us-irs-notices-irb-2014-18-pdf•Internal Revenue Bulletin 2014-18 (PDF rendition): IRS Notices
Internal Revenue Bulletin 2014-18 (PDF rendition): IRS Notices
us-irs-notices-irb-2014-18-pdfInternal Revenue Bulletin 2014-18 (PDF rendition): IRS NoticesGuidance
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. INCOME TAX Announcement 2014–17, page 1001. Announcement 2014 –17 provides guidance to foreign financial institutions (FFIs) in jurisdictions that have not signed an inter- governmental FATCA agreement, but that have reached an agreement in substance with the United States on the terms of an IGA. Announcement 2014 –17 also provides that the GIIN of a registering FFI will be included on the June 2 IRS FFI List if the FFI’s registration is finalized by May 5, 2014, rather than April 25, 2014, as originally announced In addition, Announcement 2014 –17 provides that the GIIN of a registering FFI will be included on the July 1 FFI List if the FFI’s registration is finalized by June 3, 2014. Notice 2014–28, page 990. This notice provides guidance regarding the treatment of United States persons that own stock of a PFIC through certain tax exempt organization and accounts. Notice 2014–29, page 991. This notice provides adjusted limitations on housing expenses for tax year 2014 for purpose of sections 911 of the code. This notice supersedes Notice 2006 – 87, 2006 –2 C.B. 766, Notice 2007–25, 2007–1 C.B. 760, Notice 2007–77, 2007–2 C.B. 735, Notice 2008 –107, 2008 –2 C.B. 1266, Notice 2010 –27, 2010 –1 C.B. 531, Notice 2011– 8, 2011–1 C.B. 503,Notice 2012–19, 2012–1 C.B. 440, and Notice 2013–31, 2013–1 C.B. 1099. EMPLOYEE PLANS Notice 2014–27, page 987. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in April 2014; the 24-month average segment rates; the funding segment rates applicable for April 2014; and the minimum present value rates for March 2014. The rates in this notice reflect certain changes implemented by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21). Finding Lists begin on page ii. Index for July through April begins on page iv. Bulletin No. 2014–18 April 28, 2014 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 28, 2014Bulletin No. 2014–18 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates Notice 2014–27 This notice provides guidance on the corporate bond monthly yield curve (and the corresponding spot segment rates), and the 24-month average segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice provides guid- ance as to the interest rate on 30-year Trea- sury securities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning be- fore 2008, the 30-year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I), and the minimum present value segment rates under § 417(e)(3)(D) as in effect for plan years beginning after 2007. These rates reflect certain changes implemented by the Moving Ahead for Progress in the 21st Century Act, Public Law 112–141 (MAP–21). MAP–21 provides that for purposes of § 430(h)(2), the segment rates are limited by the applicable maximum percentage or the applicable minimum percentage based on the average of seg- ment rates over a 25 year period. YIELD CURVE AND SEGMENT RATES Generally, except for certain plans un- der sections 104 and 105 of the Pension Protection Act of 2006, § 430 of the Code specifies the minimum funding require- ments that apply to single employer plans pursuant to § 412. Section 430(h)(2) spec- ifies the interest rates that must be used to determine a plan’s target normal cost and funding target. Under this provision, pres- ent value is generally determined using three 24-month average interest rates (“segment rates”), each of which applies to cash flows during specified periods. To the extent provided under § 430(h)(2)(C)(iv), these segment rates are adjusted by the applicable percentage of the 25-year aver- age segment rates for the period ending September 30 of the year preceding the calendar year in which the plan year be- gins. However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly yield curve in place of the seg- ment rates. Notice 2007– 81, 2007– 44 I.R.B. 899, provides guidelines for determining the monthly corporate bond yield curve, and the 24-month average corporate bond seg- ment rates used to compute the target nor- mal cost and the funding target. Pursuant to Notice 2007– 81, the monthly corporate bond yield curve derived from March 2014 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of March 2014 are, respectively, 1.23, 4.23, and 5.31. For plan years beginning on or after January 1, 2012, the 24-month average segmentratesdeterminedunder § 430(h)(2)(C)(iv) must be adjusted by the applicable percentage of the correspond- ing 25-year average segment rates. The 25-year average segment rates for plan years beginning in 2012, 2013, and 2014 were published in Notice 2012–55, 2012–36 I.R.B. 332, Notice 2013–11, 2013–11 I.R.B. 610, and Notice 2013–58, 2013– 40 I.R.B. 294, respectively. The three 24-month average corporate bond segment rates applicable for April 2014 without adjustment, and the adjusted 24- month average segment rates taking into account the applicable percentages of the corresponding 25-year average segment rates, are as follows: For Plan Years Beginning In 24-Month Average Segment Rates Not Adjusted Adjusted 24-Month Average Segment Rates, Based on Applicable Percentage of 25-Year Average Rates Applicable Month First Segment Second Segment Third Segment First Segment Second Segment Third Segment 2013April20141.194.065.114.946.156.76 2014April20141.194.065.114.435.626.22 30-YEAR TREASURY SECURITIES INTEREST RATES Generally for plan years beginning af- ter 2007, § 431 specifies the minimum funding requirements that apply to mul- tiemployer plans pursuant to § 412. Sec- tion 431(c)(6)(B) specifies a minimum amount for the full-funding limitation de- scribed in section 431(c)(6)(A), based on theplan’scurrentliability.Section 431(c)(6)(E)(ii)(I) provides that the inter- est rate used to calculate current liability for this purpose must be no more than 5 percent above and no more than 10 per- cent below the weighted average of the rates of interest on 30-year Treasury se- curities during the four-year period ending on the last day before the beginning of the plan year. Notice 88 –73, 1988 –2 C.B. 383, provides guidelines for determining the weighted average interest rate. The rate of interest on 30-year Treasury secu- rities for March 2014 is 3.62 percent. The Service has determined this rate as the average of the daily determinations of yield on the 30-year Treasury bond ma- turing in February 2044. The following rates were determined for plan years be- ginning in the month shown below. Bulletin No. 2014–18April 28, 2014 987 For Plan Years Beginning in 30-Year Treasury Weighted Average Permissible Range MonthYear90%to105% April20143.443.103.62 MINIMUM PRESENT VALUE SEGMENT RATES In general, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. Notice 2007– 81 provides guide- lines for determining the minimum pres- ent value segment rates. Pursuant to that notice, the minimum present value seg- ment rates determined for March 2014 are as follows: First Segment Second Segment Third Segment 1.234.235.31 DRAFTING INFORMATION The principal author of this notice is Tony Montanaro of the Employee Plans, Tax Exempt and Government Entities Di- vision. Mr. Montanaro may be e-mailed at RetirementPlanQuestions@irs.gov. April 28, 2014Bulletin No. 2014–18 988 Table I Monthly Yield Curve for December 2014 Derived from December 2014 Data MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield 0.50.2620.55.0040.55.3460.55.4780.55.53 1.00.4321.05.0241.05.3561.05.4781.05.53 1.50.6221.55.0341.55.3561.55.4781.55.53 2.00.8322.05.0542.05.3662.05.4782.05.53 2.51.0722.55.0642.55.3662.55.4782.55.53 3.01.3223.05.0743.05.3763.05.4883.05.53 3.51.5823.55.0943.55.3763.55.4883.55.53 4.01.8324.05.1044.05.3764.05.4884.05.53 4.52.0824.55.1144.55.3864.55.4884.55.53 5.02.3125.05.1245.05.3865.05.4885.05.54 5.52.5425.55.1345.55.3865.55.4885.55.54 6.02.7526.05.1446.05.3966.05.4986.05.54 6.52.9526.55.1546.55.3966.55.4986.55.54 7.03.1327.05.1647.05.3967.05.4987.05.54 7.53.3127.55.1747.55.4067.55.4987.55.54 8.03.4728.05.1848.05.4068.05.4988.05.54 8.53.6228.55.1948.55.4068.55.4988.55.54 9.03.7629.05.2049.05.4169.05.5089.05.54 9.53.8929.55.2149.55.4169.55.5089.55.54 10.04.0030.05.2250.05.4170.05.5090.05.55 10.54.1130.55.2250.55.4270.55.5090.55.55 11.04.2131.05.2351.05.4271.05.5091.05.55 