Internal Revenue Bulletin 2015-3 (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
Announcement 2015–2, page 324.
This Announcement provides a simplified process for issuers
of qualified 501(c)(3) bonds, as defined in the Announcement,
to request a closing agreement in situations in which the
borrower of the proceeds of the bonds received Prospective
Reinstatement, as defined in the Announcement, after its tax-
exempt status was automatically revoked under section
6033(j)(1) of the Internal Revenue Code (the “Code”).
Rev. Rul. 2015–2, page 321.
Insurance companies; interest rate tables. Prevailing state as-
sumed interest rates are provided for the determination of
reserves under section 807 of the Internal Revenue Code for
contracts issued in 2014 and 2015. Rev. Rul. 92–19 is sup-
plemented in part.
EMPLOYEE PLANS
Announcement 2015–3, page 328.
This announcement provides automatic approval of a change in
funding method with respect to a single-employer defined ben-
efit plan under certain circumstances in which the change in
method results from a change in the plan’s enrolled actuary.
The automatic approval provided by this announcement will
apply for plan years beginning on or after January 1, 2013.
Finding Lists begin on page ii.
Bulletin No. 2015–3
January 20, 2015

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
January 20, 2015Bulletin No. 2015–3

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 807.—Rules for
Certain Reserves
Rev. Rul. 2015–2
For purposes of § 807(d)(4) of the In-
ternal Revenue Code, for taxable years
beginning after December 31, 2013, this
ruling supplements the schedules of pre-
vailing state assumed interest rates set
forth in Rev. Rul. 92–19, 1992–1 C.B.
227. This information is to be used by
insurance companies in computing their
reserves for (1) life insurance and supple-
mentary total and permanent disability
benefits, (2) individual annuities and pure
endowments, and (3) group annuities and
pure endowments. As § 807(d)(2)(B)
requires that the interest rate used to
compute these reserves be the greater of
(1) the applicable federal interest rate,
or (2) the prevailing state assumed in-
terest rate, the table of applicable fed-
eral interest rates in Rev. Rul. 92–19 is
also supplemented.
Following are supplements to sched-
ules A, B, C, and D to Part III of Rev. Rul.
92–19, providing prevailing state assumed
interest rates for insurance products with
different features issued in 2014 and 2015,
and a supplement to the table in Part IV of
Rev. Rul. 92–19, providing the applicable
federal interest rates under § 807(d) for
2014 and 2015. This ruling does not sup-
plement Parts I and II of Rev. Rul. 92–19.
This is the twenty-third supplement to
the interest rates provided in Rev. Rul.
92–19. Earlier supplements were pub-
lished in Rev. Rul. 93–58, 1993–2 C.B.
241 (interest rates for insurance products
issued in 1992 and 1993); Rev. Rul. 94 –
11, 1994 –1 C.B. 196 (1993 and 1994);
Rev. Rul. 95– 4, 1995–1 C.B. 141 (1994
and 1995); Rev. Rul. 96 –2, 1996 –1 C.B.
141 (1995 and 1996); Rev. Rul. 97–2,
1997–1 C.B. 134 (1996 and 1997); Rev.
Rul. 98 –2, 1998 –1 C.B. 259 (1997 and
1998); Rev. Rul. 99 –10, 1999 –1 C.B. 671
(1998 and 1999); Rev. Rul. 2000 –17,
2000 –1 C.B. 842 (1999 and 2000); Rev.
Rul. 2001–11, 2001–1 C.B. 780 (2000 and
2001); Rev. Rul. 2002–12, 2002–1 C.B.
624 (2001 and 2002); Rev. Rul. 2003–24,
2003–1 C.B. 557 (2002 and 2003); Rev.
Rul. 2004 –14, 2004 –1 C.B. 511 (2003
and 2004); Rev. Rul. 2005–29, 2005–1
C.B. 1080 (2004 and 2005); Rev. Rul.
2006 –25, 2006 –1 C.B. 882 (2005 and
2006); Rev. Rul. 2007–10, 2007–1 C.B.
660 (2006 and 2007); Rev. Rul. 2008 –19,
2008 –1 C.B. 669 (2007 and 2008); Rev.
Rul. 2009 –3, 2009 –5 I.R.B. 382 (2008
and 2009); Rev. Rul. 2010 –7, 2010 – 8
I.R.B. 417 (2009 and 2010); Rev. Rul.
2011–23, 2011– 43 I.R.B. 585 (2010 and
2011); Rev. Rul. 2012– 6, 2012– 6 I.R.B.
