Internal Revenue Bulletin 2017-36 (PDF rendition): IRS Revenue Rulings

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2017–17, page 222.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 1274, 1288, and other sections of the Code,
tables set forth the rates for September 2017.
Rev. Proc. 2017– 48, page 229.
This revenue procedure provides the monthly national average
premium for qualified health plans that have a bronze level of
coverage and are offered through Exchanges for taxpayers to
use in determining their maximum individual shared responsi-
bility payment under § 5000A(c)(1)(B) of the Internal Revenue
Code and § 1.5000A–4 of the Income Tax Regulations.
EMPLOYEE PLANS
Notice 2017– 43, page 224.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for August
2017 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for July 2017, and the 30-year Treasury
rates. These rates reflect the application of § 430(h)(2)(C)(iv),
which was added by the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP-21) and amended by
section 2003 of the Highway and Transportation Funding Act of
2014 (HATFA).
Notice 2017– 44, page 226.
The notice provides model amendments that a sponsor of a
qualified defined benefit plan may use to amend its plan docu-
ment to offer bifurcated benefit distribution options to partici-
pants in accordance with final regulations issued under
§ 417(e) of the Internal Revenue Code.
Finding Lists begin on page ii.
Bulletin No. 2017–36
September 5, 2017

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.
September 5, 2017Bulletin No. 2017–36

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520.)
Rev. Rul. 2017–17
This revenue ruling provides various
prescribed rates for federal income tax
purposes for September 2017 (the cur-
rent month). Table 1 contains the short-
term, mid-term, and long-term applica-
ble federal rates (AFR) for the current
month for purposes of section 1274(d)
of the Internal Revenue Code. Table 2
contains the short-term, mid-term, and
long-term adjusted applicable federal
rates (adjusted AFR) for the current
month for purposes of section 1288(b).
Table 3 sets forth the adjusted federal
long-term rate and the long-term tax-
exempt rate described in section 382(f).
Table 4 contains the appropriate per-
centages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in
service during the current month. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized new buildings placed in service
after July 30, 2008, shall not be less than
9%. Finally, Table 5 contains the federal
rate for determining the present value of
an annuity, an interest for life or for a
term of years, or a remainder or a rever-
sionary interest for purposes of section
7520.
REV. RUL. 2017–17 TABLE 1
Applicable Federal Rates (AFR) for September 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR1.29%1.29%1.29%1.29%
110% AFR1.43%1.42%1.42%1.42%
120% AFR1.56%1.55%1.55%1.55%
130% AFR1.69%1.68%1.68%1.67%
Mid-term
AFR1.94%1.93%1.93%1.92%
110% AFR2.13%2.12%2.11%2.11%
120% AFR2.33%2.32%2.31%2.31%
130% AFR2.53%2.51%2.50%2.50%
150% AFR2.92%2.90%2.89%2.88%
175% AFR3.41%3.38%3.37%3.36%
Long-term
AFR2.60%2.58%2.57%2.57%
110% AFR2.86%2.84%2.83%2.82%
120% AFR3.12%3.10%3.09%3.08%
130% AFR3.38%3.35%3.34%3.33%
REV. RUL. 2017–17 TABLE 2
Adjusted AFR for September 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.96%.96%.96%.96%
Mid-term adjusted AFR1.45%1.44%1.44%1.44%
Long-term adjusted AFR1.93%1.92%1.92%1.91%
September 5, 2017Bulletin No. 2017–36
222

REV. RUL. 2017–17 TABLE 3
Rates Under Section 382 for September 2017
Adjusted federal long-term rate for the current month1.93%
Long-term tax-exempt rate for ownership changes during the current month (the highest
of the adjusted federal long-term rates for the current month and the prior two months.)
1.93%
REV. RUL. 2017–17 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for September 2017
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new
buildings placed in service after July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.52%
Appropriate percentage for the 30% present value low-income housing credit3.22%
REV. RUL. 2017–17 TABLE 5
Rate Under Section 7520 for September 2017
Applicable federal rate for determining the present value of an annuity, an interest for life or a term
of years, or a remainder or reversionary interest
2.4%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate is
set forth for the month of September 2017. See Rev.
Rul. 2017-17 , page 222.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month of
September 2017. See Rev. Rul. 2017-17, page 222.
Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of Sep-
tember 2017. See Rev. Rul. 2017-17, page 222.
Bulletin No. 2017–36September 5, 2017
223

