Internal Revenue Bulletin 2015-6 (PDF rendition): IRS Revenue Rulings

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
SPECIAL ANNOUNCEMENT
Notice 2015–9, page 590.
This Notice provides limited penalty relief for taxpayers who
have a balance due on their 2014 income tax return as a result
of reconciling advance payments of the premium tax credit
against the premium tax credit allowed on the tax return.
INCOME TAX
Rev. Rul. 2015–3, page 580.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, and other sections of the
Code, tables set forth the rates for February 2015.
Notice 2015– 8, page 589.
Notice 2015– 08 provides guidance on Section 45R for certain
small employers that cannot offer a qualified health plan (QHP)
through the Small Business Health Options Program (SHOP)
Exchange because the employer’s principal business address
is in a county in Iowa in which a QHP through a SHOP Exchange
will not be available for all or part of the 2015 calendar year.
Notice 2015–9, page 590.
This Notice provides limited penalty relief for taxpayers who
have a balance due on their 2014 income tax return as a result
of reconciling advance payments of the premium tax credit
against the premium tax credit allowed on the tax return.
EMPLOYEE PLANS
Notice 2015–7, page 585.
This notice announces that the Treasury Department and IRS
anticipate issuing proposed regulations that would permit a
state or local retirement system that is a governmental plan
(within the meaning of section 414(d)) to cover public charter
school employees if certain requirements are satisfied. The
notice also announces that broader transition relief will be
addressed in the proposed regulations. The notice includes a
request for public comments.
EXCISE TAX
Notice 2015–3, page 583.
This notice provides rules for claimants to make one-time
claims for the retroactively extended 2014 biodiesel mixture
and alternative fuel excise tax credits. It also provides guidance
for claimants to claim the other retroactively extended credits
for 2014, including the alternative fuel mixture excise tax
credit.
Finding Lists begin on page ii.
Bulletin No. 2015– 6
February 9, 2015

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
February 9, 2015Bulletin No. 2015– 6

Actions Relating to
Decisions of the Tax Court
It is the policy of the Internal Revenue
Service to announce at an early date
whether it will follow the holdings in cer-
tain cases. An Action on Decision is the
document making such an announcement.
An Action on Decision will be issued at
the discretion of the Service only on unap-
pealed issues decided adverse to the gov-
ernment. Generally, an Action on Deci-
sion is issued where its guidance would be
helpful to Service personnel working with
the same or similar issues. Unlike a Trea-
sury Regulation or a Revenue Ruling, an
Action on Decision is not an affirmative
statement of Service position. It is not
intended to serve as public guidance and
may not be cited as precedent.
Actions on Decisions shall be relied
upon within the Service only as conclu-
sions applying the law to the facts in the
particular case at the time the Action on
Decision was issued. Caution should be
exercised in extending the recommenda-
tion of the Action on Decision to similar
cases where the facts are different. More-
over, the recommendation in the Action
on Decision may be superseded by new
legislation, regulations, rulings, cases, or
Actions on Decisions.
Prior to 1991, the Service published
acquiescence or nonacquiescence only in
certain regular Tax Court opinions. The
Service has expanded its acquiescence
program to include other civil tax cases
where guidance is determined to be help-
ful. Accordingly, the Service now may
acquiesce or nonacquiesce in the holdings
of memorandum Tax Court opinions, as
well as those of the United States District
Courts, Claims Court, and Circuit Courts
of Appeal. Regardless of the court decid-
ing the case, the recommendation of any
Action on Decision will be published in
the Internal Revenue Bulletin.
The recommendation in every Action
on Decision will be summarized as ac-
quiescence, acquiescence in result only, or
nonacquiescence. Both “acquiescence”
and “acquiescence in result only” mean
that the Service accepts the holding of the
court in a case and that the Service will
follow it in disposing of cases with the
same controlling facts. However, “acqui-
escence” indicates neither approval nor
disapproval of the reasons assigned by the
court for its conclusions; whereas “acqui-
escence in result only” indicates disagree-
ment or concern with some or all of those
reasons. “Nonacquiescence” signifies that,
although no further review was sought,
the Service does not agree with the hold-
ing of the court and, generally, will not
follow the decision in disposing of cases
involving other taxpayers. In reference to
an opinion of a circuit court of appeals, a
“nonacquiescence” indicates that the Ser-
vice will not follow the holding on a na-
tionwide basis. However, the Service will
recognize the precedential impact of the
opinion on cases arising within the venue
of the deciding circuit.
The Commissioner does NOT ACQUI-
ESCE in the following decisions:
Gracia v. Commissioner,
1
T.C. Memo. 2004–147
Estate of Martinez v. Commissioner,
2
T.C. Memo. 2004–150
Mirarchi v. Commissioner,
3
T.C. Memo. 2004–148
Price v. Commissioner,
4
T.C. Memo. 2004–149
1
Nonacquiescence relating to the holding that a general partner who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity may exclude from gross income
under section 108(a) partnership debt cancelled in a title 11 case of the partnership.
2
Nonacquiescence relating to the holding that a general partner who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity may exclude from gross income
under section 108(a) partnership debt cancelled in a title 11 case of the partnership.
3
Nonacquiescence relating to the holding that a general partner who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity may exclude from gross income
under section 108(a) partnership debt cancelled in a title 11 case of the partnership.
4
Nonacquiescence relating to the holding that a general partner who guaranteed the debt of a partnership and was not in bankruptcy in his individual capacity may exclude from gross income
under section 108(a) partnership debt cancelled in a title 11 case of the partnership.
Bulletin No. 2015– 6February 9, 2015
579

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 42.—Low-Income
Housing Credit
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of February 2015.
See Rev. Rul. 2015–3, page 580.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of February 2015. See Rev.
Rul. 2015–3, page 580.
Section 412.—Minimum
Funding Standards
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 467.—Certain
Payments for the Use of
Property or Services
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month of
February 2015. See Rev. Rul. 2015–3, page 580.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of February 2015.
See Rev. Rul. 2015–3, page 580.
Section 483.—Interest on
Certain Deferred Payments
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 642.—Special
Rules for Credits and
Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of February 2015.
See Rev. Rul. 2015–3, page 580.
Section 807.—Rules for
Certain Reserves
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 846.—Discounted
Unpaid Losses Defined
The adjusted applicable federal short-term,
mid-term, and long-term rates are set forth for the
month of February 2015. See Rev. Rul. 2015–3,
page 580.
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 412, 467, 468, 482,
483, 642, 807, 846, 1288, 7520, 7872.)
Rev. Rul. 2015–3
This revenue ruling provides various
prescribed rates for federal income tax
purposes for February 2015 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-
term, mid-term, and long-term adjusted
applicable federal rates (adjusted AFR)
for the current month for purposes of sec-
tion 1288(b). Table 3 sets forth the ad-
justed federal long-term rate and the long-
term tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage for non-federally subsidized new
buildings placed in service after July 30,
2008, with respect to housing credit dollar
amount allocations made before January
1, 2015 shall not be less than 9%.
Finally,Table 5 contains the federal
rate for determining the present value of
an annuity, an interest for life or for a term
of years, or a remainder or a reversionary
interest for purposes of section 7520.
February 9, 2015Bulletin No. 2015– 6
580

REV. RUL. 2015–3 TABLE 1
Applicable Federal Rates (AFR) for February 2015
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR.48%.48%.48%.48%
110% AFR.53%.53%.53%.53%
120% AFR.58%.58%.58%.58%
130% AFR.62%.62%.62%.62%
Mid-term
AFR1.70%1.69%1.69%1.68%
110% AFR1.87%1.86%1.86%1.85%
120% AFR2.04%2.03%2.02%2.02%
130% AFR2.21%2.20%2.19%2.19%
150% AFR2.56%2.54%2.53%2.53%
175% AFR2.98%2.96%2.95%2.94%
Long-term
AFR2.41%2.40%2.39%2.39%
110% AFR2.66%2.64%2.63%2.63%
120% AFR2.90%2.88%2.87%2.86%
130% AFR3.14%3.12%3.11%3.10%
REV. RUL. 2015–3 TABLE 2
Adjusted AFR for February 2015
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.46%.46%.46%.46%
Mid-term adjusted AFR1.39%1.39%1.39%1.39%
Long-term adjusted AFR2.41%2.40%2.39%2.39%
REV. RUL. 2015–3 TABLE 3
Rates Under Section 382 for February 2015
Adjusted federal long-term rate for the current month2.41%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)2.68%
REV. RUL. 2015–3 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for February 2015
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service afterJuly
30, 2008, with respect to housing credit dollar amount allocations made before January 1, 2015, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.47%
Appropriate percentage for the 30% present value low-income housing credit3.20%
REV. RUL. 2015–3 TABLE 5
Rate Under Section 7520 for February 2015
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
2.0%
Bulletin No. 2015– 6February 9, 2015
581

Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 7520.—Valuation
Tables
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of February 2015. See Rev. Rul. 2015–3, page 580.
February 9, 2015Bulletin No. 2015– 6
582

Part III. Administrative, Procedural, and Miscellaneous
Biodiesel and Alternative
Fuels; Claims for 2014;
Excise Tax
Notice 2015–3
Section 1. PURPOSE
This notice provides rules claimants
must follow to make a one-time claim for
payment of the credits and payments al-
lowable under §§ 6426(c), 6426(d) and
6427(e) of the Internal Revenue Code
(Code) for biodiesel (including renewable
diesel) mixtures and alternative fuels sold
or used during calendar year 2014 (collec-
tively, 2014 biodiesel and alternative fuel
incentives). These rules are prescribed un-
der § 160(e) of the Tax Increase Preven-
tion Act of 2014 (Pub. L. 113–295) (the
Act). This notice also provides instruc-
tions for how a claimant may offset its
§ 4081 liability with the § 6426(e) alter-
native fuel mixture credit, and provides
instructions for how a claimant may make
certain income tax claims for biodiesel,
second generation biofuel, and alternative
fuel.
Section 2. BACKGROUND
Sections 6426(a) and (c) allow a
blender of a biodiesel (including renew-
able diesel) mixture to claim a $1.00-per-
gallon credit against its tax liability under
§ 4081 (relating to the tax imposed on
taxable fuel). Similarly, §§ 6426(a) and
(e) allow a blender of an alternative fuel
mixture to claim a credit against its tax
liability under § 4081, except that the
credit amount is $0.50 per gallon. Sec-
tions 6426(a) and (d) allow a person that
sells or uses alternative fuel as a fuel in a
motor vehicle or motorboat and in avia-
tion to claim a $0.50-per-gallon credit
against the claimant’s tax liability under
§ 4041 (relating to the tax imposed on
diesel fuel and alternative fuel).
Blenders of biodiesel (including re-
newable diesel) mixtures and persons that
sell or use alternative fuel as a fuel in a
motor vehicle or motorboat and in avia-
tion may claim any excess credit under
§§ 6426(c) or (d) as a payment under
§ 6427(e) or as a refundable income tax
credit under § 34. As an alternative to the
payments and credits allowed under
§§ 6426, 6427, and 34, a blender of a
biodiesel (including renewable diesel)
mixture may claim a nonrefundable in-
come tax credit under § 40A (see Section
8 of this notice for additional informa-
tion).
The Code provisions that authorize
these credits and payments expired for
sales and uses after December 31, 2013
(September 30, 2014, in the case of any
sale or use involving liquefied hydrogen),
but were reinstated by the Act for sales
and uses during 2014. Section 160(e) of
the Act directs the Secretary of the Trea-
sury (Secretary) to issue guidance provid-
ing for a one-time submission of claims
under §§ 6426(c), 6426(d) and 6427(e)
covering periods during 2014. The Act
requires the guidance to provide for a 180-
day period for the submission of claims
(in such manner as prescribed by the Sec-
retary) to begin no later than 30 days after
the guidance is issued.
Sections 152 and 153 of the Act also
reinstated Code provisions authorizing
credits for second generation biofuel pro-
ducers (§ 40(b)(6)) and biodiesel and re-
newable diesel used as fuel (§ 40A), re-
spectively. The second generation biofuel
producer credit expired for production af-
ter December 31, 2013, and was reinstated
by the Act for production during 2014.
The credit for biodiesel and renewable
diesel used as fuel expired for sales and
uses after December 31, 2013, and was
reinstated by the Act for sales and uses
during 2014.
Section 3. SCOPE
This notice provides the procedure for
claiming 2014 biodiesel and alternative
fuel incentives. Claimants that filed “pro-
tective” or anticipatory claims during
2014 for biodiesel and alternative fuel in-
centives covered by this notice should re-
file their claims pursuant to the procedures
provided in this notice. The IRS will not
treat as perfected any such protective or
anticipatory claims previously filed with
the IRS that are not timely supplemented
in accordance with these procedures.
Except as provided by this notice, the
rules in Notice 2005–4, 2005–1 C.B. 289
(providing guidance on alcohol and
biodiesel fuel tax credits and payments),
as modified by Notice 2005–62, 2005–2
C.B. 443 (providing guidance for certain
biodiesel issues not addressed in Notice
2005–4), and Notice 2006–92, 2006–2
C.B. 774 (providing guidance on alterna-
tive fuel and alternative fuel mixture
taxes, credits, and payments), apply to
claims for 2014 biodiesel and alternative
fuel incentives.
The § 6426(e) alternative fuel mixture
credit expired on December 31, 2013
(September 30, 2014, in the case of any
liquefied hydrogen mixtures), and was re-
instated by the Act for sales and uses
during 2014. This notice prescribes a
method for submitting claims relating to
alternative fuel mixtures (including lique-
fied hydrogen mixtures, if the credit was
not previously claimed) sold or used dur-
ing 2014.
This notice does not affect the income
tax claims described in Section 8 of the
notice.
Section 4. HOW TO MAKE A ONE-
TIME CLAIM FOR CREDITS AND
PAYMENTS ALLOWABLE UNDER
§§ 6426(c), 6426(d), AND 6427(e)
Claimants must follow the procedures
listed below to make a one-time claim
under this notice for payment of credits
and payments allowable under §§ 6426(c),
6426(d), and 6427(e) relating to biodiesel
and alternative fuel incentives.
•Claimants must submit claims for
2014 biodiesel and alternative fuel in-
centives on Form 8849,Claim for Re-
fund of Excise Taxes.
•Claimants must include Schedule 3
(Form 8849),Certain Fuel Mixtures
and the Alternative Fuel Credit, with
their submission and enter amounts for
2014 biodiesel and alternative fuel in-
centives on Line 2 and Line 3 of
Schedule 3, as appropriate.
•Claimants must follow the instructions
to Form 8849 and Schedule 3 when
preparing their submission to the ex-
tent that those instructions do not con-
flict with this notice.
Bulletin No. 2015– 6February 9, 2015
583