349 (2011 and 2012); Rev. Rul. 2013– 4,
2013–9 I.R.B. 520 (2012 and 2013); and
Rev. Rul. 2014 – 4, 2014 –5 I.R.B. 449
(2013 and 2014).
Part III. Prevailing State Assumed Interest Rates—Products Issued in Years After 1982.*
Schedule A
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
A. Life insurance valuation:
Guarantee Duration (years)Calendar Year of Issue 2015
10 or fewer3.75**
More than 10 but not more than 203.75**
More than 203.50**
Source: Rates calculated from the monthly averages, ending June 30, 2014, of Moody’s Composite Yield on Seasoned
Corporate Bonds.
*The terms used in the schedules in this ruling and in Part III of Rev. Rul. 92–19 are those used in the Standard Valuation
Law; the terms are defined in Rev. Rul. 92–19.
**As these rates exceed the applicable federal interest rate for 2015 of 1.68 percent, the valuation interest rate to be used
for this product under § 807 is the applicable rate specified in this table.
Bulletin No. 2015–3January 20, 2015
321

Part III, Schedule B
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
B. Single premium immediate annuities and annuity benefits involving life contingencies arising from other annuities with cash
settlement options and from guaranteed interest contracts with cash settlement options:
Part III, Schedule C24–2014
STATUTORY VALUATION INTEREST RATES
BASED ON NAIC STANDARD VALUATION LAW
FOR 2014 CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
C. Valuation interest rates for other annuities and guaranteed interest contracts that are valued on an issue year basis:
Calendar Year of IssueValuation Interest Rate
20144.50*
Source: Rates calculated from the monthly averages, ending June 30, 2014, of Moody’s Composite Yield on Seasoned
Corporate Bonds.
*As this prevailing state assumed interest rate exceeds the applicable federal interest rate for 2014 of 1.79 percent, the
valuation interest rate of 4.50 percent is to be used for this product under § 807.
Cash
Settlement
Future
InterestGuarantee DurationValuation Interest Rate For Plan Type
Options?Guarantee?(years)ABC
YesYes5 or fewer4.50*4.00*3.75*
More than 5, but not more than 104.25*4.00*3.75*
More than 10, but not more than 204.00*3.75*3.75*
More than 203.75*3.50*3.50*
YesNo5 or fewer4.50*4.00*4.00*
More than 5, but not more than 104.50*4.00*4.00*
More than 10, but not more than 204.00*3.75*3.75*
More than 203.75*3.50*3.50*
NoYes or No5 or fewer4.50*
More than 5, but not more than 104.25*NOT APPLICABLE
More than 10, but not more than 204.00*
More than 203.75*
Source: Rates calculated from the monthly averages, ending June 30, 2014, of Moody’s Composite Yield on Seasoned
Corporate Bonds.
*As these rates exceed the applicable federal interest rate for 2014 of 1.79 percent, the valuation interest rate to be used
for this product under § 807 is the applicable rate specified in the above table.
January 20, 2015Bulletin No. 2015–3
322

Part III, Schedule D24–2014
STATUTORY VALUATION INTEREST
RATES BASED ON NAIC STANDARD VALUATION LAW
FOR 2014 CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
D. Valuation interest rates for other annuities and guaranteed interest contracts that are contracts with cash settlement options and
that are valued on a change in fund basis:
Part IV. Applicable Federal Interest Rates.
TABLE OF
APPLICABLE FEDERAL INTEREST RATES
FOR PURPOSES OF § 807
EFFECT ON OTHER REVENUE
RULINGS
Rev. Rul. 92–19 is supplemented by
the addition to Part III of that ruling of
prevailing state assumed interest rates un-
der § 807 for certain insurance products
issued in 2014 and 2015 and is further
supplemented by an addition to the table
in Part IV of Rev. Rul. 92–19 listing ap-
plicable federal interest rates. Parts I and
II of Rev. Rul. 92–19 are not affected by
this ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Alexis A. MacIvor of the Office
of Associate Chief Counsel (Financial In-
stitutions and Products). For further infor-
mation regarding this revenue ruling con-
tact her at (202) 317-6995 (not a toll-free
number).
YearInterest Rate
20141.79
20151.68
Sources: Rev. Rul. 2004–106, 2004–2 C.B. 893, for the 2005 rate; Rev. Rul. 2005–77, 2005–2 C.B. 1071, for the 2006
rate; Rev. Rul. 2006–61, 2006–2 C.B 1028 for the 2007 rate; Rev. Rul. 2007–70, 2007–2 C.B. 1158 for the 2008 rate;
Rev. Rul. 2008–53, 2008–2 C.B. 1231 for the 2009 rate; Rev. Rul. 2009–38, 2009–49 I.R.B. 736, for the 2010 rate; Rev.
