Internal Revenue Bulletin 2018-38 (PDF rendition): IRS Revenue Procedures

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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 2018–70, page 441.
The notice informs taxpayers that the Treasury Department
and the IRS intend to issue proposed regulations providing that
the reduction of the exemption amount to zero under
§151(d)(5)(A) for taxable years 2018 –2025 will not be taken
into account in determining whether a taxpayer is a “qualifying
relative” under §152(d)(1)(B) for various provisions of the
Code, including the credit for other dependents under
§24(h)(4) and the head-of-household filing status under §2(b).
The §151(d) exemption amount referenced in §152(d)(1)(B) will
be treated as $4,150 (adjusted for inflation) for taxable years
in which the §151(d)(5)(A) exemption amount is zero.
REV. PROC. 2018–36, page 442.
This revenue procedure provides a current list of jurisdictions
with respect to which the reporting requirement of §§ 1.6049 –
4(b)(5) and 1.6049 – 8(a) of the Income Tax Regulations ap-
plies, effective for interest paid on or after January 1, 2019.
This revenue procedure adds two countries, Argentina and
Moldova, to this list. This revenue procedure also provides a
current list of jurisdictions with which the Department of the
Treasury and the Internal Revenue Service have determined
that it is appropriate to have an automatic exchange relation-
ship with respect to the information collected under
§§ 1.6049 – 4(b)(5) and 1.6049 – 8(a). This revenue procedure
adds one country, Greece, to this list. These two lists were last
updated by Rev. Proc. 2017– 46, 2017– 43 I.R.B. 372.
Finding Lists begin on page ii.
Bulletin No. 2018–38
September 17, 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.
September 17, 2018Bulletin No. 2018–38

Part III. Administrative, Procedural, and Miscellaneous
Guidance on Qualifying
Relative and the Exemption
Amount
Notice 2018–70
SECTION 1. PURPOSE
The Department of the Treasury (Trea-
sury Department) and the Internal Reve-
nue Service (IRS) intend to issue pro-
posed regulations clarifying the definition
of “qualifying relative” in § 152(d) for
purposes of various provisions of the In-
ternal Revenue Code (Code), including
the new $500 credit for other dependents
under § 24(h)(4) and head of household
filing status under § 2(b), for taxable years
in which the § 151(d) exemption amount
is zero.
SECTION 2. BACKGROUND
In general, § 151(a) of the Code allows
a taxpayer to claim deductions for exemp-
tions for the taxpayer and his or her
spouse (§ 151(b)), and for any dependents
(§ 151(c)). Before amendment by “An Act
to provide for reconciliation pursuant to
titles II and V of the concurrent resolution
on the budget for fiscal year 2018,” Pub.
L. No. 115–97 (Act), § 151(d) provided
for an exemption amount of a base dollar
amount that was adjusted for inflation.
Before the Act, the exemption amount for
2018 was calculated to be $4,150.See
Rev. Proc. 2017–58, 2017–45 I.R.B. 489,
modified and superseded by Rev. Proc.
2018–18, 2018–10 I.R.B. 392.
Section 152(a) of the Code generally
defines a “dependent” to mean a “qualify-
ing child” or a “qualifying relative.” Sec-
tion 152(d)(1) defines a qualifying relative
to mean an individual (A) who bears a
specific relationship to the taxpayer, (B)
whose gross income for the calendar year
in which the taxpayer’s taxable year be-
gins is less than the exemption amount (as
defined in § 151(d)), (C) who receives
over one-half of his or her support from
the taxpayer for the calendar year in
which the taxpayer’s taxable year begins,
and (D) who is not a qualifying child of
the taxpayer or any other taxpayer for any
taxable year beginning in the calendar
year in which the taxpayer’s taxable year
begins.
Section 11041(a)(2) of the Act added
§ 151(d)(5) to provide special rules for
taxable years 2018 through 2025 for the
exemption amount in § 151(d). Specifi-
cally, § 151(d)(5)(A) provides that, for a
taxable year beginning after December 31,
2017, and before January 1, 2026, the
term “exemption amount” means zero,
thereby suspending the deduction for per-
sonal exemptions.SeeH.R. Rep. No. 115–
466 at 204 (2017) (Conf. Rep.). However,
§ 151(d)(5)(B) provides that, for purposes
of any other provision of the Code, the
reduction of the exemption amount to zero
will not be taken into account in determin-
ing whether a deduction is allowed or
allowable, or whether a taxpayer is enti-
tled to a deduction, under § 151. The
Conference Report states that this provi-
sion clarifies that the reduction of the per-
sonal exemption to zero “should not alter
the operation of those provisions of the
Code which refer to a taxpayer allowed a
deduction...under section 151,” includ-
ing the child tax credit in § 24(a).Id.at
203 n.16.
