Internal Revenue Bulletin 2014-18 (PDF rendition): IRS Notices

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Announcement 2014–17, page 1001.
Announcement 2014 –17 provides guidance to foreign financial
institutions (FFIs) in jurisdictions that have not signed an inter-
governmental FATCA agreement, but that have reached an
agreement in substance with the United States on the terms of
an IGA. Announcement 2014 –17 also provides that the GIIN of
a registering FFI will be included on the June 2 IRS FFI List if the
FFI’s registration is finalized by May 5, 2014, rather than April
25, 2014, as originally announced In addition, Announcement
2014 –17 provides that the GIIN of a registering FFI will be
included on the July 1 FFI List if the FFI’s registration is finalized
by June 3, 2014.
Notice 2014–28, page 990.
This notice provides guidance regarding the treatment of
United States persons that own stock of a PFIC through certain
tax exempt organization and accounts.
Notice 2014–29, page 991.
This notice provides adjusted limitations on housing expenses
for tax year 2014 for purpose of sections 911 of the code.
This notice supersedes Notice 2006 – 87, 2006 –2 C.B. 766,
Notice 2007–25, 2007–1 C.B. 760, Notice 2007–77, 2007–2
C.B. 735, Notice 2008 –107, 2008 –2 C.B. 1266, Notice
2010 –27, 2010 –1 C.B. 531, Notice 2011– 8, 2011–1 C.B.
503,Notice 2012–19, 2012–1 C.B. 440, and Notice 2013–31,
2013–1 C.B. 1099.
EMPLOYEE PLANS
Notice 2014–27, page 987.
This notice contains updates for the corporate bond weighted
average interest rate for plan years beginning in April 2014;
the 24-month average segment rates; the funding segment
rates applicable for April 2014; and the minimum present value
rates for March 2014. The rates in this notice reflect certain
changes implemented by the Moving Ahead for Progress in the
21st Century Act, Public Law 112–141 (MAP–21).
Finding Lists begin on page ii.
Index for July through April begins on page iv.
Bulletin No. 2014–18
April 28, 2014

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
April 28, 2014Bulletin No. 2014–18

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Update for Weighted Average
Interest Rates, Yield Curves,
and Segment Rates
Notice 2014–27
This notice provides guidance on the
corporate bond monthly yield curve (and
the corresponding spot segment rates),
and the 24-month average segment rates
under § 430(h)(2) of the Internal Revenue
Code. In addition, this notice provides guid-
ance as to the interest rate on 30-year Trea-
sury securities under § 417(e)(3)(A)(ii)(II)
as in effect for plan years beginning be-
fore 2008, the 30-year Treasury weighted
average rate under § 431(c)(6)(E)(ii)(I),
and the minimum present value segment
rates under § 417(e)(3)(D) as in effect for
plan years beginning after 2007. These
rates reflect certain changes implemented
by the Moving Ahead for Progress in the
21st Century Act, Public Law 112–141
(MAP–21). MAP–21 provides that for
purposes of § 430(h)(2), the segment rates
are limited by the applicable maximum
percentage or the applicable minimum
percentage based on the average of seg-
ment rates over a 25 year period.
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006, § 430 of the Code
specifies the minimum funding require-
ments that apply to single employer plans
pursuant to § 412. Section 430(h)(2) spec-
ifies the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods. To
the extent provided under § 430(h)(2)(C)(iv),
these segment rates are adjusted by the
applicable percentage of the 25-year aver-
age segment rates for the period ending
September 30 of the year preceding the
calendar year in which the plan year be-
gins. However, an election may be made
under § 430(h)(2)(D)(ii) to use the
monthly yield curve in place of the seg-
ment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Pursuant
to Notice 2007– 81, the monthly corporate
bond yield curve derived from March
2014 data is in Table I at the end of this
notice. The spot first, second, and third
segment rates for the month of March
2014 are, respectively, 1.23, 4.23, and
5.31. For plan years beginning on or after
January 1, 2012, the 24-month average
segmentratesdeterminedunder
§ 430(h)(2)(C)(iv) must be adjusted by the
applicable percentage of the correspond-
ing 25-year average segment rates. The
25-year average segment rates for plan
years beginning in 2012, 2013, and 2014
were published in Notice 2012–55,
2012–36 I.R.B. 332, Notice 2013–11,
2013–11 I.R.B. 610, and Notice 2013–58,
2013– 40 I.R.B. 294, respectively. The
three 24-month average corporate bond
segment rates applicable for April 2014
without adjustment, and the adjusted 24-
month average segment rates taking into
account the applicable percentages of the
corresponding 25-year average segment
rates, are as follows:
For Plan
Years
Beginning
In
24-Month Average Segment
Rates Not Adjusted
Adjusted 24-Month Average
Segment Rates, Based on Applicable
Percentage of 25-Year Average Rates
Applicable
Month
First
Segment
Second
Segment
Third
Segment
First
Segment
Second
Segment
Third
Segment
2013April20141.194.065.114.946.156.76
2014April20141.194.065.114.435.626.22
30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation de-
scribed in section 431(c)(6)(A), based on
theplan’scurrentliability.Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 per-
cent below the weighted average of the
rates of interest on 30-year Treasury se-
curities during the four-year period ending
on the last day before the beginning of the
plan year. Notice 88 –73, 1988 –2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for March 2014 is 3.62 percent. The
Service has determined this rate as the
average of the daily determinations of
yield on the 30-year Treasury bond ma-
turing in February 2044. The following
rates were determined for plan years be-
ginning in the month shown below.
Bulletin No. 2014–18April 28, 2014
987

For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
April20143.443.103.62
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for March 2014 are
as follows:
First
Segment
Second
Segment
Third
Segment
1.234.235.31
DRAFTING INFORMATION
The principal author of this notice is
Tony Montanaro of the Employee Plans,
Tax Exempt and Government Entities Di-
vision. Mr. Montanaro may be e-mailed at
RetirementPlanQuestions@irs.gov.
April 28, 2014Bulletin No. 2014–18
988

Table I
Monthly Yield Curve for December 2014
Derived from December 2014 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.50.2620.55.0040.55.3460.55.4780.55.53
1.00.4321.05.0241.05.3561.05.4781.05.53
1.50.6221.55.0341.55.3561.55.4781.55.53
2.00.8322.05.0542.05.3662.05.4782.05.53
2.51.0722.55.0642.55.3662.55.4782.55.53
3.01.3223.05.0743.05.3763.05.4883.05.53
3.51.5823.55.0943.55.3763.55.4883.55.53
4.01.8324.05.1044.05.3764.05.4884.05.53
4.52.0824.55.1144.55.3864.55.4884.55.53
5.02.3125.05.1245.05.3865.05.4885.05.54
5.52.5425.55.1345.55.3865.55.4885.55.54
6.02.7526.05.1446.05.3966.05.4986.05.54
6.52.9526.55.1546.55.3966.55.4986.55.54
7.03.1327.05.1647.05.3967.05.4987.05.54
7.53.3127.55.1747.55.4067.55.4987.55.54
8.03.4728.05.1848.05.4068.05.4988.05.54
8.53.6228.55.1948.55.4068.55.4988.55.54
9.03.7629.05.2049.05.4169.05.5089.05.54
9.53.8929.55.2149.55.4169.55.5089.55.54
10.04.0030.05.2250.05.4170.05.5090.05.55
10.54.1130.55.2250.55.4270.55.5090.55.55
11.04.2131.05.2351.05.4271.05.5091.05.55
11.54.3031.55.2451.55.4271.55.5091.55.55
12.04.3832.05.2552.05.4372.05.5092.05.55
12.54.4532.55.2552.55.4372.55.5192.55.55
13.04.5233.05.2653.05.4373.05.5193.05.55
13.54.5833.55.2753.55.4373.55.5193.55.55
14.04.6334.05.2754.05.4474.05.5194.05.55
14.54.6834.55.2854.55.4474.55.5194.55.55
15.04.7235.05.2955.05.4475.05.5195.05.55
15.54.7635.55.2955.55.4475.55.5195.55.56
16.04.8036.05.3056.05.4576.05.5296.05.56
16.54.8336.55.3056.55.4576.55.5296.55.56
17.04.8637.05.3157.05.4577.05.5297.05.56
17.54.8837.55.3257.55.4577.55.5297.55.56
18.04.9138.05.3258.05.4578.05.5298.05.56
18.54.9338.55.3358.55.4678.55.5298.55.56
19.04.9539.05.3359.05.4679.05.5299.05.56
19.54.9739.55.3459.55.4679.55.5299.55.56
20.04.9940.05.3460.05.4680.05.53100.05.56
Bulletin No. 2014–18April 28, 2014
989