Rul. 2010–29, 2010–50 I.R.B. 818 for the 2011 rate; Rev. Rul. 2011–31, 2011–49 I.R.B. 829 for the 2012 rate; Rev. Rul.
2012–31, 2012–49 I.R.B. 636 for the 2013 rate; Rev. Rul. 2013–26, 2013–50 I.R.B. 628 for the 2014 rate; and Rev. Rul.
2014–31, 2014–50 I.R.B. 935 for the 2015 rate.
Cash SettlementFuture InterestGuarantee DurationValuation Interest Rate For Plan Type
Options?Guarantee?(years)ABC
YesYes5 or fewer4.75*4.50*4.00*
More than 5, but not more than 104.50*4.50*4.00*
More than 10, but not more than 204.50*4.25*3.75*
More than 204.00*4.00*3.75*
YesNo5 or fewer4.75*4.50*4.00*
More than 5, but not more than 104.75*4.50*4.00*
More than 10, but not more than 204.50*4.50*4.00*
More than 204.00*4.00*3.75*
Source: Rates calculated from the monthly averages, ending June 30, 2014, of Moody’s Composite Yield on Seasoned
Corporate Bonds.
* As these rates exceed the applicable federal interest rate for 2014 of 1.79 percent, the valuation interest rate to be used
for this product under § 807 is the applicable rate specified in the above table.
Bulletin No. 2015–3January 20, 2015
323

Part IV. Items of General Interest
TEB Voluntary Closing
Agreement Program: Relief
from violation of qualified
ownership and use
requirements for qualified
501(c)(3) bonds.
Announcement 2015–2
This Announcement provides a simpli-
fied process for issuers of qualified
501(c)(3) bonds, as defined below, to re-
quest a closing agreement in situations in
which the borrower of the proceeds of the
bonds received Prospective Reinstate-
ment, as defined below, after its tax-
exempt status was automatically revoked
under section 6033(j)(1) of the Internal
Revenue Code (the “Code”).
SECTION 1. BACKGROUND
Interest on bonds issued under section
145 of the Code (“qualified 501(c)(3)
bonds”) is tax exempt if certain require-
ments are met, including two principal
requirements under section 145(a). First,
all the property financed with the net pro-
ceeds of the bonds must be owned by an
organization exempt from tax under sec-
tion 501(c)(3) (a “501(c)(3) organiza-
tion”) or a state or local government
entity.Second, the property financed with
the net proceeds of the bonds must be used
almost exclusively by 501(c)(3) organiza-
tions in their related trade or business or
state or local government entities. If an or-
ganization for which qualified 501(c)(3)
bonds are issued fails to qualify as a
501(c)(3) organization at any time while the
bonds are outstanding, the bonds may fail to
qualify under section 145 of the Code.
Pursuant to section 6033(j), when a
501(c)(3) organization fails to file an an-
nual return or notice required under sub-
section 6033(a)(1) or 6033(i) for three
consecutive years, the organization’s sta-
tus as a 501(c)(3) organization shall be
considered revoked on and after the re-
quired date for the filing of the third an-
nual return or notice (the “Revocation
Date”). Section 6033(j)(2) of the Code
provides a mechanism by which an orga-
nization may seek reinstatement of its ex-
empt status after automatic revocation.
Pursuant to section 6033(j)(3), retroac-
tive reinstatement of the organization’s
section 501(c)(3) status may be granted in
certain situations. If an organization can
show reasonable cause for its failure to
file, the organization’s exempt status may
be reinstated retroactively to the Revoca-
tion Date, which means there will be no
time during which the organization was
not a 501(c)(3) organization. Revenue
Procedure 2014 –11, 2014 –3 IRB 411,
provides the procedures under which an auto-
matically revoked organization can request re-
instatement, including retroactive reinstate-
ment, of its exempt status. However, under
certain situations described in Rev. Proc.
2014 –11, the effective date of reinstatement of
the 501(c)(3) organization’s exempt status
may be later than the Revocation Date (“Pro-
spective Reinstatement”).
SECTION 2. APPLICATION OF THIS
ANNOUNCEMENT AND THE
CLOSING AGREEMENT PROCESS.
.01 An issuer of qualified 501(c)(3)
bonds (the “Bonds”) may apply for a clos-
ing agreement under this Announcement
if the following requirements are met:
(1) The 501(c)(3) organization that is
the beneficiary of the Bonds (the “Orga-
nization”) has received Prospective Rein-
statement of its exempt status.
