Highlights of This Issue EMPLOYMENT TAX INCOME TAX Preface The IRS Mission Introduction Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Rev. Rul. 201817 Part IV. Items of General Interest REG10295116 Definition of Terms and Abbreviations Definition of Terms Abbreviations Numerical Finding List Numerical Finding List Effect of Current Actions on Previously Published Items Finding List of Current Actions on Previously Published Items INTERNAL REVENUE BULLETIN We Welcome Comments About the Internal Revenue Bulletin Internal Revenue Bulletin: 2018-25 June 18, 2018 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. EMPLOYMENT TAX REG–102951–16 REG–102951–16 The proposed regulations eliminate the no-aggregation rule in determining the 250-return threshold for filing certain information returns electronically. These proposed regulations also require corrected returns be filed electronically if original returns were required to be filed electronically, regardless of the number of corrected returns being filed. INCOME TAX Rev. Rul. 2018–17 Rev. Rul. 2018–17 This Revenue Ruling clarifies that federal income tax withholding under § 3405 and Form 1099–R reporting under § 408(i) generally apply for the year a payment is made, as required by State law, from an individual retirement arrangement (IRA) to a State unclaimed property fund. REG–102951–16 REG–102951–16 The proposed regulations eliminate the no-aggregation rule in determining the 250-return threshold for filing certain information returns electronically. These proposed regulations also require corrected returns be filed electronically if original returns were required to be filed electronically, regardless of the number of corrected returns being filed. Preface The IRS Mission Provide America’s taxpayers top-quality service by helping them understand and meet their tax responsibilities and enforce 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 Conventions, 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 otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal 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, identifying 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, Legislation 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 Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment 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. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Rev. Rul. 2018–17 Withholding and Reporting With Respect to Payments From IRAs to State Unclaimed Property Funds ISSUES (1) Under the facts presented, is the payment by Trustee Y of Individual C’s interest in IRA O to the State J unclaimed property fund, as required by State J law, subject to federal income tax withholding under § 3405 of the Internal Revenue Code? (2) Is the payment by Trustee Y subject to reporting under § 408(i)? FACTS Individual C has an interest in IRA O, a traditional IRA trusteed by Trustee Y. Individual C, a U.S. person under § 7701(a)(30)(A) with a calendar year taxable year, has not made a withholding election with respect to her interest in IRA O. State J law requires Trustee Y to pay Individual C’s interest in IRA O to the State J unclaimed property fund under which a claim for property may be made by the owner. In 2018, Trustee Y pays Individual C’s interest in IRA O, which has a value of $1,000, to the State J unclaimed property fund. For purposes of this revenue ruling, an “IRA” is an individual retirement plan under § 7701(a)(37) (that is, an individual retirement account as defined in § 408(a) or individual retirement annuity as defined in § 408(b)), and a “traditional IRA” is an IRA that is not a Roth IRA under § 408A, a simplified employee pension under § 408(k), a SIMPLE IRA under § 408(p), or a deemed IRA under § 408(q). LAW AND ANALYSIS (1) Withholding Section 3405 provides federal income tax withholding rules with respect to designated distributions. Under § 3405(e)(1)(A), a designated distribution means, except as provided in § 3405(e)(1)(B), any distribution or payment from or under an employer deferred compensation plan, an IRA, or a commercial annuity. As relevant here, under § 3405(e)(1)(B)(ii), a designated distribution does not include the portion of a distribution or payment that it is reasonable to believe is not includible in gross income. For this purpose, the flush language under § 3405(e)(1)(B) provides that any distribution or payment from or under an IRA (other than a Roth IRA as defined in § 408A) is treated as includible in gross income. Section 3405 requires federal income tax to be withheld from two types of