us-irs-revenue-rulings-irb-2013-49-pdf•Internal Revenue Bulletin 2013-49 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2013-49 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2013-49-pdfInternal Revenue Bulletin 2013-49 (PDF rendition): IRS Revenue RulingsGuidance
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HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX Rev. Rul. 2013–24, page 594. The “base period T-bill rate” for the period ending September 30, 2013, is published, as required by section 995(f) of the Code. Rev. Proc. 2013–36, page 602. The loss payment patterns and discount factors are set forth for the 2013 accident year. These factors will be used for computing discounted unpaid losses under § 846 of the Code. Rev. Proc. 2013–37, page 612. The salvage discount factors are set forth for the 2013 acci- dent year. These factors will be used for computing discounted estimated salvage recoverable under § 832 of the Code. EMPLOYEE PLANS REG–120927–13, page 618. These proposed regulations would clarify that amounts paid to an Indian tribe member as remuneration for services per- formed in a fishing rights-related activity may be treated as compensation for purposes of applying the limits on qualified plan benefits and contributions. These regulations would affect sponsors of, and participants in, employee benefit plans of Indian tribal governments. Comments are requested by Febru- ary 13, 2014. Notice 2013–73, page 598. 2014 cost-of-living adjustments; retirements plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2014, applicable to the dollar limitations on benefits and contributions under qualified retirement plans. Other limi- tations applicable to deferred compensation plans are also affected by these adjustments under § 415. Under § 415(d), the adjustments are to be made pursuant to adjustment pro- cedures which are similar to those used to adjust benefit amounts under § 215(i)(2)(A) of the Social Security Act. This notice also contains cost-of-living adjustments for several pension-related amounts in restating the data in IR–2013– 86 issued October 31, 2013. Notice 2013–75, page 599. Weighted average interest rate update; corporate bond indi- ces; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in November 2013; the 24-month average segment rates; the funding segment rates applicable for November 2013; and the minimum present value rates for October 2013. 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). EXEMPT ORGANIZATIONS Announcement 2013– 48, page 620. The IRS has revoked its determination that Corral of Comfort Horse Rescue, Inc. of Palmdale, CA., Positive Energy Founda- tion of Lincoln, CA., Rainy Day Foundation, Inc. of Washington, D.C., Sunrise Residential and Lifeskills Center of Cincinnati, OH., and Thunder Air Museum Inc, of Lancaster, CA., qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code. Announcements of Declaratory Judgement Proceedings Under Section 7428 are on pages 620 and 621. Finding Lists begin on page ii. Bulletin No. 2013– 49 December 2, 2013 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. December 2, 2013Bulletin No. 2013– 49 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 832.—Insurance Company Taxable Income 26 CFR 1.832– 4: Gross Income. The salvage discount factors and payment patterns are set forth for 2013. These factors must be used to compute discounted estimated salvage recoverable for pur- poses of section 832 of the Code. See Rev. Proc. 2013–37, page 612. Section 846.—Discounted Unpaid Losses Defined 26 CFR 1.846 –1: Application of discount fac- tors. The composite loss discount factors for Rein- surance (Nonproportional Assumed Property) pub- lished in Rev. Proc. 2013–36, page 602. 26 CFR 1.846 –1: Application of discount fac- tors. The salvage discount factors and payment pat- terns are set forth for 2013. These factors must be used to compute discounted estimated salvage recov- erable for purposes of section 832 of the Code. See Rev. Proc. 2013–37, page 612. Section 995.—Taxation of DISC Income to Shareholders 2013 Base Period T-Bill Rate. The “base period T-bill rate” for the period ending September 30, 2013, is published as required by section 995(f) of the Code. Rev. Rul. 2013–24 Section 995(f)(1) of the Internal Reve- nue Code provides that a shareholder of a DISC shall pay interest each taxable year in an amount equal to the product of the shareholder’s DISC-related deferred tax liability for the year and the “base period T-bill rate.” Under section 995(f)(4), the base period T-bill rate is the annual rate of interest determined by the Secretary to be equivalent to the average of the 1-year constant maturity Treasury yields, as pub- lished by the Board of Governors of the Federal Reserve System, for the 1-year period ending on September 30 of the calendar year ending with (or of the most recent calendar year ending before) the close of the taxable year of the share- holder. The base period T-bill rate for the period ending September 30, 2013, is 0.140 percent. Pursuant to section 6222 of the Code, interest must be compounded daily. The table below provides factors for com- pounding the base period T-bill rate daily for any number of days in the sharehold- er’s taxable year (including a 52–53 week accounting period) for the 2013 base pe- riod T-bill rate. To compute the amount of the interest charge for the shareholder’s taxable year, multiply the amount of the shareholder’s DISC-related deferred tax liability (as defined in section 995(f)(2)) for that year by the base period T-bill rate factor corresponding to the number of days in the shareholder’s taxable year for which the interest charge is being com- puted. Generally, one would use the factor for 365 days. One would use a different factor only if the shareholder’s taxable year for which the interest charge being determined is a short taxable year, if the shareholder uses the 52–53 week taxable year, or if the shareholder’s taxable year is a leap year. For the base period T-bill rates for the periods ending in prior years, see Rev. Rul. 2012–22, 2012– 48 I.R.B. 565; Rev. Rul. 2011–30, 2011– 49 I.R.B. 826; Rev. Rul. 2010 –28, 2010 – 49 I.R.B. 804; Rev. Rul. 2009 –36, 2009 – 47 I.R.B. 650; and Rev. Rul. 2008 –51, 2008 –2 C.B. 1171. DRAFTING INFORMATION The principal author of this revenue ruling is Teresa Burridge Hughes of the Office of Associate Chief Counsel (Inter- national). For further information regard- ing this revenue ruling, contact Ms. Hughes at (202) 317-6936 (not a toll-free call). ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 1.000003836 2.000007671 3.000011507 4.000015343 5.000019178 6.000023014 7.000026850 8.000030685 9.000034521 10.000038357 11.000042193 12.000046028 13.000049864 14.000053700 15.000057536 16.000061372 17.000065207 18.000069043 19.000072879 20.000076715 21.000080551 22.000084387 23.000088223 24.000092059 25.000095895 26.000099731 27.000103567 28.000107403 29.000111239 30.000115075 31.000118911 32.000122747 33.000126583 34.000130419 35.000134255 December 2, 2013Bulletin No. 2013– 49 594 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 36.000138091 37.000141928 38.000145764 39.000149600 40.000153436 41.000157272 42.000161109 43.000164945 44.000168781 45.000172617 46.000176454 47.000180290 48.000184126 49.000187963 50.000191799 51.000195635 52.000199472 53.000203308 54.000207144 55.000210981 56.000214817 57.000218654 58.000222490 59.000226327 60.000230163 61.000234000 62.000237836 63.000241673 64.000245509 65.000249346 66.000253182 67.000257019 68.000260855 69.000264692 70.000268529 71.000272365 72.000276202 73.000280039 74.000283875 75.000287712 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 76.000291549 77.000295386 78.000299222 79.000303059 80.000306896 81.000310733 82.000314569 83.000318406 84.000322243 85.000326080 86.000329917 87.000333754 88.000337591 89.000341427 90.000345264 91.000349101 92.000352938 93.000356775 94.000360612 95.000364449 96.000368286 97.000372123 98.000375960 99.000379797 100.000383634 101.000387472 102.000391309 103.000395146 104.000398983 105.000402820 106.000406657 107.000410494 108.000414332 109.000418169 110.000422006 111.000425843 112.000429681 113.000433518 114.000437355 115.000441192 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 116.000445030 117.000448867 118.000452704 119.000456542 120.000460379 121.000464216 122.000468054 123.000471891 124.000475729 125.000479566 126.000483404 127.000487241 128.000491079 129.000494916 130.000498754 131.000502591 132.000506429 133.000510266 134.000514104 135.000517941 136.000521779 137.000525617 138.000529454 139.000533292 140.000537129 141.000540967 142.000544805 143.000548643 144.000552480 145.000556318 146.000560156 147.000563994 148.000567831 149.000571669 150.000575507 151.000579345 152.000583183 153.000587020 154.000590858 155.000594696 Bulletin No. 2013– 49December 2, 2013 595 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 156.000598534 157.000602372 158.000606210 159.000610048 160.000613886 161.000617724 162.000621562 163.000625400 164.000629238 165.000633076 166.000636914 167.000640752 168.000644590 169.000648428 170.000652266 171.000656104 172.000659942 173.000663781 174.000667619 175.000671457 176.000675295 177.000679133 178.000682972 179.000686810 180.000690648 181.000694486 182.000698325 183.000702163 184.000706001 185.000709839 186.000713678 187.000717516 188.000721355 189.000725193 190.000729031 191.000732870 192.000736708 193.000740547 194.000744385 195.000748224 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 196.000752062 197.000755901 198.000759739 199.000763578 200.000767416 201.000771255 202.000775093 203.000778932 204.000782770 205.000786609 206.000790448 207.000794286 208.000798125 209.000801964 210.000805802 211.000809641 212.000813480 