Internal Revenue Bulletin 2017-15 (PDF rendition): IRS Notices

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

# INTERNAL REVENUE BULLETIN

IRS

## 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

### Action On Decision 2017-02, page 1072.

Nonacquiescence to the holding that buildings built to operate
as retail stores are placed in service for depreciation purposes
when substantially completed to house and secure racks,
shelving and merchandise.

### Action On Decision 2017-03, page 1072.

Nonacquiescence to the holding that, under the completed
contract method of accounting, taxpayer completed a home
construction contract when it incurred 95 percent of the esti-
mated cost of constructing an entire development.

### Announcement 2017-03, page 1077.

This Announcement is issued pursuant to § 521(b) of Pub. L.
106-170, the Ticket to Work and Work Incentives Improve-
ment Act of 1999, which requires the Secretary of the Trea-
sury to report annually to the public concerning advance pric-
ing agreements (APAs) and the Advance Pricing and Mutual
Agreement Program (APMA Program), formerly known as the
Advance Pricing Agreement Program (APA Program). The first
report covered calendar years 1991 through 1999. Subse-
quent reports covered each calendar year 2000 through 2015
separately. This eighteenth report describes the experience,
structure, and activities of the APMA Program during calendar
year 2016. It does not provide guidance regarding the appli-
cation of the arm's length standard.

Bulletin No. 2017-15
April 10, 2017

### Notice 2017-17, page 1074.

This notice invites comments on a proposed revenue proce-
dure that, if finalized, will provide procedures by which a
taxpayer may request consent to change a method of account-
ing for recognizing income when the change is made for the
same taxable year for which the taxpayer adopts the new
financial accounting revenue recognition standards and the
change is made as a result of, or directly related to, the
adoption of the new revenue recognition standards.

## EMPLOYMENT TAX

### Action On Decision 2017-04, page 1072.

Acquiescence in result only as to whether Taxpayer's payment
of personal expenses on behalf of its sole shareholder-
corporate officer constitutes wages subject to Federal employ-
ment taxes.

## 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.

## Actions Relating to Court Decisions

It is the policy of the Internal Revenue
Service to announce at an early date whether
it will follow the holdings in certain 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 unappealed issues
decided adverse to the government. Gener-
ally, an Action on Decision is issued where
its guidance would be helpful to Service
personnel working with the same or similar
issues. Unlike a Treasury Regulation or a
Revenue Ruling, an Action on Decision is
not an affirmative statement of Service po-
sition. 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 conclusions
applying the law to the facts in the particular
case at the time the Action on Decision was
issued. Caution should be exercised in ex-
tending the recommendation of the Action
on Decision to similar cases where the facts
are different. Moreover, the recommenda-
tion in the Action on Decision may be su-

perseded by new legislation, regulations,
rulings, cases, or Actions on Decisions.
Prior to 1991, the Service published acqui-
escence or nonacquiescence only in certain
regular Tax Court opinions. The Service has
expanded its acquiescence program to in-
clude other civil tax cases where guidance is
determined to be helpful. 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 deciding the case, the recommenda-
tion of any Action on Decision will be pub-
lished in the Internal Revenue Bulletin.

The recommendation in every Action on
Decision will be summarized as acquies-
cence, acquiescence in result only, or non-
acquiescence. Both "acquiescence" and "ac-
quiescence 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, "acquiescence" indicates
neither approval nor disapproval of the rea-
sons assigned by the court for its conclu-
sions; whereas, "acquiescence in result
only" indicates disagreement or concern

with some or all of those reasons. "Nonac-
quiescence” signifies that, although no fur-
ther review was sought, the Service does not
agree with the holding of the court and,
generally, will not follow the decision in
disposing of cases involving other taxpay-
ers. In reference to an opinion of a circuit
court of appeals, a "nonacquiescence" indi-
cates that the Service will not follow the
holding on a nationwide basis. However, the
Service will recognize the precedential im-
pact of the opinion on cases arising within
the venue of the deciding circuit.

The Commissioner does NOT ACQUI-
ESCE in the following decisions:

Stine, LLC v. United States,1
No. 13-03224, 2015 WL 403146
(W.D. La. Jan. 27, 2015)

Shea Homes, Inc. and Subs. v. Com-
missioner,2

834 F.3d 1061 (9th Cir. 2016), aff'g
142 T.C. 60 (2014)

The Commissioner does ACQUIESCE
IN RESULT ONLY in the following de-
cision:

Scott Singer Installations, Inc. v.
Commissioner,3
T.C. Memo 2016-161

1Nonacquiescence to the holding that buildings built to operate as retail stores are placed in service for depreciation purposes when substantially completed to house and secure racks, shelving
and merchandise.

2Nonacquiescence to the holding that, under the completed contract method of accounting, taxpayer completed a home construction contract when it incurred 95 percent of the estimated
cost of constructing an entire development.

3 Acquiescence in result only as to whether Taxpayer's payment of personal expenses on behalf of its sole shareholder-corporate officer constitutes wages subject to Federal employment
taxes.

## Part III. Administrative, Procedural, and Miscellaneous

PROPOSED REVENUE
PROCEDURE FOR
REQUESTING CONSENT TO
CHANGE A METHOD OF
ACCOUNTING WHERE THE
CHANGE IS MADE AS A
RESULT OF, OR DIRECTLY
RELATED TO, THE
ADOPTION OF NEW
FINANCIAL ACCOUNTING
STANDARDS, "REVENUE
FROM CONTRACTS WITH
CUSTOMERS."

Notice 2017-17
PURPOSE

This notice invites comments on a
proposed revenue procedure that, if fi-
nalized, will provide procedures by
which a taxpayer may request consent to
change a method of accounting for rec-
ognizing income when the change is
made for the same taxable year for
which the taxpayer adopts the new fi-
nancial accounting revenue recognition
standards and the change is made as a
result of, or directly related to, the adoption
of the new revenue recognition standards (a
qualifying same-year method change).

## BACKGROUND

On May 28, 2014, the Financial Ac-
counting Standards Board (FASB) and the
International Accounting Standards Board
(IASB) jointly announced new financial
accounting standards for recognizing rev-
enue (new standards), titled "Revenue
from Contracts with Customers." See
FASB Update No. 2014-09 and IASB
International Financial Reporting Stan-
dard (IFRS) 15.

The new standards are effective for
publicly-traded entities, certain not-for-
profit entities, and certain employee
benefit plans for annual reporting peri-
ods beginning after December 15, 2017.
For all other entities, the new standards
are effective for annual reporting peri-
ods beginning after December 15, 2018.
Early adoption is allowed for reporting

periods beginning after December 15,
2016. See FASB Update No. 2015-14,
"Revenue from Contracts with Custom-
ers (Topic 606), Deferral of the Effec-
tive Date."

Since the joint announcement, FASB
and IASB have revised the new standards
and provided guidance on how to imple-
ment the new standards in certain situations.
See, e.g., FASB Update No. 2015-14;
FASB Update No. 2016-10, "Revenue
from Contracts with Customers (Topic
606), Identifying Performance Obligations
and Licensing."

On June 15, 2015, the Department of
Treasury (Treasury Department) and the
Internal Revenue Service (IRS) pub-
lished Notice 2015-40, 2015-24 I.R.B.
1057, which requested comments on
federal tax accounting issues related to
the adoption of the new standards, in-
cluding, whether the new standards are
permissible methods of accounting for
federal income tax purposes, the types
of accounting method change requests
that might result from adopting the new
standards, and whether the current pro-
cedures for obtaining IRS consent to
change a method of accounting are ad-
equate to accommodate those requests.
Very few comments were received.
Some commenters requested additional
time to respond and others reported that,
as a result of adopting the new standards,
taxpayers might request multiple changes
in accounting method. This notice ad-
dresses only the procedures for obtaining
IRS consent to a qualifying same-year
method change. The Treasury Department
and the IRS continue to invite comments
on issues of conformity between the new
standards and the Internal Revenue Code
(Code) and the Treasury Regulations
(Regulations), and are considering ad-
dressing these issues in separate guidance.

Qualifying same-year method changes
may include automatic changes for which
existing guidance, including Revenue Pro-
cedure 2015-13, 2015-1 I.R.B. 419, and
Revenue Procedure 2016-29, 2016-21
I.R.B. 880, already provides automatic
change procedures. Taxpayers requesting
consent for automatic changes for which
existing guidance already provides auto-
matic change procedures must use the exist-

ing automatic change procedures to make a
request. For qualifying same-year method
changes for which existing guidance does
not provide automatic change procedures
but which comply with § 451 of the Code or
other guidance regarding the taxable year of
inclusion of income, the taxpayer must
make the change under the proposed reve-
nue procedure.

