Internal Revenue Bulletin 2014-25 (PDF rendition): IRS Announcements

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.
EMPLOYMENT TAX
Announcement 2014–25, page 1103.
This document contains corrections to final regulations (TD 9662)
that were published in theFederal Registeron Monday,
March 31, 2014 (79 FR 17860) relating to section 3504 of the
Internal Revenue Code (Code) providing circumstances under
which a person (payor) is designated to perform the acts
required of an employer and is liable for employment taxes with
respect to wages or compensation paid by the payor to indi-
viduals performing services for the payor’s client pursuant to a
service agreement between the payor and the client.
Finding Lists begin on page ii.
Index for July through June begins on page iv.
Bulletin No. 2014–25
June 16, 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.
June 16, 2014Bulletin No. 2014–25

Part IV. Items of General Interest
Designation of Payor to
Perform Acts Required of
an Employer; Correction
Announcement 2014–25
AGENCY:Internal Revenue Service (IRS),
Treasury.
ACTION: Correcting amendment.
SUMMARY: This document contains
corrections to final regulations (TD 9662)
that were published in theFederal Reg-
isteron Monday, March 31, 2014 (79 FR
17860) relating to section 3504 of the
Internal Revenue Code (Code) providing
circumstances under which a person
(payor) is designated to perform the acts
required of an employer and is liable for
employment taxes with respect to wages
or compensation paid by the payor to in-
dividuals performing services for the pay-
or’s client pursuant to a service agreement
between the payor and the client.
DATES: This correction is effective on
June 2, 2014 and is applicable March 31,
2014.
FOR FURTHER INFORMATION CON-
TACT: Jeanne Royal Singley at (202)
317-6798 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Background
The final regulations that are subject of
this document are under section 3504 of
the Internal Revenue Code.
Need for Correction
As published, final regulations (TD
9662) contain errors that may prove to be
misleading and are in need of clarification.
Correction of Publication
Accordingly, 26 CFR part 31 is cor-
rected by making the following correcting
amendments:
PART 31—EMPLOYMENT TAXES
AND COLLECTION OF INCOME
TAX AT THE SOURCE
Paragraph 1. The authority citation for
part 31 continues to read in part as fol-
lows:
Authority: 26 U.S.C. 7805***
§ 31.3504–2 [Corrected]
Par. 2. In § 31.3504–2, paragraph
(e)(9)Example 9.the language “Corpora-
tion U” is removed and the language
“Corporation V” is added in its place. d
Martin V. Franks
Chief, Publications and
Regulations Branch,
Legal Processing Division,
Associate Chief Counsel
(Procedure and Administration).
(Filed by the Office of the Federal Register on May 30,
2014, 8:45 a.m., and published in the issue of the Federal
Register for June 2, 2014, 79 F.R. 31219)
Bulletin No. 2014–25June 16, 2014
1103

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. 2014–25June 16, 2014
i

Numerical Finding List
1
Bulletins 2014–1 through 2014–25
Announcements
2014-1, 2014-2 I.R.B.393
2014-2, 2014-4 I.R.B.448
2014-4, 2014-7 I.R.B.523
2014-05, 2014-6 I.R.B.507
2014-06, 2014-6 I.R.B.508
2014-07, 2014-6 I.R.B.508
2014-08, 2014-6 I.R.B.508