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2017– 43
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
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 average segment rates for the period
ending September 30 of the year preced-
ing the calendar year in which the plan
year begins.
1
However, an election may
be made under § 430(h)(2)(D)(ii) to use
the monthly yield curve in place of the
segment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from July 2017
data is in Table I at the end of this notice.
The spot first, second, and third segment
rates for the month of July 2017 are, re-
spectively, 1.97, 3.66, and 4.37.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant
to § 430(h)(2)(C)(iv) to be within the
applicableminimum and maximum per-
centages of the corresponding 25-year aver-
age segment rates. For plan years beginning
before 2021, the applicable minimum per-
centage is 90% and the applicable maxi-
mum percentage is 110%. The 25-year av-
erage segment rates for plan years beginning
in 2015, 2016, and 2017 were published
in Notice 2014 –50, 2014 – 40 I.R.B. 590,
Notice 2015– 61, 2015–39 I.R.B. 408, and
Notice 2016 –54, 2016 – 40 I.R.B. 429,
respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for August
2017 without adjustment for the 25-year
average segment rate limits are as follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
August 20171.733.784.69
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for August
2017 adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates, are as follows:
For Plan
Years
Beginning In
Adjusted 24-Month Average Segment
Rates
Applicable Month
First
Segment
Second
Segment
Third
Segment
2016August20174.435.916.65
2017August20174.165.726.48
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 § 431(c)(6)(A), based on the
plan’s current liability. Section 431(c)(6)
(E)(ii)(I) provides that the interest rate
used to calculate current liability for this
purpose must be no more than 5 percent
above and no more than 10 percent below
the weighted average of the rates of inter-
est on 30-year Treasury securities 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 securities for July
2017 is 2.88 percent. The Service deter-
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
September 5, 2017Bulletin No. 2017–36
224

mined this rate as the average of the daily
determinations of yield on the 30-year
Treasury bond maturing in May 2047. For
plan years beginning in the month shown
below, the weighted average of the rates
of interest on 30-year Treasury securities
and the permissible range of rates used to
calculate current liability are as follows:
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
MonthYear
August20172.892.603.03
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 July 2017 are as
follows:
First
Segment
Second
Segment
Third
Segment
1.973.664.37
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associ-
ate Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other person-
nel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-6700 or Tony
Montanaro at 202-317-8698 (not toll-free
calls).
Table I
Monthly Yield Curve for July 2017
Derived from July 2017 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.51.4120.54.1840.54.4060.54.4780.54.51
1.01.5621.04.1941.04.4061.04.4881.04.52
1.51.7021.54.1941.54.4061.54.4881.54.52
2.01.8322.04.2042.04.4062.04.4882.04.52
2.51.9422.54.2142.54.4162.54.4882.54.52
3.02.0523.04.2243.04.4163.04.4883.04.52
3.52.1523.54.2343.54.4163.54.4883.54.52
4.02.2624.04.2444.04.4164.04.4884.04.52
4.52.3624.54.2444.54.4264.54.4884.54.52
5.02.4725.04.2545.04.4265.04.4985.04.52
5.52.5825.54.2645.54.4265.54.4985.54.52
6.02.7026.04.2646.04.4266.04.4986.04.52
6.52.8126.54.2746.54.4366.54.4986.54.52
7.02.9227.04.2847.04.4367.04.4987.04.52
7.53.0327.54.2847.54.4367.54.4987.54.52
8.03.1328.04.2948.04.4368.04.4988.04.52
8.53.2328.54.2948.54.4468.54.4988.54.53
9.03.3229.04.3049.04.4469.04.4989.04.53
9.53.4129.54.3149.54.4469.54.5089.54.53
Bulletin No. 2017–36September 5, 2017
225

