Internal Revenue Bulletin 2018-17 (PDF rendition): IRS Revenue Procedures

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.
Employee Plans
Notice 2018–24, page 507.
This notice requests comments on the potential expansion of
the scope of the determination letter program for individually
designed plans during the 2019 calendar year, beyond provi-
sion of determination letters for initial qualification and qualifi-
cation upon plan termination.
Income Tax
Notice 2018–32, page 507.
This notice publishes the reference price under § 45K(d)(2)(C)
of the Internal Revenue Code for calendar year 2017. The
reference price applies in determining the amount of the en-
hanced oil recovery credit under § 43, the marginal well pro-
duction credit under § 45I, and the percentage depletion in
case of oil produced from marginal properties under § 613A.
Notice 2018–33, page 508.
Attached is Notice 2018–33, which provides for adjustments
to the limitation on housing expenses for purposes of section
911 of the Internal Revenue Code. These adjustments are
made on the basis of geographic differences in housing costs
relative to housing costs in the United States. Further, if the
limitation on housing expenses is higher for taxable year 2018
than the adjusted limitations on housing expenses provided in
Notice 2017–21, qualified taxpayers may apply the adjusted
limitations for taxable year 2018 to their 2017 taxable year.
Rev. Proc. 2018–23, page 516.
Attached is Revenue Procedure 2018–23, which provides a
waiver for the time requirements for individuals electing to
exclude their foreign earned income who must leave a foreign
country because of war, civil unrest, or similar adverse condi-
tions in that country. Rev. Proc. 2018–23 adds Turkey to the
list of waiver countries for tax year 2016 for which the mini-
mum time requirements are waived. No country is added to the
list of waiver countries for tax year 2017. Generally, U.S.
citizens or resident aliens living and working abroad are taxed
on their worldwide income. However, if their tax home is in a
foreign country and they meet either the bona fide residence
test or the physical presence test, they can choose to exclude
from their income a limited amount of their foreign earned
income ($101,300 for 2016). Both the bona fide residence
test and the physical presence test contain minimum time
requirements.
Finding Lists begin on page ii.
Bulletin No. 2018–17
April 23, 2018

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.
April 23, 2018Bulletin No. 2018–17

Part III. Administrative, Procedural, and Miscellaneous
REQUEST FOR COMMENTS
ON SCOPE OF
DETERMINATION LETTER
PROGRAM FOR
INDIVIDUALLY DESIGNED
PLANS DURING CALENDAR
YEAR 2019
Notice 2018–24
PURPOSE
This notice requests comments on the
potential expansion of the scope of the
determination letter program for individ-
ually designed plans during the 2019 cal-
endar year, beyond provision of determi-
nation letters for initial qualification and
qualification upon plan termination. In re-
viewing comments submitted in response
to this notice, the Department of the Trea-
sury (Treasury Department) and the Inter-
nal Revenue Service (IRS) will consider
the factors regarding the scope of the de-
termination letter program set forth in sec-
tion 4.03(3) of Revenue Procedure 2016–
37, 2016–29 I.R.B. 136. The Treasury
Department and the IRS will issue guid-
ance if they identify any additional types
of plans for which plan sponsors may
request determination letters during the
2019 calendar year.
BACKGROUND
Revenue Procedure 2016–37 sets forth
procedures for issuing determination let-
ters and describes an extension of the re-
medial amendment period for individually
designed plans. Effective January 1, 2017,
the sponsor of an individually designed
plan may submit a determination letter
application only for initial plan qualifica-
tion, for qualification upon plan termina-
tion, and in certain other limited circum-
stances identified in subsequent published
guidance. Section 4.03(3) of Rev. Proc.
2016–37 provides that the Treasury De-
partment and the IRS will consider each
year whether to accept determination let-
ter applications for individually designed
plans in specified circumstances other
than for initial qualification and qualifica-
tion upon plan termination.
REQUEST FOR COMMENTS
Comments are requested on specific
types of plans for which the Treasury De-
partment and the IRS should consider ac-
cepting determination letter applications
during calendar year 2019 in circum-
stances other than for initial qualification
and qualification upon plan termination.
As provided in section 4.03(3) of Rev.
Proc. 2016–37, circumstances for consid-
eration include, for example, significant
law changes, new approaches to plan de-
sign, and the inability of certain types of
plans to convert to pre-approved plan doc-
uments. Comments that suggest expand-
ing the scope of the program for a partic-
ular type of plan should not merely state
the type of plan, but should also specify
the issues applicable to that type of plan
that would justify review of that particular
plan type under the determination letter
program. Such issues may include specific
plan features and special plan designs ap-
plicable to that type of plan, or unresolved
questions of qualification in form with
respect to that type of plan.
Comments may be submitted in writ-
ing on or before June 4, 2018. Com-
ments should be mailed to Internal Rev-
enue Service, CC:PA:LPD:PR (Notice
2018–24), Room 5203, P.O. Box 7604,
Ben Franklin Station, Washington,
D.C. 20044, or sent electronically to
notice.comments@irscounsel.treas.gov.
Please include “Notice 2018–24” in the
subject line of any electronic communi-
cations. Alternatively, comments may
be hand delivered Monday through Fri-
day between the hours of 8:00 a.m. and
4:00 p.m. to CC:PA:LPD:PR (Notice
2018–24), Courier’s Desk, Internal
Revenue Service, 1111 Constitution
Ave., NW, Washington, D.C. 20224. All
comments will be available for public
inspection and copying.
DRAFTING INFORMATION
The principal author of this notice is
Angelique Carrington of the Office of As-
sociate Chief Counsel (Tax Exempt and
Government Entities). For further infor-
mation regarding this notice, contact Ms.
Carrington at (202) 317-4148 (not a toll-
free number).
2017 Section 45K(d)(2)(C)
Reference Price
Notice 2018–32
SECTION 1. PURPOSE
This notice publishes the reference
price under § 45K(d)(2)(C) of the Internal
Revenue Code for calendar year 2017.
The credit period for the nonconventional
source production credit under § 45K
ended on December 31, 2013, for facili-
ties producing coke or coke gas (other
than from petroleum based products).
However, the reference price continues to
apply in determining the amount of the
enhanced oil recovery credit under § 43,
the marginal well production credit for
qualified crude oil production under § 45I,
and the percentage depletion in case of oil
and natural gas produced from marginal
properties under § 613A.
SECTION 2. BACKGROUND
Section 45K(d)(2)(C) provides that the
term “reference price” means, with re-
spect to a calendar year, the Secretary’s
estimate of the annual average wellhead
price per barrel for all domestic crude oil
the price of which is not subject to regu-
lation by the United States.
Section 43(a) provides that, for pur-
poses of § 38, the enhanced oil recovery
credit for any taxable year is an amount
equal to 15 percent of the taxpayer’s qual-
ified enhanced oil recovery costs for such
taxable year.
Section 43(b)(1) provides that the
amount of enhanced oil recovery credit
for any taxable year shall be reduced by
an amount which bears the same ratio to
the amount of such credit (determined
without regard to this paragraph) as - (A)
the amount by which the reference price
for the calendar year preceding the calen-
dar year in which the taxable year begins
exceeds $28, bears to (B) $6. Section
43(b)(2) provides that the term “reference
price” means, with respect to any calendar
Bulletin No. 2018–17April 23, 2018
507

