Internal Revenue Bulletin 2015-28 (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.
INCOME TAX
REG–138526 –14, page 67.
These proposed regulations provide a revised definition of
issue price for purposes of the arbitrage restrictions under
section 148 that apply to tax-exempt bonds under section 103,
tax credit bonds under section 54A, and direct pay bonds
under section 6431.
EXEMPT ORGANIZATIONS
Announcement 2015–17, page 67.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
Notice 2015– 46, page 64.
This notice clarifies how a charitable hospital organization may
comply with the requirement in § 1.501(r)–4(b)(1)(iii)(F) of the
Treasury Regulations that a hospital facility include a list of
providers in its financial assistance policy (FAP). This notice
affects charitable hospital organizations.
Finding Lists begin on page ii.
Bulletin No. 2015–28
July 13, 2015

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.
July 13, 2015Bulletin No. 2015–28

Part III. Administrative, Procedural, and Miscellaneous
Clarifications to the
Requirement in the
Treasury Regulations
Under § 501(r)(4) that a
Hospital Facility’s Financial
Assistance Policy Include a
List of Providers
Notice 2015– 46
SECTION 1. PURPOSE
This notice provides clarification with
respect to how a charitable hospital orga-
nization may comply with the requirement
in § 1.501(r)–4(b)(1)(iii)(F) of the Trea-
sury Regulations that a hospital facility
include a provider list in its financial as-
sistance policy (FAP). The list must in-
clude any providers, other than the hospi-
tal facility itself, delivering emergency or
other medically necessary care in the hos-
pital facility and specify which providers
are and are not covered by the hospital
facility’s FAP.
SECTION 2. BACKGROUND
Section 9007 of the Patient Protection
and Affordable Care Act, Public Law
111–148 (124 Stat. 119 (2010)), enacted
§ 501(r) of the Internal Revenue Code,
which imposes additional requirements on
charitable hospital organizations. On De-
cember 29, 2014, the Department of the
Treasury (“Treasury Department”) and
the Internal Revenue Service (“IRS”) re-
leased final regulations (TD 9708) that
contain guidance on the requirements of
§ 501(r) and the consequences for failing
to meet any of these requirements.
Section 501(r)(1) provides that a hos-
pital organization described in § 501(r)(2)
will not be treated as described in
§ 501(c)(3) unless the organization meets
the requirements of § 501(r)(3) through
(r)(6). Section 501(r)(2)(A) defines a hos-
pital organization as including any orga-
nization that operates a facility required
by a state to be licensed, registered, or
similarly recognized as a hospital. Section
501(r)(2)(B) requires a hospital organiza-
tion that operates more than one hospital
facility to meet the requirements of
§ 501(r) separately with respect to each
hospital facility.
Although a hospital organization’s tax-
exempt status depends on its compliance
with the requirements of § 501(r), not all
failures to satisfy the requirements of
§ 501(r) will necessarily result in revoca-
tion. A failure to meet the requirements of
§ 501(r) that is neither willful nor egre-
gious is excused if the hospital facility
corrects and discloses the failure in accor-
dance with Rev. Proc. 2015–21 (2015–13
I.R.B. 817).See§ 1.501(r)–2(c). Addi-
tionally, a hospital facility’s omission or
error relating to the § 501(r) requirements
that is minor and either inadvertent or due
to reasonable cause will not be considered
a failure to meet a requirement of § 501(r)
if the hospital facility corrects such omis-
sion or error as promptly after discovery
as is reasonable given the nature of the
omission or error.See§ 1.501(r)–2(b).
Section 501(r)(4) requires a hospital
organization to establish a written FAP.
On June 26, 2012, the Treasury Depart-
ment and the IRS published a notice of
proposed rulemaking (REG–130266–11,
77 FR 38148) (2012 proposed regula-
tions) requiring each hospital facility to
establish a FAP that applies to all emer-
gency or other medically necessary care
provided by the hospital facility. A num-
ber of commenters responding to the 2012
proposed regulations noted that patients,
including emergency room patients, are
commonly seen by private physician
groups or other third-party health care
providers while in the hospital facility.
Many commenters asked for clarification
regarding the extent to which a hospital
facility’s FAP must cover these other pro-
viders, such as non-employee providers in
private physician groups or hospital-
owned practices. Some commenters indi-
cated that the FAP should apply only to
the care provided by employees of the
hospital facility itself. Other commenters
noted that, even though emergency room
physicians in some hospital facilities sep-
arately bill for emergency medical care
provided to patients, the hospital facility’s
FAP should apply to the care provided by
all emergency room physicians. Other
commenters requested that the final regu-
lations clearly require the hospital facili-
ty’s FAP to cover all providers of emer-
gency or other medically necessary care in
a hospital facility (or all services provided
in the hospital facility for the treatment of
a medical emergency or the provision of
other medically necessary care).