designated distributions from IRAs, each with its own withholding rules: periodic payments under § 3405(a), and nonperiodic distributions under § 3405(b). Under § 3405(e)(3), a nonperiodic distribution is a designated distribution that is not an annuity or similar periodic payment. In the case of a nonperiodic distribution under § 3405(e)(3), § 3405(b)(1) provides that the payor shall withhold from such distribution an amount equal to 10 percent of the distribution. Section 3405(b)(2) provides that an individual may elect not to have § 3405(b)(1) withholding apply with respect to any nonperiodic distribution. Section 35.3405–1T provides rules regarding § 3405, including general rules on withholding requirements and specific rules addressing withholding on periodic and nonperiodic distributions, notice and election procedures, and reporting and recordkeeping. Section 35.3405–1 provides rules regarding the medium through which notices required under § 3405 may be provided. The payment of Individual C’s interest in IRA O, a traditional IRA, to the State J unclaimed property fund, as required by State J law, is a payment from an IRA that is treated as includible in gross income (pursuant to the flush language of § 3405(e)(1)(B)) for purposes of § 3405(e)(1)(B)(ii). Thus, the payment is a designated distribution for purposes of § 3405. The payment from IRA O is not an annuity or similar periodic payment under § 3405(e)(2). Thus, it is a nonperiodic distribution as defined in § 3405(e)(3). Because Individual C has not made a withholding election with respect to the payment, a 10 percent withholding rate applies to the payment pursuant to § 3405(b)(1), and Trustee Y must withhold federal income tax of $100 (10% of Individual C’s $1,000 interest in IRA O). (2) Reporting Section 408(i) provides that the trustee of an individual retirement account and the issuer of an endowment contract described in § 408(b) or an individual retirement annuity must make such reports regarding such account, contract, or annuity to the Secretary and to the individuals for whom the account, contract, or annuity is, or is to be, maintained with respect to contributions (and the years to which they relate), distributions aggregating $10 or more in any calendar year, and such other matters as the Secretary may require. Section 1.408–7(a) provides that the trustee of an individual retirement account or the issuer of an individual retirement annuity who makes a distribution during any calendar year shall make a report of the distribution for such year. Form 1099–R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc., is used to satisfy this reporting obligation. Pursuant to § 408(i), Trustee Y must report the $1,000 distribution from IRA O ($900 of which is paid to the State J unclaimed property fund and $100 of which is remitted as federal income tax withholding) on a 2018 Form 1099–R identifying Individual C as the recipient. HOLDINGS (1) Under the facts presented, the payment by Trustee Y of Individual C’s interest in IRA O to the State J unclaimed property fund, as required by State J law, is subject to federal income tax withholding under § 3405. (2) The payment by Trustee Y is subject to reporting under § 408(i). TRANSITION RELIEF A person will not be treated as failing to comply with the withholding and reporting requirements described in this revenue ruling with respect to payments made before the earlier of January 1, 2019, or the date it becomes reasonably practicable for the person to comply with those requirements. DRAFTING INFORMATION The principal author of this revenue ruling is Cynthia Van Bogaert of the Office of Associate Chief Counsel (Tax Exempt and Government Entities). Ms. Van Bogaert may be reached at (202) 317-4102 (not a toll-free number).  This revenue ruling does not address whether the payment to the State unclaimed property fund otherwise complies with applicable law (for example, it does not address compliance with any applicable search requirements under State law).  