Table I
Monthly Yield Curve for July 2017
Derived from July 2017 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
10.03.4930.04.3150.04.4470.04.5090.04.53
10.53.5630.54.3250.54.4470.54.5090.54.53
11.03.6331.04.3251.04.4471.04.5091.04.53
11.53.6931.54.3351.54.4571.54.5091.54.53
12.03.7532.04.3352.04.4572.04.5092.04.53
12.53.8032.54.3452.54.4572.54.5092.54.53
13.03.8533.04.3453.04.4573.04.5093.04.53
13.53.8933.54.3553.54.4573.54.5093.54.53
14.03.9334.04.3554.04.4674.04.5094.04.53
14.53.9634.54.3554.54.4674.54.5094.54.53
15.03.9935.04.3655.04.4675.04.5195.04.53
15.54.0235.54.3655.54.4675.54.5195.54.53
16.04.0436.04.3756.04.4676.04.5196.04.53
16.54.0636.54.3756.54.4676.54.5196.54.53
17.04.0837.04.3757.04.4677.04.5197.04.54
17.54.1037.54.3857.54.4777.54.5197.54.54
18.04.1138.04.3858.04.4778.04.5198.04.54
18.54.1338.54.3858.54.4778.54.5198.54.54
19.04.1439.04.3959.04.4779.04.5199.04.54
19.54.1539.54.3959.54.4779.54.5199.54.54
20.04.1640.04.3960.04.4780.04.51100.04.54
Model Amendments to Add
Bifurcated Distribution
Options to Defined Benefit
Plans
Notice 2017– 44
I. Purpose
This notice provides model amend-
ments that a sponsor of a qualified defined
benefit plan may use to amend its plan
document to offer bifurcated benefit dis-
tribution options to participants in accor-
dance with final regulations issued under
§ 417(e) of the Internal Revenue Code
(see T.D. 9783, 2016 –39 I.R.B. 396, pub-
lished in the Federal Register on Septem-
ber 9, 2016 (81 FR 62359)). Stakeholders
have indicated that providing model
amendments would be helpful in light of
the changes to the determination letter
program that are set forth in Rev. Proc.
2016 –37, 2016 –29 I.R.B. 136.
Although a plan sponsor may use the
model language in this notice to provide a
bifurcated distribution option to partici-
pants in accordance with the final regula-
tions, a plan that provides for a bifurcated
distribution option is not required to in-
clude this specific model language. The
sponsor of a plan that currently provides
for bifurcated distributions under plan
terms that comply with the provisions of
§ 1.417(e)–1(d)(7), relating to either im-
plicit or explicit bifurcation, does not need
to amend those plan terms. In addition,
use of the model language by an employer
that has adopted a pre-approved plan will
not cause the plan to fail to be identical to
the pre-approved plan.
II. Background
Section 417 provides rules regarding
survivor annuity forms of distribution that
must be offered under qualified defined
benefit plans. Section 417(e)(3) and
§ 1.417(e)–1(d)(2) and (3) specify the ap-
plicable mortality table and the applicable
interest rate to be used to determine the
minimum present value of a benefit dis-
tributed in the form of a lump sum. These
minimum present value requirements
apply for purposes of § 411(a)(11) and
§ 417(e)(1), which permit the distribution
of a benefit under a plan to a participant in
a lump sum without the consent of the
participant or the participant’s spouse if
the present value of the benefit does not
exceed $5,000. The minimum present
value requirements also apply when deter-
mining the dollar amount of a lump sum
or other accelerated form of distribution
elected by a participant.
Under § 1.417(e)–1(d)(6), an exception
from the minimum present value require-
ments of § 417(e)(3) applies to a distribu-
tion paid in the form of an annuity that
does not decrease during the life of the
participant (other than specified permitted
decreases). If an optional form of benefit
is eligible for this exception, the require-
ment to use the § 417(e)(3) actuarial as-
sumptions to determine the amount of the
September 5, 2017Bulletin No. 2017–36
226

