Internal Revenue Bulletin 2018-14 (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.
ADMINISTRATIVE
REG–129260–16, page 470.
This Notice of Proposed Rulemaking will implement the require-
ment of the Fixing America’s Service Transportation (FAST) Act
that the Department of State deny a passport (or the renewal
of a passport) in the case of an individual if notified by the IRS
that the individual has been certified as having a seriously
delinquent tax debt. The FAST Act also permits the Department
of State to revoke a passport previously issued to such person.
The FAST Act requires the IRS to notify the Department of State
of certified seriously delinquent tax debts. The Department of
State procures services from outside contractors in connec-
tion with carrying out its responsibilities under the FAST Act.
These proposed regulations authorize the Department of State
to disclose return information to its contractors for purposes
of carrying out such responsibilities.
EMPLOYEE PLANS
Notice 2018–22, page 464.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for March
2018 used under § 417(e)(3)(D), the 24-month average
segment rates applicable for March 2018, 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).
Rev. Proc. 2018–19, page 466.
This revenue procedure modifies Rev. Proc. 2018 – 4, 2018 –1
I.R.B.146. Specifically, this revenue procedure changes one
user fee set forth in Appendix A of Rev. Proc. 2018 – 4, Sched-
ule of User Fees, with respect to applications on Form 5310,
Application for Determination for Terminating Plan. That user
fee is reduced from $3,000 to $2,300, effective January 2,
2018. Applicants who paid the $3,000 user fee listed in Rev.
Proc. 2018 – 4 will receive a refund of $700.
Rev. Proc. 2018–21, page 467.
This revenue procedure modifies the procedures of the Internal
Revenue Service for issuing opinion and advisory letters for
pre-approved master and prototype and volume submitter
plans as provided in Rev. Proc. 2015–36, 2015–27 I.R.B. 20.
In particular, this revenue procedure modifies sections
6.03(7)(c) and 16.03(7)(c) of Rev. Proc. 2015–36 to allow
pre-approved defined benefit plans containing a cash balance
formula to provide for the actual rate of return on plan assets
as the rate used to determine interest credits. This revenue
procedure also modifies section 6.03(7)(c) of Rev. Proc.
2017– 41 relating to the rates that are permitted to be used to
determine interest credits in pre-approved defined benefit
plans containing a cash balance formula. In addition, this rev-
enue procedure changes references to “hypothetical interest”
and “hypothetical interest credits” in Rev. Proc. 2015–36 to
“interest credits”, consistent with terminology in Rev. Proc.
2017– 41.
INCOME TAX
Rev. Rul. 2018–09, page 462.
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 April 2018.
Finding Lists begin on page ii.
Bulletin No. 2018–14
April 2, 2018

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
April 2, 2018Bulletin No. 2018–14

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. 2018–09
This revenue ruling provides various
prescribed rates for federal income tax
purposes for April 2018 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-
term, mid-term, and long-term adjusted
applicable federal rates (adjusted AFR)
for the current month for purposes of sec-
tion 1288(b). Table 3 sets forth the ad-
justed federal long-term rate and the long-
term tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage for non-federally subsidized new
buildings placed in service after July 30,
2008, shall not be less than 9%. Finally,
Table 5 contains the federal rate for de-
termining the present value of an annuity,
an interest for life or for a term of years, or
a remainder or a reversionary interest for
purposes of section 7520.
REV. RUL. 2018–09 TABLE 1
Applicable Federal Rates (AFR) for April 2018
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR2.12%2.11%2.10%2.10%
110% AFR2.33%2.32%2.31%2.31%
120% AFR2.55%2.53%2.52%2.52%
130% AFR2.76%2.74%2.73%2.72%
Mid-term
AFR2.72%2.70%2.69%2.68%
110% AFR2.99%2.97%2.96%2.95%
120% AFR3.27%3.24%3.23%3.22%
130% AFR3.54%3.51%3.49%3.48%
150% AFR4.09%4.05%4.03%4.02%
175% AFR4.79%4.73%4.70%4.68%
Long-term
AFR3.04%3.02%3.01%3.00%
110% AFR3.35%3.32%3.31%3.30%
120% AFR3.65%3.62%3.60%3.59%
130% AFR3.97%3.93%3.91%3.90%
REV. RUL. 2018–09 TABLE 2
Adjusted AFR for April 2018
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
adjusted AFR1.61%1.60%1.60%1.59%
Mid-term
adjusted AFR2.06%2.05%2.04%2.04%
Long-term
adjusted AFR2.30%2.29%2.28%2.28%
April 2, 2018Bulletin No. 2018–14
462

REV. RUL. 2018–09 TABLE 3
Rates Under Section 382 for April 2018
Adjusted federal long-term rate for the current month2.30%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted
federal long-term rates for the current month and the prior two months.)
2.30%
REV. RUL. 2018–09 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for April 2018
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 credit7.66%
Appropriate percentage for the 30% present value low-income housing credit3.28%
REV. RUL. 2018–09 TABLE 5
Rate Under Section 7520 for April 2018
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
3.2%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of April
2018. See Rev. Rul. 2018 – 09, page 462.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of April
2018. See Rev. Rul. 2018 – 09, page 462.
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 April 2018. See Rev. Rul.