Under § 3405(e)(1)(B)(iii), a designated distribution also does not include a payment that is subject to withholding under the withholding rules applicable to payments to nonresident aliens and foreign corporations. See § 1441 (Withholding of Tax on Nonresident Aliens), § 1442 (Withholding of Tax on Foreign Corporations), and § 1.1441–4(b)(1)(ii) (Exemptions from Withholding for Certain Effectively Connected Income and Other Amounts). Part IV. Items of General Interest REG–102951–16 Filing Requirements for Information Returns Required on Magnetic Media (Electronically) AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations amending the rules for determining whether information returns must be filed using magnetic media (electronically). The proposed regulations would require that all information returns, regardless of type, be taken into account to determine whether a person meets the 250-return threshold and, therefore, must file the information returns electronically. The proposed regulations also would require any person required to file information returns electronically to file corrected information returns electronically, regardless of the number of corrected information returns being filed. The proposed regulations will affect persons required to file information returns. DATES: Written or electronic comments and requests for a public hearing must be received by July 30, 2018. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG–102951–16), room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. Submissions may be hand-delivered Monday through Friday between the hours of 8:00 a.m. and 4:00 p.m. to CC:PA:LPD:PR (REG–102951–16), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, NW., Washington, DC 20224. Alternatively, persons may submit comments electronically via the Federal eRulemaking Portal at http://www.regulations.gov (IRS REG–102951–16). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Michael Hara, (202) 317-6845; concerning the submission of comments and requests for a public hearing, Regina L. Johnson, (202) 317-5177 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background This document contains proposed amendments to the Regulations on Procedure and Administration (26 CFR part 301) under section 6011(e) relating to the filing of information returns on magnetic media. Section 6011(e) authorizes the Secretary to prescribe regulations regarding the filing of returns on magnetic media. Section 6011(e)(2)(A) prohibits the Secretary from requiring persons to file returns on magnetic media unless the person is required to file at least 250 returns during the calendar year. Section 6011(e)(2)(B) provides that, in prescribing regulations, the Secretary shall consider the taxpayer’s ability to comply at reasonable cost with the regulations’ requirements. Section 301.6011–2(a)(1) provides that magnetic media includes any magnetic media permitted under the applicable regulations, revenue procedures, or publications, or, in the case of returns filed with the Social Security Administration, any magnetic media permitted under Social Security Administration publications, including electronic filing. Section 301.6011–2 provides rules for when information returns described in § 301.6011–2(b), such as Form 1042–S, “Foreign Person’s U.S. Source Income Subject to Withholding;” forms in the 1099 series; and Form W–2, “Wage and Tax Statement,” must be filed electronically. Under § 301.6011–2(c), a person is not required to file a type of information return covered by § 301.6011–2(b) electronically unless the person is required to file 250 or more such returns during the calendar year. Sections 301.6011–2(c)(1)(i) and (iii) and the Examples in § 301.6011–2(c)(1)(iv) describe that the 250-return threshold applies separately to each type of information return and each type of corrected information return filed, and, therefore, the forms are not aggregated for purposes of determining whether the 250-return threshold is satisfied. Section 301.6011–2(c)(2) allows the Commissioner to waive the requirement to file electronically if the request for waiver demonstrates hardship and provides that the principal factor in determining hardship will be the extent, if any, to which the cost of electronic filing exceeds the cost of filing on other media. When the rules for determining the 250-return threshold, including the rule providing that each type of information return is counted separately and not aggregated, were originally published, electronic filing was in the early stages of development and was not as commonly used as it is today. The non-aggregation rule helped to reduce cost and ease burden on taxpayers, given the existing limits on technology and accessibility to such technology. Since then, significant advances in technology have made electronic filing more prevalent and accessible. As a result, electronic filing is less costly and most often easier than paper filing. In fact, most information returns are filed electronically. In tax year 2015, approximately 98 percent of information returns were filed electronically. In tax year 2016, the percentage of information returns filed