213.000817319 214.000821157 215.000824996 216.000828835 217.000832674 218.000836512 219.000840351 220.000844190 221.000848029 222.000851868 223.000855707 224.000859546 225.000863385 226.000867223 227.000871062 228.000874901 229.000878740 230.000882579 231.000886418 232.000890257 233.000894096 234.000897935 235.000901774 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 236.000905614 237.000909453 238.000913292 239.000917131 240.000920970 241.000924809 242.000928648 243.000932488 244.000936327 245.000940166 246.000944005 247.000947844 248.000951684 249.000955523 250.000959362 251.000963201 252.000967041 253.000970880 254.000974719 255.000978559 256.000982398 257.000986238 258.000990077 259.000993916 260.000997756 261.001001595 262.001005435 263.001009274 264.001013114 265.001016953 266.001020793 267.001024632 268.001028472 269.001032311 270.001036151 271.001039990 272.001043830 273.001047670 274.001051509 275.001055349 December 2, 2013Bulletin No. 2013– 49 596 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 311.001193586 312.001197426 313.001201267 314.001205107 315.001208947 316.001212787 317.001216628 318.001220468 319.001224308 320.001228148 321.001231989 322.001235829 323.001239669 324.001243510 325.001247350 326.001251191 327.001255031 328.001258871 329.001262712 330.001266552 331.001270393 332.001274233 333.001278074 334.001281914 335.001285755 336.001289595 337.001293436 338.001297277 339.001301117 340.001304958 341.001308798 342.001312639 343.001316480 344.001320320 345.001324161 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 346.001328002 347.001331842 348.001335683 349.001339524 350.001343365 351.001347205 352.001351046 353.001354887 354.001358728 355.001362569 356.001366410 357.001370250 358.001374091 359.001377932 360.001381773 361.001385614 362.001389455 363.001393296 364.001397137 365.001400978 366.001404819 367.001408660 368.001412501 369.001416342 370.001420183 371.001424024 ANNUAL RATE, COMPOUNDED DAILY 0.140 PERCENT DAYSFACTOR 276.001059189 277.001063028 278.001066868 279.001070708 280.001074547 281.001078387 282.001082227 283.001086067 284.001089906 285.001093746 286.001097586 287.001101426 288.001105266 289.001109106 290.001112945 291.001116785 292.001120625 293.001124465 294.001128305 295.001132145 296.001135985 297.001139825 298.001143665 299.001147505 300.001151345 301.001155185 302.001159025 303.001162865 304.001166705 305.001170545 306.001174385 307.001178226 308.001182066 309.001185906 310.001189746 Bulletin No. 2013– 49December 2, 2013 597 Part III. Administrative, Procedural, and Miscellaneous 2014 Limitations Adjusted As Provided in Section 415(d), etc. 1 Notice 2013–73 Section 415 of the Internal Revenue Code (the Code) provides for dollar limita- tions on benefits and contributions under qualified retirement plans. Section 415(d) requires that the Secretary of the Treasury annually adjust these limits for cost-of- living increases. Other limitations applica- ble to deferred compensation plans are also affected by these adjustments under § 415. Under § 415(d), the adjustments are to be made pursuant to adjustment procedures which are similar to those used to adjust benefit amounts under § 215(i)(2)(A) of the Social Security Act. Cost-of-Living Adjusted Limits for 2014 Effective January 1, 2014, the limita- tion on the annual benefit under a defined benefit plan under § 415(b)(1)(A) is in- creased from $205,000 to $210,000. For a participant who separated from service before January 1, 2014, the partic- ipant’s limitation under a defined benefit plan under § 415(b)(1)(B) is computed by multiplying the participant’s compensa- tion limitation, as adjusted through 2013, by 1.0155. The limitation for defined contribution plans under § 415(c)(1)(A) is increased in 2014 from $51,000 to $52,000. The Code provides that various other dollar amounts are to be adjusted at the same time and in the same manner as the dollar limitation of § 415(b)(1)(A). After taking into account the applicable rounding rules, the amounts for 2014 are as follows: The limitation under § 402(g)(1) on the exclusion for elective deferrals described in § 402(g)(3) remains unchanged at $17,500. The annual compensation limit under §§ 401(a)(17), 404(l), 408(k)(3)(C), and 408(k)(6)(D)(ii)isincreasedfrom $255,000 to $260,000. Thedollarlimitationunder § 416(i)(1)(A)(i) concerning the definition of key employee in a top-heavy plan is increased from $165,000 to $170,000. Thedollaramountunder § 409(o)(1)(C)(ii) for determining the max- imum account balance in an employee stock ownership plan subject to a 5-year distribu- tion period is increased from $1,035,000 to $1,050,000, while the dollar amount used to determine the lengthening of the 5-year dis- tribution period is increased from $205,000 to $210,000. The limitation used in the definition of highly compensated employee under § 414(q)(1)(B) remains unchanged at $115,000. Thedollarlimitationunder § 414(v)(2)(B)(i) for catch-up contribu- tions to an applicable employer plan other than a plan described in § 401(k)(11) or 408(p) for individuals aged 50 or over remains unchanged at $5,500. The dollar limitation under § 414(v)(2)(B)(ii) for catch-up contributions to an applicable employer plan described in § 401(k)(11) or 408(p) for individuals aged 50 or over remains unchanged at $2,500. The annual compensation limitation un- der § 401(a)(17) for eligible participants in certain governmental plans that, under the plan as in effect on July 1, 1993, allowed cost-of-living adjustments to the compensa- tion limitation under the plan under § 401(a)(17) to be taken into account, is increased from $380,000 to $385,000. Thecompensationamountunder § 408(k)(2)(C) regarding simplified em- ployee pensions (SEPs) remains un- changed at $550. The limitation under § 408(p)(2)(E) re- garding SIMPLE retirement accounts re- mains unchanged at $12,000. The limitation on deferrals under § 457(e)(15) concerning deferred com- pensation plans of state and local govern- ments and tax-exempt organizations re- mains unchanged at $17,500. The compensation amounts under § 1.61-21(f)(5)(i) of the Income Tax Reg- ulations concerning the definition of “con- trol employee” for fringe benefit valuation purposes is increased from $100,000 to $105,000. The compensation amount un- der § 1.61-21(f)(5)(iii) is increased from $205,000 to $210,000. The Code also provides that several pension-related amounts are to be ad- justed using the cost-of-living adjustment under § 1(f)(3). After taking the applica- ble rounding rules into account, the amounts for 2014 are as follows: The adjusted gross income limitation under § 25B(b)(1)(A) for determining the retirement savings contribution credit for taxpayers filing a joint return is increased from $35,500 to $36,000; the limitation under § 25B(b)(1)(B) is increased from $38,500 to $39,000; and the limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $59,000 to $60,000. The adjusted gross income limitation un- der § 25B(b)(1)(A) for determining the re- tirement savings contribution credit for tax- payers filing as head of household is increased from $26,625 to $27,000; the lim- itation under § 25B(b)(1)(B) is increased from $28,875 to $29,250; and the limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $44,250 to $45,000. The adjusted gross income limitation under § 25B(b)(1)(A) for determining the retirement savings contribution credit for all other taxpayers is increased from $17,750 to $18,000; the limitation under § 25B(b)(1)(B) is increased from $19,250 to $19,500; and the limitation under §§ 25B(b)(1)(C) and 25B(b)(1)(D) is in- creased from $29,500 to $30,000. Thedeductibleamountunder § 219(b)(5)(A) for an individual making qualified retirement contributions remains unchanged at $5,500. The applicable dollar amount under § 219(g)(3)(B)(i) for determining the de- ductible amount of an IRA contribution for taxpayers who are active participants filing a joint return or as a qualifying widow(er) is increased from $95,000 to $96,000. The ap- plicabledollaramountunder § 219(g)(3)(B)(ii) for all other taxpayers (other than married taxpayers filing separate returns) is increased from $59,000 to $60,000. The applicable dollar amount un- der § 219(g)(3)(B)(iii) for a married individ- ual filing a separate return is not subject to the annual cost-of-living adjustment and re- 1 Based on News Release IR-2013-86 dated October 31, 2013 December 2, 2013Bulletin No. 2013– 49 598 mains $0. The applicable dollar amount un- der § 219(g)(7)(A) for a taxpayer who is not an active participant but whose spouse is an activeparticipantisincreasedfrom $178,000 to $181,000. The adjusted gross income limitation under § 408A(c)(3)(B)(ii)(I) for determin- ing the maximum Roth IRA contribution for married taxpayers filing a joint return or for taxpayers filing as a qualifying wid- ow(er) is increased from $178,000 to $181,000. The adjusted gross income lim- itation under § 408A(c)(3)(B)(ii)(II) for all other taxpayers (other than married taxpayers filing separate returns) is in- creased from $112,000 to $114,000. The applicabledollaramountunder § 408A(c)(3)(B)(ii)(III) for a married in- dividual filing a separate return is not sub- ject to an annual cost-of-living adjustment and remains $0. Thedollaramountunder § 430(c)(7)(D)(i)(II) used to determine excess employee compensation with re- spect to a single-employer defined benefit pension plan for which the special elec- tion under § 430(c)(2)(D) has been made isincreasedfrom$1,066,000to $1,084,000. Drafting Information The principal author of this notice is John Heil of the Employee Plans, Tax Exempt and Government Entities Divi- sion. For further information regarding the data in this notice, please contact the Em- ployee Plans’ taxpayer assistance tele- phone service at 1-877-829-5500 (a toll- free call) between the hours of 8:30 a.m. and 4:30 p.m. Eastern time Monday through Friday. For information regarding the methodology used in arriving at the data in this notice, please e-mail Mr. Heil atRetirementPlanQuestions@irs.gov. Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates Notice 2013–75 This notice provides guidance on the cor- porate 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 guidance as to the interest rate on 30-year Treasury se- curities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008, the 30-year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I), and the mini- mum 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 appli- cable maximum percentage or the applica- ble minimum percentage based on the aver- age of segment rates over a 25 year period. YIELD CURVE AND SEGMENT RATES Generally, except for certain plans under sections 104 and 105 of the Pension Protec- tion Act of 2006, § 430 of the Code specifies the minimum funding requirements that ap- ply to single employer plans pursuant to § 412. Section 430(h)(2) specifies the inter- est rates that must be used to determine a plan’s target normal cost and funding target. Under this provision, present value is gen- erally determined using three 24-month av- erage interest rates (“segment rates”), each of which applies to cash flows during spec- ified periods. To the extent provided under § 430(h)(2)(C)(iv), these segment rates are adjusted by the applicable percentage of the 25-year average segment rates for the period ending September 30 of the year preceding the calendar year in which the plan year begins. However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly yield curve in place of the segment 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 segment rates used to compute the target normal cost and the funding target. Pursuant to Notice 2007– 81, the monthly corporate bond yield curve derived from October 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of October 2013 are, respectively, 1.24, 4.47, and 5.52. For plan years begin- ning on or after January 1, 2012, the 24- month average segment rates determined under § 430(h)(2)(C)(iv) must be adjusted by the applicable percentage of the corre- sponding 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 aver- age corporate bond segment rates applicable for November 2013 without adjustment, and the adjusted 24-month average segment rates taking into account the applicable per- centages of the corresponding 25-year aver- age segment rates, are as follows: Bulletin No. 2013– 49December 2, 2013 599 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 October 2013 is 3.68 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 August 2043. The following rates were determined for plan years be- ginning in the month shown below. 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 October 2013 are as follows: 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. For Plan Years Beginning in 30-Year Treasury Weighted Average Permissible Range MonthYear90%to105% November20133.453.103.62 First Segment Second Segment Third Segment 1.244.475.52 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 2012November20131.314.055.055.546.857.52 2013November20131.314.055.054.946.156.76 2014November20131.314.055.054.435.626.22 December 2, 2013Bulletin No. 2013– 49 600 Table I Monthly Yield Curve for October 2013 Derived from October 2013 Data MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield 0.50.3320.55.2940.55.5560.55.6580.55.70 1.00.4921.05.3041.05.5561.05.6581.05.70 1.50.6721.55.3141.55.5661.55.6581.55.70 2.00.8622.05.3242.05.5662.05.6582.05.70 2.51.0822.55.3342.55.5762.55.6682.55.70 3.01.3123.05.3443.05.5763.05.6683.05.70 3.51.5523.55.3543.55.5763.55.6683.55.70 4.01.8024.05.3644.05.5764.05.6684.05.70 4.52.0424.55.3744.55.5864.55.6684.55.71 5.02.2825.05.3745.05.5865.05.6685.05.71 5.52.5225.55.3845.55.5865.55.6685.55.71 6.02.7526.05.3946.05.5966.05.6786.05.71 6.52.9826.55.4046.55.5966.55.6786.55.71 7.03.1927.05.4147.05.5967.05.6787.05.71 7.53.4027.55.4147.55.5967.55.6787.55.71 8.03.5928.05.4248.05.6068.05.6788.05.71 8.53.7728.55.4348.55.6068.55.6788.55.71 9.03.9329.05.4349.05.6069.05.6789.05.71 9.54.0929.55.4449.55.6069.55.6789.55.71 10.04.2330.05.4550.05.6170.05.6890.05.71 10.54.3630.55.4550.55.6170.55.6890.55.71 11.04.4731.05.4651.05.6171.05.6891.05.72 11.54.5831.55.4751.55.6171.55.6891.55.72 12.04.6732.05.4752.05.6272.05.6892.05.72 12.54.7632.55.4852.55.6272.55.6892.55.72 13.04.8333.05.4853.05.6273.05.6893.05.72 13.54.9033.55.4953.55.6273.55.6893.55.72 14.04.9634.05.4954.05.6374.05.6994.05.72 14.55.0134.55.5054.55.6374.55.6994.55.72 15.05.0535.05.5055.05.6375.05.6995.05.72 15.55.0935.55.5155.55.6375.55.6995.55.72 16.05.1236.05.5156.05.6376.05.6996.05.72 16.55.1536.55.5256.55.6376.55.6996.55.72 17.05.1837.05.5257.05.6477.05.6997.05.72 17.55.2037.55.5357.55.6477.55.6997.55.72 18.05.2238.05.5358.05.6478.05.6998.05.72 18.55.2438.55.5458.55.6478.55.6998.55.73 19.05.2539.05.5459.05.6479.05.7099.05.73 19.55.2739.55.5459.55.6579.55.7099.55.73 20.05.2840.05.5560.05.6580.05.70100.05.73 Bulletin No. 2013– 49December 2, 2013 601 26 CFR 601.201: Rulings and determination letters. (Also: Part I, Sections 846; 1.846-1.) Rev. Proc. 2013–36 SECTION 1. PURPOSE This revenue procedure prescribes the loss payment patterns and discount factors for the 2013 accident year. These factors will be used to compute discounted un- paid losses under § 846 of the Internal Revenue Code.SeeRev. Proc. 2012– 44, 2012– 49 I.R.B. 645, for background con- cerning the loss payment patterns and ap- plication of the discount factors. SECTION 2. SCOPE This revenue procedure applies to any taxpayer that is required to discount un- paid losses under § 846 for a line of busi- ness using the discount factors published by the Secretary. SECTION 3. TABLES OF DISCOUNT FACTORS .01 The following tables present sepa- rately for each line of business the dis- count factors under § 846 for accident year 2013. All the discount factors pre- sented in this section were determined us- ing the applicable interest rate under § 846(c) for 2013, which is 2.16 percent, and by assuming all loss payments occur in the middle of the calendar year. .02 If the groupings of individual lines of business on the annual statement change, taxpayers must discount unpaid losses on the resulting line of business in accordance with the discounting patterns that would have applied to those unpaid losses based on their classification on the 2010 annual state- ment.SeeRev. Proc. 2012– 44, 2012– 49 I.R.B. 645, section 2, for additional back- ground on discounting under § 846 and the use of the Secretary’s tables. .03 Section V of Notice 88 –100, 1988 –2 C.B. 439, sets forth a composite method for computing discounted unpaid losses for ac- cident years that are not separately reported on the annual statement. The tables sepa- rately provide discount factors for taxpayers who elect to use the composite method of section V of Notice 88 –100.SeeRev. Proc. 2002–74, 2002–2 C.B. 980. .04 Tables. Accident and Health (Other Than Disability Income or Credit Disability Insurance) Taxpayers that do not use the composite method of Notice 88 –100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the 2013 and later taxable years. Taxpayers that use the composite method of Notice 88 –100 should use 98.9372 percent to discount all unpaid losses in this line of business that are out- standing at the end of the 2013 taxable year. Auto Physical Damage Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201390.265790.26579.73439.623098.8565 201499.74789.48220.25220.246997.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years0.12610.12610.124798.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. December 2, 2013Bulletin No. 2013– 49 602 Commercial Auto/Truck Liability/Medical Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201325.703425.703474.296670.938295.4798 201448.266422.562951.733649.665296.0017 201567.883419.617132.116630.910196.2436 201682.063014.179517.937017.245996.1471 201790.41618.35329.58399.175695.7395 201894.62934.21325.37075.115395.2448 201997.02032.39102.97972.809294.2754 202098.22831.20811.77171.648893.0643 202198.66530.43701.33471.242893.1103 202298.86350.19821.13651.069294.0830 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.19820.93820.892095.0674 20240.19820.74000.710896.0618 20250.19820.54170.525897.0618 20260.19820.34350.336898.0526 2027 and later years0.19820.14530.143798.9372 Taxpayers that use the composite method of Notice 88–100 should use 95.2133 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Composite Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201339.528139.528160.471956.879794.0596 201462.026722.498637.973335.368093.1390 201573.701711.675026.298324.331592.5211 201680.08466.383019.915418.405592.4188 201785.78185.697114.218213.044891.7468 201890.28094.49929.71918.779190.3280 201991.95881.67788.04127.272890.4439 202092.97221.01347.02786.405691.1463 202194.08351.11135.91655.420791.6201 202294.74690.66345.25314.867392.6551 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.66344.58984.302093.7289 20240.66343.92643.724494.8545 20250.66343.26313.134496.0555 20260.66342.59972.531697.3791 2027 and later years0.66341.93641.915898.9372 Taxpayers that use the composite method of Notice 88–100 should use 94.0296 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Bulletin No. 2013– 49December 2, 2013 603 Fidelity/Surety Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201322.844922.844977.155174.959897.1547 201455.858533.013744.141543.210797.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years22.070722.070721.836298.