Treatment of United States
Persons that Own Stock of
Passive Foreign Investment
Companies Through Certain
Organizations and Accounts
that Are Tax Exempt
Notice 2014–28
SECTION 1. PURPOSE
This notice announces that the Depart-
ment of the Treasury (Treasury Depart-
ment) and the Internal Revenue Service
(IRS) will amend the regulations under
section 1291 of the Internal Revenue
Code (Code) to provide guidance con-
cerning the treatment of United States per-
sons (U.S. persons) that own stock of a
passiveforeigninvestmentcompany
within the meaning of section 1297(a)
(PFIC) through: an organization or an ac-
count that is exempt from tax under sec-
tion 501(a) because it is described in sec-
tion 501(c), 501(d), or 401(a); a state
college or university described in section
511(a)(2)(B); a plan described in section
403(b) or 457(b); an individual retirement
plan or annuity as defined in section
7701(a)(37); or a qualified tuition pro-
gram described in section 529 or 530.
SECTION 2. BACKGROUND
.01 Sections 1291 and 1298
Section 1291 imposes a special tax and
interest charge on a U.S. person that is a
shareholder of a PFIC and receives an
excess distribution (within the meaning of
section 1291(b)) from the PFIC or recog-
nizes gain derived from a disposition of
the PFIC that is treated as an excess dis-
tribution (within the meaning of section
1291(a)(2)). Section 1298(a) sets forth at-
tribution rules that treat a U.S. person as
the owner of PFIC stock that is owned by
another person. The section 1298(a) attri-
bution rules will not apply to treat stock
owned (or treated as owned) by a U.S.
person as owned by any other person,
except to the extent provided in regula-
tions. Section 1298(a)(1)(B). Section
1298(f) provides that a U.S. person that is
a shareholder of a PFIC must file an an-
nual report containing the information re-
quired by the Secretary. Section 1298(g)
provides that the Secretary shall provide
such regulations as may be necessary or
appropriate to carry out the purposes of
sections 1291 through 1298.
.02 Regulations under Sections 1291 and
1298
On December 31, 2013, the Treasury
Department and the IRS published tempo-
rary and proposed regulations under sec-
tions 1291 and 1298 (2014 –3 I.R.B. 394)
that defined the terms shareholder and in-
direct shareholder for purposes of section
1291. See § 1.1291–1T(b)(7) and (8).
These definitions are cross-referenced in
the definition of shareholder and indirect
shareholder in the section 1298(f) infor-
mation reporting regulations, as well as in
other PFIC regulations. See §§ 1.1291–
9T(j) 1.1298 –1T(a). Under § 1.1291–
1T(b)(7), the term shareholder means any
U.S. person that owns stock of a PFIC
directly or indirectly. Section 1.1291–
1T(b)(8) defines the term indirect share-
holder as a U.S. person that indirectly
owns stock of a PFIC, and provides rules
for attributing ownership of PFIC stock
through domestic and foreign corpora-
tions, partnerships, S corporations, es-
tates, and trusts. For example, § 1.1291–
1T(b)(8)(iii)(C)provides that, in general,
each beneficiary of a foreign or domestic
nongrantor trust that directly or indirectly
owns stock of a PFIC is considered to own
a proportionate amount of the PFIC stock
and, thus, each beneficiary that is a U.S. per-
son is an indirect shareholder of the PFIC.
.03 Tax Exempt Organizations
In general, § 1.1291–1(e) provides that
section 1291 applies to a PFIC share-
holder that is an organization exempt from
tax under chapter 1 of the Code only if a
dividend from the PFIC owned by the
organization would be taxable to the or-
ganization under subchapter F of Subtitle
A of the Code (sections 501 through 530)
(subchapter F). Section 1.1298 –1T(c)(1)
provides that a PFIC shareholder that is an
organization exempt from tax under sec-
tion 501(a) because it is described in sec-
tion 501(c), 501(d), or 401(a), a state col-
lege or university described in section
511(a)(2)(B), a plan described in section
403(b) or 457(b), an individual retirement
plan or annuity as defined in section
7701(a)(37), or a qualified tuition program
described in section 529 or 530 (each a tax
exempt organization or account) is re-
quired to file an annual report under sec-
tion 1298(f) with respect to a PFIC only if
income derived with respect to the PFIC
would be taxable to the organization or
account under subchapter F.
Neither the Code nor the section 1291
regulations provide specific guidance on the
application of section 1291 to a U.S. person
that owns stock of a PFIC through a tax
exempt organization or account, other than
an employees’ trust described in section
401(a) that is exempt from tax under section
501(a) (section 401(a) trust). The attribution
rules that generally apply to treat a U.S.
beneficiary of a nongrantor trust as owning
PFIC stock owned by the trust do not apply
to a U.S. person that owns an interest in a
section 401(a) trust. § 1.1291–1T(b)(8)(iii)(C).
Thus, a U.S. person that is a beneficiary of
a section 401(a) trust is not treated as an
indirect shareholder with respect to any
PFIC stock held by the trust for purposes
of section 1291.
Although § 1.1291–1(e) provides that or-
ganizationsexemptfromtaxunder
chapter 1 of the Code generally are not
subject to section 1291 with respect to their
direct or indirect ownership of PFIC stock, a
U.S. person that is a beneficiary of or has an
interest in a tax exempt organization or ac-
count may be treated as a direct or indirect
shareholder of the PFIC stock owned by the
organization or account under § 1.1291–
1T(b)(7) and (8), and thus may be subject to
taxation under section 1291.
SECTION 3. TREATMENT OF U.S.
PERSONS THAT OWN STOCK OF A
PFIC THROUGH CERTAIN
ORGANIZATIONS AND ACCOUNTS
THAT ARE TAX EXEMPT
The Treasury Department and the IRS
believe that the application of the PFIC
rules to a U.S. person treated as owning
stock of a PFIC through a tax exempt
organization or account described in
§ 1.1298 –1T(c)(1) would be inconsistent
with the tax policies underlying the PFIC
rules and the tax provisions applicable to
tax exempt organizations and accounts.
For example, applying the PFIC rules to a
U.S. person that is treated as a shareholder
of a PFIC through the U.S. person’s own-
ership of an individual retirement account
(IRA) described in section 408(a) that
April 28, 2014Bulletin No. 2014–18
990

owns stock of a PFIC would be inconsis-
tent with the principle of deferred taxation
provided by IRAs. Accordingly, the Trea-
sury Department and the IRS will amend
the definition of shareholder in the section
1291 regulations to provide that a U.S.
person that owns stock of a PFIC through
a tax exempt organization or account (as
described in § 1.1298 –1T(c)(1)) is not
treated as a shareholder of the PFIC. This
amendment will affect all regulations that
cross-reference the § 1.1291–1T(b)(7) and
(8) definitions of shareholder and indirect
shareholder, including § 1.1298 –1T(a).
SECTION 4. EFFECTIVE DATE
The regulations incorporating the guid-
ance described in this notice will be effec-
tive for taxable years of U.S. persons that
own stock of a PFIC through a tax exempt
organization or account ending on or after
December 31, 2013.
SECTION 5. DRAFTING
INFORMATION
The principal author of this notice is
Susan E. Massey of the Office of Associ-
ate Chief Counsel (International). For fur-
ther information regarding this notice con-
tact Susan Massey at (202) 317-6934 (not
a toll-free number).
Determination of Housing
Cost Amounts Eligible for
Exclusion or Deduction for
2014
Notice 2014–29
SECTION 1. PURPOSE
This notice provides adjustments to the
limitation on housing expenses for pur-
poses of section 911 of the Internal Rev-
enue Code (Code) for specific locations
for 2014. These adjustments are made on
the basis of geographic differences in
housing costs relative to housing costs in
the United States.
SECTION 2. BACKGROUND
Section 911(a) of the Code allows a
qualified individual to elect to exclude
from gross income the foreign earned in-
come and housing cost amount of such
individual. Section 911(c)(1) defines the
term “housing cost amount” as an amount
equal to the excess of (A) the housing
expenses of an individual for the taxable
year to the extent such expenses do not
exceed the amount determined under sec-
tion 911(c)(2), over (B) 16 percent of the
exclusion amount (computed on a daily
basis) in effect under section 911(b)(2)(D)
for the calendar year in which such tax-
able year begins ($271.78 per day for
2014, or $99,200 for the full year),
multiplied by the number of days of that
taxable year within the applicable period
described in section 911(d)(1). The appli-
cable period is the period during which
the individual meets the tax home require-
ment of section 911(d)(1) and either the
bona fide residence requirement of section
911(d)(1)(A) or the physical presence re-
quirement of section 911(d)(1)(B). As-
suming that the entire taxable year of a
qualified individual is within the applicable
period, the section 911(c)(1)(B) amount for
2014 is $15,872 ($99,200 x .16).
Section 911(c)(2)(A) of the Code lim-
its the housing expenses taken into ac-
count in section 911(c)(1)(A) to an
amount equal to (i) 30 percent (adjusted as
may be provided under the Secretary’s
authority under section 911(c)(2)(B)) of
the amount in effect under section
911(b)(2)(D) for the calendar year in
which the taxable year of the individual
begins, multiplied by (ii) the number of
days of that taxable year within the appli-
cableperioddescribedinsection
911(d)(1).Thus, under this general limita-
tion, a qualified individual whose entire tax-
able year is within the applicable period is
limited to maximum housing expenses of
$29,760 ($99,200 x .30) in 2014.
Section 911(c)(2)(B) of the Code au-
thorizes the Secretary to issue regulations
or other guidance to adjust the percentage
under section 911(c)(2)(A)(i) based on
geographic differences in housing costs
relative to housing costs in the United
States. Pursuant to this authority, the In-
ternal Revenue Service (IRS) and the
Treasury Department published Notice
2006 – 87, 2006 –2 C.B. 766, and Notice
2007–25, 2007–1 C.B. 760, for 2006, No-
tice 2007–77, 2007–2 C.B. 735, for 2007,
Notice 2008 –107, 2008 –2 C.B. 1266, for
2008 and 2009, Notice 2010 –27, 2010 –1
C.B. 531, for 2009 and 2010, Notice
2011– 8, 2011–1 C.B. 503, for 2010 and
2011, Notice 2012–19, 2012–1 C.B. 440
for 2011 and 2012, and Notice 2013–31,
2013–1 C.B. 1099, for 2012 and 2013, to
provide adjustments to the limitation on
housing expenses for qualified individuals
incurring housing expenses in countries
with high housing costs relative to hous-
ing costs in the United States.
SECTION 3. TABLE OF ADJUSTED
LIMITATIONS FOR 2014
The following table provides adjusted
limitations on housing expenses (in lieu of
the otherwise applicable limitation of
$29,760) for 2014.
CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
AngolaLuanda84,000230.14
ArgentinaBuenos Aires56,500154.79
AustraliaAdelaide29,90081.92
AustraliaDarwin, Northern Country30,60083.84
AustraliaMelbourne37,800103.56
AustraliaPerth40,400110.68
Bulletin No. 2014–18April 28, 2014
991

