Internal Revenue Bulletin 2015-4 (PDF rendition): IRS Revenue Rulings

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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
Rev. Rul. 2015–1, page 331.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, and other sections of the
Code, tables set forth the rates for January 2015.
Notice 2015–2, page 334.
This notice provides a special administrative procedure that
allows employers that treated transit benefits in excess of
$130 per month per employee as wages in 2014 and have not
yet filed their fourth quarter Form 941 for 2014 to make
necessary corrections on their fourth quarter Form 941.
EMPLOYMENT TAX
Notice 2015–2, page 334.
This notice provides a special administrative procedure that
allows employers that treated transit benefits in excess of
$130 per month per employee as wages in 2014 and have not
yet filed their fourth quarter Form 941 for 2014 to make
necessary corrections on their fourth quarter Form 941.
Finding Lists begin on page ii.
Bulletin No. 2015– 4
January 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.
January 26, 2015Bulletin No. 2015– 4

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of January 2015. See
Rev. Rul. 2015–1, page 331.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of January 2015. See Rev.
Rul. 2015–1, page 331.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The adjusted applicable federal short-term,
mid-term, and long-term rates are set forth for the
month of January 2015. See Rev. Rul. 2015–1,
page 331.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of January 2015. See
Rev. Rul. 2015–1, page 331.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of January 2015. See
Rev. Rul. 2015–1, page 331.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Rev. Rul. 2015–1
Thisrevenue ruling provides various
prescribed rates for federal income tax
purposes for January 2015 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month
for purposes of section 1274(d) of the
Internal Revenue Code. Table 2 contains
the short-term, mid-term, and long-term
adjusted applicable federal rates (ad-
justed AFR) for the current month for
purposes of section 1288(b). Table 3
sets forth the adjusted federal long-term
rate and the long-term tax-exempt rate
described in section 382(f). Table 4 con-
tains the appropriate percentages for de-
terminingthelow-incomehousing
credit described in section 42(b)(1) for
buildings placed in service during the
current month. However, under section
42(b)(2), the applicable percentage for
non-federally subsidized new buildings
placed in service after July 30, 2008,
with respect to housing credit dollar
amount allocations made before January
1, 2014, shall not be less than 9%. Table
5 contains the federal rate for determin-
ing the present value of an annuity, an
interest for life or for a term of years, or
a remainder or a reversionary interest
for purposes of section 7520. Finally,
Table 6 contains the deemed rate of
return for transfers made during calen-
dar year 2015 to pooled income funds
described in section 642(c)(5) that have
been in existence for less than 3 taxable
years immediately preceding the taxable
year in which the transfer was made.
Bulletin No. 2015– 4January 26, 2015
331

REV. RUL. 2015–1 TABLE 1
Applicable Federal Rates (AFR) for January 2015
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.41%.41%.41%.41%
110% AFR.45%.45%.45%.45%
120% AFR.49%.49%.49%.49%
130% AFR.53%.53%.53%.53%
Mid-term
AFR1.75%1.74%1.74%1.73%
110% AFR1.92%1.91%1.91%1.90%
120% AFR2.10%2.09%2.08%2.08%
130% AFR2.27%2.26%2.25%2.25%
150% AFR2.63%2.61%2.60%2.60%
175% AFR3.07%3.05%3.04%3.03%
Long-term
AFR2.67%2.65%2.64%2.64%
110% AFR2.94%2.92%2.91%2.90%
120% AFR3.21%3.18%3.17%3.16%
130% AFR3.48%3.45%3.44%3.43%
REV. RUL. 2015–1 TABLE 2
Adjusted AFR for January 2015
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.41%.41%.41%.41%
Mid-term adjusted AFR1.36%1.36%1.36%1.36%
Long-term adjusted AFR2.67%2.65%2.64%2.64%
REV. RUL. 2015–1 TABLE 3
Rates Under Section 382 for January 2015
Adjusted federal long-term rate for the current month2.67%
Long-term tax-exempt rate for ownership changes during the current month
(the highest of the adjusted federal long-term rates for the current month and the prior two months.)2.80%
REV. RUL. 2015–1 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for January 2015
Note: Undersection 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July
30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2014, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.51%
Appropriate percentage for the 30% present value low-income housing credit3.22%
January 26, 2015Bulletin No. 2015– 4
332

REV. RUL. 2015–1 TABLE 5
Rate Under Section 7520 for January 2015
Applicable federal rate for determining the present value of an annuity, an
interest for life or a term of years, or a remainder or reversionary interest2.2%
REV. RUL. 2015–1 TABLE 6
Deemed Rate for Transfers to New Pooled Income Funds During 2015
Deemed rate of return for transfers during 2015 to pooled income funds that have
been in existence for less than 3 taxable years1.2%
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of January 2015. See Rev. Rul. 2015–1, page 331.