Section 11022(a) of the Act amended
§ 24 of the Code to create a $500 credit for
certain dependents of a taxpayer other than a
qualifying child described in § 24(c), for
whom the child tax credit is allowed. The
$500 credit applies to two categories of de-
pendents: (1) qualifying children for whom
a child tax credit is not allowed and (2)
qualifying relatives as defined in § 152(d).
See§ 24(h)(4)(A). Like the amendment to
§ 151(d) reducing the exemption amount to
zero, this new credit applies for taxable
years 2018 through 2025. The Conference
Report explains the intended scope of this
credit: “The credit is further modified to
temporarily provide for a $500 nonrefund-
able credit for qualifying dependents other
than qualifying children. The provision gen-
erallyretains the present-law definition of
dependent.” See H.R. Rep. No. 115–466 at
227 (emphasis added).
Separately, Code § 2(b)(1)(A) defines a
head of household to include an individual
who is not married at the close of the
taxable year, who is not a surviving
spouse (as defined in § 2(a)), and who
maintains as his or her home a household
for a qualifying individual for the required
period of time. A qualifying individual
under § 2(b)(1)(A)(ii) includes a qualify-
ing relative if the taxpayer is entitled to a
deduction under § 151 for the person for
the taxable year. Under § 151(c), a deduc-
tion is allowed for individuals who are
dependents as defined in § 152, including
qualifying relatives described in § 152(d).
SECTION 3. GUIDANCE UNDER
CONSIDERATION
The Treasury Department and the IRS
intend to issue proposed regulations provid-
ing that the reduction of the exemption
amount to zero under § 151(d)(5)(A) for
taxable years 2018–2025 will not be taken
into account in determining whether a per-
son is a qualifying relative under § 152(d)
(1)(B). Accordingly, in defining a qualifying
relative for purposes of various provisions
of the Code that refer to the definition of
dependent in § 152, including, without lim-
itation, for purposes of the new credit under
§ 24(h)(4) and head of household filing sta-
tus under § 2(b), the § 151(d) exemption
amount referenced in § 152(d)(1)(B) will be
treated as $4,150 (adjusted for inflation), for
taxable years in which the § 151(d)(5)(A)
exemption amount is zero.
Section 151(d) provides for two different
exemption amounts for taxable years 2018
through 2025. For purposes of determining
whether a deduction is allowed for personal
exemptions, § 151(d)(5)(A) requires that the
exemption amount be zero—thereby sus-
pending this deduction. But for other provi-
sions of the Code that reference the deduc-
tion for other purposes, Congress indicated
in § 151(d)(5)(B) that the reduction of the
exemption amount to zero is not to be taken
into account. Instead, the exemption amount
should remain $4,150 for 2018 (adjusted for
inflation in future years).
Construing § 152 in light of the struc-
ture of the statute, theTreasury Department
and the IRS believe that the exemption
amount referenced in that section must be
$4,150 (adjusted for inflation), rather than
zero, for purposes of determining who is a
qualifying relative. This interpretation ac-
cords with § 151(d)(5), which aims to sus-
pend the deduction for personal exemptions
Bulletin No. 2018–38September 17, 2018
441

without substantively changing other Code
provisions that directly or indirectly refer-
ence the § 151(d) exemption amount.
This interpretation is also confirmed by
the structure of several Code provisions that
necessitate a non-zero exemption amount in
§ 152(d)(1)(B). For example, to be a quali-
fying relative under § 152(d)(1)(B), an in-
dividual must have gross income that is
“less than the exemption amount.” But if the
exemption amount were zero, an individu-
al’s gross income would have to be less than
zero—a near impossibility. And because it
would be highly unusual for an individual to
have gross income less than zero,
1
virtually
no individuals would be eligible as qualify-
ing relatives. A zero exemption amount
would thus effectively render § 152(d)(1)
(B) inoperable and eliminate an entire cate-
gory of dependents. The Treasury Depart-
ment and IRS do not believe Congress in-
tended to make such a significant change in
such an indirect manner.
