Internal Revenue Bulletin 2015-43 (PDF rendition): IRS Notices

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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
Notice 2015–70, page 604.
Request for Comments on Definitions of Section 48 Property.
This notice requests comments from the public on how to
define certain types of qualified property for purposes of sec-
tion 48 of the Internal Revenue Code and provides a 120 day
period from the date of publication of the notice in the Internal
Revenue Bulletin for submission of comments.
EMPLOYEE PLANS
Notice 2015–71, page 606.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for October
2015 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for October 2015, and the 30-year
Treasury rates. These rates reflect the application of
§ 430(h)(2)(C)(iv), which was added by the Moving Ahead for
Progress in the 21st Century Act, Public Law 112–141 (MAP–
21) and amended by section 2003 of the Highway and Trans-
portation Funding Act of 2014 (HATFA).
EXCISE TAX
Notice 2015– 60, page 604.
Notice 2015–60 provides the applicable dollar amount that
applies for determining the fee imposed by §§ 4375 and 4376
for policy years and plan years ending on or after October 1,
2015 and before September 30, 2016.
ADMINISTRATIVE
Notice 2015– 60, page 604.
Notice 2015–60 provides the applicable dollar amount that
applies for determining the fee imposed by §§ 4375 and 4376
for policy years and plan years ending on or after October 1,
2015 and before September 30, 2016.
Finding Lists begin on page ii.
Bulletin No. 2015– 43
October 26, 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.
October 26, 2015Bulletin No. 2015– 43

Part III. Administrative, Procedural, and Miscellaneous
Adjusted Applicable Dollar
Amount for Fee Imposed by
§§ 4375 and 4376
Notice 2015– 60
I. PURPOSE
This notice provides the adjusted ap-
plicable dollar amount to be multiplied by
the average number of covered lives for
purposes of the fee imposed by §§ 4375
and 4376 of the Internal Revenue Code
for policy years and plan years that end on
or after October 1, 2015, and before Oc-
tober 1, 2016.
II. BACKGROUND
Section 4375 imposes a fee on the is-
suer of a specified health insurance policy
for each policy year ending after Septem-
ber 30, 2012, and before October 1, 2019.
Section 4376 imposes a fee on the plan
sponsor of an applicable self-insured
health plan for each plan year ending after
September 30, 2012, and before October
1, 2019. The fee imposed by §§ 4375 and
4376 helps to fund the Patient-Centered
Outcomes Research Institute (PCORI)
and is calculated using the average num-
ber of lives covered under the policy or
plan and the applicable dollar amount for
that policy year or plan year. Under
§§ 4375(a) and 4376(a), the applicable
dollar amount is $2 for policy and plan
years ending on or after October 1, 2013,
and before October 1, 2014.
1
Treas. Reg.
§§ 46.4375–1(c)(4) and 46.4376 –1(c)(3).
Under §§ 4375(d) and 4376(d) and
Treas. Reg. §§ 46.4375–1(c)(4) and
46.4376 –1(c)(3), the applicable dollar
amount for policy years and plan years
ending in any Federal fiscal year begin-
ning on or after October 1, 2014 is in-
creased based on increases in the pro-
jected per capita amount of National
Health Expenditures. Specifically, the ap-
plicable dollar amount is the sum of –
(i) The applicable dollar amount for the
policy year or plan year ending in the
previous Federal fiscal year; plus
(ii) Theamount equal to the product of –
(A) The applicable dollar amount for
the policy year or plan year end-
ing in the previous Federal fiscal
year; and
(B) The percentage increase in the
projected per capita amount of
NationalHealthExpenditures
most recently released by the De-
partment of Health and Human
Services (HHS) before the begin-
ning of the Federal fiscal year.