Bulletin No. 2015– 4January 26, 2015
333

Part III. Administrative, Procedural, and Miscellaneous
Application of Retroactive
Increase in Excludable
Transit Benefits
Notice 2015–2
PURPOSE
This notice provides guidance related
to the enactment of section 103 of the Tax
Increase Prevention Act of 2014 (TIPA),
Pub. L. 113–295, which increased the
monthly transit benefit exclusion under
§ 132(f)(2)(A) of the Internal Revenue
Code from $130 per participating em-
ployee to $250 per participating employee
for the period of January 1, 2014, through
December 31, 2014. To address employ-
ers’ questions regarding the retroactive
application of the increased exclusion for
2014 and to reduce filing and reporting bur-
dens, the Internal Revenue Service (Service)
is clarifying how the increase applies for
2014 and providing a special administrative
procedure for employers to use in filing
Form 941, Employer’s QUARTERLY Fed-
eral Tax Return, for the fourth quarter of
2014 to reflect changes in the excludable
amount for transit benefits provided in all
quarters of 2014 and in filing Forms W–2,
Wage and Tax Statement.
BACKGROUND
Section132(a)(5) provides that any
fringe benefit that is a qualified transporta-
tion fringe is excluded from gross income.
Section 132(f)(1) provides in relevant part
that the term “qualified transportation
fringe” includes (when provided by an em-
ployer to an employee): (1) transportation in
a commuter highway vehicle between home
and work, (2) any transit pass, or (3) quali-
fied parking. Under § 132(f)(3), cash reim-
bursements by employers for transit passes
constitute a qualified transportation fringe
only if a voucher or similar item which may
be exchanged only for a transit pass is not
readily available for direct distribution by
the employer to the employee. Section
1.132–9(b) of the Income Tax Regulations
provides guidance on the exclusion for qual-
ified transportation fringes. See § 1.132–
9(b) Q/A 16(b)(4) for the meaning of the
term “readily available.” See also Rev. Rul.
2014 –32, 2014 –50 I.R.B. 917, for guidance
on the use of smartcards, debit or credit
cards, or other electronic media to provide
qualified transportation fringe benefits to
employees.
Section 132(f)(2) provides that the
amount of fringe benefits which is pro-
vided by an employer to any employee
and which may be excluded from gross
income under § 132(a)(5) shall not exceed
$100 per month in the case of the aggre-
gate of transportation in a commuter high-
way vehicle and any transit pass, and $175
in the case of qualified parking. These
amounts are adjusted annually for infla-
tion under § 132(f)(6). Prior to enactment
of TIPA, the adjusted maximum monthly
excludable amount for 2014 for the aggre-
gate of transportation in a commuter high-
way vehicle and any transit pass was $130
and the adjusted maximum monthly ex-
cludable amount for qualified parking was
$250. See section 3.16 of Rev. Proc.