year, the reference price determined for
such calendar year under § 45K(d)(2)(C).
Section 45I(a) provides that, for pur-
poses of § 38, the marginal well produc-
tion credit for any taxable year is an
amount equal to the product of the credit
amount and the qualified crude oil produc-
tion and the qualified natural gas produc-
tion which is attributable to the taxpayer.
Section 45I(b)(1) provides that for
crude oil, the amount of the marginal well
production credit is $3 per barrel of qual-
ified crude oil production.
Section 45I(b)(2) provides that the $3
amount under § 45I(b)(1) shall each be
reduced (but not below zero) by an
amount which bears the same ratio to such
amount (determined without regard to this
paragraph) as – (i) the excess (if any) of
the applicable reference price over $15,
bears to (ii) $3. The applicable reference
price for a taxable year is the reference
price of the calendar year preceding the
calendar year in which the taxable year
begins.
Section 45I(c) provides that the term
reference price means, with respect to any
calendar year – (i) in the case of qualified
crude oil production, the reference price
determined under § 45K(d)(2)(C).
Section 613A(c)(6)(A) provides, in
general, the allowance for depletion under
§ 611 shall be computed in accordance
with § 613 with respect to - (i) so much of
the taxpayer’s average daily marginal pro-
duction of domestic crude oil as does not
exceed the taxpayer’s depletable oil quan-
tity (determined without regard to para-
graph (3)(A)(ii)), and (ii) so much of the
taxpayer’s average daily marginal produc-
tion of domestic natural gas as does not
exceed the taxpayer’s depletable natural
gas quantity (determined without regard
to paragraph (3)(A)(ii)), and the applica-
ble percentage shall be deemed to be spec-
ified in subsection (b) of § 613 for pur-
poses of subsection (a) of that section.
Section 613A(c)(6)(C) provides that
the term “applicable percentage” means
the percentage (not greater than 25 per-
cent) equal to the sum of - (i) 15 percent,
plus (ii) 1 percentage point for each whole
dollar by which $20 exceeds the reference
price for crude oil for the calendar year
preceding the calendar year in which the
taxable year begins. For purposes of this
paragraph, the term “reference price”
means, with respect to any calendar year,
the reference price determined for such
calendar year under § 45K(d)(2)(C).
SECTION 3. REFERENCE PRICE
The reference price under § 45K(d)(2)(C)
for calendar year 2017 is $48.05.
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is
Martha M. Garcia of the Office of Asso-
ciate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice, contact Ms. Garcia
on (202) 317-6853 (not a toll-free num-
ber).
Determination of Housing
Cost Amounts Eligible for
Exclusion or Deduction for
2018
Notice 2018–33
SECTION 1. PURPOSE
This notice provides adjustments to the
limitation on housing expenses for pur-
poses of section 911 of the Internal Rev-
enue Code for specific locations for 2018.
These adjustments are made on the basis
of geographic differences in housing costs
relative to housing costs in the United
States.
SECTION 2. BACKGROUND
Section 911(a) allows a qualified indi-
vidual to elect to exclude from gross in-
come the foreign earned income and hous-
ing cost amount of such individual. The
term “housing cost amount” is generally
the total of the housing expenses for the
taxable year minus a base housing
amount. See section 911(c)(1). For this
purpose, the housing expenses taken
into account are limited to an amount
that is tied to the maximum foreign
earned income exclusion. Specifically,
the limit on such housing expenses
equals 30 percent (adjusted as may be
provided under the Secretary’s authority
under section 911(c)(2)(B)) of the max-
imum exclusion amount (computed on a
daily basis), multiplied by the number of
days in the applicable period that fall
within the taxable year. See section
911(c)(2)(A). Thus, under this general
limitation, a qualified individual whose
entire taxable year is within the appli-
cable period is limited to maximum
housing expenses of $31,230 ($104,100
x .30) for 2018.
Similarly, the computation of the base
housing amount is also tied to the maxi-
mum foreign earned income exclusion.
Specifically, the base housing amount is
16% of the maximum exclusion amount
(computed on a daily basis), multiplied by
the number of days in the applicable pe-
riod that fall within the taxable year. See
sections 911(c)(1)(B) and 911(d)(1). As-
suming that the entire taxable year of a
qualified individual is within the applica-
ble period, the base housing amount for
2018 is $16,656 ($104,100 x .16).Section
911(c)(2)(B) authorizes the Secretary to is-
sue regulations or other guidance to adjust
the percentage under section 911(c)(2)
(A)(i) (which determines the limit on hous-
ing expenses) based on geographic differ-
ences in housing costs relative to housing
costs in the United States. Pursuant to this
authority, the Department of the Treasury
(Treasury Department) and the Internal
Revenue Service (IRS) have published an-
nual notices concerning the limitation on the
section 911 housing cost amounts since the
2006 taxable year.
For more background on the foreign
housing exclusion, see https://www.irs.gov/
individuals/international-taxpayers/foreign-
housing-exclusion-or deduction.
SECTION 3. TABLE OF ADJUSTED
LIMITATIONS FOR 2018
The following table provides adjusted
limitations on housing expenses (in lieu
of the otherwise applicable limitation of
$31,230) for 2018.
April 23, 2018Bulletin No. 2018–17
508