2018 – 09, page 462.
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 April
2018. See Rev. Rul. 2018 – 09, page 462.
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 April
2018. See Rev. Rul. 2018 – 09, page 462.
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 April
2018. See Rev. Rul. 2018 – 09, page 462.
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 April
2018. See Rev. Rul. 2018 – 09, page 462.
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 April 2018. See Rev. Rul. 2018 – 09,
page 462.
Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month
of April 2018. See Rev. Rul. 2018 – 09, page 462.
Bulletin No. 2018–14April 2, 2018
463

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2018–22
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
Section 430 specifies the minimum
funding requirements that apply to single-
employer plans (except for CSEC plans
under § 414(y)) pursuant 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, present value is generally de-
termined using three 24-month average
interest rates (“segment rates”), each of
which applies to cash flows during speci-
fied periods. To the extent provided under
§ 430(h)(2)(C)(iv),these segment rates are
adjusted by the applicable percentage of the
25-year average segment rates for the period
ending September 30 of the year preceding
the calendar year in which the plan year
begins.
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 February
2018 data is in Table 2018 –1 at the end of
this notice. The spot first, second, and
third segment rates for the month of Feb-
ruary 2018 are, respectively, 2.72, 3.94,
and 4.33.
The 24-month average segment rates de-
termined under § 430(h)(2)(C)(i) through
(iii) must be adjusted pursuant to § 430(h)
(2)(C)(iv) to be within the applicable mini-
mum and maximum percentages of the cor-
responding 25-year average segment rates.
For plan years beginning before 2021, the
applicable minimum percentage is 90% and
the applicable maximum percentage is
110%. The 25-year average segment rates
for plan years beginning in 2016, 2017, and
2018 were published in Notice 2015– 61,
2015–39 I.R.B. 408; Notice 2016 –54,
2016 – 40 I.R.B. 429; and Notice 2017–50,
2017– 41 I.R.B. 280, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for March
2018 without adjustment for the 25-year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable MonthFirst SegmentSecond SegmentThird Segment
March 20181.893.664.46
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for March
2018, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning In
Applicable MonthFirst SegmentSecond SegmentThird Segment
2017March 20184.165.726.48
2018March 20183.925.526.29
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 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 Febru-
ary 2018 is 3.13 percent. The Service de-
termined this rate as the average of the
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)).
April 2, 2018Bulletin No. 2018–14
464

daily determinations of yield on the 30-
year Treasury bond maturing in Novem-
ber 2047 determined each day through
February 7, 2018 and the yield on the
30-year Treasury bond maturing in Feb-
ruary 2048 determined each day for the
balance of the month. For plan years be-
ginning in March 2018, the weighted av-
erage of the rates of interest on 30-year
Treasury securities and the permissible
range of rates used to calculate current
liability are as follows:
Treasury Weighted Average Rates
For Plan Years
Beginning In
30-Year Treasury
Weighted Average
Permissible Range
90% to 105%
March 20182.842.56 to 2.98
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 February 2018
are as follows:
Minimum Present Value Segment Rates
MonthFirst SegmentSecond SegmentThird Segment
February 20182.723.944.33
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
numbers).
Table 2018-2
Monthly Yield Curve for February 2018
Derived from February 2018 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.52.1320.54.2540.54.3460.54.3880.54.40
1.02.3121.04.2641.04.3461.04.3881.04.40
1.52.4721.54.2641.54.3561.54.3881.54.40
2.02.6222.04.2642.04.3562.04.3882.04.40
2.52.7322.54.2742.54.3562.54.3882.54.40
3.02.8323.04.2743.04.3563.04.3883.04.40
3.52.9123.54.2743.54.3563.54.3883.54.40
4.02.9924.04.2744.04.3564.04.3884.04.40
4.53.0724.54.2844.54.3564.54.3884.54.40
5.03.1525.04.2845.04.3565.04.3885.04.40
5.53.2325.54.2845.54.3665.54.3885.54.40
6.03.3126.04.2946.04.3666.04.3886.04.40
6.53.3926.54.2946.54.3666.54.3986.54.40
7.03.4627.04.2947.04.3667.04.3987.04.40
7.53.5427.54.2947.54.3667.54.3987.54.40
8.03.6128.04.3048.04.3668.04.3988.04.40
8.53.6728.54.3048.54.3668.54.3988.54.40
9.03.7429.04.3049.04.3669.04.3989.04.40
9.53.8029.54.3049.54.3669.54.3989.54.40
10.03.8530.04.3150.04.3670.04.3990.04.40
10.53.9030.54.3150.54.3670.54.3990.54.40
11.03.9431.04.3151.04.3771.04.3991.04.40
Bulletin No. 2018–14April 2, 2018
465

Table 2018-2
Monthly Yield Curve for February 2018
Derived from February 2018 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
11.53.9831.54.3151.54.3771.54.3991.54.40
12.04.0232.04.3252.04.3772.04.3992.04.40
12.54.0532.54.3252.54.3772.54.3992.54.40
13.04.0833.04.3253.04.3773.04.3993.04.40
13.54.1033.54.3253.54.3773.54.3993.54.40
14.04.1334.04.3254.04.3774.04.3994.04.40
14.54.1534.54.3354.54.3774.54.3994.54.40
15.04.1635.04.3355.04.3775.04.3995.04.40
15.54.1835.54.3355.54.3775.54.3995.54.40
16.04.1936.04.3356.04.3776.04.3996.04.41
16.54.2036.54.3356.54.3776.54.3996.54.41
17.04.2137.04.3357.04.3777.04.3997.04.41
17.54.2237.54.3457.54.3877.54.3997.54.41
18.04.2338.04.3458.04.3878.04.3998.04.41
18.54.2338.54.3458.54.3878.54.4098.54.41
19.04.2439.04.3459.04.3879.04.4099.04.41
19.54.2439.54.3459.54.3879.54.4099.54.41
20.04.2540.04.3460.04.3880.04.40100.04.41
Rev. Proc. 2018–19
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 2018 – 4, 2018 –1 I.R.B. 146. Spe-
cifically, this revenue procedure changes
one user fee set forth in Appendix A of
Rev. Proc. 2018 – 4, Schedule of User
Fees, with respect to applications on Form
5310, Application for Determination for
Terminating Plan. That user fee is reduced
from $3,000 to $2,300, effective January
2, 2018. Applicants who paid the $3,000
user fee listed in Rev. Proc. 2018 – 4 will
receive a refund of $700.