2013–35, 2013– 47 I.R.B. 357. TIPA
amended § 132(f)(2) to increase the max-
imum monthly excludable amount for the
aggregate of employer-provided com-
muter highway vehicle transportation and
transit pass benefits to an amount equal to
the maximum monthly excludable amount
for qualified parking. The amendment is
effective retroactively beginning on Janu-
ary 1, 2014, and extends through Decem-
ber 31, 2014.
Amounts that are excluded from gross
income under § 132 are also excluded
from Federal Insurance Contributions Act
(FICA) taxes (social security and Medi-
care, including Additional Medicare Tax)
and Federal income tax withholding. Sec-
tions 3121(a)(20) and 3401(a)(19).
Generally, corrections of overpay-
ments of FICA tax are made after an error
has been ascertained using the adjustment
process under § 6413 or using the refund
claim process under § 6402. An error is
ascertained when the employer has suffi-
cient knowledge of the error to be able to
correct it.
Under§§31.6413(a)–1(a)and
31.6413(a)–2(b) of the Employment Tax
Regulations, before making an adjustment
of an overpayment of FICA tax, an em-
ployer generally must repay or reimburse
its employee in the amount of the over-
collection prior to the expiration of the
period of limitations on credit or refund,
and, for FICA tax overcollected in a prior
year (other than Additional Medicare
Tax), must also secure the employee’s
written statement confirming that the em-
ployee has not made any previous claims
(or the claims were rejected) and will not
make any future claims for refund or
credit of the amount of the overcollected
FICA tax. An employer repays the em-
ployee by direct payment to the employee;
an employer reimburses an employee by
applying the amount of the overcollection
against the employee FICA tax which at-
taches to wages paid by the employer
to the employee. Sections 31.6413(a)–
1(a)(2)(ii) and 31.6413(a)–2(a)(1) provide
that withheld Additional Medicare Tax
can only be repaid or reimbursed and sub-
sequently adjusted during the same calen-
dar year in which is it withheld. Similarly,
§ 31.6413(a)–1(b)provides that employers
cannot adjust overpayments of withheld in-
come tax after the end of the calendar year.
Rather, the withheld Additional Medicare
Tax and the withheld income tax are applied
against the taxes shown on the employee’s
individual income tax return (for example,
Form 1040, U.S. Individual Income Tax
Return) and any excess will be refunded to
the employee.
Section 31.6402(a)–2 provides rules
under which a refund claim for an over-
payment of FICA tax (other than Addi-
tional Medicare Tax) may be made. Pur-
suant to § 31.6402(a)–2(a), an employer
has a duty to assure that its employee’s
rights to recover overcollected taxes are
protected by repaying or reimbursing
overcollected amounts. Alternatively, an
employer may obtain the employee’s con-
sent to the filing of the refund claim. Un-
der § 31.6402(a)–2(a)(iii), no refund to
the employer is permitted with regard to
Additional Medicare Tax which the em-
ployer deducted or withheld from the em-
ployee. Similarly, under §§ 6414 and
31.6414 –1, no refund to the employer is
allowed for the overpayment of withheld
income tax which the employer deducted
or withheld from an employee.
To make employment tax corrections
for overpayments (that is, to make adjust-
ments or to claim refunds), an employer
January 26, 2015Bulletin No. 2015– 4
334

uses the “X”form that corresponds to the
return being corrected. Thus, an employer
corrects overreported taxes on a previously
filed Form 941 by filing Form 941–X, Ad-
justed Employer’s QUARTERLY Federal
Tax Return or Claim for Refund. A sepa-
rate X form must be filed for each taxable
period.
APPLICATION OF RETROACTIVE
INCREASE TO TRANSIT BENEFITS
PROVIDED IN 2014
For purposes of the remaining discus-
sion, “transit benefits” refers to the aggre-
gate benefit of transportation in a com-
muter highway vehicle and transit passes
that meet the requirements of § 132 and
the applicable regulations. Pursuant to the
change made by TIPA, which was retro-
active to January 1, 2014, transit benefits
provided during 2014 by an employer to
an employee in excess of $130 (the former
maximum monthly excludable amount)
up to $250 (the amended maximum
monthly excludable amount) are excluded
from the employee’s gross income and
wages. These excess amounts are referred
to as “excess transit benefits” in this no-
tice. The exclusion applies whether the
employer provided the transit benefits in
2014 out of its own funds or whether the
transit benefits were provided during 2014
through compensation reduction arrange-
ments as permitted by §§ 132(f)(4) and
1.132–9(b) Q/A 11–15.