Under the final regulations, a hospital
facility’s FAP must apply to all emer-
gency and medically necessary care pro-
vided in the hospital facility only to the
extent the care is provided by the hospital
facility itself or a substantially-related en-
tity.See§ 1.501(r)–4(b)(1)(i); § 1.501(r)–
1(b)(28) (defining “substantially-related
entity” generally as a partnership in which
the hospital organization owns a capital or
profits interest, or a disregarded entity of
which the hospital organization is the sole
member or owner, that provides emer-
gency or other medically necessary care in
the hospital facility unless the provision of
such care constitutes an unrelated trade or
business). However, the Treasury Depart-
ment and the IRS also agreed with com-
menters that, because patients are typi-
cally unaware of the relationships
between a hospital facility and the health-
care providers working in the hospital fa-
cility, it is important for a hospital facili-
ty’s FAP to clearly disclose which
services provided in the hospital facility
are covered by the FAP and which are not.
Such information may be valuable not
only for patients seeking to understand
what financial assistance they may qualify
for individually, but also for those seeking
to understand the health needs of the com-
munity and the resources available to
meet them. Therefore, in response to com-
ments and in order to provide transpar-
ency for patients and communities, the
final regulations require a hospital facili-
ty’s FAP to include a list of providers,
other than the hospital facility itself, de-
livering emergency or other medically
necessary care in the hospital facility and
specify which providers are covered by
the hospital facility’s FAP and which are
not (“provider list”).See§ 1.501(r)–
4(b)(1)(iii)(F).
Recently, concerns regarding the pro-
vider list requirement have been ex-
pressed, particularly with respect to large
hospital facilities where the number of
providers delivering emergency or medi-
July 13, 2015Bulletin No. 2015–28
64

cally necessary care can be quite large.
Commenters have noted that the provider
list may change frequently because physi-
cians move or change aspects of their
practice and providers’ relationships with
a hospital facility may be complicated and
subject to change. Commenters have
stated that creating a provider list and
keeping it up to date will be difficult.
However, community advocates have in-
dicated that although providing this infor-
mation may require some additional effort
by hospitals, it is valuable information
that is often impossible for patients or
community members to obtain otherwise
and is necessary in order to evaluate what
financial assistance is available.
Additionally, practical questions re-
garding the provider list have been raised.
For example, some commenters have
questioned whether the entire provider list
must be included in the FAP itself, or
whether it could be provided in a separate
document, as is allowed for the disclosure
of the percentage of gross charges that a
hospital facility uses under § 1.501(r)–
5(b)(3) to determine the amounts gener-
ally billed for any emergency or medically
necessary care it provides to an individual
who is eligible for assistance under its
FAP. Further, some have questioned
whether the provider list could specify the
emergency or other medically necessary
care covered by the FAP by department or
by type of service, if all of the providers in
the department or of the service are cov-
ered by the hospital facility’s FAP.
In response to these comments and
questions, this notice provides hospital fa-
cilities with clarification regarding how a
hospital facility may comply with the pro-
vider list requirement.
1
SECTION 3. SPECIFICATION OF
PROVIDERS AND CARE COVERED
BY THE FAP
.01Provider list. A hospital facility’s
FAP must include a list of any providers,
other than the hospital facility itself, pro-
viding emergency or other medically nec-
essary care in the hospital facility that
specifies which providers are covered by
its FAP and which are not.See§ 1.501(r)–
4(b)(1)(iii)(F). For purposes of this re-
quirement, a hospital facility may list the
names of individual doctors, practice
groups, or any other entities that are pro-
viding emergency or medically necessary
care in the hospital facility by the name
used either to contract with the hospital or
to bill patients for care provided. For ex-
ample, if all of the doctors in a practice
group that provides emergency or other
medically necessary care in the hospital
facility are covered by the hospital facili-
ty’s FAP, the hospital facility may include
the name of the practice group, rather than
the name of each individual doctor, in its
provider list and indicate which services
of the practice group are covered by the
FAP. Alternatively, a hospital facility may
specify providers by reference to a depart-
ment or a type of service if the reference
makes clear which services and providers
are covered. For example, if all providers
of all services in a department of a hospi-
tal facility are covered by the FAP, the
hospital facility’s FAP may include the
department, rather than the specific names
of doctors or practice groups, in its pro-
vider list and indicate that the services in
that department are covered by the FAP.
Similarly, if no providers of services in a
department of the hospital facility are cov-
ered by the FAP, the provider list may
include the department and indicate that
none of the services provided in the de-
partment are covered by the FAP.
.02Partial coverage of emergency or
other medically necessary care. If a pro-
vider is covered by a hospital facility’s
FAP in some circumstances but not in
others, the hospital facility must describe
the circumstances in which the emergency
or other medically necessary care deliv-
ered by the provider will and will not be
covered by the FAP. For example, if the
hospital facility has a contract with an
outside provider to deliver certain spe-
cialty services in the hospital facility’s
emergency room that are covered by the
FAP but other emergency or medically
necessary care delivered in the hospital
facility by the provider is not covered by
the FAP, the hospital facility must de-
scribe the circumstances in which the out-
side provider’s services will and will not
be covered by the FAP.
.03Providers covered by policies other
than the hospital facility’s FAP. A hospi-
tal facility’s provider list must indicate
whether the services of a particular pro-
vider are or are not covered by the hospi-
tal facility’s FAP but is not required to
indicate whether that provider’s services
are (or may be) covered by another enti-
ty’s financial aid policy or program.