2014-09, 2014-6 I.R.B.508
2014-10, 2014-6 I.R.B.508
2014-11, 2014-6 I.R.B.508
2014-12, 2014-6 I.R.B.509
2014-13, 2014-10 I.R.B.620
2014-14, 2014-16 I.R.B.948
2014-15, 2014-16 I.R.B.973
2014-16, 2014-17 I.R.B.983
2014-17, 2014-18 I.R.B.1007
2014-18, 2014-17 I.R.B.983
2014-19, 2014-17 I.R.B.984
2014-20, 2014-20 I.R.B.1027
2014-21, 2014-20 I.R.B.1030
2014-22, 2014-22 I.R.B.1071
2014-23, 2014-22 I.R.B.1072
2014-24, 2014-23 I.R.B.1086
2014-25, 2014-25 I.R.B.1103
Notices
2014-1, 2014-2 I.R.B.270
2014-2, 2014-3 I.R.B.407
2014-3, 2014-3 I.R.B.408
2014-4, 2014-2 I.R.B.274
2014-5, 2014-2 I.R.B.276
2014-6, 2014-2 I.R.B.279
2014-7, 2014-4 I.R.B.445
2014-8, 2014-5 I.R.B.452
2014-9, 2014-5 I.R.B.455
2014-10, 2014-9 I.R.B.605
2014-11, 2014-13 I.R.B.880
2014-12, 2014-9 I.R.B.606
2014-13, 2014-10 I.R.B.616
2014-14, 2014-13 I.R.B.881
2014-15, 2014-12 I.R.B.661
2014-16, 2014-14 I.R.B.920
2014-17, 2014-13 I.R.B.881
2014-18, 2014-15 I.R.B.926
2014-19, 2014-17 I.R.B.979
2014-20, 2014-16 I.R.B.937
2014-21, 2014-16 I.R.B.938
2014-22, 2014-16 I.R.B.940
2014-23, 2014-16 I.R.B.942
2014-24, 2014-16 I.R.B.942
2014-25, 2014-17 I.R.B.981
2014-27, 2014-18 I.R.B.987
2014-28, 2014-18 I.R.B.990
Notices—Continued
2014-29, 2014-18 I.R.B.991
2014-31, 2014-20 I.R.B.1006
2014-32, 2014-20 I.R.B.1006
2014-33, 2014-21 I.R.B.1033
2014-34, 2014-23 I.R.B.1069
2014-35, 2014-23 I.R.B.1072
2014-36, 2014-22 I.R.B.1058
2014-37, 2014-24 I.R.B.1100
2014-38, 2014-24 I.R.B.1100
Proposed Regulations
REG–15489,0–03 2014-6 I.R.B.504
REG–15942,0–04 2014-2 I.R.B.374
REG–14446,8–05 2014-6 I.R.B.474
REG–16319,5–05 2014-15 I.R.B.930
REG–11930,5–11 2014-8 I.R.B.524
REG–14097,4–11 2014-3 I.R.B.438
REG–12153,4–12 2014-6 I.R.B.473
REG–12270,6–12 2014-11 I.R.B.647
REG–13436,1–12 2014-13 I.R.B.895
REG–13698,4–12 2014-2 I.R.B.378
REG–11335,0–13 2014-3 I.R.B.440
REG–13096,7–13 2014-13 I.R.B.884
REG–13123,9–13 2014-22 I.R.B.1069
REG–14103,6–13 2014-7 I.R.B.516
REG–14317,2–13 2014-2 I.R.B.383
REG–15076,0–13 2014-23 I.R.B.1078
REG–10864,1–14 2014-15 I.R.B.928
Revenue Procedures
2014-1, 2014-1 I.R.B.1
2014-2, 2014-1 I.R.B.90
2014-3, 2014-1 I.R.B.111
2014-4, 2014-1 I.R.B.125
2014-5, 2014-1 I.R.B.169
2014-6, 2014-1 I.R.B.198
2014-7, 2014-1 I.R.B.238
2014-8, 2014-1 I.R.B.242
2014-9, 2014-2 I.R.B.281
2014-10, 2014-2 I.R.B.293
2014-11, 2014-3 I.R.B.411
2014-12, 2014-3 I.R.B.415
2014-13, 2014-3 I.R.B.419
2014-14, 2014-2 I.R.B.295
2014-15, 2014-5 I.R.B.456
2014-16, 2014-9 I.R.B.606
2014-17, 2014-12 I.R.B.661
2014-18, 2014-7 I.R.B.513
2014-19, 2014-10 I.R.B.619
2014-20, 2014-9 I.R.B.614
2014-21, 2014-11 I.R.B.641
2014-22, 2014-11 I.R.B.646
2014-23, 2014-12 I.R.B.685
2014-24, 2014-13 I.R.B.879
2014-25, 2014-15 I.R.B.927
2014-28, 2014-16 I.R.B.944
2014-30, 2014-20 I.R.B.1009
Revenue Procedures—Continued
2014-31, 2014-20 I.R.B.1009
2014-32, 2014-23 I.R.B.1073
2014-33, 2014-22 I.R.B.1065
Revenue Rulings
2014-1, 2014-2 I.R.B.263
2014-2, 2014-2 I.R.B.255
2014-3, 2014-2 I.R.B.259
2014-4, 2014-5 I.R.B.449
2014-6, 2014-7 I.R.B.510
2014-8, 2014-11 I.R.B.624
2014-9, 2014-17 I.R.B.975
2014-10, 2014-14 I.R.B.906
2014-11, 2014-14 I.R.B.906
2014-12, 2014-15 I.R.B.923
2014-13, 2014-19 I.R.B.1003
2014-15, 2014-24 I.R.B.1095
2014-16, 2014-24 I.R.B.1097
2014-17, 2014-24 I.R.B.1093
Treasury Decisions
9649, 2014-2 I.R.B.265
