Highlights of This Issue Employee Plans Income Tax Preface The IRS Mission Introduction Part III. Administrative, Procedural, and Miscellaneous Notice 201824 Notice 201832 Notice 201833 Rev. Proc. 201823 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: 2018-17 April 23, 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. Employee Plans Notice 2018–24 Notice 2018–24 This notice requests comments on the potential expansion of the scope of the determination letter program for individually designed plans during the 2019 calendar year, beyond provision of determination letters for initial qualification and qualification upon plan termination. Income Tax Notice 2018–32 Notice 2018–32 This notice publishes the reference price under § 45K(d)(2)(C) of the Internal Revenue Code for calendar year 2017. The reference price applies in determining the amount of the enhanced oil recovery credit under § 43, the marginal well production credit under § 45I, and the percentage depletion in case of oil produced from marginal properties under § 613A. Notice 2018–33 Notice 2018–33 Attached is Notice 2018–33, which provides for adjustments to the limitation on housing expenses for purposes of section 911 of the Internal Revenue Code. These adjustments are made on the basis of geographic differences in housing costs relative to housing costs in the United States. Further, if the limitation on housing expenses is higher for taxable year 2018 than the adjusted limitations on housing expenses provided in Notice 2017–21, qualified taxpayers may apply the adjusted limitations for taxable year 2018 to their 2017 taxable year. Rev. Proc. 2018–23 Rev. Proc. 2018–23 Attached is Revenue Procedure 2018–23, which provides a waiver for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2018–23 adds Turkey to the list of waiver countries for tax year 2016 for which the minimum time requirements are waived. No country is added to the list of waiver countries for tax year 2017. Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. However, if their tax home is in a foreign country and they meet either the bona fide residence test or the physical presence test, they can choose to exclude from their income a limited amount of their foreign earned income ($101,300 for 2016). Both the bona fide residence test and the physical presence test contain minimum time requirements. 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 III. Administrative, Procedural, and Miscellaneous Notice 2018–24 REQUEST FOR COMMENTS ON SCOPE OF DETERMINATION LETTER PROGRAM FOR INDIVIDUALLY DESIGNED PLANS DURING CALENDAR YEAR 2019 PURPOSE This notice requests comments on the potential expansion of the scope of the determination letter program for individually designed plans during the 2019 calendar year, beyond provision of determination letters for initial qualification and qualification upon plan termination. In reviewing comments submitted in response to this notice, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) will consider the factors regarding the scope of the determination letter program set forth in section 4.03(3) of Revenue Procedure 2016–37, 2016–29 I.R.B. 136. The Treasury Department and the IRS will issue guidance if they identify any additional types of plans for which plan sponsors may request determination letters during the 2019 calendar year. BACKGROUND Revenue Procedure 2016–37 sets forth procedures for issuing determination letters and describes an extension of the remedial amendment period for individually designed plans. Effective January 1, 2017, the sponsor of an individually designed plan may submit a determination letter application only for initial plan qualification, for qualification upon plan termination, and in certain other limited circumstances identified in subsequent published guidance. Section 4.03(3) of Rev. Proc. 2016–37 provides that the Treasury Department and the IRS will consider each year whether to accept determination letter applications for individually designed plans in specified circumstances other than for initial qualification and qualification upon plan termination. REQUEST FOR COMMENTS Comments are requested on specific types of plans for which the Treasury Department and the IRS should consider accepting determination letter applications during calendar year 2019 in circumstances other than for initial qualification and qualification upon plan termination. As provided in section 4.03(3) of Rev. Proc. 2016–37, circumstances for consideration include, for