Notice 2014 –56, 2014 –2 C.B. 674,
provides that the adjusted applicable dol-
lar amount for policy years and plan years
that end on or after October 1, 2014, and
before October 1, 2015 is $2.08. Notice
2014 –56 also provides that the adjusted
applicable dollar amount for subsequent
policy years and plan years will be pub-
lished in the Internal Revenue Bulletin.
III. ADJUSTED APPLICABLE
DOLLAR AMOUNT
The applicable dollar amount that must
be used to calculate the fee imposed by
§§ 4375 and 4376 for policy years and
plan years that end on or after October 1,
2015, and before October 1, 2016, is
$2.17. The increase from the prior amount
is calculated by multiplying the adjusted
applicable dollar amount for policy years
and plan years ending in the previous Fed-
eral fiscal year, $2.08, by the percentage
increase of the projected per capita
amount of National Health Expenditures
published by HHS on July 22, 2015. See
https://www.cms.gov/Research-Statistics-
Data-and-Systems/Statistics-Trends-and-
Reports/NationalHealthExpendData/Down-
loads/Proj2014tables.zip, Table 3. The
percentage increase is calculated after ad-
justment to reflect updates to the data used
to calculate the prior amount, $2.08,
which was based on the per capita
amounts of National Health Expenditures
for 2014 and 2015 published by HHS on
September 3, 2014.
IV. EFFECTIVE DATE
This notice is effective for policy years
and plan years ending on or after October
1, 2015.
V. DRAFTING INFORMATION
The principal author of this notice is R.
Lisa Mojiri-Azad of the Office of Associ-
ate Chief Counsel (Tax Exempt & Gov-
ernment Entities). For further information
regarding this notice, contact Ms. Mojiri-
Azad at (202) 317-5500 (not a toll free
number).
Request for Comments on
Definitions of Section 48
Property
Notice 2015–70
SECTION 1. PURPOSE
The Department of the Treasury
(“Treasury Department”) and the Internal
Revenue Service (“IRS”) anticipate issu-
ing regulations under § 48 of the Internal
Revenue Code to define certain types of
property qualifying for the energy credit
under § 48. This notice requests com-
ments on how to define these types of
property; specifically, this notice requests
comments on the definition of certain
equipment using solar energy, certain
equipment used to produce, distribute, or
use energy derived from a geothermal de-
posit, qualified fuel cell property, quali-
fied microturbine property, combined heat
and power system property, qualified
small wind energy property, and equip-
ment using the ground or ground water as
a thermal energy source.
SECTION 2. BACKGROUND
For purposes of computing the invest-
ment credit under § 46, § 48(a)(1) pro-
vides, in part, that the energy credit for
any taxable year is the energy percentage
of the basis of each energy property
placed in service during such taxable year.
1
The applicable dollar amount is $1 for policy and plan years ending before October 1, 2013.
October 26, 2015Bulletin No. 2015– 43
604

Section 48(a)(3)(A) sets forth the types
of property qualifying as energy property
for the energy credit. The types of prop-
erty listed in § 48(a)(3)(A) include certain
solar energy property, certain equipment
used to produce, distribute, or use energy
derived from a geothermal deposit, quali-
fied fuel cell property, qualified microtur-
bine property, combined heat and power
system property, qualified small wind en-
ergy property, and equipment using the
ground or ground water as a thermal en-
ergy source. Section 48(c) further defines
some of these terms for purposes of the
energy credit.
Section 48(a)(3)(B) provides that, in
order to be eligible for the energy credit,
the construction, reconstruction, or erec-
tion of the property must be completed by
the taxpayer, or, if the taxpayer acquires
the property, the original use of the prop-
erty must commence with the taxpayer.
Section 48(a)(3)(C) provides that depreci-
ation or amortization of the property must
be allowable. Section 48(a)(3)(D) pro-
vides that the property must meet the per-
formance and quality standards which
have been prescribed by the Secretary of
the Treasury (after consultation with the
Secretary of Energy) and are in effect at
the time the property is acquired by the
taxpayer.