In addition, the new $500credit that
Congress enacted at the same time, and in
the same Act, as it reduced the § 151(d)
exemption amount likewise depends on a
non-zero exemption amount in § 152(d)(1)
(B). Section 24(h)(4)(A), as amended, cre-
ates a $500 credit available for each depen-
dent of the taxpayer other than a qualifying
child for whom the child tax credit is al-
lowed. This provision references the defini-
tion of dependent in section 152, which
includes both qualifying relatives and qual-
ifying children, and it was understood at the
time of enactment that this provision “gen-
erally retain[ed] the present-law definition
of dependent.” H.R. Rep. No. 115–466 at
227. But if the exemption amount refer-
enced in § 152(d)(1)(B) were zero, the en-
tire category of qualifying relatives would
be effectively excised from the definition of
dependent. As a consequence, the $500
credit generally would not be available for
qualifying relatives, and the availability of
this credit would shrink to only a limited
category of qualifying children for whom
the child tax credit is not allowed. This does
not appear to be what Congress intended
when it enacted the new $500 credit.
Further, head of household filing status
also depends on a non-zero exemption
amount in § 152(d)(1)(B). Under § 2(b)(1)
(A), an individual is considered a head of
household if,inter alia, he or she main-
tains as his or her home a household for
either (i) a qualifying child or (ii) “any
other person who is a dependent of the
taxpayer.” Because the only dependents
other than qualifying children are qualify-
ing relatives, a zero exemption amount in
§ 152(d)(1)(B), and the resulting near
elimination of qualifying relatives, would
render the express provision for other de-
pendents in § 2(b)(1)(A)(ii) superfluous. It
also would deny head of household filing
status to many individuals who previously
qualified for that filing status and other-
wise would continue to qualify. There is
no reason to believe that Congress in-
tended its alteration of the § 151(d) ex-
emption amount to have this effect.
Accordingly, the Treasury Depart-
ment and IRS intend to propose regula-
tions to clarify that the reduction of the
exemption amount to zero in § 151(d)
(5)(A) for taxable years 2018–2025
does not apply to the gross income lim-
itation in the definition of qualifying
relative in § 152(d)(1)(B).
SECTION 4. RELIANCE
Before the issuance of the proposed
regulations described in this notice, tax-
payers may rely on the rules described in
section 3 of this notice.
SECTION 5. REQUEST FOR
COMMENTS
The Treasury Department and the IRS
request comments on all aspects of the
proposed guidance under consideration as
described in this notice.
Written comments may be submitted
by November 16, 2018, to Internal
Revenue Service, CC:PA:LPD:PR (No-
tice 2018–70), Room 5203, P.O. Box
7604, Ben Franklin Station, Washing-
ton, D.C. 20044, or electronically to
Notice.Comments@irscounsel.treas.gov
(please include “Notice 2018–70” in the
subject line). Alternatively, comments
may be hand-delivered between the
hours of 8:00 a.m. and 4:00 p.m. Mon-
day to Friday to CC:PA:LPD:PR (No-
tice 2018–70), Courier’s Desk, Internal
Revenue Service, 1111 Constitution Av-
enue NW, Washington, D.C. 20224.
Comments will be available for public
inspection and copying.
SECTION 6. DRAFTING
INFORMATION
The principal author of this notice is
Victoria J. Driscoll of the Office of Asso-
ciate Chief Counsel (Income Tax & Ac-
counting). For further information, re-
garding this notice contact Victoria J.
Driscoll at (202) 317-4718 (not a toll-free
number).
26 CFR 601.201: Rulings and determination letters
(Also Part 1, §§ 6049; 1.6049–4, 1.6049–8)
Implementation of
Nonresident Alien Deposit
Interest Regulations
Rev. Proc. 2018–36
SECTION 1. PURPOSE
This revenue procedure provides a
current list of the jurisdictions with re-
spect to which the reporting requirement
of §§ 1.6049–4(b)(5) and 1.6049–8(a)
of the Income Tax Regulations applies,
effective for interest paid on or after
January 1, 2019.
This revenue procedure also provides a
current list of the jurisdictions with which
the Department of the Treasury (Treasury
Department) and the Internal Revenue
Service (IRS) have determined that it is
appropriate to have an automatic ex-
change relationship with respect to the
information collected under §§ 1.6049–
4(b)(5) and 1.6049–8(a).
SECTION 2. BACKGROUND
Sections 1.6049–4(b)(5) and 1.6049–
8(a), as revised by TD 9584, 2012–20
I.R.B. 900, require the reporting of certain
deposit interest paid to nonresident alien
individuals on or after January 1, 2013.
Section 1.6049–4(b)(5) provides that in
the case of interest aggregating $10 or
more paid to a nonresident alien individ-
ual (as defined in section 7701(b)(1)(B))
that is reportable under § 1.6049–8(a), the
payor is required to make an information
return on Form 1042–S, Foreign Person’s
1
This could occur if an individual engaged in a business involving the sale of goods incurs inventory costs that exceed gross sales revenue. See § 1.61–3(a).
