Internal Revenue Bulletin 2017-10 (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. 2017–07, page 1007
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, 7872, and other sections of
the Code, tables set forth the rates for March 2017.
EXEMPT ORGANIZATIONS
Announcement 2017–02, page 1009
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
Finding Lists begin on page ii.
Bulletin No. 2017–10
March 6, 2017

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.
March 6, 2017Bulletin No. 2017–10

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
642, 1288, 7520, 7872.)
Rev. Rul. 2017–07
This revenue ruling provides various
prescribed rates for federal income tax
purposes for March 2017 (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,
shall not be less than 9%. Finally, 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.
REV. RUL. 2017–07 TABLE 1
Applicable Federal Rates (AFR) for March 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR1.01%1.01%1.01%1.01%
110% AFR1.11%1.11%1.11%1.11%
120% AFR1.21%1.21%1.21%1.21%
130% AFR1.31%1.31%1.31%1.31%
Mid-term
AFR2.05%2.04%2.03%2.03%
110% AFR2.25%2.24%2.23%2.23%
120% AFR2.47%2.45%2.44%2.44%
130% AFR2.67%2.65%2.64%2.64%
150% AFR3.08%3.06%3.05%3.04%
175% AFR3.60%3.57%3.55%3.54%
Long-term
AFR2.78%2.76%2.75%2.74%
110% AFR3.06%3.04%3.03%3.02%
120% AFR3.34%3.31%3.30%3.29%
130% AFR3.62%3.59%3.57%3.56%
REV. RUL. 2017–07 TABLE 2
Adjusted AFR for March 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.75%.75%.75%.75%
Mid-term adjusted AFR1.53%1.52%1.52%1.52%
Long-term adjusted AFR2.06%2.05%2.04%2.04%
Bulletin No. 2017–10March 6, 2017
1007

REV. RUL. 2017–07 TABLE 3
Rates Under Section 382 for March 2017
Adjusted federal long-term rate for the current month2.06%
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.)
2.09%
REV. RUL. 2017–07 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for March 2017
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings
placed in service after July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.56%
Appropriate percentage for the 30% present value low-income housing credit3.24%
REV. RUL. 2017–07 TABLE 5
Rate Under Section 7520 for March 2017
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 interest
2.4%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of March 2017. See
Rev. Rul. 2017– 07, page 1007.
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 March 2017. See Rev. Rul.
2017– 07, page 1007.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
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 March 2017. See
Rev. Rul. 2017– 07, page 1007.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of March 2017. See
Rev. Rul. 2017– 07, page 1007.
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 March 2017. See Rev. Rul. 2017– 07, page 1007.
Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of March
2017. See Rev. Rul. 2017– 07, page 1007.
March 6, 2017Bulletin No. 2017–10
1008

Part IV. Items of General Interest
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2017–02
Table of Contents
The Internal Revenue Service has re-
voked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code
of 1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date of
announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section
170(c)(2) if the organization has not
timely filed a suit for declaratory judg-
ment under section 7428 and if the con-
tributor (1) had knowledge of the revoca-
tion of the ruling or determination letter,
(2) was aware that such revocation was
imminent, or (3) was in part responsible
for or was aware of the activities or omis-
sions of the organization that brought
about this revocation.
If on the other hand a suit for declara-
tory judgment has been timely filed, con-
tributions from individuals and organiza-
tions described in section 170(c)(2) that
are otherwise allowable will continue to
be deductible. Protection under section
7428(c) would begin on March 6, 2017
and would end on the date the court first
determines the organization is not de-
scribed in section 170(c)(2) as more par-
ticularly set for in section 7428(c)(1). For
individual contributors, the maximum de-
duction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
NAME OF ORGANIZATIONEffective Date of RevocationLOCATION
Palms Residential Care Facility1/1/2012Los Angeles, CA
Albina Youth Opportunity School, Inc.7/1/2013Portland, OR
Peoples Communication, Inc.1/1/2014New York, NY
East Alabama Community Development Corporation10/1/2012Anniston, AL
Marion Shooters Club1/1/2014Marion, MT
Brownsville Board of Realtors Educational Foundation1/1/2012Brownsville, TX
The Adam Project, Inc.1/1/2014Dayton, OH
Friendly Earth, Inc.1/1/2013Seattle, WA
Wise Business Association, Inc.1/1/2014Wise, VA
Arizona Latin Association Community Productions1/1/2013Tolleson, AZ
Logansport Burmese Community, Inc.1/1/2014Logansport, IN
Banditos Baseball Club9/18/2014Katy, TX
Kelly Enterprise, Inc.1/1/2014Baltimore, MD
NABA-Elite, Inc.1/1/2014Santa Fe Springs, CA
Dr. Zachery Tims Enrichment Center Inc.1/1/2014Windermere, FL
Bulletin No. 2017–10March 6, 2017
1009