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
AustraliaSydney32,78289.81
AustriaVienna35,40096.99
Bahamas, TheGrand Bahama Island30,90084.66
Bahamas, TheNassau49,700136.16
BahrainBahrain44,000120.55
BarbadosBarbados37,700103.29
BelgiumAntwerp36,600100.27
BelgiumBrussels49,000134.25
BelgiumGosselies43,800120.00
BelgiumHoogbuul36,600100.27
BelgiumMons43,800120.00
BelgiumSHAPE/Chievres43,800120.00
BermudaBermuda90,000246.58
Bosnia-HerzegovinaSarajevo31,30085.75
BrazilBrasilia41,100112.60
BrazilRio de Janeiro35,10096.16
BrazilSao Paulo56,600155.07
CanadaCalgary44,200121.10
CanadaDartmouth36,700100.55
CanadaEdmonton35,10096.16
CanadaHalifax36,700100.55
CanadaLondon, Ontario30,00082.19
CanadaMontreal56,500154.79
CanadaOttawa50,600138.63
CanadaQuebec42,900117.53
CanadaToronto52,400143.56
CanadaVancouver46,500127.40
CanadaVictoria33,20090.96
CanadaWinnipeg31,70086.85
Cayman IslandsGrand Cayman48,000131.51
ChileSantiago50,400138.08
ChinaBeijing71,200195.07
ChinaHong Kong114,300313.15
ChinaShanghai57,001156.17
ColombiaBogota58,700160.82
ColombiaAll cities other than Bogota49,400135.34
Costa RicaSan Jose32,00087.67
DenmarkCopenhagen43,704119.74
Dominican RepublicSanto Domingo45,500124.66
EcuadorGuayaquil30,80084.38
EcuadorQuito37,500102.74
EstoniaTallinn46,600127.67
FranceGarches86,000235.62
FranceLe Havre34,70095.07
FranceLyon47,700130.68
April 28, 2014Bulletin No. 2014–18
992

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
FranceMarseille46,400127.12
FranceMontpellier38,400105.21
FranceParis86,000235.62
FranceSevres86,000235.62
FranceSuresnes86,000235.62
FranceVersailles86,000235.62
GermanyBabenhausen42,200115.62
GermanyBad Aibling36,00098.63
GermanyBad Nauheim33,70092.33
GermanyBaumholder40,800111.78
GermanyBerlin51,500141.10
GermanyBirkenfeld40,800111.78
GermanyBoeblingen51,200140.27
GermanyBonn42,000115.07
GermanyButzbach33,00090.41
GermanyCologne56,200153.97
GermanyDarmstadt42,200115.62
GermanyFrankfurt am Main44,000120.55
GermanyFriedberg33,70092.33
GermanyGarmisch-Partenkirchen39,000106.85
GermanyGelnhausen53,100145.48
GermanyGermersheim31,90087.40
GermanyGiebelstadt36,40099.73
GermanyGiessen36,00098.63
GermanyGrafenwoehr42,000115.07
GermanyHanau53,100145.48
GermanyHannover31,50086.30
GermanyHeidelberg39,400107.95
GermanyIdar-Oberstein40,800111.78
GermanyIngolstadt59,400162.74
GermanyKaiserslautern, Landkreis50,900139.45
GermanyKitzingen36,40099.73
GermanyLeimen39,400107.95
GermanyLudwigsburg51,200140.27
GermanyMainz57,000156.16
GermanyMannheim39,400107.95
GermanyMunich59,400162.74
GermanyNellingen51,200140.27
GermanyNeubruecke40,800111.78
GermanyOber Ramstadt42,200115.62
GermanyOberammergau39,000106.85
GermanyPfullendorf41,400113.42
GermanyPirmasens50,900139.45
GermanyRheinau39,400107.95
GermanySchwetzingen39,400107.95
Bulletin No. 2014–18April 28, 2014
993

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
GermanySeckenheim39,400107.95
GermanySembach50,900139.45
GermanyStuttgart51,200140.27
GermanyVilseck42,000115.07
GermanyWahn42,000115.07
GermanyWertheim36,40099.73
GermanyWiesbaden57,000156.16
GermanyWuerzburg36,40099.73
GermanyZweibruecken50,900139.45
GermanyAll cities other than Augsburg,
Babenhausen, Bad Aibling, Bad Kreuznach,
Bad Nauheim, Baumholder, Berchtesgaden,
Berlin, Birkenfeld, Boeblingen, Bonn,
Bremen, Bremerhaven, Butzbach, Cologne,
Darmstadt, Delmenhorst, Duesseldorf,
Erlangen, Flensburg, Frankfurt am
Main, Friedberg, Fuerth, Garlstedt,
Garmisch-Partenkirchen, Geilenkirchen,
Gelnhausen, Germersheim, Giebelstadt,
Giessen, Grafenwoehr, Grefrath, Greven,
Gruenstadt, Hamburg, Hanau, Handorf,
Hannover, Heidelberg, Heilbronn,
Herongen, Idar-Oberstein, Ingolstadt,
Kaiserslautern, Landkreis, Kalkar,
Karlsruhe, Kerpen, Kitzingen, Koblenz,
Leimen, Leipzig, Ludwigsburg, Mainz,
Mannheim, Mayen, Moenchen-Gladbach,
Muenster, Munich, Nellingen, Neubruecke,
Noervenich, Nuernberg, Ober Ramstadt,
Oberammergau, Osterholz-Scharmbeck,
Pirmasens, Rheinau, Rheinberg,
Schwabach, Schwetzingen, Seckenheim,
Sembach, Stuttgart, Twisteden, Vilseck,
Wahn, Wertheim, Wiesbaden, Worms,
Wuerzburg, Zirndorf and Zweibruecken
41,400113.42
GhanaAccra36,00098.63
GreeceArgyroupolis32,90090.14
GreeceAthens42,200115.62
GreeceElefsis42,200115.62
GreeceEllinikon42,200115.62
GreeceMt. Hortiatis32,90090.14
GreeceMt. Parnis42,200115.62
GreeceMt. Pateras42,200115.62
GreeceNea Makri42,200115.62
GreecePerivolaki32,90090.14
GreecePiraeus42,200115.62
GreeceTanagra42,200115.62
GreeceThessaloniki32,90090.14
GuatemalaGuatemala City41,800114.52
GuyanaGeorgetown35,00095.89
Holy See, TheHoly See, The57,300156.99
April 28, 2014Bulletin No. 2014–18
994

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
HungaryBudapest32,50089.04
HungaryPapá44,500121.92
IndiaMumbai67,920186.08
IndiaNew Delhi56,124153.76
IndonesiaJakarta37,776103.50
IrelandDublin49,800136.44
IrelandShannon Area39,300107.67
IsraelTel Aviv50,800139.18
ItalyCatania33,50091.78
ItalyGenoa41,800114.52
ItalyGioia Tauro31,20085.48
ItalyLa Spezia40,400110.68
ItalyLeghorn35,90098.36
ItalyMilan85,600234.52
ItalyNaples54,400149.04
ItalyParma43,500119.18
ItalyPisa35,90098.36
ItalyPordenone-Aviano43,500119.18
ItalyRome57,300156.99
ItalySigonella33,50091.78
ItalyTurin42,800117.26
ItalyVicenza45,100123.56
ItalyAll cities other than Avellino, Brindisi,
Catania, Florence, Gaeta, Genoa, Gioia
Tauro, La Spezia, Leghorn, Milan, Mount
Vergine, Naples, Nettuno, Parma, Pisa,
Pordenone-Aviano, Rome, Sardinia,
Sigonella, Turin, Verona, and Vicenza
35,00095.89
JamaicaKingston41,200112.88
JapanAkashi32,00087.67
JapanAtsugi40,900112.05
JapanCamp Zama40,900112.05
JapanChiba-Ken40,900112.05
JapanFussa40,900112.05
JapanGifu74,300203.56
JapanGotemba30,60083.84
JapanHaneda40,900112.05
JapanIwakuni33,00090.41
JapanKanagawa-Ken40,900112.05
JapanKomaki74,300203.56
JapanMachidi-Shi40,900112.05
JapanMisawa34,80095.34
JapanNagoya74,300203.56
JapanOkinawa Prefecture59,400162.74
JapanOsaka-Kobe90,664248.39
JapanSagamihara40,900112.05
Bulletin No. 2014–18April 28, 2014
995