9650, 2014-3 I.R.B.394
9651, 2014-4 I.R.B.441
9652, 2014-12 I.R.B.655
9653, 2014-6 I.R.B.460
9654, 2014-6 I.R.B.461
9655, 2014-9 I.R.B.541
9656, 2014-11 I.R.B.626
9657, 2014-13 I.R.B.687
9658, 2014-13 I.R.B.748
9659, 2014-12 I.R.B.653
9660, 2014-13 I.R.B.842
9661, 2014-13 I.R.B.855
9662, 2014-16 I.R.B.933
9663, 2014-22 I.R.B.1038
9664, 2014-22 I.R.B.1045
9665, 2014-22 I.R.B.1050
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin
2013–52, dated December 23, 2013.
June 16, 2014Bulletin No. 2014–25
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2014–1 through 2014–25
Announcements:
2007-44
Modified by
Ann. 2014-4, 2014-7 I.R.B.523
2011-49
Modified by
Ann. 2014-4, 2014-7 I.R.B.523
Notices:
2002-23
Superseded by
Notice 2014-35, 2014-23 I.R.B.1072
2003-37
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2006-87, 2006-2 C.B. 766
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2006-109
Modified by
Notice 2014-4, 2014-2 I.R.B.274
2007-25, 2007-1 C.B. 760
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2007-59
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2007-77, 2007-2 C.B. 735
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2008-107, 2008-2 C.B. 1266
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2009-78
Superseded by
T.D. 9654 2014-6 I.R.B.461
2010-27, 2010-1 C.B. 531
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
Notices—Continued:
2010-27, 2010-1 C.B. 531
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2011-14
Modified by
Rev. Proc. 2014-33, 2014-22 I.R.B.1065
2013-1
Modified by
Notice 2014-22, 2014-16 I.R.B.940
2013-1
Modified by
Notice 2014-38, 2014-24 I.R.B.1100
2013-13
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2013-17
Amplified by
Notice 2014-1, 2014-2 I.R.B.270
2014-22
Superseded by
Notice 2014-38, 2014-24 I.R.B.1100
Revenue Procedures:
2003-49
Modified and superseded by
Rev. Proc. 2014-14, 2014-2 I.R.B.295
2004-42
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2004-43
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2011-4
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2011-14
Modified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2011-14
Clarified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2011-14
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
Revenue Procedures—Continued:
2011-44
Modified and Superseded by
Rev. Proc. 2014-11, 2014-3 I.R.B.411
2011-49
Modified by
Rev. Proc. 2014-6, 2014-1 I.R.B.198
2012-14
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2012-19
Modified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2012-19
Superseded by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2012-20
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2012-20
Superseded by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2013-1
Superseded by
Rev. Proc. 2014-1, 2014-1 I.R.B.1
2013-2
Superseded by
Rev. Proc. 2014-2, 2014-1 I.R.B.90
2013-3
Superseded by
Rev. Proc. 2014-3, 2014-1 I.R.B.111
2013-4
Superseded by
Rev. Proc. 2014-4, 2014-1 I.R.B.125
2013-5
Superseded by
Rev. Proc. 2014-5, 2014-1 I.R.B.169
2013-6
Superseded by
Rev. Proc. 2014-6, 2014-1 I.R.B.198
2013-7
Superseded by
Rev. Proc. 2014-7, 2014-1 I.R.B.238
2013-8
Superseded by
Rev. Proc. 2014-8, 2014-1 I.R.B.242
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23,
2013.