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. Financial Guaranty/Mortgage Guaranty Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20136.25156.251593.748590.976797.0433 201443.015436.763956.984655.782997.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years28.492328.492328.189598.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. International (Composite) Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201339.528139.528160.471956.879794.0596 201462.026722.498637.973335.368093.1390 201573.701711.675026.298324.331592.5211 201680.08466.383019.915418.405592.4188 201785.78185.697114.218213.044891.7468 201890.28094.49929.71918.779190.3280 201991.95881.67788.04127.272890.4439 202092.97221.01347.02786.405691.1463 202194.08351.11135.91655.420791.6201 202294.74690.66345.25314.867392.6551 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.66344.58984.302093.7289 20240.66343.92643.724494.8545 20250.66343.26313.134496.0555 20260.66342.59972.531697.3791 2027 and later years0.66341.93641.915898.9372 Taxpayers that use the composite method of Notice 88–100 should use 94.0296 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. December 2, 2013Bulletin No. 2013– 49 604 Medical Professional Liability — Claims-Made Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20136.34626.346293.653887.528793.4599 201423.095816.749676.904272.489894.2599 201541.682718.586858.317355.269194.7729 201656.526714.844043.473341.459495.3674 201771.288214.761528.711827.434895.5524 201882.302311.014117.697716.895095.4643 201986.51434.212013.485713.002796.4182 202091.14224.62798.85788.605997.1564 202194.86643.72425.13365.027697.9351 202297.54082.67452.45922.433098.9372 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2023 and later years2.4592 –– 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Medical Professional Liability — Occurrence Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20131.20441.204498.795689.125790.2122 20144.33763.133295.662487.883991.8688 201511.81617.478588.183982.223493.2408 201624.708812.892875.291270.968194.2583 201742.386317.677457.613754.633794.8276 201857.160014.773842.840040.881395.4281 201968.979711.819631.020329.817896.1234 202082.424713.445017.575316.872496.0006 202186.70844.283713.291612.907197.1073 202291.67014.96178.32998.170998.0913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2023 and later years4.96173.36833.332598.9372 Taxpayers that use the composite method of Notice 88–100 should use 95.3404 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Bulletin No. 2013– 49December 2, 2013 605 Miscellaneous Casualty Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201369.073169.073130.926930.146997.4781 201485.516916.443814.483114.177797.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years 7.24157.24157.164698.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201360.971960.971939.028137.493996.0690 201482.905921.934117.094116.134194.3843 201589.27836.372410.721710.041793.6585 201691.56052.28228.43957.951994.2233 201794.42552.86495.57455.228093.7836 201896.58992.16443.41013.153292.4675 201997.60231.01242.39772.198091.6740 202098.00340.40111.99661.840292.1637 202198.34100.33761.65901.538792.7462 202298.57270.23171.42731.337893.7231 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.23171.19571.132594.7155 20240.23170.96400.922895.7250 20250.23170.73240.708696.7547 20260.23170.50070.489897.8131 2027 and later years0.23170.26910.266298.9372 Taxpayers that use the composite method of Notice 88–100 should use 94.5541 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Other (Including Credit) Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201354.658954.658945.341144.367997.8536 201484.231429.572515.768615.436097.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years7.88437.88437.800598.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. December 2, 2013Bulletin No. 2013– 49 606 Other Liability — Claims-Made Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20137.42707.427092.573086.123893.0334 201425.280817.853874.719269.938593.6018 201544.210818.930155.789252.315893.7741 201656.495612.284843.504441.029194.3102 201769.283812.788330.716228.989794.3793 201877.66628.382322.333821.143594.6702 201983.15725.491016.842816.050295.2940 202088.17775.020511.822311.322595.7717 202193.13154.95396.86856.559995.5080 202292.9490-0.18267.05106.886297.6617 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20233.26393.78713.735998.6482 2024 and later years3.26390.52320.517698.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.6406 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Other Liability — Occurrence Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201310.072110.072189.927982.010091.1953 201424.399514.327475.600569.300191.6662 201537.336612.937262.663457.720892.1126 201652.414215.077647.585843.728091.8931 201764.343711.929535.656332.614991.4704 201873.79509.451226.205023.766790.6950 201979.77565.980720.224418.235190.1640 202084.09634.320615.903714.261989.6766 202185.68781.591514.312212.961490.5616 202286.92241.234613.077611.993591.7100 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20231.234611.843111.004792.9213 20241.234610.60859.994694.2131 20251.23469.37408.962795.6125 20261.23468.13947.908597.1626 2027 and later years1.23466.90486.831498.9372 Taxpayers that use the composite method of Notice 88–100 should use 92.9062 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Bulletin No. 2013– 49December 2, 2013 607 Private Passenger Auto Liability/Medical Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201342.988142.988157.011955.188396.8013 201471.993129.005128.006927.063796.6325 201584.825012.831815.175014.678696.7288 201692.35007.52517.65007.389896.5989 201796.26653.91653.73353.590896.1796 201897.98801.72142.01201.928495.8467 201998.79580.80781.20421.153695.7990 202099.24450.44870.75550.725095.9639 202199.45430.20970.54570.528796.8694 202299.63700.18270.36300.355497.8984 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2023 and later years0.18270.18030.178398.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Products Liability — Claims-Made Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20134.52704.527095.473086.495090.5963 201416.013411.486583.986676.753491.3877 201545.131329.117954.868748.980789.2688 201639.2459-5.885460.754155.987392.1539 201744.83575.589855.164351.546793.4422 201872.161527.325827.838525.040889.9502 201980.44488.283419.555217.209488.0042 202073.2957-7.149126.704324.807092.8952 202187.482414.186612.517611.003887.9062 202287.75000.267712.250010.970989.5588 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.267711.982310.937491.2792 20240.267711.714710.903193.0721 20250.267711.447010.868094.9424 20260.267711.179310.832396.8954 2027 and later years0.267710.911710.795798.9372 Taxpayers that use the composite method of Notice 88–100 should use 93.5799 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. December 2, 2013Bulletin No. 2013– 49 608 Products Liability – Occurrence Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20137.19367.193692.806483.683990.1704 201416.95559.761983.044575.624791.0653 201528.362411.406971.637665.728891.7518 201639.794511.432160.205555.593692.3397 201754.390614.596145.609442.041592.1773 201860.90606.515439.094036.364293.0174 201967.77606.870032.224030.205993.7373 202075.71197.935924.288122.837294.0263 202179.59663.884720.403419.404095.1021 202283.94304.346416.057015.430196.0957 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20234.346411.710711.370397.0940 20244.34647.36437.222998.0799 2025 and later years4.34643.01792.985998.9372 Taxpayers that use the composite method of Notice 88–100 should use 97.2932 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Reinsurance — Nonproportional Assumed Property Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201320.100320.100379.899776.508195.7551 201459.283339.183040.716738.556794.6950 201573.086713.803426.913325.437894.5177 201680.36757.280819.632518.628294.8848 201787.72787.360312.272211.591294.4514 201894.44546.71755.55465.051990.9495 201996.51432.06893.48573.069988.0707 202097.94681.43262.05321.688382.2272 202197.4560-0.49092.54402.220987.2972 202297.0652-0.39082.93482.663890.7662 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20230.18362.75122.535892.1696 20240.18362.56752.404993.6659 20250.18362.38392.271395.2743 20260.18362.20032.134797.0199 2027 and later years0.18362.01661.995298.9372 Taxpayers that use the composite method of Notice 88–100 should use 91.9206 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Bulletin No. 2013– 49December 2, 2013 609 Reinsurance — Nonproportional Assumed Liability Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20133.49873.498796.501387.141890.3012 201423.217019.718376.783069.094089.9860 201543.748320.531356.251749.834688.5920 201638.9131-4.835261.086955.798191.3422 201747.92989.016752.070247.889891.9715 201880.031532.101719.968516.477782.5182 201976.5053-3.529223.494720.397786.8180 202078.17011.664921.829919.155587.7491 202180.07171.901519.928317.647388.5539 202279.8791-0.192620.120918.223190.5681 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20231.124618.996317.480192.0183 20241.124617.871716.721093.5611 20251.124616.747115.945595.2132 20261.124615.622515.153296.9959 2027 and later years1.124614.497914.343898.9372 Taxpayers that use the composite method of Notice 88–100 should use 91.9297 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Reinsurance — Nonproportional Assumed Financial Lines Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 20131.54231.542398.457791.079692.5063 201420.927319.385079.072773.453792.8939 201530.47059.543369.529565.394594.0530 201646.304315.833753.695750.803294.6132 201751.84645.542148.153646.298996.1484 201872.786920.940527.213126.133596.0328 201982.09679.309717.903317.288296.5643 202089.26307.166410.737010.418397.0321 202195.36926.10624.63084.471696.5616 202296.79951.43033.20053.122597.5627 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20231.43031.77021.744398.5356 2024 and later years1.43030.33990.336398.