SECTION 2. BACKGROUND
.01 Rev. Proc. 2018 – 4 explains how
the Internal Revenue Service (Service)
provides advice to taxpayers on issues un-
der the jurisdiction of the Commissioner,
Tax Exempt and Government Entities Di-
vision, Employee Plans Rulings and
Agreements Office (Employee Plans Rul-
ings and Agreements), including proce-
dures for requesting determination letters
from the Service. It also includes the user
fees that are required to be paid when
requesting various types of advice.
.02 Appendix A of Rev. Proc. 2018 – 4
sets forth the specific fee applicable with
respect to each category or subcategory of
submission under the revenue procedure.
Section .06 of Appendix A sets forth the
fees applicable to determination letters.
The user fee applicable to a determination
letter request submitted on Form 5310
provided in section .06(1)(c) of Appendix
A was increased from $2,300 for 2017 to
$3,000 for 2018.
SECTION 3. MODIFICATION OF
REV. PROC. 2018–4
Section .06(1)(c) of Appendix A of
Rev. Proc. 2018 – 4 is modified to read as
follows:
(c) Form 5310 (Application for Deter-
mination for Terminating Plan) $2,300.
SECTION 4. REFUND OF USER
FEE
Taxpayers who paid a $3,000 user fee
in connection with the submission of a
determination letter request on Form 5310
will receive a refund of $700 (the differ-
ence between the $3,000 user fee listed in
Rev. Proc. 2018 – 4 and the $2,300 user
fee listed in this revenue procedure).
SECTION 5. PAPERWORK
REDUCTION ACT
The collections of information con-
tained in Revenue Procedure 2018 – 4
have been reviewed and approved by the
Office of Management and Budget in
accordance with the Paperwork Reduc-
tion Act (44 U.S.C. 3507) under control
number 1545-1520.
An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information un-
less the collection of information displays
a valid OMB control number.
The collections of information in Rev.
Proc. 2018 – 4 are in sections 6.02, 6.03,
6.05, 6.06, 10.03, 10.04, 10.12, 10.15,
10.16, 10.18, 11.04, 16, 17, 18, 21.02,
22.03, 23.02, 23.08, 27.05, 27.06, 27.07,
27.08, 27.09, 27.10, 27.13, 28.01, 28.06,
28.07, and 29.10, and in Appendices C, E,
and F. This information is required to
evaluate and process the request for a let-
ter ruling or determination letter, and,
with respect to determination letters, in-
formation collected will be used to deter-
April 2, 2018Bulletin No. 2018–14
466

mine whether a plan is entitled to favor-
able tax treatment as a qualified plan. In
addition,this information will be used to
help the Service delete certain informa-
tion from the text of the letter ruling or
determination letter before it is made
available for public inspection, as re-
quired by §§ 6110 and 6104. The col-
lections of information are required to
obtain a letter ruling or determination
letter. The likely respondents are indi-
viduals, businesses or other for-profit
institutions, tax exempt organizations,
and government entities.
The estimated total annual reporting
and/or recordkeeping burden with respect
to letter ruling requests is 769 hours. The
estimated total annual reporting and/or re-
cordkeeping burden with respect to deter-
mination letters is 17,382 hours.
The estimated annual burden per re-
spondent/recordkeeper varies from 15
minutes to 40 hours, depending on indi-
vidual circumstances and the type of re-
quest involved, with an estimated average
burden of 6.01 hours for letter ruling re-
quests and 2.02 hours for determination
letter requests. The estimated number of
respondents and/or recordkeepers is 128
for letter rulings and 8,605 for determina-
tion letters.