## REQUEST FOR COMMENTS ON ISSUES OF CONFORMITY BETWEEN THE NEW STANDARDS AND THE CODE AND REGULATIONS

Adoption of the new standards may
create or increase differences between
financial accounting and tax accounting
rules. The Treasury Department and the
IRS recognize that there is interest in
clarifying whether the new standards are
permissible methods of accounting that
may be used for federal income tax pur-
poses. Accordingly, the Treasury De-
partment and the IRS continue to seek
comments on the specific issues identi-
fied in Notice 2015-40 regarding con-
formity between the new standards and
the Code and the Regulations. Com-
ments are specifically requested on the
following issues:

1\. To what extent would using the new
standards for federal income tax purposes
result in acceleration or deferral of income
under § 451 or other income provisions of
the Code?

2\. What industry and/or transaction-
specific issues might arise as a result of
the new standards that may need to be
addressed in future guidance?

3\. To what extent do the new stan-
dards deviate from the requirements of
§ 451? In what situations should the IRS
allow taxpayers who adopt the new stan-
dards to follow their book method of
accounting for tax purposes (for exam-
ple, where income is always acceler-
ated)?

4\. To what extent do the rules regard-
ing allocation of standalone sales price
and transaction price in the new standards
affect taxpayers' ability to satisfy their tax
obligations?

## REQUEST FOR COMMENTS ON PROCEDURES FOR METHOD CHANGES

This notice sets forth proposed proce-
dures for obtaining IRS consent to a qual-
ifying same-year method change. In con-
nection with this notice, the Treasury
Department and the IRS request com-
ments on all aspects of the proposed pro-
cedures and on the specific method
change issues identified in Notice 2015-
40. Comments are specifically requested
on the following issues:

1\. Is the exception for small businesses
in paragraph 5.02(2) of the proposed rev-
enue procedure appropriate?

2\. What types of changes in methods of
accounting do taxpayers anticipate re-
questing?

3\. Do taxpayers anticipate requesting
changes in methods of accounting prior to
the effective dates of the new standards?

4\. Which procedures should taxpayers
be required to use to request permission
for a qualifying same-year method
change, the automatic accounting method
change procedures or the advance consent
procedures?

5\. What changes, other than those de-
scribed in Section 5 of the proposed rev-
enue procedure, do taxpayers expect will
be requested in the year the taxpayer
adopts the new financial standards, and
should they be allowed as automatic
changes?

6\. What related accounting method
changes do taxpayers anticipate request-
ing that may appropriately be made on a
single Form 3115?

7\. If multiple changes are requested on
a single Form 3115, should the taxpayer
report a separate § 481 adjustment for
each change and should those adjustments
be netted and a single spread period ap-
plied?

8\. What alternatives to filing a Form
3115 would reduce the burden of compli-
ance?

9\. What transition procedures may be
helpful?

10\. What additional procedural
changes would be appropriate and help-
ful?

## WHERE TO SEND COMMENTS

Comments must be submitted by July
26, 2017. Comments, identified by Notice
2017-17, may be submitted using one of
the following methods:

· By Mail:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2017-17)
Room 5203
P.O. Box 7602
Ben Franklin Station
Washington, D.C. 20044

· By Hand or Courier Delivery: Sub-
missions may be hand-delivered
Monday through Friday between the
hours of 8 a.m. and 4 p.m. to:
Courier's Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR
(Notice 2017-17)

1111 Constitution Avenue, N.W.
Washington, D.C. 20224

· Electronic: Alternatively, persons may
submit comments electronically to
Notice.Comments@irscounsel.treas.gov.
Please include "Notice 2017-17" in the
subject line of any electronic communi-
cations.

All submissions will be available for pub-
lic inspection and copying in room 1621,
1111 Constitution Avenue, N.W., Wash-
ington, D.C., from 9 a.m. to 4 p.m.

PROPOSED REV. PROC. [2017-XX]

## SECTION 1. PURPOSE

This revenue procedure provides pro-
cedures under § 446 of the Internal Rev-
enue Code (Code) and § 1.446-1(e) of the
Income Tax Regulations (Regulations)
to obtain consent of the Commissioner
of Internal Revenue (Commissioner) to
change a method of accounting for recog-
nizing income for federal income tax pur-
poses when the change is a result of, or
directly related to, adoption of the new
financial accounting standards for recog-
nizing revenue by the taxpayer and is
made for the same taxable year as the
adoption of the new financial accounting
standards for recognizing revenue that
were issued by the Financial Accounting
Standards Board (FASB) and the Interna-
tional Accounting Standards Board
(IASB). See FASB Update No. 2014-09,

"Revenue from Contracts with Customers
(Topic 606)," and IASB International Fi-
nancial Reporting Standard (IFRS) 15,
"Revenue from Contracts with Custom-
ers."

## SECTION 2. BACKGROUND

.01 Method of accounting generally.

(1) Section 446(a) of the Code and
§ 1.446-1(a)(1) of the Regulations pro-
vide that taxable income is computed un-
der the method of accounting the taxpayer
regularly uses to compute income in keep-
ing the taxpayer's books.

(2) Section 1.446-1(a)(4) of the Reg-
ulations requires a taxpayer to maintain
accounting records that include the tax-
payer's regular books of account and
other records and data necessary to sup-
port the entries on the taxpayer's books of
account and on the taxpayer's return.

.02 Consent for a change in method of
accounting. Section 446(e) of the Code
and § 1.446-1(e)(2)(i) of the Regulations
provide that, except as otherwise pro-
vided, a taxpayer must secure the consent
of the Commissioner before changing a
method of accounting for any item for
federal income tax purposes.

.03 Accounting for income generally.
Section 451(a) of the Code and § 1.451-
1(a) of the Regulations provide that any
item of gross income must be included in
gross income in the year in which it was
received by the taxpayer unless it is in-
cludible for a different year pursuant to
the taxpayer's method of accounting.

.04 New revenue recognition stan-
dards.

(1) The FASB and the IASB have an-
nounced new financial accounting stan-
dards for recognizing revenue (new stan-
dards). See FASB Update No. 2014-09,
IASB International Financial Reporting
Standard (IFRS) 15, and section 3 of this
revenue procedure.

(2) The new standards are effective for
publicly-traded entities, certain not-for-
profit entities, and certain employee ben-
efit plans for annual reporting periods be-
ginning after December 15, 2017. For all
other entities, the new standards are effec-
tive for annual reporting periods begin-
ning after December 15, 2018. Early
adoption is allowed for reporting periods
beginning after December 15, 2016. See
FASB Update No. 2015-14, "Revenue

from Contracts with Customers (Topic
606), Deferral of the Effective Date."

.05 Effect of new revenue recognition
standards.

(1) The Internal Revenue Service (Ser-
vice) anticipates that many taxpayers will
request consent to change a method of
accounting for one or more items of in-
come as a result of, or directly related, to
the adoption of the new revenue standards
for the same taxable year that the new
standards are adopted for financial ac-
counting purposes.

(2) The Service must balance taxpay-
ers' need to comply with the new stan-
dards with the Service's need to approve
appropriate method changes.

## SECTION 3. DEFINITIONS

.01 Change in Method of Accounting
Definitions. The definitions in section 3 of
Rev. Proc. 2015-13, 2015-5 I.R.B. 419,
or any successor, apply for purposes of
this revenue procedure.

.02 New Standards. "New standards"
refers to the financial accounting stan-
dards for recognizing revenue that were
issued in FASB Update No. 2014-09,
"Revenue from Contracts with Customers
(Topic 606)," and IASB International Fi-
nancial Reporting Standard (IFRS) 15,
"Revenue from Contracts with Custom-
ers," as updated and revised hereafter.

.03 Qualifying Same-Year Method
Change. A qualifying same-year method
change is a change of method of account-
ing for recognizing income that is made
for the same year as the year the taxpayer
adopts the new standards and made as a
result of, or directly related to, the adop-
tion of those standards.

## SECTION 4. SCOPE

This revenue procedure applies to tax-
payers that adopt the new standards and
that request the Commissioner's consent,
pursuant to § 446(e) of the Code and
§ 1.446-1(e)(3) of the Income Tax Reg-

ulations, to make a qualifying same-year
method change.

