Internal Revenue Bulletin: 2019-06

February 4, 2019

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.


Announcement 2019–1 Announcement 2019–1

This Announcement is being issued to provide notification to all consumers of the Internal Revenue Bulletin, that there were no articles submitted for publication in IRB 2019–06, dated Monday, February 4, 2019.


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.


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 Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.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 IV. Items of General Interest

Announcement 2019–1

This Announcement is being issued to provide notification to all consumers of the Internal Revenue Bulletin, that there were no articles submitted for publication in IRB 2019–06, dated Monday, February 4, 2019.

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.


The following abbreviations in current use and formerly used will appear in material published in the Bulletin.






B.T.A.—Board of Tax Appeals.


C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.



Ct.D.—Court Decision.



DC—Dummy Corporation.


Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.




E.O.—Executive Order.


ERISA—Employee Retirement Income Security Act.



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.


GP—General Partner.


IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.


LP—Limited Partner.





P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.



PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.


S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.



T.I.R.—Technical Information Release.




U.S.C.—United States Code.




Numerical Finding List

Numerical Finding List

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin 2018–52, dated December 27, 2018.

Bulletin 2019–6


Article Issue Link Page
2019-1 2019-06 I.R.B. 2019-06 566



Article Issue Link Page
2019-01 2019-02 I.R.B. 2019-02 275
2019-02 2019-02 I.R.B. 2019-02 281
2019-03 2019-03 I.R.B. 2019-03 350
2019-04 2019-02 I.R.B. 2019-02 282
2019-05 2019-02 I.R.B. 2019-02 283
2019-06 2019-03 I.R.B. 2019-03 353
2019-08 2019-03 I.R.B. 2019-03 354
2019-09 2019-04 I.R.B. 2019-04 403
2019-11 2019-05 I.R.B. 2019-05 430


Proposed Regulations:

Article Issue Link Page
REG-104259-18 2019-02 I.R.B. 2019-02 300
REG-104352-18 2019-03 I.R.B. 2019-03 357
REG-106089-18 2019-05 I.R.B. 2019-05 431


Revenue Procedures:

Article Issue Link Page
2019-1 2019-01 I.R.B. 2019-01 1
2019-2 2019-01 I.R.B. 2019-01 106
2019-3 2019-01 I.R.B. 2019-01 130
2019-4 2019-01 I.R.B. 2019-01 146
2019-5 2019-01 I.R.B. 2019-01 230
2019-6 2019-02 I.R.B. 2019-02 284
2019-7 2019-01 I.R.B. 2019-01 268
2019-8 2019-03 I.R.B. 2019-03 347
2019-9 2019-02 I.R.B. 2019-02 293
2019-10 2019-02 I.R.B. 2019-02 296
2019-12 2019-04 I.R.B. 2019-04 401


Revenue Rulings:

Article Issue Link Page
2019-03 2019-02 I.R.B. 2019-02 272


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 2018–27 through 2018–52 is in Internal Revenue Bulletin 2018–52, dated December 27, 2018.

Bulletin 2019–6


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Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.