Neither § 132 nor the change made by
TIPA mandates that employers provide
additional transit benefits to their employ-
ees for 2014. With regard to transit bene-
fits provided pursuant to compensation re-
duction arrangements, §1.132–9(b) Q/A
13 provides that, each month, the amount
of the compensation reduction may not
exceed the combined applicable statutory
monthly limit for transportation in a com-
muter highway vehicle and transit passes.
Section 1.132–9(b) Q/A 14(b) provides
that the compensation reduction election
must be made before the employee is able
to receive the cash or other taxable
amount at the employee’s discretion. Ac-
cordingly, employees may not retroac-
tively increase their compensation reduc-
tion for 2014 to take advantage of the
increase in the excludable amount for
transit benefits in 2014. In addition, em-
ployees may not reduce their compensa-
tion by more than $130 per month in 2015
(the applicable statutory monthly limit for
2015) in order to receive any permissible
reimbursement for transit benefits in-
curred in 2014.
Furthermore, TIPA did not change the
other requirements of § 132, including the
limitation on providing cash reimburse-
ments for transit passes when transit
passes are readily available for direct dis-
tribution by the employer to the employee.
SPECIAL ADMINISTRATIVE
PROCEDURE FOR EMPLOYERS
WHO DESIRE TO MAKE
ADJUSTMENTS FOR 2014 ON THE
FORM 941 FILED FOR THE FOURTH
QUARTER OF 2014
Employers who originally reported ex-
cess transit benefits as includible in gross
income and wages and withheld income
taxes and FICA taxes would normally be
required to file Form 941–X for each
quarter to make corrections.
Due to the timing of the statutory
change and the due dates for Forms 941
for the fourth quarter of 2014 and Forms
W–2, and in order to reduce administra-
tive burden, the Service is providing a
special administrative procedure for em-
ployers that treated excess transit benefits
as wages and that have not yet filed their
fourth quarter Form 941 for 2014. Em-
ployers who desire to use this special ad-
ministrative procedure must repay or re-
imbursetheiremployeesforthe
overcollected FICA tax (including any
Additional Medicare Tax) on the excess
transit benefits for all four quarters of
2014 on or before filing the fourth quarter
Form 941. The employer, in reporting
amounts on its fourth quarter Form 941,
may reduce the fourth quarter Wages, tips
and compensation reported on line 2, Tax-
able social security wages reported on line
5a, Taxable Medicare wages and tips re-
ported on line 5c, and Taxable wages &
tips subject to Additional Medicare Tax
withholding reported on line 5d by the
excess transit benefits for all four quarters
of 2014. By taking advantage of this spe-
cial administrative procedure, employers
will avoid having to file Forms 941–X,
and will also avoid having to file Forms
W–2c as discussed below.
This procedure can only be used to the
extent that employers have repaid or re-
imbursed their employees for the em-
ployee share of FICA tax (including any
Additional Medicare Tax) attributable to
the excess transit benefits. Under this spe-
cial administrative procedure, employers
may only correct the employer share of
FICA tax if the employees’ share of FICA
tax has been repaid or reimbursed to the
employees. Employers using this special
procedure do not need to obtain written
statements from their employees confirm-
ing, for each employee, that the employee
did not make a claim (or if the employee
did make a claim, the claim was rejected)
and will not make a claim for refund of
FICA tax overcollected in a prior year.