September 17, 2018Bulletin No. 2018–38
442

U.S. Source Income Subject to Withhold-
ing, for the calendar year in which the
interest is paid. Interest that is reportable
under § 1.6049–8(a) is interest described
in section 871(i)(2)(A)that relates to a
deposit maintained at an office within
the United States and that is paid to a
resident of a jurisdiction that is identi-
fied, in an applicable revenue procedure
(see § 601.601(d)(2)) as of December 31
prior to the calendar year in which the
interest ispaid, as a jurisdiction with which
the United States has in effect an income tax
or other convention or bilateral agreement
relating to the exchange of tax information
within the meaning of section 6103(k)(4),
under which the competent authority is the
Secretary of the Treasury or his delegate and
the United States agrees to provide, as well
as receive, information. The preamble to the
regulations noted that the IRS is not re-
quired to exchange information with an-
other jurisdiction, even if an information
exchange agreement is in effect, if there are
concerns about confidentiality, safeguarding
of data exchanged, the use of the informa-
tion, or other factors that would make the
exchange of information inappropriate.
Rev. Proc. 2012–24, 2012–20 I.R.B.
913, was published contemporaneously
with the publication of TD 9584 to pro-
vide a list of those jurisdictions with
which the United States has in force an
information exchange agreement, such
that interest paid to residents of such ju-
risdictions must be reported by payors to
the extent required under §§ 1.6049–
4(b)(5) and 1.6049–8(a), and to provide a
separate list identifying those jurisdictions
with which the automatic exchange of the
information collected under the regula-
tions has been determined by the Treasury
Department and the IRS to be appropriate.
Rev. Proc. 2012–24 was updated and
superseded by Rev. Proc. 2014–64,
2014–53 I.R.B. 1022, and the lists of ju-
risdictions in Rev. Proc. 2014–64 were
supplemented by Rev. Proc. 2015–50,
2015–42 I.R.B. 583; Rev. Proc. 2016–18,
2016–17 I.R.B. 635; Rev. Proc. 2016–56,
2016–52 I.R.B. 920; Rev. Proc. 2017–31,
2017–16 I.R.B. 1104; and Rev. Proc.
2017–46, 2017–43 I.R.B. 372.
This revenue procedure updates and
restates the lists of jurisdictions in Rev.
Proc. 2014–64 as supplemented, adding
Argentina and Moldova as jurisdictions
with which the United States has in force
a relevant information exchange agree-
ment, and adding Greece as a jurisdiction
with which the relevant automatic ex-
change of information has been deter-
mined appropriate.
SECTION 3. JURISDICTIONS OF
RESIDENCE WITH RESPECT TO
WHICH THE REPORTING
REQUIREMENT APPLIES
The following are the jurisdictions
with which the United States has in effect
an income tax or other convention or bi-
lateral agreement relating to the exchange
of tax information within the meaning of
section 6103(k)(4) pursuant to which the
United States agrees to provide, as well as
receive, information and under which the
competent authority is the Secretary of the
Treasury or his delegate:
Antigua & Barbuda
Argentina
Aruba
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belgium
Bermuda
Brazil
British Virgin Islands
Bulgaria
Canada
Cayman Islands
China
Colombia
Costa Rica
Croatia
Curaçao
Cyprus
Czech Republic
Denmark
Dominica
Dominican Republic
Egypt
Estonia
Faroe Islands
Finland
France
Germany
Gibraltar
Greece
Greenland
Grenada
Guernsey
Guyana
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Jamaica
Japan
Jersey
Kazakhstan
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Marshall Islands
Mauritius
Mexico
Moldova
Monaco
Morocco
Netherlands
Netherlands special municipalities:
Bonaire, Sint Eustatius, and Saba
New Zealand
Norway
Pakistan
Panama
Peru
Philippines
Poland
Portugal
Romania
Russian Federation
Saint Lucia
Sint Maarten
Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
Sweden
Switzerland
Thailand
Trinidad and Tobago
Tunisia
Turkey
Ukraine
United Kingdom
Venezuela
Bulletin No. 2018–38September 17, 2018
443

SECTION 4. JURISDICTIONS
WITH WHICH THE TREASURY
DEPARTMENT AND THE IRS
HAVE DETERMINED THAT
AUTOMATIC EXCHANGE OF
DEPOSIT INTEREST
INFORMATION IS APPROPRIATE
The following list identifies the juris-
dictions with which the automatic ex-
change of the information collected under
§§ 1.6049–4(b)(5) and 1.6049–8 has
been determined by the Treasury Depart-
ment and the IRS to be appropriate:
Australia
Azerbaijan
Belgium
Brazil
Canada
Colombia
Croatia
Czech Republic
Denmark
Estonia
Finland
France
Germany
Gibraltar
Greece
Guernsey
Hungary
Iceland
India
Ireland
Isle of Man
Israel
Italy
Jamaica
Jersey
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Mauritius
Mexico
Netherlands
New Zealand
Norway
Panama
Poland
Portugal
Saint Lucia
Slovak Republic
Slovenia
South Africa
Spain
Sweden
United Kingdom
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Procs. 2014–64, 2015–50, 2016–
18, 2016–56, 2017–31, and 2017–46 are
superseded with respect to interest paid on
or after January 1, 2019.