benefit payable in the optionalform does
not apply, and the actuarial assumptions that
are used for this purpose must instead sat-
isfy the requirements of § 411(a) that they
not result in an impermissible forfeiture of
the accrued benefit. See § 1.411(a)– 4T(a).
To facilitate the payment of benefits
partly in the form of an annuity and partly
as a single sum (or other accelerated
form), the Department of the Treasury
and the Internal Revenue Service (IRS)
amended the regulations under § 417(e) to
permit plans to simplify the calculation of
the amount of certain optional forms of
benefit. The change was made to encour-
age sponsors of plans that include single
sum distribution options to offer partici-
pants the additional option to bifurcate
their benefits in order to receive a portion
in an annuity form (providing financial
protection against unexpected longevity)
and the remainder in an accelerated form
(providing increased liquidity during re-
tirement).
Section 1.417(e)–1(d)(7) provides
rules under which the participant’s ac-
crued benefit may be “bifurcated” (into
two or more parts), so that the minimum
present value requirements of § 417(e)
(3) apply only to the portion of the par-
ticipant’s accrued benefit that is paid in
the accelerated form. Section 1.417(e)–
1(d)(7) applies to distributions with an-
nuity starting dates in plan years begin-
ning on or after January 1, 2017, or, if
the taxpayer elects, to earlier periods.
Section 1.417(e)–1(d)(7)(ii)(A) and
(B) provides two acceptable bifurcation
methods that a plan sponsor may choose
to include in plan terms. Under the ex-
plicit bifurcation method, a plan permits a
participant to elect to divide his or her
accrued benefit into two or more portions,
and the minimum present value rules of
§ 417(e)(3) are applied separately to each
portion of the accrued benefit as if it were
the participant’s entire benefit. Under the
implicit bifurcation method, a plan per-
mits a participant to elect the payment of
a single-sum amount if the remaining por-
tion of the participant’s accrued benefit is
no less than the total accrued benefit re-
duced by the actuarial equivalent of the
single sum (determined using the actuarial
assumptions that apply under § 417(e)(3)).
Section 1.417(e)–1(d)(7)(iii) sets forth
rules of operation for these bifurcation
methods, including rules describing cer-
tain circumstances under which the im-
plicit bifurcation method is not available.
The appendix to this notice provides
model language that may be used for each
of these methods, as applicable to the
plan. The model language provides for the
payment of the minimum amounts re-
quired to be paid in order to comply with
the rules of § 1.417(e)–1(d)(7). A plan
may provide for amounts that exceed the
minimum amounts required to be paid
pursuant to § 1.417(e)–1(d)(7), but the
treatment specified under section III.A of
this notice does not apply to a plan
amendment that differs from the model
language in order to provide greater
amounts.
Section 411(d)(6) prohibits a plan
amendment that decreases a participant’s
accrued benefit. With respect to benefits
attributable to service before an amend-
ment, a plan amendment that effectively
eliminates or reduces an early retirement
benefit or retirement-type subsidy or that
eliminates an optional form of benefit will
be treated as reducing accrued benefits
under § 411(d)(6). However, the last sen-
tence of § 411(d)(6)(B) states that the
Secretary may, by regulations, provide
that § 411(d)(6)(B) does not apply to a
plan amendment that eliminates an op-
tional form of benefit (other than a plan
amendment that has the effect of eliminat-
ing or reducing an early retirement benefit
or a retirement-type subsidy).Section
1.417(e)–1(d)(7)(iv) exercises this authority
with respect to certain amendments adopted
to implement a bifurcated distribution op-
tion pursuant to § 1.417(e)–1(d)(7). Pursu-
ant to this authority, § 1.417(e)–1(d)(7)(iv)
provides that § 411(d)(6) is not violated as a
result of an amendment to a plan to imple-
ment a bifurcated distribution option if cer-
tain conditions are satisfied. This relief ap-
plies with respect to a plan amendment
adopted on or before December 31, 2017, if,
for plan years beginning before January 1,
2017, the § 417(e)(3) applicable interest rate
and applicable mortality table were used to
calculate the amount of a distribution that
was made to settle a portion of the accrued
benefit under the plan, and, pursuant to
§ 1.417(e)–1(d)(7), the requirements of
§ 417(e)(3) and § 1.417(e)–1(d) are not re-
quired to be applied to the distribution.
III. Model Amendments
A. Treatment of adoption of model
amendments
The model amendments set forth in the
Appendix may be used to implement ei-
ther of the two methods set forth in
§ 1.417(e)–1(d)(7) for computing the
amount to be paid to a participant who
elects to receive his or her accrued benefit
in an optional form of payment consisting
partially of an annuity and partially of a
more accelerated form of payment. Note
that the Implicit Bifurcation Amendment
may not be used with respect to distribu-
tions for which § 1.417(e)–1(d)(7)(iii)(C)
prohibits the use of implicit bifurcation.
Pursuant to this notice:
1. Adoption of a plan amendment in-
corporating the language in either of
the model amendments in accor-
dance with this notice will not cause
a plan to violate the requirements of
§ 417(e) and § 1.417(e)–1(d)(7);
2. Such a plan amendment that is ad-
opted on or before December 31,
2017, is eligible for the limited relief
from the application of the anti-
cutback provisions of § 411(d)(6) pro-
vided under § 1.417(e)–1(d)(7)(iv);
and
3. In the case of a pre-approved plan, if
one of these model amendments is
adopted by an adopting employer
rather than by the sponsor/practitio-
ner/provider, theadoption of the
amendment will not cause the plan to
fail to be identical to the pre-approved
plan (see section 8.03(2) of Rev. Proc.
2017– 41, 2017–29 I.R.B. 92, 108 –
109, or section 19.03(4)(c) of Rev.
Proc. 2015–36, 2015–27 I.R.B. 20,
39, as applicable).
B. Applicable conditions
The treatment described in section
III.A of this notice applies only if the
following conditions are satisfied:
1. The terms of the model amendment
are not modified, except as other-
wise permitted in section III.C of
this notice;
2. The plan is operated in accordance
with the amendment from and after
the effective date of the amendment;
and
Bulletin No. 2017–36September 5, 2017
227

