HIGHLIGHTS OF THIS ISSUE ADMINISTRATIVE The IRS Mission Introduction Part I Announcement 2021-4 Definition of Terms Abbreviations Numerical Finding List1 Numerical Finding List Finding List of Current Actions on Previously Published Items1 How to get the Internal Revenue Bulletin INTERNAL REVENUE BULLETIN We Welcome Comments About the Internal Revenue Bulletin Internal Revenue Bulletin: 2021-09 March 1, 2021 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 Announcement 2021-4, page 895. 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 2021-9, dated Monday, March 1, 2021. 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 Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.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 Announcement 2021-4 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 2021-9, dated Monday, March 1, 2021. 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 List1 Numerical Finding List Bulletin 2021–9 Announcements: Article Issue Link Page 2021-01 2021-04 I.R.B. 2021-04 506 2021-02 2021-08 I.R.B. 2021-08 892 2021-03 2021-08 I.R.B. 2021-08 892 2021-04 2021-09 I.R.B. 2021-09 895 Notices: Article Issue Link Page 2021-01 2021-02 I.R.B. 2021-02 315 2021-03 2021-02 I.R.B. 2021-02 316 2021-04 2021-02 I.R.B. 2021-02 319 2021-02 2021-03 I.R.B. 2021-03 478 2021-05 2021-03 I.R.B. 2021-03 479 2021-07 2021-03 I.R.B. 2021-03 482 2021-09 2021-05 I.R.B. 2021-05 678 2021-06 2021-06 I.R.B. 2021-06 822 2021-08 2021-06 I.R.B. 2021-06 823 2021-11 2021-06 I.R.B. 2021-06 827 2021-12 2021-06 I.R.B. 2021-06 828 2021-13 2021-06 I.R.B. 2021-06 832 2021-10 2021-07 I.R.B. 2021-07 888 Proposed Regulations: Article Issue Link Page REG-130081-19 2021-02 I.R.B. 2021-02 321 REG-114615-16 2021-03 I.R.B. 2021-03 489 REG-111950-20 2021-05 I.R.B. 2021-05 683 REG-115057-20 2021-05 I.R.B. 2021-05 714 Revenue Procedures: Article Issue Link Page 2021-01 2020-01 I.R.B. 2020-01 1 2021-02 2020-01 I.R.B. 2020-01 116 2021-03 2020-01 I.R.B. 2020-01 140 2021-04 2020-01 I.R.B. 2020-01 157 2021-05 2020-01 I.R.B. 2020-01 250 2021-07 2020-01 I.R.B. 2020-01 290 2021-09 2020-03 I.R.B. 2020-03 485 2021-08 2020-04 I.R.B. 2020-04 502 2021-10 2020-04 I.R.B. 2020-04 503 2021-12 2020-05 I.R.B. 2020-05 681 2021-11 2020-06 I.R.B. 2020-06 833 2021-15 2020-08 I.R.B. 2020-08 891 Revenue Rulings: Article Issue Link Page 2021-01 2021-02 I.R.B. 2021-02 294 2021-02 2021-04 I.R.B. 2021-04 495 2021-03 2021-05 I.R.B. 2021-05 674 2021-04 2021-06 I.R.B. 2021-06 724 Treasury Decisions: Article Issue Link Page 9925 2021-02 I.R.B. 2021-02 296 9940 2021-02 I.R.B. 2021-02 311 9932 2021-03 I.R.B. 2021-03 345 Treasury Decisions:—Continued Article Issue Link Page 9939 2021-03 I.R.B. 2021-03 376 9941 2021-03 I.R.B. 2021-03 396 9942 2021-03 I.R.B. 2021-03 450 9937 2021-04 I.R.B. 2021-04 495 9936 2021-05 I.R.B. 2021-05 508 9943 2021-05 I.R.B. 2021-05 577 9945 2021-05 I.R.B. 2021-05 627 9946 2021-06 I.R.B. 2021-06 726 9947 2021-06 I.R.B. 2021-06 748 9948 2021-06 I.R.B. 2021-06 801 9938 2021-07 I.R.B. 2021-07 838 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27 2020. Finding List of Current Actions on Previously Published Items1 Bulletin 2021–9 How to get the Internal Revenue Bulletin 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.