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
JapanSaitama-Ken40,900112.05
JapanSasebo35,40096.99
JapanTachikawa40,900112.05
JapanTokyo96,000263.01
JapanTokyo-to40,900112.05
JapanYokohama52,600144.11
JapanYokosuka47,700130.68
JapanYokota40,900112.05
KazakhstanAlmaty48,000131.51
KoreaAmmo Depot #930,10082.47
KoreaCamp Carroll32,60089.32
KoreaCamp Colbern57,100156.44
KoreaCamp Market57,100156.44
KoreaCamp Mercer57,100156.44
KoreaChinhae30,90084.66
KoreaK-1657,100156.44
KoreaKimhae31,10085.21
KoreaKimpo Airfield57,100156.44
KoreaMunsan35,00095.89
KoreaOsan AB36,00098.63
KoreaPusan31,10085.21
KoreaPyongtaek35,70097.81
KoreaSeoul57,100156.44
KoreaSuwon57,100156.44
KoreaTaegu34,30093.97
KoreaTongduchon31,90087.40
KoreaUijongbu33,80092.60
KoreaWaegwan32,60089.32
KoreaAllcities other than Ammo Depot #9, Camp
Carroll, Camp Colbern, Camp Market,
Camp Mercer, Changwon, Chinhae,
Chunchon, K-16, Kimhae, Kimpo Airfield,
Kunsun, Kwangju, Munsan, Osan AB,
Pusan, Pyongtaek, Seoul, Suwon, Taegu,
Tongduchon, Uijongbu, and Waegwan
33,00090.41
KuwaitKuwait City64,400176.44
KuwaitAll cities other than Kuwait City57,700158.08
LuxembourgLuxembourg47,000128.77
MacedoniaSkopje35,40096.99
MalaysiaKuala Lumpur46,200126.58
MalaysiaAll cities other than Kuala Lumpur33,70092.33
MaltaMalta55,100150.96
MexicoMazatlan31,00084.93
MexicoMerida37,900103.84
MexicoMexico City47,900131.23
MexicoMonterrey33,20090.96
April 28, 2014Bulletin No. 2014–18
996

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
MexicoAll cities other than Ciudad Juarez,
Cuernavaca, Guadalajara, Hermosillo,
Matamoros, Mazatlan, Merida, Metapa,
Mexico City, Monterrey, Nogales, Nuevo
Laredo, Reynosa, Tapachula, Tijuana,
Tuxtla Gutierrez, and Veracruz
39,400107.95
MozambiqueMaputo39,500108.22
NamibiaWindhoek32,10087.95
NetherlandsAmsterdam52,900144.93
NetherlandsAruba36,00098.63
NetherlandsBrunssum41,000112.33
NetherlandsEygelshoven41,000112.33
NetherlandsHague, The68,300187.12
NetherlandsHeerlen41,000112.33
NetherlandsHoensbroek41,000112.33
NetherlandsHulsberg41,000112.33
NetherlandsKerkrade41,000112.33
NetherlandsLandgraaf41,000112.33
NetherlandsMaastricht41,000112.33
NetherlandsPapendrecht41,100112.60
NetherlandsRotterdam41,100112.60
NetherlandsSchaesburg41,000112.33
NetherlandsSchinnen41,000112.33
NetherlandsSchiphol52,900144.93
NetherlandsYpenburg68,300187.12
NetherlandsAll cities other than Amsterdam, Aruba,
Brunssum, Coevorden, Eygelshoven,
The Hague, Heerlen, Hoensbroek,
Hulsberg, Kerkrade, Landgraaf, Maastricht,
Margraten, Papendrecht, Rotterdam,
Schaesburg, Schinnen, Schiphol, and
Ypenburg
40,600111.23
Netherlands AntillesCuracao45,800125.48
New ZealandAuckland35,70097.81
New ZealandChristchurch32,10087.95
New ZealandWellington33,80092.60
NicaraguaManagua31,80087.12
NigeriaAbuja36,00098.63
NorwayOslo49,000134.25
NorwayStavanger41,600113.97
NorwayAll cities other than Oslo and Stavanger37,700103.29
PanamaPanama City35,50097.26
ParaguayAsuncion31,10085.21
PeruLima39,100107.12
PhilippinesCavite39,000106.85
PhilippinesManila39,000106.85
PolandPoland29,40080.55
PortugalAlverca52,400143.56
Bulletin No. 2014–18April 28, 2014
997

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
PortugalLisbon52,400143.56
QatarDoha36,26499.35
QatarAll cities other than Doha32,40088.77
RussiaMoscow108,000295.89
RussiaSaint Petersburg60,000164.38
RussiaSakhalin Island77,500212.33
RussiaVladivostok77,500212.33
RussiaYekaterinburg47,400129.86
RwandaKigali31,50086.30
Saudi ArabiaJeddah30,66784.02
Saudi ArabiaRiyadh40,000109.59
SingaporeSingapore86,300236.44
South AfricaPretoria39,300107.67
SpainBarcelona40,600111.23
SpainMadrid69,800191.23
SpainRota42,600116.71
SpainValencia40,100109.86
SpainAll cities other than Barcelona, Madrid,
Rota, Seville, Seville Province, and
Valencia
30,30083.01
SurinameParamaribo33,00090.41
SwitzerlandBern72,200197.81
SwitzerlandGeneva100,500275.34
SwitzerlandZurich39,219107.45
SwitzerlandAll cities other than Bern, Geneva and
Zurich
32,90090.14
TaiwanTaipei46,188126.54
TanzaniaDar Es Salaam44,000120.55
ThailandBangkok59,000161.64
Trinidad and TobagoPort of Spain54,500149.32
TurkeyIzmir-Cigli31,60086.58
TurkeyYamanlar31,60086.58
UkraineKiev72,000197.26
United Arab EmiratesAbu Dhabi49,687136.13
United Arab EmiratesDubai57,174156.64
United KingdomBasingstoke41,099112.60
United KingdomBath41,000112.33
United KingdomBracknell62,100170.14
United KingdomBristol40,500110.96
United KingdomBrookwood44,200121.10
United KingdomCambridge44,100120.82
United KingdomCaversham73,800202.19
United KingdomCheltenham53,600146.85
United KingdomCroughton45,000123.29
United KingdomFairford43,700119.73
United KingdomFarnborough54,700149.86
April 28, 2014Bulletin No. 2014–18
998

CountryLocation
Limitation on
Housing Expenses
(full year)
Limitation on
Housing Expenses
(daily)
United KingdomFelixstowe42,500116.44
United KingdomGibraltar44,616122.24
United KingdomHarrogate47,400129.86
United KingdomHigh Wycombe62,100170.14
United KingdomKemble43,700119.73
United KingdomLakenheath55,900153.15
United KingdomLiverpool39,800109.04
United KingdomLondon88,700243.01
United KingdomLoudwater69,900191.51
United KingdomMenwith Hill47,400129.86
United KingdomMildenhall55,900153.15
United KingdomOxfordshire44,500121.92
United KingdomPlymouth44,500121.92
United KingdomPortsmouth44,500121.92
United KingdomReading62,100170.14
United KingdomRochester45,700125.21
United KingdomSamlesbury44,200121.10
United KingdomSouthampton44,200121.10
United KingdomSurrey48,402132.61
United KingdomWaterbeach45,500124.66
United KingdomWiltshire42,300115.89
United KingdomAll cities other than Basingstoke,
Bath, Belfast, Birmingham, Bracknell,
Bristol, Brookwood, Brough, Cambridge,
Caversham, Chelmsford, Cheltenham,
Chicksands, Croughton, Dunstable,
Edinburgh, Edzell, Fairford, Farnborough,
Felixstowe, Ft. Halstead, Gibraltar,
Glenrothes, Greenham Common,
Harrogate, High Wycombe, Hythe,
Kemble, Lakenheath, Liverpool, London,
Loudwater, Menwith Hill, Mildenhall,
Nottingham, Oxfordshire, Plymouth,
Portsmouth, Reading, Rochester,
Samlesbury, Southampton, Surrey,
Waterbeach, Welford, West Byfleet, and
Wiltshire
44,200121.10
VenezuelaCaracas57,000156.16
VietnamHanoi46,800128.22
VietnamHo Chi Minh City42,000115.07
SECTION 4. ELECTION TO APPLY
2014 ADJUSTED LIMITATIONS TO
2013 TAXABLE YEAR
For some locations, the limitation on
housing expenses provided in section 3 of
this notice may be higher than the limita-
tion on housing expenses provided in the
“Table of Adjusted Limitations for 2013”
in Notice 2013–31. A qualified individual
incurring housing expenses in such a lo-
cation during 2013 may apply the adjusted
limitation on housing expenses provided
in section 3 of this notice in lieu of the
amounts provided in the “Table of Ad-
justed Limitations for 2013” in Notice
2013–31 (and as set forth in the Instruc-
tions to Form 2555 (2013)).
Treasury and the IRS anticipate that
future annual notices providing adjust-
ments to housing expense limitations will
make a similar election available to qual-
ified individuals that incur housing ex-
penses in the immediately preceding year.
Bulletin No. 2014–18April 28, 2014
999