.04Maintaining the provider list in a
document separate from the FAP. A hos-
pital facility may maintain the list of pro-
viders in a document separate from the
FAP, such as in an appendix, provided
that the document includes the date on
which it was created or last updated. If a
hospital facility maintains its provider list
in a document separate from the FAP, the
hospital facility’s FAP must state that the
list of providers is maintained in a docu-
ment separate from the FAP and explain
how members of the public may readily
obtain it free of charge, both online and on
paper.
SECTION 4. UPDATING THE
PROVIDER LIST
Under § 501(r)(4), a hospital organiza-
tion is required to establish a FAP for each
hospital facility it operates. A hospital or-
ganization has established a FAP for a
hospital facility only if an authorized body
of the hospital facility has adopted the
policy for the hospital facility and the
hospital facility has implemented the pol-
icy.See§ 1.501(r)–4(d)(1). If the only
change a hospital facility makes to its
FAP is to update the provider list (whether
the provider list is in the FAP or in a
separate document), the FAP does not
need to be adopted by an authorized body
of the hospital facility again in order for
the FAP to continue to be considered “es-
tablished.”
SECTION 5. OMISSIONS AND
ERRORS IN THE PROVIDER LIST
Minor omissions and errors that are
either inadvertent or due to reasonable
cause are not considered failures to meet a
requirement of § 501(r) if they are
1
The final regulations contain a collection of information that has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act
of 1995 (44 U.S.C. § 3507(d)) under control number 1545-0047. This notice clarifies, but makes no material change to, one of these collections of information. Accordingly, this notice has
no impact on the estimated annual reporting burden provided in the final regulations.
Bulletin No. 2015–28July 13, 2015
65

promptly corrected, and hospital organi-
zations are not required to disclose such
omissions or errors.See§ 1.501(r)–
2(b)(1). Omissions or errors in a hospital
facility’s provider list, including a failure
to include a provider in that list or to
identify a service covered by the FAP,
will be considered minor and either inad-
vertent or due to reasonable cause if the
hospital facility takes reasonable steps to
ensure that its list of providers is accurate.
A hospital facility that updates its list of
providers by adding new or missing infor-
mation, correcting erroneous information,
and deleting obsolete information at least
quarterly will be considered to have taken
reasonable steps to ensure that its list is
accurate and will be considered to have
corrected any minor omissions or errors in
the list for purposes of § 1.501(r)–2(b).
SECTION 6. EFFECTIVE DATE
This notice is applicable with respect
to taxable years beginning after December
29, 2015.See§ 1.501(r)–7(a).
SECTION 7. DRAFTING
INFORMATION
The principal author of this notice is
Stephanie N. Robbins of the Office of
Associate Chief Counsel (TEGE). For fur-
ther information regarding this notice,
contact Stephanie N. Robbins at (202)
317-5800 (not a toll-free number).
July 13, 2015Bulletin No. 2015–28
66

Part IV. Items of General Interest
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2015–17
Table of Contents
The Internal Revenue Service has re-
voked its determination that the organiza-
tions listed below qualify as organizations
described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date of
announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on July 13, 2015 and
would end on the date the court first de-
termines the organization is not described
in section 170(c)(2) as more particularly
set for in section 7428(c)(1). For individ-
ual contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This ben-
efit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.
NAME OF ORGANIZATIONEffective Date of RevocationLOCATION
The Village Academy, Inc.January 1, 2012St. Louis, MO
Carman MinistriesJanuary 1, 2010Tulsa, OK
Childhood Dreams Foundation, Inc.January 1, 2010New Haven, CT
King InstituteJanuary 1, 2011Carrollton, TX
McLaren Health Plan, Inc.August 1, 2012Flint, MI
Wilemans Belle Isle NeighborhoodMay 1, 2011Oklahoma City, OK
Issue Price Definition for
Tax-Exempt Bonds
REG–138526 –14
AGENCY:Internal Revenue Service
(IRS), Treasury.
ACTION:Partial withdrawal of notice of
proposed rulemaking, notice of proposed
rulemaking, and notice of public hearing.
SUMMARY:This document partially
withdraws the portion of the notice of
proposed rulemaking published in the
Federal Registeron September 16, 2013
(78 FR 56842), relating to the definition of
issue price for purposes of the arbitrage
restrictions under section 148 of the Inter-
nal Revenue Code (Code). This document
also contains a notice of proposed rule-
making that provides a revised definition
of issue price for purposes of the arbitrage
restrictions. In addition, this document
provides notice of a public hearing on the
proposed regulations in this document.
The proposed regulations in this docu-
ment affect issuers of tax-exempt and
other tax-advantaged bonds.
DATES:Written or electronic comments
must be received by September 22, 2015.
Requests to speak and outlines of topics to
be discussed at the public hearing sched-
uled forOctober 28, 2015,at 10:00 a.m.,
must be received by September 22, 2015.
ADDRESSES:Send submissions to: CC:
PA:LPD:PR (REG–138526–14), Internal
Revenue Service, P.O. Box 7604, Ben
Franklin Station, Washington, DC 20044.
Submissions may be hand delivered to: CC:
PA:LPD:PR Monday through Friday be-
tween the hours of 8 a.m. and 4 p.m. to
CC:PA:LPD:PR (REG–138526–14), Cou-
rier’s Desk, Internal Revenue Service, 1111
Constitution Avenue, NW, Washington,
DC, or sent electronically via the Federal
eRulemaking Portal atwww.regulations.
gov(IRS REG–138526–14). The public
hearing will be held at the Internal Reve-
nue Building, 1111 Constitution Avenue,
NW, Washington, DC.