11.54.3031.55.2451.55.4271.55.5091.55.55 12.04.3832.05.2552.05.4372.05.5092.05.55 12.54.4532.55.2552.55.4372.55.5192.55.55 13.04.5233.05.2653.05.4373.05.5193.05.55 13.54.5833.55.2753.55.4373.55.5193.55.55 14.04.6334.05.2754.05.4474.05.5194.05.55 14.54.6834.55.2854.55.4474.55.5194.55.55 15.04.7235.05.2955.05.4475.05.5195.05.55 15.54.7635.55.2955.55.4475.55.5195.55.56 16.04.8036.05.3056.05.4576.05.5296.05.56 16.54.8336.55.3056.55.4576.55.5296.55.56 17.04.8637.05.3157.05.4577.05.5297.05.56 17.54.8837.55.3257.55.4577.55.5297.55.56 18.04.9138.05.3258.05.4578.05.5298.05.56 18.54.9338.55.3358.55.4678.55.5298.55.56 19.04.9539.05.3359.05.4679.05.5299.05.56 19.54.9739.55.3459.55.4679.55.5299.55.56 20.04.9940.05.3460.05.4680.05.53100.05.56 Bulletin No. 2014–18April 28, 2014 989 Treatment of United States Persons that Own Stock of Passive Foreign Investment Companies Through Certain Organizations and Accounts that Are Tax Exempt Notice 2014–28 SECTION 1. PURPOSE This notice announces that the Depart- ment of the Treasury (Treasury Depart- ment) and the Internal Revenue Service (IRS) will amend the regulations under section 1291 of the Internal Revenue Code (Code) to provide guidance con- cerning the treatment of United States per- sons (U.S. persons) that own stock of a passiveforeigninvestmentcompany within the meaning of section 1297(a) (PFIC) through: an organization or an ac- count that is exempt from tax under sec- tion 501(a) because it is described in sec- tion 501(c), 501(d), or 401(a); a state college or university described in section 511(a)(2)(B); a plan described in section 403(b) or 457(b); an individual retirement plan or annuity as defined in section 7701(a)(37); or a qualified tuition pro- gram described in section 529 or 530. SECTION 2. BACKGROUND .01 Sections 1291 and 1298 Section 1291 imposes a special tax and interest charge on a U.S. person that is a shareholder of a PFIC and receives an excess distribution (within the meaning of section 1291(b)) from the PFIC or recog- nizes gain derived from a disposition of the PFIC that is treated as an excess dis- tribution (within the meaning of section 1291(a)(2)). Section 1298(a) sets forth at- tribution rules that treat a U.S. person as the owner of PFIC stock that is owned by another person. The section 1298(a) attri- bution rules will not apply to treat stock owned (or treated as owned) by a U.S. person as owned by any other person, except to the extent provided in regula- tions. Section 1298(a)(1)(B). Section 1298(f) provides that a U.S. person that is a shareholder of a PFIC must file an an- nual report containing the information re- quired by the Secretary. Section 1298(g) provides that the Secretary shall provide such regulations as may be necessary or appropriate to carry out the purposes of sections 1291 through 1298. .02 Regulations under Sections 1291 and 1298 On December 31, 2013, the Treasury Department and the IRS published tempo- rary and proposed regulations under sec- tions 1291 and 1298 (2014 –3 I.R.B. 394) that defined the terms shareholder and in- direct shareholder for purposes of section 1291. See § 1.1291–1T(b)(7) and (8). These definitions are cross-referenced in the definition of shareholder and indirect shareholder in the section 1298(f) infor- mation reporting regulations, as well as in other PFIC regulations. See §§ 1.1291– 9T(j) 1.1298 –1T(a). Under § 1.1291– 1T(b)(7), the term shareholder means any U.S. person that owns stock of a PFIC directly or indirectly. Section 1.1291– 1T(b)(8) defines the term indirect share- holder as a U.S. person that indirectly owns stock of a PFIC, and provides rules for attributing ownership of PFIC stock through domestic and foreign corpora- tions, partnerships, S corporations, es- tates, and trusts. For example, § 1.1291– 1T(b)(8)(iii)(C)provides that, in general, each beneficiary of a foreign or domestic nongrantor trust that directly or indirectly owns stock of a PFIC is considered to own a proportionate amount of the PFIC stock and, thus, each beneficiary that is a U.S. per- son is an indirect shareholder of the PFIC. .03 Tax Exempt Organizations In general, § 1.1291–1(e) provides that section 1291 applies to a PFIC share- holder that is an organization exempt from tax under chapter 1 of the Code only if a dividend from the PFIC owned by the organization would be taxable to the or- ganization under subchapter F of Subtitle A of the Code (sections 501 through 530) (subchapter F). Section 1.1298 –1T(c)(1) provides that a PFIC shareholder that is an organization exempt from tax under sec- tion 501(a) because it is described in sec- tion 501(c), 501(d), or 401(a), a state col- lege or university described in section 511(a)(2)(B), a plan described in section 403(b) or 457(b), an individual retirement plan or annuity as defined in section 7701(a)(37), or a qualified tuition program described in section 529 or 530 (each a tax exempt organization or account) is re- quired to file an annual report under sec- tion 1298(f) with respect to a PFIC only if income derived with respect to the PFIC would be taxable to the organization or account under subchapter F. Neither the Code nor the section 1291 regulations provide specific guidance on the application of section 1291 to a U.S. person that owns stock of a PFIC through a tax exempt organization or account, other than an employees’ trust described in section 401(a) that is exempt from tax under section 501(a) (section 401(a) trust). The attribution rules that generally apply to treat a U.S. beneficiary of a nongrantor trust as owning PFIC stock owned by the trust do not apply to a U.S. person that owns an interest in a section 401(a) trust. § 1.1291–1T(b)(8)(iii)(C). Thus, a U.S. person that is a beneficiary of a section 401(a) trust is not treated as an indirect shareholder with respect to any PFIC stock held by the trust for purposes of section 1291. Although § 1.1291–1(e) provides that or- ganizationsexemptfromtaxunder chapter 1 of the Code generally are not subject to section 1291 with respect to their direct or indirect ownership of PFIC stock, a U.S. person that is a beneficiary of or has an interest in a tax exempt organization or ac- count may be treated as a direct or indirect shareholder of the PFIC stock owned by the organization or account under § 1.1291– 1T(b)(7) and (8), and thus may be subject to taxation under section 1291. SECTION 3. TREATMENT OF U.S. PERSONS THAT OWN STOCK OF A PFIC THROUGH CERTAIN ORGANIZATIONS AND ACCOUNTS THAT ARE TAX EXEMPT The Treasury Department and the IRS believe that the application of the PFIC rules to a U.S. person treated as owning stock of a PFIC through a tax exempt organization or account described in § 1.1298 –1T(c)(1) would be inconsistent with the tax policies underlying the PFIC rules and the tax provisions applicable to tax exempt organizations and accounts. For example, applying the PFIC rules to a U.S. person that is treated as a shareholder of a PFIC through the U.S. person’s own- ership of an individual retirement account (IRA) described in section 408(a) that April 28, 2014Bulletin No. 2014–18 990 owns stock of a PFIC would be inconsis- tent with the principle of deferred taxation provided by IRAs. Accordingly, the Trea- sury Department and the IRS will amend the definition of shareholder in the section 1291 regulations to provide that a U.S. person that owns stock of a PFIC through a tax exempt organization or account (as described in § 1.1298 –1T(c)(1)) is not treated as a shareholder of the PFIC. This amendment will affect all regulations that cross-reference the § 1.1291–1T(b)(7) and (8) definitions of shareholder and indirect shareholder, including § 1.1298 –1T(a). SECTION 4. EFFECTIVE DATE The regulations incorporating the guid- ance described in this notice will be effec- tive for taxable years of U.S. persons that own stock of a PFIC through a tax exempt organization or account ending on or after December 31, 2013. SECTION 5. DRAFTING INFORMATION The principal author of this notice is Susan E. Massey of the Office of Associ- ate Chief Counsel (International). For fur- ther information regarding this notice con- tact Susan Massey at (202) 317-6934 (not a toll-free number). Determination of Housing Cost Amounts Eligible for Exclusion or Deduction for 2014 Notice 2014–29 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 (Code) for specific locations for 2014. 