Section 1.48 –9 of the Income Tax
Regulations provides additional clarifica-
tions to the definitions of qualified energy
property under § 48. Those regulations
have not been updated since 1987, before
the types of property listed in this notice
were added to § 48(a)(3)(A). The Trea-
sury Department and the IRS anticipate
issuing regulations to define these types of
property for purposes of the energy credit
under § 48.
SECTION 3. TYPES OF PROPERTY
ELIGIBLE FOR THE ENERGY
CREDIT
.01Equipment which uses solar energy
to generate electricity. Section 48(a)(3)(A)(i)
provides that energy property includes
equipment which uses solar energy to
generate electricity to heat or cool (or
provide hot water for use in) a structure or
to provide solar process heat, excepting
property used to generate energy for the
purpose of heating a swimming pool. Sec-
tion 48(a)(2)(A)(i)(II) provides that the
energy percentage for such property is 30
percent for periods before January 1,
2017. After that the energy percentage is
10 percent.
.02Equipment which uses solar energy
to illuminate. Section 48(a)(3)(A)(ii) pro-
vides that energy property includes equip-
ment which uses solar energy to illumi-
nate the inside of a structure using fiber-
optic distributed sunlight but only with
respect to periods ending before January
1, 2017. Section 48(a)(2)(A)(i)(III) pro-
vides that the energy percentage for such
property is 30 percent.
.03Equipment using energy from geo-
thermal sources. Section 48(a)(3)(A)(iii)
provides that energy property includes
equipment used to produce, distribute, or
use energy derived from a geothermal de-
posit (within the meaning of § 613(e)(2))
but only, in the case of electricity gener-
ated by geothermal power, up to (but not
including) the electrical transmission
stage. Section 48(a)(2)(A)(ii) provides
that the energy percentage for such prop-
erty is 10 percent.
.04Qualified fuel cell property. Sec-
tion 48(a)(3)(A)(iv) provides that energy
property includes qualified fuel cell prop-
erty. Section 48(a)(2)(A)(i)(I) provides
that the energy percentage for qualified
fuel cell property is 30 percent. Section
48(c)(1)(A) defines qualified fuel cell
property, in general, as a fuel cell power
plant which has a nameplate capacity of at
least 0.5 kilowatt of electricity using an
electrochemical process and has an
electricity-onlygenerationefficiency
greater than 30 percent. The term “fuel
cellpowerplant”isdefinedin
§ 48(c)(1)(C) as an integrated system
comprised of a fuel cell stack assembly
and associated balance of plant compo-
nents which converts a fuel into electricity
using electrochemical means. Section
48(c)(1)(B) limits the energy credit
amount for qualified fuel cell property
each year to $1,500 per 0.5 kilowatt of
capacityofsuchproperty.Section
48(c)(1)(D) provides that the qualified
fuel cell property must be placed in ser-
vice before January 1, 2017.
.05Qualified microturbine property.
Section 48(a)(3)(A)(iv) provides that en-
ergy property includes qualified microtur-
bine property. Section 48(a)(2)(A)(ii) pro-
vides that the energy percentage for
qualified microturbine property is 10 per-
cent. Section 48(c)(2)(D) provides that the
qualified microturbine property must be
placed in service before January 1, 2017.
Section 48(c)(2)(A) defines qualified mi-
croturbine property as a stationary micro-
turbine power plant which has a name-
plate capacity of less than 2,000 kilowatts
and has an electricity-only generation ef-
ficiency of not less than 26 percent at
International Standard Organization con-
ditions. Section 48(c)(2)(C) clarifies that
the term “stationary microturbine power
plant” means an integrated system com-
prised of a gas turbine engine, a combus-
tor, a recuperator or regenerator, a gener-
ator or alternator, and associated balance
of plant components which converts a fuel
into electricity and thermal energy. That
term also includes all secondary compo-
nents located between the existing infra-
structure for fuel delivery and the existing
infrastructure for power distribution, in-
cluding equipment and controls for meet-
ing relevant power standards, such as volt-
age, frequency, and power factors. Section
48(c)(2)(B) limits the amount of the § 48
credit for qualified microturbine property
to an amount equal to $200 per each kilo-
watt of capacity of such property.