example, significant law changes, new approaches to plan design, and the inability of certain types of plans to convert to pre-approved plan documents. Comments that suggest expanding the scope of the program for a particular type of plan should not merely state the type of plan, but should also specify the issues applicable to that type of plan that would justify review of that particular plan type under the determination letter program. Such issues may include specific plan features and special plan designs applicable to that type of plan, or unresolved questions of qualification in form with respect to that type of plan. Comments may be submitted in writing on or before June 4, 2018. Comments should be mailed to Internal Revenue Service, CC:PA:LPD:PR (Notice 2018–24), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044, or sent electronically to email@example.com. Please include “Notice 2018–24” in the subject line of any electronic communications. Alternatively, comments 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 (Notice 2018–24), Courier’s Desk, Internal Revenue Service, 1111 Constitution Ave., NW, Washington, D.C. 20224. All comments will be available for public inspection and copying. DRAFTING INFORMATION The principal author of this notice is Angelique Carrington of the Office of Associate Chief Counsel (Tax Exempt and Government Entities). For further information regarding this notice, contact Ms. Carrington at (202) 317-4148 (not a toll-free number). Notice 2018–32 2017 Section 45K(d)(2)(C) Reference Price SECTION 1. PURPOSE This notice publishes the reference price under § 45K(d)(2)(C) of the Internal Revenue Code for calendar year 2017. The credit period for the nonconventional source production credit under § 45K ended on December 31, 2013, for facilities producing coke or coke gas (other than from petroleum based products). However, the reference price continues to apply in determining the amount of the enhanced oil recovery credit under § 43, the marginal well production credit for qualified crude oil production under § 45I, and the percentage depletion in case of oil and natural gas produced from marginal properties under § 613A. SECTION 2. BACKGROUND Section 45K(d)(2)(C) provides that the term “reference price” means, with respect to a calendar year, the Secretary’s estimate of the annual average wellhead price per barrel for all domestic crude oil the price of which is not subject to regulation by the United States. Section 43(a) provides that, for purposes of § 38, the enhanced oil recovery credit for any taxable year is an amount equal to 15 percent of the taxpayer’s qualified enhanced oil recovery costs for such taxable year. Section 43(b)(1) provides that the amount of enhanced oil recovery credit for any taxable year shall be reduced by an amount which bears the same ratio to the amount of such credit (determined without regard to this paragraph) as - (A) the amount by which the reference price for the calendar year preceding the calendar year in which the taxable year begins exceeds $28, bears to (B) $6. Section 43(b)(2) provides that the term “reference price” means, with respect to any calendar year, the reference price determined for such calendar year under § 45K(d)(2)(C). Section 45I(a) provides that, for purposes of § 38, the marginal well production credit for any taxable year is an amount equal to the product of the credit amount and the qualified crude oil production and the qualified natural gas production which is attributable to the taxpayer. Section 45I(b)(1) provides that for crude oil, the amount of the marginal well production credit is $3 per barrel of qualified crude oil production. Section 45I(b)(2) provides that the $3 amount under § 45I(b)(1) shall each be reduced (but not below zero) by an amount which bears the same ratio to such amount (determined without regard to this paragraph) as – (i) the excess (if any) of the applicable reference price over $15, bears to (ii) $3. The applicable reference price for a taxable year is the reference price of the calendar year preceding the calendar year in which the taxable year begins. Section 45I(c) provides that the term reference price means, with respect to any calendar year – (i) in the case of qualified crude oil production, the reference price determined under § 45K(d)(2)(C). Section 613A(c)(6)(A) provides, in general, the allowance for depletion under § 611 shall be computed in accordance with § 613 with respect to - (i) so much of the taxpayer’s average