3. In accordance with § 1.417(e)–1(d)
(7)(iii)(D), if a plan has an early
retirement benefit, a retirement-type
subsidy, an optional form of benefit,
or an ancillary benefit that applies
only to a portion of a participant’s
accrued benefit, and the plan pro-
vides for a distribution of some (but
not all) of the participant’s accrued
benefit, the plan specifies the portion
of the participant’s total accrued
benefit that is paid by that partial
distribution.
C. Permitted modifications to the model
amendments
A plan sponsor may modify the lan-
guage of a model amendment without af-
fecting the treatment described in section
III.A to conform the language of the
model amendment to the plan’s terminol-
ogy or organization or to satisfy the con-
dition set forth in section III.B.3 of this
notice, provided that the modifications do
not alter the meaning of any of the provi-
sions of the model amendment. In addi-
tion, in the case of a pre-approved plan,
some portions of the model amendment
may be included in the basic plan docu-
ment, and others may be included in the
adoption agreement, as appropriate.
D. Permitted plan designs using the
model amendments
Plan sponsors may limit the extent to
which bifurcation is available with respect
to a participant’s accrued benefit, specify
the number of forms of distribution
among which an accrued benefit may be
bifurcated, or limit the combinations of
forms that are available for this purpose.
The following illustrates some of the ways
in which plan terms may limit the bifur-
cation of a participant’s accrued benefit:
•A participant who elects to bifurcate
his or her accrued benefit may divide
the benefit between no more than two
distribution forms.
•Bifurcation may be available only for
specified percentage divisions of the
accrued benefit that are set forth in the
plan. For example, a plan could pro-
vide that the only permitted bifurca-
tions are a 50/50 or a 75/25 division.
•Bifurcation may be available only be-
tween the portion of an accrued benefit
earned before a specified date and the
portion of an accrued benefit earned on
and after that date.
•A participant may elect to bifurcate his
or her accrued benefit only into a lump
sum distribution and an annuity (and
the amount permitted to be paid as a
lump sum may be capped at a speci-
fied dollar amount or a specified per-
centage of the participant’s accrued
benefit).
The second and third paragraphs of the
model amendment for the explicit bifurca-
tion method, and the third paragraph of the
model amendment for the implicit bifurca-
tion method, set out optional provisions that
may be included in a plan amendment to
implement these limitations.
Drafting Information
The principal authors of this notice are
Diane S. Bloom and Linda S. F. Marshall
of the Office of Associate Chief Counsel
(Tax Exempt and Government Entities).
Ms. Bloom and Ms. Marshall can be
reached at (202) 317-6700 (not a toll-free
number).
Appendix
Model Amendments for a Defined Benefit Plan that Satisfy § 417(e)(3) of the Internal Revenue Code with Respect to
Bifurcated Distribution Options.
Instructions:These model amendments set forth language that may be added to a plan in order for the plan to offer bifurcated
optional forms of benefit determined under one of the two bifurcation methods described in § 1.417(e)–1(d)(7): (1) the explicit
bifurcation method or (2) the implicit bifurcation method. Consistent with the requirements of § 1.417(e)–1(d)(7)(iii)(C), the model
Implicit Bifurcation Method amendment may not be used in any case described in that paragraph.
Explicit Bifurcation Method
Effective for annuity starting dates on or after ________ [insert date], if a participant so elects, the participant’s accrued benefit
will be divided and distributed as described below:
A participant may elect to divide his or her accrued benefit to the following extent: _____________________________
[describe the permissible divisions of the accrued benefit].
A participant may elect a combination of distribution options for the divided portions of his or her accrued benefit to the following
extent: ________________________________
[describe available distribution options and designate any limit on the distribution options that may be combined for an accrued
benefit that is bifurcated].
If a participant elects to divide his or her accrued benefit, the amount of the distribution payable with respect to each specified
portion of the accrued benefit is determined in accordance with the method for calculating the amount of a distribution payable in
the optional form elected for that portion as if that portion were the participant’s entire accrued benefit.
September 5, 2017Bulletin No. 2017–36
228