Bulletin No. 2014–25June 16, 2014
iii

Revenue Procedures—Continued:
2013-9
Superseded by
Rev. Proc. 2014-9, 2014-2 I.R.B.281
2013-10
Superseded by
Rev. Proc. 2014-10, 2014-2 I.R.B.293
2013-22
Modified by
Rev. Proc. 2014-28, 2014-16 I.R.B.944
2013-24
Obsoleted by
Rev. Proc. 2014-23, 2014-12 I.R.B.685
2013-27
Obsoleted by
Rev. Proc. 2014-23, 2014-12 I.R.B.685
2013-28
Obsoleted by
Rev. Proc. 2014-31, 2014-20 I.R.B.1009
2013-32
Superseded in part by
Rev. Proc. 2014-1, 2014-1 I.R.B.1, and
Rev. Proc. 2014-3, 2014-1 I.R.B.111
2014-1
Amplified by
Rev. Proc. 2014-18, 2014-7 I.R.B.513
2014-1 I.R.B. 111
Amplified by
Rev. Proc. 2014-24, 2014-13 I.R.B.879
2014-3
Amplified by
Rev. Proc. 2014-18, 2014-7 I.R.B.513
2014-3 I.R.B 111
Amplified by
Rev. Proc. 2014-24, 2014-13 I.R.B.879
2014-4
Modified by
Rev. Proc. 2014-19, 2014-10 I.R.B.619
Proposed Regulations:
209054-87
A portion withdrawn by
REG-113350-13 2014-3 I.R.B.440
Revenue Rulings:
2005-40
Distinguished by
Rev. Rul. 2014-15, 2014-24 I.R.B.1095
2005-48 (2005-2 CB 259)
Obsoleted by
T.D. 9659 2014-12 I.R.B.653
Revenue Rulings—Continued:
2013-17
Amplified by
Notice 2014-19, 2014-17 I.R.B.979
2013-17
Amplified by
Notice 2014-25, 2014-17 I.R.B.981
2002-89
Distinguished by
Rev. Rul. 2014-15, 2014-24 I.R.B.1095
Treasury Decision:
9644
Correction by
Ann. 2014-18, 2014-17 I.R.B.983
9644
Correction by
Ann. 2014-19, 2014-17 I.R.B.984
June 16, 2014Bulletin No. 2014–25
iv

INDEX
Internal Revenue Bulletins 2014–1 through
2014–25
The abbreviation and number in parenthesis following the index
entry refer to the specific item; numbers in roman and italic type
following the parentheses refer to the Internal Revenue Bulletin in
which the item may be found and the page number on which it
appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
ADMINISTRATIVE
Average area purchase price safe-harbors guidance for 2014 (RP 31)
20,1009
Consolidated returns; d failure to p[roperly include subsidiary
(RP 24) 13,879
Extension of time to file estate tax return to elect portability of a
deceased spousal unused exclusion amount under section
2010(c)(5)(A). (RP 18) 7,513
Method change procedures for dispositions of tangible deprecia-
ble property (RP 17) 12,661
Maximum Vehicle Values for which the special valuation rules
of regulations section 1.61–21(d) and (e) may be used (Notice 11)
13,880
Minimum essential coverage, information reporting (TD 9660)
13,842
Regulations:
26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR
1.6081–8 amended. 26 CFR 301.6011–2 amended. 26
CFR 301.6721–1 amended. 26 CFR 1.6011–8 amended.
26 CFR 301.6722–1 amended; minimum essential cover-
age, information reporting (TD 9660) 13,842
Per Capita Payments from Proceeds of Settlements of Indian
Tribal Trust Cases (Notice 22) 16,940
Per Capita Payments from Proceeds of Settlements of Indian
Tribal Trust Cases (Notice 38) 24,1100
Virtual Currency (Notice 21) 16,938
EMPLOYEE PLANS
Definition of a substantial risk of forfeiture (TD 9659) 12,653
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Excepted benefits (REG–143172–13) 2,383
EMPLOYEE PLANS—Cont.