## SECTION 5. GENERAL APPLICATION PROCEDURES AND AUDIT PROTECTION

.01 Qualifying Same-Year Method
Change under Existing Automatic Change
Guidance.

A method change that is within the
scope of section 4 of this revenue proce-
dure that qualifies as an automatic change
in the List of Automatic Changes (under
Rev. Proc. 2016-29, 2016-21 I.R.B. 880,
or any successor) and otherwise satisfies
the requirements of paragraphs 5.01(1)
(a)-(d) of Rev. Proc. 2015-13 (or any
successor), must be implemented by ap-
plying the automatic change procedures in
Section 6 of Rev. Proc. 2015-13 (or any
successor) and the List of Automatic
Changes.

.02 Qualifying Same-Year Method Change
that Complies with Income Provisions of the
Code or the Regulations.

(1) A method change that is within the
scope of section 4 of this revenue proce-
dure that is not described in section 5.01
of this revenue procedure, which satisfies
the requirements of sections 5.01(1)(c)
and (d) of Rev. Proc. 2015-13 (or any
successor), and which complies with
§ 451 of the Code or other guidance, must
be implemented by applying the auto-
matic change procedures in section 6 of
Rev. Proc. 2015-13 (or any successor). A
taxpayer making a change under this sec-
tion 5.02 must file a Form 3115, check the
box for line 1(b), and write "Rev. Proc.
2017-XX" followed by the applicable in-
come provision of the Code or Income
Tax Regulations or the applicable relevant
guidance. In addition, the taxpayer must
attach a brief description of the change
and why it satisfies the applicable income
provision or guidance referenced in line
1(b) of the Form 3115.

(2) A taxpayer with one or more sepa-
rate and distinct trade(s) or business(es),

within the meaning of § 1.446-1(d), that
individually have (a) total assets of less
than $10 million as of the first day of the
taxable year for which a change in method
of accounting is requested, or (b) average
annual gross receipts of $10 million or
less for the three preceding taxable years,
as determined under § 1.263(a)-3(h)(3)
(substituting “separate and distinct trade
or business" for "taxpayer"), may make
the change for each such separate and
distinct trade or business on a cut-off ba-
sis. Accordingly, a § 481(a) adjustment is
neither permitted nor required for each
such separate and distinct trade or busi-
ness. See section 2.07 of Rev. Proc.
2015-13.

(3) A § 481(a) adjustment must be
computed for the year of change for all
separate and distinct trades or businesses
other than those for which paragraph
5.02(2) of this revenue procedure provides
otherwise and for taxpayers for which
paragraph 5.02(2) of this revenue proce-
dure does not apply. See section 7.02 of
Rev. Proc. 2015-13.

.03 Multiple Requests. Multiple re-
quests to make qualifying same-year
method changes may be made in one re-
quest.

## SECTION 6. EFFECTIVE DATE

This revenue procedure is effective for
taxable years ending on or after [INSERT
DATE OF PUBLICATION OF FINAL
REVENUE PROCEDURE].

## SECTION 7. DRAFTING INFORMATION

The principal author of this revenue
procedure is Charles Gorham of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding this revenue procedure, contact
Mr. Gorham at (202) 317-7003 (not toll-
free number), or Peter E. Ford, at (202)
317-7011 (not a toll-free number).

## Part IV. Items of General Interest

### Announcement 2017-03

#### Announcement and Report Concerning Advance Pricing Agreements

March 27, 2017

This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act
of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs)
and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement
Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year
2000 through 2015 separately. This eighteenth report describes the experience, structure, and activities of the APMA Program during
calendar year 2016. It does not provide guidance regarding the application of the arm's length standard.

Part I of this report includes information on the structure, composition, and operation of the APMA Program; Part II presents
statistical data; and Part III includes general descriptions of various elements of the APAs executed in 2016, including types of
transactions covered, transfer pricing methods used, and completion time.

John C. C. Hughes
Acting Director, Advance Pricing and Mutual Agreement Program

# Part I. The APMA Program - Structure, Composition, and Operation [Pub. L. 106-170 § 521(b)(2)(A)]

In February of 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing
Operations within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff
responsible for transfer pricing cases, thereby forming the APMA Program.

After the formation of the APMA Program, the team that developed the IRS position in a bilateral or multilateral case and finalized
the APA with the taxpayer also became responsible for discussing the case and obtaining an agreement with the treaty partner. This
compression of functions into a single APA team has helped to eliminate inefficiencies and has decreased the amount of time it takes
to reach resolution once a case is set for discussion with the treaty partner.

As of December 30, 2016, the APMA Program was comprised of 62 team leaders, 20 economists, and 10 senior managers organized
into 10 groups (7 team leader groups and 3 economist groups). Each team leader group has responsibility for cases involving certain
countries with one of the economist groups also taking responsibility of a country. Because of the large volume of cases with certain
treaty partners, some countries are the responsibility of more than one group. The APMA Program's main office is located in
Washington, DC, and it also has a significant presence in San Francisco and the Los Angeles area.

On August 31, 2015, new revenue procedures governing MAP and APA applications were published in 2015-35 I.R.B. on pages
236 and 263, respectively. Revenue Procedure (Rev. Proc.) 2015-41 provides guidance and instructions on filing APA requests as
well as guidance and information on the administration of APAs. Rev. Proc. 2015-41 updates and supersedes Rev. Proc. 2006-9,
2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B. 1133, which is also superseded. Rev. Proc. 2015-40 provides
procedures and guidance on requesting assistance from the U.S. Competent Authority where the taxpayer believes that the actions
of the United States or a treaty country result or will result in the taxpayer being subject to taxation not in accordance with the
applicable U.S. tax treaty. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54, 2006-2 C.B. 1035.

The model APA agreement, which was last significantly revised in 2009, is currently under review for future changes. The 2009 model
appears in this report as Appendix 1. A list of primary APMA contacts is available at https://www.irs.gov/businesses/corporations/apma-
contacts.

# Part II. APMA Program Statistical Data [Pub. L. 106-170 § 521(b)(2)(C)(i-viii)]

Table 1: APA Applications Filed § 521(b)(2)(C)(i)

Unilateral

Bilateral

Multilateral

Total

Filed 1991-19994

401

Filed 2000-2015

542

1194

1746

Filed in 2016

Total Filed 1991-2016

2245

Applications Filed 2007-2016

200

150

100

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

The table above illustrates the number of complete applications filed per year. As of December 31, 2016, APMA had also received
17 user fee filings that were not yet accompanied by substantially complete APA applications, in addition to the 98 complete APA
applications.

Bilateral APAs Filed by Country 2016

Japan
31%

Canada
8%

Germany
7%

Italy
4%

India
34%

UK
4%

All Other Countries
12%

4The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

Table 2: Executed and Pending APAs § 521(b)(2)(C)(ii-vi)

Unilateral

Bilateral

Multilateral

Total

Total Executed 1991-2015

539

958

1511

Total Executed in 2016

Total Executed 1991-2016

560

1023

1597

Total Pending

322

398

Renewals Executed in 2016

Renewals Pending

131

166

APAs Executed 2007-2016

150

100

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

Of the 86 agreements executed in 2016, 41 percent were new APAs (i.e., not a renewal of a prior APA). This was a slight increase
from the 40 percent executed in 2015.

Bilateral APAs
Executed by Country 2016

All Other Countries
11%

Germany
5% France
4%

Korea
6%

Japan
54%

Canada
20%

As the chart above illustrates, nearly three quarters of the total number of bilateral APAs executed in 2016 involved the United States
entering into mutual agreements with either Japan or Canada.

# Pending APAs 2007-2016

500

400

300

200

100

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

The number of pending APAs dropped slightly from 2015 to 2016 with Japan and Canada continuing to account for almost half of
all pending bilateral APAs.

