceeds the CPI
for calendar year 1988. Section
1274A(d)(2)(B) defines the CPI for any
calendar year as the average of the Con-
sumer Price Index as of the close of the
12-month period ending on September 30
of that calendar year.
INFLATION-ADJUSTED AMOUNTS
UNDER § 1274A
For debt instruments arising out of
sales or exchanges after December 31,
1989, the inflation-adjusted amounts un-
der § 1274A are shown in Table 1.
December 1, 2014Bulletin No. 2014–49
910

Rev. Rul. 2014–30 Table 1
Inflation-Adjusted Amounts Under Section 1274A
Calendar Year of Sale
or Exchange
1274A(b) Amount
(qualified debt instrument)
1274A(c)(2)(A) Amount
(cash method debt instrument)
1990$2,933,200$2,095,100
1991$3,079,600$2,199,700
1992$3,234,900$2,310,600
1993$3,332,400$2,380,300
1994$3,433,500$2,452,500
1995$3,523,600$2,516,900
1996$3,622,500$2,587,500
1997$3,723,800$2,659,900
1998$3,823,100$2,730,800
1999$3,885,500$2,775,400
2000$3,960,100$2,828,700
2001$4,085,900$2,918,500
2002$4,217,500$3,012,500
2003$4,280,800$3,057,700
2004$4,381,300$3,129,500
2005$4,483,000$3,202,100
2006$4,630,300$3,307,400
2007$4,800,800$3,429,100
2008$4,913,400$3,509,600
2009$5,131,700$3,665,500
2010$5,115,100$3,653,600
2011$5,201,300$3,715,200
2012$5,339,300$3,813,800
2013$5,468,200$3,905,900
2014$5,557,200$3,969,500
2015$5,647,300$4,033,800
Note:These inflation adjustments were computed using the All-Urban, Consumer Price Index, 1982–1984 base, published
by the Bureau of Labor Statistics.
EFFECT ON OTHER DOCUMENTS
Rev. Rul. 2013–23, 2013–48 I.R.B.
590, is supplemented and superseded.
DRAFTING INFORMATION
The author of this revenue ruling is
Pradip Chandrasoma of the Office of As-
sociate Chief Counsel (Financial Institu-
tions & Products). For further information
regarding this revenue ruling, contact An-
drea Hoffenson at (202) 317-7053 (not a
toll-free number).
Bulletin No. 2014–49December 1, 2014
911

Part III. Administrative, Procedural, and Miscellaneous
Eligibility for Minimum
Essential Coverage Under
Pregnancy-Based Medicaid
and CHIP Programs
Notice 2014–71
PURPOSE
This notice provides guidance on eligi-
bility for minimum essential coverage for
purposes of the premium tax credit under
§ 36B of the Internal Revenue Code for
pregnancy-related Medicaid and Chil-
dren’s Health Insurance Program (CHIP)
programs.
BACKGROUND
Beginning in 2014, eligible individuals
covered under a qualified health plan
through a Health Insurance Marketplace,
also called an Exchange, are allowed a
premium tax credit under § 36B. Under
§ 36B and § 1.36B–2 of the Income Tax
Regulations, in general, coverage of an
individual (who may be the taxpayer
claiming the premium tax credit or a
member of the taxpayer’s family) may be
subsidized by the premium tax credit only
for months the individual is enrolled in a
qualified health plan through an Exchange
and is not eligible for other minimum es-
sential coverage.
In general, an individual is treated as
eligible for minimum essential coverage un-
der a government sponsored-program if the
individual meets the eligibility criteria for
coverage under the program. However, the
Commissioner may define eligibility for
minimum essential coverage under specific
government-sponsored programs in addi-
tional published guidance. Section 1.36B–
2(c)(2)(i).
Section 5000A(f)(1)(A) provides that
minimum essential coverage includes
coverage under the Medicaid program un-
der title XIX of the Social Security Act and
CHIP under title XXI of the Social Security
Act. An individual who becomes pregnant
may become eligible for Medicaid or CHIP
coverage solely because of that condition.