For letter rulings, the estimated annual
frequency of responses is one request per
applicant, except that a taxpayer request-
ing a letter ruling may also request a pre-
submission conference.
For determination letters, the estimated
annual frequency of responses (used for
reporting requirements only) is once every
three years.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by § 6103.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2018 – 4 is modified.
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective as
of January 2, 2018.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kathleen Herrmann of the
Office of Associate Chief Counsel (Tax
Exempt and Government Entities). For
further information regarding this revenue
procedure or submissions under Revenue
Procedure 2018 – 4, contact Don Kieffer
of Employee Plans Rulings and Agree-
ments, at (908) 301-2655 (not a toll-free
number).
Rev. Proc. 2018–21
SECTION 1. PURPOSE
This revenue procedure modifies the
procedures of the Internal Revenue Ser-
vice (IRS) for issuing opinion and advi-
sory letters for pre-approved master and
prototype and volume submitter plans as
provided in Rev. Proc. 2015–36, 2015–27
I.R.B. 20. In particular, this revenue pro-
cedure modifies sections 6.03(7)(c) and
16.03(7)(c) of Rev. Proc. 2015–36 to al-
low pre-approved defined benefit plans
containing a cash balance formula to pro-
vide for the actual rate of return on plan
assets as the rate used todetermine inter-
est credits. This revenue procedure also
modifies section 6.03(7)(c) of Rev.
Proc. 2017– 41, 2017–29 I.R.B. 92, re-
lating to the rates that are permitted to
be used to determine interest credits in
pre-approved defined benefit plans con-
taining a cash balance formula. In addi-
tion, this revenue procedure changes
references to “hypothetical interest” and
“hypothetical interest credits” in Rev.
Proc. 2015–36 to “interest credits”, con-
sistent with terminology in Rev. Proc.
2017– 41.
SECTION 2. BACKGROUND
.01 Rev. Proc. 2015–36 sets forth the
procedures for obtaining opinion and ad-
visory letters for qualified pre-approved
plans submitted to the IRS with respect to
remedial amendment cycles prior to the
third six-year cycle.
.02 Rev. Proc. 2015–36 was modified
and superseded by Rev. Proc. 2017– 41
with respect to applications for opinion
letters for pre-approved plans submitted
for the third (and subsequent) six-year re-
medial amendment cycles. Rev. Proc.
2017– 41 modified the IRS pre-approved
plan letter program by combining the
master and prototype and volume submit-
ter plan programs into a new Opinion Let-
ter program. The provisions of Rev. Proc.
2015–36 continue to apply to applications
for opinion and advisory letters submitted
during the second six-year remedial
amendment cycle. The second six-year re-
medial amendment cycle for pre-approved
defined benefit plans began on February 1,
2013, and ends on April 30, 2020.
1
De-
fined benefit plans submitted for opinion
and advisory letters for the second six-
year remedial amendment cycle continue
to be reviewed by the IRS.
.03 Sections 4.12 and 13.08 of Rev.
Proc. 2015–36 set forth definitions related
to hybrid plans. Under these sections, a
statutory hybrid plan is a defined benefit
plan that contains a statutory hybrid ben-
efit formula, as defined in § 1.411(a)(13)–
1(d)(4). A cash balance plan is a defined
benefit plan that includes a cash balance
formula. A cash balance formula is a stat-
utory hybrid benefit formula used to de-
termine all or any part of a participant’s
accumulated benefit, under which the ac-
cumulated benefit is expressed as the cur-
rent balance of a hypothetical account
maintained for the participant. Sections
4.12 and 13.08 of Rev. Proc. 2015–36
describe the hypothetical account balance
as generally consisting of principal credits
and hypothetical interest credits.
.04 Pursuant to sections 6.03(7)(a) and
16.03(7)(a) of Rev. Proc. 2015–36, opin-
ion and advisory letters, respectively, will
not be issued to statutory hybrid plans that
contain a statutory hybrid benefit formula
that is not a cash balance formula.
.05 Sections 6.03(7)(c) and 16.03(7)(c)
of Rev. Proc. 2015–36 provide that opin-
1
Rev. Proc. 2016 –37, 2016 –29 I.R.B 136, provides that the second six-year remedial amendment cycle for pre-approved defined benefit plans would end on January 31, 2019 unless the
IRS were to revise these timing requirements and that any such revisions would be announced in future guidance. Ann. 2018 – 05, 2018 –13 I.R.B. 461 (March 26, 2018), extends this deadline
to April 30, 2020.
Bulletin No. 2018–14April 2, 2018
467

ion and advisory letters, respectively, will
not be issued for statutory hybrid plans
that include provisions that allow a rate
used to determine hypothetical interest to
be based on the actual return on plan
assets or a subset of plan assets (as de-
scribed in § 1.411(b)(5)–1(d)(5)(ii)) or the
rate of return on certain regulated invest-
ment companies (RICs) (as described in
§ 1.411(b)(5)–1(d)(5)(iv)).
.06 Section 4.03(1) of Rev. Proc.
2017– 41 clarifies that for purposes of the
definition of “cash balance formula” the
“hypothetical account balance generally
consists of Principal Credits and Interest
Credits.” Corresponding clarifications are
made throughout that revenue procedure,
where applicable.