Final rules to implement the 90-day waiting period limitation
(TD 9656) 11,626
Letter rulings:
And determination letters:
Areas which will not be issued from Associate Chief
Counsel and Division counsel (TE/GE) (RP 3) 1,111
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 1,281
And general information letters; procedures (RP 4) 1,125
User fees, request for letter rulings (RP 8) 1,242
Letter rulings and general information letters (RP 4) 1,125
Letter rulings or determination letters (RP 1) 1,1
Proposed rules to clarify length of reasonable and bona fide
employment-based orientation period, consistent with the 90-
day waiting period limitation (REG–122706–12) 11,647
Qualification, determination letters (RP 6) 1,198
Qualified plans:
Application of the Windsor Decision and Rev. Rul. 2013–17
(Notice 19) 17,979
Determination Letters (RP 19) 10,619
Discrimination (Notice 5) 2,276
Filing Requirements (Notice 35) 23,1072
Filing Requirements (RP 32) 23,1073
Mid-Year Amendments (Notice 37) 24,1100
Opinion letters (Ann 4) 7,523
Opinion letters (Ann 16) 17,523
Qualified retirement plans covered compensation, permitted dis-
parity (RR 3) 2,259
Qualified retirement plans
Rollovers (RR 9) 17,975
Proposed Regulation:
26 CFR 54.9815–2708, amended; REG–122706–12) 11,647
Removal of the Qualified Payment Card Agent Program (REG–
163195–05) 15,930
Request for Information Regarding Provider Non-Discrimination
(REG–108641–14) 15,928
Rulings and determination letters, user fees (RP 8) 1,242
Technical advice memorandum or TAM (RP 2) 1,90
Technical advice procedures (RP 5) 1,169
Full funding limitations, weighted average interest rates, segment
rates for:
January 2014 (Notice 8) 5,452
Weighted average interest rates
Segment rates for February 2014 (Notice 13) 10,616
Segment rates for March 2014 (Notice 16) 14,920
Segment rates for March 2014 (Notice 27) 18,987
Segment rates for May 2014 (Notice 34) 23,1069
EMPLOYMENT TAX
Definitions and Reporting Requirements for Shareholders of
Passive Foreign Investment Companies; Corrected; Reg–
112966–10 (Ann 25) 25,1103
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Bulletin No. 2014–25June 16, 2014
v

EMPLOYMENT TAX—Cont.
Employment tax liability of agents authorized under section 3504
(TD 9649) 2,265
Employment tax obligations of a third party that enters into a
service agreement with an employer to take on the employer’s
employment tax responsibilities (TD 9662) 16,933
Letter rulings or determination letters (RP 1) 1,1
Proposed Regulation:
26 CFR 54.9815–2708, amended; REG–122706–12) 11,647
Regulations:
26 CFR 31–3504–2, added; employment tax obligations of a
third party that enters into a service agreement with an
employer to take on the employer’s employment tax re-
sponsibilities (TD 9662) 16,933
26 CFR 1.83–3 is revised; definition of a substantial risk of
forfeiture (TD 9659) 12,653
26 CFR 54,9801–1, thru–6, amended; 26 CFR 54.9802–1,
amended; 26 CFR 54.9815–2708, added; 26 CFR
54.9831–1, amended (TD 9656) 12,626
Technical Advice Memorandum (TAM) (RP 2) 1,90
Virtual Currency (Notice 21) 16,90
ESTATE TAX
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Extension of time to file estate tax return to elect portability of a
deceased spousal unused exclusion amount under section
2010(c)(5)(A) (RP 18) 7,513
Letter rulings or determination letters (RP 1) 1,1
Technical Advice Memorandum (TAM) (RP 2) 1,90
EXCISE TAX
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Final rules to implement the 90-day waiting period limitation
(TD 9656) 11,626
Information reporting by applicable large employers on health
insurance coverage offered under employer-sponsored plans
(TD 9661) 13,855
Interim guidance regarding supporting organizations (Notice 4)
2,274
Letter rulings or determination letters (RP 1) 1,1
Notice for ACA Section 9010 Health Insurance Providers Fee
and expatriate plans (Notice 14) 16,942
Proposed rules to clarify length of reasonable and bona fide
employment-based orientation period, consistent with the 90-
day waiting period limitation (REG–122706–12) 11,647
Proposed Regulation:
26 CFR 54.9815–2708, amended; REG–122706–12) 11,647
Regulations:
301.6056–1, –2, added; Information reporting by applicable
large employers on health insurance coverage offered un-
der employer-sponsored plans (TD 9661) 13,855
26 CFR 54,9801–1, thru–6, amended; 26 CFR 54.9802–1,
amended; 26 CFR 54.9815–2708, added; 26 CFR
54.9831–1, amended (TD 9656) 12,626
Technical Advice Memorandum (TAM) (RP 2) 1,90
EXEMPT ORGANIZATIONS
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Form 990 Revenue Procedure update to revoke Revenue Proce-
dure 79–6 (RP 22) 11,646