Because Medicaid coverage based on preg-
nancy under § 1902(a)(10)(A)(i)(IV) and
(a)(10)(A)(ii)(IX) of the Social Security Act
(42 U.S.C. 1396a(a)(10)(A)(i)(IV), (a)(10)(A)
(ii)(IX)) may provide limited benefits,
§ 1.5000A–2(b)(1)(ii)(C) provides that it
is not minimum essential coverage within
the meaning of § 5000A(f)(1)(A). Under
§ 5000A(f)(1)(E), the Secretary of Health
and Human Services (HHS), in coordina-
tion with the Secretary of the Treasury,
may designate health benefits coverage
not specified in § 5000A(f) as minimum
essential coverage. HHS has designated
pregnancy-based Medicaid coverage as
minimum essential coverage in states that
provide full Medicaid benefits under that
program. See Center for Medicaid and
CHIP Services letter to state health offi-
cials (SHO #14–002), November 7, 2014.
Under § 2112 of the Social Security
Act (42 U.S.C. 1397ll), states may expand
coverage under their CHIP programs to
targeted low-income pregnant women.
Pregnancy-related CHIP coverage pro-
vides full CHIP benefits and is minimum
essential coverage.
Medicaid or CHIP coverage as a result
of pregnancy applies only for the duration
of the pregnancy plus a period of up to 90
days afterwards. Without a special rule, an
individual enrolled in a qualified health
plan before the pregnancy would lose el-
igibility for the premium tax credit sub-
sidy for the coverage as a result of the
pregnancy. If, after the birth, the individ-
ual is not eligible for Medicaid or CHIP
coverage on another basis, she would be
required to re-enroll in a qualified health
plan to maintain coverage. (The loss of
Medicaid or CHIP coverage generally
makes an individual eligible for a special
enrollment period for a qualified health
plan.) The special rule announced in this
notice provides continuity of care to these
individuals.
GUIDANCE
An individual enrolled in a qualified
health plan who becomes eligible for
Medicaid coverage for pregnancy-related
services that is minimum essential cover-
age, or for CHIP coverage based on preg-
nancy, is treated as eligible for minimum
essential coverage under the Medicaid or
CHIP coverage for purposes of the pre-
mium tax credit only if the individual en-
rolls in the coverage.
EFFECTIVE DATE
This notice is effective on November 7,
2014.
DRAFTING INFORMATION
The principal author of this notice is
Arvind Ravichandran of the Office of the
Associate Chief Counsel (Income Tax and
Accounting). For further information re-
garding this notice, contact Mr. Ravichan-
dran at (202) 317-4718 (not a toll-free
number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2014–73
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I). The rates in this
notice reflect the application of § 430(h)
(2)(C)(iv), which was added by the
Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141
(MAP–21) and amended by section 2003
of the Highway and Transportation Fund-
ing Act of 2014, Public Law 113–159
(HATFA).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
December 1, 2014Bulletin No. 2014–49
912

ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies to
cash flows during specified periods. To the
extent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the ap-
plicable percentage of the 25-year average
segment rates for the period ending Septem-
ber 30 of the year preceding the calendar
year in which the plan year begins. How-
ever, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates.
Notice 2007–81, 2007–44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. In accor-
dance with the methodology specified in
Notice 2007–81, the monthly corporate
bond yield curve derived from October
2014 data is in Table I at the end of this
notice. The spot first, second, and third
segment rates for the month of October
2014 are, respectively, 1.29, 3.81, and
4.88.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) by the applicable per-
centage of the corresponding 25-year av-
erage segment rates. Section 2003(a) of
HATFA amended the applicable percent-
ages under § 430(h)(2)(C)(iv). This
change generally applies to plan years be-
ginning on or after January 1, 2013. How-
ever, pursuant to section 2003(e)(2) of
HATFA, a plan sponsor can elect not to
have the amendments made to the appli-
cable percentages by section 2003 of
HATFA apply to any plan year beginning
in 2013. These elections can be made ei-
ther for all purposes or, alternatively, for
purposes of determining the adjusted
funding target attainment percentage un-
der § 436. The 25-year average segment
rates for plan years beginning in 2012,
2013, 2014 and 2015 were published in
Notice 2012–55, 2012–36 I.R.B. 332, No-
tice 2013–11, 2013–11 I.R.B. 610, Notice
2013–58, 2013–40 I.R.B. 294, and Notice
2014–50, 2014–40 I.R.B. 590, respec-
tively.