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) of the Code allows a qualified individual to elect to exclude from gross income the foreign earned in- come and housing cost amount of such individual. Section 911(c)(1) defines the term “housing cost amount” as an amount equal to the excess of (A) the housing expenses of an individual for the taxable year to the extent such expenses do not exceed the amount determined under sec- tion 911(c)(2), over (B) 16 percent of the exclusion amount (computed on a daily basis) in effect under section 911(b)(2)(D) for the calendar year in which such tax- able year begins ($271.78 per day for 2014, or $99,200 for the full year), multiplied by the number of days of that taxable year within the applicable period described in section 911(d)(1). The appli- cable period is the period during which the individual meets the tax home require- ment of section 911(d)(1) and either the bona fide residence requirement of section 911(d)(1)(A) or the physical presence re- quirement of section 911(d)(1)(B). As- suming that the entire taxable year of a qualified individual is within the applicable period, the section 911(c)(1)(B) amount for 2014 is $15,872 ($99,200 x .16). Section 911(c)(2)(A) of the Code lim- its the housing expenses taken into ac- count in section 911(c)(1)(A) to an amount equal to (i) 30 percent (adjusted as may be provided under the Secretary’s authority under section 911(c)(2)(B)) of the amount in effect under section 911(b)(2)(D) for the calendar year in which the taxable year of the individual begins, multiplied by (ii) the number of days of that taxable year within the appli- cableperioddescribedinsection 911(d)(1).Thus, under this general limita- tion, a qualified individual whose entire tax- able year is within the applicable period is limited to maximum housing expenses of $29,760 ($99,200 x .30) in 2014. Section 911(c)(2)(B) of the Code au- thorizes the Secretary to issue regulations or other guidance to adjust the percentage under section 911(c)(2)(A)(i) based on geographic differences in housing costs relative to housing costs in the United States. Pursuant to this authority, the In- ternal Revenue Service (IRS) and the Treasury Department published Notice 2006 – 87, 2006 –2 C.B. 766, and Notice 2007–25, 2007–1 C.B. 760, for 2006, No- tice 2007–77, 2007–2 C.B. 735, for 2007, Notice 2008 –107, 2008 –2 C.B. 1266, for 2008 and 2009, Notice 2010 –27, 2010 –1 C.B. 531, for 2009 and 2010, Notice 2011– 8, 2011–1 C.B. 503, for 2010 and 2011, Notice 2012–19, 2012–1 C.B. 440 for 2011 and 2012, and Notice 2013–31, 2013–1 C.B. 1099, for 2012 and 2013, to provide adjustments to the limitation on housing expenses for qualified individuals incurring housing expenses in countries with high housing costs relative to hous- ing costs in the United States. SECTION 3. TABLE OF ADJUSTED LIMITATIONS FOR 2014 The following table provides adjusted limitations on housing expenses (in lieu of the otherwise applicable limitation of $29,760) for 2014. CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) AngolaLuanda84,000230.14 ArgentinaBuenos Aires56,500154.79 AustraliaAdelaide29,90081.92 AustraliaDarwin, Northern Country30,60083.84 AustraliaMelbourne37,800103.56 AustraliaPerth40,400110.68 Bulletin No. 2014–18April 28, 2014 991 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) AustraliaSydney32,78289.81 AustriaVienna35,40096.99 Bahamas, TheGrand Bahama Island30,90084.66 Bahamas, TheNassau49,700136.16 BahrainBahrain44,000120.55 BarbadosBarbados37,700103.29 BelgiumAntwerp36,600100.27 BelgiumBrussels49,000134.25 BelgiumGosselies43,800120.00 BelgiumHoogbuul36,600100.27 BelgiumMons43,800120.00 BelgiumSHAPE/Chievres43,800120.00 BermudaBermuda90,000246.58 Bosnia-HerzegovinaSarajevo31,30085.75 BrazilBrasilia41,100112.60 BrazilRio de Janeiro35,10096.16 BrazilSao Paulo56,600155.07 CanadaCalgary44,200121.10 CanadaDartmouth36,700100.55 CanadaEdmonton35,10096.16 CanadaHalifax36,700100.55 CanadaLondon, Ontario30,00082.19 CanadaMontreal56,500154.79 CanadaOttawa50,600138.63 CanadaQuebec42,900117.53 CanadaToronto52,400143.56 CanadaVancouver46,500127.40 CanadaVictoria33,20090.96 CanadaWinnipeg31,70086.85 Cayman IslandsGrand Cayman48,000131.51 ChileSantiago50,400138.08 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 DenmarkCopenhagen43,704119.74 Dominican RepublicSanto Domingo45,500124.66 EcuadorGuayaquil30,80084.38 EcuadorQuito37,500102.74 EstoniaTallinn46,600127.67 FranceGarches86,000235.62 FranceLe Havre34,70095.07 FranceLyon47,700130.68 April 28, 2014Bulletin No. 2014–18 992 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) FranceMarseille46,400127.12 FranceMontpellier38,400105.21 FranceParis86,000235.62 FranceSevres86,000235.62 FranceSuresnes86,000235.62 FranceVersailles86,000235.62 GermanyBabenhausen42,200115.62 GermanyBad Aibling36,00098.63 GermanyBad Nauheim33,70092.33 GermanyBaumholder40,800111.78 GermanyBerlin51,500141.10 GermanyBirkenfeld40,800111.78 GermanyBoeblingen51,200140.27 GermanyBonn42,000115.07 GermanyButzbach33,00090.41 GermanyCologne56,200153.97 GermanyDarmstadt42,200115.62 GermanyFrankfurt am Main44,000120.55 GermanyFriedberg33,70092.33 GermanyGarmisch-Partenkirchen39,000106.85 GermanyGelnhausen53,100145.48 GermanyGermersheim31,90087.40 GermanyGiebelstadt36,40099.73 GermanyGiessen36,00098.63 GermanyGrafenwoehr42,000115.07 GermanyHanau53,100145.48 GermanyHannover31,50086.30 GermanyHeidelberg39,400107.95 GermanyIdar-Oberstein40,800111.78 GermanyIngolstadt59,400162.74 GermanyKaiserslautern, Landkreis50,900139.45 GermanyKitzingen36,40099.73 GermanyLeimen39,400107.95 GermanyLudwigsburg51,200140.27 GermanyMainz57,000156.16 GermanyMannheim39,400107.95 GermanyMunich59,400162.74 GermanyNellingen51,200140.27 GermanyNeubruecke40,800111.78 GermanyOber Ramstadt42,200115.62 GermanyOberammergau39,000106.85 GermanyPfullendorf41,400113.42 GermanyPirmasens50,900139.45 GermanyRheinau39,400107.95 GermanySchwetzingen39,400107.95 Bulletin No. 2014–18April 28, 2014 993 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) GermanySeckenheim39,400107.95 GermanySembach50,900139.45 GermanyStuttgart51,200140.27 GermanyVilseck42,000115.07 GermanyWahn42,000115.07 GermanyWertheim36,40099.73 GermanyWiesbaden57,000156.16 GermanyWuerzburg36,40099.73 GermanyZweibruecken50,900139.45 GermanyAll cities other than Augsburg, Babenhausen, Bad Aibling, Bad Kreuznach, Bad Nauheim, Baumholder, Berchtesgaden, Berlin, Birkenfeld, Boeblingen, Bonn, Bremen, Bremerhaven, Butzbach, Cologne, Darmstadt, Delmenhorst, Duesseldorf, Erlangen, Flensburg, Frankfurt am Main, Friedberg, Fuerth, Garlstedt, Garmisch-Partenkirchen, Geilenkirchen, Gelnhausen, Germersheim, Giebelstadt, Giessen, Grafenwoehr, Grefrath, Greven, Gruenstadt, Hamburg, Hanau, Handorf, Hannover, Heidelberg, Heilbronn, Herongen, Idar-Oberstein, Ingolstadt, Kaiserslautern, Landkreis, Kalkar, Karlsruhe, Kerpen, Kitzingen, Koblenz, Leimen, Leipzig, Ludwigsburg, Mainz, Mannheim, Mayen, Moenchen-Gladbach, Muenster, Munich, Nellingen, Neubruecke, Noervenich, Nuernberg, Ober Ramstadt, Oberammergau, Osterholz-Scharmbeck, Pirmasens, Rheinau, Rheinberg, Schwabach, Schwetzingen, Seckenheim, Sembach, Stuttgart, Twisteden, Vilseck, Wahn, Wertheim, Wiesbaden, Worms, Wuerzburg, Zirndorf and Zweibruecken 41,400113.42 GhanaAccra36,00098.63 GreeceArgyroupolis32,90090.14 GreeceAthens42,200115.62 GreeceElefsis42,200115.62 GreeceEllinikon42,200115.62 GreeceMt. Hortiatis32,90090.14 GreeceMt. Parnis42,200115.62 GreeceMt. Pateras42,200115.62 GreeceNea Makri42,200115.62 GreecePerivolaki32,90090.14 GreecePiraeus42,200115.62 GreeceTanagra42,200115.62 GreeceThessaloniki32,90090.14 GuatemalaGuatemala City41,800114.52 GuyanaGeorgetown35,00095.89 Holy See, TheHoly See, The57,300156.99 April 28, 2014Bulletin No. 2014–18 994 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) HungaryBudapest32,50089.04 HungaryPapá44,500121.92 IndiaMumbai67,920186.08 IndiaNew Delhi56,124153.76 IndonesiaJakarta37,776103.50 IrelandDublin49,800136.44 IrelandShannon Area39,300107.67 IsraelTel Aviv50,800139.18 ItalyCatania33,50091.78 ItalyGenoa41,800114.52 ItalyGioia Tauro31,20085.48 ItalyLa Spezia40,400110.68 ItalyLeghorn35,90098.36 ItalyMilan85,600234.52 ItalyNaples54,400149.04 ItalyParma43,500119.18 ItalyPisa35,90098.36 ItalyPordenone-Aviano43,500119.18 ItalyRome57,300156.99 ItalySigonella33,50091.78 ItalyTurin42,800117.26 ItalyVicenza45,100123.56 ItalyAll cities other than Avellino, Brindisi, Catania, Florence, Gaeta, Genoa, Gioia Tauro, La Spezia, Leghorn, Milan, Mount