(2) The Organization’s exempt status
has not been previously revoked since the
issue date of the Bonds. If the proceeds of
the Bonds were used to refund prior qual-
ified 501(c)(3) bonds, for purposes of this
Announcement, the “issue date” means
the issue date of the refunded bonds.
(3) The request for the closing agree-
ment is submitted within 12 months of the
date of the reinstatement letter. If the re-
instatement letter is dated before Decem-
ber 30, 2014, the issuer has 12 months
from December 30, 2014 to submit a clos-
ing agreement under this Announcement.
(4) The Bonds are not under examina-
tion by the Internal Revenue Service.
.02 To obtain relief under this An-
nouncement, an issuer must submit the
documents in (1) and (2) below to the
address provided in Section 2.05 of this
Announcement and pay the closing agree-
ment amount computed in accordance
with Section 2.04 of this Announcement:
(1) Three executed copies of the com-
pleted closing agreement, including the
Attachment A, in the form attached as an
Exhibit to this Announcement,
(2) A copy of the reinstatement letter
received by the Organization.
.03 If the Organization’s revocation af-
fects more than one of the issuer’s bond
issues, the issuer may submit one closing
agreement to cover all affected bond is-
sues. If theBonds fail to qualify because
more than one Organization that is the bor-
rower of the proceeds of the Bonds had its
exempt status revoked under section 6033(j)
of the Code, the issuer must submit a sepa-
rate closing agreement under this An-
nouncement for each Organization.
.04 The closing agreement amount for
each bond issue covered by a closing
agreement will equal $500 for each calen-
dar month or portion thereof in the period
starting with the month that includes the
Revocation Date and ending in the month
that includes the effective date of the re-
instatement of the exempt status of the
Organization. Theissuer must pay the clos-
ing agreement amount for each bond issue
included in the closing agreement as pro-
vided in the Attachment to the Agreement.
.05 The issuer must submit items in
Section 2.02 of this Announcement to:
Internal Revenue Service (TE/GE)
1122 Town & Country Commons
Chesterfield, MO 63017
Attn: Ken Stengel, SE:T:GE:TEB:CPM
.06 Issuers of bonds for which there are
violations not covered under this An-
nouncement should refer to Notice 2008 –
31, 2008 –11 IRB 592 (March 17, 2008),
setting forth the Office of Tax Exempt
Bonds’ Voluntary Closing Agreement
Program.
SECTION 3. DRAFTING
INFORMATION
The principal author of this Announce-
ment is James L. Held of the IRS Office of
Tax Exempt Bonds. For further informa-
tion regarding this Announcement, con-
tact James Held at (401) 528-1869 (not a
toll-free number).
January 20, 2015Bulletin No. 2015–3
324

Exhibit
CLOSING AGREEMENT ON FINAL DETERMINATION
COVERING SPECIFIC MATTERS
Under section 7121 of the Internal Revenue Code of 1986, as amended (the “Code“), Issuer Name, Issuer EIN (the ”Issuer“),
Affected Organization Name, Affected Organization EIN, (the “Affected Organization”) and the Commissioner of Internal Revenue
(the “IRS”) make this closing agreement (the “Agreement”).
WHEREAS, this Agreement is based on the following facts and representations:
A. This Agreement is in settlement of issues raised in a request for a voluntary closing agreement pertaining to the (insert Legal
Description of Bonds, Par Amount, Name, Type, Project, Series, Etc.) (the “Bonds”), issued on (Issue Date(s)).
B. Except as otherwise specifically stated in this paragraph B, the Issuer and Affected Organization make the following
representations:
1. The Bonds were issued and sold under the representation to bondholders that the Bonds comply with all provisions of the
Code such that interest on the Bonds is not included in the bondholders’ gross income.
2. The Bonds were issued as qualified 501(c)(3) bonds pursuant to section 145 of the Code.
3. The Affected Organization represents that on (insert Date of Revocation), the Affected Organization’s status as an
organization described in section 501(c)(3) of the Code was revoked pursuant to section 6033(j) of the Code.
4. The Affected Organization represents that the Affected Organization received reinstatement of its exempt status as an
organization described in section 501(c)(3) of the Code effective on (Insert Date).
5. The Issuer and Affected Organization represent that they are aware of no reason, other than the Affected Organization’s
revocation under section 6033(j), that the bonds fail to qualify as qualified 501(c)(3) bonds the interest on which is
excludable from gross income under section 103 of the Code.
6. The Issuer represents that to the best of the Issuer’s knowledge and belief, the above representations of the Affected
Organization are true, accurate and complete.