electronically rose to 98.5 percent. Advances in tax return preparation software, as well as the prevalence of tax return preparers and third-party service providers who offer information return preparation and electronic filing, have also contributed to the increase in electronic filing. The concerns regarding taxpayer burden and cost associated with electronic filing have been significantly mitigated since the non-aggregation rule in § 301.6011–2(c)(1)(i) and (iii) of the regulations was first published. Therefore, determining the 250-return threshold on a form-by-form basis without aggregation is no longer necessary to relieve taxpayer burden and cost. Accordingly, these regulations simplify the rules for determining the 250-return threshold by requiring aggregation of all information returns covered by § 301.6011–2(b) for purposes of determining the 250-return threshold. In addition, these regulations provide that corrected information returns must be filed electronically if the original information returns were filed electronically. These rule changes will help facilitate efficient and effective tax administration. Explanation of Provisions These proposed regulations remove the non-aggregation rule in § 301.6011–2(c)(1)(iii) that counts the number of information returns required to be filed on a form-by-form basis. The proposed regulations add a new paragraph (4) to § 301.6011–2(b) to provide that if during a calendar year a person is required to file a total of 250 or more information returns of any type covered by § 301.6011–2(b), the person is required to file those information returns electronically. For example, under these proposed regulations, if a person is required to file 200 Forms 1099–INT, “Interest Income,” and 200 Forms 1099–DIV, that person must file all Forms 1099–INT and Forms 1099–DIV electronically because that person is required to file, in the aggregate, at least 250 information returns covered by § 301.6011–2(b). Corrected information returns are not taken into account in determining whether the 250-return threshold is met under proposed § 301.6011–2(b)(4) for purposes of determining whether information returns covered by § 301.6011–2(b) must be filed electronically. Examples in proposed § 301.6011–2(c)(1)(iv) illustrate this rule. The proposed regulations also provide that corrected information returns covered by § 301.6011–2(b) must be filed electronically if the information returns originally filed for the calendar year are required to be filed electronically. If fewer than 250 returns covered by § 301.6011–2(b) are required to be filed for the calendar year, the original returns for the calendar year, as well as the corrected returns for the calendar year, are not required to be filed electronically. See proposed § 301.6011–2(b)(4), Example 4. The proposed regulations also amend § 301.6721–1(a)(2)(ii) regarding the penalty for failure to file correct information returns to remove references to the prior rule for determining the number of returns on a form-by-form basis and the prior corrected return rule. The proposed regulations do not amend the existing regulations allowing persons who are required to file returns electronically to request a waiver of the electronic-filing requirement. See § 301.6011–2(c)(2). This waiver authority will be exercised so as not to unduly burden taxpayers lacking the necessary data-processing capabilities or access to return preparers and third-party service providers at a reasonable cost. Proposed Effective/Applicability Date These proposed regulations will be effective on the date of the publication of the Treasury Decision adopting these rules as final in the Federal Register. However, to give information-return filers sufficient time to comply with these regulations, these proposed regulations will not apply to information returns required to be filed before January 1, 2019. Accordingly, these proposed regulations provide that § § 301.6011–2(b)(4) and 301.6721–1(a)(2)(ii), as amended, will be effective for information returns required to be filed after December 31, 2018. Section 301.6011–2(b)(5), as amended, will be effective for corrected information returns filed after December 31, 2018. Special Analyses This regulation is not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memorandum of Agreement (April 11, 2018) between the Department of the Treasury and the Office of Management and Budget regarding review of tax regulations. When the Internal Revenue Service issues a proposed rulemaking imposing a collection of information requirement on small entities, the Regulatory Flexibility Act (RFA) requires the agency to “prepare and make available for public comment an initial regulatory flexibility analysis,” which will “describe the impact of the proposed rule on small entities.” 