For plan years beginning in years 2012
through 2017, pursuant to the changes
made by HATFA, the applicable mini-
mum percentage is 90% and the applica-
ble maximum percentage is 110%. These
applicable percentages are referred to as
HATFA applicable percentages. As de-
scribed in the preceding paragraph, a spe-
cial election is available for any plan year
beginning in 2013 under which this
change made by HATFA can be disre-
garded for all purposes or for limited pur-
poses. To the extent such an election is
made, the applicable minimum percentage
for a plan year beginning in 2013 is 85%
and the applicable maximum percentage
for that plan year is 115%. These applica-
ble percentages are referred to as
MAP–21 applicable percentages.
The three 24-month average corporate
bond segment rates applicable for Novem-
ber 2014 without adjustment for the 25-
year average segment rate limits are as
follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
November 20141.184.085.18
Based on § 430(h)(2)(C)(iv) as
amended by section 2003 of HATFA, the
24-month averages applicable for Novem-
ber 2014 adjusted for the HATFA appli-
cable percentages of the corresponding
25-year average segment rates, are as fol-
lows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates, Based on the HATFA
Applicable Percentage of 25-Year
Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2013November20145.236.517.16
2014November20144.996.326.99
2015November20144.726.116.81
Based on § 430(h)(2)(C)(iv) as in ef-
fect prior to amendment by section 2003
of HATFA, the three 24-month averages
applicable for November 2014 adjusted
for the MAP–21 applicable percentages of
the corresponding 25-year average seg-
ment rates, for plan years beginning in
2013, are as follows:
Bulletin No. 2014–49December 1, 2014
913

For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates, Based on the MAP-21
Applicable Percentage of 25-Year
Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2013November20144.946.156.76
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation de-
scribed in section 431(c)(6)(A), based on
the plan’s current liability. Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 per-
cent below the weighted average of the
rates of interest on 30-year Treasury se-
curities during the four-year period ending
on the last day before the beginning of the
plan year. Notice 88–73, 1988–2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for October 2014 is 3.04 percent.
The Service has determined this rate as
the average of the daily determinations of
yield on the 30-year Treasury bond ma-
turing in August 2044. The following
rates were determined for plan years be-
ginning in the month shown below.
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
November20143.383.043.55
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007–81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for October 2014
are as follows:
First
Segment
Second
Segment
Third
Segment
1.293.814.88
DRAFTING INFORMATION
The principal author of this notice is
Paul Stern of the Employee Plans, Tax
Exempt and Government Entities Divi-
sion. Mr. Stern may be e-mailed at
RetirementPlanQuestions@irs.gov.
December 1, 2014Bulletin No. 2014–49
914

Table I