.07 Section 6.03(7)(c) of Rev. Proc.
2017– 41 also deletes the restriction on
using a rate that is based on the actual
return on plan assets in determining inter-
est credits. This modification allows non-
standardized pre-approved defined benefit
plans with a cash balance formula that are
submitted for an opinion letter during the
third (and subsequent) six-year remedial
amendment cycles to provide for a rate
that is based on the actual return on plan
assets as the rate used to determine inter-
est credits, including a rate that is equal to
the actual rate of return on aggregate plan
assets.
.08 Subsequent to the release of Rev.
Proc. 2017– 41, the IRS received com-
ments requesting that plans submitted un-
der Rev. Proc. 2015–36 be permitted to
provide for a rate equal to the actual rate
of return on aggregate plan assets as
the rate used to determine interest credits.
The IRS has determined that it is appro-
priate to allow master and prototype non-
standardized defined benefit plans and
volume submitter defined benefit plans
that contain a cash balance formula, sub-
mitted pursuant to Rev. Proc. 2015–36
with respect to the second six-year reme-
dial amendment cycle, to provide for a
rate equal to (but not merely based on) the
actual rate of return on aggregate plan
assets as the rate used to determine inter-
est credits and to clarify that, although
these plans generally may not provide that
the rate used to determine interest credits
is based on the rate of return on RICs, the
rate used to determine interest credits may
be equal to the actual rate of return on
aggregate plan assets even if that return
includes returns on RICs. The IRS has
also determined that Rev. Proc. 2017– 41
should be revised, consistent with these
changes to Rev. Proc. 2015–36, to allow
pre-approved defined benefit plans that
contain a cash balance formula, submitted
with respect to the third (and subsequent)
six-year remedial amendment cycles, to
provide for a rate equal to the actual rate
of return on aggregate plan assets as the
rate used to determine interest credits
(rather than a rate that is merely based on
the actual return on plan assets) and to
clarify that the rate used to determine in-
terest credits may be equal to the actual
rate of return on aggregate plan assets
even if that return includes returns on
RICs. Further, the IRS has determined
that Rev. Proc. 2015–36 should be modi-
fied to make clarifying changes to the
definition of hypothetical account balance
and related clarifications, throughout the
revenue procedure, where applicable, con-
sistent with Rev. Proc. 2017– 41.
SECTION 3. MODIFICATIONS OF
REV. PROC. 2015–36 AND REV.
PROC. 2017–41
.01 Sections 6.03(7)(c) and 16.03(7)(c)
of Rev. Proc. 2015–36, describing areas
not covered by opinion letters and advi-
sory letters, respectively, with respect to
statutoryhybridplans,andsection
6.03(7)(c) of Rev. Proc. 2017– 41, de-
scribing areas not covered by opinion let-
ters with respect to statutory hybrid plans,
are revised to read as follows:
(c) Provisions under which a rate used
to determine Interest Credits is based on
the actual rate of return on aggregate as-
sets of the plan described in § 1.411(b)
(5)–1(d)(5)(ii)(A) or therate of return
on certain regulated investment compa-
nies (RICs) described in § 1.411(b)
(5)–1(d)(5)(iv) (unless the plan provides
that the rate used to determine Interest
Credits is equal to the actual rate of
return on the aggregate assets of the
plan), or is based on or equal to the
actual rate of return on a subset of plan
assets (as described in § 1.411(b)(5)–
1(d)(5)(ii)(B)).
.02 In addition to the changes in sec-
tions 6.03(7)(c) and 16.03(7)(c) of Rev.
Proc. 2015–36, clarifications to terminol-
ogy relating to statutory hybrid plans are
made to remove references to hypothetical
interest or hypothetical interest credits and
replace them with references to interest
credit(s) throughout Rev. Proc. 2015–36,
consistent with the changes made in Rev.
Proc. 2017– 41. These changes to Rev.
Proc. 2015–36 are as follows:
(1) Sections 4.12(1) and 13.08(1), de-
fining “Cash Balance Formula” are re-
vised in part so that the last sentence of
each of those sections reads as follows:
“The hypothetical account balance gener-
ally consists of Principal Credits and In-
terest Credits.”
(2) Sections 4.12(4) and (6) and
13.08(4) and (6) relating to the definition
of “Hypothetical Interest” and “Principal
Credit” for master and prototype and vol-
ume submitter plans, respectively, are
each revised to refer to “Interest Credit”
or “interest credit” rather than “Hypothet-
ical Interest” or “hypothetical interest,” as
applicable.
(3) Sections 6.03(7)(b) and 16.03(7)(b)
listing an area not covered by opinion or
advisory letters, respectively, with respect
to statutory hybrid plans are each revised
to replace, “Provisions that allow for hy-
pothetical interest crediting” with, “Provi-
sions under which Interest Credits are.”
SECTION 4. PAPERWORK
REDUCTION ACT
The collection of information con-
tained in Rev. Proc. 2015–36 has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U.S.C. 3507) under control number 1545-
1674.