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
AngolaLuanda84,000230.14
ArgentinaBuenos Aires56,500154.79
AustraliaMelbourne32,10087.95
AustraliaPerth34,30093.97
AustraliaSydney64,700177.26
AustriaVienna35,40096.99
Bahamas, TheNassau49,700136.16
BahrainBahrain48,300132.33
BarbadosBarbados37,700103.29
BelgiumAntwerp31,30085.75
BelgiumBrussels42,900117.53
BelgiumGosselies38,200104.66
BelgiumHoogbuul31,30085.75
BelgiumMons38,200104.66
BelgiumSHAPE/Chievres38,200104.66
BermudaBermuda90,000246.58
BrazilRio de Janeiro35,10096.16
BrazilSao Paulo56,600155.07
CanadaCalgary39,400107.95
CanadaMontreal52,500143.84
CanadaOttawa44,600122.19
CanadaQuebec35,70097.81
CanadaToronto46,700127.95
CanadaVancouver44,700122.47
CanadaVictoria40,500110.96
Cayman IslandsGrand Cayman48,000131.51
ChileSantiago40,900112.05
ChinaBeijing71,200195.07
ChinaHong Kong114,300313.15
ChinaShanghai57,001156.17
ColombiaBogota58,700160.82
ColombiaAll cities other than Bogota49,400135.34
Costa RicaSan Jose32,00087.67
Democratic Republic
of the Congo
Kinshasa42,000115.07
DenmarkCopenhagen43,704119.74
Dominican Republic Santo Domingo45,500124.66
EcuadorQuito38,200104.66
El SalvadorSan Salvador32,00087.67
EstoniaTallinn46,600127.67
FranceGarches73,600201.64
FranceLyon40,700111.51
FranceMarseille39,700108.77
FranceMontpellier32,80089.86
FranceParis73,600201.64
FranceSevres73,600201.64
Bulletin No. 2018–17April 23, 2018
509