Bilateral APAs Pending by Country 2016

All Other Countries
19%

China
4%

Japan
34%

UK
5%

Korea
7%

Germany
8%

India
9%

Canada
14%

Table 3: APAs Revoked or Cancelled and Applications Withdrawn

## § 521(b)(2)(C)(vii)

Table 4: APAs Finalized or Renewed7 by Industry § 521(b)(2)(C)(viii)

Unilateral

Bilateral

Multilateral

Total

Revoked or Cancelled in 2016

Total Revoked or Cancelled 1991-20165

Applications Withdrawn in 2016

Total Applications Withdrawn 1991-20166

224

Industry

Manufacturing

Wholesale/Retail Trade

Services

All Other Industries

APAs by Industry Finalized or Renewed 2016

Manufacturing
47%

Wholesale/Retail
Trade
38%

All Other Industries
8%

Services
7%

Table 4a: Manufacturing APAs Finalized or Renewed 2016

Wholesale/Retail Trade

Computer and Electronic Products

Chemical

Transportation Equipment

Miscellaneous Manufacturing8

All Other Types of Manufacturing

5The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

6The first APA Statutory Report, which compiled APA data from 1991-1999, did not report the cumulative number of applications for those years by submission type, so the cumulative
totals cannot be reported in that manner.

7APAs finalized or renewed are the same as APAs executed.

8Miscellaneous Manufacturing is NAICS code 339.

Manufacturing APAs
Finalized or Renewed 2016

Chemical
15%

Computer and
Electronic Products
17%

Transportation
Equipment
15%

All Other
Manufacturing
30%

Miscellaneous
Manufacturing
23%

## Table 4b: Wholesale/Retail Trade APAs Finalized or Renewed 2016

Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods

Merchant Wholesalers, Nondurable Goods

All Other Types of Other Wholesale/Retail Trade

Wholesale/Retail Trade APAs Finalized or Renewed 2016

All Other
Wholesalers
9%

Merchant
Wholesalers,
Nondurable Goods
27%

Merchant
Wholesalers, Durable
Goods
64%

# Part III. General Descriptions of APAs Executed in 2016 [Pub. L. 106-170 § 521(b)(2)(D) and (E)]

## Nature of the Relationships § 521(b)(2)(D)(i)

Relationships between Controlled Parties in 2016

U.S. Parent & Non-
U.S. Subsidiary
20%

Sister Companies
15%

Non-U.S. Parent &
U.S. Subsidiary
65%

As in prior years, more than half of the APAs executed in 2016 involved transactions between non-U.S. parents and U.S. subsidiaries.

### Covered Transactions, Functions and Risks, and Tested Parties § 521(b)(2)(D)(ii-iii)

Types of Covered Transactions in 2016

Sale of Tangible
Property into the U.S.
27%

All Other Types of
Covered Transactions
2%

Sale of Tangible
Property from the
U.S.
17%

Provision of Services
by a Non-U.S. Entity
14%

Use of Intangible
Property by a U.S.
Entity
14%

Provision of Services
by a U.S. Entity
20%

Use of Intangible
Property by a Non-
U.S. Entity
6%

Although the majority of transactions9 covered in APAs executed in 2016 involve the sale of tangible goods and the provision of services,
the IRS also has successfully completed numerous APAs involving the use of intangible property. While transactions involving intangibles
may be more challenging and represent a smaller percentage of the covered transactions in 2016 (20 percent), the IRS continues to seek
opportunities to work with taxpayers and treaty partners to provide prospective certainty for such transactions wherever appropriate.

In the majority of APAs, the covered transactions involve numerous business functions and risks. For instance, with respect to
functions, APAs involving manufactured products typically involve a controlled group that conducts research and development
(R&D), engages in product design and engineering, manufactures the product, markets and distributes the product, and performs
support functions such as legal, finance, and human resources services. Regarding risks, the controlled group may assume a variety
of risks including market risks, R&D risks, financial risks, credit and collection risks, product liability risks, and general business
risks. In the APA evaluation process, a significant amount of time and effort is devoted to understanding how the functions and risks
are allocated amongst the controlled group of companies that are party to the covered transactions. Generally, for methods requiring
selection of a tested party, the tested party that is chosen will be the least complex of the controlled taxpayers.

9APAs often cover more than one type of transaction.

Types of Tested Parties in 2016

U.S. Distributor
42%

All Other Types of
Tested Parties
1%

Non-U.S. Distributor
12%

Non-U.S. Service
Provider
6%

Non-U.S.
Manufacturer
6%

U.S. Manufacturer
17%

U.S. Service Provider
16%

75 percent of the tested parties in 201610 were U.S. distributors, U.S. manufacturers, or U.S. service providers.

### Transfer Pricing Methods Used

#### § 521(b)(2)(D)(iv)

Consistent with prior years, in 2016, the primary transfer pricing method (TPM) used for both the sale of tangible property and the
use of intangible property was the comparable profits method/transactional net margin method (CPM/TNMM). The CPM/TNMM
was used for 89 percent of transfers of tangible and intangible property while all other methods combined accounted for the other
11 percent of such transactions.

For covered transfers of tangible and intangible property that used the CPM/TNMM, an operating margin (OM) continues to be the
most common profit level indicator (PLI) used to benchmark results. It was utilized 67 percent of the time. Other PLIs, such as the
Berry Ratio and Return on Assets or Capital Employed, made up the other 33 percent. As used here, OM means the ratio of operating
profits to sales,11 and "Berry Ratio" means the ratio of gross profit to operating expenses.12 The majority of services transactions (76
percent) also used the CPM/TNMM, and OM was the most common PLI (used 43 percent of the time). 13

### Sources of Comparables, Comparables Selection Criteria, and Nature of Adjustments to Comparables or Tested Party Data

### § 521(b)(2)(D)(v-vii)

For the APAs executed in 2016 that used external comparable data in the analysis, the most widely used data source for comparables
was Standard and Poor's Compustat/Capital IQ database. Other sources were also used in appropriate cases (e.g., where the tested
party was not the U.S. entity or transaction-based methods were applied). The other more commonly used databases are listed in the
table below.

Table 5: Sources of Comparable Data

Avention (formerly known as OneSource)

Mergent

Bloomberg

Orbis

Disclosure

Recap

Global Vantage

RoyaltySource

ktMINE

RoyaltyStat

LoanConnector

Worldscope

In making comparability adjustments, the standard balance sheet adjustments identified in Treas. Reg. § 1.482-1(d) and § 1.482-5(c),
including adjustments for differing amounts of payables, receivables, and inventory, were made in the majority of cases. Where
appropriate, adjustments for different accounting practices were made to convert from LIFO to FIFO inventory accounting, and a
small number of cases also involved the accounting reclassification of expenses, e.g., from COGS to operating expenses.

10Not all APAs executed in 2016 involved a tested party.

11 See Treas. Reg. § 1.482-5(b)(4)(ii)(A).

12See Treas. Reg. § 1.482-5(b)(4)(ii)(B).

13In 2016, the majority of the APAs that covered services transactions also included tangible/intangible transactions and were not tested under a separate PLI.

# Ranges, Targets, and Adjustment Mechanisms § 521(b)(2)(D)(viii-ix)

The majority of transactions covered in APAs target an interquartile range as described in Treas. Reg. § 1.482-1(e)(2)(iii)(C). Where
the transaction involves a royalty payment for the use of intangible property, both specific royalty rates and ranges have been used.
In some cases where the covered transaction is the payment of a royalty based solely on external royalty agreements, a secondary
method, e.g., a test of the post-royalty operating margin, has also been used. The testing periods of the APAs executed in 2016 were
either: (1) a single year, (2) the term of the APA only, or (3) the term of the APA plus rollback years.

APAs executed in 2016 included a number of mechanisms for making adjustments to tested party results when the results fall outside
the range or do not match the point required by the APA. The following are examples of the mechanisms used: an adjustment
bringing the tested party's results to the closer edge of the range applied to the results of a single year; an adjustment to the closer
edge of the range applied to the results over the APA term; an adjustment to the specified point or royalty rate; or an adjustment to
the median of the range for a single year.

# Critical Assumptions § 521(b)(2)(D)(v)

The model APA used by the IRS (included as Appendix 1 of this report) includes a standard critical assumption that there will be
no material changes to the taxpayer's business or to its tax or financial accounting practices during the APA term. Each of the APAs
executed in 2016 included this standard critical assumption. A few bilateral cases have included critical assumptions tied either to
the taxpayer's profitability in a certain year or over the term of the APA, or to the amount of non-covered transactions as a percentage
of the taxpayer's revenue. Pursuant to § 7.06(3) of Rev. Proc. 2015-41, 2015 I.R.B. 263, APMA will cancel an APA in the event
of a failure of a critical assumption unless the parties agree to revise the APA.