For example, when adjusted housing ex-
pense limitations for 2015 are issued, it is
expected that taxpayers will be permitted
to apply those adjusted limitations to the
2014 taxable year.
EFFECT ON OTHER DOCUMENTS
This notice supersedes Notice 2006 –
87, 2006 –2 C.B. 766, Notice 2007–25,
2007–1 C.B. 760, Notice 2007–77,
2007–2 C.B. 735, Notice 2008 –107,
2008 –2 C.B. 1266, Notice 2010 –27,
2010 –1 C.B. 531, Notice 2011– 8, 2011–1
C.B. 503, Notice 2012–19, 2012–1 C.B.
440, and Notice 2013–31, 2013–1 C.B.
1099.
EFFECTIVE DATE
This notice is effective for taxable
years beginning on or after January 1,
2014. However, as provided in section 4,
a taxpayer may elect to apply the 2014
adjusted housing limitations contained in
section 3 of this notice to his or her tax-
able year beginning in 2013.
DRAFTING INFORMATION
The principal author of this notice is
Susan E. Massey of the Office of Associ-
ate Chief Counsel (International). For fur-
ther information regarding this notice con-
tact Ms. Massey at (202) 317-6934 (not a
toll-free number).
April 28, 2014Bulletin No. 2014–18
1000

Part IV. Items of General Interest
Update on Jurisdictions
Treated as Having an IGA
in Effect and on FATCA
Financial Institution
Registration
Announcement 2014–17
Since the 2012 release of the Model 1
and Model 2 intergovernmental agree-
ments (IGAs) to implement the Foreign
Account Tax Compliance Act (FATCA),
there has been robust and growing interest
from jurisdictions worldwide to enter into
IGAs. To date, the United States has
signed IGAs with 26 jurisdictions and has
reached agreements in substance or is in
advanced discussions with many others.
Foreign financial institutions (FFIs) and
other stakeholders continue to express
strong support for a broad IGA network as
a way to facilitate FATCA compliance
while avoiding legal conflicts, and to more
effectively and efficiently implement
cross-border tax information reporting.
They have also expressed practical con-
cerns about the status of FFIs in jurisdic-
tions that are known to be in an advanced
stage of concluding an IGA, but have not
yet signed an agreement. For this reason,
the U.S. Department of the Treasury
(Treasury) and the Internal Revenue Ser-
vice (IRS) are issuing this announcement
to provide FFIs in jurisdictions that al-
ready have reached an agreement in sub-
stance on the terms of an IGA with the
clarity they need to prepare to comply
with FATCA. This announcement also ad-
dresses stakeholders’ practical concerns
by allowing an FFI ten additional days to
register in preparation for FATCA imple-
mentation on July 1 and still ensure that
its Global Intermediary Identification
Number (GIIN) will appear on the first
public list of GIINs.
Background
The final regulations provide that the
IRS will publish a list identifying all
countries that are treated as having a
Model 1 or Model 2 IGA in effect. Reg.
§§ 1.1471–1(b)(78) and (79). Notice 2013–
43,2013–31 I.R.B. 113, provides that this
list is maintained on the Treasury website
athttp://www.treasury.gov/resource-center/
tax-policy/treaties/Pages/FATCA-Archive.
aspx. A link to the list is also available on
the IRS website athttp://www.irs.gov/
Businesses/Corporations/Information-for-
Foreign-Financial-Institutions.Notice
2013– 43 further provides that Treasury
and the IRS intend to include on this list
jurisdictions that have signed, but may not
yet have brought into force, an IGA.
The final regulations generally provide
that, in order for withholding not to apply,
a withholding agent must obtain an FFI’s
GIIN for payments made after June 30,
2014, and must confirm that the GIIN
appears on the IRS FFI List. A special
rule, however, provides that a withholding
agent does not need to obtain a reporting
Model 1 FFI’s GIIN for payments made
before January 1, 2015. See Reg.
§ 1.1471–3(d)(4)(iv)(A). Notice 2013– 43
and Announcement 2014 –1, 2014 –2
I.R.B. 393, indicate that FFIs must regis-
ter on the FATCA registration website by
April 25, 2014 (GMT -5), to ensure they
are included on the first IRS FFI List,
which is expected to be electronically
available on June 2, 2014 (GMT -5).
Stakeholders generally have expressed
concerns that FFIs located in jurisdictions
that are expected to sign an IGA, but have
not yet signed the agreement, are unable
to plan effectively and efficiently for the
July 1 implementation of FATCA given
the uncertainty regarding when the rele-
vant IGA may be signed and therefore
treated as being in effect. More specifi-
cally, stakeholders have expressed con-
cern that certain jurisdictions will not
have signed an IGA by April 25, 2014,
and accordingly that FFIs in those juris-
dictions will not be able to timely register
consistent with their expected IGA status.
For example, some FFIs that expect to be
reporting Model 2 FFIs may not be able to
register by April 25 if legal impediments
would prevent them from agreeing to the
terms of the FFI Agreement that would
apply absent the modifications applicable
to reporting Model 2 FFIs under a signed
Model 2 IGA. Some FFIs that expect to be
reporting Model 1 FFIs and therefore to
rely on the special rule providing that
withholding agents do not need to obtain
GIINs of reporting Model 1 FFIs before
January 1, 2015, are concerned about
missing the April 25 deadline in case the
relevant IGA is not in fact signed, and
therefore treated as being in effect, by July
1. Other FFIs that expect to be reporting
Model 1 FFIs wish to ensure their inclu-
sion on the first IRS FFI List in order to
simplify the documentation of their status
with withholding agents (even though
withholding agents should not require re-
porting Model 1 FFIs to provide GIINs
until January 1, 2015), but are concerned
that they will not be able to register as
reporting Model 1 FFIs before April 25 if
their jurisdiction’s IGA is not signed, and
therefore treated as being in effect, by that
date.
Expansion of IGAs Treated as Being
in Effect to Include Agreements in
Substance
This announcement aims to address
these concerns by providing that the juris-
dictions listed on the Treasury and IRS
websites as jurisdictions that are treated as
having an IGA in effect will also include
jurisdictions that, before July 1, 2014,
have reached agreements in substance
with the United States on the terms of an
IGA and have consented to be included on
the Treasury and IRS list, even if those
agreements have not yet been signed.
Such jurisdictions will be treated as hav-
ing an IGA in effect from the date that the
jurisdiction provides its consent (or April
2, 2014, the date of the public release of
this announcement, if later) until Decem-
ber 31, 2014, the date by which the IGA
must be signed in order for this status to
continue without interruption. Treasury
expects to add jurisdictions to this list in
the coming weeks as additional jurisdic-
tions consent to inclusion on the list and
additional agreements in substance are
reached. Jurisdictions that reach agree-
ments in substance on or after July 1,
2014, will not be included in the list of
jurisdictions that are treated as having an
IGA in effect until the IGA is signed.
The text of the agreements in substance
that are treated as being in effect will not
be published by the IRS or Treasury until
the IGA is signed. Instead, the list will
specify only whether the relevant IGA is a
Bulletin No. 2014–18April 28, 2014
1001

Model 1 or a Model 2 IGA. Until the IGA
is signed, the jurisdiction will be treated as
having in effect the relevant model provi-
sions. This means that an FFI resident in,
or organized under the laws of, a jurisdic-
tion that is listed on the Treasury and IRS
websites as having reached an agreement
in substance will be permitted to register
on the FATCA registration website con-
sistent with its treatment under the rele-
vant model IGA and will be permitted to
certify its status to a withholding agent
consistent with that treatment. Treasury
generally has a policy of not deviating
from the model text except in limited cir-
cumstances in Annex II. Any modifica-
tions made in the relevant IGA to the
model Annex II categories of exempt ben-
eficial owners, deemed compliant FFIs,
and accounts excluded from the definition
of financial accounts will therefore not be
applicable until the IGA is signed.
A jurisdiction may be removed from
the list of jurisdictions that are treated as
having an IGA in effect if Treasury deter-
mines that the jurisdiction is not taking the
steps necessary to bring the IGA into
force within a reasonable period of time,
and, as noted above, a jurisdiction will be
removed from the list if the jurisdiction
fails to sign the IGA by December 31,
2014. If a jurisdiction is removed from the
list, FFIs that are resident in, or organized
under the laws of, that jurisdiction, and
branches that are located in that jurisdic-
tion, will, from the first day of the month
following the month of removal, no longer
be entitled to the status that would be
provided under the IGA, and will be re-
quired to update their status on the
FATCA registration website accordingly.
New Dates for Registering to Ensure
GIIN Inclusion on the IRS FFI List
As described in Notice 2013– 43, FFIs
resident in, or organized under the laws
of, a jurisdiction that is treated as having
an IGA in effect, which, pursuant to this
announcement includes jurisdictions listed
on the Treasury and IRS websites as hav-
ing reached agreements in substance on
IGAs before July 1, 2014, should register
on the FATCA registration website as a
registered deemed-compliant FFI (which
would include all reporting Model 1 FFIs)
or a participating FFI (which would in-
clude all reporting Model 2 FFIs), as ap-
plicable. Importantly, withholding agents
are still not required to obtain the GIINs
of FFIs that are treated as reporting Model
1 FFIs before January 1, 2015.
Based on the IRS experience with the
registration system and GIIN generation
process to date, the IRS now believes that
it can ensure registering FFIs that their
GIINs will be included on the June 2 IRS
FFI List if their registrations are finalized
by May 5, 2014 (GMT -5), rather than
April 25, 2014, as originally announced.
Further, the IRS believes it can ensure
registering FFIs that their GIINs will be
included on the July 1 IRS FFI List if their
registrations are finalized by June 3, 2014
(GMT -5). FFIs that finalize their registra-
tions after May 5 or June 3 may still be
included on the June 2 or July 1 IRS FFI
List, respectively; however, the IRS can-
not provide assurance that this will be the
case. The IRS will continue processing
registrations in the order received; how-
ever, processing times may increase as the
May 5 and June 3 dates approach.
Finally, Treasury and the IRS remind
all withholding agents that, in accordance
with Reg. § 1.1471–3(e)(3), a withholding
agent that receives a Form W– 8 from a
payee with a GIIN that does not yet ap-
pear on the published IRS FFI List has 90
days to verify that the GIIN appears on the
list before the withholding agent will be
treated as having reason to know that the
chapter 4 status of the payee is unreliable
or incorrect. In addition, a withholding
agent that receives a Form W– 8 from a
payee indicating that the payee has ap-
plied for a GIIN has 90 days to obtain the
GIIN from the payee and verify it against
the IRS FFI List before the withholding
agent will be treated as having reason to
know that the chapter 4 status of the payee
is unreliable or incorrect.
DRAFTING INFORMATION
The principal author of this announce-
ment is Michael Kaercher of the Office of
Associate Chief Counsel (International).
For further information regarding this an-
nouncement, contact Mr. Kaercher at 202-
317-6942 (not a toll-free number).
April 28, 2014Bulletin No. 2014–18
1002