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.5436 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. December 2, 2013Bulletin No. 2013– 49 610 Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary and Theft) Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201355.614555.614544.385543.581498.1884 201489.332833.718210.667210.442397.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years5.33365.33365.276998.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. Warranty Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201385.410185.410114.589914.420498.8387 201499.538814.12870.46120.451597.8913 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 2015 and later years0.23060.23060.228198.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2015 taxable year. Workers’ Compensation Estimated Cumulative Losses Paid Estimated Losses Paid Each Year Unpaid Losses at Year End Discounted Unpaid Losses at Year End Discount Factors Tax Year(%)(%)(%)(%)(%) 201321.897321.897378.102770.559090.3413 201443.496221.598956.503850.252188.9359 201556.006112.509943.993938.693387.9515 201663.55447.548236.445631.899787.5269 201768.98805.433731.012027.096787.3751 201873.95674.968726.043322.659987.0089 201976.05802.101323.942021.025587.8187 202077.63651.578522.363519.884388.9139 202180.11942.482819.880617.804289.5556 202281.34561.226218.654416.949490.8600 Taxpayers that do not use the composite method of Notice 88–100 should use the following factors to discount unpaid losses incurred in this line of business in the 2013 accident year and that are outstanding at the end of the tax year shown. 20231.226217.428116.076192.2420 20241.226216.201915.183993.7167 20251.226214.975714.272495.3043 20261.226213.749413.341397.0319 2027 and later years1.226212.523212.390198.9372 Taxpayers that use the composite method of Notice 88–100 should use 93.4456 percent to discount unpaid losses incurred in this line of business in 2013 and prior years and that are outstanding at the end of the 2023 taxable year. Bulletin No. 2013– 49December 2, 2013 611 SECTION 4. DRAFTING INFORMATION The principal author of this revenue procedure is David Remus of the Office of Associate Chief Counsel (Financial Insti- tutions & Products). For further informa- tion regarding this revenue procedure con- tact Mr. Remus on (202) 622-3970 (not a toll-free call). 26 CFR 601.201: Rulings and determination letters. (Also: Part I, Section 832, 846; 1.832-4, 1.846-1.) Rev. Proc. 2013–37 SECTION 1. PURPOSE This revenue procedure prescribes the salvage discount factors for the 2013 ac- cident year. These factors must be used to compute discounted estimated salvage re- coverable under § 832 of the Internal Rev- enue Code. SECTION 2. BACKGROUND Section 832(b)(5)(A) requires that all es- timated salvage recoverable (including that which cannot be treated as an asset for state accounting purposes) be taken into account in computing the deduction for losses in- curred. Under § 832(b)(5)(A), paid losses are reduced by salvage and reinsurance re- covered during the taxable year. This amount is adjusted to reflect changes in dis- counted unpaid losses on nonlife insurance contracts and in unpaid losses on life insur- ance contracts. An adjustment is then made to reflect any changes in discounted esti- mated salvage recoverable and in reinsur- ance recoverable. Pursuant to § 832(b), the amount of estimated salvage is determined on a dis- counted basis in accordance with proce- dures established by the Secretary. SECTION 3. SCOPE This revenue procedure applies to any taxpayer that is required to discount esti- mated salvage recoverable under § 832. SECTION 4. TABLES OF DISCOUNT FACTORS .01 The following tables present sepa- rately for each line of business the dis- count factors under § 832 for the 2013 accident year. All the discount factors pre- sented in this section were determined us- ing the applicable interest rate under § 846(c) for 2013, which is 2.16 percent, and by assuming all estimated salvage is recovered in the middle of the calendar year. .02 These tables must be used by tax- payers irrespective of whether they elected to discount unpaid losses using their own experience under § 846(e). .03 Section V of Notice 88 –100, 1988 –2 C.B. 439, provides a composite discount factor to be used in determining the discounted unpaid losses for accident years that are not separately reported on the annual statement approved by the Na- tional Association of Insurance Commis- sioners. The tables separately provide dis- count factors for taxpayers who elect to use the composite method. Rev. Proc. 2002–74, 2002–2 C.B. 980, clarifies that for certain insurance companies subject to tax under § 831 the composite method for discounting unpaid losses set forth in No- tice 88 –100, section V, is permitted but not required. Rev. Proc. 2002–74 further provides alternative methods for comput- ing discounted unpaid losses that are per- mitted for insurance companies not using the composite method, and sets forth a procedure for insurance companies to ob- tain automatic consent of the Commis- sioner to change to one of the methods described therein. .04 Tables. Accident and Health (Other Than Disability Income or Credit Disability Insurance) Taxpayers that do not use the compos- ite method of Notice 88 –100 should use 98.9372 percent to discount salvage re- coverable with respect to losses incurred in this line of business in the 2013 acci- dent year as of the end of the 2013 and later taxable years. Taxpayers that use the composite method of Notice 88 –100 should use 98.9372 percent to discount all salvage recoverable in this line of business as of the end of the 2013 taxable year. Auto Physical Damage Tax Year Discount Factors (%) 201398.4882 201497.8913 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2015 and later years98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2015 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Commercial Auto/Truck Liability/Medical Tax Year Discount Factors (%) 201396.0918 201495.6766 201596.0149 201695.5121 201795.9064 201895.6648 201992.3932 202091.0203 202193.1830 202294.1559 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 202395.1400 202496.1331 202597.1298 202698.1108 2027 and later years 98.9372 December 2, 2013Bulletin No. 2013– 49 612 Commercial Auto/Truck Liability/Medical Taxpayers that use the composite method of Notice 88–100 should use 95.0296 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Composite Tax Year Discount Factors (%) 201395.8312 201495.6601 201595.8323 201694.6468 201795.0231 201894.6757 201994.5640 202095.0764 202195.0903 202296.0842 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 202397.0831 202498.0706 2025 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 97.2205 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Fidelity/Surety Tax Year Discount Factors (%) 201396.6294 201497.8913 Fidelity/Surety Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2015 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Financial Guaranty/Mortgage Guaranty Tax Year Discount Factors (%) 201396.2442 201497.8913 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2015 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. International (Composite) Tax Year Discount Factors (%) 201395.8312 201495.6601 201595.8323 201694.6468 International (Composite) 201795.0231 201894.6757 201994.5640 202095.0764 202195.0903 202296.0842 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 202397.0831 202498.0706 2025 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 97.2205 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Medical Professional Liability — Claims-Made Tax Year Discount Factors (%) 201395.2786 201495.9565 201594.0862 201696.2641 201796.4417 201896.8118 201997.5213 202098.0020 202197.9851 202298.9372 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Bulletin No. 2013– 49December 2, 2013 613 Medical Professional Liability — Claims-Made Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Medical Professional Liability — Occurrence Tax Year Discount Factors (%) 201395.7712 201497.3870 201596.9618 201697.9399 201797.1545 201898.2412 201997.7408 202097.8032 202196.3820 202297.3760 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 202398.3399 2024 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.3944 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Miscellaneous Casualty Tax Year Discount Factors (%) 201397.1217 201497.8913 Miscellaneous Casualty Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2015 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Multiple Peril Lines (Homeown- ers/Farmowners, Commercial Multiple Peril, and Special Liabil- ity (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) Tax Year Discount Factors (%) 201396.3826 201496.3451 201596.7517 201695.2517 201796.4850 201896.8610 201996.9777 202096.8985 202196.6327 202298.9372 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Other (Including Credit) Tax Year Discount Factors (%) 201397.6897 201497.8913 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2015 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Other Liability — Claims-Made Tax Year Discount Factors (%) 201395.1076 201495.4013 201595.4350 201696.3406 201796.3743 201896.5027 201997.3792 202097.3555 202197.5726 202298.5464 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. December 2, 2013Bulletin No. 2013– 49 614 Other Liability — Occurrence Tax Year Discount Factors (%) 201392.6226 201493.5130 201594.4491 201694.9634 201795.5708 201896.4140 201996.5549 202096.4769 202197.9444 202298.9372 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Private