An agency may not conduct or spon-
sor, and a person is not required to re-
spond to, a collection of information un-
less the collection of information displays
a valid OMB control number.
The collection of information in Rev.
Proc. 2015–36 is in sections 5.11, 8.02,
11.02, 12, 14.05, 15.02, 18, and 24. This
information is required to enable the
Commissioner, Tax Exempt and Govern-
ment Entities Division of the Internal
Revenue Service to make determinations
in connection with plan qualification. This
information will be used to determine
whether a plan is entitled to favorable tax
treatment. The likely respondents are
banks, insurance companies, other finan-
April 2, 2018Bulletin No. 2018–14
468

cial institutions, law, actuarial, and con-
sulting firms, employee benefit practitio-
ners and employers.
The estimated total annual reporting
and/or recordkeeping burden is 988,290
hours.
The estimated annual burden per respon-
dent/recordkeeper varies from 1/2 to 2,000
hours, depending on individual circum-
stances, with an estimated average of 3.18
hours. The estimated number of respondents
and/or recordkeepers is 310,315.
The estimated frequency of responses
is occasional.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by 26 U.S.C. § 6103.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 2015–36 and Rev. Proc.
2017– 41 are modified.
SECTION 6. EFFECTIVE DATE
The modifications in this revenue pro-
cedure are effective as of March 16, 2018.
SECTION 7. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kathleen Herrmann of the
Office of Associate Chief Counsel (Tax
Exempt and Government Entities). For
further information regarding this revenue
procedure, contact Employee Plans (513)
975-6319 (not a toll-free number).
Bulletin No. 2018–14April 2, 2018
469

Part IV. Items of General Interest
Disclosure of Returns and
Return Information in
Connection with Written
Contracts or Agreements
for the Acquisition of
Property or Services for
Tax Administration
Purposes
REG–129260–16
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION:Notice of proposed rulemaking.
SUMMARY:This document contains pro-
posed regulations under section 6103(n)
of the Internal Revenue Code (Code) to
authorize the Department of State to dis-
close returns and return information to its
contractors who assist the Department of
State in carrying out its responsibilities
under section 32101 of the Fixing Amer-
ica’s Surface Transportation (FAST) Act.
The FAST Act requires the IRS to notify
the Department of State of certified seri-
ously delinquent tax debts, and the De-
partment of State procures services from
outside contractors in connection with
carrying out its responsibilities under the
FAST Act.
DATES: Written and electronic com-
ments and requests for a public hearing
must be received by April 12, 2018.
ADDRESSES: Send submissions to: CC:
PA:LPD:PR(REG–129260 –16), Room
5207, Internal Revenue Service, P.O. Box
7604, Ben Franklin Station, Washington,
DC 20044. Submissions may be hand deliv-
ered Monday through Friday between the
hours of 8:00 a.m. and 4:00 p.m. to CC:PA:
LPD:PR(REG–129260 –16),Courier’s
Desk, Internal Revenue Service, 1111 Con-
stitution Avenue, NW, Washington, DC
20224. Alternatively, taxpayers may submit
comments electronically via the Federal
eRulemaking Portal atwww.regulations.gov
(IRS REG–129260 –16).
FOR FURTHER INFORMATION CON-
TACT:Concerning the proposed regula-
tions, Brittany Harrison of the Office of
Associate Chief Counsel (Procedure and
Administration), (202) 317-6833; con-
cerning the submission of comments and
requests for a public hearing, Regina
Johnson, (202) 317-6901 (not toll-free
numbers).
SUPPLEMENTARY INFORMATION:
Background and Explanation of
Provisions
This document contains proposed
amendments to the Procedure and Admin-
istration Regulations (26 CFR part 301)
under section 6103(n) of the Code. On
December 4, 2015, the FAST Act, Public
Law 114 –94, 129 Stat. 1312, was enacted
into law. Section 32101 of the FAST Act
adds section 7345 to the Internal Revenue
Code. Section 7345 requires the IRS to
notify the Department of State of tax debts
that the IRS certifies as seriously delin-
quent. Section 7345(b) generally defines a
seriously delinquent tax debt as an unpaid,
legally enforceable Federal tax liability of
an individual that has been assessed, is
greater than $50,000 (as indexed for infla-
tion), and with respect to which a notice of
lien has been filed pursuant to section
6323 and the administrative rights under
section 6320 with respect to such filing
have been exhausted or have lapsed, or a
levy has been made pursuant to section
6331. Section 32101 of the FAST Act
generally requires the Department of State
to deny a passport (or the renewal of a
passport) in the case of an individual if
notified by the IRS that the individual has
been certified as having a seriously delin-
quent tax debt and permits the Department
of State to revoke a passport previously
issued to such person.