Vergine, Naples, Nettuno, Parma, Pisa, Pordenone-Aviano, Rome, Sardinia, Sigonella, Turin, Verona, and Vicenza 35,00095.89 JamaicaKingston41,200112.88 JapanAkashi32,00087.67 JapanAtsugi40,900112.05 JapanCamp Zama40,900112.05 JapanChiba-Ken40,900112.05 JapanFussa40,900112.05 JapanGifu74,300203.56 JapanGotemba30,60083.84 JapanHaneda40,900112.05 JapanIwakuni33,00090.41 JapanKanagawa-Ken40,900112.05 JapanKomaki74,300203.56 JapanMachidi-Shi40,900112.05 JapanMisawa34,80095.34 JapanNagoya74,300203.56 JapanOkinawa Prefecture59,400162.74 JapanOsaka-Kobe90,664248.39 JapanSagamihara40,900112.05 Bulletin No. 2014–18April 28, 2014 995 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) JapanSaitama-Ken40,900112.05 JapanSasebo35,40096.99 JapanTachikawa40,900112.05 JapanTokyo96,000263.01 JapanTokyo-to40,900112.05 JapanYokohama52,600144.11 JapanYokosuka47,700130.68 JapanYokota40,900112.05 KazakhstanAlmaty48,000131.51 KoreaAmmo Depot #930,10082.47 KoreaCamp Carroll32,60089.32 KoreaCamp Colbern57,100156.44 KoreaCamp Market57,100156.44 KoreaCamp Mercer57,100156.44 KoreaChinhae30,90084.66 KoreaK-1657,100156.44 KoreaKimhae31,10085.21 KoreaKimpo Airfield57,100156.44 KoreaMunsan35,00095.89 KoreaOsan AB36,00098.63 KoreaPusan31,10085.21 KoreaPyongtaek35,70097.81 KoreaSeoul57,100156.44 KoreaSuwon57,100156.44 KoreaTaegu34,30093.97 KoreaTongduchon31,90087.40 KoreaUijongbu33,80092.60 KoreaWaegwan32,60089.32 KoreaAllcities 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 33,00090.41 KuwaitKuwait City64,400176.44 KuwaitAll cities other than Kuwait City57,700158.08 LuxembourgLuxembourg47,000128.77 MacedoniaSkopje35,40096.99 MalaysiaKuala Lumpur46,200126.58 MalaysiaAll cities other than Kuala Lumpur33,70092.33 MaltaMalta55,100150.96 MexicoMazatlan31,00084.93 MexicoMerida37,900103.84 MexicoMexico City47,900131.23 MexicoMonterrey33,20090.96 April 28, 2014Bulletin No. 2014–18 996 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) MexicoAll cities other than Ciudad Juarez, Cuernavaca, Guadalajara, Hermosillo, Matamoros, 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 NetherlandsBrunssum41,000112.33 NetherlandsEygelshoven41,000112.33 NetherlandsHague, The68,300187.12 NetherlandsHeerlen41,000112.33 NetherlandsHoensbroek41,000112.33 NetherlandsHulsberg41,000112.33 NetherlandsKerkrade41,000112.33 NetherlandsLandgraaf41,000112.33 NetherlandsMaastricht41,000112.33 NetherlandsPapendrecht41,100112.60 NetherlandsRotterdam41,100112.60 NetherlandsSchaesburg41,000112.33 NetherlandsSchinnen41,000112.33 NetherlandsSchiphol52,900144.93 NetherlandsYpenburg68,300187.12 NetherlandsAll cities other than Amsterdam, Aruba, Brunssum, Coevorden, Eygelshoven, The Hague, Heerlen, Hoensbroek, Hulsberg, Kerkrade, Landgraaf, Maastricht, Margraten, Papendrecht, Rotterdam, Schaesburg, Schinnen, Schiphol, and Ypenburg 40,600111.23 Netherlands AntillesCuracao45,800125.48 New ZealandAuckland35,70097.81 New ZealandChristchurch32,10087.95 New ZealandWellington33,80092.60 NicaraguaManagua31,80087.12 NigeriaAbuja36,00098.63 NorwayOslo49,000134.25 NorwayStavanger41,600113.97 NorwayAll cities other than Oslo and Stavanger37,700103.29 PanamaPanama City35,50097.26 ParaguayAsuncion31,10085.21 PeruLima39,100107.12 PhilippinesCavite39,000106.85 PhilippinesManila39,000106.85 PolandPoland29,40080.55 PortugalAlverca52,400143.56 Bulletin No. 2014–18April 28, 2014 997 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) PortugalLisbon52,400143.56 QatarDoha36,26499.35 QatarAll cities other than Doha32,40088.77 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 SingaporeSingapore86,300236.44 South AfricaPretoria39,300107.67 SpainBarcelona40,600111.23 SpainMadrid69,800191.23 SpainRota42,600116.71 SpainValencia40,100109.86 SpainAll cities other than Barcelona, Madrid, Rota, Seville, Seville Province, and Valencia 30,30083.01 SurinameParamaribo33,00090.41 SwitzerlandBern72,200197.81 SwitzerlandGeneva100,500275.34 SwitzerlandZurich39,219107.45 SwitzerlandAll cities other than Bern, Geneva and Zurich 32,90090.14 TaiwanTaipei46,188126.54 TanzaniaDar Es Salaam44,000120.55 ThailandBangkok59,000161.64 Trinidad and TobagoPort of Spain54,500149.32 TurkeyIzmir-Cigli31,60086.58 TurkeyYamanlar31,60086.58 UkraineKiev72,000197.26 United Arab EmiratesAbu Dhabi49,687136.13 United Arab EmiratesDubai57,174156.64 United KingdomBasingstoke41,099112.60 United KingdomBath41,000112.33 United KingdomBracknell62,100170.14 United KingdomBristol40,500110.96 United KingdomBrookwood44,200121.10 United KingdomCambridge44,100120.82 United KingdomCaversham73,800202.19 United KingdomCheltenham53,600146.85 United KingdomCroughton45,000123.29 United KingdomFairford43,700119.73 United KingdomFarnborough54,700149.86 April 28, 2014Bulletin No. 2014–18 998 CountryLocation Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) United KingdomFelixstowe42,500116.44 United KingdomGibraltar44,616122.24 United KingdomHarrogate47,400129.86 United KingdomHigh Wycombe62,100170.14 United KingdomKemble43,700119.73 United KingdomLakenheath55,900153.15 United KingdomLiverpool39,800109.04 United KingdomLondon88,700243.01 United KingdomLoudwater69,900191.51 United KingdomMenwith Hill47,400129.86 United KingdomMildenhall55,900153.15 United KingdomOxfordshire44,500121.92 United KingdomPlymouth44,500121.92 United KingdomPortsmouth44,500121.92 United KingdomReading62,100170.14 United KingdomRochester45,700125.21 United KingdomSamlesbury44,200121.10 United KingdomSouthampton44,200121.10 United KingdomSurrey48,402132.61 United KingdomWaterbeach45,500124.66 United KingdomWiltshire42,300115.89 United KingdomAll cities other than Basingstoke, Bath, Belfast, Birmingham, Bracknell, Bristol, Brookwood, Brough, Cambridge, Caversham, Chelmsford, Cheltenham, Chicksands, Croughton, Dunstable, Edinburgh, Edzell, Fairford, Farnborough, Felixstowe, Ft. Halstead, Gibraltar, Glenrothes, Greenham Common, Harrogate, High Wycombe, Hythe, Kemble, Lakenheath, Liverpool, London, Loudwater, Menwith Hill, Mildenhall, Nottingham, Oxfordshire, Plymouth, Portsmouth, Reading, Rochester, Samlesbury, Southampton, Surrey, Waterbeach, Welford, West Byfleet, and Wiltshire 44,200121.10 VenezuelaCaracas57,000156.16 VietnamHanoi46,800128.22 VietnamHo Chi Minh City42,000115.07 SECTION 4. ELECTION TO APPLY 2014 ADJUSTED LIMITATIONS TO 2013 TAXABLE YEAR For some locations, the limitation on housing expenses provided in section 3 of this notice may be higher than the limita- tion on housing expenses provided in the “Table of Adjusted Limitations for 2013” in Notice 2013–31. A qualified individual incurring housing expenses in such a lo- cation during 2013 may apply the adjusted limitation on housing expenses provided in section 3 of this notice in lieu of the amounts provided in the “Table of Ad- justed Limitations for 2013” in Notice 2013–31 (and as set forth in the Instruc- tions to Form 2555 (2013)). Treasury and the IRS anticipate that future annual notices providing adjust- ments to housing expense limitations will make a similar election available to qual- ified individuals that incur housing ex- penses in the immediately preceding year. Bulletin No. 2014–18April 28, 2014 999 For example, when adjusted housing ex- pense limitations for 2015 are issued, it is expected that taxpayers will be permitted to apply those adjusted limitations to the 2014 taxable year. EFFECT ON OTHER DOCUMENTS This notice supersedes Notice 2006 – 87, 2006 –2 C.B. 766, Notice 2007–25, 2007–1 C.B. 760, Notice 2007–77, 2007–2 C.B. 735, Notice 2008 –107, 2008 –2 C.B. 1266, Notice 2010 –27, 2010 –1 C.B. 531, Notice 2011– 8, 2011–1 C.B. 503, Notice 2012–19, 2012–1 C.B. 440, and Notice 2013–31, 2013–1 C.B. 1099. EFFECTIVE DATE This notice is effective for taxable years beginning on or after January 1, 2014. However, as provided in section 4, a taxpayer may elect to apply the 2014 adjusted housing limitations contained in section 3 of this notice to his or her tax- able year beginning in 2013. DRAFTING INFORMATION The principal author of this notice is Susan E. Massey of the Office of Associ- ate Chief Counsel (International). For fur- ther information regarding this notice con- tact Ms. Massey at (202) 317-6934 (not a toll-free number). April 28, 2014Bulletin No. 2014–18 1000 Part IV. Items of General Interest Update on Jurisdictions Treated as Having an IGA in Effect and on FATCA Financial Institution Registration Announcement 2014–17 Since the 2012 release of the Model 1 and Model 2 intergovernmental agree- ments (IGAs) to implement the Foreign