.06Combined heat and power system
property. Section 48(a)(3)(A)(v) provides
that energy property includes combined
heat and power system property. Section
48(a)(2)(A)(ii) provides that the energy
percentage for combined heat and power
system property is 10 percent. Section
48(c)(3)(A)(iv) provides that the com-
bined heat and power system property
must be placed in service before January
1, 2017. Section 48(c)(3)(A) defines com-
bined heat and power system property as
property comprising a system which uses
the same energy source for the simultane-
ous or sequential generation of electrical
power, mechanical shaft power, or both,
in combination with the generation of
steam or other forms of useful thermal
energy (including heating and cooling ap-
plications). The system must produce at
least 20 percent of its total useful energy
in the form of thermal energy which is not
used to produce electrical or mechanical
power (or combination thereof) and at
least 20 percent of its total useful energy
in the form of electrical or mechanical
power (or combination thereof), and the
Bulletin No. 2015– 43October 26, 2015
605

energy efficiency percentage of the sys-
tem must exceed 60 percent. Section
48(c)(3)(B) contains limitations on the
combined heat and power system property
for which the energy credit may be
claimed.
.07Qualified small wind energy prop-
erty. Section 48(a)(3)(A)(vi) provides that en-
ergy property includes qualified small wind
energy property. Section 48(a)(2)(A)(i)(IV)
provides that the energy percentage for
qualified small wind energy property is
30 percent. Section 48(c)(4)(C) provides
that the qualified small wind energy
property must be placed in service be-
fore January 1, 2017. Section 48(c)(4)(A)
defines qualified small wind energy prop-
erty as property using a wind turbine
which has a nameplate capacity of not
more than 100 kilowatts to generate elec-
tricity.
.08Equipment using the ground or
ground water as a thermal energy source.
Section 48(a)(3)(A)(vii) provides that en-
ergy property includes equipment which
uses the ground or ground water as a
thermal energy source to heat a structure
or as a thermal energy sink to cool a
structure, but only with respect to periods
ending before January 1, 2017. Section
48(a)(2)(A)(ii) provides that the energy
percentage for such property using the
ground or ground water as a thermal en-
ergy source is 10 percent.
SECTION 4. REQUEST FOR
COMMENTS
.01 The Treasury Department and the
IRS request comments on issues that
should be addressed in proposed regula-
tions on the definition of certain types of
property under § 48. Specifically, the
Treasury Department and the IRS request
comments that address the following:
(1) Whether only property that actually
produces electricity may be considered
energy property or whether property such
as storage devices and power conditioning
equipment may also be considered energy
property.
(2) Whether dual-use property should
qualify for the credit and, if so, under what
circumstances it should qualify. If it should
qualify, what portion of the basis of dual use
property should be taken into account in
computing the energy percentage.
(3) Comprehensive definitions of the
property described in Section 3 of this
notice.
(4) Definitions of terms such as storage
devices, power conditioning equipment,
transfer equipment, and other property
commonly used in conjunction with prop-
erty described in Section 3 of this notice,
as well as definitions of parts related to the
functioning of these items.
(5) The need for other energy-related
definitions.
.02 Any comments must be received by
February 16, 2016.
SECTION 5. ADDRESS TO SEND
COMMENTS
.01 Comments on the definition of
qualified property for purposes of the en-
ergy credit under § 48 should be sent to:
Internal Revenue Service
CC:PA:LPD:PR (Notice 2015–70)
Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
Please include “Notice 2015–70” on the
cover page.