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
FranceSuresnes73,600201.64
FranceVersailles73,600201.64
FranceAll cities other than Garches, Le Havre,
Lyon, Marseille, Montpellier, Paris,
Sevres, Suresnes and Versailles
31,90087.40
GermanyBabenhausen36,10098.90
GermanyBaumholder35,90098.36
GermanyBerlin44,100120.82
GermanyBirkenfeld35,90098.36
GermanyBoeblingen43,900120.27
GermanyBonn42,000115.07
GermanyCologne56,200153.97
GermanyDarmstadt36,10098.90
GermanyFrankfurt am Main37,700103.29
GermanyGarmisch-Partenkirchen33,90092.88
GermanyGelnhausen45,500124.66
GermanyGiessen36,00098.63
GermanyGrafenwoehr36,40099.73
GermanyHanau45,500124.66
GermanyHeidelberg33,70092.33
GermanyIdar-Oberstein35,90098.36
GermanyIngolstadt51,500141.10
GermanyKaiserslautern, Landkreis44,200121.10
GermanyKarlsruhe34,80095.34
GermanyKoblenz35,40096.99
GermanyLeimen33,70092.33
GermanyLudwigsburg43,900120.27
GermanyMainz48,100131.78
GermanyMannheim33,70092.33
GermanyMunich51,500141.10
GermanyNellingen43,900120.27
GermanyNeubruecke35,90098.36
GermanyOber Ramstadt36,10098.90
GermanyOberammergau33,90092.88
GermanyPfullendorf35,40096.99
GermanyPirmasens44,200121.10
GermanyRheinau33,70092.33
GermanySchwetzingen33,70092.33
GermanySeckenheim33,70092.33
GermanySembach44,200121.10
GermanyStuttgart43,900120.27
GermanyVilseck36,40099.73
GermanyWahn42,000115.07
GermanyWiesbaden48,100131.78
GermanyZweibrueken44,200121.10
April 23, 2018Bulletin No. 2018–17
510

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
GermanyAll cities other than Augsburg, Baben-
hausen, Bad Aibling, Bad Kreuznach,
Bad Nauheim, Baumholder, Berchtes-
gaden, Berlin, Birkenfeld, Boeblingen,
Bonn, Bremen, Bremerhaven, Butz-
bach, Cologne, Darmstadt, Delmen-
horst, Duesseldorf, Erlangen, Flensburg,
Frankfurt am Main, Friedberg, Fuerth,
Garlstedt, Garmisch-Partenkirchen, Gei-
lenkirchen, Gelnhausen, Germersheim,
Giebelstadt, Grafenwoehr, Grefrath,
Greven, Gruenstadt, Hamburg, Hanau,
Handorf, Hannover, Heidelberg, Hei-
lbronn, Herongen, Idar-Oberstein, In-
golstadt, Kaiserslautern, Landkreis,
Kalkar, Karlsruhe, Kerpen, Kitzingen,
Koblenz, Leimen, Leipzig, Ludwigs-
burg, Mainz, Mannheim, Mayen,
Moenchen-Gladbach, Muenster, Mu-
nich, Nellingen, Neubruecke, Noer-
venich, Nuernberg, Ober Ramstadt,
Oberammergau, Osterholz-Scharmbeck,
Pirmasens, Rheinau, Rheinberg,
Schwabach, Schwetzingen, Secken-
heim, Sembach, Stuttgart, Twisteden,
Vilseck, Wahn, Wertheim, Wiesbaden,
Worms, Wuerzburg, Zirndorf and
Zweibrueken
35,40096.99
GhanaAccra36,00098.63
GreeceAthens36,10098.90
GreeceElefsis36,10098.90
GreeceEllinikon36,10098.90
GreeceMt. Parnis36,10098.90
GreeceMt. Pateras36,10098.90
GreeceNea Makri36,10098.90
GreecePiraeus36,10098.90
GreeceTanagra36,10098.90
GuatemalaGuatemala City41,800114.52
GuineaConakry51,300140.55
GuyanaGeorgetown35,00095.89
Holy See, TheHoly See, The49,000134.25
HungaryBudapest32,50089.04
IndiaMumbai67,920186.08
IndiaNew Delhi56,124153.76
IndonesiaJakarta37,776103.50
IrelandBeer Sheva56,200153.97
IrelandDublin42,600116.71
IrelandShannon Area33,70092.33
IsraelTel Aviv50,800139.18
ItalyGenoa41,800114.52
ItalyLa Spezia40,400110.68
ItalyMilan73,200200.55
Bulletin No. 2018–17April 23, 2018
511