The repayment or reimbursement of
overwithheld social security tax and the
corresponding reduction for wages re-
ported on Form 941, line 5a, Taxable so-
cial security wages, must take into ac-
count that refunds or credits of social
security tax are limited to the amount paid
on that portion of the excess transit bene-
fits that, when added to other wages for
the year, did not exceed the social security
wage base for 2014 ($117,000).
To ensure that use of this special ad-
ministrative procedure does not result in a
mismatch between the total taxes reported
on Form 941, line 10, Total taxes after
adjustments, and the Total liability for the
quarter reported on Form 941, Line 14
(for a monthly schedule depositor) or
Schedule B (Form 941) (for a semiweekly
schedule depositor), an employer should
use the following procedure. The em-
ployer should reduce the last liability of
the quarter reported (that is, Month 3 on
line 14 or the last liability entry on Sched-
ule B) by the amount of the tax reduction
due to use of the special administrative
procedure. If the amount of the tax reduc-
tion exceeds the last liability of the quarter
reported on line 14 or Schedule B, the
employer should apply the amount of the
tax reduction to reduce previous liabilities
in reverse order until the amount of the tax
reduction is completely used. Note that
negative numbers must not be entered on
Line 14 or Schedule B.
The same procedures are available to
filers of other employment tax returns re-
porting FICA taxes (for example, the re-
lated Spanish-language return or return
for U.S. possessions) and to filers of em-
Bulletin No. 2015– 4January 26, 2015
335

ployment tax returns reporting taxes under
the Railroad Retirement Tax Act.
NORMAL PROCEDURES FOR
EMPLOYERS WHO HAVE FILED
FOURTH QUARTER FORM 941 OR
HAVE NOT REPAID OR
REIMBURSED EMPLOYEES PRIOR
TO FILING FOURTH QUARTER
FORM 941
Employers that have already filed the
fourth quarter Form 941 must use Form
941–X and normal procedures to make an
adjustment or claim a refund for any quar-
ter in 2014 with regard to the overpay-
ment of tax on the excess transit benefits
after repaying or reimbursing the employ-
ees or, for claims for refund, securing
consents from their employees. Similarly,
to the extent employers have not repaid or
reimbursed their employees who received
excess transit benefits in 2014 prior to
filing the fourth quarter Form 941, the
employers must use Form 941–X to make
an adjustment or claim for refund with
respect to the excess transit benefits pro-
vided to those employees and must follow
the normal procedures.
Under the normal procedures, the em-
ployer must obtain the required statements
under §§ 31.6413(a)–1 or 31.6402(a)–2
(subject to the exception for making rea-
sonable efforts). Furthermore, the em-
ployer may not repay or reimburse, make
an adjustment with respect to, or seek a
refund of Additional Medicare Tax or in-
come tax deducted or withheld from the
employee in 2014.
EMPLOYER INSTRUCTIONS FOR
FORM W–2
Employers that paid excess transit ben-
efits and have not furnished 2014 Forms
W–2 to their employees must take into
account the increased exclusion for transit
benefits in calculating the amount of
wages reported in box 1, Wages, tips,
other compensation; box 3, Social security
wages; and box 5, Medicare wages and
tips. Employers that have repaid or reim-
bursed their employees for the overcol-
lected FICA taxes prior to furnishing
Form W–2 (whether they utilized the spe-
cial administrative procedure or the nor-
mal procedures) must reduce the amounts
of withheld tax reported in box 4, Social
security tax withheld, and box 6, Medi-
care tax withheld, by the amounts of the
repayments or reimbursements. Note that
under the normal procedures, the amount
reported in box 6, Medicare tax withheld,
will not be reduced with regard to any
Additional Medicare Tax withheld on the
excess transit benefits because no repay-
ment or reimbursement of such amount is
permitted after the end of 2014.
In all cases, employers must report in
box 2, Federal income tax withheld, the
amount of income tax actually withheld
during 2014. The additional income tax
withholding will be applied against the
taxes shown on the employee’s individual
income tax return (Form 1040, U.S. Indi-
vidual Income Tax Return).