.02 Submissions may be hand deliv-
ered Monday through Friday between the
hours of 8 a.m. and 4 p.m. to:
Internal Revenue Service
Courier’s Desk
1111 Constitution Ave., N.W.
Washington, DC 20224
Attn: CC:PA:LPD:PR
(Notice 2015–70)
.03 Submissions may also be sent elec-
tronically to the following e-mail address:
Notice.Comments@irscounsel.treas.gov
Please include “Notice 2015–70” in the
subject line.
All comments will be available for
public inspection and copying.
SECTION 6. DRAFTING
INFORMATION
The principal author of this notice is Pat-
rick S. Kirwan of the Office of Associate
Chief Counsel (Passthroughs & Special In-
dustries). For further information regarding
this notice contact Mr. Kirwan at (202) 317-
6853 (not a toll-free number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2015–71
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods. To
the extent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the
applicable percentage of the 25-year aver-
age segment rates for the period ending
September 30 of the year preceding the
calendar year in which the plan year be-
gins.
1
However, an election may be made
under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
October 26, 2015Bulletin No. 2015– 43
606

Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from September
2015 data is in Table I at the end of this
notice. The spot first, second, and third
segment rates for the month of September
2015 are, respectively, 1.69, 4.11, and
5.07.
The 24-month average segment rates
determinedunder§430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) to be within the appli-
cable minimum and maximum percent-
ages of the corresponding 25-year average
segment rates. For plan years beginning
before 2018, the applicable minimum per-
centage is 90% and the applicable maxi-
mum percentage is 110%. The 25-year
average segment rates for plan years be-
ginning in 2014, 2015, and 2016 were
published in Notice 2013–58, 2013– 40
I.R.B. 294, Notice 2014 –50, 2014 – 40
I.R.B. 590, and Notice 2015– 61, 2015–39
I.R.B. 408, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for October
2015 without adjustment for the 25-year
average segment rate limits are as follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
October 20151.354.015.04
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for October
2015 adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates, are as follows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
2014October20154.996.326.99
2015October20154.726.116.81
2016October20154.435.916.65
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation de-
scribed in § 431(c)(6)(A), based on the
plan’scurrentliability.Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 per-
cent below the weighted average of the
rates of interest on 30-year Treasury se-
curities during the four-year period ending
on the last day before the beginning of the
plan year. Notice 88 –73, 1988 –2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for September 2015 is 2.95 percent.
The Service determined this rate as the
average of the daily determinations of
yield on the 30-year Treasury bond ma-
turing in August 2045. For plan years
beginning in the month shown below, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rate used to calculate
current liability are as follows:
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
October20153.142.833.30
Bulletin No. 2015– 43October 26, 2015
607

MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for September
2015 are as follows:
First
Segment
Second
Segment
Third
Segment
1.694.115.07
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-6391 or Tony
Montanaro at 202-317-8698 (not toll-free
numbers).