•Each claimant must claim all 2014
biodiesel and alternative fuel incen-
tives for which the claimant is eligible
on a single Form 8849.
•Each claimant must mail its submis-
sion to the address listed for Schedule
3 in the instructions to Form 8849 un-
derWhere to File. Alternatively,
claimants may electronically file Form
8849 and Schedule 3 through any elec-
tronic return originator, transmitter, or
intermediate service provider partici-
pating in the IRSe-fileprogram for
excise taxes.
•Claimants are reminded that they must
be registered by the IRS in order to
make alternative fuel claims under
§§ 6426(d) and 6427(e) and to make
alternative fuel mixture claims under
§ 6426(e) (described in Section 6 of
this notice). Claimants that are not al-
ready registered by the IRS may apply
to the IRS for registration by filing
Form 637,Application for Registra-
tion (For Certain Excise Tax Activi-
ties), in accordance with the instruc-
tions to Form 637.
Section 5. CLAIM PERIOD AND DUE
DATE FOR BIODIESEL AND
ALTERNATIVE FUEL INCENTIVES
Although a claimant may submit its
claim under this notice as early as January
16, 2015, the 180-day claim period for
2014 biodiesel and alternative fuel incen-
tives begins on February 9, 2015. Conse-
quently, all claims for 2014 biodiesel and
alternative fuel incentives must be filed on
or before August 8, 2015. The IRS will
not process claims filed after that date.
The IRS will deem any claim that is sub-
mitted by the method prescribed in this
notice before February 9, 2015, as filed on
February 9, 2015.
If the IRS does not pay a 2014 biodie-
sel and alternative fuel incentives claim
that conforms to this notice within 60
days after the claim is received, the IRS
will pay the claim with interest from the
claim filing date (February 9, 2015, in
the case of claims submitted before
that date) using the overpayment rate
and method provided by § 6621 of the
Code.
Section 6. HOW TO MAKE AN
ALTERNATIVE FUEL MIXTURE
CLAIM UNDER § 6426(e)
For 2014, all alternative fuel mixture
credit claims allowed by § 6426(e), in-
cluding claims for the fourth quarter, must
be made on Form 720X,Amended Quar-
terly Federal Excise Tax Return. Al-
though in prior years § 6426(e) claims
could be made on the Form 720,Quar-
terly Federal Excise Tax Return, the IRS
is unable to process 2014 claims on the
fourth quarter Form 720 due to the timing
of enactment of the Act. Failure to file a
Form 720,Quarterly Federal Excise Tax
Return, and remit the § 4081 tax due for
any quarter in 2014 before submitting a
claim allowed by § 6426(e) on Form
720X will result in delayed processing of
the claim and delayed payment of refunds
resulting from the credit. Similarly, failure
to follow the claim procedure in this sec-
tion will result in delayed processing and
payment of 2014 § 6426(e) claims. Claim-
ants are reminded that the claim for a
§ 6426(e) credit for any quarter may not
exceed the § 4081 liability incurred in the
quarter for which the credit is being
claimed. Form 720X allows claimants to
adjust multiple quarters on a single Form
720X.
Section 7. CLAIM PERIOD AND DUE
DATE FOR ALTERNATIVE FUEL
MIXTURE CREDITS
The claim period for the 2014 alterna-
tive fuel mixture credit begins on Febru-
ary 9, 2015. The IRS will deem any claim
that is submitted by the method prescribed
in section 6 of this notice before February
9, 2015, as filed on February 9, 2015.
Generally, claims for the § 6426(e) alter-
native fuel mixture credit must be made
within three years from the time the return
was filed or two years from the time the
tax was paid, whichever is later.
Section 8. CLAIMS NOT AFFECTED
BY THIS NOTICE
This notice does not affect 2014 claims
for the nonrefundable income tax credit
under § 40(b)(6) for second generation
biofuel producers. Taxpayers should con-
tinue to submit these claims separately on,
and in accordance with, Form 6478,Bio-
fuel Producer Credit. The notice also does
not affect 2014 claims for the nonrefund-
able income tax credits under § 40A(b)(1)
for biodiesel mixtures, § 40A(b)(2) for
biodiesel (including renewable diesel), or
under § 40A(b)(4) for the small agri-
biodiesel producer credit. Taxpayers
should continue to submit these claims
separately on, and in accordance with,
Form 8864,Biodiesel and Renewable
Diesel Fuels Credit. A taxpayer must sub-
mit Form 8864 with its income tax return
in accordance with the instructions to its
income tax return form. Taxpayers are
reminded that under § 40A(c), credits al-
lowable under § 40A must be reduced to
the extent that any benefit is claimed un-
der §§ 6426 and 6427 with respect to the
same biodiesel (including renewable die-
sel).
Similarly, this notice does not affect
2014 claims for the refundable income tax
credit under § 34 for biodiesel mixtures or
alternative fuel. Taxpayers should con-
tinue to submit these claims separately on,
and in accordance with, Form 4136,
Credit for Federal Tax Paid on Fuels.A
taxpayer must submit Form 4136 with its
income tax return in accordance with the
instructions to its income tax return form.
Taxpayers are reminded that under
§ 34(b), credits are not allowed under § 34
for any amount properly payable under
§ 6427 and claimed in a timely filed claim.
For this purpose, the IRS will treat as
timely filed any claim submitted for
amounts payable under § 6427 that con-
forms to the rules provided in this notice.
Section 9. DRAFTING INFORMATION
The principal author of this notice is
Amanda F. Dunlap of the Office of Asso-
ciate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice contact Amanda F.
Dunlap on (202) 317-6855 (not a toll-free
number).
February 9, 2015Bulletin No. 2015– 6
584

Relief for Certain
Participants in § 414(d)
Governmental Plans
Notice 2015–7
I. PURPOSE
The IRS and the Treasury Department
anticipate issuing proposed regulations
under § 414(d) of the Internal Revenue
Code (Code) to define the term “govern-
mental plan.” This document describes
specific rules that the IRS and Treasury
Department are considering proposing
that relate to whether a State or local
retirement system that covers employees
of a charter school is a governmental plan
within the meaning of § 414(d). Section
III of this notice describes the guidance
under consideration, which would provide
that employees of a public charter school
may participate in a State or local retire-
ment system if certain conditions are sat-
isfied. Section IV of this notice discusses
the potential for broader transition relief
for governmental plans once final regula-
tions under § 414(d) are issued. Section V
of this notice requests comments on the
guidance under consideration described in
section III of this notice.
II. BACKGROUND
Section 414(d) of the Code provides
that the term governmental plan generally
means “a plan established and maintained
for its employees by the Government of
the United States, by the government of
any State or political subdivision thereof,
or by any agency or instrumentality of any
of the foregoing.” See sections 3(32) and
4021(b)(2) of the Employee Retirement
Income Security Act of 1974 (ERISA) for
definitions of the term “governmental
plan,” which govern for purposes of title I
and title IV of ERISA, respectively.
1
Currently, there are no regulations in-
terpreting § 414(d) of the Code. Neither
§ 414(d) of the Code nor ERISA define
key terms relating to governmental plans,
including the terms “established and
maintained,” “political subdivision,”
“agency,” and “instrumentality.” Revenue
Ruling 89–49, 1989–1 C.B. 117, pro-
vides guidance for determining whether a
retirement plan maintained by an organi-
zation is a governmental plan within the
meaning of § 414(d). The revenue ruling
lists several factors for determining
whether a sponsoring organization or par-
ticipating employer is an agency or instru-
mentality of the United States or any State
or political subdivision of a State. The
factors in Rev. Rul. 89–49 are similar to
the factors listed in Rev. Rul. 57–128,
1957–1 CB 31, which provides guidance
on whether an entity is an instrumentality
that is wholly-owned by one or more
States or political subdivisions of a State
for purposes of the exemption from em-
ployment taxes under §§ 3121(b)(7) and
3306(c)(7) of the Code.
Rev. Rul. 57–128 lists the following
factors to be considered in determining
whether an organization is an instrumen-
tality of one or more States or political
subdivisions thereof: (1) whether the or-
ganization is used for a governmental pur-
pose and performs a governmental func-
tion; (2) whether performance of its
function is on behalf of one or more States
or political subdivisions; (3) whether there
are any private interests involved, or
whether the States or political subdivi-
sions involved have the powers and inter-
ests of an owner; (4) whether control and
supervision of the organization is vested
in public authority or authorities; (5)
whether express or implied statutory au-
thority or other authority is necessary for
the creation and/or use of such an instru-
mentality, and whether such authority ex-
ists; and (6) the degree of the organiza-
tion’s financial autonomy and the source
of its operating expenses.
Rev. Rul. 89–49 focuses more on the
degree of control that the Federal or State
government has over the organization’s
everyday operations than Rev. Rul. 57–
128. Other factors considered in Rev. Rul.
89–49 include: whether there is specific
legislation creating the organization; the
source of funds for the organization; the
manner in which the organization’s trust-
ees or operating board are selected; and
whether the applicable government unit
considers the employees of the organiza-
tion to be employees of the applicable
government unit. Rev. Rul. 89–49 pro-
vides that satisfaction of one or all of the
factors is not necessarily determinative of
whether an organization is a governmental
entity.
On November 8, 2011, the IRS and
Treasury Department published an Ad-
vance Notice of Proposed Rulemaking
(ANPRM) (REG–157714–06), relating to
the definition of a governmental plan un-
der § 414(d) of the Code, in theFederal
Register(76 FR 69172) (§ 414(d) AN-
PRM). The § 414(d) ANPRM describes
guidance under consideration that would
set forth rules relating to the determina-
tion of whether a retirement plan is a
governmental plan within the meaning of
§ 414(d).
2
The guidance under consider-
ation would define key terms relating to
governmental plans, including “estab-
lished and maintained,” “political subdi-
vision,” and “agency or instrumentality.”
For purposes of determining whether
an entity is an agency or instrumentality
of the United States or an agency or in-
strumentality of a State or political subdi-
vision of a State, the guidance under con-
sideration described in the § 414(d)
ANPRM would provide a facts and cir-
cumstances analysis. The factors used in
this analysis are drawn from the factors
historically used in governmental plan de-
terminations, including the factors set
forth in Rev. Ruls. 57–128 and 89–49, as
well as court decisions.
3
The factors de-
scribed in the anticipated guidance de-
scribed in the § 414(d) ANPRM include
whether the entity’s governing board or
body is controlled by a State or political
subdivision; whether the members of the
entity’s governing board or body are pub-
licly nominated and elected; the extent to
1
The definition of the term “governmental plan” also includes special rules relating to (a) plans to which the Railroad Retirement Act of 1935 or 1937 (49Stat. 967, as amended by 50 Stat.
307) applies, (b) plans of an international organization that is exempt from taxation by reason of the International Organizations Immunities Act (59 Stat. 669), and (c) certain plans that
are established and maintained by an Indian tribal government (as defined in § 7701(a)(40)), a subdivision of an Indian tribal government (determinedin accordance with § 7871(d)), or
an agency or instrumentality of either.
2
The IRS and Treasury Department also issued an ANPRM (REG-133223-08) relating to special rules for ITGs on November 8, 2011 in theFederal Register(76 FR 69188).
3
For a discussion of court cases analyzing governmental entity status, see the discussion under the heading, “Judicial Determinations of Governmental Entity Status” in the Appendix to the
§ 414(d) ANPRM.
Bulletin No. 2015– 6February 9, 2015
585