Under section 6103(a) of the Code, re-
turns and return information are confidential
unless the Code otherwise authorizes di-
sclosure. The FAST Act added section
6103(k)(11), which provides that, upon cer-
tification under section 7345, the IRS is
authorized to disclose return information to
the Department of State with respect to a
taxpayer who has a seriously delinquent tax
debt. Specifically, upon certification under
section 7345, section 6103(k)(11)(A) autho-
rizes the IRS to disclose to officers and
employees of the Department of State (i) the
taxpayer identity information with respect to
the certified taxpayer and (ii) the amount of
such seriously delinquent tax debt. Section
6103(k)(11)(A). Section 6103(k)(11)(B)
limits the use of return information dis-
closed under subparagraph (A) for the pur-
poses of, and to the extent necessary in,
carrying out the requirements of section
32101 of the FAST Act.
The Department of State engages con-
tractors to assist in carrying out its respon-
sibilities with respect to passports, including
responsibilities related to implementation of
section 32101 of the FAST Act. Because
such contractors are not “officers and em-
ployees” of the Department of State, section
6103(k)(11) of the Code does not authorize
the disclosure of return information to such
contractors.
Section 6103(n) of the Code autho-
rizes, pursuant to regulations prescribed
by the Secretary, the disclosure of returns
and return information to any person for
purposes of tax administration to the ex-
tent necessary in connection with, among
other things, a written contract for ser-
vices. The definition of the term “tax ad-
ministration” includes “the administra-
tion, management, conduct, direction, and
supervision of the execution and applica-
tion of the internal revenue laws or related
statutes....”Section 6103(b)(4). Because
implementation of the FAST Act relates
to the administration, management, con-
duct, direction, and supervision of the ex-
ecution and application of the internal rev-
enue laws and related statutes, disclosure
of return information for the purpose of
carrying out responsibilities under the
FAST Act is a tax administration purpose.
The Treasury regulations provide that,
pursuant to the provisions of section
6103(n) of the Code and subject to certain
conditions, officers and employees of the
Treasury Department, a State tax agency,
the Social Security Administration, or the
Department of Justice are authorized to
disclose returns and return information to
any person or to an officer or employee of
the person, for purposes of tax adminis-
tration (as defined in section 6103(b)(4)),
to the extent necessary in connection with
a written contract or an agreement for the
acquisition of the providing of services.
Section 301.6103(n)–1(a)(1). Any person,
April 2, 2018Bulletin No. 2018–14
470

or officer or employee of the person, who
receives such disclosed returns or return
information may further disclose the re-
turns or return information to its own of-
ficers or employees whose duties or re-
sponsibilities require such information
in order to provide the services. Section
301.6103(n)–1(a)(2)(i). Whenauthorized
in writing by the IRS, such person, or officer
or employee of the person, may further dis-
closesuch information to the extent nec-
essary to provide services, including to
its agents or subcontractors (or such
agents’ or subcontractors’ officers or
employees). Section 301.6103(n)–1(a)
(2)(ii). Agents or subcontractors (or
their officers or employees) who receive
such returns or return information may
further disclose the returns or return in-
formation to their officers or employees
whose duties or responsibilities require
the returns or return information for a
purpose described in § 301.6103(n)–
1(a). Section 301.6103(n)–1(a)(3). The
regulations under section 6103(n) of the
Code provide a number of rules related
to limitations on such disclosures, pen-
alties potentially applicable to recipients
of returns and return information, noti-
fication requirements applicable to re-
cipients of returns and return informa-
tion, and safeguards requirements. See
section 301.6103(n)–1(b), –1(c), –1(d),
–1(e).
These proposed regulations add the
Department of State to the list of agencies
in current § 301.6103(n)–1(a)(1) whose
officers and employees may disclose re-
turns and return information to any person
or to an officer or employee of such per-
son for tax administration purposes to the
extent necessary in connection with a
written contract for the acquisition of
property or services. These proposed reg-
ulations authorize the Department of State
to disclose returns and return information
to its contractors providing services in
connection with the revocation or denial
of passports pursuant to the requirements
of section 7345 and the FAST Act.
Special Analyses
Certain IRS regulations, including this
one, are exempt from the requirements of
Executive Order 12866, as supplemented
and reaffirmed by Executive Order 13563.
Therefore, a regulatory impact assessment
is not required.
The purpose of these regulations is to
allow the Department of State to share tax
return information with its contractors for
tax administration purposes. As a recipi-
ent of tax return information, the Depart-
ment of State is required to comply with
the reporting and other requirements un-
der section 6103(p)(4). The Department of
State is also responsible for the training
and inspection of its contractors and en-
suring that all safeguarding standards are
met. These proposed regulations do not
impose a reporting burden on the Depart-
ment of State’s contractors and will not
require the contractors to file information
with the IRS. Because the proposed regu-
lations do not impose a collection of in-
formation on entities other than the De-
partment of State, they do not impose a
collection of information on small entities.
Accordingly, it is hereby certified that
these regulations will not have a signifi-
cant economic impact on a substantial
number of small entities. Accordingly, a
regulatory flexibility analysis is not re-
quired under the Regulatory Flexibility
Act (5 U.S.C. chapter 6).
Pursuant to section 7805(f) of the
Code, these proposed regulations have
been submitted to the Chief Counsel for
Advocacy of the Small Business Admin-
istration for comment on their impact on
small business.