Interim guidance regarding supporting organizations (Notice 4)
2,274
Letter rulings:
And determination letters:
Areas which will not be issued from Associate Chief
Counsel and Division counsel (TE/GE) (RP 3) 1,111
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 1,281
And general information letters; procedures (RP 4) 1,125
User fees, request for letter rulings (RP 8) 1,242
Letter rulings (RP 10) 2,293; (RP 9) 2,281
Letter rulings or determination letters (RP 1) 1,1
Proposed procedures for charitable hospitals to correct and dis-
close failures to meet section 501(r) (Notice 3) 3,408
Reliance on proposed regulations for tax-exempt hospitals
(Notice 2) 3,407
Rulings and determination letters, user fees (RP 8) 1,242
Technical Advice Memorandum (TAM) (RP 2) 1,90
Technical advice procedures (RP 5) 1,169
INCOME TAX
Accounting method change, sales-base royalties and vendor al-
lowances (RP 33) 22,1065
Acquiring Corporation for Purposes of Section 381 (REG–
131239–13) 22,1069
Adequate disclosure revenue procedure (RP 15) 5,456
Advance Pricing and Mutual Agreement Program (Ann 14) 16,
948
Allocation of section 47 credits by a partnership to its partners
(RP 12) 3,415
Allocation of section 752 recourse liabilities among related par-
ties (REG–136984–12) 2,378
Amount of the life insurance reserves taken into account under
§ 807 of the Internal Revenue Code for variable contracts (RR 7)
9,539
Areas in which rulings will not be issued; Associate Chief
Counsel (International) (RP 7) 1,238
Average area purchase price safe-harbors guidance for 2014
(RP 31) 20,1009
Basis in assets of tax exempt trusts (REG–154890–03) 6,504
Bond premium carryforward (TD 9653) 6,460
Cafeteria plans, FSA reimbursements, and HSA contribution
limits for same-sex spouses (Notice 1) 2,270
2014 Census Count (Notice 12) 9,606
Contribution of built-in lost property to a partnership; mandatory
basis adjustments in the event of a substantial built-in loss or
substantial basis reduction; modification of basis allocation
rules (REG–144468–05) 6,474
June 16, 2014Bulletin No. 2014–25
vi

INCOME TAX—Cont.
Current refunding of Recovery Zone facility bonds (Notice 9) 5,
455
Declaratory judgement suits (Ann 5) 6,507; (Ann 6) 6,507;
(Ann 7) 6,508; (Ann 8) 6,508; (Ann 9) 6,508; (Ann 10) 6,
508; (Ann 12) 6,509
Definition of a substantial risk of forfeiture (TD 9659) 12,653
Definitions applicable to U.S. persons owning interests in passive
foreign investment companies (REG–113350–13) 3,440
Depreciation, asset class, ethanol plants (RR 17) 24,641
Depreciation deduction, limitations on certain automobiles
(RP 21) 11,641
Determination of housing cost eligible exclusion or deduction for
2014 (Notice 29) 18,991
Determination of ownership in a passive foreign investment
company; annual filing requirements for shareholders of
passive foreign investment companies; filing requirements
for constructive owners in certain foreign corporations
(REG–140974–11) 3,438; (TD 9650) 3,394
correction (Ann 22) 22,1071
Determining stock ownership for purposes of whether an
entity is a surrogate foreign corporation (TD 9654) 6,461;
(REG–121534–12) 6,473
Discharge of indebtedness secured by real property (RP 20) 9,
614
Disciplinary actions involving attorneys, certified public ac-
countants, enrolled agents, and enrolled actuaries (Ann 13)
10,620
Disciplinary actions involving attorneys, certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 20) 20,
1027
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Equity-linked instruments and dividend equivalents (Notice 14)
13,881
FATCA financial institution registration update (Ann 1) 2,393
FATCA IGA and registration update (Ann 17) 18,1001
Final FFI agreement for participating FFI and reporting Model 2
FFI (RP 13) 3,419
Foreign Earned Income Exclusion (RP 25) 15,927
Further guidance on FATCA implementation and related with-
holding provisions (Notice 33) 21,1033
2014 – 2015 Guidance Priority List- Solicitation Notice (Notice 18)
15,926
Guidance regarding reinstatement following auto revocation of
tax-exempt status under section 6033(j) (RP 11) 3,411
Income tax treatment of per capita payments made from funds held
in trust by the Secretary of the Interior (Notice 17) 13,881
2015 Inflation adjusted amounts for Health Savings Accounts
(HSAs) (RP 30) 20,1009
Inflation Adjustment Factors (Notice 36) 22,1058
Information reporting by foreign financial institutions and with-
holding on payments to foreign financial institutions and other
foreign entities (REG–130967–13) 13,884
Information reporting by foreign financial institutions and with-
holding on payments to foreign financial institutions and other
foreign entities (TD 9657) 13,687
INCOME TAX—Cont.