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified andclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2014–18April 28, 2014
i

Numerical Finding List
1
Bulletins 2014 –1 through 2014 –18
Announcements
2014-1, 2014-2 I.R.B.393
2014-2, 2014-4 I.R.B.448
2014-4, 2014-7 I.R.B.523
2014-05, 2014-6 I.R.B.507
2014-06, 2014-6 I.R.B.508
2014-07, 2014-6 I.R.B.508
2014-08, 2014-6 I.R.B.508
2014-09, 2014-6 I.R.B.508
2014-10, 2014-6 I.R.B.508
2014-11, 2014-6 I.R.B.508
2014-12, 2014-6 I.R.B.509
2014-13, 2014-10 I.R.B.620
2014-14, 2014-16 I.R.B.948
2014-15, 2014-16 I.R.B.973
2014-16, 2014-17 I.R.B.983
2014-17, 2014-18 I.R.B.1001
2014-18, 2014-17 I.R.B.983
2014-19, 2014-17 I.R.B.984
Notices
2014-1, 2014-2 I.R.B.270
2014-2, 2014-3 I.R.B.407
2014-3, 2014-3 I.R.B.408
2014-4, 2014-2 I.R.B.274
2014-5, 2014-2 I.R.B.276
2014-6, 2014-2 I.R.B.279
2014-7, 2014-4 I.R.B.445
2014-8, 2014-5 I.R.B.452
2014-9, 2014-5 I.R.B.455
2014-10, 2014-9 I.R.B.605
2014-11, 2014-13 I.R.B.880
2014-12, 2014-9 I.R.B.606
2014-13, 2014-10 I.R.B.616
2014-14, 2014-13 I.R.B.881
2014-15, 2014-12 I.R.B.661
2014-16, 2014-14 I.R.B.920
2014-17, 2014-13 I.R.B.881
2014-18, 2014-15 I.R.B.926
2014-19, 2014-17 I.R.B.979
2014-20, 2014-16 I.R.B.937
2014-21, 2014-16 I.R.B.938
2014-22, 2014-16 I.R.B.940
2014-23, 2014-16 I.R.B.942
2014-24, 2014-16 I.R.B.942
2014-25, 2014-17 I.R.B.981
2014-27, 2014-18 I.R.B.987
2014-28, 2014-18 I.R.B.990
2014-29, 2014-18 I.R.B.991
Proposed Regulations
REG-154890-03, 2014-6 I.R.B.504
REG-159420-04, 2014-2 I.R.B.374
REG-144468-05, 2014-6 I.R.B.474
Proposed Regulations—Continued
REG-163195-05, 2014-15 I.R.B.930
REG-119305-11, 2014-8 I.R.B.524
REG-140974-11, 2014-3 I.R.B.438
REG-121534-12, 2014-6 I.R.B.473
REG-122706-12, 2014-11 I.R.B.647
REG-134361-12, 2014-13 I.R.B.895
REG-136984-12, 2014-2 I.R.B.378
REG-113350-13, 2014-3 I.R.B.440
REG-130967-13, 2014-13 I.R.B.884
REG-141036-13, 2014-7 I.R.B.516
REG-143172-13, 2014-2 I.R.B.383
REG-108641-14, 2014-15 I.R.B.928
Revenue Procedures
2014-1, 2014-1 I.R.B.1
2014-2, 2014-1 I.R.B.90
2014-3, 2014-1 I.R.B.111
2014-4, 2014-1 I.R.B.125
2014-5, 2014-1 I.R.B.169
2014-6, 2014-1 I.R.B.198
2014-7, 2014-1 I.R.B.238
2014-8, 2014-1 I.R.B.242
2014-9, 2014-2 I.R.B.281
2014-10, 2014-2 I.R.B.293
2014-11, 2014-3 I.R.B.411
2014-12, 2014-3 I.R.B.415
2014-13, 2014-3 I.R.B.419
2014-14, 2014-2 I.R.B.295
2014-15, 2014-5 I.R.B.456
2014-16, 2014-9 I.R.B.606
2014-17, 2014-12 I.R.B.661
2014-18, 2014-7 I.R.B.513
2014-19, 2014-10 I.R.B.619
2014-20, 2014-9 I.R.B.614
2014-21, 2014-11 I.R.B.641
2014-22, 2014-11 I.R.B.646
2014-23, 2014-12 I.R.B.685
2014-24, 2014-13 I.R.B.879
2014-25, 2014-15 I.R.B.927
2014-28, 2014-16 I.R.B.944
Revenue Rulings
2014-1, 2014-2 I.R.B.263
2014-2, 2014-2 I.R.B.255
2014-3, 2014-2 I.R.B.259
2014-4, 2014-5 I.R.B.449
2014-6, 2014-7 I.R.B.510
2014-8, 2014-11 I.R.B.624
2014-9, 2014-17 I.R.B.975
2014-10, 2014-14 I.R.B.906
2014-11, 2014-14 I.R.B.906
2014-12, 2014-15 I.R.B.923
Treasury Decisions
9649, 2014-2 I.R.B.265
9650, 2014-3 I.R.B.394
Treasury Decisions—Continued
9651, 2014-4 I.R.B.441
9652, 2014-12 I.R.B.655
9653, 2014-6 I.R.B.460
9654, 2014-6 I.R.B.461
9655, 2014-9 I.R.B.541
9656, 2014-11 I.R.B.626
9657, 2014-13 I.R.B.687
9658, 2014-13 I.R.B.748
9659, 2014-12 I.R.B.653
9660, 2014-13 I.R.B.842
9661, 2014-13 I.R.B.855
9662, 2014-16 I.R.B.933
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin
2013–52, dated December 23, 2013.
April 28, 2014Bulletin No. 2014–18
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletins 2014 –1 through 2014 –18
Announcements:
2007-44
Modified by
Ann. 2014-4, 2014-7 I.R.B.523
2011-49
Modified by
Ann. 2014-4, 2014-7 I.R.B.523
Notices:
2003-37
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2006-87, 2006-2 C.B. 766
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2006-109
Modified by
Notice 2014-4, 2014-2 I.R.B.274
2007-25, 2007-1 C.B. 760
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2007-59
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2007-77, 2007-2 C.B. 735
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2008-107, 2008-2 C.B. 1266
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2009-78
Superseded by
T.D. 9654 2014-6 I.R.B.461
2010-27, 2010-1 C.B. 531
Superseded by
Notice 2014-29, 2014-18 I.R.B.991
2013-1
Superseded by
Notice 2014-22, 2014-16 I.R.B.940
2013-1
Modified by
Notice 2014-22, 2014-16 I.R.B.940
Revenue Procedures—Continued:
2013-13
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2013-17
Amplified by
Notice 2014-1, 2014-2 I.R.B.270
Revenue Procedures:
2003-49
Modified and superseded by
Rev. Proc. 2014-14, 2014-2 I.R.B.295
2004-42
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2004-43
Obsoleted by
REG-163195-05 2014-15 I.R.B.930
2011-4
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2011-14
Modified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2011-14
Clarified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2011-14
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2011-44
Modified and Superseded by
Rev. Proc. 2014-11, 2014-3 I.R.B.411
2011-49
Modified by
Rev. Proc. 2014-6, 2014-1 I.R.B.198
2012-14
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2012-19
Modified by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
2012-19
Superseded by
Rev. Proc. 2014-16, 2014-9 I.R.B.606
Revenue Procedures—Continued:
2012-20
Modified by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2012-20
Superseded by
Rev. Proc. 2014-17, 2014-12 I.R.B.661
2013-1
Superseded by
Rev. Proc. 2014-1, 2014-1 I.R.B.1
2013-2
Superseded by
Rev. Proc. 2014-2, 2014-1 I.R.B.90
2013-3
Superseded by
Rev. Proc. 2014-3, 2014-1 I.R.B.111
2013-4
Superseded by
Rev. Proc. 2014-4, 2014-1 I.R.B.125
2013-5
Superseded by
Rev. Proc. 2014-5, 2014-1 I.R.B.169
2013-6
Superseded by
Rev. Proc. 2014-6, 2014-1 I.R.B.198
2013-7
Superseded by
Rev. Proc. 2014-7, 2014-1 I.R.B.238
2013-8
Superseded by
Rev. Proc. 2014-8, 2014-1 I.R.B.242
2013-9
Superseded by
Rev. Proc. 2014-9, 2014-2 I.R.B.281
2013-10
Superseded by
Rev. Proc. 2014-10, 2014-2 I.R.B.293
2013-22
Modified by
Rev. Proc. 2014-28, 2014-16 I.R.B.944
2013-24
Obsoleted by
Rev. Proc. 2014-23, 2014-12 I.R.B.685
2013-27
Obsoleted by
Rev. Proc. 2014-23, 2014-12 I.R.B.685
1
A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23,
2013.
Bulletin No. 2014–18April 28, 2014
iii