Implicit Bifurcation Method
Effective for annuity starting dates on or after ________ [insert date],if a participant so elects, the participant will receive a portion of
his or her accrued benefit in the form of a single-sum payment as described below. For any participant who so elects, the remainder of
the participant’s accrued benefit not payable in the form of asingle-sum payment, expressed in the form of ________ [insert plan’s normal
form of benefit] commencing when the participant attains normal retirement age (or at the current date, if later)will be equal to the excess of:
(1) The participant’s total accrued benefit expressed in that form; over
(2) The annuity payable in that form that is actuarially equivalent to the single-sum payment, determined using the applicable
interest rate under section 1.417(e)–1(d)(2) and the applicable mortality table under section 1.417(e)–1(d)(3).
A participant may elect to receive as a single-sum payment the following amount: __________________________
[describe (as a dollar figure or as a formula) the amount that may be distributed as a single-sum payment].
A participant who elects to receive a single-sum payment pursuant to this [section] may elect to receive the remainder of his or
her accrued benefit in any of the following forms of payment: ____________________________________
[describe available distribution options and any limit on the distribution options under which the remainder of the participant’s
benefit may be paid].
If a participant elects to receive a portion of his or her accrued benefit in the form of a single-sum payment, then the amount of the
distribution payable with respect to the remainder of the benefit is determined in accordance with the method for calculating the amount
of a distribution payable in the optional form elected for that remainder as if that remainder were the participant’s entire accrued benefit.
Rev. Proc. 2017– 48
SECTION 1. PURPOSE
This revenue procedure provides the
monthly national average premium for quali-
fied health plans that have a bronze level of
coverage and are offered through Exchanges
for taxpayers to use in determining their max-
imum individual shared responsibility pay-
ment under § 5000A(c)(1)(B) of the Internal
Revenue Code and § 1.5000A– 4 of the In-
come Tax Regulations.
SECTION 2. BACKGROUND
.01 Section 5000A provides that if a
taxpayer, or an individual for whom the
taxpayer is liable, is without minimum
essential coverage for one or more months
in a taxable year, then the taxpayer is
liable for the individual shared responsi-
bility payment when filing his or her fed-
eral income tax return, unless an exemp-
tion applies.See§ 5000A(a), (b)(1). In
general, under § 5000A a taxpayer is lia-
ble for any individual who is a dependent,
as defined in § 152, of the taxpayer.See
§§ 5000A(b)(3)(A) and 1.5000A–1(c).
Married individuals who file a joint return
for a taxable year are jointly liable for any
individual shared responsibility payment for
a month included in the taxable year.See
§§ 5000A(b)(3)(B) and 1.5000A–1(c)(3).
.02 For each taxable year, the individ-
ual shared responsibility payment is the
lesser of (1) the sum of the monthly pen-
alty amounts, or (2) the sum of the
monthly national average bronze plan pre-
miums for the shared responsibility fam-
ily.See§ 1.5000A– 4(a). The monthly na-
tional average bronze plan premium
means, for a month for which a shared
responsibility payment is imposed, 1/12
of the annual national average premium
for qualified health plans that (1) have a
bronze level of coverage, (2) would pro-
vide coverage for the taxpayer’s shared
responsibility family members, and (3) are
offered through Exchanges for plan years
beginning in a calendar year with or
within which the taxable year ends.See
§§ 5000A(c)(1)(B) and 1.5000A– 4(c).
Shared responsibility family means, for a
month in a taxable year, all nonexempt
individuals for whom the taxpayer and the
taxpayer’s spouse, if the taxpayer is mar-
ried and files a joint return with the
spouse, are liable for the shared responsi-
bility payment under § 5000A for that
taxable year.See§ 1.5000A–1(d)(17).
.03 Revenue Procedure 2014 – 46,
2014 –12 C.B. 367, describes the method-
ology used to determine the monthly na-
tional average bronze plan premium and
provides the premium amount for 2014.
Revenue Procedure 2015–15, 2015–5
I.R.B. 564, provides the premium amount
for 2015. Revenue Procedure 2016 – 43,
2016 –36 I.R.B. 316, provides the pre-
mium amount for 2016.
SECTION 3. MONTHLY NATIONAL
AVERAGE BRONZE PLAN PREMIUM
.01Monthly National Average Bronze
Plan Premium.Forpurposesof
§ 5000A(c)(1)(B) and § 1.5000A– 4, the
monthly national average premium for
qualified health plans that have a bronze
level of coverage and are offered through
Exchanges is $272 per individual.
.02Maximum Monthly National Aver-
age Bronze Plan Premium. For purposes of
§ 5000A(c)(1)(B) and § 1.5000A– 4, the max-
imum monthly national average premium for
qualified health plans that have a bronze level
of coverage and are offered through Ex-
changes is $1,360 for a shared responsibility
family with five or more members.
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for tax-
able years ending after December 31, 2016.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Revenue Procedure 2016 – 43 is super-
seded.
SECTION 6. DRAFTING
INFORMATION
The principal author of this revenue pro-
cedure is James Beatty of the Office of
Associate Chief Counsel (Income Tax and
Accounting). For further information regard-
ing this revenue procedure, contact Mr. Beatty
at (202) 317-7006 (not a toll-free number).
Bulletin No. 2017–36September 5, 2017
229