5 U.S.C. 603(a). Section 605(b) of the RFA allows an agency to certify a rule, in lieu of preparing an analysis, if the proposed rulemaking is not expected to have a significant economic impact on a substantial number of small entities. This proposed rule directly affects information-return filers that file more than 250 returns of any type covered by § 301.6011–2(b), which includes a substantial number of small entities. However, the IRS has determined that the economic impact on small entities affected by the proposed rule would not be significant. Under sections 6011(e) and § 301.6011–2(c)(1), information-return filers already must file information returns electronically if during a calendar year a person is required to file a total of 250 or more information returns of any type covered by § 301.6011–2(b). The proposed rule merely amends the method of counting those 250 returns to determine if the 250-return threshold is met. Information filers may request a waiver of the electronic-filing requirement if they lack the necessary data-processing capabilities or access to return preparers and third-party service providers at a reasonable cost, and the IRS routinely grants meritorious hardship waiver requests. Accordingly, the burden on the limited number of small entities that are not currently filing electronically will be slight, and small entities that would experience a hardship because of this proposed rule may seek a waiver. The Commissioner of the IRS hereby certifies that this rule will not have a significant economic impact on a substantial number of small entities. The IRS invites comment from members of the public who believe there will be a significant impact on small information return filers. Pursuant to section 7805(f) of the Code, this notice of proposed rulemaking has been submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business. Comments and Requests for Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any electronic and written comments that are submitted timely to the IRS as prescribed in this preamble under the ADDRESSES heading. The Treasury Department and the IRS request comments on all aspects of the proposed rules. All comments will be available at www.regulations.gov or upon request. A public hearing will be scheduled if requested in writing by any person that timely submits written comments. If a public hearing is scheduled, then notice of the date, time, and place for the public hearing will be published in the Federal Register. Drafting Information The principal author of these proposed regulations is Michael Hara of the Office of the Associate Chief Counsel (Procedure and Administration). List of Subjects in 26 CFR Part 301 Income taxes, Penalties, Reporting and recordkeeping requirements. Proposed Amendments to the Regulations Accordingly, 26 CFR part 301 is proposed to be amended as follows: PART 301—PROCEDURE AND ADMINISTRATION Paragraph 1. The authority citation for part 301 is amended by adding a sectional authority for § 301.6721–1 to read as follows: Authority: 26 U.S.C. 7805 * * * * * * * * Section 301.6721–1 is also issued under 26 U.S.C. 6011(e). * * * * * Par. 2. Section 301.6011–2 is amended as follows: a. Paragraphs (b)(4) through (6) are added. b. Paragraphs (c)(1)(iii) and (iv) are removed. c. Paragraph (g)(2) is revised. The additions and revisions read as follows: § 301.6011–2 Required use of magnetic media. * * * * * (b) * * * (4) Aggregation of returns. For purposes of determining whether the number of returns a person is required to file meets the 250-return threshold under paragraph (c)(1)(i) of this section, all types of returns covered by paragraphs (b)(1) and (2) of this section required to be filed during the calendar year are aggregated. Corrected returns are not taken into account in determining whether the 250-return threshold is met. (5) Corrected returns. Any person required to file returns covered by paragraphs (b)(1) and (2) of this section on magnetic media for a calendar year must file corrected returns covered by paragraphs (b)(1) and (2) of this section for such calendar year on magnetic media. (6) Examples. The provisions of paragraphs (b)(4) and (5) of this section are illustrated by the following examples: Example 1. For the 2018 calendar year, Company W is required to file 200 Forms 1099–INT, “Interest Income,” and 200 Forms 1099–DIV, “Dividends