Interest:
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2014 (RR 1) 2,263
February 2014 (RR 6) 7,510
March 2014 (RR 8) 11,624
April 2014 (RR 12) 15,923
May 2014 (RR 13) 19,1003
June 2014 (RR 16) 24,1097
Intra-group gross receipts (REG–159420–04) 2,374
Insurance tax, insurance companies, interest rate tables (RR 4) 5,449
Letter rulings or determination letters (RP 1) 1,1
Low-Income Housing Credit (Notice 15) 12,661
Maximum Vehicle Values for which the special valuation rules
of regulations section 1.61–21(d) and (e) may be used (Notice
11) 13,880
Method change procedures for dispositions of tangible deprecia-
ble property (RP 17) 12,661
Minimum essential coverage, information reporting (TD 9660)
13,842
Net investment income tax; TD 9644 Correction (Ann 2014–18)
17,983
Net investment income tax; TD 9644 Correction (Ann 2014–19)
17,984
Postponement of deadline for § 165(i) election for losses attrib-
utable to September 2013 major flooding in Colorado (Notice
20) 16,937
Premium tax credit (TD 9663) 22,1038
Principal residence, treatment of National Mortgage Settlement
payments (RR 2) 2,255
Qualified census tracts (RP 14) 2,295
Real Estate Investment Trust (REG–150760–13) 23,1078
Refundable Credit For Coverage Under a Qualified Health Plan,
Definition and Rules Relating to Applicable Taxpayer (Notice
23) 16,942
Regarding disguised sales, generally (REG–119305–11) 8,524
Removal of the Qualified Payment Card Agent Program (REG–
163195–05) 15,930
Retiree Health Benefits Provided Through Employer’s Wholly-
Owned Subsidiary (RR–15) 24,1095
26 CFR 1.6045–1T: Returns of information of brokers and barter
exchanges (temporary), correction to TD 9658 (Ann 21) 20,
1030
Revocations, exempt organization (Ann 11) 6,508
Sales-bases royalties and vendor allowances (TD 9652) 12,655
2013 Section 45K Inflation Adjustment Factor – Nonconven-
tional Fuel source Credit (Notice 25) 17,981
Section 67 Limitations on Estates or Trusts (REG–128224–06)
22,1046
Shared responsibility for employers regarding health coverage
(TD 9655) 9,541
Shared responsibility payment for not maintaining minimum
essential coverage (REG–141036–13) 7,541
Standard Industry Fare Level (SIFL) (RR 10) 14,906
Tangible property regulations method change guidance (RP 16)
9,606
Bulletin No. 2014–25June 16, 2014
vii

INCOME TAX—Cont.