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
withamplifiedandclarified, 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,modifiedand
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. 2017–36September 5, 2017
i

Numerical Finding List
1
Bulletin 2017–27 through 2017–36
Action on Decision:
2017-5, 2017-27 I.R.B.1
2017-6, 2017-33 I.R.B.194
Announcements:
2017-05, 2017-27 I.R.B.5
2017-08, 2017-28 I.R.B.9
2017-09, 2017-35 I.R.B.219
2017-10, 2017-33 I.R.B.210
Notices:
2017-36, 2017-33 I.R.B.208
2017-37, 2017-29 I.R.B.89
2017-38, 2017-30 I.R.B.147
2017-39, 2017-31 I.R.B.150
2017-40, 2017-32 I.R.B.190
2017-41, 2017-34 I.R.B.211
2017-42, 2017-34 I.R.B.212
2017-43, 2017-36 I.R.B.224
2017-44, 2017-36 I.R.B.226
Proposed Regulations:
REG-139633-08, 2017-31 I.R.B.175
REG-128483-15, 2017-32 I.R.B.191
REG-136118-15, 2017-28 I.R.B.9
Revenue Procedures:
2017-41, 2017-29 I.R.B.92
2017-42, 2017-29 I.R.B.124
2017-43, 2017-31 I.R.B.153
2017-44, 2017-35 I.R.B.216
2017-45, 2017-35 I.R.B.216
2017-48, 2017-36 I.R.B.229
Revenue Rulings:
2017-14, 2017-27 I.R.B.2
2017-15, 2017-32 I.R.B.176
2017-16, 2017-35 I.R.B.215
2017-17, 2017-36 I.R.B.222
Treasury Decisions:
9819, 2017-29 I.R.B.85
9820, 2017-32 I.R.B.178
9821, 2017-32 I.R.B.181
9822, 2017-33 I.R.B.195
9823, 2017-33 I.R.B.206
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017– 01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
September 5, 2017Bulletin No. 2017–36
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2017–27 through 2017–36
Notices:
2015-77
Amplified by
Notice 2017-40, 2017-32 I.R.B.190
Revenue Procedures:
2016-27
Modified by
Rev. Proc. 2017-43, 2017-31 I.R.B.153
2016-27
Superseded by
Rev. Proc. 2017-43, 2017-31 I.R.B.153
2016-48
Superseded by
Rev. Proc. 2017-48, 2017-36 I.R.B.229
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017– 01 through 2017–26 is in Internal Revenue Bulletin
2017–26, dated June 27, 2017.
Bulletin No. 2017–36September 5, 2017
iii

INTERNAL REVENUE BULLETIN
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