FOR FURTHER INFORMATION
CONTACT:Concerning the proposed
regulations, Lewis Bell at (202) 317-6980;
concerning submissions of comments and
the hearing, Oluwafunmilayo (Funmi)
Taylor at (202) 317-6901 (not a toll-free
number).
SUPPLEMENTARY
INFORMATION:
Paperwork Reduction Act
The collection of information con-
tained in § 1.148–1 has been reviewed
and approved by the Office of Manage-
ment and Budget in accordance with the
Paperwork Reduction Act of 1995 (44
U.S.C. 3507(d)) under control number
Bulletin No. 2015–28July 13, 2015
67

1545–1347. The collection of information
in this proposed regulation is in § 1.148–
1(f)(2)(ii), which contains a requirement
that the issuer obtain certifications and
supporting documentation regarding the
underwriter’s sales of the issuer’s bonds.
The collection of information in § 1.148–
1(f)(2)(ii) is an increase in the total annual
burden under control number 1545–1347.
The respondents are issuers of tax-exempt
bonds that wish to use the alternative
method in § 1.148–1(f)(2)(ii).
Estimated total annual recordkeeping
burden: 52,276 hours.
Estimated average annual burden hours
per respondent: 4 hours.
Estimated number of respondents:
12,546.
Estimated annual frequency of re-
sponses: 20,910.
Comments on the collection of infor-
mation should be sent to theOffice of
Management and Budget, Attn: Desk
Officer for the Department of the Trea-
sury, Office of Information and Regula-
tory Affairs, Washington, DC 20503, with
copies to theInternal Revenue Service,
Attn: IRS Reports Clearance Officer, SE:
CAR:MP:T:T:SP, Washington DC 20224.
Comments on the collection of informa-
tion should be received by August 24,
2015.
Comments are sought on whether the
proposed collection of information is nec-
essary for the proper performance of the
IRS, including whether the information
will have practical utility;
The accuracy of the estimated burden
associated with the proposed collection of
information;
How the quality, utility, and clarity of
the information to be collected may be
enhanced;
How the burden of complying with the
proposed collection of information may
be minimized, including through the ap-
plication of automated collection tech-
niques and other forms of information
technology; and
Estimates of capital or start-up costs
and costs of operation, maintenance, and
purchase of service to provide informa-
tion.
An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information un-
less it displays a valid control number
assigned by the Office of Management
and Budget.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally tax returns and tax
return information are confidential, as re-
quired by section 6103.
Background
This document contains proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1) on the arbitrage
investment restrictions under section 148
of the Code. On June 18, 1993, the De-
partment of the Treasury (Treasury De-
partment) and the IRS published compre-
hensive final regulations in theFederal
Register(TD 8476, 58 FR 33510) on the
arbitrage investment restrictions and re-
lated provisions for tax-exempt bonds un-
der sections 103, 148, 149, and 150. Since
that time, those final regulations have
been amended in certain limited respects
(the regulations issued in 1993 and the
amendments thereto are collectively re-
ferred to as the Existing Regulations).
A notice of proposed rulemaking was
published in theFederal Register(78 FR
56842; REG–148659–07) on September
16, 2013 (the 2013 Proposed Regula-
tions), which proposes amendments to the
Existing Regulations to address market
developments, simplify certain provi-
sions, address certain technical issues, and
make the regulations more administrable.
One significant change in the 2013 Pro-
posed Regulations addresses the definition
of issue price. Comments were received,
and a public hearing was held on February
5, 2014. After considering the comments
and the statements made at the public
hearing, the Treasury Department and the
IRS have decided to withdraw § 1.148–
1(f) of the 2013 Proposed Regulations
relating to issue price and to propose
new regulations. This document (the
Proposed Regulations) contains the re-
proposed definition of issue price. The
Treasury Department and the IRS will
address the remaining provisions con-
tained in the 2013 Proposed Regulations
at a later time.
Explanation of Provisions
For purposes of the arbitrage invest-
ment restrictions, section 148(h) provides
that yield on an issue is to be determined
on the basis of the issue price (within the
meaning of sections 1273 and 1274). The
reason for using issue price (rather than
sales proceeds less the costs of issuance)
to determine yield for purposes of section
148(h) is to ensure that issuers bear the
costs of issuance, rather than recover these
costs through arbitrage profits. See H.
Rep. No. 99–426, at 517 (1985). Con-
gress thought that this requirement would
encourage issuers to scrutinize costs of
issuance more closely and would encour-
age better targeting of the federal subsidy
associated with tax-exempt bonds. Id., at
517–518. The issue price definition under
the Existing Regulations generally fol-
lows the issue price definition used for
computing original issue discount on debt
instruments under sections 1273 and
1274, with certain modifications. The def-
inition under the Existing Regulations
provides that generally the issue price of
bonds that are publicly offered is the first
price at which a substantial amount of the
bonds is sold to the public. However, the
issue price definition in the Existing Reg-
ulations defines substantial amount as ten
percent and applies a reasonable expecta-
tions standard (rather than a standard
based on actual sales) for determining the
issue price of bonds that are publicly of-
fered. Specifically, the issue price of
bonds for which a bona fide public offer-
ing is made is determined as of the sale
date based on reasonable expectations re-
garding the initial offering price. The is-
sue prices of bonds with different pay-
ment and credit terms are determined
separately. Notice 2010–35, published
May 10, 2010 (2010–19 IRB 660), pro-
vides that the arbitrage definition of issue
price also applies to other tax-advantaged
bond programs, including Build America
Bonds under section 54AA and other
Qualified Tax Credit Bonds under section
54A.