which a State has financial responsibility
for the general debts and other liabilities
of entity; and the extent to which the
entity is delegated, pursuant to statute, the
authority to exercise sovereign powers.
For a complete discussion of each of the
factors in the guidance under consider-
ation described in the § 414(d) ANPRM,
see the discussion under the heading
“Definition of agency or instrumentality
of a State or a political subdivision of a
State” in the “Explanation of Provisions”
section of the Appendix to the § 414(d)
ANPRM.
The § 414(d) ANPRM requested com-
ments from the public on the guidance un-
der consideration. With respect to this re-
quest, members of the public charter school
community submitted over 2,000 com-
ments, which, together with all of the other
comment letters received, the IRS and Trea-
sury Department continue to review. Al-
though the § 414(d) ANPRM does not
change the law regarding or directly address
whether a charter school is a governmental
entity or whether employees of charter
schools are permitted to participate in a gov-
ernmental plan (such as a State or local
retirement system), comments from mem-
bers of the charter school community raised
several concerns with the guidance under
consideration. Mainly, the commenters ex-
pressed concern that if the guidance de-
scribed in the § 414(d) ANPRM were pub-
lished in its current form as a final
regulation, the guidance would deter State
or local retirement systems from permitting
charter school employee participation in
their retirement systems in order to retain
their governmental plan status. Commenters
indicated that this, in turn, would jeopardize
the retirement security of charter school em-
ployees and adversely affect charter
schools’ ability to attract and retain teachers.
Forty-two States and the District of
Columbia have laws authorizing the char-
tering of independent public schools of
choice. These schools, often referred to as
public charter schools, are generally
funded with public revenue on a per-
pupil basis. Public charter schools do
not charge tuition, are open to all stu-
dents within a specified geographic
boundary, and are viewed by States as
part of the public school system. How-
ever, public charter schools typically
operate independently of the governance
structures that generally are in place for
other public schools, such as a district
board of education.
In general, States that authorize public
charter schools either require or permit
public charter school employees to par-
ticipate in their State retirement sys-
tems. In response to the § 414(d) AN-
PRM, commenters from the public
charter school community expressed
concern that the autonomy granted to
public charter schools would mean that
charter school employees would not be
able to continue participation in State or
local retirement systems. Commenters
argued that Congress intended charter
schools to be treated as public schools,
but recognized that charter schools were
not subject to governmental control in
the same manner as traditional public
schools.
4
Commenters requested that,
when the guidance under consideration
described in the § 414(d) ANPRM is
ultimately issued, the guidance permit
participation of public charter school
employees in governmental plans. One
request was that the proposed regula-
tions provide the use of a safe harbor to
permit public charter school employees
to participate in State or local retirement
systems. Other requests included that
the proposed regulations provide a re-
vised set of factors, without distinction
between main factors and other factors,
that a typical public charter school
would more clearly satisfy; that the pro-
posed regulations include an example
under the facts and circumstances test
showing that a typical public charter
school is an agency or instrumentality of
a State or political subdivision of a
State; and that the proposed regulations
provide a grandfathering rule permitting
current and future public charter school
employees to participate in a State or
local retirement system.
III. GUIDANCE UNDER
CONSIDERATION
After review and consideration of com-
ments received with respect to the
§ 414(d) ANPRM, the IRS and Treasury
Department are considering issuing the
guidance described in section III.A of this
notice relating to whether a State or local
retirement system that covers employees
of a public charter school is a governmen-
tal plan within the meaning of § 414(d).
The guidance under consideration would
take into account the special and unique
nature of public charter schools, the gov-
ernance structure associated with these
schools, the structure of many public
school systems that permit or encourage
public school teachers to move between
public charter and traditional public
schools, and the relationship between pub-
lic charter schools and the agencies autho-
rized by the State or political subdivision
of the State (such as an authorized public
chartering agency as defined in 20 U.S.C.
§ 7721i(4)) that hold these schools ac-
countable for academic results. It is ex-
pected that the principles described in sec-
tion III.A of this notice would apply
regardless of whether the retirement plan
is a defined benefit, defined contribution,
§ 403(b), or § 457(b) governmental plan.
The IRS and Treasury Department intend
the guidance described in section III.A of
this notice to cover only employees of
public charter schools and anticipate that
the effect of participation of employees of
entities other than public charter schools
in a State or local retirement system on the
system’s status as a governmental plan
under § 414(d) of the Code would be
determined in accordance with the general
rules set forth in the regulations after final
regulations under § 414(d) are issued.
A.Participation of a public charter
school in a State or local retirement
system
The IRS and Treasury Department are
considering proposing regulations under
§ 414(d) specifying that a State or local
retirement system that covers employees
of a public charter school will not fail to
4
SeePart B of the Individuals with Disabilities Act, 20 U.S.C. § 1400et. seq.,under which charter schools are treated as public schools for purposes of eligibility for federal funding and
20 U.S.C. § 7221i(1)(A), under which a charter school is defined as a public school that “is exempt from significant State or local rules that inhibit the flexible operation and management
of public schools,...”
February 9, 2015Bulletin No. 2015– 6
586