daily marginal production of domestic crude oil as does not exceed the taxpayer’s depletable oil quantity (determined without regard to paragraph (3)(A)(ii)), and (ii) so much of the taxpayer’s average daily marginal production of domestic natural gas as does not exceed the taxpayer’s depletable natural gas quantity (determined without regard to paragraph (3)(A)(ii)), and the applicable percentage shall be deemed to be specified in subsection (b) of § 613 for purposes of subsection (a) of that section. Section 613A(c)(6)(C) provides that the term “applicable percentage” means the percentage (not greater than 25 percent) equal to the sum of - (i) 15 percent, plus (ii) 1 percentage point for each whole dollar by which $20 exceeds the reference price for crude oil for the calendar year preceding the calendar year in which the taxable year begins. For purposes of this paragraph, the term “reference price” means, with respect to any calendar year, the reference price determined for such calendar year under § 45K(d)(2)(C). SECTION 3. REFERENCE PRICE The reference price under § 45K(d)(2)(C) for calendar year 2017 is $48.05. SECTION 4. DRAFTING INFORMATION The principal author of this notice is Martha M. Garcia of the Office of Associate Chief Counsel (Passthroughs & Special Industries). For further information regarding this notice, contact Ms. Garcia on (202) 317-6853 (not a toll-free number). Notice 2018–33 Determination of Housing Cost Amounts Eligible for Exclusion or Deduction for 2018 SECTION 1. PURPOSE This notice provides adjustments to the limitation on housing expenses for purposes of section 911 of the Internal Revenue Code for specific locations for 2018. These adjustments are made on the basis of geographic differences in housing costs relative to housing costs in the United States. SECTION 2. BACKGROUND Section 911(a) allows a qualified individual to elect to exclude from gross income the foreign earned income and housing cost amount of such individual. The term “housing cost amount” is generally the total of the housing expenses for the taxable year minus a base housing amount. See section 911(c)(1). For this purpose, the housing expenses taken into account are limited to an amount that is tied to the maximum foreign earned income exclusion. Specifically, the limit on such housing expenses equals 30 percent (adjusted as may be provided under the Secretary’s authority under section 911(c)(2)(B)) of the maximum exclusion amount (computed on a daily basis), multiplied by the number of days in the applicable period that fall within the taxable year. See section 911(c)(2)(A). Thus, under this general limitation, a qualified individual whose entire taxable year is within the applicable period is limited to maximum housing expenses of $31,230 ($104,100 x .30) for 2018. Similarly, the computation of the base housing amount is also tied to the maximum foreign earned income exclusion. Specifically, the base housing amount is 16% of the maximum exclusion amount (computed on a daily basis), multiplied by the number of days in the applicable period that fall within the taxable year. See sections 911(c)(1)(B) and 911(d)(1). Assuming that the entire taxable year of a qualified individual is within the applicable period, the base housing amount for 2018 is $16,656 ($104,100 x .16). Section 911(c)(2)(B) authorizes the Secretary to issue regulations or other guidance to adjust the percentage under section 911(c)(2)(A)(i) (which determines the limit on housing expenses) based on geographic differences in housing costs relative to housing costs in the United States. Pursuant to this authority, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) have published annual notices concerning the limitation on the section 911 housing cost amounts since the 2006 taxable year. For more background on the foreign housing exclusion, see https://www.irs.gov/individuals/international-taxpayers/foreign-housing-exclusion-or deduction. SECTION 3. TABLE OF ADJUSTED LIMITATIONS FOR 2018 The following table provides adjusted limitations on housing expenses (in lieu of the otherwise applicable limitation of $31,230) for 2018. Country Location Limitation on Housing Expenses (full year) Limitation on Housing Expenses (daily) Angola Luanda 84,000 230.14 Argentina Buenos Aires 56,500 154.79 Australia Melbourne 32,100 87.95 Australia Perth 34,300 93.97 Australia Sydney 64,700 177.26 Austria Vienna 35,400 96.99 Bahamas, The Nassau 49,700 136.16 Bahrain Bahrain 48,300 132.33 Barbados Barbados 37,700 