Revenue Procedures—Continued:
2013-32
Superseded in part by
Rev. Proc. 2014-1, 2014-1 I.R.B.1, and
Rev. Proc. 2014-3, 2014-1 I.R.B.111
2014-1
Amplified by
Rev. Proc. 2014-18, 2014-7 I.R.B.513
2014-1 I.R.B. 111
Amplified by
Rev. Proc. 2014-24, 2014-13 I.R.B.879
2014-3
Amplified by
Rev. Proc. 2014-18, 2014-7 I.R.B.513
2014-3 I.R.B 111
Amplified by
Rev. Proc. 2014-24, 2014-13 I.R.B.879
2014-4
Modified by
Rev. Proc. 2014-19, 2014-10 I.R.B.619
Proposed Regulations:
209054-87
A portion withdrawn by
REG-113350-13 2014-3 I.R.B.440
Revenue Rulings:
2005-48 (2005-2 CB 259)
Obsoleted by
T.D. 9659 2014-12 I.R.B.653
2013-17
Amplified by
Notice 2014-19, 2014-17 I.R.B.979
2013-17
Amplified by
Notice 2014-25, 2014-17 I.R.B.981
Treasury Decision:
9644
Correction by
Ann. 2014-18, 2014-17 I.R.B.983
9644
Correction by
Ann. 2014-19, 2014-17 I.R.B.984
April 28, 2014Bulletin No. 2014–18
iv

INDEX
Internal Revenue Bulletins 2014–1 through
2014–18
The abbreviation and number in parenthesis following the index
entry refer to the specific item; numbers in roman and italic type
following the parentheses refer to the Internal Revenue Bulletin in
which the item may be found and the page number on which it
appears.
Key to Abbreviations:
AnnAnnouncement
CDCourt Decision
DODelegation Order
EOExecutive Order
PLPublic Law
PTEProhibited Transaction Exemption
RPRevenue Procedure
RRRevenue Ruling
SPRStatement of Procedural Rules
TCTax Convention
TDTreasury Decision
TDOTreasury Department Order
ADMINISTRATIVE
Consolidated returns; failure to p[roperly include subsidiary (RP 24)
13,879
Extension of time to file estate tax return to elect portability of a
deceased spousal unused exclusion amount under section
2010(c)(5)(A). (RP 18) 7,513
Method change procedures for dispositions of tangible deprecia-
ble property (RP 17) 12,661
Maximum Vehicle Values for which the special valuation rules
of regulations section 1.61–21(d) and (e) may be used (Notice 11)
13,880
Minimum essential coverage, information reporting (TD 9660)
13,842
Regulations:
26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR
1.6081– 8 amended. 26 CFR 301.6011–2 amended. 26
CFR 301.6721–1 amended. 26 CFR 1.6011– 8 amended.
26 CFR 301.6722–1 amended; minimum essential cover-
age, information reporting 13,842
Per Capita Payments from Proceeds of Settlements of Indian
Tribal Trust Cases (Notice 22) 16,940
Virtual Currency (Notice 21) 16,938
EMPLOYEE PLANS
Definition of a substantial risk of forfeiture l (TD 9659) 12,653
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Excepted benefits (REG–143172–13) 2,383
Final rules to implement the 90-day waiting period limitation
(TD 9656) 11,626
EMPLOYEE PLANS—Cont.
Letter rulings:
And determination letters:
Areas which will not be issued from Associate Chief
Counsel and Division counsel (TE/GE) (RP 3) 1,111
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 1,281
And general information letters; procedures (RP 4) 1,125
User fees, request for letter rulings (RP 8) 1,242
Letter rulings and general information letters (RP 4) 1,125
Letter rulings or determination letters (RP 1) 1,1
Proposed rules to clarify length of reasonable and bona fide
employment-based orientation period, consistent with the 90-
day waiting period limitation (REG–122706 –12) 11,647
Qualification, determination letters (RP 6) 1,198
Qualified plans:
Application of the Windsor Decision and Rev. Rul. 2013–17
(Notice 19) 17,979
Discrimination (Notice 5) 2,276
Opinion letters (Ann 4) 7,523
Opinion letters (Ann 16) 17,983
Determination Letters (RP 19) 10,619
Qualified retirement plans covered compensation, permitted dis-
parity (RR 3) 2,259
Qualified retirement plans
Rollovers (RR 9) 17,975
Regulations:
26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647
Removal of the Qualified Payment Card Agent Program (REG–
163195– 05) 15,930
Request for Information Regarding Provider Non-Discrimination
(REG–108641–14) 15,928
Rulings and determination letters, user fees (RP 8) 1,242
Technical advice memorandum or TAM (RP 2) 1,90
Technical advice procedures (RP 5) 1,169
Full funding limitations, weighted average interest rates, segment
rates for:
January 2014 (Notice 8) 5,452
Weighted average interest rates
Segment rates for February 2014 (Notice 13) 10,616
Segment rates for March 2014 (Notice 16) 14,920
Segment rates for March 2014 (Notice 27) 18,987
EMPLOYMENT TAX
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Employment tax liability of agents authorized under section 3504
(TD 9649) 2,265
Employment tax obligations of a third party that enters into a
service agreement with an employer to take on the employer’s
employment tax responsibilities (TD 9662) 16,933
Regulations:
26 CFR 31–3504 –2, added; employment tax obligations of a
third party that enters into a service agreement with an
employer to take on the employer’s employment tax re-
sponsibilities (TD 9662) 16,933
Bulletin No. 2014–18April 28, 2014
v

EMPLOYMENT TAX—Cont.
Letter rulings or determination letters (RP 1) 1,1
Regulations:
26 CFR 1.83–3 is revised; definition of a substantial risk of
forfeiture (TD 9659) 12,653
26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647
26 CFR 54,9801–1, thru– 6, amended; 26 CFR 54.9802–1,
amended; 26 CFR 54.9815–2708, added; 26 CFR
54.9831–1, amended (TD 9656) 12,626
Technical Advice Memorandum (TAM) (RP 2) 1,90
Virtual Currency (Notice 21) 16,938
ESTATE TAX
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Extension of time to file estate tax return to elect portability of a
deceased spousal unused exclusion amount under section
2010(c)(5)(A) (RP 18) 7,513
Letter rulings or determination letters (RP 1) 1,1
Technical Advice Memorandum (TAM) (RP 2) 1,90
EXCISE TAX
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Final rules to implement the 90-day waiting period limitation
(TD 9656) 11,626
Information reporting by applicable large employers on health
insurance coverage offered under employer-sponsored plans
(TD 9661) 13,855
Regulations:
301.6056 –1, –2, added; Information reporting by applicable
large employers on health insurance coverage offered un-
der employer-sponsored plans (TD 9661) 13,855
Interim guidance regarding supporting organizations (Notice 4)
2,274
Letter rulings or determination letters (RP 1) 1,1
Notice for ACA Section 9010 Health Insurance Providers Fee
and expatriate plans (Notice 24) 16,942
Proposed rules to clarify length of reasonable and bona fide
employment-based orientation period, consistent with the 90-
day waiting period limitation (REG–122706 –12) 11,647
Regulations:
26 CFR 54.9815–2708, amended; REG–122706 –12) 11,647
26 CFR 54,9801–1, thru– 6, amended; 26 CFR 54.9802–1,
amended; 26 CFR 54.9815–2708, added; 26 CFR
54.9831–1, amended (TD 9656) 12,626
Technical Advice Memorandum (TAM) (RP 2) 1,90
EXEMPT ORGANIZATIONS
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Form 990 Revenue Procedure update to revoke Revenue Proce-
dure 79 – 6 (RP 22) 11,646
Interim guidance regarding supporting organizations (Notice 4)
2,274
EXEMPT ORGANIZATIONS—Cont.
Letter rulings:
And determination letters:
Areas which will not be issued from Associate Chief
Counsel and Division counsel (TE/GE) (RP 3) 1,111
Exemption application determination letter rulings under
sections 501 and 521 (RP 9) 1,281
And general information letters; procedures (RP 4) 1,125
User fees, request for letter rulings (RP 8) 1,242
Letter rulings (RP 10) 2,293; (RP 9) 2,281
Letter rulings or determination letters (RP 1) 1,1
Proposed procedures for charitable hospitals to correct and dis-
close failures to meet section 501(r) (Notice 3) 3,408
Reliance on proposed regulations for tax-exempt hospitals
(Notice 2) 3,407
Rulings and determination letters, user fees (RP 8) 1,242
Technical Advice Memorandum (TAM) (RP 2) 1,90
Technical advice procedures (RP 5) 1,169
INCOME TAX
Adequate disclosure revenue procedure (RP 15) 5,456
Advance Pricing and Mutual Agreement Program (Ann 14) 16,948
Allocation of section 47 credits by a partnership to its partners
(RP 12) 3,415
Allocation of section 752 recourse liabilities among related par-
ties (REG–136984 –12) 2,378
Amount of the life insurance reserves taken into account under
§ 807 of the Internal Revenue Code for variable contracts (RR
7) 9,539
Areas in which rulings will not be issued; Associate Chief
Counsel (International) (RP 7) 1,238
Basis in assets of tax exempt trusts (REG–154890 – 03) 6,504
Bond premium carryforward (TD 9653) 6,460
Cafeteria plans, FSA reimbursements, and HSA contribution
limits for same-sex spouses (Notice 1) 2,270
2014 Census Count (Notice 12) 9,606
Contribution of built-in lost property to a partnership; mandatory
basis adjustments in the event of a substantial built-in loss or
substantial basis reduction; modification of basis allocation
rules (REG–144468 – 05) 6,474
Current refunding of Recovery Zone facility bonds (Notice 9) 5,455
Declaratory judgement suits (Ann 5) 6,507; (Ann 6) 6,507;
(Ann 7) 6,508; (Ann 8) 6,508; (Ann 9) 6,508; (Ann 10) 6,
508; (Ann 12) 6,509
Definition of a substantial risk of forfeiture (TD 9659) 12,653
Definitions applicable to U.S. persons owning interests in passive
foreign investment companies (REG–113350 –13) 3,440
Depreciation deduction, limitations on certain automobiles (RP
21) 11,641
Determination of housing cost eligible exclusion or deduction for
2014 (Notice 29) 18,991
Determination of ownership in a passive foreign investment
company; annual filing requirements for shareholders of pas-
sive foreign investment companies; filing requirements for
constructive owners in certain foreign corporations (REG–
140974 –11) 3,438; (TD 9650) 3,394
April 28, 2014Bulletin No. 2014–18
vi