Account Tax Compliance Act (FATCA), there has been robust and growing interest from jurisdictions worldwide to enter into IGAs. To date, the United States has signed IGAs with 26 jurisdictions and has reached agreements in substance or is in advanced discussions with many others. Foreign financial institutions (FFIs) and other stakeholders continue to express strong support for a broad IGA network as a way to facilitate FATCA compliance while avoiding legal conflicts, and to more effectively and efficiently implement cross-border tax information reporting. They have also expressed practical con- cerns about the status of FFIs in jurisdic- tions that are known to be in an advanced stage of concluding an IGA, but have not yet signed an agreement. For this reason, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Ser- vice (IRS) are issuing this announcement to provide FFIs in jurisdictions that al- ready have reached an agreement in sub- stance on the terms of an IGA with the clarity they need to prepare to comply with FATCA. This announcement also ad- dresses stakeholders’ practical concerns by allowing an FFI ten additional days to register in preparation for FATCA imple- mentation on July 1 and still ensure that its Global Intermediary Identification Number (GIIN) will appear on the first public list of GIINs. Background The final regulations provide that the IRS will publish a list identifying all countries that are treated as having a Model 1 or Model 2 IGA in effect. Reg. §§ 1.1471–1(b)(78) and (79). Notice 2013– 43,2013–31 I.R.B. 113, provides that this list is maintained on the Treasury website athttp://www.treasury.gov/resource-center/ tax-policy/treaties/Pages/FATCA-Archive. aspx. A link to the list is also available on the IRS website athttp://www.irs.gov/ Businesses/Corporations/Information-for- Foreign-Financial-Institutions.Notice 2013– 43 further provides that Treasury and the IRS intend to include on this list jurisdictions that have signed, but may not yet have brought into force, an IGA. The final regulations generally provide that, in order for withholding not to apply, a withholding agent must obtain an FFI’s GIIN for payments made after June 30, 2014, and must confirm that the GIIN appears on the IRS FFI List. A special rule, however, provides that a withholding agent does not need to obtain a reporting Model 1 FFI’s GIIN for payments made before January 1, 2015. See Reg. § 1.1471–3(d)(4)(iv)(A). Notice 2013– 43 and Announcement 2014 –1, 2014 –2 I.R.B. 393, indicate that FFIs must regis- ter on the FATCA registration website by April 25, 2014 (GMT -5), to ensure they are included on the first IRS FFI List, which is expected to be electronically available on June 2, 2014 (GMT -5). Stakeholders generally have expressed concerns that FFIs located in jurisdictions that are expected to sign an IGA, but have not yet signed the agreement, are unable to plan effectively and efficiently for the July 1 implementation of FATCA given the uncertainty regarding when the rele- vant IGA may be signed and therefore treated as being in effect. More specifi- cally, stakeholders have expressed con- cern that certain jurisdictions will not have signed an IGA by April 25, 2014, and accordingly that FFIs in those juris- dictions will not be able to timely register consistent with their expected IGA status. For example, some FFIs that expect to be reporting Model 2 FFIs may not be able to register by April 25 if legal impediments would prevent them from agreeing to the terms of the FFI Agreement that would apply absent the modifications applicable to reporting Model 2 FFIs under a signed Model 2 IGA. Some FFIs that expect to be reporting Model 1 FFIs and therefore to rely on the special rule providing that withholding agents do not need to obtain GIINs of reporting Model 1 FFIs before January 1, 2015, are concerned about missing the April 25 deadline in case the relevant IGA is not in fact signed, and therefore treated as being in effect, by July 1. Other FFIs that expect to be reporting Model 1 FFIs wish to ensure their inclu- sion on the first IRS FFI List in order to simplify the documentation of their status with withholding agents (even though withholding agents should not require re- porting Model 1 FFIs to provide GIINs until January 1, 2015), but are concerned that they will not be able to register as reporting Model 1 FFIs before April 25 if their jurisdiction’s IGA is not signed, and therefore treated as being in effect, by that date. Expansion of IGAs Treated as Being in Effect to Include Agreements in Substance This announcement aims to address these concerns by providing that the juris- dictions listed on the Treasury and IRS websites as jurisdictions that are treated as having an IGA in effect will also include jurisdictions that, before July 1, 2014, have reached agreements in substance with the United States on the terms of an IGA and have consented to be included on the Treasury and IRS list, even if those agreements have not yet been signed. Such jurisdictions will be treated as hav- ing an IGA in effect from the date that the jurisdiction provides its consent (or April 2, 2014, the date of the public release of this announcement, if later) until Decem- ber 31, 2014, the date by which the IGA must be signed in order for this status to continue without interruption. Treasury expects to add jurisdictions to this list in the coming weeks as additional jurisdic- tions consent to inclusion on the list and additional agreements in substance are reached. Jurisdictions that reach agree- ments in substance on or after July 1, 2014, will not be included in the list of jurisdictions that are treated as having an IGA in effect until the IGA is signed. The text of the agreements in substance that are treated as being in effect will not be published by the IRS or Treasury until the IGA is signed. Instead, the list will specify only whether the relevant IGA is a Bulletin No. 2014–18April 28, 2014 1001 Model 1 or a Model 2 IGA. Until the IGA is signed, the jurisdiction will be treated as having in effect the relevant model provi- sions. This means that an FFI resident in, or organized under the laws of, a jurisdic- tion that is listed on the Treasury and IRS websites as having reached an agreement in substance will be permitted to register on the FATCA registration website con- sistent with its treatment under the rele- vant model IGA and will be permitted to certify its status to a withholding agent consistent with that treatment. Treasury generally has a policy of not deviating from the model text except in limited cir- cumstances in Annex II. Any modifica- tions made in the relevant IGA to the model Annex II categories of exempt ben- eficial owners, deemed compliant FFIs, and accounts excluded from the definition of financial accounts will therefore not be applicable until the IGA is signed. A jurisdiction may be removed from the list of jurisdictions that are treated as having an IGA in effect if Treasury deter- mines that the jurisdiction is not taking the steps necessary to bring the IGA into force within a reasonable period of time, and, as noted above, a jurisdiction will be removed from the list if the jurisdiction fails to sign the IGA by December 31, 2014. If a jurisdiction is removed from the list, FFIs that are resident in, or organized under the laws of, that jurisdiction, and branches that are located in that jurisdic- tion, will, from the first day of the month following the month of removal, no longer be entitled to the status that would be provided under the IGA, and will be re- quired to update their status on the FATCA registration website accordingly. New Dates for Registering to Ensure GIIN Inclusion on the IRS FFI List As described in Notice 2013– 43, FFIs resident in, or organized under the laws of, a jurisdiction that is treated as having an IGA in effect, which, pursuant to this announcement includes jurisdictions listed on the Treasury and IRS websites as hav- ing reached agreements in substance on IGAs before July 1, 2014, should register on the FATCA registration website as a registered deemed-compliant FFI (which would include all reporting Model 1 FFIs) or a participating FFI (which would in- clude all reporting Model 2 FFIs), as ap- plicable. Importantly, withholding agents are still not required to obtain the GIINs of FFIs that are treated as reporting Model 1 FFIs before January 1, 2015. Based on the IRS experience