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
ItalyNaples49,100134.52
ItalyParma37,200101.92
ItalyPordenone-Aviano38,100104.38
ItalyRome49,000134.25
ItalyTurin36,600100.27
ItalyVicenza39,900109.32
JamaicaKingston41,200112.88
JapanAtsugi39,700108.77
JapanCamp Zama39,700108.77
JapanChiba-Ken39,700108.77
JapanFussa39,700108.77
JapanGifu74,300203.56
JapanHaneda39,700108.77
JapanIwakuni31,40086.03
JapanKanagawa-Ken39,700108.77
JapanKomaki74,300203.56
JapanMachidi-Shi39,700108.77
JapanMisawa31,70086.85
JapanNagoya74,300203.56
JapanOkinawa Prefecture56,000153.42
JapanOsaka-Kobe90,664248.39
JapanSagamihara39,700108.77
JapanSaitama-Ken39,700108.77
JapanSasebo32,20088.22
JapanTachikawa39,700108.77
JapanTokyo89,000243.84
JapanTokyo-to39,700108.77
JapanYokohama47,400129.86
JapanYokosuka46,100126.30
JapanYokota37,400102.47
JerusalemJerusalem49,000134.25
JerusalemWest Bank49,000134.25
KazakhstanAlmaty48,000131.51
KoreaCamp Carroll31,60086.58
KoreaCamp Colbern54,200148.49
KoreaCamp Market59,300162.47
KoreaCamp Mercer54,200148.49
KoreaK-1659,300162.47
KoreaKimhae31,70086.85
KoreaKimpo Airfield59,300162.47
KoreaMunsan33,90092.88
KoreaOsan AB39,200107.40
KoreaPohang31,90087.40
KoreaPusan31,70086.85
KoreaPyongtaek42,200115.62
KoreaSeoul59,300162.47
April 23, 2018Bulletin No. 2018–17
512

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
KoreaSuwon59,300162.47
KoreaTaegu36,00098.63
KoreaTongduchon35,20096.44
KoreaUijongbu32,70089.59
KoreaWaegwan31,60086.58
KoreaAll cities other than Ammo Depot #9,
Camp Carroll, Camp Colbern, Camp
Market, Camp Mercer, Changwon,
Chinhae, Chunchon, K-16, Kimhae,
Kimpo Airfield, Kunsun, Kwangju,
Munsan, Osan AB, Pusan, Pyongtaek,
Seoul, Suwon, Taegu, Tongduchon,
Uijongbu, and Waegwan
31,90087.40
KuwaitKuwait City64,400176.44
KuwaitAll cities other than Kuwait City57,700158.08
LuxembourgLuxembourg40,100109.86
MacedoniaSkopje35,40096.99
MalaysiaKuala Lumpur46,200126.58
MalaysiaAll cities other than Kuala Lumpur33,70092.33
MaltaMalta55,100150.96
MexicoMerida37,900103.84
MexicoMexico City47,900131.23
MexicoMonterrey33,20090.96
MexicoAll cities other than Ciudad Juarez, Cuer-
navaca, Guadalajara, Hermosillo, Mata-
moros, Mazatlan, Merida, Metapa,
Mexico City, Monterrey, Nogales,
Nuevo Laredo, Reynosa, Tapachula,
Tijuana, Tuxtla Gutierrez, and Veracruz
39,400107.95
MozambiqueMaputo39,500108.22
NamibiaWindhoek32,10087.95
NetherlandsAmsterdam52,900144.93
NetherlandsAruba36,00098.63
NetherlandsBrunssum35,90098.36
NetherlandsEygelshoven35,90098.36
NetherlandsHague, The58,400160.00
NetherlandsHeerlen35,90098.36
NetherlandsHoensbroek35,90098.36
NetherlandsHulsberg35,90098.36
NetherlandsKerkrade35,90098.36
NetherlandsLandgraaf35,90098.36
NetherlandsMaastricht35,90098.36
NetherlandsPapendrecht35,20096.44
NetherlandsRotterdam35,20096.44
NetherlandsSchaesburg35,90098.36
NetherlandsSchinnen35,90098.36
NetherlandsSchiphol52,900144.93
NetherlandsYpenburg58,400160.00
Bulletin No. 2018–17April 23, 2018
513

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
NetherlandsAll cities other than Amsterdam, Aruba,
Brunssum, Coevorden, Eygelshoven,
The Hague, Heerlen, Hoensbroek, Huls-
berg, Kerkrade, Landgraaf, Maastricht,
Margraten, Papendrecht, Rotterdam,
Schaesburg, Schinnen, Schiphol, and
Ypenburg
34,70095.07
Netherlands Antilles Curacao45,800125.48
New ZealandAuckland35,70097.81
New ZealandChristchurch32,10087.95
New ZealandWellington33,80092.60
NicaraguaManagua31,80087.12
NigeriaAbuja36,00098.63
NorwayOslo36,10098.90
OmanMuscat41,300113.15
PanamaPanama City39,500108.22
PeruLima39,100107.12
PhilippinesCavite33,50091.78
PhilippinesManila37,380102.41
PortugalAlverca44,800122.74
PortugalLisbon44,800122.74
QatarAl Udeid (in All Cities)32,40088.77
QatarDoha45,888125.72
QatarAll cities other than Doha32,40088.77
RomaniaBucharest41,200112.88
RussiaMoscow108,000295.89
RussiaSaint Petersburg60,000164.38
RussiaSakhalin Island77,500212.33
RussiaVladivostok77,500212.33
RussiaYekaterinburg47,400129.86
RwandaKigali31,50086.30
Saudi ArabiaJeddah30,66784.02
Saudi ArabiaRiyadh40,000109.59
SingaporeSingapore80,500220.55
SloveniaLjubljana51,400140.82
South AfricaPretoria39,300107.67
SpainBarcelona40,600111.23
SpainMadrid59,700163.56
SpainRota36,500100.00
SpainValencia34,30093.97
SurinameParamaribo33,00090.41
SwitzerlandBern65,600179.73
SwitzerlandGeneva93,300255.62
SwitzerlandZurich39,219107.45
SwitzerlandAll cities other than Bern, Geneva and
Zurich
32,90090.14
TaiwanTaipei46,188126.54
TanzaniaDar Es Salaam44,000120.55
April 23, 2018Bulletin No. 2018–17
514