SECTION 6. EFFECTIVE DATE
With respect to the jurisdictions newly
listed in Section 3, this revenue procedure
is effective for interest paid on or after
January 1, 2019.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Jackie Bennett Manasterli of
the Office of Associate Chief Counsel (In-
ternational). For further information re-
garding this revenue procedure, contact
Ms. Manasterli at (202) 317-6941 (not a
toll-free number).
September 17, 2018Bulletin No. 2018–38
444

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. 2018–38September 17, 2018
i

Numerical Finding List
1
Bulletin 2018–27 through 2018–38
Announcements:
2018-09, 2018-28 I.R.B.206
2018-12, 2018-30 I.R.B.232
Notices:
2018-48, 2018-28 I.R.B.9
2018-56, 2018-27 I.R.B.3
2018-58, 2018-33 I.R.B.305
2018-59, 2018-28 I.R.B.196
2018-60, 2018-31 I.R.B.275
2018-61, 2018-31 I.R.B.278
2018-62, 2018-34 I.R.B.316
2018-63, 2018-34 I.R.B.318
2018-64, 2018-35 I.R.B.347
2018-65, 2018-35 I.R.B.350
2018-67, 2018-36 I.R.B.409
2018-68, 2018-36 I.R.B.418
2018-69, 2018-37 I.R.B.426
2018-70, 2018-38 I.R.B.441
Proposed Regulations:
REG-103474-18, 2018-32 I.R.B.284
REG-106977-18, 2018-27 I.R.B.6
REG-107892-18, 2018-35 I.R.B.353
REG-112176-18, 2018-37 I.R.B.430
Revenue Procedures:
2018-35, 2018-28 I.R.B.204
2018-36, 2018-38 I.R.B.442
2018-37, 2018-29 I.R.B.210
2018-38, 2018-31 I.R.B.280
2018-39, 2018-34 I.R.B.319
2018-40, 2018-34 I.R.B.320
2018-42, 2018-36 I.R.B.424
2018-43, 2018-36 I.R.B.425
2018-44, 2018-37 I.R.B.426
2018-45, 2018-37 I.R.B.428
Revenue Rulings:
2018-19, 2018-27 I.R.B.1
2018-20, 2018-28 I.R.B.8
2018-21, 2018-32 I.R.B.282
2018-22, 2018-34 I.R.B.308
2018-23, 2018-36 I.R.B.405
2018-24, 2018-36 I.R.B.407
Treasury Decisions:
9834, 2018-31 I.R.B.233
9835, 2018-33 I.R.B.288
9836, 2018-33 I.R.B.291
9838, 2018-34 I.R.B.309
9839, 2018-35 I.R.B.325
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–01 through 2018–26 is in Internal Revenue Bulletin
2018–26, dated June 27, 2018.
September 17, 2018Bulletin No. 2018–38
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2018–27 through 2018–38
Notices:
2014-5
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2015-28
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2016-57
Modified by
Notice 2018-69, 2018-37 I.R.B.426
2017-45
Modified by
Notice 2018-69, 2018-37 I.R.B.426
Revenue Procedures:
2015-27
Amplified by
Rev. Proc. 2018-39, 2018-34 I.R.B.319
2017-24
Amplified by
Rev. Proc. 2018-39, 2018-34 I.R.B.319
2018-31
Modified by
Rev. Proc. 2018-44, 2018-37 I.R.B.426
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–01 through 2018–26 is in Internal Revenue Bulletin
2018–26, dated June 27, 2018.
Bulletin No. 2018–38September 17, 2018
iii

INTERNAL REVENUE BULLETIN
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