be a governmental plan within the mean-
ing of § 414(d) if certain conditions are
satisfied. Specifically, the guidance under
consideration would specify that a State or
local retirement system will not fail to be
a governmental plan within the meaning
of § 414(d) merely because the system
permits employees of an entity that satis-
fies the requirements listed in paragraphs
(a) through (e) below to participate in the
system:
(a) The entity is a nonsectarian inde-
pendent public school that serves a gov-
ernmental purpose by providing tuition-
free elementary or secondary education,
or both.
(b) The entity is established and oper-
ated in accordance with a specific State
statute authorizing the granting of charters
to create independent public schools or
authorizing the establishment of indepen-
dent public schools.
(c) Participation in the State or local
retirement system by the entity’s employ-
ees is expressly required or permitted un-
der applicable law.
(d) The entity satisfies either paragraph
(d)(1) or (d)(2) below.
(1) The entity’s governing board or
body is controlled by a State, political
subdivision of a State, or agency or instru-
mentality of a State or of a political sub-
division of a State. For this purpose, either
(i) a State, political subdivision of a State,
or an agency or instrumentality of a State
or political subdivision of a State must
have the power to nominate, appoint, re-
move, and replace a majority of the mem-
bers of the entity’s governing board or
body, or (ii) a majority of the members of
the entity’s governing board or body must
be publicly nominated and elected.
(2) In lieu of satisfying the require-
ments in paragraph (d)(1), the entity sat-
isfies the requirements in paragraphs
(d)(2)(i) through (d)(2)(iii) below.
(i) The primary source of the entity’s
funding is from a State, political subdivi-
sion of a State, or agency or instrumental-
ity of a State or political subdivision of a
State.
(ii) The rights of the entity’s employ-
ees to their accrued benefits under the
State or local retirement system are not
dependent on whether the entity continues
to participate in the system and, in the
event the entity ceases participation, a
governmental entity has responsibility for
the accrued benefits of the entity’s em-
ployees, including the continued funding
of the accrued benefits, to no lesser extent
than a governmental entity has responsi-
bility for the continued funding of the
accrued benefits of the employees of any
other participating employer in the system
in the event that other employer were to
cease to be a participating employer.
(iii) The entity is part of a local educa-
tional agency, as defined in 20 U.S.C.
7801(26) (or is its own local educational
agency), and is subject to the significant
regulatory control and oversight by a
State, political subdivision of a State, or
agency or instrumentality of a State or
political subdivision of a State, as de-
scribed in paragraphs (d)(2)(iii)(1) and
(d)(2)(iii)(2) below.
(1) The entity is held accountable by an
authorized public chartering agency as de-
fined in 20 U.S.C. § 7221i(4), which has
the power to approve, renew, and revoke
the charter of the entity. For this purpose,
the authorized public chartering agency
must be authorized under State law to
approve charters for the creation of inde-
pendent public schools and to hold the
entity accountable for results.
(2) The entity is required to comply
with health and safety standards, as well
as academic and financial accountability
standards, that are similar to those that are
generally applicable to other public
schools in the State.
(e) All financial interests of ownership
in the entity are held by a State, political
subdivision of a State, or agency or instru-
mentality of a State or of a political sub-
division of a State. A State, political sub-
division of a State, or agency or
instrumentality of a State or political sub-
division of a State is not treated as holding
all financial ownership interests in an en-
tity unless, upon dissolution or final liqui-
dation of the entity, the entity’s governing
documents require the entity’s net assets
to be distributed to another public school
that meets the requirements in (a) through
(e) of this section III.A or to a State,
political subdivision of a State, or agency
or instrumentality thereof.
B.Example
For purposes of illustrating the guid-
ance under consideration described in sec-
tion III.A of this notice, the following
example is provided.
1.Facts. Charter School A is an inde-
pendent public school of choice (that is, a
public school in which parents have a
choice in determining the school their
children will attend) established and oper-
ated in accordance with the laws of State
X as a nonprofit corporation under
§ 501(c)(3) of the Code. Charter School A
is a nonsectarian elementary school that
provides tuition-free education.
Under the laws of State X, Charter
School A has elected to be a participating
employer in State X’s Retirement System
P, which is a defined benefit governmental
plan as described in § 414(d). Under the
laws of State X, Charter School A is re-
sponsible for making any employer con-
tribution that otherwise would be the legal
responsibility of the school district, and
the State X will be responsible for making
employer contributions to the same extent
it would be legally responsible if the em-
ployees of Charter School A were school
district employees.
Charter School A is funded through
appropriations of State X based on the
school’s average daily attendance. This
funding mechanism is similar to the fund-
ing mechanism for traditional public
schools. Charter School A is controlled by
an independent board of directors elected
by parents of children who are enrolled in
the charter school. Although subject to
certain State X laws relating to education,
Charter School A is exempt from other
State X laws that apply to traditional pub-
lic schools, such as laws relating to stu-
dent transportation and purchasing and
contracting. Charter School A, like all
public charter schools in State X, is over-
seen by the State X Board of Education
(which is the sole authorized public char-
tering agency in State X). For example,
Charter School A is subject to audit by the
State X Board of Education, which has the
power to place the charter school on pro-
bation, not renew the charter contract, or
revoke the charter contract. Charter
School A is also subject to the same health
and safety standards and state-level edu-
cational assessments used for accountabil-
ity purposes as traditional public schools
in State X. In addition, Charter School A
must participate in the statewide testing
programs of State X.
Bulletin No. 2015– 6February 9, 2015
587

The board of directors for Charter
School A is responsible for budgeting,
staffing, and other management of the
school, but State X requires that Charter
School A must satisfy generally accepted
accounting standards of fiscal manage-
ment. Charter School A’s charter provides
that it will engage in an annual indepen-
dent, outside audit by a certified public
accountant of its financial and administra-
tive operations and will provide a copy of
the audit to the State X Board of Educa-
tion. Charter School A must comply with
rules and implementing statutes that pre-
scribe how appropriations of State X may
be spent.
Charter School A’s governing docu-
ments require that, upon closure, dissolu-
tion, or final liquidation of the entity,
Charter School A’s net assets would be
distributed to another public school that
meets the requirements in (a) through (e)
of section III.A of this notice or to an
agency or instrumentality of State X, such
as a traditional public school or the State
X Board of Education.
2.Conclusion. Based on the facts de-
scribed in section III.B.1 of this notice,
Charter School A meets the requirements
of the guidance under consideration de-
scribed in section III.A of this notice.
Therefore, State X’s Retirement System P
will not fail to be a governmental plan
within the meaning of § 414(d) merely
because the system permits Charter
School A to participate in the system as a
participating employer.
C.Coordination with other agencies
The IRS and Treasury Department, in
developing the guidance under consider-
ation described in section III.A of this
notice, consulted with the Department of
Labor (DOL) and Pension Benefit Guar-
anty Corporation (PBGC) (the “Agen-
cies”). As was the case with the § 414(d)
ANPRM, staff from the DOL and PBGC
agreed that it would be advantageous for
the Agencies and the regulated commu-
nity for there to be coordinated criteria for
determining whether a plan is a govern-
mental plan within the meaning of
§ 414(d) of the Code, section 3(32) of
ERISA, and section 4021(b)(2) of ERISA.
With respect to this notice, the IRS and
Treasury Department also consulted with
the Department of Education.
IV. TRANSITION RELIEF
A.Periods prior to the effective date of
final regulations under § 414(d) of the
Code
The guidance under consideration in
section III.A of this notice would first be
issued as part of the proposed regulations
under § 414(d). The IRS and Treasury
Department anticipate that the proposed
regulations will provide guidance under
§ 414(d), including the guidance under
consideration described in section III.A of
this notice and the subject matter of the
guidance under consideration described in
the § 414(d) ANPRM. The proposed reg-
ulations will reflect consideration of com-
ments received in response to the com-
ment requests in this notice and the
§ 414(d) ANPRM. Before the proposed
regulations are ultimately adopted as final
regulations, consideration will be given to
any written or electronic comments that
are submitted to the IRS in accordance
with the comment request that will be
included in the preamble to the proposed
regulations. The preamble to the proposed
regulations will request comments on all
aspects of the proposed rules.
The IRS and Treasury Department an-
ticipate that the final regulations under
§ 414(d) will apply prospectively and will
include a delayed effective date. The IRS
and Treasury Department anticipate that
the final regulations under § 414(d) will
provide that a State or local retirement
system that covers employees of a public
charter school that meets the requirements
of the guidance under consideration de-
scribed in section III.A of this notice for
periods starting on and after the effective
date of the final regulations will not fail to
be a governmental plan within the mean-
ing of § 414(d), even if the plan covered
those employees for periods before the
effective date of the final regulations
when the public charter school did not
meet the requirements of the guidance un-
der consideration described in section
III.A of this notice.
The guidance under consideration de-
scribed in section III.A of this notice
should not be construed to create any in-
ference concerning the proper interpreta-
tion of § 414(d) prior to the effective date
of final regulations under § 414(d).
B.Broader transition relief
The § 414(d) ANPRM requested com-
ments on whether safe harbors or transi-
tion relief, including grandfathering,
should be provided in the proposed regu-
lations. Some commenters suggested that
the proposed regulations grandfather re-
tirement plans that have received § 414(d)
private letter rulings from the IRS, while
other commenters advocated for full
grandfathering for employees of any en-
tity that has previously been a participat-
ing employer in a governmental plan.
Comments were also received requesting
that future guidance provide ade minimis
exception, create safe and unsafe harbors
for governmental plan determinations, im-
plement an extended period to come into
compliance with the requirements after
final regulations under § 414(d) are is-
sued, and provide the ability to correct a
§ 414(d) governmental plan under the
Employee Plans Compliance Resolution
System, Rev. Proc. 2013–12 (2013–4 IRB
313), if the plan is not in compliance with
final regulations under § 414(d). Com-
menters also pointed out that, in at least
some cases, state contractual or constitu-
tional protections may serve to restrict a
state’s ability to amend the plan provi-
sions that apply to certain participants.
The IRS and Treasury Department are in
the process of reviewing each of these
comments. It is expected that questions
regarding broader transition relief will be
addressed when proposed regulations are
issued under § 414(d) of the Code.
V. COMMENTS REQUESTED
Comments are requested regarding the
guidance under consideration that is de-
scribed in III.A of this notice. Comments
are also requested regarding whether the
requirements of the guidance under con-
sideration described in section III.A of
this notice are sufficient to limit the guid-
ance to participation of employees of pub-
lic charter schools in a State or local re-
tirement system and, for example, to not
cover participation of employees of enti-
ties that provide management or other ser-
vices to public charter schools. Written
comments should be submitted by May
11, 2015. Send submissions to CC:PA:
LPD:PR, (Notice 2015–07), Room 5203,
Internal Revenue Service, PO Box 7604,
February 9, 2015Bulletin No. 2015– 6
588