7. The Issuer represents that it satisfies all of the requirements for relief under Announcement 2015–2.
C. Based on the representations of the Issuer and Affected Organization in paragraph B, the IRS has a basis to conclude that
interest on the Bonds is includable in the bondholders’ gross income because the described revocation of the Affected
Organization’s status under section 6033(j) of the Code resulted in the failure of the Bonds to meet the requirements of section
145(a) of the Code.
D. The IRS has not formally asserted any claims against the Issuer or the Affected Organization, or sought to tax interest on the
Bonds.
E. The Issuer, the Affected Organization and the IRS desire to resolve the violation described in paragraph C.
F. The terms of this Agreement were arrived at pursuant to Announcement 2015–2 and may differ from the settlement terms of
other closing agreements.
G. The Issuer and the Affected Organization also represent that payment of the Settlement Amount defined below shall be made
from sources other than proceeds of bonds described in sections 103, 54A or 54AA of the Code.
NOW, IT IS HEREBY DETERMINED AND AGREED PURSUANT TO THIS AGREEMENT EXECUTED BY THE
PARTIES HERETO UNDER SECTION 7121 OF THE CODE THAT FOR FEDERAL INCOME TAX PURPOSES:
1. Prior to the execution of this Agreement by the IRS, the Issuer shall cause to be electronically paid the sum of $__________,
(_______________________ Dollars) (the “Settlement Amount”) to the U.S. Treasury via the Electronic Federal Tax Payment
System and in accordance with the directions contained in the Attachment to this Agreement.
2. The Settlement Amount is not refundable or subject to credit or offset under any circumstance.
3. The Settlement Amount or any portion thereof paid by or on behalf of the Issuer shall not be deductible or amortizable for
federal income tax purposes by any person.
4. The Settlement Amount shall not be treated as income to any person benefiting from this Agreement.
5. The bondholders shall not be required to include interest paid on the Bonds in gross income because of the specific violation
identified in paragraph C.
6. The IRS may take any appropriate action, including requiring bondholders to include interest paid on the Bonds in gross
income, for any violation not specifically listed in paragraph C that has occurred or will occur with respect to the Bonds.
7. This Agreement is not based upon an examination of the Bonds by the IRS and does not preclude or impede an examination
of the Bonds, the Issuer, the Affected Organization, or any Bondholder with respect to matters not addressed herein.
8. This Agreement may not be cited or relied upon by any person or entity whatsoever as precedent in the disposition of any other
case.
Bulletin No. 2015–3January 20, 2015
325

9. This Agreement is final and conclusive, except that:
a. The matter it relates to may be reopened in the event of fraud, malfeasance, or misrepresentation of a material fact;
b. It is subject to sections of the Code that expressly provide that effect be given to their provisions notwithstanding any other
law or rule of law; and
c. If it relates to a tax period ending after the effective date of this agreement, it is subject to any law enacted after the
Agreement date that applies to that tax period.
This space intentionally left blank.
January 20, 2015Bulletin No. 2015–3
326

By signing, the parties certify that they have read and agreed to the terms of this Agreement.
ISSUER:EIN:
By signing, I certify that I have the authority to execute this Agreement on behalf of Issuer
BY:________________________________________________
SIGNATURE
________________________________________________
NAME (PLEASE PRINT)
________________________________________________
TITLE
________________________________________________
DATE
AFFECTED ORGANIZATION:EIN:
By signing, I certify that I have the authority to execute this Agreement on behalf of Affected Organization
BY:_______________________________________________
SIGNATURE
________________________________________________
NAME (PLEASE PRINT)
________________________________________________
TITLE
________________________________________________
DATE
COMMISSIONER OF INTERNAL REVENUE:
BY:________________________________________________
SIGNATURE
Karen A. Skinder
Acting Manager, Tax Exempt Bonds Compliance & Program
Management
______________________________________
NAME AND TITLE
________________________________________________
DATE
Attachment A
Taxpayer Information Worksheet for Electronic Federal Tax Payment System Deposit
This Agreement requires the electronic deposit of the Settlement Amount set forth in the Agreement to the U.S. Treasury through
the Electronic Federal Tax Payment System (EFTPS) as a term for resolution of certain identified matters related to the
tax-advantaged treatment of interest paid on a municipal obligation. This Settlement Amount will be deposited in accordance with
this Attachment.
In signing the Agreement, the Issuer represents that to the best of its knowledge, the information provided below is correct. Unless
specifically stated otherwise is in this Attachment, Issuer is to deposit the Settlement Amount through the EFTPS (eitherEFTPS –
DirectorEFTPS – Through a Financial Institution) accurately and in accordance with this information and the terms of this
Agreement.