October 26, 2015Bulletin No. 2015– 43
608

Table I
Monthly Yield Curve for September 2015
Derived from September 2015 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturity Yield
0.50.5520.54.8140.55.1060.55.2080.55.25
1.00.9021.04.8241.05.1061.05.2081.05.25
1.51.2221.54.8441.55.1161.55.2081.55.26
2.01.4922.04.8542.05.1162.05.2182.05.26
2.51.7122.54.8642.55.1162.55.2182.55.26
3.01.8923.04.8743.05.1263.05.2183.05.26
3.52.0523.54.8843.55.1263.55.2183.55.26
4.02.2124.04.8944.05.1264.05.2184.05.26
4.52.3624.54.9044.55.1364.55.2184.55.26
5.02.5125.04.9145.05.1365.05.2285.05.26
5.52.6625.54.9245.55.1365.55.2285.55.26
6.02.8126.04.9346.05.1466.05.2286.05.26
6.52.9626.54.9346.55.1466.55.2286.55.26
7.03.1127.04.9447.05.1467.05.2287.05.26
7.53.2627.54.9547.55.1467.55.2287.55.27
8.03.4028.04.9648.05.1568.05.2288.05.27
8.53.5428.54.9748.55.1568.55.2388.55.27
9.03.6629.04.9749.05.1569.05.2389.05.27
9.53.7829.54.9849.55.1569.55.2389.55.27
10.03.8930.04.9950.05.1670.05.2390.05.27
10.53.9930.55.0050.55.1670.55.2390.55.27
11.04.0831.05.0051.05.1671.05.2391.05.27
11.54.1731.55.0151.55.1671.55.2391.55.27
12.04.2532.05.0152.05.1772.05.2392.05.27
12.54.3132.55.0252.55.1772.55.2492.55.27
13.04.3833.05.0353.05.1773.05.2493.05.27
13.54.4333.55.0353.55.1773.55.2493.55.28
14.04.4834.05.0454.05.1874.05.2494.05.28
14.54.5334.55.0454.55.1874.55.2494.55.28
15.04.5735.05.0555.05.1875.05.2495.05.28
15.54.6035.55.0555.55.1875.55.2495.55.28
16.04.6336.05.0656.05.1876.05.2496.05.28
16.54.6636.55.0656.55.1976.55.2496.55.28
17.04.6937.05.0757.05.1977.05.2597.05.28
17.54.7137.55.0757.55.1977.55.2597.55.28
18.04.7338.05.0858.05.1978.05.2598.05.28
18.54.7538.55.0858.55.1978.55.2598.55.28
19.04.7739.05.0959.05.2079.05.2599.05.28
19.54.7839.55.0959.55.2079.55.2599.55.28
20.04.8040.05.0960.05.2080.05.25100.05.28
Bulletin No. 2015– 43October 26, 2015
609

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– 43October 26, 2015
i

Numerical Finding List
1
Bulletins 2015–27 through 2015– 43
Announcements:
2015-17, 2015-28 I.R.B.67
2015-18, 2015-33 I.R.B.198
2015-19, 2015-32 I.R.B.157
2015-20, 2015-38 I.R.B.355
2015-21, 2015-34 I.R.B.220
2015-22, 2015-35 I.R.B.288
2015-23, 2015-36 I.R.B.311
2015-24, 2015-36 I.R.B.313
2015-25, 2015-39 I.R.B.422
Notices:
2015-43, 2015-29 I.R.B.73
2015-46, 2015-28 I.R.B.64
2015-47, 2015-30 I.R.B.76
2015-48, 2015-30 I.R.B.77
2015-49, 2015-30 I.R.B.79
2015-50, 2015-30 I.R.B.81
2015-51, 2015-31 I.R.B.133
2015-52, 2015-35 I.R.B.227
2015-53, 2015-33 I.R.B.190
2015-54, 2015-34 I.R.B.210
2015-55, 2015-34 I.R.B.217
2015-56, 2015-35 I.R.B.235
2015-57, 2015-36 I.R.B.294
2015-58, 2015-37 I.R.B.322
2015-59, 2015-40 I.R.B.459
2015-60, 2015-43 I.R.B.604
2015-61, 2015-39 I.R.B.408
2015-62, 2015-39 I.R.B.411
2015-63, 2015-40 I.R.B.461
2015-64, 2015-40 I.R.B.464
2015-65, 2015-40 I.R.B.466
2015-66, 2015-41 I.R.B.541
2015-67, 2015-41 I.R.B.546
2015-68, 2015-41 I.R.B.547
2015-69, 2015-41 I.R.B.550
2015-70, 2015-43 I.R.B.604
2015-71, 2015-43 I.R.B.606
Proposed Regulations:
REG-136459-09, 2015-37 I.R.B.332
REG-155164-09, 2015-41 I.R.B.560
REG-109370-10, 2015-33 I.R.B.198
REG-112997-10, 2015-39 I.R.B.422
REG-103033-11, 2015-37 I.R.B.325
REG-109813-11, 2015-37 I.R.B.330