INCOME TAX—Cont.
Determining stock ownership for purposes of whether an entity is
a surrogate foreign corporation (TD 9654) 6,461; (REG–
121534 –12) 6,473
Discharge of indebtedness secured by real property (RP 20)9,
614
Disciplinary actions involving attorneys, certified public accoun-
tants, enrolled agents, and enrolled actuaries (Ann 13) 10,620
Domestic areas in which the Service will not issue letter rulings
or determination letters (RP 3) 1,111
Equity-linked instruments and dividend equivalents (Notice 14)
13,881
FATCA financial institution registration update (Ann 1) 2,393
FATCA IGA and registration update (Ann 17) 18,1001
Final FFI agreement for participating FFI and reporting Model 2
FFI (RP 13) 3,419
Foreign Earned Income Exclusion (RP 25) 15,927
2014 –2015 Guidance Priority List- Solicitation Notice (Notice 18)
15,926
Guidance regarding reinstatement following auto revocation of
tax-exempt status under section 6033(j) (RP 11) 3,411
Income tax treatment of per capita payments made from funds
held in trust by the Secretary of the Interior (Notice 17) 13,881
Information reporting by foreign financial institutions and with-
holding on payments to foreign financial institutions and other
foreign entities (REG–130967–13) 13,884
Regulation:
26 CFR 1.1471– 0, amended; 26 CFR 1.1471–1, amended; 26
CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26
CFR 1.1471– 4, amended; 26 CFR 1.1471–5, amended; 26
CFR 1.1471– 6, amended; 26 CFR 1.1472–1, amended; 26
CFR 1.1473–1, amended; 26 CFR 1474 –1, amended; 26
CFR 1.1474 – 6, amended. (Reg–130967–13) 13,884
Information reporting by foreign financial institutions and with-
holding on payments to foreign financial institutions and other
foreign entities (TD 9657) 13,687
Regulations:
26 CFR 1.1471– 0, amended; 26 CFR 1.1471–1, amended; 26
CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26
CFR 1.1471– 4, amended; 26 CFR 1.1471–5, amended; 26
CFR 1.1471– 6, amended; 26 CFR 1.1472–1, amended; 26
CFR 1.1473–1, amended; 26 CFR 1474 –1, amended; 26
CFR 1.1474 – 6, amended. (TD 9657) 13,687
Interest:
Investment:
Federal short-term, mid-term, and long-term rates for:
January 2014 (RR 1) 2,263
February 2014 (RR 6) 7,510
March 2014 (RR 8) 11,624
April 2014 (RR 12) 15,923
Intra-group gross receipts (REG–159420 – 04) 2,374
Insurance tax, insurance companies, interest rate tables (RR 4) 5,
449
Letter rulings or determination letters (RP 1) 1,1
Low-Income Housing Credit (Notice 15) 12,661
INCOME TAX—Cont.
Maximum Vehicle Values for which the special valuation rules
of regulations section 1.61–21(d) and (e) may be used (Notice
11) 13,880
Method change procedures for dispositions of tangible deprecia-
ble property (RP 17) 12,661
Minimum essential coverage, information reporting (TD 9660)
13,842
Regulations:
26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR
1.6081– 8 amended. 26 CFR 301.6011–2 amended. 26
CFR 301.6721–1 amended. 26 CFR 1.6011– 8 amended.
26 CFR 301.6722–1 amended. (TD 9660) 13,842
Net investment income tax; TD 9644 Correction (Ann 2014 –18)
17,983
Net investment income tax; TD 9644 Correction (Ann 2014 –19)
17,984
Postponement of deadline for § 165(i) election for losses attrib-
utable to September 2013 major flooding in Colorado (Notice)
(Notice 20) 16,937
Principal residence, treatment of National Mortgage Settlement
payments (RR 2) 2,255
Qualified census tracts (RP 14) 2,295
Refundable Credit For Coverage Under a Qualified Health Plan,
Definition and Rules Relating to Applicable Taxpayer (Notice 23)
16,942
Regarding disguised sales, generally (REG–119305–11) 8,524
Regulations:
26 CFR 1.83–3 is revised; definition of a substantial risk of
forfeiture (TD 9659) 12,653
26 CFR 1.263A– 0, thru–3, amended; 1.471–3 amended;
sales-base royalties and vendor allowances (TD 9652) 12,
655
Removal of the Qualified Payment Card Agent Program (REG–
163195– 05) 15,930
Regulations:
26 CFR 301.6724 –1(c)(6), amended; 26 CFR 31.3406(g)–
1(f), 26 CFR 301.6724 –1(e)(1)(vi)(H), and 26 CFR
301.6724 –1(f)(5)(vii), removed;removal of the qualified
payment ard agent program (REG–163195– 05) 15,930
Revocations, exempt organization (Ann 11) 6,508
Sales-bases royalties and vendor allowances (TD 9652) 12,655
2013 Section 45K Inflation Adjustment Factor - Nonconven-
tional Fuel source Credit (Notice 25) 17,981
Shared responsibility for employers regarding health coverage
(TD 9655) 9,541
Shared responsibility payment for not maintaining minimum
essential coverage (REG–141036 –13) 7,516
Standard Industry Fare Level (SIFL) (RR 10) 14,906
Tangible property regulations method change guidance (RP 16)
9,606
Technical Advice Memorandum (TAM) (RP 2) 1,90
Transition relief for the tax credit for employee health insurance
expenses of certain small employers (Notice 6) 2,279
Transition relief under section 5000A for certain individuals
without minimum essential coverage (Notice 10) 9,605
Bulletin No. 2014–18April 28, 2014
vii

INCOME TAX—Cont.
Treatment of U.S. persons that own stock of passive foreign
investment companies through certain organizations and ac-
counts that are tax exempt (Notice 28)18 990
Underpayment and overpayments, quarter beginning: April 1,
2014 (RR 11) 14,906
Virtual Currency (Notice 21) 16,938
Withholding of tax on certain U.S. source income paid to foreign
persons and revision of information reporting and backup
withholding regulations (REG–134361–12) 13,895
Proposed Regulations:
26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26
CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26
CFR 1.441– 6, amended; 26 CFR 1.1441.7, amended; 26
CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26
CFR 1.6041–1, amended; 26 CFR 1.6041– 4, amended; 26
CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26
CFR 1.6045–1, amended; 26 CFR 1.6049 – 4, amended; 26
CFR 1.6049 –5, amended; 26 CFR31.3406(g)–1, amended;
26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3,
amended; Withholding of tax on certain U.S. source in-
come paid to foreign persons and revision of information
reporting and backup withholding regulations (REG–
134361–12) 13,895
Withholding of tax on certain U.S. source income paid to foreign
persons and revision of information reporting and backup
withholding regulations (TD 9658) 13,748
Regulations:
26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26
CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26
CFR 1.441– 6, amended; 26 CFR 1.1441.7, amended; 26
CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26
CFR 1.6041–1, amended; 26 CFR 1.6041– 4, amended; 26
CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26
CFR 1.6045–1, amended; 26 CFR 1.6049 – 4, amended; 26
CFR 1.6049 –5, amended; 26 CFR 31.3406(g)–1, amend-
ed; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3,
amended; Withholding of tax on certain U.S. source in-
come paid to foreign persons and revision of information
reporting and backup withholding regulations (TD 9658)
13,748
SELF-EMPLOYMENT TAX
Virtual Currency (Notice 21) 16,938
SPECIAL ANNOUNCEMENT
Advance Pricing and Mutual Agreement Program (Ann 14) 16,
948
April 28, 2014Bulletin No. 2014–18
viii

INTERNAL REVENUE BULLETIN
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