Ben Franklin Station, Washington, D.C.
20044. Comments may also be hand deliv-
ered Monday through Friday between the
hours of 8 a.m. and 4:00 p.m. to: Internal
Revenue Service, CC:PA:LPD:PR, (Notice
2015–07), Courier’s Desk, Internal Reve-
nue Service, 1111 Constitution Avenue,
N.W., Washington DC. Alternatively, com-
ments may be submitted via the Internet at
notice.comments@irscounsel.treas.gov
(Notice 2015–07). All comments will be
available for public inspection.
DRAFTING INFORMATION
The principal author of this notice is
Pamela R. Kinard of the Office of the
Division Counsel/Associate Chief Coun-
sel (Tax Exempt and Government Enti-
ties). For further information regarding
this notice, contact Ms. Kinard or Sarah
Bolen at (202) 317-6799 (not a toll-free
number).
Section 45R–2015
Guidance with Respect to
the Tax Credit for
Employee Health Insurance
Expenses of Certain Small
Employers
Notice 2015– 8
I. PURPOSE
This notice provides guidance on sec-
tion 45R of the Internal Revenue Code
(Code) for certain small employers that
cannot offer a qualified health plan (QHP)
through the Small Business Health Op-
tions Program (SHOP) Exchange because
the employer’s principal business address
is in a county in Iowa in which a QHP
through a SHOP Exchange will not be
available for all or part of 2015 calendar
year. Section IV of this notice includes a
list of those counties. With respect to
those employers in Iowa, this notice pro-
vides guidance on how to satisfy the re-
quirements for the section 45R credit for
coverage provided during the 2015 calen-
dar year and the portion of a health plan
year beginning in 2015, if any, that con-
tinues into 2016. (See Notice 2014–6,
2014 I.R.B. 279, for guidance on counties
in other states in which a QHP through a
SHOP Exchange might not be available
during 2014.)
II. BACKGROUND
Section 45R was added to the Code by
section 1421 of the Patient Protection and
Affordable Care Act, enacted March 23,
2010, Pub. L. No. 111–148. Section 45R
offers a tax credit to certain small employ-
ers that provide health insurance coverage
to their employees (eligible small employ-
ers). The credit generally is available for
taxable years beginning after December
31, 2009. For taxable years beginning af-
ter December 31, 2013, the credit is avail-
able only with respect to premiums paid
by a small employer for a QHP offered by
the employer to its employees through a
SHOP Exchange, and is available only for
a period of two-consecutive-taxable years.
Additionally, for taxable years beginning
after December 31, 2013, the maximum
credit rate is increased to 50 percent from
35 percent for eligible small employers
(and to 35 percent from 25 percent for
tax-exempt eligible small employers). An
eligible small employer may claim the
credit by filing an income tax return and
attaching Form 8941, “Credit for Small
Employer Health Insurance Premiums”
(or in the case of tax-exempt eligible
small employers, filing Form 990–T, “Ex-
empt Organization Business Income Tax
Return,” and attaching Form 8941).
The Treasury Department and the IRS
issued final regulations under section 45R
on June 30, 2014 (79 FR 36640). The
regulations provide guidance on determin-
ing eligibility for the credit and calculat-
ing and claiming the credit.
The Treasury Department and the IRS
have been advised by the Department of
Health and Human Services (HHS) that
for calendar year 2015 the SHOP Ex-
changes in Iowa will not have QHPs
available in certain counties for employers
to offer to their employees. Under HHS
regulations governing employer eligibility
for SHOP Exchanges, an employer may
either (1) offer coverage to all of its eli-
gible full-time employees through the
SHOP whose service area includes the
employer’s principal business address, or
(2) offer coverage to each eligible full-
time employee through the SHOP whose
service area includes that employee’s pri-
mary worksite. 45 CFR 155.710(b)(3).
Under either approach, an employer may
offer SHOP coverage to employees whose
primary worksite is at its principal busi-
ness address only if that address is located
within the service area of the SHOP. As a
result, absent the relief provided in this
notice, an otherwise eligible small em-
ployer with its principal business address
in a county without any QHPs available
would be denied the opportunity to claim
the section 45R credit for 2015. To pro-
vide these otherwise eligible small em-
ployers an opportunity to claim the sec-
tion 45R credit for 2015, this notice
provides relief for those employers for the
plan year of the employer’s group health
plan beginning in 2015, including any
portion of that plan year that continues
into 2016, with respect to employees
whose primary worksite is at the employ-
er’s principal business address.
On December 17, 2013, the Treasury
Department and the IRS issued Notice
2014–6, 2014–2 I.R.B. 279, which pro-
vided transition relief for employers in
certain counties in Washington and Wis-
consin with no SHOP coverage available
in 2014. The Treasury Department and the
IRS have determined that similar relief,
described in section III of this notice, is
appropriate for employers in certain coun-
ties in Iowa with no SHOP coverage
available in 2015. Nothing in this notice is
intended to modify or otherwise affect the
relief provided in Notice 2014–6.
III. 2015 RELIEF
An eligible small employer with a prin-
cipal business address in one of the coun-
ties listed in section IV below may calcu-
late the credit under section 45R by
treating health insurance coverage pro-
vided for the 2015 health plan year as
qualifying for the section 45R credit, pro-
vided that that the coverage would have
qualified for a credit under section 45R
under the rules applicable before January
1, 2014. This treatment applies with re-
spect to the coverage provided during the
2015 calendar year and during any portion
of a health plan year beginning in 2015
that continues into 2016. If the eligible
small employer claims the section 45R
credit for the 2015 taxable year, then the
credit will be calculated at the 50 percent
Bulletin No. 2015– 6February 9, 2015
589