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. 2017–10March 6, 2017
i

Numerical Finding List
1
Bulletin 2017–1 through 2017–10
Action on Decision:
2017-1, 2016-7 I.R.B.868
Announcements:
2017-01, 2017-08 I.R.B.941
2017-02, 2017-10 I.R.B.1007
Notices:
2017-1, 2017-2 I.R.B.367
2017-2, 2017-4 I.R.B.539
2017-3, 2017-2 I.R.B.368
2017-4, 2017-4 I.R.B.541
2017-5, 2017-6 I.R.B.779
2017-6, 2017-3 I.R.B.422
2017-7, 2017-3 I.R.B.423
2017-8, 2017-3 I.R.B.423
2017-9, 2017-4 I.R.B.542
2017-10, 2017-4 I.R.B.544
2017-12, 2017-5 I.R.B.742
2017-13, 2017-6 I.R.B.780
2017-14, 2017-6 I.R.B.783
2017-15, 2017-6 I.R.B.783
2017-16, 2017-7 I.R.B.913
2017-18, 2017-9 I.R.B.997
2017-19, 2017-9 I.R.B.1000
Proposed Regulations:
REG-137604-07, 2017-7 I.R.B.923
REG-128276-12, 2017-2 I.R.B.369
REG-103477-14, 2017-5 I.R.B.746
REG-112324-15, 2017-4 I.R.B.547
REG-127203-15, 2017-7 I.R.B.921
REG-131643-15, 2017-6 I.R.B.865
REG-134438-15, 2017-2 I.R.B.373
REG-112800-16, 2017-4 I.R.B.569
REG-123829-16, 2017-5 I.R.B.764
REG-123841-16, 2017-5 I.R.B.766
REG-133353-16, 2017-2 I.R.B.372
REG-134247-16, 2017-5 I.R.B.744
REG-135122-16, 2017-9 I.R.B.1005
Revenue Procedures:
2017-1, 2017-1 I.R.B.1
2017-2, 2017-1 I.R.B.106
2017-3, 2017-1 I.R.B.130
2017-4, 2017-1 I.R.B.146
2017-5, 2017-1 I.R.B.230
2017-7, 2017-1 I.R.B.269
2017-12, 2017-3 I.R.B.424
2017-13, 2017-6 I.R.B.787
2017-14, 2017-3 I.R.B.426
2017-15, 2017-3 I.R.B.437
2017-16, 2017-3 I.R.B.501
Revenue Procedures:—Continued
2017-18, 2017-5 I.R.B.743
2017-19, 2017-7 I.R.B.913
2017-21, 2017-6 I.R.B.791
2017-22, 2017-6 I.R.B.863
2017-23, 2017-7 I.R.B.915
2017-24, 2017-7 I.R.B.916
Revenue Rulings:
2017-1, 2017-3 I.R.B.377
2017-2, 2017-2 I.R.B.364
2017-3, 2017-4 I.R.B.522
2017-4, 2017-6 I.R.B.776
2017-5, 2017-9 I.R.B.1000
2017-7, 2017-10 I.R.B.1009
Treasury Decisions:
9794, 2017-2 I.R.B.273
9795, 2017-2 I.R.B.326
9796, 2017-3 I.R.B.380
9801, 2017-2 I.R.B.355
9802, 2017-2 I.R.B.361
9803, 2017-3 I.R.B.384
9804, 2017-3 I.R.B.406
9806, 2017-4 I.R.B.524
9807, 2017-5 I.R.B.573
9808, 2017-5 I.R.B.580
9809, 2017-5 I.R.B.664
9810, 2017-6 I.R.B.775
9811, 2017-7 I.R.B.869
9814, 2017-7 I.R.B.878
9815, 2017-9 I.R.B.944
9817, 2017-9 I.R.B.968
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2016 –27 through 2016 –52 is in Internal Revenue Bulletin
2016 –52, dated December 26, 2016.
March 6, 2017Bulletin No. 2017–10
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2017–1 through 2017–10
Notices:
2002-1
Amplified by
Notice 2017-1, 2017-2 I.R.B.367
2010-46
Obsoleted by
Notice 2017-1, 2017-2 I.R.B.367
2016-29
Modified by
Notice 2017-6, 2017-3 I.R.B.422
Revenue Procedures:
2013-22
Clarified by
Rev. Proc. 2017-18, 2017-05 I.R.B.743
2015-57
Modified by
Rev. Proc. 2017-24, 2017-07 I.R.B.916
Treasury Decisions:
2010-46
Obsoleted by
T.D. 9815 2017-09 I.R.B.944
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2016 –27 through 2016 –52 is in Internal Revenue Bulletin
2016 –52, dated December 26, 2016.
Bulletin No. 2017–10March 6, 2017
iii

INTERNAL REVENUE BULLETIN
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