# Term Lengths of APAs Executed in 2016 § 521(b)(2)(D)(x)

Table 6: Term Lengths of APAs Executed in 2016

Term Length (years)

Number of APAS

Average

Term Length of APAs Executed in 2016

Number of APAS

Number of Years

As described in § 3.03(1) of Rev. Proc. 2015-41, taxpayers should request an APA term that would cover at least 5 prospective years
and may also request that the APA be "rolled back" to cover one or more earlier taxable years, although the appropriate APA term
is decided on a case-by-case basis. Of the APAs executed in 2016, only 20 percent included rollback years. A substantial number
of those APAs with terms of greater than 5 years were submitted as a request for a 5-year term, and the additional years were agreed
to between the taxpayer and the IRS (or, in the case of a bilateral APA, between the IRS and the foreign government upon the
taxpayer's request) to ensure a reasonable amount of prospectivity in the APA term.

# Amount of Time Taken to Complete New and Renewal APAs § 521(b)(2)(E)

Table 7: Months to Complete New and Renewal APAs Executed in 2016

Unilateral

Bilateral

Unilateral &amp; Bilateral

Average

Median

Average

Median

Average

Median

New

33.9

23.4

50.5

48.8

48.7

46.7

Renewal

21.8

12.0

34.2

32.1

29.9

23.2

New &amp; Renewal

24.1

15.4

42.4

35.6

37.9

32.8

Months to Complete New and Renewal APAs Executed in 2016

60.0

Months to Complete

50.0

New

40.0

8
Renewal

30.0

20.0

ENew &
Renewal

10.0

0.0

Median

Average
Unilateral

Average

Median

Median
Unilateral &
Bilateral

Average

Bilateral

Type of APA

The median time required to complete an APA in 2016 increased slightly from 31.9 months in 2015 to 32.8 months in 2016.

# Efforts to Ensure Compliance with APAS

## § 521(b)(2)(F)

As described in § 7.02 (1) of Rev. Proc. 2015-41, taxpayers are required to file annual reports to demonstrate compliance with the
terms and conditions of their APA. The filing and review of these annual reports are critical parts of the APA process. Through annual
report review, the APMA Program monitors taxpayer compliance with APAs on a contemporaneous basis. Annual report review also
provides current information on the success or problems associated with the various TPMs adopted in the APA process.

Each annual report received by the APMA Program is assigned to a designated APMA team leader. Whenever possible, annual report
reviews are assigned to the team leader who worked the case, or another staff member who is already familiar with the relevant facts
and terms of the APA. Other team leaders and economists may assist the assigned staff member as well. The annual report is also
sent to the field personnel with exam jurisdiction over the taxpayer. The field personnel conduct a compliance review and coordinate
with APMA personnel to resolve any questions or problems that might arise.

## Nature of Documentation Required in Annual Report

### § 521(b)(2)(D)(xi)

APA agreements require taxpayers to file timely and complete annual reports describing their operations and demonstrating
compliance with the APA's terms and conditions. Not every annual report will include each of the items listed in the following
table14; they are required where the facts demonstrate a need for such documentation.

14The source of this list is the 2009 APA Model Agreement.

Statement regarding all material differences between Taxpayer's business operations during APA year and description of Taxpayer's business operations contained in Taxpayer's APA request. If there are no material differences, a statement to that effect.

Statement concerning all material changes in Taxpayer's accounting methods and classifications, and methods of estimation, from those described or used in Taxpayer's request for the APA. If there has been no material change in accounting methods and classifications or methods of estimation, a statement to that effect.

Any change to the taxpayer notice information.

Description of any failure to meet critical assumptions. If there has been none, a statement to that effect.

Statement identifying whether or not any material information submitted while the APA request was pending is discovered to be false, incorrect, or incomplete.

The amount, reason for, and financial analysis of any compensating adjustment, for the APA year, including but not limited to: the amounts paid or received by each affected entity; the character (such as capital or ordi- nary expense) and country source of the funds transferred, and the specific line item(s) of any affected U.S. tax return; and any change to any entity classification for federal income tax purposes of any member of Tax- payer's group that is relevant to the APA.

The amounts, description, reason for, and financial analysis of any book-tax difference relevant to the TPM for the APA year, as reflected on Schedule M-1 or Schedule M-3 of the U.S. return for the APA year.

Statement regarding whether Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.

Financial statements and any necessary account detail to show compliance with the TPM, with a copy of the opinion from an independent certified public accountant or other documentation required by paragraph 5(f) of the APA.

10.

Financial analysis demonstrating Taxpayer's compliance with TPM.

11.

Organizational chart.

12.

A copy of the APA and any amendment.

13.

A penalty of perjury statement.

# Approaches for Sharing of Currency or Other Risks § 521(b)(2)(D)(xii)

In appropriate cases, APAs may provide specific approaches for dealing with currency risk, such as adjustment mechanisms and/or
critical assumptions.

# APPENDIX 1- Model APA (based on Rev. Proc. 2006-9) [§ 521(b)(2)(B)]

## ADVANCE PRICING AGREEMENT between [Insert Taxpayer's Name] and THE INTERNAL REVENUE SERVICE

## PARTIES

The Parties to this Advance Pricing Agreement (APA) are the Internal Revenue Service (IRS) and [Insert Taxpayer's Name],
EIN
.

## RECITALS

[Insert Taxpayer Name] is the common parent of an affiliated group filing consolidated U.S. tax returns (collectively referred to
as "Taxpayer"), and is entering into this APA on behalf of itself and other members of its consolidated group.

Taxpayer's principal place of business is [City, State]. [Insert general description of taxpayer and other relevant parties].

This APA contains the Parties' agreement on the best method for determining arm's-length prices of the Covered Transactions
under I.R.C. section 482, the Treasury Regulations thereunder, and any applicable tax treaties.

{If renewal, add} [Taxpayer and IRS previously entered into an APA covering taxable years ending
to
executed
on
.]

## AGREEMENT

The Parties agree as follows:

1\. Covered Transactions. This APA applies to the Covered Transactions, as defined in Appendix A.

2\. Transfer Pricing Method. Appendix A sets forth the Transfer Pricing Method (TPM) for the Covered Transactions.

3\. Term. This APA applies to the APA Term, as defined in Appendix A.

4\. Operation.

a. Revenue Procedure 2006-9 governs the interpretation, legal effect, and administration of this APA.

b. Nonfactual oral and written representations, within the meaning of sections 10.04 and 10.05 of Revenue Procedure 2006-9
(including any proposals to use particular TPMs), made in conjunction with the APA Request constitute statements made in
compromise negotiations within the meaning of Rule 408 of the Federal Rules of Evidence.

5\. Compliance.

a. Taxpayer must report its taxable income in an amount that is consistent with Appendix A and all other requirements of this APA
on its timely filed U.S. Return. However, if Taxpayer's timely filed U.S. Return for any taxable year covered by this APA (APA
Year) is filed prior to, or no later than 60 days after, the effective date of this APA, then Taxpayer must report its taxable income
for that APA Year in an amount that is consistent with Appendix A and all other requirements of this APA either on the original
U.S. Return or on an amended U.S. Return filed no later than 120 days after the effective date of this APA, or through such
other means as may be specified herein.

b. {Use or edit the following when U.S. Group or Foreign Group contains more than one member.} [This APA addresses the
arm's-length nature of prices charged or received in the aggregate between Taxpayer and Foreign Participants with respect to
the Covered Transactions. Except as explicitly provided, this APA does not address and does not bind the IRS with respect to
prices charged or received, or the relative amounts of income or loss realized, by particular legal entities that are members of
U.S. Group or that are members of Foreign Group.]

c. For each APA Year, if Taxpayer complies with the terms and conditions of this APA, then the IRS will not make or propose
any allocation or adjustment under I.R.C. section 482 to the amounts charged in the aggregate between Taxpayer and Foreign
Participant[s] with respect to the Covered Transactions.

d. If Taxpayer does not comply with the terms and conditions of this APA, then the IRS may:

i. enforce the terms and conditions of this APA and make or propose allocations or adjustments under I.R.C. section 482
consistent with this APA;

ii. cancel or revoke this APA under section 11.06 of Revenue Procedure 2006-9; or

iii. revise this APA, if the Parties agree.