1.
Total Amount of Tax Deposit:$______
2. Issuer Employee Identification Number (EIN):_________
3. Issuer Name Control (4 characters):_______
4. Issuer Name (up to 35 characters):_________
5. Tax Type (5 characters):80384
6. Tax Year (2 digits):____
7. Tax Month (2 digits):____
Bulletin No. 2015–3January 20, 2015
327

The Issuer’s financial institution may call the EFTPS Financial Institution Helpline for questions or assistance at1-800-605-9876
(Monday – Friday, 8:00 a.m. – 8:00 p.m., Eastern Standard Time).
NOTE:If the Issuer isnotenrolled inEFTPS – DirectorEFTPS – Through a Financial Institution, or is otherwise unable to
use the Same Day Payment option, the Issuer should provide its financial institution with the information listed above and direct it
to accurately deposit the Settlement Amount utilizing the following routing and account numbers:Note that theReceiving
ABA/Routing Number,Receiving FI Name, Tax Type(underBeneficiary)andBeneficiary FIindicated below do not change.
Receiving ABA/Routing Number:091036164 FRB MPLS ETA
Receiving FI Name:US TREAS SINGLE TX
Beneficiary:Issuer EIN: Name Control: Issuer Name 35 Characters:80384:YY:MM
Beneficiary FI:20092900IRS
If the financial institution has difficulty transmitting the EFTPS same-day payment, please call1-800-382-0045(Monday – Friday,
7:45 a.m. – 4:30 p.m. Central Standard Time) to receive assistance from a Customer Service Representative at the Minneapolis
Federal Reserve Bank.
CONTACT INFORMATION
ISSUER
Name:
Address:
Attn:
Phone Number:
AFFECTED ORGANIZATION
Name:
Address:
Attn:
Phone Number:
Automatic Approval of
Change in Funding Method
for Takeover Plans
Announcement 2015–3
Purpose
This announcement provides automatic
approval of a change in funding method
with respect to a single-employer defined
benefit plan under certain circumstances
in which the change in method results
from a change in the plan’s enrolled actu-
ary. The automatic approval provided by
this announcement will apply for plan
years beginning on or after January 1,
2013.
Background
Under § 412(c)(5) of the Internal Rev-
enue Code (“Code”), as in effect prior to
the Pension Protection Act of 2006 (“PPA
‘06”), any change of funding method re-
quires the approval of the Secretary.
A change in funding method can occur
when both the enrolled actuary and busi-
ness organization providing actuarial ser-
vices for a plan are changed and the new
enrolled actuary uses different valuation
software than the prior enrolled actuary or
otherwise applies the overall funding
method in a different manner. Section
4.03 of Rev. Proc. 2000 – 40, 2000 –2 C.B.
357, provided automatic approval for cer-
tain changes in funding method that oc-
curred with respect to “takeover plans”
(that is, plans for which both the enrolled
actuary and the business organization pro-
viding actuarial services are changed).
Section 412(d)(1) of the Code, as
amended by PPA ‘06, retains the require-
ment that a change in funding method be
approved by the Secretary. Under PPA
‘06, a single funding method must be used
to determine the liabilities for any single-
employer defined benefit plan subject to
§ 430, but there may be some variation in
the manner the method is applied. (Rev.
Proc. 2000 – 40 has not been updated to
reflect the changes made by PPA ‘06.
Moreover, the calculations that were used
for the pre-PPA ‘06 five percent test that
was a condition of automatic approval for
takeover plans are not used under § 430.)
For plan years beginning on or after
January 1, 2009, Announcement 2010 –3,
2010 – 4 I.R.B. 333, provides automatic
approval for certain changes in funding
method used to determine the minimum
funding requirement for defined benefit
plans subject to the requirements of § 430.
These approvals apply to certain funding
method changes that result either from a
change in the valuation software used to
determine the liabilities for such plans or
from a change in the enrolled actuary and
the business organization providing actu-
arial services to the plan. Under An-
nouncement 2010 –3, five percent tests
similar to the five percent tests under sec-
tion 4.03(3) of Rev. Proc. 2000 – 40 are
required to be applied with respect to the
January 20, 2015Bulletin No. 2015–3
328

liabilities and assets reflected on the
ScheduleSB(Form5500,Single-
Employer Defined Benefit Plan Actuarial
Information) for the prior plan year.