Tax Treatment of Qualified Retirement Plan Payment of Acci-
dent or Health Insurance Premiums (TD 9665) 22,1050
Technical Advice Memorandum (TAM) (RP 2) 1,90
Transition relief for the tax credit for employee health insurance
expenses of certain small employers (Notice 6) 2,279
Transition relief under section 5000A for certain individuals
without minimum essential coverage (Notice 10) 9,605
Treatment of Income from certain government bonds held by
certain active banks for purposes of the passive foreign invest-
ment company (PFIC) rules (Notice 31) 20,1006
Treatment of Property Used To Acquire Parent Stock or Secu-
rities in Certain Triangular Reorganizations Involving Foreign
Corporations (Notice 32) 20,1006
Treatment of U.S. persons that own stock of passive foreign
investment companies through certain organizations and ac-
counts that are tax exempt (Notice 28) 18,990
Underpayment and overpayments, quarter beginning: April 1,
2014 (RR 11) 14,906
Virtual Currency (Notice 21) 16,938
Withholding of tax on certain U.S. source income paid to foreign
persons and revision of information reporting and backup
withholding regulations (REG–134361–12) 13,895
Withholding of tax on certain U.S. source income paid to foreign
persons and revision of information reporting and backup
withholding regulations (TD 9658) 13,748
Proposed Regulations:
26 CFR 1.856–10 added; 1.856–3 modified: definition of real
estate investment trust real property (REG–150760–13)
23,1078
26 CFR 301.6724–1(c)(6), amended; 26 CFR 31.3406(g)–
1(f), 26 CFR 301.6724–1(e)(1)(vi)(H), and 26 CFR
301.6724–1(f)(5)(vii), removed;removal of the qualified
payment ard agent program (REG–163195–05) 15,930
26 CFR 1.1471–0, amended; 26 CFR 1.1471–1, amended; 26
CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26
CFR 1.1471–4, amended; 26 CFR 1.1471–5, amended; 26
CFR 1.1471–6, amended; 26 CFR 1.1472–1, amended; 26
CFR 1.1473–1, amended; 26 CFR 1474–1, amended; 26
CFR 1.1474–6, amended. (Reg–130967–13) 13,930
26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26
CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26
CFR 1.441–6, amended; 26 CFR 1.1441.7, amended; 26
CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26
CFR 1.6041–1, amended; 26 CFR 1.6041–4, amended; 26
CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26
CFR 1.6045–1, amended; 26 CFR 1.6049–4, amended; 26
CFR 1.6049–5, amended; 26 CFR 31.3406(g)–1, amend-
ed; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3,
amended; Withholding of tax on certain U.S. source in-
come paid to foreign persons and revision of information
reporting and backup withholding regulations (REG–
134361–12) 13,895
INCOME TAX—Cont.
Regulations:
26 CFR 1.67–4, added; 1.67–4T, removed (TD 9664) 22,
1045
26 CFR 1.83–3 is revised; definition of a substantial risk of
forfeiture (TD 9659) 12,653
26 CFR 1.263A–0, thru–3, amended; 1.471–3 amended;
sales-base royalties and vendor allowances (TD 9652) 12,
655
26 CFR 1.36B–0 amended (TD 9663) 22,1022
26 CFR 1.36B–5 amended (TD 9663) 22,1022
26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR
1.6081–8 amended. 26 CFR 301.6011–2 amended. 26
CFR 301.6721–1 amended. 26 CFR 1.6011–8 amended.
26 CFR 301.6722–1 amended. (TD 9660) 13,842
26 CFR 1.72–15, amended, 26 CFR 1.105–4, removed, 26
CFR 1.105–6, removed, 26 CFR 1.106–1, amended, 26
CFR 1.401–1, amended, 26 CFR 1.402(c)–2, amended;
Tax Treatment of Qualified Retirement Plan Payment of
Accident or Health Insurance Premiums (TD 9665) 22,
1050
26 CFR 1.1471–0, amended; 26 CFR 1.1471–1, amended; 26
CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26
CFR 1.1471–4, amended; 26 CFR 1.1471–5, amended; 26
CFR 1.1471–6, amended; 26 CFR 1.1472–1, amended; 26
CFR 1.1473–1, amended; 26 CFR 1474–1, amended; 26
CFR 1.1474–6, amended. (TD 9657) 13,687
26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26
CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26
CFR 1.441–6, amended; 26 CFR 1.1441.7, amended; 26
CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26
CFR 1.6041–1, amended; 26 CFR 1.6041–4, amended; 26
CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26
CFR 1.6045–1, amended; 26 CFR 1.6049–4, amended; 26
CFR 1.6049–5, amended; 26 CFR 31.3406(g)–1, amend-
ed; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3,
amended; Withholding of tax on certain U.S. source in-
come paid to foreign persons and revision of information
reporting and backup withholding regulations, correction
to (TD 9658) 20,103013,748
SELF-EMPLOYMENT TAX
Virtual Currency (Notice 21) 16,938
SPECIAL ANNOUNCEMENT
Advance Pricing and Mutual Agreement Program (Ann 14) 16,
948
TAX CONVENTIONS
Kuwait Reciprocal Exemption for income from the international
operation of aircraft (Ann 24) 23,1086
June 16, 2014Bulletin No. 2014–25
viii

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