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
ThailandBangkok59,000161.64
Trinidad and Tobago Port of Spain54,500149.32
TurkeyIzmir-Cigli31,60086.58
TurkeyYamanlar31,60086.58
UkraineKiev72,000197.26
United Arab Emirates Abu Dhabi49,687136.13
United Arab Emirates Dubai57,174156.64
United KingdomBasingstoke41,099112.60
United KingdomBath41,000112.33
United KingdomBracknell62,100170.14
United KingdomBristol33,10090.68
United KingdomBrookwood37,200101.92
United KingdomCambridge36,10098.90
United KingdomCaversham73,800202.19
United KingdomCheltenham43,900120.27
United KingdomCroughton38,000104.11
United KingdomFairford35,90098.36
United KingdomFarnborough54,700149.86
United KingdomFelixstowe34,80095.34
United KingdomGibraltar44,616122.24
United KingdomHarrogate39,200107.40
United KingdomHigh Wycombe62,100170.14
United KingdomHuntingdon37,200101.92
United KingdomKemble35,90098.36
United KingdomLakenheath47,900131.23
United KingdomLiverpool32,60089.32
United KingdomLondon72,600198.90
United KingdomLoudwater57,200156.71
United KingdomMenwith Hill39,200107.40
United KingdomMildenhall47,900131.23
United KingdomOxfordshire36,40099.73
United KingdomPlymouth36,40099.73
United KingdomPortsmouth36,40099.73
United KingdomReading62,100170.14
United KingdomRochester37,400102.47
United KingdomSamlesbury37,200101.92
United KingdomSouthampton44,200121.10
United KingdomSurrey48,402132.61
United KingdomWaterbeach37,300102.19
United KingdomWiltshire34,70095.07
Bulletin No. 2018–17April 23, 2018
515

CountryLocation
Limitation on Housing
Expenses (full year)
Limitation on Housing
Expenses (daily)
United KingdomAll cities other than Basingstoke, Bath,
Belfast, Birmingham, Bracknell, Bris-
tol, Brookwood, Brough, Cambridge,
Caversham, Chelmsford, Cheltenham,
Chicksands, Croughton, Dunstable, Ed-
inburgh, Edzell, Fairford, Farnborough,
Felixstowe, Ft. Halstead, Gibraltar,
Glenrothes, Greenham Common, Harro-
gate, High Wycombe, Huntingdon,
Hythe, Kemble, Lakenheath, Liverpool,
London, Loudwater, Menwith Hill,
Mildenhall, Nottingham, Oxfordshire,
Plymouth, Portsmouth, Reading, Roch-
ester, Samlesbury, Southampton, Sur-
rey, Waterbeach, Welford, West By-
fleet, and Wiltshire
37,200101.92
VenezuelaCaracas57,000156.16
VietnamHanoi46,800128.22
VietnamHo Chi Minh City42,000115.07
SECTION 4. OPTION TO APPLY
2018 ADJUSTED LIMITATIONS TO
2017 TAXABLE YEAR
For some locations, the limitation on
housing expenses provided in Section 3 of
this notice may be higher than the limitation
on housing expenses provided in the “Table
of Adjusted Limitations for 2017” in Notice
2017–21. A qualified individual incurring
housing expenses in such a location during
2017 may apply the adjusted limitation on
housing expenses provided in Section 3 of
this notice for 2017 in lieu of the amounts
provided in the “Table of Adjusted Limita-
tions for 2017” in Notice 2017–21 (and as
set forth in the Instructions to Form 2555,
Foreign Earned Income, for 2017).
The Treasury Department and the IRS
anticipate that future annual notices pro-
viding adjustments to housing expense
limitations will make a similar option
available to qualified individuals that in-
cur housing expenses in the immediately
preceding year. For example, when ad-
justed housing expense limitations for
2019 are issued, it is expected that taxpay-
ers will be permitted to apply those ad-
justed limitations to the 2018 taxable year.
SECTION 5. Filing Prior Year or
Amended Tax Returns
Notice 2011–8, 2011–8 I.R.B. 503;
Notice 2012–19, 2012–10 I.R.B. 440; No-
tice 2013–31, 2013–21 I.R.B. 1099; No-
tice 2014–29, 2014–18 I.R.B. 991; Notice
2015–33, 2015–18 I.R.B. 934; No-
tice 2016–21, 2016–12 I.R.B. 465; and No-
tice 2017–21, 2017–13 I.R.B. 1026 are
relisted to assist those individuals who are
filing prior year or amended tax returns.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
This notice supersedes Notice 2006–
87, 2006–43 I.R.B. 766; Notice 2007–25,
2007–12 I.R.B. 760; Notice 2007–77,
2007–40 I.R.B. 735; Notice 2008–107,
2008–50 I.R.B. 1265; Notice 2010–27,
2010–15 I.R.B. 531; Notice 2011–8,
2011–8 I.R.B. 503; Notice 2012–19,
2012–10 I.R.B. 440; Notice 2013–31,
2013–21 I.R.B. 1099; Notice 2014–29,
2014–18 I.R.B. 991; Notice 2015–33,
2015–18 I.R.B. 934; Notice 2016–21,
2016–12 I.R.B. 465; and Notice 2017–21,
2017–13 I.R.B. 1026.
SECTION 7. EFFECTIVE DATE
This notice is effective for taxable
years beginning on or after January 1,
2018. However, as provided in Section 4,
a taxpayer may apply the 2018 adjusted
housing limitations contained in Section 3
of this notice to his or her taxable year
beginning in 2017.
SECTION 8. DRAFTING
INFORMATION
The principal author of this notice is
Kate Y. Hwa of the Office of Associate
Chief Counsel (International). For further
information regarding this notice contact
Kate Y. Hwa on (202) 317-6934 (not a
toll-free number).
26 CFR § 1.911–2: Qualified individuals.
(Also: Part I, §§ 911; 1.911–2.)
Rev. Proc. 2018–23
SECTION 1. PURPOSE
.01 This revenue procedure provides
information to any individual who failed
to meet the eligibility requirements of
section 911(d)(1) of the Internal Reve-
nue Code because adverse conditions in
a foreign country precluded the individ-
ual from meeting those requirements.
.02 The Internal Revenue Service
previously has listed countries for which
the eligibility requirements of section
911(d)(1) of the Code are waived under
section 911(d)(4) because of adverse
conditions in those countries. See
Rev. Proc. 2017–26, 2017–13, I.R.B.
1036.
April 23, 2018Bulletin No. 2018–17
516