Section III.B of Notice 2014 –53,
2014 – 43 I.R.B. 737 (which provides
guidance on the changes to the funding
stabilization rules for single-employer
pension plans that were made by section
2003 of the Highway and Transportation
Funding Act of 2014) provides for the
filing of an amended Schedule SB for the
2013 plan year under certain circum-
stances. This announcement expands
upon the automatic approval for takeover
plans under Announcement 2010 –3 by al-
lowing the five percent tests to be per-
formed for the year in which the takeover
occurs, and permits the newly hired enrolled
actuary to use a signed actuarial valuation
report issued by the prior enrolled actuary
for the plan in lieu of the Schedule SB. This
change facilitates the filing of an amended
Schedule SB for the 2013 plan year for a
takeover plan without the need for the
newly hired enrolled actuary to perform the
five percent test using the valuation results
for the 2012 plan year.
Automatic Approval for Takeover Plans
For a plan subject to the requirements
of § 430, automatic approval is granted for
a change in funding method that results
from a change in enrolled actuary if all of
the conditions set forth in paragraphs (1)
through (4) below are satisfied:
(1) There has been both a change in the
enrolled actuary for the plan and a change
in the business organization providing ac-
tuarial services to the plan, and the new
enrolled actuary uses different valuation
software or otherwise applies the funding
method that was used by the prior actuary
to determine the funding target, target nor-
mal cost and actuarial value of assets in a
different manner than the prior enrolled
actuary;
(2) The funding target and target nor-
mal cost for the prior plan year, as calcu-
lated by the new enrolled actuary (using
the actuarial assumptions of the prior en-
rolled actuary and without regard to any
adjustments for employee contributions
and plan-related expenses), are both
within five percent of the values for the
funding target and target normal cost re-
ported in the prior plan year’s Schedule
SB (signed by the prior enrolled actuary
regardless of whether it was filed) or ac-
tuarial report;
(3) The actuarial value of plan assets
for the prior plan year, as calculated by the
new enrolled actuary (using the actuarial
assumptions of the prior enrolled actuary
to the extent applicable), is within five
percent of the value for the actuarial value
of plan assets reported in the prior plan
year’s Schedule SB (signed by the prior
enrolled actuary regardless of whether it
was filed) or actuarial report; and
(4) The funding method used by the
new enrolled actuary to determine the
funding target, target normal cost, and ac-
tuarial value of assets for purposes of the
comparisons described in paragraphs (2)
and (3) must be substantially the same as
the method used by the prior enrolled ac-
tuary to determine those amounts and
must be consistent with the description of
the method contained in the prior plan
year’s Schedule SB (signed by the prior
enrolled actuary regardless of whether it
was filed) or actuarial report.
Alternatively, the comparisons of the
funding target, target normal cost, and ac-
tuarial value of assets described in para-
graphs (2) through (4) can be made on the
basis of the current plan year, provided
that the prior enrolled actuary has issued
an actuarial report that includes those re-
sults (or has provided a signed Schedule
SB to the new enrolled actuary for the
current plan year, if revision of the Sched-
ule SB is permitted).
For purposes of this announcement, an
actuarial report must be signed by the
enrolled actuary for the plan and must
meet the applicable standards of perfor-
mance under regulations issued by the
Joint Board for the Enrollment of Actuar-
ies. See 20 CFR 901.20. Also, current
plan year means the first plan year for
which a Schedule SB is signed by the new
enrolled actuary and prior plan year
means the plan year that immediately pre-
cedes the current plan year.
If the automatic approval granted pur-
suant to this announcement for a change
in the plan’s funding method that results
from a change in the plan’s enrolled actu-
ary applies, the new enrolled actuary is
permitted to use new actuarial assump-
tions and a new funding method for the
current plan year only if those changes are
permitted under the generally applicable
requirements of § 430(h) and § 412(d)(1).
Pursuant to § 1.430(d)–1(f)(1)(ii) of the
Income Tax Regulations, once the Sched-
ule SB has been filed for a plan year, the
assumptions and methods generally can-
not be changed for that plan year. How-
ever, the enrolled actuary can use new
assumptions and methods, to the extent
the change is permitted under guidance
issued by the Commissioner, including
this announcement. For example, see Sec-
tion III.B of Notice 2014 –53, Guidance
on Pension Funding Stabilization under
the Highway and Transportation Funding
Act of 2014 (HATFA).
The following example illustrates the
application of this announcement:
Plan S is a single employer defined
benefit plan subject to § 430 with a plan
year that is the calendar year and a valu-
ation date of January 1. Assume a January
1, 2013 actuarial report is signed by the
plan’s enrolled actuary using the segment
interest rates under MAP-21
1
on Septem-
ber 1, 2013, and the corresponding Sched-
ule SB for the 2013 plan year is filed by
the plan administrator on July 15, 2014.