Passenger Auto Liability/Medical Tax Year Discount Factors (%) 201397.0706 201496.9687 201596.9501 201696.4757 201796.4634 201896.5763 201996.3892 202096.6383 202197.6225 202298.6028 Private Passenger Auto Liability/Medical Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Products Liability — Claims-Made Tax Year Discount Factors (%) 201392.2286 201493.4576 201592.0267 201696.2215 201794.6124 201898.6304 201997.2433 202088.9465 202198.6843 202298.9372 Taxpayers that do not use the composite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.3136 percent to discount salvage re- coverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Products Liability – Occurrence Tax Year Discount Factors (%) 201392.9273 201492.9980 201593.6660 201694.6880 201795.1420 201895.8302 201995.7694 202097.5022 202197.0413 202298.0355 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2023 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Reinsurance — Nonproportional Assumed Property Tax Year Discount Factors (%) 201394.5748 201496.3787 201594.7317 201693.7440 201795.4876 201894.6692 201997.6860 202092.4794 202196.9357 202297.9499 Bulletin No. 2013– 49December 2, 2013 615 Reinsurance — Nonproportional Assumed Property Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 96.4869 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Reinsurance — Nonproportional Assumed Liability Tax Year Discount Factors (%) 201390.3595 201492.1774 201587.9515 201688.9859 201793.5912 201895.9635 201995.3061 202095.7404 202194.3801 202297.4575 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 202398.4227 2024 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.4548 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Reinsurance — Nonproportional Assumed Financial Lines Tax Year Discount Factors (%) 201391.0140 201492.3376 201595.1527 201695.2554 201796.3242 201894.8469 201996.3368 202096.2848 202198.7677 202298.9372 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2023 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. Special Property (Fire, Allied Lines, Inland Marine, Earth- quake, Burglary and Theft) Tax Year Discount Factors (%) 201397.2489 201497.8913 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to dis- count salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Special Property (Fire, Allied Lines, Inland Marine, Earth- quake, Burglary and Theft) Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2015 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Warranty Tax Year Discount Factors (%) 201396.8834 201497.8913 Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2013 accident year. 2015 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 98.9372 percent to discount sal- vage recoverable as of the end of the 2015 taxable year with respect to losses incurred in this line of busi- ness in 2013 and prior years. Workers’ Compensation Tax Year Discount Factors (%) 201393.4664 201494.6736 201595.3195 201694.1675 201793.6989 201893.1688 201993.6398 202094.7487 202194.9592 202295.9566 December 2, 2013Bulletin No. 2013– 49 616 Workers’ Compensation Taxpayers that do not use the com- posite method of Notice 88–100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with re- spect to losses incurred in this line of business in the 2013 accident year. 202396.9634 202497.9719 2025 and later years 98.9372 Taxpayers that use the composite method of Notice 88–100 should use 97.2990 percent to discount salvage recoverable as of the end of the 2023 taxable year with respect to losses in- curred in this line of business in 2013 and prior years. SECTION 5. DRAFTING INFORMATION The principal author of this revenue procedure is David Remus of the Office of Associate Chief Counsel (Financial Insti- tutions & Products). For further informa- tion regarding this revenue procedure con- tact Mr. Remus on (202) 622-3970 (not a toll-free call). Bulletin No. 2013– 49December 2, 2013 617 Part IV. Items of General Interest Notice of Proposed Rulemaking Treatment of Income from Indian Fishing Rights- Related Activity as Compensation REG–120927–13 AGENCY:Internal Revenue Service (IRS), Treasury. ACTION:Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations that would clarify that amounts paid to an Indian tribe mem- ber as remuneration for services per- formed in a fishing rights-related activity may be treated as compensation for pur- poses of applying the limits on qualified plan benefits and contributions. These reg- ulations would affect sponsors of, and par- ticipants in, employee benefit plans of In- dian tribal governments. DATES: Comments and requests for a public hearing must be received by Feb- ruary 13, 2014. ADDRESSES:Send submissions to CC: PA:LPD:PR(REG–120927–13),room 5205, Internal Revenue Service, PO Box 7604, Ben Franklin Station, Washington D.C. 20044. Submissions may be hand- delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA: LPD:PR(REG–120927–13),Courier’s Desk, Internal Revenue Service, 1111 Con- stitution Avenue, N.W., Washington, DC, 20224, or sent electronically via the Federal eRulemaking Portal atwww.regulations.gov (IRS REG–120927–13). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Sarah Bolen or Pamela Ki- nard at (202) 622-6060 or (202) 317- 6700; concerning the submission of com- ments or to request a public hearing, Oluwafunmilayo Taylor, (202) 622-7180 or (202) 317-6901 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background Indian tribal governments (ITGs) and individual tribe members conduct fishing activities to generate revenue, protect crit- ical habitats, and preserve tribal customs and traditions. Various treaties, federal statutes, and Presidential executive orders reserve to Indian tribe members the right to fish for subsistence and commercial purposes both on and off reservations. Be- cause many of the treaties, statutes, and executive orders were adopted before pas- sage of the Federal income tax, they often do not expressly address the question of whether income derived by Indians and ITGs from protected fishing activities is exempt from taxation.SeeH.R. Rep. 100 –1104, at p. 77 (1988). Congress added section 7873 to the Internal Revenue Code as part of the Technical and Miscellaneous Revenue Act of 1988 (Public Law 100-647). Sec- tion 7873(a)(1) provides that no income tax shall be imposed on income derived from a fishing rights-related activity of an Indian tribe by (A) a member of the tribe directly or through a qualified Indian en- tity, or (B) a qualified Indian entity. Sec- tion 7873(a)(2) provides that no employ- menttaxshallbeimposedon remuneration paid for services performed in a fishing rights-related activity of an Indian tribe by a member of such tribe for another member of such tribe or for a qualified Indian entity. Thus, section 7873(a) exempts income derived from a fishing rights-related activity (“fishing rights-related income”) from both income and employment taxes. Section 7873(b)(1) defines fishing rights-related activity with respect to an Indian tribe as any activity directly related to harvesting, processing, or transporting fish harvested in the exercise of a recog- nized fishing right of the tribe or to selling such fish but only if substantially all of such harvesting was performed by mem- bers of such tribe. Section 415(a)(1) provides that a trust that is part of a pension, profit-sharing, or stock bonus plan shall not constitute a qualified trust under section 401(a) if (A) in the case of a defined benefit plan, the plan provides for the payment of benefits with respect to a participant which exceed the limitation of section 415(b), or (B) in the case of a defined contribution plan, contributions and other additions under the plan with respect to any participant for any taxable year exceed the limitation of section 415(c). Section 415(b)(1) provides that bene- fits with respect to a participant exceed the annual limitation for defined benefit plans if, when expressed as an annual benefit (within the meaning of section 415(b)(2)), the participant’s annual benefit is greater than the lesser of $160,000 (as adjusted in accordance with section 415(d)(1)) or 100 percent of the participant’s average com- pensation for the participant’s high 3 years. Section 415(b)(3) provides that, for purposes of section 415(b)(1), a partici- pant’s high 3 years will be the period of consecutive calendar years (not more than 3) during which the participant had the greatest aggregate compensation from the employer. In the case of an employee within the meaning of section 401(c)(1) (that is, a self-employed individual treated as an employee), the preceding sentence is applied by substituting for “compensation from the employer” the following: “the participant’s earned income (within the meaning of section 401(c)(2) but deter- mined without regard to any exclusion under section 911).” Section 415(c)(1) provides that contri- butions and other additions with respect to a participant exceed the annual limitation for defined contribution plans if, when expressed as an annual addition (within the meaning of section 415(c)(2)) to the participant’s account, the participant’s an- nual addition is greater than the lesser of $40,000 (as adjusted in accordance with section 415(d)(1)) or 100 percent of the participant’scompensation.Section 415(c)(3) provides that the term “partici- pant’s compensation” means the compen- sation of the participant from the em- ployer for the year. Section 1.415(c)–2(a) of the Income Tax Regulations generally provides that compensation from the em- ployer within the meaning of section 415(c)(3) includes all items of remunera- December 2, 2013Bulletin No. 2013– 49 618 tion described in §1.415(c)–2(b), but ex- cludes the items of remuneration de- scribed in §1.415(c)–2(c). Section 