SECTION 2. BACKGROUND
.01 Sections 911(a) of the Code allows
a “qualified individual,” as defined in sec-
tion 911(d)(1), to exclude from gross in-
come the individual’s foreign earned in-
come and the housing cost amount.
.02 Section 911(d)(1) of the Code de-
fines the term “qualified individual” as an
individual whose tax home is in a foreign
country and who is (A) a citizen of the
United States and establishes to the satis-
faction of the Secretary of the Treasury
that the individual has been abona fide
resident of a foreign country or countries
for an uninterrupted period that includes
an entire taxable year, or (B) a citizen or
resident of the United States who, during
any period of 12 consecutive months, is
present in a foreign country or countries
during at least 330 full days.
.03 Section 911(d)(4) of the Code
provides anexception to the eligibility re-
quirements of section 911(d)(1). An individ-
ual will be treated as a qualified individual
with respect to a period in which the indi-
vidual was abona fideresident of, or was
present in, a foreign country if the individual
left the country during a period for which
the Secretary of the Treasury, after consul-
tation with the Secretary of State, deter-
mines that individuals were required to
leave because of war, civil unrest, or similar
adverse conditions that precluded the nor-
mal conduct of business. An individual must
establish that but for those conditions the
individual could reasonably have been ex-
pected to meet the eligibility requirements.
SECTION 3. APPLICATION
.01 For 2016, in addition to the deter-
mination with respect to South Sudan de-
scribed in Rev. Proc. 2017–26, the Secre-
tary of the Treasury, in consultation with
the Secretary of State, has determined that
war, civil unrest, or similar adverse con-
ditions precluded the normal conduct of
business in the following country begin-
ning on the specified date:
CountryDate of Departure On or After
TurkeyOctober 29, 2016
Accordingly, for purposes of section
911 of the Code, an individual who left
Turkey on or after October 29, 2016, will
be treated as a qualified individual with
respect to the period during which that
individual was present in, or was abona
fideresident of, Turkey if the individual
establishes a reasonable expectation that
he or she would have met the require-
ments of section 911(d) but for those con-
ditions.
.02 To qualify for relief under section
911(d)(4) of the Code, an individual must
have established residency, or have been
physically present, in the foreign country
on or before the date that the Secretary of
the Treasury determines that individuals
were required to leave the foreign country.
Accordingly, individuals who were first
physically present or established resi-
dency in Turkey after October 29, 2016,
are not eligible to qualify for the excep-
tion provided in section 911(d)(4) of the
Code for taxable year 2016.
.03 For 2017, the Secretary of the Trea-
sury, in consultation with the Secretary of
State, has determined that no country has
experienced war, civil unrest, or similar
adverse conditions that precluded the nor-
mal conduct of business. Therefore, no
country is listed in this revenue procedure
for section 911 purposes for tax year
2017.
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Previously issued revenue procedures
under section 911(d)(4) remain in full
force and effect. However, Rev. Proc.
2017–26, 2017–13, I.R.B. 1036, is supple-
mented.
SECTION 5. INQUIRIES
A taxpayer who needs assistance on how
to claim this exclusion, or on how to file an
amended return, should consult the section
under the headingForeign Earned Income
Exclusionathttps://www.irs.gov/individuals/
international-taxpayers/us-citizens-and-
resident-aliens-abroad; consult the sec-
tion under the headingHowtoGetTax
Helpat the same web address; or con-
tact a local IRS office.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kate Y. Hwa of the Office of
Associate Chief Counsel (International).
For further information regarding this rev-
enue procedure contact Kate Y. Hwa on
(202) 317-6934 (not a toll free number).
Bulletin No. 2018–17April 23, 2018
517