The definition of issue price in the
2013 Proposed Regulations differs signif-
icantly from that in the Existing Regula-
tions. Consistent with section 148(h), the
2013 Proposed Regulations retain the rule
that issue price generally will be deter-
July 13, 2015Bulletin No. 2015–28
68

mined under the rules of sections 1273
and 1274. The 2013 Proposed Regulations
parallel the language in the existing sec-
tion 1273 regulations by providing that
the issue price of tax-exempt bonds issued
for money is the first price at which a
substantial amount of the bonds is sold to
the public. The 2013 Proposed Regula-
tions provide a safe harbor under which an
issuer may treat the first price at which a
minimum of 25 percent of the bonds in an
issue (with the same credit and payment
terms) actually is sold to the public as the
issue price, provided that all orders at this
price received from the public during the
offering period are filled (to the extent that
the public orders at such price do not
exceed the amount of bonds sold). Thus,
the 2013 Proposed Regulations base the
determination of issue price on actual
sales prices instead of reasonably ex-
pected sales at initial public offering
prices. The 2013 Proposed Regulations
also remove the definition of a “substan-
tial amount” as ten percent.
The 2013 Proposed Regulations define
the term “public” to mean any person
other than an “underwriter.” The 2013
Proposed Regulations define the term “un-
derwriter” to mean any person that pur-
chases bonds from the issuer for the pur-
pose of effecting the original distribution
of the bonds or otherwise participates di-
rectly or indirectly in the original distri-
bution. An underwriter includes a lead
underwriter and any member of a syndi-
cate that contractually agrees to partici-
pate in the underwriting of the bonds for
the issuer. A securities dealer (whether or
not a member of the issuer’s underwriting
syndicate) that purchases bonds (whether
or not from the issuer) for the purpose of
effecting the original distribution of the
bonds is also treated as an underwriter for
this purpose. An underwriter generally in-
cludes a party related to an underwriter. A
person that holds bonds for investment is
not an underwriter with respect to those
bonds.
A number of comments were received
on the 2013 Proposed Regulations issue
price definition. In general, the comment-
ers requested the withdrawal of the por-
tion of the 2013 Proposed Regulations
relating to the definition or the re-proposal
of the definition using the existing reason-
able expectations test regarding the initial
public offering price, with certain clarifi-
cations. Commenters pointed out that is-
sue price must be determined as of the
sale date to provide certainty that the
bonds will qualify as tax-exempt and meet
state or local requirements for debt issu-
ance. The sale date is the date when the
syndicate or sole underwriter in contrac-
tual privity with the issuer signs the agree-
ment to buy the bonds from the issuer and
when the terms of the bond issue are set.
Commenters expressed concern about in-
sufficient sales of bonds preventing a
timely determination of issue price on the
sale date. The commenters noted that the
syndicate or sole underwriter in contrac-
tual privity purchases the bonds from the
issuer, so the syndicate or sole under-
writer, rather than the issuer, will bear the
risk of any market fluctuations after the
sale date. Because the issuer neither bears
this risk nor receives any further proceeds,
any later change in price is not a factor
that affects the costs of issuance paid by
the issuer. In addition, later sales prices
could reflect changes in the market,
whereas the purpose of using issue price is
to preclude recovery of issuance costs
through arbitrage profits. See H. Rep. No.
99–426, at 517.
In general, the lower the issue price for
the bonds bearing a stated interest rate, the
higher the yield. Economically, the issuer
should want to receive the highest price
for the bonds and pay the lowest yield.
This aligns with the purpose of the arbi-
trage provisions to minimize arbitrage in-
vestment benefits and remove incentives
to issue more tax-exempt bonds, and thus
to limit the federal revenue cost of the tax
subsidy for tax-exempt bonds. Many of
the commenters stated, however, that the
use of actual sales prices likely would
result in lower bond offering prices so as
to ensure that each issue would meet the
25 percent threshold in the safe harbor in
the 2013 Proposed Regulations as of the
sale date of the bonds. The commenters
pointed to unsold bonds in particular ma-
turities of an overall tax-exempt bond is-
sue that includes a series of bonds with
separate maturities and issue prices as the
particular impediment to meeting an ac-
tual sale requirement as of the sale date.
These lower bond prices would reduce
proceeds and increase borrowing costs for
issuers, increase bond yields for arbitrage
purposes, and increase federal tax subsi-
dies.
In addition, commenters suggested that
the definition of underwriter in the 2013
Proposed Regulations was unduly broad
and ambiguous. In particular, commenters
expressed concern that the 2013 Proposed
Regulations effectively required the issuer
to obtain price information from dealers
that are not in a contractual relationship
with the issuer or underwriting syndicate.