with the registration system and GIIN generation process to date, the IRS now believes that it can ensure registering FFIs that their GIINs will be included on the June 2 IRS FFI List if their registrations are finalized by May 5, 2014 (GMT -5), rather than April 25, 2014, as originally announced. Further, the IRS believes it can ensure registering FFIs that their GIINs will be included on the July 1 IRS FFI List if their registrations are finalized by June 3, 2014 (GMT -5). FFIs that finalize their registra- tions after May 5 or June 3 may still be included on the June 2 or July 1 IRS FFI List, respectively; however, the IRS can- not provide assurance that this will be the case. The IRS will continue processing registrations in the order received; how- ever, processing times may increase as the May 5 and June 3 dates approach. Finally, Treasury and the IRS remind all withholding agents that, in accordance with Reg. § 1.1471–3(e)(3), a withholding agent that receives a Form W– 8 from a payee with a GIIN that does not yet ap- pear on the published IRS FFI List has 90 days to verify that the GIIN appears on the list before the withholding agent will be treated as having reason to know that the chapter 4 status of the payee is unreliable or incorrect. In addition, a withholding agent that receives a Form W– 8 from a payee indicating that the payee has ap- plied for a GIIN has 90 days to obtain the GIIN from the payee and verify it against the IRS FFI List before the withholding agent will be treated as having reason to know that the chapter 4 status of the payee is unreliable or incorrect. DRAFTING INFORMATION The principal author of this announce- ment is Michael Kaercher of the Office of Associate Chief Counsel (International). For further information regarding this an- nouncement, contact Mr. Kaercher at 202- 317-6942 (not a toll-free number). April 28, 2014Bulletin No. 2014–18 1002 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. 2014–18April 28, 2014 i Numerical Finding List 1 Bulletins 2014 –1 through 2014 –18 Announcements 2014-1, 2014-2 I.R.B.393 2014-2, 2014-4 I.R.B.448 2014-4, 2014-7 I.R.B.523 2014-05, 2014-6 I.R.B.507 2014-06, 2014-6 I.R.B.508 2014-07, 2014-6 I.R.B.508 2014-08, 2014-6 I.R.B.508 2014-09, 2014-6 I.R.B.508 2014-10, 2014-6 I.R.B.508 2014-11, 2014-6 I.R.B.508 2014-12, 2014-6 I.R.B.509 2014-13, 2014-10 I.R.B.620 2014-14, 2014-16 I.R.B.948 2014-15, 2014-16 I.R.B.973 2014-16, 2014-17 I.R.B.983 2014-17, 2014-18 I.R.B.1001 2014-18, 2014-17 I.R.B.983 2014-19, 2014-17 I.R.B.984 Notices 2014-1, 2014-2 I.R.B.270 2014-2, 2014-3 I.R.B.407 2014-3, 2014-3 I.R.B.408 2014-4, 2014-2 I.R.B.274 2014-5, 2014-2 I.R.B.276 2014-6, 2014-2 I.R.B.279 2014-7, 2014-4 I.R.B.445 2014-8, 2014-5 I.R.B.452 2014-9, 2014-5 I.R.B.455 2014-10, 2014-9 I.R.B.605 2014-11, 2014-13 I.R.B.880 2014-12, 2014-9 I.R.B.606 2014-13, 2014-10 I.R.B.616 2014-14, 2014-13 I.R.B.881 2014-15, 2014-12 I.R.B.661 2014-16, 2014-14 I.R.B.920 2014-17, 2014-13 I.R.B.881 2014-18, 2014-15 I.R.B.926 2014-19, 2014-17 I.R.B.979 2014-20, 2014-16 I.R.B.937 2014-21, 2014-16 I.R.B.938 2014-22, 2014-16 I.R.B.940 2014-23, 2014-16 I.R.B.942 2014-24, 2014-16 I.R.B.942 2014-25, 2014-17 I.R.B.981 2014-27, 2014-18 I.R.B.987 2014-28, 2014-18 I.R.B.990 2014-29, 2014-18 I.R.B.991 Proposed Regulations REG-154890-03, 2014-6 I.R.B.504 REG-159420-04, 2014-2 I.R.B.374 REG-144468-05, 2014-6 I.R.B.474 Proposed Regulations—Continued REG-163195-05, 2014-15 I.R.B.930 REG-119305-11, 2014-8 I.R.B.524 REG-140974-11, 2014-3 I.R.B.438 REG-121534-12, 2014-6 I.R.B.473 REG-122706-12, 2014-11 I.R.B.647 REG-134361-12, 2014-13 I.R.B.895 REG-136984-12, 2014-2 I.R.B.378 REG-113350-13, 2014-3 I.R.B.440 REG-130967-13, 2014-13 I.R.B.884 REG-141036-13, 2014-7 I.R.B.516 REG-143172-13, 2014-2 I.R.B.383 REG-108641-14, 2014-15 I.R.B.928 Revenue Procedures 2014-1, 2014-1 I.R.B.1 2014-2, 2014-1 I.R.B.90 2014-3, 2014-1 I.R.B.111 2014-4, 2014-1 I.R.B.125 2014-5, 2014-1 I.R.B.169 2014-6, 2014-1 I.R.B.198 2014-7, 2014-1 I.R.B.238 2014-8, 2014-1 I.R.B.242 2014-9, 2014-2 I.R.B.281 2014-10, 2014-2 I.R.B.293 2014-11, 2014-3 I.R.B.411 2014-12, 2014-3 I.R.B.415 2014-13, 2014-3 I.R.B.419 2014-14, 2014-2 I.R.B.295 2014-15, 2014-5 I.R.B.456 2014-16, 2014-9 I.R.B.606 2014-17, 2014-12 I.R.B.661 2014-18, 2014-7 I.R.B.513 2014-19, 2014-10 I.R.B.619 2014-20, 2014-9 I.R.B.614 2014-21, 2014-11 I.R.B.641 2014-22, 2014-11 I.R.B.646 2014-23, 2014-12 I.R.B.685 2014-24, 2014-13 I.R.B.879 2014-25, 2014-15 I.R.B.927 2014-28, 2014-16 I.R.B.944 Revenue Rulings 2014-1, 2014-2 I.R.B.263 2014-2, 2014-2 I.R.B.255 2014-3, 2014-2 I.R.B.259 2014-4, 2014-5 I.R.B.449 2014-6, 2014-7 I.R.B.510 2014-8, 2014-11 I.R.B.624 2014-9, 2014-17 I.R.B.975 2014-10, 2014-14 I.R.B.906 2014-11, 2014-14 I.R.B.906 2014-12, 2014-15 I.R.B.923 Treasury Decisions 9649, 2014-2 I.R.B.265 9650, 2014-3 I.R.B.394 Treasury Decisions—Continued 9651, 2014-4 I.R.B.441 9652, 2014-12 I.R.B.655 9653, 2014-6 I.R.B.460 9654, 2014-6 I.R.B.461 9655, 2014-9 I.R.B.541 9656, 2014-11 I.R.B.626 9657, 2014-13 I.R.B.687 9658, 2014-13 I.R.B.748 9659, 2014-12 I.R.B.653 9660, 2014-13 I.R.B.842 9661, 2014-13 I.R.B.855 9662, 2014-16 I.R.B.933 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23, 2013. April 28, 2014Bulletin No. 2014–18 ii Finding List of Current Actions on Previously Published Items 1 Bulletins 2014 –1 through 2014 –18 Announcements: 2007-44 Modified by Ann. 2014-4, 2014-7 I.R.B.523 2011-49 Modified by Ann. 2014-4, 2014-7 I.R.B.523 Notices: 2003-37 Obsoleted by REG-163195-05 2014-15 I.R.B.930 2006-87, 2006-2 C.B. 766 Superseded by Notice 2014-29, 2014-18 I.R.B.991 2006-109 Modified by Notice 2014-4, 2014-2 I.R.B.274 2007-25, 2007-1 C.B. 760 Superseded by Notice 2014-29, 2014-18 I.R.B.991 2007-59 Obsoleted by REG-163195-05 2014-15 I.R.B.930 2007-77, 2007-2 C.B. 735 Superseded by Notice 2014-29, 2014-18 I.R.B.991 2008-107, 2008-2 C.B. 1266 Superseded by Notice 2014-29, 2014-18 I.R.B.991 2009-78 Superseded by T.D. 9654 2014-6 I.R.B.461 2010-27, 2010-1 C.B. 531 Superseded by Notice 2014-29, 2014-18 I.R.B.991 2013-1 Superseded by Notice 2014-22, 2014-16 I.R.B.940 2013-1 Modified by Notice 2014-22, 2014-16 I.R.B.940 Revenue Procedures—Continued: 2013-13 Obsoleted by REG-163195-05 2014-15 I.R.B.930 2013-17 Amplified by Notice 2014-1, 2014-2 I.R.B.270 Revenue Procedures: 2003-49 Modified and superseded by Rev. Proc. 2014-14, 2014-2 I.R.B.295 2004-42 Obsoleted by REG-163195-05 2014-15 I.R.B.930 2004-43 Obsoleted by REG-163195-05 2014-15 I.R.B.930 2011-4 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B.661 2011-14 Modified by Rev. Proc. 2014-16, 2014-9 I.R.B.606 2011-14 Clarified by Rev. Proc. 2014-16, 2014-9 I.R.B.606 2011-14 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B.661 2011-44 Modified and Superseded by Rev. Proc. 2014-11, 2014-3 I.R.B.411 2011-49 Modified by Rev. Proc. 2014-6, 2014-1 I.R.B.198 2012-14 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B.661 2012-19 Modified by Rev. Proc. 2014-16, 2014-9 I.R.B.606 2012-19 Superseded by Rev. Proc. 2014-16, 2014-9 I.R.B.606 Revenue Procedures—Continued: 2012-20 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B.661 2012-20 Superseded by Rev. Proc. 2014-17, 2014-12 I.R.B.661 2013-1 Superseded by Rev. Proc. 2014-1, 2014-1 I.R.B.1 2013-2 Superseded by Rev. Proc. 2014-2, 2014-1 I.R.B.90 2013-3 Superseded by Rev. Proc. 2014-3, 2014-1 I.R.B.111 2013-4 Superseded by Rev. Proc. 2014-4, 2014-1 I.R.B.125 2013-5 Superseded by Rev. Proc. 2014-5, 2014-1 I.R.B.169 2013-6 Superseded by Rev. Proc. 2014-6, 2014-1 I.R.B.198 2013-7 Superseded by Rev. Proc. 2014-7, 2014-1 I.R.B.238 2013-8 Superseded by Rev. Proc. 2014-8, 2014-1 I.R.B.242 2013-9 Superseded by Rev. Proc. 2014-9, 2014-2 I.R.B.281 2013-10 Superseded by Rev. Proc. 2014-10, 2014-2 I.R.B.293 2013-22 Modified by Rev. Proc. 2014-28, 2014-16 I.R.B.944 2013-24 Obsoleted by Rev. Proc. 2014-23, 2014-12 I.R.B.685 2013-27 Obsoleted by Rev. Proc. 2014-23, 2014-12 I.R.B.685 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23, 2013. Bulletin No. 2014–18April 28, 2014 iii Revenue Procedures—Continued: 2013-32 Superseded in part by Rev. Proc. 2014-1, 2014-1 I.R.B.1, and Rev. Proc. 2014-3, 2014-1 I.R.B.111 2014-1 Amplified by Rev. Proc. 2014-18, 2014-7 I.R.B.513 2014-1 I.R.B. 111 Amplified by Rev. Proc. 2014-24, 2014-13 I.R.B.879 2014-3 Amplified by Rev. Proc. 2014-18, 2014-7 I.R.B.513 2014-3 I.R.B 111 Amplified by Rev. Proc. 2014-24, 2014-13 I.R.B.879 2014-4 Modified by Rev. Proc. 2014-19, 2014-10 