e. Taxpayer must timely file an Annual Report (an original and four copies) for each APA Year in accordance with Appendix C
and section 11.01 of Revenue Procedure 2006-9. Taxpayer must file the Annual Report for all APA Years through the APA Year
ending [insert year] by [insert date]. Taxpayer must file the Annual Report for each subsequent APA Year by [insert month and day]
immediately following the close of that APA Year. (If any date falls on a weekend or holiday, the Annual Report shall be due on
the next date that is not a weekend or holiday.) The IRS may request additional information reasonably necessary to clarify or
complete the Annual Report. Taxpayer will provide such requested information within 30 days. Additional time may be allowed for
good cause.

f. The IRS will determine whether Taxpayer has complied with this APA based on Taxpayer's U.S. Returns, the Financial
Statements, and other APA Records, for the APA Term and any other year necessary to verify compliance. For Taxpayer to comply
with this APA, {use the following or an alternative} an independent certified public accountant must render an opinion that
Taxpayer's Financial Statements present fairly, in all material respects, Taxpayer's financial position under U.S. GAAP.

g. In accordance with section 11.04 of Revenue Procedure 2006-9, Taxpayer will (1) maintain the APA Records, and (2) make
them available to the IRS in connection with an examination under section 11.03. Compliance with this subparagraph constitutes
compliance with the record-maintenance provisions of I.R.C. sections 6038A and 6038C for the Covered Transactions for any
taxable year during the APA Term.

h. The True Taxable Income within the meaning of Treasury Regulations sections 1.482-1(a)(1) and (i)(9) of a member of an
affiliated group filing a U.S. consolidated return will be determined under the I.R.C. section 1502 Treasury Regulations.

i. {Optional for US Parent Signatories) To the extent that Taxpayer's compliance with this APA depends on certain acts of Foreign
Group members, Taxpayer will ensure that each Foreign Group member will perform such acts.

6\. Critical Assumptions. This APA's critical assumptions, within the meaning of Revenue Procedure 2006-9, section 4.05, appear
in Appendix B. If any critical assumption has not been met, then Revenue Procedure 2006-9, section 11.06, governs.

7\. Disclosure. This APA, and any background information related to this APA or the APA Request, are: (1) considered "return
information" under I.R.C. section 6103(b)(2)(C); and (2) not subject to public inspection as a "written determination" under I.R.C.
section 6110(b)(1). Section 521(b) of Pub. L. 106-170 provides that the Secretary of the Treasury must prepare a report for public
disclosure that includes certain specifically designated information concerning all APAs, including this APA, in a form that does not
reveal taxpayers' identities, trade secrets, and proprietary or confidential business or financial information.

8\. Disputes. If a dispute arises concerning the interpretation of this APA, the Parties will seek a resolution by the Director of the
Advance Pricing and Mutual Agreement Program, to the extent reasonably practicable, before seeking alternative remedies.

9\. Materiality. In this APA the terms "material" and "materially" will be interpreted consistently with the definition of "material
facts" in Revenue Procedure 2006-9, section 11.06(4).

10\. Section Captions. This APA's section captions, which appear in italics, are for convenience and reference only. The captions do
not affect in any way the interpretation or application of this APA.

11\. Terms and Definitions. Unless otherwise specified, terms in the plural include the singular and vice versa. Appendix D contains
definitions for capitalized terms not elsewhere defined in this APA.

12\. Entire Agreement and Severability. This APA is the complete statement of the Parties' agreement. The Parties will sever, delete,
or reform any invalid or unenforceable provision in this APA to approximate the Parties' intent as nearly as possible.

13\. Successor in Interest. This APA binds, and inures to the benefit of, any successor in interest to Taxpayer.

14\. Notice. Any notices required by this APA or Revenue Procedure 2006-9 must be in writing. Taxpayer will send notices to the
IRS at the address and in the manner set forth in Revenue Procedure 2006-9, section 4.11. The IRS will send notices to:

Taxpayer Corporation
Attn: Jane Doe, Sr. Vice President (Taxes)
1000 Any Road
Any City, USA 10000
(phone:
)

15\. Effective Date and Counterparts. This APA is effective starting on the date, or later date of the dates, upon which all Parties
execute this APA. The Parties may execute this APA in counterparts, with each counterpart constituting an original.

WITNESS,

The Parties have executed this APA on the dates below.

[Taxpayer Name in all caps]

By:
Jane Doe
Sr. Vice President (Taxes)

Date:

201

IRS
By:

Date:

201

John C. C. Hughes
Acting Director, Advance Pricing and Mutual
Agreement Program

## APPENDIX A COVERED TRANSACTIONS AND TRANSFER PRICING METHOD (TPM)

### 1. Covered Transactions.

[Define the Covered Transactions.]

### 2. APA Term.

This APA applies to Taxpayer's taxable years ending
through
(APA Term).

### 3. TPM.

{Note: If appropriate, adapt language from the following examples. }
[The Tested Party is
.]

#### · CUP Method

The TPM is the comparable uncontrolled price (CUP) method. The Arm's Length Range of the price charged for
is between
and
per unit.

#### . CUT Method

The TPM is the CUT Method. The Arm's Length Range of the royalty charged for the license of
is between
% and _ % of [Taxpayer's, Foreign Participants', or other specified party's] Net Sales Revenue. [Insert
definition of net sales revenue or other royalty base.]

#### . Resale Price Method (RPM)

The TPM is the resale price method (RPM). The Tested Party's Gross Margin for any APA Year is defined as follows:
the Tested Party's gross profit divided by its sales revenue (as those terms are defined in Treasury Regulations
sections 1.482-5(d)(1) and (2) for that APA Year. The Arm's Length Range is between \_% and\_%, and the
Median of the Arm's Length Range is __ %.

#### . Cost Plus Method

The TPM is the cost plus method. The Tested Party's Cost Plus Markup is defined as follows for any APA Year: the
Tested Party's ratio of gross profit to production costs (as those terms are defined in Treasury Regulations sections
1.482-3(d)(1) and (2)) for that APA Year. The Arm's Length Range is between __ % and __ %, and the Median
of the Arm's Length Range is __ %.

#### . CPM with Berry Ratio PLI

The TPM is the comparable profits method (CPM). The profit level indicator is a Berry Ratio. The Tested Party's
Berry Ratio is defined as follows for any APA Year: the Tested Party's gross profit divided by its operating expenses
(as those terms are defined in Treasury Regulations sections 1.482-5(d)(2) and (3)) for that APA Year. The Arm's
Length Range is between __ and _, and the Median of the Arm's Length Range is _.

#### . CPM using an Operating Margin PLI

The TPM is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested
Party's Operating Margin is defined as follows for any APA Year: the Tested Party's operating profit divided by its
sales revenue (as those terms are defined in Treasury Regulations section 1.482-5(d)(1) and (4)) for that APA Year.
The Arm's Length Range is between __ % and _%, and the Median of the Arm's Length Range is __ %.

#### . CPM using a Three-year Rolling Average Operating Margin PLI

The TPM is the comparable profits method (CPM). The profit level indicator is an operating margin. The Tested
Party's Three-Year Rolling Average operating margin is defined as follows for any APA Year: the sum of the Tested
Party's operating profit (within the meaning of Treasury Regulation section 1.482-5(d)(4) for that APA Year and the
two preceding years, divided by the sum of its sales revenue (within the meaning of Treasury Regulation section
1.482-5(d)(1)) for that APA Year and the two preceding years. The Arm's Length Range is between _% and
%, and the Median of the Arm's Length Range is __ %.

### . Residual Profit Split Method

The TPM is the residual profit split method. [Insert description of routine profit level determinations and residual
profit-split mechanism].

[Insert additional provisions as needed.]

### 4. Application of TPM.

For any APA Year, if the results of Taxpayer's actual transactions produce a [price per unit, royalty rate for the Covered
Transactions] [or] [Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin, Three-Year Rolling Average Operating Margin
for the Tested Party] within the Arm's Length Range, then the amounts reported on Taxpayer's U.S. Return must clearly reflect such
results.

For any APA year, if the results of Taxpayer's actual transactions produce a [price per unit, royalty rate] [or] [Gross Margin, Cost
Plus Markup, Berry Ratio, Operating Margin, Three-Year Rolling Average Operating Margin for the Tested Party] outside the Arm's
Length Range, then amounts reported on Taxpayer's U.S. Return must clearly reflect an adjustment that brings the [price per unit,
royalty rate] [or] [Tested Party's Gross Margin, Cost Plus Markup, Berry Ratio, Operating Margin, Three-Year Rolling Average
Operating Margin] to the Median.