and Distributions,” for a total of 400 returns. Because Company W is required to file 250 or more returns covered by paragraphs (b)(1) and (2) of this section for the calendar year, Company W must file all Forms 1099–INT and Forms 1099–DIV electronically. Example 2. During the 2018 calendar year, Company X has 200 employees in Puerto Rico and 75 employees in American Samoa, for a total of 275 returns. Because Company X is required to file 250 or more returns covered by paragraphs (b)(1) and (2) of this section for the calendar year, Company X must file Forms 499R–2/W–2PR, “Commonwealth of Puerto Rico Withholding Statement,” and Forms W–2AS, “American Samoa Wage and Tax Statement,” electronically. Example 3. For the 2018 calendar year, Company Y files 300 original Forms 1099–MISC, “Miscellaneous Income.” Later, Company Y files 70 corrected Forms 1099–MISC for the 2018 calendar year. Because Company Y is required to file 250 or more returns covered by paragraphs (b)(1) and (2) of this section for the calendar year, Company Y must file its original 300 Forms 1099–MISC, as well as its 70 corrected Forms 1099–MISC for the 2018 calendar year, electronically. * * * * * (g) * * * (2) Paragraphs (a)(1), (b)(1) and (2), (c)(1)(i), (c)(2), (d), (e), and (f) of this section are effective for information returns required to be filed after December 31, 1996. For information returns required to be filed after December 31, 1989, and before January 1, 1997, see section 6011(e) [26 USC 6011(e)]. Paragraph (b)(4) of this section is effective for information returns required to be filed after December 31, 2018. Paragraph (b)(5) of this section is effective for corrected information returns filed after December 31, 2018. * * * * * Par. 3. Section 301.6721–1 is amended as follows: a. By removing the fifth through seventh sentences in paragraph (a)(2)(ii). b. Adding paragraph (h). The revisions and addition reads as follows: § 301.6721–1 Failure to file correct information returns. * * * * * (h) Effective dates. Paragraph (a)(2)(ii) of this section is effective for information returns required to be filed after December 31, 2018. Kirsten Wielobob Deputy Commissioner for Services and Enforcement. Note (Filed by the Office of the Federal Register on May 30, 2018, 8:45 a.m. and published in the issue of the Federal Register for May 31, 2018, 83 F.R. 24948) Definition of Terms and Abbreviations Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the effect: Amplified describes a situation where no change is being made in a prior published 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 applied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare with modified, below). Clarified is used in those instances where the language in a prior ruling is being made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed. Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them. Modified is used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare with amplified and clarified, above). Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions. This term is most commonly used in a ruling that lists previously published rulings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revoked describes situations where the position in the previously published ruling is not correct and the correct position is being stated in a new ruling. Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same position published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single ruling a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new ruling does more than restate the substance of a prior ruling, a combination of terms is used. For example, modified and superseded describes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously published ruling is first modified and then, as modified, is superseded. Supplemented is used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original ruling has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the additions, and supersedes all prior rulings in the series. Suspended is used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The following abbreviations in current use and formerly used will appear in material 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. Numerical Finding List Numerical Finding List 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 2018–1 through 2018–25 Announcements: Article Issue Link Page 2018-01 2018-09 I.R.B. 2018-09 387 2018-02 2018-09 I.R.B. 2018-09 387 2018-03 2018-09 I.R.B. 2018-09 387 2018-04 2018-10 I.R.B. 2018-10 401 2018-05 2018-13 I.R.B. 2018-13 461 2018-07 2018-16 I.R.B. 2018-16 