I.R.B.619 Proposed Regulations: 209054-87 A portion withdrawn by REG-113350-13 2014-3 I.R.B.440 Revenue Rulings: 2005-48 (2005-2 CB 259) Obsoleted by T.D. 9659 2014-12 I.R.B.653 2013-17 Amplified by Notice 2014-19, 2014-17 I.R.B.979 2013-17 Amplified by Notice 2014-25, 2014-17 I.R.B.981 Treasury Decision: 9644 Correction by Ann. 2014-18, 2014-17 I.R.B.983 9644 Correction by Ann. 2014-19, 2014-17 I.R.B.984 April 28, 2014Bulletin No. 2014–18 iv INDEX Internal Revenue Bulletins 2014–1 through 2014–18 The abbreviation and number in parenthesis following the index entry refer to the specific item; numbers in roman and italic type following the parentheses refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears. Key to Abbreviations: AnnAnnouncement CDCourt Decision DODelegation Order EOExecutive Order PLPublic Law PTEProhibited Transaction Exemption RPRevenue Procedure RRRevenue Ruling SPRStatement of Procedural Rules TCTax Convention TDTreasury Decision TDOTreasury Department Order ADMINISTRATIVE Consolidated returns; failure to p[roperly include subsidiary (RP 24) 13,879 Extension of time to file estate tax return to elect portability of a deceased spousal unused exclusion amount under section 2010(c)(5)(A). (RP 18) 7,513 Method change procedures for dispositions of tangible deprecia- ble property (RP 17) 12,661 Maximum Vehicle Values for which the special valuation rules of regulations section 1.61–21(d) and (e) may be used (Notice 11) 13,880 Minimum essential coverage, information reporting (TD 9660) 13,842 Regulations: 26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR 1.6081– 8 amended. 26 CFR 301.6011–2 amended. 26 CFR 301.6721–1 amended. 26 CFR 1.6011– 8 amended. 26 CFR 301.6722–1 amended; minimum essential cover- age, information reporting 13,842 Per Capita Payments from Proceeds of Settlements of Indian Tribal Trust Cases (Notice 22) 16,940 Virtual Currency (Notice 21) 16,938 EMPLOYEE PLANS Definition of a substantial risk of forfeiture l (TD 9659) 12,653 Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Excepted benefits (REG–143172–13) 2,383 Final rules to implement the 90-day waiting period limitation (TD 9656) 11,626 EMPLOYEE PLANS—Cont. Letter rulings: And determination letters: Areas which will not be issued from Associate Chief Counsel and Division counsel (TE/GE) (RP 3) 1,111 Exemption application determination letter rulings under sections 501 and 521 (RP 9) 1,281 And general information letters; procedures (RP 4) 1,125 User fees, request for letter rulings (RP 8) 1,242 Letter rulings and general information letters (RP 4) 1,125 Letter rulings or determination letters (RP 1) 1,1 Proposed rules to clarify length of reasonable and bona fide employment-based orientation period, consistent with the 90- day waiting period limitation (REG–122706 –12) 11,647 Qualification, determination letters (RP 6) 1,198 Qualified plans: Application of the Windsor Decision and Rev. Rul. 2013–17 (Notice 19) 17,979 Discrimination (Notice 5) 2,276 Opinion letters (Ann 4) 7,523 Opinion letters (Ann 16) 17,983 Determination Letters (RP 19) 10,619 Qualified retirement plans covered compensation, permitted dis- parity (RR 3) 2,259 Qualified retirement plans Rollovers (RR 9) 17,975 Regulations: 26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647 Removal of the Qualified Payment Card Agent Program (REG– 163195– 05) 15,930 Request for Information Regarding Provider Non-Discrimination (REG–108641–14) 15,928 Rulings and determination letters, user fees (RP 8) 1,242 Technical advice memorandum or TAM (RP 2) 1,90 Technical advice procedures (RP 5) 1,169 Full funding limitations, weighted average interest rates, segment rates for: January 2014 (Notice 8) 5,452 Weighted average interest rates Segment rates for February 2014 (Notice 13) 10,616 Segment rates for March 2014 (Notice 16) 14,920 Segment rates for March 2014 (Notice 27) 18,987 EMPLOYMENT TAX Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Employment tax liability of agents authorized under section 3504 (TD 9649) 2,265 Employment tax obligations of a third party that enters into a service agreement with an employer to take on the employer’s employment tax responsibilities (TD 9662) 16,933 Regulations: 26 CFR 31–3504 –2, added; employment tax obligations of a third party that enters into a service agreement with an employer to take on the employer’s employment tax re- sponsibilities (TD 9662) 16,933 Bulletin No. 2014–18April 28, 2014 v EMPLOYMENT TAX—Cont. Letter rulings or determination letters (RP 1) 1,1 Regulations: 26 CFR 1.83–3 is revised; definition of a substantial risk of forfeiture (TD 9659) 12,653 26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647 26 CFR 54,9801–1, thru– 6, amended; 26 CFR 54.9802–1, amended; 26 CFR 54.9815–2708, added; 26 CFR 54.9831–1, amended (TD 9656) 12,626 Technical Advice Memorandum (TAM) (RP 2) 1,90 Virtual Currency (Notice 21) 16,938 ESTATE TAX Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Extension of time to file estate tax return to elect portability of a deceased spousal unused exclusion amount under section 2010(c)(5)(A) (RP 18) 7,513 Letter rulings or determination letters (RP 1) 1,1 Technical Advice Memorandum (TAM) (RP 2) 1,90 EXCISE TAX Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Final rules to implement the 90-day waiting period limitation (TD 9656) 11,626 Information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans (TD 9661) 13,855 Regulations: 301.6056 –1, –2, added; Information reporting by applicable large employers on health insurance coverage offered un- der employer-sponsored plans (TD 9661) 13,855 Interim guidance regarding supporting organizations (Notice 4) 2,274 Letter rulings or determination letters (RP 1) 1,1 Notice for ACA Section 9010 Health Insurance Providers Fee and expatriate plans (Notice 24) 16,942 Proposed rules to clarify length of reasonable and bona fide employment-based orientation period, consistent with the 90- day waiting period limitation (REG–122706 –12) 11,647 Regulations: 26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647 26 CFR 54,9801–1, thru– 6, amended; 26 CFR 54.9802–1, amended; 26 CFR 54.9815–2708, added; 26 CFR 54.9831–1, amended (TD 9656) 12,626 Technical Advice Memorandum (TAM) (RP 2) 1,90 EXEMPT ORGANIZATIONS Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Form 990 Revenue Procedure update to revoke Revenue Proce- dure 79 – 6 (RP 22) 11,646 Interim guidance regarding supporting organizations (Notice 4) 2,274 EXEMPT ORGANIZATIONS—Cont. Letter rulings: And determination letters: Areas which will not be issued from Associate Chief Counsel and Division counsel (TE/GE) (RP 3) 1,111 Exemption application determination letter rulings under sections 501 and 521 (RP 9) 1,281 And general information letters; procedures (RP 4) 1,125 User fees, request for letter rulings (RP 8) 1,242 Letter rulings (RP 10) 2,293; (RP 9) 2,281 Letter rulings or determination letters (RP 1) 1,1 Proposed procedures for charitable hospitals to correct and dis- close failures to meet section 501(r) (Notice 3) 3,408 Reliance on proposed regulations for tax-exempt hospitals (Notice 2) 3,407 Rulings and determination letters, user fees (RP 8) 1,242 Technical Advice Memorandum (TAM) (RP 2) 1,90 Technical advice procedures (RP 5) 1,169 INCOME TAX Adequate disclosure revenue procedure (RP 15) 5,456 Advance Pricing and Mutual Agreement Program (Ann 14) 16,948 Allocation of section 47 credits by a partnership to its partners (RP 12) 3,415 Allocation of section 752 recourse liabilities among related par- ties (REG–136984 –12) 2,378 Amount of the life insurance reserves taken into account under § 807 of the Internal Revenue Code for variable contracts (RR 7) 9,539 Areas in which rulings will not be issued; Associate Chief Counsel (International) (RP 7) 1,238 Basis in assets of tax exempt trusts (REG–154890 – 03) 6,504 Bond premium carryforward (TD 9653) 6,460 Cafeteria plans, FSA reimbursements, and HSA contribution limits for same-sex spouses (Notice 1) 2,270 2014 Census Count (Notice 12) 9,606 Contribution of built-in lost property to a partnership; mandatory basis adjustments in the event of a substantial built-in loss or substantial basis reduction; modification of basis allocation rules (REG–144468 – 05) 6,474 Current refunding of Recovery Zone facility bonds (Notice 9) 5,455 Declaratory judgement suits (Ann 5) 6,507; (Ann 6) 6,507; (Ann 7) 6,508; (Ann 8) 6,508; (Ann 9) 6,508; (Ann 10) 6, 508; (Ann 