For purposes of this Appendix A, the "results of Taxpayer's actual transactions" means the results reflected in Taxpayer's and Tested
Party's books and records as computed under U.S. GAAP [insert another relevant accounting standard if applicable], with the
following adjustments:

(a) [The fair value of stock-based compensation as disclosed in the Tested Party's audited financial statements shall be treated as an
operating expense]; and

(b) To the extent that the results in any prior APA Year are relevant (for example, to compute a multi-year average), such results
shall be adjusted to reflect the amount of any adjustment made for that prior APA Year under this Appendix A.

### 5. APA Revenue Procedure Treatment

If Taxpayer makes an adjustment under paragraph 4 of this Appendix A (a "primary adjustment"), Taxpayer and its related foreign
entity may elect APA Revenue Procedure Treatment in accordance with section 11.02(3) of Revenue Procedure 2006-9 and avoid
the possible adverse tax consequences of a secondary adjustment that would otherwise follow the primary adjustment.

[Insert additional provisions as needed.]

## APPENDIX B CRITICAL ASSUMPTIONS

This APA's critical assumptions are:

1\. The business activities, functions performed, risks assumed, assets employed, and financial and tax accounting methods and
classifications [and methods of estimation] of Taxpayer in relation to the Covered Transactions will remain materially the same as
described or used in Taxpayer's APA Request. A mere change in business results will not be a material change.

[Insert additional provisions as needed.]

## APPENDIX C APA RECORDS AND ANNUAL REPORT

## APA RECORDS

The APA Records will consist of all documents listed below for inclusion in the Annual Report, as well as all documents, notes,
work papers, records, or other writings that support the information provided in such documents.

## ANNUAL REPORT

The Annual Report (and each of the four copies required by paragraph 5(e) of this APA) will include:

1\. Two copies of a properly completed APA Annual Report Summary in the form of Appendix E to this APA, one copy of the
form bound with, and one copy provided separately from, the rest of the Annual Report.

2\. A table of contents, organized as follows:

3\. Statements that fully identify, describe, analyze, and explain:

a. All material differences between the U.S. Group's business operations (including functions, risks assumed, markets,
contractual terms, economic conditions, property, services, and assets employed) during the APA Year from the business operations
described in the APA Request. If there have been no material differences, the Annual Report will include a statement to that effect.

b. All material differences between the U.S. Group's accounting methods and classifications, and methods of estimation used
during the APA Year, from those described or used in the APA Request. If any change was made to conform to changes in U.S.
GAAP (or other relevant accounting standards) Taxpayer will specifically identify the change. If there has been no material change
in accounting methods and classifications or methods of estimation, the Annual Report will include a statement to that effect.

c. Any change to the Taxpayer notice information in paragraph 14 of this APA.

d. Any failure to meet any critical assumption. If there has been no failure, the Annual Report will include a statement to that
effect.

e. Whether or not material information submitted while the APA Request was pending is discovered to be false, incorrect, or
incomplete.

f. Any change to any entity classification for federal income tax purposes (including any change that causes an entity to be
disregarded for federal income tax purposes) of any Worldwide Group member that is a party to the Covered Transactions or is
otherwise relevant to the TPM.

g. The amount, reason for, and financial analysis of (1) any primary adjustments made under Appendix A for the APA Year; and
(2) any (a) secondary adjustments that follow such primary adjustments or (b) accounts receivable that Taxpayer establishes, in lieu
of secondary adjustments, by electing APA Revenue Procedure Treatment pursuant to paragraph 5 of Appendix A and Revenue
Procedure 2006-9, section 11.02(3), for the APA Year, including but not limited to:

i. the amounts due or owed, and paid or received by each affected entity;

ii. the character (such as capital, ordinary, income, expense) and country source of the funds transferred, and the specific affected
line item(s) of any affected U.S. Return;

iii. the date(s) and means by which the payments are or will be made; and

iv. whether or not APA Revenue Procedure was elected pursuant to paragraph 5 of Appendix A and Revenue Procedure 2006-9,
section 11.02(3).

h. The amounts, description, reason for, and financial analysis of any book-tax difference relevant to the TPM for the APA Year,
as reflected on Schedule M-1 or Schedule M-3 of the U.S. Return for the APA Year.

i. Whether Taxpayer contemplates requesting, or has requested, to renew, modify, or cancel the APA.

4\. The Financial Statements, and any necessary account detail to show compliance with the TPM, including consolidating financial
statements, segmented financial data, records from the general ledger, or similar information if the assets, liabilities, income, or
expenses relevant to showing compliance with the TPM are a subset of the assets, liabilities, income, or expenses presented in the
Financial Statements.

5\. {Use the following or the alternative prescribed by paragraph 5(f) of this APA:} A copy of the independent certified public
accountant's opinion required by paragraph 5(f) of this APA.

6\. A financial analysis that reflects Taxpayer's TPM calculations for the APA Year. The calculations must reconcile with and
reference the information required under item 4 above in sufficient account detail to allow the IRS to determine whether Taxpayer
has complied with the TPM.

7\. An organizational chart for the Worldwide Group, revised annually to reflect all ownership or structural changes of entities that
are parties to the Covered Transactions or are otherwise relevant to the TPM.

### 8. A copy of the APA and any amendment.

9\. A penalty of perjury statement, executed in accordance with Revenue Procedure 2006-9, section 11.01(6) and (7).

## APPENDIX D DEFINITIONS

The following definitions control for all purposes of this APA. The definitions appear alphabetically below:

Term

Definition

Annual Report

A report within the meaning of Revenue Procedure 2006-9, section 11.01.

APA

This Advance Pricing Agreement, which is an "advance pricing agreement" within the meaning of Revenue Procedure 2006-9, section 2.04.

APA Records

The records specified in Appendix C.

APA Request

Taxpayer's request for this APA dated including any amendments or supplemental or additional information thereto.

APA Year

This term is defined in paragraph 5(a) of this APA.

Covered Transaction(s)

This term is defined in Appendix A.

Financial Statements

Financial statements prepared in accordance with U.S. GAAP and stated in U.S. dollars.

Foreign Group

Worldwide Group members that are not U.S. persons.

Foreign Participants

[name the foreign entities involved in Covered Transactions].

I.R.C.

The Internal Revenue Code of 1986, 26 U.S.C., as amended.

Pub. L. 106-170

The Ticket to Work and Work Incentives Improvement Act of 1999.

Revenue Procedure 2006-9

Rev. Proc. 2006-9, 2006-1 C.B. 278.

Transfer Pricing Method (TPM)

A transfer pricing method within the meaning of Treasury Regulation section 1.482-1(b) and Revenue Procedure 2006-9, section 2.04.

U.S. GAAP

U.S. generally-accepted accounting principles.

U.S. Group

Worldwide Group members that are U.S. persons.

U.S. Return

For each taxable year, the "returns with respect to income taxes under subtitle A" that Taxpayer must "make" in accordance with I.R.C. section 6012. {Or substitute for partnership: For each taxable year, the "return" that Taxpayer must "make" in accordance with I.R.C. section 6031.}

Worldwide Group

Taxpayer and all organizations, trades, businesses, entities, or branches (whether or not incorpo- rated, organized in the United States, or affiliated) owned or controlled directly or indirectly by the same interests.

## APPENDIX E APA ANNUAL REPORT SUMMARY FORM

The APA Annual Report Summary on the next page is a required APA Record. The APA Team Leader supplies some of the
information requested on the form. Taxpayer is to supply the remaining information requested by the form and submit the form as
part of its Annual Report.