The commenters also expressed concern
that the proposed definition of underwriter
necessitated determining a dealer’s intent
for buying bonds because whether a
dealer was an underwriter depended upon
whether the dealer purchased bonds with
“the purpose of effecting the original dis-
tribution of the bonds.”
In response to the comments received,
the Treasury Department and the IRS are
re-proposing an amended definition of is-
sue price for tax-exempt bonds. Consis-
tent with section 148(h), the Proposed
Regulations retain the rule that issue price
generally will be determined under the
rules of sections 1273 and 1274. The Pro-
posed Regulations also parallel the lan-
guage in the existing section 1273 regula-
tions and the Existing Regulations by
providing that the issue price of bonds
issued for money is the first price at which
a substantial amount of the bonds is sold
to the public. This rule uses actual sales to
determine issue price and is consistent
with section 1273. The Proposed Regula-
tions retain the rule in the Existing Regu-
lations that ten percent is a substantial
amount.
The Proposed Regulations also retain
the rule for tax-exempt bonds that the
issue prices of bonds with different pay-
ment and credit terms are determined sep-
arately. Tax-exempt bond issues often in-
clude bonds with different payment and
credit terms that generally sell at different
prices. In response to commenters’ con-
cerns regarding the need for certainty with
respect to the determination of issue price
of the issue as of the sale date and that less
than a substantial amount of particular
bonds included within an issue may be
sold by that time, the Proposed Regula-
tions provide an alternative method of de-
termining issue price for bonds a substan-
tial amount of which is not sold pursuant
to orders received from the public as of
Bulletin No. 2015–28July 13, 2015
69

the sale date. Under this alternative
method, an issuer may treat the initial
offering price to the public as the issue
price, provided certain requirements are
met.
In particular, the alternative method re-
quires that the underwriters fill all orders
at the initial offering price placed by the
public and received by the underwriters
on or before the sale date (to the extent the
orders do not exceed the amount of bonds
to be sold) and do not fill any order re-
ceived by the underwriters on or before
the sale date at a price higher than the
initial offering price. Further, the alterna-
tive method requires the lead underwriter
(or sole underwriter, if applicable) to pro-
vide certification with respect to certain
matters under the alternative method, in-
cluding a certification that no underwriter
will fill an order received from the public
after the sale date and before the issue
date at a price higher than the initial of-
fering price, except if the higher price is
the result of a market change for those
bonds after the sale date (for example, due
to a change in interest rates), and that it
will provide the issuer with supporting
documentation for the matters covered by
the certifications.
Documentation of the initial offering
price may include a copy of the pricing
wire (or equivalent communication). Doc-
umentation of bonds for which an under-
writer filled an order placed by the public
after the sale date and before the issue
date at a price higher than the initial of-
fering price includes both pricing infor-
mation (amounts, prices, and sale dates)
and information regarding the correspond-
ing market change, such as proof of the
values of a broad-based index of munici-
pal bond interest rates on bonds similar to
the type and credit rating of the bonds
being sold. The issuer must not know or
have reason to know, after exercising due
diligence, that the certifications are false.
The Treasury Department and the IRS
recognize that, under syndicate agree-
ments among underwriters and MSRB
rules, underwriters are free to sell bonds
after the bond purchase agreement is
signed at a fair and reasonable price dif-
ferent from the initial offering price. The
alternative method allows the use of initial
offering price as the issue price in circum-
stances in which bonds are sold after the
sale date and before the issue date at a
higher price, provided that the higher
price results from a market change for
those bonds after the sale date. Based on
available data, the Treasury Department
and the IRS believe that the frequency of
sales by underwriters at higher prices be-
tween the sale date and the issue date is
limited. Thus, the burden, in effect, of
requiring underwriters to maintain initial
public offering prices for unsold bonds
until the issue date absent justification for
higher prices based on market changes
should be limited. The Treasury Depart-
ment and the IRS request comments on
other safeguards or alternative approaches
to ensure that the prices obtained by un-
derwriters in actual sales of bonds to the
public between the sale date and the issue
date are consistent with use of initial of-
fering prices to the public as of the sale
date as a simplifying assumption for issue
price determinations in the alternative
method.
The Proposed Regulations define “pub-
lic” for purposes of determining the issue
price of tax-exempt bonds as any person
other than an underwriter or a related
party to an underwriter. The Proposed
Regulations define “underwriter” to in-
clude (i) any person that contractually
agrees to participate in the initial sale of
the bonds to the public by entering into a
contract with the issuer or into a contract
with a lead underwriter to form an under-
writing syndicate and (ii) any person that,
on or before the sale date, directly or
indirectly enters into a contract or other
arrangement to sell the bonds with any of
the foregoing (for example, a retail distri-
bution contract between a member of an
underwriting syndicate or selling group
and another dealer that is not in the syn-
dicate or selling group).
The Proposed Regulations remove as
unnecessary a rule in the Existing Regu-
lations expressly stating that the issue
price does not change if part of the issue is
later sold at a different price. The Trea-
sury Department and the IRS intend no
substantive change by the removal.
In accordance with section 6001, the
issuer should maintain documentation in
its books and records to support its issue
price determinations. This documentation
includes the specific certifications and
documentation required to determine is-
sue price under the alternative method, as
well as documentation to support issue
price determinations under the general
rule. For example, under the general rule,
an issuer should include in its books and
records any certification from the lead (or
sole) underwriter regarding the first price
at which a substantial amount of the bonds
were sold to the public and reasonable
supporting documentation for this price.