Comments and Requests for Public
Hearing
Before the regulations proposed herein
are adopted as final regulations, consider-
ation will be given to any electronic and
written comments that are submitted
timely to the IRS as prescribed in this
preamble under the ADDRESSES head-
ing. The Treasury Department and the IRS
request comments on all aspects of the
proposed regulations. All comments sub-
mitted will be made available atwww.
regulations.govor upon request. A public
hearing may be scheduled if requested in
writing by a person that timely submits
written comments. If a public hearing is
scheduled, notice of the date, time, and
place of the hearing will be published in
theFederal Register.
Drafting Information
The principal author of these proposed
regulations is Brittany Harrison of the Of-
fice of the Associate Chief Counsel (Pro-
cedure and Administration).
*****
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 301 is pro-
posed to be amended as follows:
PART 301—PROCEDURE AND
ADMINISTRATION
Paragraph 1. The authority citation for
part 301 continues to read in part as fol-
lows:
Authority: 26 U.S.C. 7805***
Par. 2. Sections 6103(n)–1(a)(1) and
(e)(4)(i) are amended by removing the
language “or the Department of Justice”
and adding the language “the Department
of Justice, or the Department of State” in
its place.
Par. 3. Section 301.6103(n)–1(g) is
amended to read as follows:
(g)Applicability date. This section is
applicable on June 5, 2007, except that
paragraphs (a) and (e)(4)(i) of this section
apply to the Department of State on or
after March 12, 2018.
Kirsten Wielobob,
Deputy Commissioner for Services and
Enforcement.
(Filed by the Office of the Federal Register on March 12,
2018, 8:45 a.m., and published in the issue of the Federal
Register for March 13, 2018, 83 F.R. 10811)
Bulletin No. 2018–14April 2, 2018
471

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. 2018–14April 2, 2018
i

Numerical Finding List
1
Bulletin 2018 –1 through 2018 –14
Announcements:
2018-01, 2018-9 I.R.B.387
2018-02, 2018-9 I.R.B.387
2018-03, 2018-9 I.R.B.387
2018-04, 2018-10 I.R.B.401
2018-05, 2018-13 I.R.B.461
Notices:
2018-01, 2018-3 I.R.B.285
2018-02, 2018-2 I.R.B.281
2018-03, 2018-2 I.R.B.285
2018-05, 2018-6 I.R.B.341
2018-06, 2018-3 I.R.B.300
2018-07, 2018-4 I.R.B.317
2018-08, 2018-7 I.R.B.352
2018-10, 2018-8 I.R.B.359
2018-11, 2018-11 I.R.B.425
2018-12, 2018-12 I.R.B.441
2018-13, 2018-6 I.R.B.341
2018-14, 2018-7 I.R.B.353
2018-15, 2018-9 I.R.B.376
2018-16, 2018-10 I.R.B.390
2018-17, 2018-9 I.R.B.376
2018-18, 2018-12 I.R.B.443
2018-19, 2018-12 I.R.B.443
2018-20, 2018-12 I.R.B.444
2018-22, 2018-14 I.R.B.464
Proposed Regulations:
REG-119514-15, 2018-04 I.R.B.325
REG-129260-16, 2018-14 I.R.B.470
REG-118067-17, 2018-08 I.R.B.360
REG-132197-17, 2018-10 I.R.B.404
REG-133491-17, 2018-11 I.R.B.430
Revenue Procedures:
2018-1, 2018-1 I.R.B.1
2018-2, 2018-1 I.R.B.106
2018-3, 2018-1 I.R.B.130
2018-4, 2018-1 I.R.B.146
2018-5, 2018-1 I.R.B.244
2018-7, 2018-1 I.R.B.282
2018-8, 2018-2 I.R.B.286
2018-9, 2018-2 I.R.B.290
2018-10, 2018-7 I.R.B.355
2018-11, 2018-5 I.R.B.334
2018-12, 2018-6 I.R.B.349
2018-13, 2018-7 I.R.B.356
2018-14, 2018-9 I.R.B.378
2018-15, 2018-9 I.R.B.379
2018-16, 2018-9 I.R.B.383
2018-17, 2018-9 I.R.B.384
2018-18, 2018-10 I.R.B.392
Revenue Procedures:—Continued
2018-19, 2018-14 I.R.B.466
2018-20, 2018-11 I.R.B.427
2018-21, 2018-14 I.R.B.467
Revenue Rulings:
2018-01, 2018-2 I.R.B.275
2018-02, 2018-2 I.R.B.277
2018-03, 2018-2 I.R.B.278
2018-04, 2018-4 I.R.B.304
2018-05, 2018-6 I.R.B.339
2018-06, 2018-10 I.R.B.388
2018-07, 2018-13 I.R.B.445
2018-09, 2018-14 I.R.B.462
Treasury Decisions:
9829, 2018-04 I.R.B.308
9830, 2018-11 I.R.B.423
9831, 2018-13 I.R.B.459
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
April 2, 2018Bulletin No. 2018–14
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2018 –1 through 2018 –14
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2017–27 through 2017–52 is in Internal Revenue Bulletin
2017–52, dated December 27, 2017.
Bulletin No. 2018–14April 2, 2018
iii

INTERNAL REVENUE BULLETIN
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