12) 6,509 Definition of a substantial risk of forfeiture (TD 9659) 12,653 Definitions applicable to U.S. persons owning interests in passive foreign investment companies (REG–113350 –13) 3,440 Depreciation deduction, limitations on certain automobiles (RP 21) 11,641 Determination of housing cost eligible exclusion or deduction for 2014 (Notice 29) 18,991 Determination of ownership in a passive foreign investment company; annual filing requirements for shareholders of pas- sive foreign investment companies; filing requirements for constructive owners in certain foreign corporations (REG– 140974 –11) 3,438; (TD 9650) 3,394 April 28, 2014Bulletin No. 2014–18 vi INCOME TAX—Cont. Determining stock ownership for purposes of whether an entity is a surrogate foreign corporation (TD 9654) 6,461; (REG– 121534 –12) 6,473 Discharge of indebtedness secured by real property (RP 20)9, 614 Disciplinary actions involving attorneys, certified public accoun- tants, enrolled agents, and enrolled actuaries (Ann 13) 10,620 Domestic areas in which the Service will not issue letter rulings or determination letters (RP 3) 1,111 Equity-linked instruments and dividend equivalents (Notice 14) 13,881 FATCA financial institution registration update (Ann 1) 2,393 FATCA IGA and registration update (Ann 17) 18,1001 Final FFI agreement for participating FFI and reporting Model 2 FFI (RP 13) 3,419 Foreign Earned Income Exclusion (RP 25) 15,927 2014 –2015 Guidance Priority List- Solicitation Notice (Notice 18) 15,926 Guidance regarding reinstatement following auto revocation of tax-exempt status under section 6033(j) (RP 11) 3,411 Income tax treatment of per capita payments made from funds held in trust by the Secretary of the Interior (Notice 17) 13,881 Information reporting by foreign financial institutions and with- holding on payments to foreign financial institutions and other foreign entities (REG–130967–13) 13,884 Regulation: 26 CFR 1.1471– 0, amended; 26 CFR 1.1471–1, amended; 26 CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26 CFR 1.1471– 4, amended; 26 CFR 1.1471–5, amended; 26 CFR 1.1471– 6, amended; 26 CFR 1.1472–1, amended; 26 CFR 1.1473–1, amended; 26 CFR 1474 –1, amended; 26 CFR 1.1474 – 6, amended. (Reg–130967–13) 13,884 Information reporting by foreign financial institutions and with- holding on payments to foreign financial institutions and other foreign entities (TD 9657) 13,687 Regulations: 26 CFR 1.1471– 0, amended; 26 CFR 1.1471–1, amended; 26 CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26 CFR 1.1471– 4, amended; 26 CFR 1.1471–5, amended; 26 CFR 1.1471– 6, amended; 26 CFR 1.1472–1, amended; 26 CFR 1.1473–1, amended; 26 CFR 1474 –1, amended; 26 CFR 1.1474 – 6, amended. (TD 9657) 13,687 Interest: Investment: Federal short-term, mid-term, and long-term rates for: January 2014 (RR 1) 2,263 February 2014 (RR 6) 7,510 March 2014 (RR 8) 11,624 April 2014 (RR 12) 15,923 Intra-group gross receipts (REG–159420 – 04) 2,374 Insurance tax, insurance companies, interest rate tables (RR 4) 5, 449 Letter rulings or determination letters (RP 1) 1,1 Low-Income Housing Credit (Notice 15) 12,661 INCOME TAX—Cont. Maximum Vehicle Values for which the special valuation rules of regulations section 1.61–21(d) and (e) may be used (Notice 11) 13,880 Method change procedures for dispositions of tangible deprecia- ble property (RP 17) 12,661 Minimum essential coverage, information reporting (TD 9660) 13,842 Regulations: 26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR 1.6081– 8 amended. 26 CFR 301.6011–2 amended. 26 CFR 301.6721–1 amended. 26 CFR 1.6011– 8 amended. 26 CFR 301.6722–1 amended. (TD 9660) 13,842 Net investment income tax; TD 9644 Correction (Ann 2014 –18) 17,983 Net investment income tax; TD 9644 Correction (Ann 2014 –19) 17,984 Postponement of deadline for § 165(i) election for losses attrib- utable to September 2013 major flooding in Colorado (Notice) (Notice 20) 16,937 Principal residence, treatment of National Mortgage Settlement payments (RR 2) 2,255 Qualified census tracts (RP 14) 2,295 Refundable Credit For Coverage Under a Qualified Health Plan, Definition and Rules Relating to Applicable Taxpayer (Notice 23) 16,942 Regarding disguised sales, generally (REG–119305–11) 8,524 Regulations: 26 CFR 1.83–3 is revised; definition of a substantial risk of forfeiture (TD 9659) 12,653 26 CFR 1.263A– 0, thru–3, amended; 1.471–3 amended; sales-base royalties and vendor allowances (TD 9652) 12, 655 Removal of the Qualified Payment Card Agent Program (REG– 163195– 05) 15,930 Regulations: 26 CFR 301.6724 –1(c)(6), amended; 26 CFR 31.3406(g)– 1(f), 26 CFR 301.6724 –1(e)(1)(vi)(H), and 26 CFR 301.6724 –1(f)(5)(vii), removed;removal of the qualified payment ard agent program (REG–163195– 05) 15,930 Revocations, exempt organization (Ann 11) 6,508 Sales-bases royalties and vendor allowances (TD 9652) 12,655 2013 Section 45K Inflation Adjustment Factor - Nonconven- tional Fuel source Credit (Notice 25) 17,981 Shared responsibility for employers regarding health coverage (TD 9655) 9,541 Shared responsibility payment for not maintaining minimum essential coverage (REG–141036 –13) 7,516 Standard Industry Fare Level (SIFL) (RR 10) 14,906 Tangible property regulations method change guidance (RP 16) 9,606 Technical Advice Memorandum (TAM) (RP 2) 1,90 Transition relief for the tax credit for employee health insurance expenses of certain small employers (Notice 6) 2,279 Transition relief under section 5000A for certain individuals without minimum essential coverage (Notice 10) 9,605 Bulletin No. 2014–18April 28, 2014 vii INCOME TAX—Cont. Treatment of U.S. persons that own stock of passive foreign investment companies through certain organizations and ac- counts that are tax exempt (Notice 28)18 990 Underpayment and overpayments, quarter beginning: April 1, 2014 (RR 11) 14,906 Virtual Currency (Notice 21) 16,938 Withholding of tax on certain U.S. source income paid to foreign persons and revision of information reporting and backup withholding regulations (REG–134361–12) 13,895 Proposed Regulations: 26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26 CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26 CFR 1.441– 6, amended; 26 CFR 1.1441.7, amended; 26 CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26 CFR 1.6041–1, amended; 26 CFR 1.6041– 4, amended; 26 CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26 CFR 1.6045–1, amended; 26 CFR 1.6049 – 4, amended; 26 CFR 1.6049 –5, amended; 26 CFR31.3406(g)–1, amended; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3, amended; Withholding of tax on certain U.S. source in- come paid to foreign persons and revision of information reporting and backup withholding regulations (REG– 134361–12) 13,895 Withholding of tax on certain U.S. source income paid to foreign persons and revision of information reporting and backup withholding regulations (TD 9658) 13,748 Regulations: 26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26 CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26 CFR 1.441– 6, amended; 26 CFR 1.1441.7, amended; 26 CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26 CFR 1.6041–1, amended; 26 CFR 1.6041– 4, amended; 26 CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26 CFR 1.6045–1, amended; 26 CFR 1.6049 – 4, amended; 26 CFR 1.6049 –5, amended; 26 CFR 31.3406(g)–1, amend- ed; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3, amended; Withholding of tax on certain U.S. source in- come paid to foreign persons and revision of information reporting and backup withholding regulations (TD 9658) 13,748 SELF-EMPLOYMENT TAX Virtual Currency (Notice 21) 16,938 SPECIAL ANNOUNCEMENT Advance Pricing and Mutual Agreement Program (Ann 14) 16, 948 April 28, 2014Bulletin No. 2014–18 viii INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available atwww.irs.gov/irb/. CUMULATIVE BULLETINS The contents of the weekly Bulletins were consolidated semiannually into permanent, indexed, Cumulative Bulletins through the 2008 –2 edition. INTERNAL REVENUE BULLETINS ON CD-ROM Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet atwww.irs.gov/cdorders(discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the IRS Bulletin Unit, SE:W:CAR:MP:P:SPA, Washington, DC 20224. Internal Revenue Service Washington, DC 20224 Official Business Penalty for Private Use, $300
Poursuivez vos recherches dans ChatGPT ou Claude
Connectez Omnilex pour rechercher dans le corpus juridique depuis votre assistant IA.