rate (35 percent for tax-exempt eligible
small employers) for the entire 2015 tax-
able year. If the eligible small employer
first claims the section 45R credit for the
2015 taxable year, the 2015 taxable year
will be the first year of the two-
consecutive-taxable year credit period. If
the eligible small employer first claims the
section 45R credit for the 2014 taxable
year, then the 2015 taxable year will be
the second year of the two-consecutive-
taxable year credit period, regardless of
whether the eligible small employer takes
advantage of the relief in this notice re-
garding the credit for coverage provided
under the rules applicable before January
1, 2014.
The relief in this notice is illustrated
by the following examples. The exam-
ples assume that the employer is an el-
igible small employer that is not a tax-
exempt employer, and that its principal
business address is in a county listed in
this notice.
Example 1. (i)Facts. Employer does not claim
the credit for coverage provided for its 2014 taxable
year. Employer has a 2015 health plan year and a
2015 taxable year that both begin January 1, 2015,
and end December 31, 2015. Employer provides
health insurance coverage from January 1, 2015,
through December 31, 2015, that would have qual-
ified Employer for a credit under section 45R under
the rules applicable to taxable years beginning be-
fore January 1, 2014.
(ii)Conclusion. Employer may claim the credit
at the 50 percent rate under section 45R for coverage
provided for the entire 2015 taxable year. If Em-
ployer claims the credit for coverage provided for
the 2015 taxable year, the 2015 taxable year is the
first year of its two-consecutive-taxable year credit
period.
Example 2. (i)Facts. Employer does not claim
the credit for coverage provided for its 2014 taxable
year. Employer has a 2015 taxable year that begins
January 1, 2015, and ends December 31, 2015, and a
2015 health plan year that begins April 1, 2015, and
ends March 31, 2016. From April 1, 2015 through
December 31, 2015 (the initial months of its plan
year that begins April 1, 2015) and from January 1,
2016 through March 31, 2016, Employer provides
coverage that would have qualified Employer for a
credit under section 45R under the rules applicable
to taxable years beginning before January 1, 2014.
(ii)Conclusion. Employer may claim the credit
at the 50 percent rate under section 45R for coverage
provided from April 1, 2015 through December 31,
2015. Employer may also claim the credit under
section 45R for coverage provided for its 2016 tax-
able year from January 1, 2016 through March 31,
2016 (in addition to any credit under section 45R for
which Employer is eligible based on coverage pro-
vided from April 1 through December 31 of the 2016
taxable year).
Example 3. (i)Facts. Employer has a 2015 tax-
able year that begins January 1, 2015 and ends
December 31, 2015, and a 2015 health plan year that
begins May 1, 2015 and ends April 30, 2016. Em-
ployer provided coverage through a SHOP plan for
2014 and qualifies for, and claims, the credit for
2014. In 2015, Employer provides coverage through
a SHOP plan for January 2015. Beginning February
1 and through April 30, 2015, Employer provides
coverage with a policy for the remainder of the plan
year that would have qualified Employer for a credit
under section 45R under the rules applicable to tax-
able years beginning before January 1, 2014. From
May 1, 2015, through December 31, 2015 (the initial
months of its plan year that begins May 1, 2015), and
from January 1, 2016, through April 30, 2016, Em-
ployer provides coverage that would have qualified
Employer for a credit under section 45R under the
rules applicable to taxable years beginning before
January 1, 2014.
(ii)Conclusion. Employer may claim the credit
at the 50 percent rate under section 45R for coverage
provided from January 1, 2015, through December
31, 2015. Employer may not claim the credit under
section 45R for coverage provided for its 2016 tax-
able year because its two-consecutive-taxable year
period ends with 2015.
IV. LIST OF IOWA COUNTIES
Adair, Adams, Appanoose, Audubon,
Benton, Black Hawk, Boone, Bremer, Bu-
chanan, Buena Vista, Butler, Calhoun,
Carroll, Cass, Cedar, Cerro Gordo, Cher-
okee, Chickasaw, Clarke, Clinton, Craw-
ford, Dallas, Davis, Decatur, Delaware,
Des Moines, Dubuque, Floyd, Franklin,
Fremont, Greene, Grundy, Guthrie, Ham-
ilton, Hancock, Hardin, Harrison, Henry,
Humboldt, Iowa, Jackson, Jasper, Jeffer-
son, Johnson, Jones, Keokuk, Kossuth,
Lee, Linn, Louisa, Lucas, Madison, Ma-
haska, Marion, Marshall, Mills, Mitchell,
Monona, Monroe, Montgomery, Musca-
tine, Page, Palo Alto, Pocahontas, Polk,
Pottawattamie, Poweshiek, Ringgold, Sac,
Scott, Shelby, Story, Tama, Taylor,
Union, Van Buren, Wapello, Warren,
Washington, Wayne, Webster, Winne-
bago, Worth, Wright.
V. EFFECTIVE DATE
This notice is effective as of January
16, 2015 and applies to periods after
December 31, 2014.
DRAFTING INFORMATION
The principal author of this notice is
Stephanie Caden of the Office of Division
Counsel/Associate Chief Counsel (Tax
Exempt and Government Entities). For
further information regarding this notice
contact Stephanie Caden at (202) 317-
5500 (not a toll-free number).
PENALTY RELIEF RELATED
TO ADVANCE PAYMENTS
OF THE PREMIUM TAX
CREDIT FOR 2014
Notice 2015–9
Purpose
This Notice provides limited relief for
taxpayers who have a balance due on their
2014 income tax return as a result of rec-
onciling advance payments of the pre-
mium tax credit against the premium tax
credit allowed on the tax return. Specifi-
cally, this Notice provides relief from the
penalty under § 6651(a)(2) of the Internal
Revenue Code for late payment of a bal-
ance due and the penalty under § 6654(a)
for underpayment of estimated tax. To
qualify for the relief, taxpayers must meet
certain requirements described below.
This relief applies only for the 2014 tax-
able year.
This relief does not apply to any un-
derpayment of the individual shared re-
sponsibility payment resulting from the
application of § 5000A because such un-
derpayments are not subject to either the
§ 6651(a)(2) penalty or the § 6654(a) pen-
alty.
Background
Section 6651(a)(2) imposes a penalty
on a failure to pay (on or before the due
date for payment, including any exten-
sion of time for payment) an amount
shown as tax on any return. However,
the § 6651(a)(2) penalty is not imposed if
the taxpayer shows that the failure was
due to reasonable cause and not willful
neglect. In general, individuals must pay
the tax shown on the return by April 15.
Section 6654(a) imposes a penalty in
the case of an underpayment of estimated
tax by an individual. Generally, taxpayers
are required to make tax payments on
non-wage income in quarterly install-
ments. An underpayment of estimated tax
is the excess of the required quarterly es-
timated tax payment over the amount ac-
tually paid on or before the due date for
February 9, 2015Bulletin No. 2015– 6
590