Proposed Effective/Applicability Date
The Proposed Regulations are pro-
posed to apply prospectively to bonds that
are sold on or after the date that is 90 days
after publication of the Treasury decision
adopting these rules as final regulations in
theFederal Register.In addition, issuers
may rely upon the Proposed Regulations
with respect to bonds that are sold on or
after June 24, 2015, and before the date
that is 90 days after publication of the
Treasury decision adopting these rules as
final regulations in theFederal Register.
Special Analyses
It has been determined that this notice
of proposed rulemaking is not a signifi-
cant regulatory action as defined in Exec-
utive Order 12866, as supplemented by
Executive Order 13563. Therefore, a reg-
ulatory assessment is not required. It has
also been determined that section 553(b)
of the Administrative Procedure Act (5
U.S.C. Chapter 5) does not apply.
It is hereby certified that these Pro-
posed Regulations, if adopted, would not
have a significant economic impact on a
substantial number of small entities.
Therefore, a Regulatory Flexibility Anal-
ysis under the Regulatory Flexibility Act
(5 U.S.C. chapter 6) is not required. This
certification is based generally on the fact
that any effect on small entities by these
rules generally flows from section 148 of
the Code.
Section 148(h) of the Code requires the
yield on an issue of bonds to be deter-
mined on the basis of issue price (within
the meaning of sections 1273 and 1274).
Under section 1273, the issue price is the
first price at which a substantial amount of
the bonds were sold to the public. Section
1.148–1(f)(2)(ii) of the Proposed Regula-
tions gives effect to the statute by requir-
ing the issuer to obtain certifications and
July 13, 2015Bulletin No. 2015–28
70

documentation regarding sales of the
bonds from the underwriter of the bonds,
which is the party that sells the bonds to
the public. This information will be used
to support the issue price of the bonds for
audit and other purposes. Any economic
impact of obtaining this information is
minimal because most of the information
already is provided to issuers by the un-
derwriters under existing industry prac-
tices. Accordingly, these proposed
changes do not add to the impact on small
entities imposed by the statutory provi-
sion. Pursuant to section 7805(f) of the
Code, this notice of proposed rulemaking
has been submitted to the Chief Counsel
for Advocacy of the Small Business Ad-
ministration for comment on its impact on
small business.
Comments and Public Hearing
Before these Proposed Regulations are
adopted as final regulations, consideration
will be given to any comments that are
submitted timely to the IRS as prescribed
in this preamble under the “Addresses”
heading. The IRS and the Treasury De-
partment request comments on all aspects
of the proposed rules. All comments that
are submitted by the public will be avail-
able for public inspection and copying at
www.regulations.govor upon request.
A public hearing has been scheduled
for October 28, 2015, at 10:00 a.m., in the
IRS Auditorium, Internal Revenue Ser-
vice, 1111 Constitution Avenue, NW,
Washington, DC. Due to building security
procedures, visitors must enter at the Con-
stitution Avenue entrance. In addition, all
visitors must present photo identification
to enter the building. Because of access
restrictions, visitors will not be admitted
beyond the immediate entrance area more
than 15 minutes before the hearing starts.
For more information about having your
name placed on the building access list to
attend the hearing, see the “FOR FUR-
THER INFORMATION CONTACT”
section of this preamble.
The rules of 26 CFR 601.601(a)(3) ap-
ply to the hearing. Persons who wish to
present oral comments at the hearing must
submit written or electronic comments
and an outline of the topics to be dis-
cussed and the time to be devoted to each
topic by September 22, 2015. Such per-
sons should submit a signed paper original
and eight (8) copies or an electronic copy.
A period of 10 minutes will be allotted to
each person for making comments. An
agenda showing the scheduling of the
speakers will be prepared after the dead-
line for receiving outlines has passed.
Copies of the agenda will be available free
of charge at the hearing.
Drafting Information
The principal authors of these regula-
tions are Johanna Som de Cerff and Lewis
Bell, Office of Associate Chief Counsel
(Financial Institutions and Products), IRS.
However, other personnel from the IRS
and the Treasury Department participated
in their development.
*****
Partial Withdrawal of Notice of
Proposed Rulemaking
Accordingly, under the authority of 26
U.S.C. 7805, § 1.148–1(f) of the notice of
proposed rulemaking (REG–148659–07)
that was published in theFederal Regis-
teron September 16, 2013 (78 FR
56842), is withdrawn.
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 1 is pro-
posed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805***
Par. 2. Section 1.148–0(c) is amended
by adding entries for §§ 1.148–1(f) and
1.148–11(m) to read as follows:
§ 1.148 – 0 Scope and table of contents.
*****
(c)Table of contents.***
§ 1.148 –1 Definitions and elections.
*****
(f) Definition of issue price.
(1) In general.
(2) Bonds issued for money.
(3) Definitions.
(4) Special rules.
*****
§ 1.148 –11 Effective/applicability dates.
*****
(m) Definition of issue price.
Par. 3. Section 1.148–1 is amended by
revising the definition ofissue pricein
paragraph (b) and adding paragraph (f) to
read as follows:
§ 1.148 –1 Definitions and elections.