APA Annual Report SUMMARY

Department of the Treasury- Internal Revenue Service Large Business and International Division Transfer Pricing Operations Advance Pricing and Mutual Agreement Program

APA No. Team Leader Economist Intl Examiner

APA Information

Taxpayer Name:

Taxpayer EIN: NAICS:

APA Term: Taxable years ending to Original APA [ ] Renewal APA [ ] Annual Report due dates: 201 __ for all APA Years through APA Year ending in 200 _; for each APA Year thereafter, on [month and day] immediately following the close of the APA Year Principal foreign country(ies) involved in covered transaction(s): ☒

Type of APA: [ ] unilateral [ ] bilateral with ☒ Tested party is [ ] US [ ] foreign [ ] both Approximate dollar volume of covered transactions (on an annual basis) involving tangible goods and services:

[] N/A [ ] &lt;$50 million [] $50-100 million [] $100-250 APA tests on (check all that apply): [ ] annual basis [ ] multi-year basis [ ] term basis ☒ APA provides (check all that apply) a: ☒ [ ] range [ ] point [ ] floor only [ ] ceiling only [ ] other ☒ APA provides for adjustment (check all that apply) to: ☒ [ ] nearest edge [ ] median [ ] other point

million [] $250-500 million [] &gt;$500 million ☒

APA Annual Report
Information

APA date executed:

201

This APA Annual Report Summary is for APA Year(s) ending in 200_ and
was filed on
201

(to be completed
by the Taxpayer)

Check here [ ] if Annual Report was filed after original due date but in accordance with extension.
☐
Has this APA been amended or changed?
☐ ☐
no
Effective Date:
yes

Has Taxpayer complied with all APA terms and conditions?
☐
yes
☐
no

Were all the critical assumptions met? [ ] yes [ ] no
☐ ☐

Has a Primary Compensating Adjustment been made in any APA Year covered by this Annual Report?
[ ] yes [ ] no If yes, which year(s): 200
☐

Have any necessary Secondary Compensating Adjustments been made?
☐
yes
☐
no

Did Taxpayer elect APA Revenue Procedure treatment? [ ] yes
☐
no

Any change to the entity classification of a party to the APA?
☐
yes
☐
no
Taxpayer notice information contained in the APA remains unchanged?
☐
yes
☐
no
Taxpayer's current US principal place of business: (City, State)

APA Annual Report
Checklist of
Key Contents
(to be completed
by the Taxpayer)

Financial analysis reflecting TPM calculations

☐ yes ☐ no

Financial statements showing compliance with TPM(s)

☐ yes ☐ no

Schedule M-1 or M-3 book-tax differences

☐ yes ☐ no

Current organizational chart of relevant portion of world-wide group

☐ yes ☐ no

Attach copy of APA

☐ yes ☐ no

Other APA records and documents included:

Contact Information

Authorized Representative

Phone Number

Affiliation and Address

## 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:

Amplified describes 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).

Clarified is 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.

Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.

Modified is 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 and clarified, above).

Obsoleted describes 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.

Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.

Superseded describes 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
superseded describes 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.

Supplemented is 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.

Suspended is 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.

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.

COOP-Cooperative.

IC-Insurance Company.

Ct.D .- Court Decision.

I.R.B .- Internal Revenue Bulletin.

CY-County.

LE-Lessee.

D-Decedent.

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.

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.

BK-Bank.

B.T.A .- Board of Tax Appeals.

C-Individual.

C.B .- Cumulative Bulletin.

CFR-Code of Federal Regulations.

CI-City.

DC-Dummy Corporation.

X-Corporation.

Y-Corporation.

Z-Corporation.

### Numerical Finding List1

Bulletin 2017-1 through 2017-15

#### Action on Decision:

2017-1, 2017-7 I.R.B. 868
2017-2, 2017-15 I.R.B. 1072

2017-3, 2017-15 I.R.B. 1072

2017-4, 2017-15 I.R.B. 1072

#### Announcements:

2017-01, 2017-08 I.R.B. 941
2017-02, 2017-10 I.R.B. 1007
2017-03, 2017-15 I.R.B. 1077

#### Notices:

2017-1, 2017-2 I.R.B. 367
2017-2, 2017-4 I.R.B. 539
2017-3, 2017-2 I.R.B. 368
2017-4, 2017-4 I.R.B. 541
2017-5, 2017-6 I.R.B. 779
2017-6, 2017-3 I.R.B. 422
2017-7, 2017-3 I.R.B. 423
2017-8, 2017-3 I.R.B. 423
2017-9, 2017-4 I.R.B. 542
2017-10, 2017-4 I.R.B. 544
2017-12, 2017-5 I.R.B. 742
2017-13, 2017-6 I.R.B. 780
2017-14, 2017-6 I.R.B. 783
2017-15, 2017-6 I.R.B. 783
2017-16, 2017-7 I.R.B. 913
2017-17, 2017-15 I.R.B. 1073
2017-18, 2017-9 I.R.B. 997
2017-19, 2017-9 I.R.B. 1000
2017-20, 2017-11 I.R.B. 1010
2017-21, 2017-13 I.R.B. 1026
2017-22, 2017-13 I.R.B. 1033

### Proposed Regulations:

REG-137604-07, 2017-7 I.R.B. 923
REG-128276-12, 2017-2 I.R.B. 369
REG-103477-14, 2017-5 I.R.B. 746
REG-112324-15, 2017-4 I.R.B. 547
REG-127203-15, 2017-7 I.R.B. 918
REG-131643-15, 2017-6 I.R.B. 865
REG-134438-15, 2017-2 I.R.B. 373
REG-112800-16, 2017-4 I.R.B. 569
REG-123829-16, 2017-5 I.R.B. 764
REG-123841-16, 2017-5 I.R.B. 766
REG-133353-16, 2017-2 I.R.B. 372
REG-134247-16, 2017-5 I.R.B. 744
REG-135122-16, 2017-9 I.R.B. 1005

### Revenue Procedures:

2017-1, 2017-1 I.R.B. 1
2017-2, 2017-1 I.R.B. 106
2017-3, 2017-1 I.R.B. 130

Revenue Procedures :- Continued

2017-4, 2017-1 I.R.B. 146
2017-5, 2017-1 I.R.B. 230
2017-7, 2017-1 I.R.B. 269
2017-12, 2017-3 I.R.B. 424
2017-13, 2017-6 I.R.B. 787
2017-14, 2017-3 I.R.B. 426
2017-15, 2017-3 I.R.B. 437
2017-16, 2017-3 I.R.B. 501
2017-18, 2017-5 I.R.B. 743
2017-19, 2017-7 I.R.B. 913
2017-21, 2017-6 I.R.B. 791
2017-22, 2017-6 I.R.B. 863
2017-23, 2017-7 I.R.B. 915
2017-24, 2017-7 I.R.B. 916
2017-25, 2017-14 I.R.B. 1039
2017-26, 2017-13 I.R.B. 1036
2017-27, 2017-14 I.R.B. 1042
2017-28, 2017-14 I.R.B. 1061
2017-29, 2017-14 I.R.B. 1065

#### Revenue Rulings:

2017-1, 2017-3 I.R.B. 377
2017-2, 2017-2 I.R.B. 364
2017-3, 2017-4 I.R.B. 522
2017-4, 2017-6 I.R.B. 776
2017-5, 2017-9 I.R.B. 1000
2017-6, 2017-12 I.R.B. 1011
2017-7, 2017-10 I.R.B. 1009
2017-8, 2017-14 I.R.B. 1037

Treasury Decisions:

9794, 2017-2 I.R.B. 273
9795, 2017-2 I.R.B. 326
9796, 2017-3 I.R.B. 380
9801, 2017-2 I.R.B. 355
9802, 2017-2 I.R.B. 361
9803, 2017-3 I.R.B. 384
9804, 2017-3 I.R.B. 406
9806, 2017-4 I.R.B. 524
9807, 2017-5 I.R.B. 573
9808, 2017-5 I.R.B. 580
9809, 2017-5 I.R.B. 664
9810, 2017-6 I.R.B. 775
9811, 2017-7 I.R.B. 869
9814, 2017-7 I.R.B. 878
9815, 2017-9 I.R.B. 944
9817, 2017-9 I.R.B. 968

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2016-27 through 2016-52 is in Internal Revenue Bulletin
2016-52, dated December 26, 2016.

### Finding List of Current Actions on Previously Published Items1

Bulletin 2017-1 through 2017-15

Notices:

2002-1
Amplified by
Notice 2017-1, 2017-2 I.R.B. 367

2010-46
Obsoleted by
Notice 2017-1, 2017-2 I.R.B. 367

2016-29
Modified by
Notice 2017-6, 2017-3 I.R.B. 422

#### Revenue Procedures:

2013-22
Clarified by
Rev. Proc. 2017-18, 2017-05 I.R.B. 743

2015-57
Modified by
Rev. Proc. 2017-24, 2017-07 I.R.B. 916

#### Treasury Decisions:

2010-46
Obsoleted by
T.D. 9815 2017-09 I.R.B. 944

# Internal Revenue Service Washington, DC 20224

Official Business
Penalty for Private Use, $300

# INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

# We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we
would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
(www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.

Internal Revenue Bulletin 2017-15 (PDF rendition): IRS Notices

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