REG-138344-13, 2015-41 I.R.B.557
REG-139483-13, 2015-40 I.R.B.475
REG-115452-14, 2015-32 I.R.B.158
REG-127895-14, 2015-41 I.R.B.556
REG-132075-14, 2015-35 I.R.B.288
REG-138526-14, 2015-28 I.R.B.67
REG-143800-14, 2015-37 I.R.B.347
Proposed Regulations:—Continued
REG-102648-15, 2015-31 I.R.B.134
REG-102837-15, 2015-27 I.R.B.43
REG-123640-15, 2015-37 I.R.B.350
Revenue Procedures:
2015-34, 2015-27 I.R.B.4
2015-36, 2015-27 I.R.B.20
2015-38, 2015-36 I.R.B.295
2015-39, 2015-33 I.R.B.195
2015-40, 2015-35 I.R.B.236
2015-41, 2015-35 I.R.B.263
2015-42, 2015-36 I.R.B.310
2015-43, 2015-40 I.R.B.467
2015-44, 2015-38 I.R.B.354
2015-45, 2015-39 I.R.B.412
2015-46, 2015-39 I.R.B.414
2015-47, 2015-39 I.R.B.419
2015-48, 2015-40 I.R.B.469
2015-49, 2015-41 I.R.B.555
2015-50, 2015-42 I.R.B.583
2015-51, 2015-42 I.R.B.583
Revenue Rulings:
2015-15, 2015-27 I.R.B.1
2015-16, 2015-31 I.R.B.130
2015-17, 2015-39 I.R.B.358
2015-18, 2015-34 I.R.B.209
2015-19, 2015-36 I.R.B.291
2015-20, 2015-38 I.R.B.353
2015-21, 2015-40 I.R.B.447
Treasury Decisions:
9723, 2015-31 I.R.B.84
9726, 2015-31 I.R.B.98
9727, 2015-32 I.R.B.154
9728, 2015-33 I.R.B.169
9729, 2015-35 I.R.B.221
9730, 2015-35 I.R.B.223
9731, 2015-37 I.R.B.314
9732, 2015-39 I.R.B.371
9733, 2015-41 I.R.B.494
9734, 2015-41 I.R.B.500
9735, 2015-37 I.R.B.316
9736, 2015-39 I.R.B.402
9737, 2015-40 I.R.B.449
9738, 2015-40 I.R.B.453
9739, 2015-41 I.R.B.528
9740, 2015-42 I.R.B.573
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.
October 26, 2015Bulletin No. 2015– 43
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2015–27 through 2015– 43
Notices:
2014-4
Modified by
Notice 2015-51, 2015-31 I.R.B.133
2014-17
Superseded by
Notice 2015-67, 2015-41 I.R.B.546
Proposed Regulations:
2009-57
Obsoleted by
REG-112997-10 2015-39 I.R.B.422
Revenue Procedures:
1992-75
Clarified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2003-40
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2003-78
Modified by
Rev. Proc. 2015-46, 2015-39 I.R.B.414
2006-9
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2006-9
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2006-54
Modified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2006-54
Superseded by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
2008-31
Modified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2008-31
Superseded by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2011-49
Modified by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
Revenue Procedures:—Continued
2011-49
Superseded by
Rev. Proc. 2015-36, 2015-27 I.R.B.20
2015-14
Modified by
Rev. Proc. 2015-39, 2015-33 I.R.B.195
2015-40
Amplified by
Rev. Proc. 2015-41, 2015-35 I.R.B.263
2015-41
Amplified by
Rev. Proc. 2015-40, 2015-35 I.R.B.236
Treasury Decisions:
58-422
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
66-284
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-250
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
79-289
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
96-29
Obsoleted by
T.D. 9739 2015-41 I.R.B.528
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– 43October 26, 2015
iii

INTERNAL REVENUE BULLETIN
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