*****
(b)***
Issue pricemeans issue price as de-
fined in paragraph (f) of this section.
*****
(f)Definition of issue price—(1)In
general. Except as otherwise provided in
this paragraph (f),issue priceis defined in
sections 1273 and 1274 and the regula-
tions under those sections.
(2)Bonds issued for money—(i)In
general. The issue price of bonds issued
for money is the first price at which a
substantial amount of the bonds is sold to
the public.
(ii)Alternative method based on initial
offering price. As an alternative to the
general rule in paragraph (f)(2)(i) of this
section, if the underwriters have not re-
ceived orders placed by the public for a
substantial amount of tax-exempt bonds
on or before the sale date, the issuer may
treat the initial offering price to the public
as the issue price of the bonds if all of the
following requirements are met:
(A) The underwriters fill all orders at
the initial offering price placed by the
public and received by the underwriters
on or before the sale date (to the extent the
orders do not exceed the amount of bonds
to be sold), and no underwriter fills an
order placed by the public and received by
the underwriters on or before the sale date
at a price higher than the initial offering
price.
(B) The issuer obtains from the lead
underwriter in the underwriting syndicate
or selling group (or, if applicable, the sole
underwriter) certification of the following:
(1) The initial offering price;
(2) That the underwriters met the re-
quirements of paragraph (f)(2)(ii)(A) of
this section;
(3) That no underwriter will fill an or-
der placed by the public and received after
the sale date and before the issue date at a
Bulletin No. 2015–28July 13, 2015
71

price higher than the initial offering price,
except if the higher price is the result of a
market change (such as a decline in inter-
est rates) for those bonds after the sale
date; and
(4) That the lead (or sole) underwriter
will provide the issuer supporting docu-
mentation for the matters covered by the
certifications in paragraphs (f)(2)(ii)(B)(1)
and (2) of this section and, with regard to
paragraph (f)(2)(ii)(B)(3) of this section,
either documentation regarding any bonds
for which an underwriter filled an order
placed by the public and received after the
sale date and before the issue date at a
price higher than the initial offering price
and the corresponding market change for
those bonds, or a certification that no un-
derwriter filled such orders at a price
higher than the initial offering price.
(C) The issuer does not know or have
reason to know, after exercising due dili-
gence, that the certifications described in
paragraph (f)(2)(ii)(B) of this section are
false.
(3)Definitions. For purposes of this
paragraph (f), the following definitions
apply:
(i)Public.Publicmeans any person (as
defined in section 7701(a)(1)) other than
an underwriter or a related party (as de-
fined in § 1.150–1(b)) to an underwriter.
(ii)Underwriter. The termunderwriter
includes—
(A) Any person (as defined in section
7701(a)(1)) that contractually agrees to
participate in the initial sale of the bonds
to the public by entering into a contract
with the issuer (or with the lead under-
writer to form an underwriting syndicate);
and
(B) Any person that, on or before the
sale date, directly or indirectly enters into
a contract or other arrangement with a
person described in paragraph (f)(3)(ii)(A) of
this section to sell the bonds.
(4)Special rules. For purposes of this
paragraph (f), the following special rules
apply:
(i)Separate determinations. The issue
price of bonds in an issue that do not have
the same credit and payment terms is de-
termined separately.
(ii)Substantial amount. Ten percent is
a substantial amount.
(iii)Bonds issued for property.Ifa
bond is issued for property, the adjusted
applicable Federal rate, as determined un-
der section 1288, is used in lieu of the
applicable Federal rate to determine the
bond’s issue price under section 1274.
Par. 4. Section 1.148–11 is amended
by adding paragraph (m) to read as fol-
lows:
§ 1.148 –11 Effective/applicability dates.
*****
(m)Definition of issue price. The def-
inition of issue price in § 1.148–1(b) and
(f) applies to bonds that are sold on or
after the date that is 90 days after the date
of publication of the Treasury decision
adopting these rules as final regulations in
theFederal Register.
John M. Dalrymple,
Deputy Commissioner for
Services and Enforcement.
(Filed by the Office of the Federal Register on June 23,
2015, 8:45 a.m., and published in the issue of the Federal
Register for June 24, 2015, 80 F.R. 15411)
July 13, 2015Bulletin No. 2015–28
72

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. 2015–28July 13, 2015
i

Numerical Finding List
1
Bulletin 2015–27 through 2015–28
Announcements:
2015-17, 2015-28 I.R.B.67
Notices:
2015-46, 2015-28 I.R.B.64
Proposed Regulations:
REG-138526-14, 2015-28 I.R.B.67
REG-102837-15, 2015-27 I.R.B.43
Revenue Procedures:
2015-34, 2015-27 I.R.B.4
2015-36, 2015-27 I.R.B.20
Revenue Rulings:
2015-15, 2015-27 I.R.B.1
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
July 13, 2015Bulletin No. 2015–28
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–27 through 2015–28
Revenue Procedures:
2011-49
Modified by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
2011-49
Superseded by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2015–01 through 2015–26 is in Internal Revenue Bulletin
2015–26, dated June 29, 2015.
Bulletin No. 2015–28July 13, 2015
iii

INTERNAL REVENUE BULLETIN
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Washington, DC 20224
Official Business
Penalty for Private Use, $300