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
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
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,modifiedand
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. 2018–17April 23, 2018
i

Numerical Finding List
1
Bulletin 2018–1 through 2018–17
Announcements:
2018-01, 2018-9 I.R.B.387
2018-02, 2018-9 I.R.B.387
2018-03, 2018-9 I.R.B.387
2018-04, 2018-10 I.R.B.401
2018-05, 2018-13 I.R.B.461
2018-07, 2018-16 I.R.B.503
Notices:
2018-01, 2018-3 I.R.B.285
2018-02, 2018-2 I.R.B.281
2018-03, 2018-2 I.R.B.285
2018-05, 2018-6 I.R.B.341
2018-06, 2018-3 I.R.B.300
2018-07, 2018-4 I.R.B.317
2018-08, 2018-7 I.R.B.352
2018-10, 2018-8 I.R.B.359
2018-11, 2018-11 I.R.B.425
2018-12, 2018-12 I.R.B.441
2018-13, 2018-6 I.R.B.341
2018-14, 2018-7 I.R.B.353
2018-15, 2018-9 I.R.B.376
2018-16, 2018-10 I.R.B.390
2018-17, 2018-9 I.R.B.376
2018-18, 2018-12 I.R.B.443
2018-19, 2018-12 I.R.B.443
2018-20, 2018-12 I.R.B.444
2018-21, 2018-15 I.R.B.472
2018-22, 2018-14 I.R.B.464
2018-23, 2018-15 I.R.B.474
2018-24, 2018-17 I.R.B.507
2018-25, 2018-15 I.R.B.476
2018-26, 2018-16 I.R.B.480
2018-28, 2018-16 I.R.B.492
2018-29, 2018-16 I.R.B.495
2018-31, 2018-16 I.R.B.501
2018-32, 2018-17 I.R.B.507
2018-33, 2018-17 I.R.B.508
Proposed Regulations:
REG-119514-15, 2018-04 I.R.B.325
REG-129260-16, 2018-14 I.R.B.470
REG-118067-17, 2018-08 I.R.B.360
REG-132197-17, 2018-10 I.R.B.404
REG-132197-17, 2018-10 I.R.B.404
REG-132434-17, 2018-16 I.R.B.503
Revenue Procedures:
2018-1, 2018-1 I.R.B.1
2018-2, 2018-1 I.R.B.106
2018-3, 2018-1 I.R.B.130
2018-4, 2018-1 I.R.B.146
2018-5, 2018-1 I.R.B.244
Revenue Procedures:—Continued
2018-7, 2018-1 I.R.B.282
2018-8, 2018-2 I.R.B.286
2018-9, 2018-2 I.R.B.290
2018-10, 2018-7 I.R.B.355
2018-11, 2018-5 I.R.B.334
2018-12, 2018-6 I.R.B.349
2018-13, 2018-7 I.R.B.356
2018-14, 2018-9 I.R.B.378
2018-15, 2018-9 I.R.B.379
2018-16, 2018-9 I.R.B.383
2018-17, 2018-9 I.R.B.384
2018-18, 2018-10 I.R.B.392
2018-19, 2018-14 I.R.B.466
2018-20, 2018-11 I.R.B.427
2018-21, 2018-14 I.R.B.467
2018-23, 2018-17 I.R.B.516
Revenue Rulings:
2018-01, 2018-2 I.R.B.275
2018-02, 2018-2 I.R.B.277
2018-03, 2018-2 I.R.B.278
2018-04, 2018-4 I.R.B.304
2018-05, 2018-6 I.R.B.339
2018-06, 2018-10 I.R.B.388
2018-07, 2018-13 I.R.B.445
2018-09, 2018-14 I.R.B.462
2018-10, 2018-16 I.R.B.477
Treasury Decisions:
9829, 2018-04 I.R.B.308
9830, 2018-11 I.R.B.423
9831, 2018-13 I.R.B.459
9832, 2018-16 I.R.B.477
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
April 23, 2018Bulletin No. 2018–17
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2018–1 through 2018–17
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
Bulletin No. 2018–17April 23, 2018
iii

INTERNAL REVENUE BULLETIN
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Bulletins are available atwww.irs.gov/irb/.
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would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
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