In January 2014, the plan has a new
enrolled actuary and a new business orga-
nization providing actuarial services for
the plan for the 2014 plan year. The new
enrolled actuary reproduces the prior en-
rolled actuary’s funding target, target nor-
mal cost, and actuarial value of plan assets
for the 2013 actuarial valuation using the
prior enrolled actuary’s methods and as-
sumptions and the results are within five
percent of those values that were com-
puted by the prior actuary. The segment
interest rate rules under HATFA are ap-
plied for the 2013 plan year. Automatic
approval is granted under this announce-
ment for the change in funding method
that occurred in connection with the
change in the enrolled actuary. The new
enrolled actuary prepares a revised 2013
1
The Moving Ahead for Progress in the 21
st
Century Act (MAP-21), Pub. L. No.112-141.
Bulletin No. 2015–3January 20, 2015
329

Schedule SB that reflects the use of the
HATFA segment interest rates, which is
filed with the amended Form 5500.
The new enrolled actuary may not use
new actuarial assumptions or funding
methods for the 2013 plan year actuarial
valuation (other than using the HATFA
segment interest rates and applying the
automatic approval under this announce-
ment) because the Schedule SB had al-
ready been filed for that year. However,
for the 2014 plan year, the new enrolled
actuary may use new actuarial assump-
tions and a new funding method, but only
if the generally applicable requirements of
§ 430(h) and § 412(d)(1) are satisfied.
Effect on other guidance
Announcement 2010-3 is amplified.
Drafting information
The principal authors of this an-
nouncement are Steven H. Klubock and
Carolyn E.Zimmerman of the Employee
Plans, Tax Exempt and Government Enti-
ties Division. For further information re-
garding this announcement, please email
RetirementPlanQuestions@irs.gov.
January 20, 2015Bulletin No. 2015–3
330

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2015–3January 20, 2015
i

Numerical Finding List
1
Bulletin 2015–1 through 2015–3
Announcements:
2015-2, 2015-3 I.R.B.324
2015-3, 2015-3 I.R.B.328
Proposed Regulations:
REG-109187-11, 2015-2 I.R.B.277
REG-132751-14, 2015-2 I.R.B.279
REG-145878-14, 2015-2 I.R.B.290
Notices:
2015-1, 2015-2 I.R.B.249
Revenue Procedures:
2015-1, 2015-1 I.R.B.1
2015-2, 2015-1 I.R.B.105
2015-3, 2015-1 I.R.B.129
2015-4, 2015-1 I.R.B.144
2015-5, 2015-1 I.R.B.186
2015-6, 2015-1 I.R.B.194
2015-7, 2015-1 I.R.B.231
2015-8, 2015-1 I.R.B.235
2015-9, 2015-2 I.R.B.249
2015-10, 2015-2 I.R.B.261
2015-12, 2015-2 I.R.B.265
Revenue Rulings:
2015-2, 2015-3 I.R.B.321
Treasury Decisions:
9707, 2015-2 I.R.B.247
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin
2014 –52, dated December 28, 2014.
January 20, 2015Bulletin No. 2015–3
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–1 through 2015–3
Announcements:
2010-3
Amplified by
Ann. 2015-3, 2015-3 I.R.B.328
Revenue Procedures:
2014-01
Superseded by
Rev. Proc. 2015-01, 2015-01 I.R.B.1
2014-02
Superseded by
Rev. Proc. 2015-02, 2015-01 I.R.B.105
2014-03
Superseded by
Rev. Proc. 2015-03, 2015-01 I.R.B.129
2014-04
Superseded by
Rev. Proc. 2015-04, 2015-01 I.R.B.144
2014-05
Superseded by
Rev. Proc. 2015-05, 2015-01 I.R.B.186
2014-06
Superseded by
Rev. Proc. 2015-06, 2015-01 I.R.B.194
2014-07
Superseded by
Rev. Proc. 2015-07, 2015-01 I.R.B.231
2014-08
Superseded by
Rev. Proc. 2015-08, 2015-01 I.R.B.235
2014-10
Superseded by
Rev. Proc. 2015-10, 2015-2 I.R.B.261
2003-63
Superseded by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
Revenue Rulings:
92-19
Supplemented by
Rev. Rul. 2015-02, 2015-3 I.R.B.321
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014 –27 through 2014 –52 is in Internal Revenue Bulletin 2014 –52, dated December 28,
2014.
Bulletin No. 2015–3January 20, 2015
iii

INTERNAL REVENUE BULLETIN
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