Monthly Yield Curve for October 2014
Derived from October 2014 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.50.2520.54.5240.54.9260.55.0680.55.13
1.00.4921.04.5441.04.9261.05.0681.05.13
1.50.7421.54.5641.54.9361.55.0681.55.13
2.00.9722.04.5742.04.9362.05.0682.05.13
2.51.2122.54.5942.54.9462.55.0782.55.13
3.01.4423.04.6143.04.9463.05.0783.05.13
3.51.6623.54.6243.54.9563.55.0783.55.13
4.01.8624.04.6444.04.9564.05.0784.05.13
4.52.0624.54.6544.54.9664.55.0784.55.14
5.02.2525.04.6645.04.9665.05.0885.05.14
5.52.4325.54.6845.54.9765.55.0885.55.14
6.02.5926.04.6946.04.9766.05.0886.05.14
6.52.7526.54.7046.54.9766.55.0886.55.14
7.02.8927.04.7147.04.9867.05.0887.05.14
7.53.0327.54.7247.54.9867.55.0987.55.14
8.03.1628.04.7348.04.9868.05.0988.05.14
8.53.2828.54.7448.54.9968.55.0988.55.15
9.03.3929.04.7549.04.9969.05.0989.05.15
9.53.4929.54.7649.55.0069.55.0989.55.15
10.03.5930.04.7750.05.0070.05.0990.05.15
10.53.6730.54.7850.55.0070.55.1090.55.15
11.03.7631.04.7951.05.0171.05.1091.05.15
11.53.8331.54.8051.55.0171.55.1091.55.15
12.03.9032.04.8152.05.0172.05.1092.05.15
12.53.9632.54.8252.55.0172.55.1092.55.15
13.04.0233.04.8353.05.0273.05.1093.05.15
13.54.0833.54.8353.55.0273.55.1193.55.16
14.04.1334.04.8454.05.0274.05.1194.05.16
14.54.1734.54.8554.55.0374.55.1194.55.16
15.04.2135.04.8555.05.0375.05.1195.05.16
15.54.2535.54.8655.55.0375.55.1195.55.16
16.04.2936.04.8756.05.0376.05.1196.05.16
16.54.3236.54.8756.55.0476.55.1296.55.16
17.04.3537.04.8857.05.0477.05.1297.05.16
17.54.3837.54.8957.55.0477.55.1297.55.16
18.04.4138.04.8958.05.0578.05.1298.05.16
18.54.4338.54.9058.55.0578.55.1298.55.16
19.04.4639.04.9059.05.0579.05.1299.05.17
19.54.4839.54.9159.55.0579.55.1299.55.17
20.04.5040.04.9160.05.0580.05.12100.05.17
Bulletin No. 2014–49December 1, 2014
915

Part IV. Items of General Interest
Announcement 2014–33
AGENCY:Internal Revenue Service (IRS),
Treasury.
ACTION:Changes to the Internal Reve-
nue Bulletin (IRB).
SUMMARY:IRS will no longer publish
an index to the IRB starting with IRB
2015–01, due to the availability of elec-
tronic search tools, In addition, the fol-
lowing section will be eliminated from the
IRB; “INTERNAL REVENUE BULLE-
TINS ON CD-ROM” and “CUMULA-
TIVE BULLETINS.”
EFFECTIVE DATE:
January 5, 2015
SUPPLEMENTARY
INFORMATION:
Background
IRB Index
As of March 11, 2013, Announcement
2013–12, IRB 2013–11, the IRS ceased
publishing printed copies of the IRB, ren-
dering the index for printed copy unneces-
sary. Announcement 2014–27 published
July 7, 2014, I.R.B. 120, cited that due to the
availability of electronic search tools, and
after a 90 day comment period, the index
would be removed from the IRB.
INTERNAL REVENUE BULLETINS
ON CD-ROM SECTION
The IRB was available annually as part
of Publication 1796 (Tax Products CD-
ROM). This product was discontinued in
2012. The weekly Internal Revenue Bul-
letins are available atwww.irs.gov/irb.
CUMULATIVE BULLETINS SECTION
As of March 11, 2013, Announcement
2013–12, IRB 2013–11, the IRB has pro-
vided information regarding the cessation of
the Cumulative Bulletin, this section and
statement will not appear starting in 2015.
EFFECT ON OTHER DOCUMENTS:
Announcement 2013–12, 2013–11
I.R.B. 651, is supplemented. Announce-
ments 2008–87, 2008–02 I.R.B 843, is
supplemented.