1.415(c)–2(b) generally pro- vides that, for purposes of applying the limitations of section 415, the term com- pensation means remuneration for ser- vices. Specifically, under §1.415(c)– 2(b)(1), compensation includes employee wages, salaries, fees for professional ser- vices, and other amounts received (with- out regard to whether or not an amount is paid in cash) for personal services actually rendered in the course of employment with the employer maintaining the plan, to the extent that the amounts are includible in gross income. In addition, §1.415(c)– 2(b)(2) provides that in the case of an employee within the meaning of section 401(c)(1) (a self-employed employee), compensation includes the employee’s earned income (as described in section 401(c)(2)) plus amounts deferred at the election of the employee that would be includible in gross income but for the rules of section 402(e)(3), 402(h)(1)(B), 402(k), or 457(b). Section 1.415(c)–2(c) excludes certain items from the definition of compensation under section 415(c)(3). Specifically, §1.415(c)–2(c)(1) excludes contributions (other than certain elective contributions) made by the employer to a plan of de- ferred compensation to the extent that the contributions are not includible in the gross income of the employee for the tax- able year in which contributed. Likewise, distributions from plans (whether quali- fied or not) are generally not considered to be compensation for section 415 purposes. Section 1.415(c)–2(c)(2) excludes from compensation amounts realized from the exercise of nonstatutory options and amounts realized when restricted stock or other property held by an employee be- comes freely transferable or is no longer subject to a substantial risk of forfeiture. Section 1.415(c)–2(c)(3) excludes from compensation amounts realized from the sale, exchange, or other disposition of stock acquired under a statutory stock op- tion (as defined in §1.421–1(b)). Finally, §1.415(c)–2(c)(4) excludes from compen- sation other amounts that receive special tax benefits, such as certain premiums for group-term life insurance. Section 1.415(c)–2(d) provides safe harbor definitions that a plan is permitted to use to define compensation in a manner that satisfies section 415(c)(3). Section 1.415(c)–2(d)(2) provides a safe harbor definition of compensation that includes only those items listed in §1.415(c)– 2(b)(1) or (b)(2) and excludes all the items listed in §1.415(c)–2(c). Section 415(c)– 2(d)(3) provides a separate safe harbor definition of compensation that includes wages within the meaning of section 3401(a), plus amounts that would be in- cluded in wages but for an election under section125(a),132(f)(4),402(e)(3), 402(h)(1)(b), 402(k), or 457(b). Explanation of Provisions Because fishing rights-related income is not subject to income tax, an issue has been raised as to whether such income is included as compensation for purposes of section 415(c)(3) and §1.415(c)–2(b). The proposed regulations would clarify that cer- tain fishing rights-related income is included in the definition of compensation. Specifi- cally, these regulations would provide that amounts paid to a member of an Indian tribe as remuneration for services performed in a fishing rights-related activity (as defined in section 7873(b)(1)) do not fail to be treated ascompensationunder§1.415(c)– 2(b)(1) and (b)(2) (and are not excluded from the definition of compensation pursu- ant to §1.415(c)–2(c)(4)) merely because those amounts are not subject to income tax as a result of section 7873(a)(1). Thus, the determination of whether an amount consti- tutes wages, salaries, or earned income for purposes of §1.415(c)–2(b)(1) or (b)(2) is made without regard to the exemption from taxation under section 7873(b)(1) and (b)(2). In addition, by permitting fishing rights-related income to be treated as wages, salaries, or earned income under §1.415(c)– 2(b)(1) and (b)(2), plans that accept contri- butions of fishing rights-related income would not be precluded from utilizing the safe harbor definitions of compensation un- der §1.415(c)–2(d)(2) and (d)(3) of the reg- ulations. Proposed Applicability Date These regulations are proposed to ap- ply for taxable years ending on or after the date of publication of the Treasury deci- sion adopting these rules as final regula- tions in theFederal Register. Taxpayers, however, may rely on these proposed reg- ulations for periods preceding the effec- tive date, pending the issuance of final regulations. If, and to the extent, the final regulations are more restrictive than the rules in these proposed regulations, those provisions of the final regulations will be applied without retroactive effect. Special Analyses It has been determined that this notice of proposed rulemaking is not a signifi- cant regulatory action as defined in Exec- utive Order 12866, as supplemented by Executive Order 13563. Therefore, a reg- ulatory assessment is not required. It has also been determined that 5 U.S.C. 533(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations. Because these regulations do not impose a collection of information on small entities, the provisions of the Reg- ulatory Flexibility Act (5 U.S.C. chapter 6) do not apply and a Regulatory Flexi- bility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, these regulations have been submit- ted to the Office of Chief Counsel for Advocacy of the Small Business Admin- istration for comments on its impact on small business. Comments and Requests for Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any comments that are submitted timely to the IRS as prescribed in this preamble under the “Addresses” heading. In addition to general comments on the proposed regulations, the IRS and the Treasury Department request com- ments on the taxation of qualified plan distributions that are attributable to fishing rights-related income, and the application of section 72(f)(2) (which treats certain amounts as basis for purposes of comput- ing employee contributions if those amounts would have not been includible in income had they been paid directly to the employee). All comments are avail- able atwww.regulations.govor upon re- quest. A public hearing will be scheduled if requested in writing by any person who Bulletin No. 2013– 49December 2, 2013 619 timely submits written comments. If a public hearing is scheduled, notice of the date, time, and place of the public hearing will be published in theFederal Register. Consultation and Coordination with Indian Tribal Governments These proposed regulations take into account comments provided through a number of general consultation sessions held with the Indian tribal community in recent years. Consistent with Executive Order 13175, the Treasury Department and the IRS expect to hold a telephone consultation on a date between November 15, 2013 and February 13, 2014. This telephone consultation session will fo- cus principally on the contribution of section 7873 income to qualified retire- ment plans and the taxation of qualified plan distributions that are attributable to this income. Information relating to the consultation, including the date, time, registration requirements, and procedures for submitting written and oral comments, will be available on the IRS website relat- ing to Indian tribal governments at:http:// www.irs.gov/Government-Entities/Indian- Tribal-Governments. Drafting Information The principal author of these regula- tions is Sarah R. Bolen, Office of Division Counsel/Associate Chief Counsel (Tax Exempt and Government Entities). How- ever, other personnel from the IRS and the Treasury Department participated in the development of these regulations. ***** Proposed Amendments to the Regulations Accordingly, 26 CFR part 1 is pro- posed to be amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805*** Par. 2. Section 1.415(c)–2 is amended by adding paragraphs (g)(9) and (h) to read as follows: §1.415(c)–2 Compensation. ***** (g)*** (9)Income derived by Indians from exercise of fishing rights. Amounts paid to a member of an Indian tribe directly or through a qualified Indian entity (within the meaning of section 7873(b)(3)) as compensation for services performed in a fishing rights-related activity (as defined in section 7873(b)(1)) of the tribe do not fail to constitute compensation under paragraphs (b)(1) and (b)(2) of this sec- tion and are not excluded from the defini- tion of compensation pursuant to para- graph (c)(4) of this section merely because those amounts are not subject to income or employment taxes as a result of section 7873(a)(1) and (a)(2). Thus, the determination of whether an amount con- stitutes wages, salaries, or earned income for purposes of paragraph (b)(1) or (a)(2) of this section is made without regard to the exemption from taxation under section 7873(a)(1) and (a)(2). (h)Effective/applicability date. Section 1.415(c)–2(g)(9) shall apply for plan years ending on or after the date of publication of the Treasury decision adopting these rules as final regulations in theFederal Register. Heather C. Maloy, Acting Deputy Commissioner for Services and Enforcement. (Filed by the Office of the Federal Register on November 14, 2013, 8:45 a.m., and published in the issue of the Federal Register for November 15, 2013, 78 F.R. 68780) Notice of Dispositions of Declaratory Judgment Proceedings under Section 7428 Announcement 2013– 47 This announcement serves notice to donors that on July 9, 2013, the United States Tax Court entered an order and decision that, effective January 1, 2005, the organization listed below is not recog- nized as an organization described in sec- tion 501(c)(3), is not exempt from tax under section 501(a), and is not an orga- nization described in section 170(c)(2). First