503 2018-08 2018-19 I.R.B. 2018-19 552 2018-09 2018-24 I.R.B. 2018-24 752 Notices: Article Issue Link Page 2018-01 2018-03 I.R.B. 2018-03 285 2018-02 2018-02 I.R.B. 2018-02 281 2018-03 2018-02 I.R.B. 2018-02 285 2018-05 2018-06 I.R.B. 2018-06 341 2018-06 2018-03 I.R.B. 2018-03 300 2018-07 2018-04 I.R.B. 2018-04 317 2018-08 2018-07 I.R.B. 2018-07 352 2018-10 2018-08 I.R.B. 2018-08 359 2018-11 2018-11 I.R.B. 2018-11 425 2018-12 2018-12 I.R.B. 2018-12 441 2018-13 2018-06 I.R.B. 2018-06 341 2018-14 2018-07 I.R.B. 2018-07 353 2018-15 2018-09 I.R.B. 2018-09 376 2018-16 2018-10 I.R.B. 2018-10 390 2018-17 2018-09 I.R.B. 2018-09 376 2018-18 2018-12 I.R.B. 2018-12 443 2018-19 2018-12 I.R.B. 2018-12 443 2018-20 2018-12 I.R.B. 2018-12 444 2018-21 2018-15 I.R.B. 2018-15 472 2018-22 2018-14 I.R.B. 2018-14 464 2018-23 2018-15 I.R.B. 2018-15 474 2018-24 2018-17 I.R.B. 2018-17 507 2018-25 2018-15 I.R.B. 2018-15 476 2018-26 2018-16 I.R.B. 2018-16 480 2018-27 2018-20 I.R.B. 2018-20 580 2018-28 2018-16 I.R.B. 2018-16 492 2018-29 2018-16 I.R.B. 2018-16 495 2018-30 2018-21 I.R.B. 2018-21 610 2018-31 2018-16 I.R.B. 2018-16 501 2018-32 2018-17 I.R.B. 2018-17 507 2018-33 2018-17 I.R.B. 2018-17 508 2018-34 2018-19 I.R.B. 2018-19 549 2018-35 2018-18 I.R.B. 2018-18 520 2018-36 2018-20 I.R.B. 2018-20 582 2018-37 2018-18 I.R.B. 2018-18 521 2018-38 2018-18 I.R.B. 2018-18 522 2018-39 2018-20 I.R.B. 2018-20 582 2018-40 2018-20 I.R.B. 2018-20 583 2018-41 2018-20 I.R.B. 2018-20 584 2018-42 2018-24 I.R.B. 2018-24 750 2018-43 2018-20 I.R.B. 2018-20 590 2018-44 2018-21 I.R.B. 2018-21 611 2018-45 2018-21 I.R.B. 2018-21 620 2018-46 2018-21 I.R.B. 2018-21 621 2018-47 2018-21 I.R.B. 2018-21 621 2018-49 2018-22 I.R.B. 2018-22 624 2018-50 2018-22 I.R.B. 2018-22 626 2018-51 2018-22 I.R.B. 2018-22 628 2018-52 2018-22 I.R.B. 2018-22 629 2018-53 2018-22 I.R.B. 2018-22 631 2018-54 2018-24 I.R.B. 2018-54 750 Proposed Regulations: Article Issue Link Page REG-119514-15 2018-04 I.R.B. 2018-04 325 REG-102951-16 2018-25 I.R.B. 2018-25 755 REG-129260-16 2018-14 I.R.B. 2018-14 470 REG-118067-17 2018-08 I.R.B. 2018-08 360 REG-132197-17 2018-10 I.R.B. 2018-10 404 REG-132197-17 2018-10 I.R.B. 2018-10 404 REG-132434-17 2018-16 I.R.B. 2018-16 503 Revenue Procedures: Article Issue Link Page 2018-1 2018-01 I.R.B. 2018-01 1 2018-2 2018-01 I.R.B. 2018-01 106 2018-3 2018-01 I.R.B. 2018-01 130 2018-4 2018-01 I.R.B. 2018-01 146 2018-5 2018-01 I.R.B. 2018-01 244 2018-7 2018-01 I.R.B. 2018-01 282 2018-8 2018-02 I.R.B. 2018-02 286 2018-9 2018-02 I.R.B. 2018-02 290 2018-10 2018-07 I.R.B. 2018-07 355 2018-11 2018-05 I.R.B. 2018-05 334 2018-12 2018-06 I.R.B. 2018-06 349 2018-13 2018-07 I.R.B. 2018-07 356 2018-14 2018-09 I.R.B. 2018-09 378 2018-15 2018-09 I.R.B. 2018-09 379 2018-16 2018-09 I.R.B. 2018-09 383 2018-17 2018-09 I.R.B. 2018-09 384 2018-18 2018-10 I.R.B. 2018-10 392 2018-19 2018-14 I.R.B. 2018-14 466 2018-20 2018-11 I.R.B. 2018-11 427 2018-21 2018-14 I.R.B. 2018-14 467 2018-22 2018-18 I.R.B. 2018-18 524 2018-23 2018-17 I.R.B. 2018-17 516 2018-24 2018-18 I.R.B. 2018-18 525 2018-25 2018-18 I.R.B. 2018-18 543 2018-26 2018-18 I.R.B. 2018-18 546 2018-27 2018-20 I.R.B. 2018-20 591 2018-28 2018-20 I.R.B. 2018-20 592 2018-29 2018-22 I.R.B. 2018-22 634 2018-30 2018-21 I.R.B. 2018-21 622 2018-31 2018-22 I.R.B. 2018-22 637 2018-32 2018-23 I.R.B. 2018-23 739 2018-33 2018-22 I.R.B. 2018-22 734 2018-34 2018-23 I.R.B. 2018-23 748 Revenue Rulings: Article Issue Link Page 2018-01 2018-02 I.R.B. 2018-02 275 2018-02 2018-02 I.R.B. 2018-02 277 2018-03 2018-02 I.R.B. 2018-02 278 2018-04 2018-04 I.R.B. 2018-04 304 2018-05 2018-06 I.R.B. 2018-06 339 2018-06 2018-10 I.R.B. 2018-10 388 2018-07 2018-13 I.R.B. 2018-13 445 2018-09 2018-14 I.R.B. 2018-14 462 2018-10 2018-16 I.R.B. 2018-16 477 2018-11 2018-18 I.R.B. 2018-18 518 2018-12 2018-20 I.R.B. 2018-20 575 2018-13 2018-20 I.R.B. 2018-20 576 2018-14 2018-23 I.R.B. 2018-23 736 2018-15 2018-23 I.R.B. 2018-23 736 2018-16 2018-23 I.R.B. 2018-23 737 2018-17 2018-25 I.R.B. 2018-25 753 Treasury Decisions: Article Issue Link Page 9829 2018-04 I.R.B. 2018-04 308 9830 2018-11 I.R.B. 2018-11 423 9831 2018-13 I.R.B. 2018-13 459 9832 2018-16 I.R.B. 2018-16 477 Effect of Current Actions on Previously Published Items Finding List of Current Actions on Previously Published Items 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 2018–1 through 2018–25 Notices: Old Article Action New Article Issue Link Page 2003-65 Modified by Notice 2018-30 2018-21 I.R.B. 2018-21 610 INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page (www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.