December 1, 2014Bulletin No. 2014–49
916

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2014–49December 1, 2014
i

Numerical Finding List
1
Bulletins 2014–27 through 2014–49
Announcements:
2014-2, 2014-28 I.R.B.120
2014-28, 2014-34 I.R.B.391
2014-29, 2014-35 I.R.B.452
2014-31, 2014-46 I.R.B.827
2014-32, 2014-48 I.R.B.907
2014-33, 2014-49 I.R.B.916
Notices:
2014-40, 2014-27 I.R.B.100
2014-41, 2014-27 I.R.B.97
2014-42, 2014-34 I.R.B.387
2014-43, 2014-31 I.R.B.249
2014-44, 2014-32 I.R.B.270
2014-45, 2014-34 I.R.B.388
2014-46, 2014-36 I.R.B.520
2014-47, 2014-36 I.R.B.522
2014-48, 2014-36 I.R.B.523
2014-49, 2014-41 I.R.B.665
2014-50, 2014-40 I.R.B.590
2014-51, 2014-40 I.R.B.594
2014-52, 2014-42 I.R.B.712
2014-53, 2014-43 I.R.B.739
2014-54, 2014-41 I.R.B.670
2014-55, 2014-41 I.R.B.672
2014-56, 2014-41 I.R.B.674
2014-57, 2014-42 I.R.B.723
2014-58, 2014-44 I.R.B.746
2014-59, 2014-44 I.R.B.747
2014-60, 2014-43 I.R.B.743
2014-61, 2014-43 I.R.B.746
2014-62, 2014-44 I.R.B.749
2014-63, 2014-45 I.R.B.759
2014-64, 2014-45 I.R.B.759
2014-65, 2014-47 I.R.B.842
2014-66, 2014-46 I.R.B.820
2014-67, 2014-46 I.R.B.822
2014-68, 2014-47 I.R.B.842
2014-69, 2014-48 I.R.B.903
2014-70, 2014-48 I.R.B.905
2014-71, 2014-49 I.R.B.912
2014-73, 2014-49 I.R.B.912
Proposed Regulations:
REG-151416-06, 2014-47 I.R.B.870
REG-104579-13, 2014-33 I.R.B.370
REG-120756-13, 2014-31 I.R.B.252
REG-105067-14, 2014-34 I.R.B.391
REG-110948-14, 2014-30 I.R.B.239
REG-121542-14, 2014-28 I.R.B.119
REG-107012-14, 2014-33 I.R.B.371
REG-123286-14, 2014-33 I.R.B.377
REG-209459-78, 2014-31 I.R.B.253
REG-129507-14, 2014-38 I.R.B.561
Proposed Regulations:—Continued
REG-129786-14, 2014-38 I.R.B.562
REG-105739-11, 2014-41 I.R.B.704
REG-136676-13, 2014-45 I.R.B.814
Revenue Procedures:
2014-26, 2014-27 I.R.B.26
2014-27, 2014-27 I.R.B.41
2014-29, 2014-28 I.R.B.105
2014-37, 2014-33 I.R.B.363
2014-38, 2014-29 I.R.B.132
2014-39, 2014-29 I.R.B.151
2014-40, 2014-30 I.R.B.229
2014-41, 2014-33 I.R.B.364
2014-42, 2014-29 I.R.B.193
2014-43, 2014-32 I.R.B.273
2014-44, 2014-32 I.R.B.274
2014-45, 2014-34 I.R.B.388
2014-46, 2014-33 I.R.B.367
2014-47, 2014-35 I.R.B.393
2014-48, 2014-36 I.R.B.527
2014-49, 2014-37 I.R.B.535
2014-50, 2014-37 I.R.B.540
2014-51, 2014-37 I.R.B.543
2014-52, 2014-38 I.R.B.560
2014-53, 2014-39 I.R.B.573
2014-54, 2014-41 I.R.B.675
2014-55, 2014-44 I.R.B.753
2014-56, 2014-45 I.R.B.762
2014-57, 2014-45 I.R.B.777
2014-58, 2014-45 I.R.B.793
2014-59, 2014-47 I.R.B.843
2014-60, 2014-47 I.R.B.854
2014-61, 2014-47 I.R.B.860
Revenue Rulings:
2014-14, 2014-27 I.R.B.12
2014-19, 2014-32 I.R.B.266
2014-20, 2014-28 I.R.B.101
2014-21, 2014-34 I.R.B.381
2014-22, 2014-37 I.R.B.523
2014-23, 2014-40 I.R.B.575
2014-24, 2014-37 I.R.B.529
2014-25, 2014-40 I.R.B.574
2014-26, 2014-41 I.R.B.663
2014-26, 2014-41 I.R.B.663
2014-27, 2014-47 I.R.B.832
2014-28, 2014-45 I.R.B.756
2014-30, 2014-49 I.R.B.910
Treasury Decisions:
9664, 2014-32 I.R.B.254
9668, 2014-27 I.R.B.1
9669, 2014-28 I.R.B.103
9670, 2014-29 I.R.B.121
9671, 2014-29 I.R.B.124
9672, 2014-30 I.R.B.196
Treasury Decisions:—Continued
9673, 2014-30 I.R.B.212
9674, 2014-30 I.R.B.225
9675, 2014-31 I.R.B.242
9676, 2014-32 I.R.B.260
9677, 2014-31 I.R.B.241
9678, 2014-32 I.R.B.262
9679, 2014-32 I.R.B.267
9680, 2014-32 I.R.B.254
9681, 2014-33 I.R.B.340
9682, 2014-33 I.R.B.342
9683, 2014-33 I.R.B.330
9684, 2014-33 I.R.B.345
9685, 2014-34 I.R.B.379
9686, 2014-34 I.R.B.382
9687, 2014-36 I.R.B.486
9688, 2014-36 I.R.B.482
9689, 2014-36 I.R.B.456
9690, 2014-38 I.R.B.548
9691, 2014-38 I.R.B.547
9692, 2014-40 I.R.B.574
9693, 2014-41 I.R.B.596
9694, 2014-41 I.R.B.626
9695, 2014-42 I.R.B.707
9696, 2014-43 I.R.B.727
9697, 2014-43 I.R.B.729
9698, 2014-47 I.R.B.836
9699, 2014-46 I.R.B.818
9700, 2014-48 I.R.B.897
9701, 2014-49 I.R.B.908
9702, 2014-48 I.R.B.899
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014–01 through 2014–26 is in Internal Revenue Bulletin
2014–26, dated June 30, 2014.
December 1, 2014Bulletin No. 2014–49
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2014–27 through 2014–49
Announcements:
2008-87
Supplemented by
Ann. 2014-33, 2014-49 I.R.B.916
2012-11
Supplemented by
Ann. 2014-2, 2014-28 I.R.B.120
2013-11
Supplemented by
Ann. 2014-2, 2014-28 I.R.B.120
2013-12
Supplemented by
Ann. 2014-33, 2014-49 I.R.B.916
2010-41
Obsoleted by
Rev. Proc. 2014-43, 2014-32 I.R.B.273
Proposed Regulations:
84-102
Obsoleted by
REG-151416-06 2014-47 I.R.B.870
Revenue Procedures:
1981-38
Superseded by
Rev. Proc. 2014-42, 2014-29 I.R.B.193
93-37
Modified and Superseded by
Rev. Proc. 2014-43, 2014-32 I.R.B.273
1981-38
Modified by
Rev. Proc. 2014-42, 2014-29 I.R.B.193
2000-12
Superseded by
Rev. Proc. 2014-39, 2014-29 I.R.B.151
2002-23
Superseded by
Rev. Proc. 2014-55, 2014-44 I.R.B.753
2002-55
Revoked by
Rev. Proc. 2014-39, 2014-29 I.R.B.151
2003-64
Superseded by
Rev. Proc. 2014-47, 2014-35 I.R.B.393
Revenue Procedures—Continued:
2003-75
Superseded by
Rev. Proc. 2014-55, 2014-44 I.R.B.753
2004-21
Superseded by
Rev. Proc. 2014-47, 2014-35 I.R.B.393
2005-77
Superseded by
Rev. Proc. 2014-47, 2014-35 I.R.B.393
2011-14
Modified by
Rev. Proc. 2014-48, 2014-36 I.R.B.527
2011-14
Modified by
Rev. Proc. 2014-54, 2014-41 I.R.B.675
2011-16
Superseded by
Rev. Proc. 2014-51, 2014-37 I.R.B.543
2011-16
Modified by
Rev. Proc. 2014-51, 2014-51 I.R.B.543
2012-38
Superseded by
Rev. Proc. 2014-27, 2014-27 I.R.B.26
2012-46
Superseded by
Rev. Proc. 2014-26, 2014-27 I.R.B.41
2014-4
Amplified by
Rev. Proc. 2014-40, 2014-30 I.R.B.229
2014-4
Modified by
Rev. Proc. 2014-41, 2014-41 I.R.B.675
2014-5
Amplified by
Rev. Proc. 2014-40, 2014-30 I.R.B.229
2014-8
Amplified by
Rev. Proc. 2014-40, 2014-30 I.R.B.229
2014-9
Amplified by
Rev. Proc. 2014-40, 2014-30 I.R.B.229
2014-10
Amplified by
Rev. Proc. 2014-40, 2014-30 I.R.B.229
Revenue Procedures—Continued:
2014-13
Modified by
Rev. Proc. 2014-38, 2014-29 I.R.B.132
2014-13
Superseded by
Rev. Proc. 2014-38, 2014-29 I.R.B.132
2014-16
Superseded by
Rev. Proc. 2014-51, 2014-37 I.R.B.543
2014-16
Modified by
Rev. Proc. 2014-51, 2014-37 I.R.B.543
2014-12
Modified by
Rev. Proc. 2014-54, 2014-41 I.R.B.675
2014-17
Modified by
Rev. Proc. 2014-54, 2014-41 I.R.B.675
Revenue Rulings:
2008-40
Modified by
Rev. Rul. 2014-24, 2014-37 I.R.B.529
2011-1
Modified by
Rev. Rul. 2014-24, 2014-37 I.R.B.529
2012-6
Modified by
Rev. Rul. 2014-24, 2014-37 I.R.B.529
2013-23
Superseded by
Rev. Rul. 2014-30, 2014-49 I.R.B.910
2013-23
Supplemented by
Rev. Rul. 2014-30, 2014-49 I.R.B.910
Notices:
2010-62
Amplified by
Notice 2014-58, 2014-44 I.R.B.746
2013-1
Modified by
Notice 2014-61, 2014-43 I.R.B.746
2013-1
Superseded by
Notice 2014-61, 2014-43 I.R.B.746
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014–01 through 2014–26 is in Internal Revenue Bulletin 2014–26, dated June 30, 2014.
Bulletin No. 2014–49December 1, 2014
iii

Notices—Continued:
2013-11
Modified by
Notice 2014-48, 2014-36 I.R.B.523
2013-23
Modified by
Notice 2014-48, 2014-36 I.R.B.523
2013-28
Modified by
Notice 2014-48, 2014-36 I.R.B.523
2013-29
Modified by
Notice 2014-46, 2014-36 I.R.B.520
2013-29
Clarified by
Notice 2014-46, 2014-36 I.R.B.520
2013-32
Modified by
Notice 2014-48, 2014-36 I.R.B.523
2013-37
Modified by
Notice 2014-48, 2014-36 I.R.B.523
2013-38
Superseded by
Notice 2014-61, 2014-43 I.R.B.746
2013-51
Obsoleted by
Notice 2014-42, 2014-34 I.R.B.387
2013-60
Modified by
Notice 2014-46, 2014-36 I.R.B.520
2013-60
Clarified by
Notice 2014-46, 2014-36 I.R.B.520
2013-65
Superseded by
Notice 2014-57, 2014-42 I.R.B.723
2013-38
Superseded by
Notice 2014-61, 2014-43 I.R.B.746
2014-44
Supplemented by
Notice 2014-45, 2014-34 I.R.B.388
Treasury Decisions:
2005-47
Obsoleted by
T.D. 9668 2014-27 I.R.B.1
2010-51
Obsoleted by
T.D. 9684 2014-33 I.R.B.345
2010-71
Obsoleted by
T.D. 9684 2014-33 I.R.B.345
2011-6
Obsoleted by
T.D. 9684 2014-33 I.R.B.345
2011-9
Obsoleted by
T.D. 9684 2014-33 I.R.B.345
December 1, 2014Bulletin No. 2014–49
iv

INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available atwww.irs.gov/irb/.
CUMULATIVE BULLETINS
The contents of the weekly Bulletins were consolidated semiannually into permanent, indexed, Cumulative Bulletins through the
2008–2 edition.
INTERNAL REVENUE BULLETINS ON CD-ROM
Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be
purchased from National Technical Information Service (NTIS) on the Internet atwww.irs.gov/cdorders(discount for online orders)
or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.
We Welcome Comments About the Internal Revenue Bulletin
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
(www.irs.gov) or write to the IRS Bulletin Unit, SE:W:CAR:MP:P:SPA, Washington, DC 20224.
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300