Step, Inc. Manahawkin, NJ Deletions from Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code Announcement 2013– 48 The Internal Revenue Service has re- voked its determination that the organiza- tions listed below qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. Generally, the Service will not dis- allow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Rev- enue Bulletin that an organization no lon- ger qualifies. However, the Service is not precluded from disallowing a deduction for any contributions made after an orga- nization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judg- ment under section 7428 and if the con- tributor (1) had knowledge of the revoca- tion of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omis- sions of the organization that brought about this revocation. If on the other hand, a suit for declaratory judgment has been timely filed, contributions from individu- als and organizations described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on De- cember 2, 2013, and would end on the date the court first determines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428(c)(1). For individual contrib- utors, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not ex- tended to any individual, in whole or in December 2, 2013Bulletin No. 2013– 49 620 part, for the acts or omissions of the orga- nization that were the basis for revocation. Corral of Comfort Horse Rescue, Inc. Palmdale, CA Positive Energy Foundation Lincoln, CA Rainy Day Foundation Washington, DC Sunrise Residential and Lifeskills Center Cincinnati, OH Thunder Air Museum Lancaster, CA Section 7428(c) Validation of Certain Contributions Made During Pendency of Declaratory Judgment Proceedings Announcement 2013– 49 This announcement serves notice to potential donors that the organization listed below has recently filed a timely declaratory judgment suit under section 7428 of the Code, challenging revocation of its status as an eligible donee under section 170(c)(2). Protection under section 7428(c) of the Code begins on the date that the notice of revocation is published in the Internal Revenue Bulletin and ends on the date on which a court first determines that an or- ganization is not described in section 170(c)(2), as more particularly set forth in section 7428(c)(1). In the case of individual contributors, the maximum amount of contributions protected during this period is limited to $1,000.00, with a husband and wife being treated as one contributor. This protection is not extended to any individual who was responsible, in whole or in part, for the acts or omissions of the organizations that were the basis for the revocation. This protection also applies (but with- out limitation as to amount) to organiza- tions described in section 170(c)(2) which are exempt from tax under section 501(a). If the organization ultimately prevails in its declaratory judgment suit, deductibility of contributions would be subject to the normal limitations set forth under section 170. Dr. R. C. Samantha Roy Institute of Sci- ence and Technology, Inc. Green Bay, WI Michael Joy Fine Arts Scholarship Fund Victoria, TX Bulletin No. 2013– 49December 2, 2013 621 Definition of Terms 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. Revenue rulings and revenue proce- dures (hereinafter referred to as “rul- ings”) 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. 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. 2013– 49December 2, 2013 i Numerical Finding List 1 Bulletins 2013–27 through 2013– 49 Announcements: 2013-35, 2013-27 I.R.B.46 2013-36, 2013-33 I.R.B.142 2013-37, 2013-34 I.R.B.155 2013-38, 2013-36 I.R.B.185 2013-39, 2013-35 I.R.B.167 2013-40, 2013-38 I.R.B.226 2013-41, 2013-40 I.R.B.322 2013-42, 2013-44 I.R.B.464 2013-43, 2013-46 I.R.B.524 2013-44, 2013-47 I.R.B.545 2013-45, 2013-47 I.R.B.546 2013-46, 2013-48 I.R.B.593 2013-47, 2013-49 I.R.B.620 2013-48, 2013-49 I.R.B.620 2013-49, 2013-49 I.R.B.621 Notices: 2013-41, 2013-29 I.R.B.60 2013-42, 2013-29 I.R.B.61 2013-43, 2013-31 I.R.B.113 2013-44, 2013-29 I.R.B.62 2013-45, 2013-31 I.R.B.116 2013-46, 2013-31 I.R.B.117 2013-47, 2013-31 I.R.B.120 2013-48, 2013-31 I.R.B.120 2013-49, 2013-32 I.R.B.127 2013-50, 2013-32 I.R.B.133 2013-51, 2013-34 I.R.B.153 2013-52, 2013-35 I.R.B.159 2013-53, 2013-36 I.R.B.173 2013-54, 2013-40 I.R.B.287 2013-55, 2013-38 I.R.B.207 2013-56, 2013-39 I.R.B.262 2013-57, 2013-40 I.R.B.293 2013-58, 2013-40 I.R.B.294 2013-59, 2013-40 I.R.B.297 2013-60, 2013-44 I.R.B.431 2013-61, 2013-44 I.R.B.432 2013-62, 2013-45 I.R.B.466 2013-63, 2013-44 I.R.B.436 2013-64, 2013-44 I.R.B.438 2013-65, 2013-44 I.R.B.440 2013-66, 2013-46 I.R.B.498 2013-67, 2013-45 I.R.B.470 2013-68, 2013-46 I.R.B.501 2013-69, 2013-46 I.R.B.503 2013-70, 2013-47 I.R.B.528 2013-71, 2013-47 I.R.B.532 2013-72, 2013-48 I.R.B.592 2013-73, 2013-49 I.R.B.598 2013-75, 2013-49 I.R.B.599 Proposed Regulations: REG-124148-05, 2013-44 I.R.B.444 REG-161948-05, 2013-44 I.R.B.449 REG-148659-07, 2013-45 I.R.B.473 REG-132251-11, 2013-37 I.R.B.191 REG-148812-11, 2013-45 I.R.B.484 REG-111753-12, 2013-40 I.R.B.302 REG-112815-12, 2013-35 I.R.B.162 REG-114122-12, 2013-35 I.R.B.163 REG-136630-12, 2013-40 I.R.B.303 REG-140789-12, 2013-32 I.R.B.136 REG-144990-12, 2013-39 I.R.B.264 REG-110732-13, 2013-43 I.R.B.405 REG-111837-13, 2013-39 I.R.B.266 REG-113792-13, 2013-38 I.R.B.211 REG-115300-13, 2013-37 I.R.B.197 REG-120927-13, 2013-39 I.R.B.618 Revenue Procedures: 2013-28, 2013-27 I.R.B.28 2013-29, 2013-33 I.R.B.141 2013-30, 2013-36 I.R.B.173 2013-31, 2013-38 I.R.B.208 2013-32, 2013-28 I.R.B.55 2013-33, 2013-38 I.R.B.209 2013-34, 2013-43 I.R.B.398 2013-35, 2013-47 I.R.B.537 2013-36, 2013-49 I.R.B.602 2013-37, 2013-49 I.R.B.612 Revenue Rulings: 2013-13, 2013-32 I.R.B.124 2013-15, 2013-28 I.R.B.47 2013-16, 2013-40 I.R.B.275 2013-17, 2013-38 I.R.B.201 2013-18, 2013-37 I.R.B.186 2013-19, 2013-39 I.R.B.240 2013-20, 2013-40 I.R.B.272 2013-21, 2013-43 I.R.B.396 2013-22, 2013-46 I.R.B.496 2013-23, 2013-48 I.R.B.590 2013-24, 2013-49 I.R.B.594 Treasury Decisions: 9620, 2013-27 I.R.B.1 9621, 2013-28 I.R.B.49 9622, 2013-30 I.R.B.64 9623, 2013-30 I.R.B.73 9624, 2013-31 I.R.B.86 9625, 2013-34 I.R.B.147 9626, 2013-34 I.R.B.149 9627, 2013-35 I.R.B.156 9628, 2013-36 I.R.B.169 9629, 2013-37 I.R.B.188 9630, 2013-38 I.R.B.199 9631, 2013-38 I.R.B.205 9632, 2013-39 I.R.B.241 Treasury Decisions—Continued: 9633, 2013-39 I.R.B.227 9634, 2013-40 I.R.B.272 9635, 2013-40 I.R.B.273 9636, 2013-43 I.R.B.331 9637, 2013-44 I.R.B.427 9638, 2013-46 I.R.B.487 9639, 2013-48 I.R.B.588 9640, 2013-48 I.R.B.548 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin 2013–26, dated June 24, 2013. December 2, 2013Bulletin No. 2013– 49 ii Finding List of Current Actions on Previously Published Items 1 Bulletins 2013–27 through 2013– 49 Notices: 2004-23 Clarified by Notice 2013-57, 2013-40 I.R.B.293 2004-50 Clarified by Notice 2013-57, 2013-40 I.R.B.293 2005-70 Obsoleted by T.D. 9633 2013-39 I.R.B.227 2006-40 Superseded by Notice 2013-68, 2013-46 I.R.B.501 2009-41 Clarified and amplified by Notice 2013-70, 2009-53 Clarified and amplified by Notice 2013-70, 2012-74 Obsoleted by Notice 2013-51, 2013-34 I.R.B.153 2013-16 Superseded by Notice 2013-55, 2013-38 I.R.B.207 2013-29 Clarified by Notice 2013-60, 2013-44 I.R.B.431 2013-36 Appendix updated by Notice 2013-55, 2013-38 I.R.B.207 Superseded by Notice 2013-55, 2013-38 I.R.B.207 2013-39 Amplified by Notice 2013-47, 2013-31 I.R.B.120 2013-40 Amplified by Notice 2013-47, 2013-31 I.R.B.120 Revenue Procedures: 81-60 Modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 Revenue Procedures—Continued: 83-59 Modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 86-42 Modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 90-52 Modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 96-30 Modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 97-48 Situation 1 superseded, Situation 2 obsoleted by Rev. Proc. 2013-30, 2013-36 I.R.B.173 2003-43 Modified and superseded by Rev. Proc. 2013-30, 2013-36 I.R.B.173 2003-48 Obsoleted in part and superseded in part by Rev. Proc. 2013-32, 2013-28 I.R.B.55 2003-61 Superseded by Rev. Proc. 2013-34, 2013-43 I.R.B.398 2004-34 Modified and clarified by Rev. Proc. 2013-29, 2013-33 I.R.B.141 2004-48 Modified and superseded by Rev. Proc. 2013-30, 2013-36 I.R.B.173 2004-49 Sections 4.01 & 4.02 modified and superseded, Section 4.03 obsoleted by Rev. Proc. 2013-30, 2013-36 I.R.B.173 2007-44 Modified by Ann. 2013-37, 2013-34 I.R.B.155 2007-62 Modified and superseded by Rev. Proc. 2013-30, 2013-36 I.R.B.173 2009-25 Pilot program discontinued by Rev. Proc. 2013-32, 2013-28 I.R.B.55 2011-18 Modified and clarified by Rev. Proc. 2013-29, 2013-33 I.R.B.141 2011-49 Modified by Ann. 2013-37, 2013-34 I.R.B.155 Revenue Procedures—Continued: 2012-25 Obsoleted in part by Rev. Proc. 2013-28, 2013-27 I.R.B.28 2013-1 Amplified and modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 2013-3 Amplified and modified by Rev. Proc. 2013-32, 2013-28 I.R.B.55 Proposed Regulations: 112815-12 Corrected by Ann. 2013-45, 2013-47 I.R.B.546 Revenue Rulings: 58-66 Amplified and clarified by Rev. Rul. 2013-17, 2013-38 I.R.B.201 2012-33 Supplemented and superseded by Rev. Rul. 2013-23, 2013-48 I.R.B.590 2013-17 Supplemented by Notice 2013-61, 2013-44 I.R.B.432 Treasury Decisions: 9610 Corrected by Ann. 2013-41, 2013-40 I.R.B.322 9612 Corrected by Ann. 2013-35, 2013-27 I.R.B.46 9622 Corrected by Ann. 2013-39, 2013-35 I.R.B.167 9627 Corrected by Ann. 2013-44, 2013-37 I.R.B.545 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–1 through 2013–26 is in Internal Revenue Bulletin 2013–26, dated June 24, 2013. Bulletin No. 2013– 49December 2, 2013 iii 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
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