Employers that repaid or reimbursed
their employees for the overcollected
FICA taxes after furnishing Forms W–2 to
their employees but before filing Forms
W–2 with the Social Security Administra-
tion (SSA) must check the “Void” box at
the top of each incorrect Form W–2 (Copy
A). The employer must prepare new
Forms W–2 with the correct information,
and send these new Forms W–2 (Copy A)
to the SSA. The employers must write
“CORRECTED” on the employees’ new
copies (B, C, and 2) and furnish them to
the employees. See the 2014 General In-
structions for Forms W–2 and W–3.
Employers that have already filed 2014
Forms W–2 with SSA must file Forms
W–2c, Corrected Wage and Tax State-
ment, to take into account the increased
exclusion for transit benefits and to reflect
any repayments or reimbursements of the
withheld FICA tax and must furnish cop-
ies of Form W–2c to the employees.
DRAFTING INFORMATION
The principal author of this notice is
Jean M. Casey of the Office of Division
Counsel/Associate Chief Counsel (Tax
Exempt & Government Entities). For fur-
ther information regarding this notice con-
tact Ms. Casey on (202) 317-4774 (not a
toll-free number).
January 26, 2015Bulletin No. 2015– 4
336

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– 4January 26, 2015
i

Numerical Finding List
1
Bulletin 2015–1 through 2015– 4
Announcements:
2015-2, 2015-3 I.R.B.324
2015-3, 2015-3 I.R.B.328
Proposed Regulations:
REG-109187-11, 2015-2 I.R.B.277
REG-132751-14, 2015-2 I.R.B.279
REG-145878-14, 2015-2 I.R.B.290
Notices:
2015-1, 2015-2 I.R.B.249
2015-2, 2015-4 I.R.B.334
Revenue Procedures:
2015-1, 2015-1 I.R.B.1
2015-2, 2015-1 I.R.B.105
2015-3, 2015-1 I.R.B.129
2015-4, 2015-1 I.R.B.144
2015-5, 2015-1 I.R.B.186
2015-6, 2015-1 I.R.B.194
2015-7, 2015-1 I.R.B.231
2015-8, 2015-1 I.R.B.235
2015-9, 2015-2 I.R.B.249
2015-10, 2015-2 I.R.B.261
2015-12, 2015-2 I.R.B.265
Revenue Rulings:
2015-1, 2015-4 I.R.B.331
2015-2, 2015-3 I.R.B.321
Treasury Decisions:
9707, 2015-2 I.R.B.247
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin
2014 –52, dated December 28, 2014.
January 26, 2015Bulletin No. 2015– 4
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–1 through 2015– 4
Announcements:
2010-3
Amplified by
Ann. 2015-3, 2015-3 I.R.B.328
Revenue Procedures:
2014-01
Superseded by
Rev. Proc. 2015-01, 2015-01 I.R.B.1
2014-02
Superseded by
Rev. Proc. 2015-02, 2015-01 I.R.B.105
2014-03
Superseded by
Rev. Proc. 2015-03, 2015-01 I.R.B.129
2014-04
Superseded by
Rev. Proc. 2015-04, 2015-01 I.R.B.144
2014-05
Superseded by
Rev. Proc. 2015-05, 2015-01 I.R.B.186
2014-06
Superseded by
Rev. Proc. 2015-06, 2015-01 I.R.B.194
2014-07
Superseded by
Rev. Proc. 2015-07, 2015-01 I.R.B.231
2014-08
Superseded by
Rev. Proc. 2015-08, 2015-01 I.R.B.235
2014-10
Superseded by
Rev. Proc. 2015-10, 2015-2 I.R.B.261
2003-63
Superseded by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
Revenue Rulings:
92-19
Supplemented by
Rev. Rul. 2015-02, 2015-3 I.R.B.321
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin 2014 –52, dated December 28,
2014.
Bulletin No. 2015– 4January 26, 2015
iii

INTERNAL REVENUE BULLETIN
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