the payment. Most taxpayers will avoid
this penalty if they owe less than $1,000 in
tax on their 2014 income tax return after
subtracting their withholding, or if their
withholding and estimated taxes total at
least 90% of the tax for taxable year
2014, or 100% of the tax shown on their
2013 taxable year return. Additionally,
§ 6654(e)(3) authorizes the Internal Rev-
enue Service (the Service) to waive the
§ 6654(a) penalty for underpayments of
estimated tax in unusual circumstances to
the extent its imposition would be against
equity and good conscience.
Beginning in 2014, an eligible individ-
ual covered, or whose family member is
covered, under a qualified health plan
through an Affordable Insurance Ex-
change (Exchange), also called a Health
Insurance Marketplace, is allowed a pre-
mium tax credit under § 36B.
Section 1412 of the Patient Protection
and Affordable Care Act, Pub. L. No.
111–148, 124 Stat. 119, and the Health
Care and Education Reconciliation Act of
2010, Pub. L. No. 111–152, 124 Stat.
1029, provides that a taxpayer may re-
ceive assistance in paying premiums for
coverage in a qualified health plan
through advance payments of the pre-
mium tax credit. Advance credit payments
are made directly to the insurance pro-
vider. The amount of the advance credit
payments is determined when an individ-
ual enrolls in a qualified health plan
through an Exchange and is based on pro-
jected household income and family size
for the year of coverage.
A taxpayer claims the premium tax
credit on the income tax return for the
taxable year of coverage. The amount of
the credit is based on actual household
income and family size for the year re-
flected on the tax return. Under
§ 36B(f)(2) and § 1.36B–4(a)(1)(i) of the
Income Tax Regulations, a taxpayer must
reconcile, or compare, the amount of pre-
mium tax credit allowed on the tax return
with advance credit payments. Changes in
the circumstances on which the advance
credit payments are based could result in a
difference between the amount of advance
credit payments and the premium tax
credit to which the taxpayer is entitled. If
advance credit payments are more than
the premium tax credit allowed on the
return, the difference (excess advance
payments) is treated as additional tax and
may result in either a smaller refund or a
larger balance due (or, if the premium tax
credit allowed is more than the advance
credit payments made, the excess credit
amount may result in a larger refund or
lower balance due). Taxable year 2014 is
the first year for which taxpayers will be
required to reconcile advance credit pay-
ments with the premium tax credit.
Penalty Relief for 2014
Some taxpayers who have a balance
due on their 2014 income tax returns at-
tributable to the reconciliation of their ad-
vance credit payments and the premium
tax credit calculated on their returns may
not be able to pay by the due date for
payment, generally April 15. Taxpayers
who do not pay their entire tax liability by
the due date for payment generally would
be liable for the § 6651(a)(2) penalty for
failure to pay, unless they requested and
were granted relief due to reasonable
cause. Additionally, some taxpayers may
discover when they reconcile advance
credit payments with the premium tax
credit that their estimated tax payments
were understated, potentially making
these taxpayers liable for the § 6654(a)
estimated tax penalty. Therefore, in con-
sideration of these factors, and consistent
with the authority in § 6651(a)(2) and
§ 6654(e)(3) to provide relief from penal-
ties for taxpayers, this Notice provides
relief from the § 6651(a)(2) and § 6654(a)
penalties for taxpayers who satisfy the
requirements in this Notice.
Pursuant to this Notice, the Service
will abate the § 6651(a)(2) penalty for
taxable year 2014 for taxpayers who (i)
are otherwise current with their filing and
payment obligations; (ii) have a balance
due for the 2014 taxable year due to ex-
cess advance payments of the premium
tax credit; and (iii) report the amount of
excess advance credit payments on their
2014 tax return timely filed, including ex-
tensions (Line 46 of Form 1040 or Line 29
of Form 1040A).
Further, the Service will waive the
§ 6654 penalty for taxable year 2014 for
an underpayment of estimated tax for tax-
payers who have an underpayment attrib-
utable to excess advance credit payments
if the taxpayers (i) are otherwise current
with their filing and payment obligations;
and (ii) report the amount of the excess
advance credit payments on a 2014 tax
return timely filed, including extensions.
For purposes of this Notice, taxpayers
will be treated as current with their filing
and payment obligations if as of the date
they file their 2014 income tax returns,
they (i) have filed, or filed an extension
for, all currently required federal tax re-
turns, and (ii) paid or have entered into an
installment agreement (which is not in
default), an offer in compromise, or both
to satisfy a federal tax liability. If a tax-
payer has not paid a tax due because there
is a genuine dispute between the taxpayer
and the Service that has not been finally
determined as to the existence or amount
of the correct tax liability under the law,
then the amount of tax in dispute will be
treated as being current during the pen-
dency of the dispute.
Taxpayers should be aware that this
Notice does not extend the time to file a
return. To obtain an automatic extension
of time to file, a taxpayer should file Form
4868, “Application for Automatic Exten-
sion of Time to File U.S. Individual In-
come Tax Return,” on or before April 15,
2015. Additionally, § 6601 imposes inter-
est on amounts of tax not paid by the due
date, determined without regard to an ex-
tension of time for payment. Taxpayers
will be required to pay interest on the
balance due from the original deadline to
pay, which is generally April 15, 2015,
even if they qualify for penalty relief un-
der this Notice. Nothing in this Notice
affects the ability of a taxpayer to claim
relief based on existing law and proce-
dures.
Procedure for Claiming Penalty Relief
Requesting relief from the failure to pay
penalty
Generally, the Service automatically
assesses the § 6651(a)(2) penalty against
taxpayers and sends a notice demanding
payment. When responding to such a no-
tice, taxpayers should submit a letter to
the address listed in the notice that con-
tains the statement: “I am eligible for the
relief granted under Notice 2015–9 be-
cause I received excess advance payment
of the premium tax credit.”
Taxpayers who file their returns by
April 15, 2015 will be entitled to relief
Bulletin No. 2015– 6February 9, 2015
591

under this Notice even if they have not
fully paid the underlying liability by the
time they request relief.
Taxpayers who file their returns after
April 15, 2015 must fully pay the under-
lying liability by April 15, 2016 to be
eligible for relief under this Notice.
Interest will accrue until the underly-
ing liability is fully paid. See Publica-
tion 4849,Can’t Pay the Tax You Owe?,
for further information on how to pay
your past due federal income tax
liability.
Requesting relief from the estimated tax
penalty
To request a waiver of the § 6654(a)
penalty as provided in this Notice, taxpay-
ers should check box A in Part II of Form
2210, complete page 1 of the form, and
include the form with their return, along
with the statement: “Received excess ad-
vance payment of the premium tax
credit.” Taxpayers do not need to attach
documentation from the Exchange, ex-
plain the circumstances under which they
received an excess advance payment, or
complete any page other than page 1 of
the Form 2210. Taxpayers also do not
need to figure the amount of penalty for
the penalty to be waived.
Contact Information
The principal author of this Notice is
Danielle W. Pierce of the Office of As-
sociate Chief Counsel (Procedure & Ad-
ministration). For further information
regarding this Notice, contact Danielle
Pierce at (202) 317-6845 (not a toll-free
number).
February 9, 2015Bulletin No. 2015– 6
592

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2015– 6February 9, 2015
i

Numerical Finding List
1
Bulletin 2015–1 through 2015–6
Announcements:
2015-2, 2015-3 I.R.B.324
2015-3, 2015-3 I.R.B.328
2015-4, 2015-5 I.R.B.565
Proposed Regulations:
REG-109187-11, 2015-2 I.R.B.277
REG-132751-14, 2015-2 I.R.B.279
REG-145878-14, 2015-2 I.R.B.290
REG-153656-3, 2015-5 I.R.B.566
Notices:
2015-1, 2015-2 I.R.B.249
2015-2, 2015-4 I.R.B.334
2015-3, 2015-6 I.R.B.583
2015-4, 2015-5 I.R.B.407
2015-5, 2015-5 I.R.B.408
2015-6, 2015-5 I.R.B.412
2015-7, 2015-6 I.R.B.585
2015-8, 2015-6 I.R.B.589
2015-9, 2015-6 I.R.B.590
Revenue Procedures:
2015-1, 2015-1 I.R.B.1
2015-2, 2015-1 I.R.B.105
2015-3, 2015-1 I.R.B.129
2015-4, 2015-1 I.R.B.144
2015-5, 2015-1 I.R.B.186
2015-6, 2015-1 I.R.B.194
2015-7, 2015-1 I.R.B.231
2015-8, 2015-1 I.R.B.235
2015-9, 2015-2 I.R.B.249
2015-10, 2015-2 I.R.B.261
2015-12, 2015-2 I.R.B.265
2015-13, 2015-5 I.R.B.419
2015-14, 2015-5 I.R.B.450
2015-15, 2015-5 I.R.B.564
Revenue Rulings:
2015-1, 2015-4 I.R.B.331
2015-2, 2015-3 I.R.B.321
2015-3, 2015-6 I.R.B.580
Treasury Decisions:
9707, 2015-2 I.R.B.247
9708, 2015-5 I.R.B.337
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014–27 through 2014–52 is in Internal Revenue Bulletin
2014–52, dated December 28, 2014.
February 9, 2015Bulletin No. 2015– 6
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2015–1 through 2015–6
Announcements
2010-3
Amplified by
Ann. 2015-3, 2015-3 I.R.B.328
Revenue Procedures
2014-01
Superseded by
Rev. Proc. 2015-01, 2015-01 I.R.B.1
2014-02
Superseded by
Rev. Proc. 2015-02, 2015-01 I.R.B.105
2014-03
Superseded by
Rev. Proc. 2015-03, 2015-01 I.R.B.129
2014-04
Superseded by
Rev. Proc. 2015-04, 2015-01 I.R.B.144
2014-05
Superseded by
Rev. Proc. 2015-05, 2015-01 I.R.B.186
2014-06
Superseded by
Rev. Proc. 2015-06, 2015-01 I.R.B.194
2014-07
Superseded by
Rev. Proc. 2015-07, 2015-01 I.R.B.231
2014-08
Superseded by
Rev. Proc. 2015-08, 2015-01 I.R.B.235
2014-10
Superseded by
Rev. Proc. 2015-10, 2015-2 I.R.B.261
2003-63
Superseded by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-12, 2015-2 I.R.B.265
2011-14
Modified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
Revenue Procedures—Continued
2011-14
Amplified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
2011-14
Clarified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
1997-27
Clarified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
1997-27
Modified by
Rev. Proc. 2015-13, 2015-5 I.R.B.419
Revenue Rulings
92-19
Supplemented by
Rev. Rul. 2015-02, 2015-3 I.R.B.321
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014–27 through 2014–52 is in Internal Revenue Bulletin 2014–52, dated December 28,
2014.
Bulletin No. 2015– 6February 9, 2015
iii

INTERNAL REVENUE BULLETIN
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