103.29 Belgium Antwerp 31,300 85.75 Belgium Brussels 42,900 117.53 Belgium Gosselies 38,200 104.66 Belgium Hoogbuul 31,300 85.75 Belgium Mons 38,200 104.66 Belgium SHAPE/Chievres 38,200 104.66 Bermuda Bermuda 90,000 246.58 Brazil Rio de Janeiro 35,100 96.16 Brazil Sao Paulo 56,600 155.07 Canada Calgary 39,400 107.95 Canada Montreal 52,500 143.84 Canada Ottawa 44,600 122.19 Canada Quebec 35,700 97.81 Canada Toronto 46,700 127.95 Canada Vancouver 44,700 122.47 Canada Victoria 40,500 110.96 Cayman Islands Grand Cayman 48,000 131.51 Chile Santiago 40,900 112.05 China Beijing 71,200 195.07 China Hong Kong 114,300 313.15 China Shanghai 57,001 156.17 Colombia Bogota 58,700 160.82 Colombia All cities other than Bogota 49,400 135.34 Costa Rica San Jose 32,000 87.67 Democratic Republic of the Congo Kinshasa 42,000 115.07 Denmark Copenhagen 43,704 119.74 Dominican Republic Santo Domingo 45,500 124.66 Ecuador Quito 38,200 104.66 El Salvador San Salvador 32,000 87.67 Estonia Tallinn 46,600 127.67 France Garches 73,600 201.64 France Lyon 40,700 111.51 France Marseille 39,700 108.77 France Montpellier 32,800 89.86 France Paris 73,600 201.64 France Sevres 73,600 201.64 France Suresnes 73,600 201.64 France Versailles 73,600 201.64 France All cities other than Garches, Le Havre, Lyon, Marseille, Montpellier, Paris, Sevres, Suresnes and Versailles 31,900 87.40 Germany Babenhausen 36,100 98.90 Germany Baumholder 35,900 98.36 Germany Berlin 44,100 120.82 Germany Birkenfeld 35,900 98.36 Germany Boeblingen 43,900 120.27 Germany Bonn 42,000 115.07 Germany Cologne 56,200 153.97 Germany Darmstadt 36,100 98.90 Germany Frankfurt am Main 37,700 103.29 Germany Garmisch-Partenkirchen 33,900 92.88 Germany Gelnhausen 45,500 124.66 Germany Giessen 36,000 98.63 Germany Grafenwoehr 36,400 99.73 Germany Hanau 45,500 124.66 Germany Heidelberg 33,700 92.33 Germany Idar-Oberstein 35,900 98.36 Germany Ingolstadt 51,500 141.10 Germany Kaiserslautern, Landkreis 44,200 121.10 Germany Karlsruhe 34,800 95.34 Germany Koblenz 35,400 96.99 Germany Leimen 33,700 92.33 Germany Ludwigsburg 43,900 120.27 Germany Mainz 48,100 131.78 Germany Mannheim 33,700 92.33 Germany Munich 51,500 141.10 Germany Nellingen 43,900 120.27 Germany Neubruecke 35,900 98.36 Germany Ober Ramstadt 36,100 98.90 Germany Oberammergau 33,900 92.88 Germany Pfullendorf 35,400 96.99 Germany Pirmasens 44,200 121.10 Germany Rheinau 33,700 92.33 Germany Schwetzingen 33,700 92.33 Germany Seckenheim 33,700 92.33 Germany Sembach 44,200 121.10 Germany Stuttgart 43,900 120.27 Germany Vilseck 36,400 99.73 Germany Wahn 42,000 115.07 Germany Wiesbaden 48,100 131.78 Germany Zweibrueken 44,200 121.10 Germany All cities other than Augsburg, Babenhausen, Bad Aibling, Bad Kreuznach, Bad Nauheim, Baumholder, Berchtesgaden, Berlin, Birkenfeld, Boeblingen, Bonn, Bremen, Bremerhaven, Butzbach, Cologne, Darmstadt, Delmenhorst, Duesseldorf, Erlangen, Flensburg, Frankfurt am Main, Friedberg, Fuerth, Garlstedt, Garmisch-Partenkirchen, Geilenkirchen, Gelnhausen, Germersheim, Giebelstadt, Grafenwoehr, Grefrath, Greven, Gruenstadt, Hamburg, Hanau, Handorf, Hannover, Heidelberg, Heilbronn, Herongen, Idar-Oberstein, Ingolstadt, Kaiserslautern, Landkreis, Kalkar, Karlsruhe, Kerpen, Kitzingen, Koblenz, Leimen, Leipzig, Ludwigsburg, Mainz, Mannheim, Mayen, Moenchen-Gladbach, Muenster, Munich, Nellingen, Neubruecke, Noervenich, Nuernberg, Ober Ramstadt, Oberammergau, Osterholz-Scharmbeck, Pirmasens, Rheinau, Rheinberg, Schwabach, Schwetzingen, Seckenheim, Sembach, Stuttgart, Twisteden, Vilseck, Wahn, Wertheim, Wiesbaden, Worms, Wuerzburg, Zirndorf and Zweibrueken 35,400 96.99 Ghana Accra 36,000 98.63 Greece Athens 36,100 98.90 Greece Elefsis 36,100 98.90 Greece Ellinikon 36,100 98.90 Greece Mt. Parnis 36,100 98.90 Greece Mt. Pateras 36,100 98.90 Greece Nea Makri 36,100 98.90 Greece Piraeus 36,100 98.90 Greece Tanagra 36,100 98.90 Guatemala Guatemala City 41,800 114.52 Guinea Conakry 51,300 140.55 Guyana Georgetown 35,000 95.89 Holy See, The Holy See, The 49,000 134.25 Hungary Budapest 32,500 89.04 India Mumbai 67,920 186.08 India New Delhi 56,124 153.76 Indonesia Jakarta 37,776 103.50 Ireland Beer Sheva 56,200 153.97 Ireland Dublin 42,600 116.71 Ireland Shannon Area 33,700 92.33 Israel Tel Aviv 50,800 139.18 Italy Genoa 41,800 114.52 Italy La Spezia 40,400 110.68 Italy Milan 73,200 200.55 Italy Naples 49,100 134.52 Italy Parma 37,200 101.92 Italy Pordenone-Aviano 38,100 104.38 Italy Rome 49,000 134.25 Italy Turin 36,600 100.27 Italy Vicenza 39,900 109.32 Jamaica Kingston 41,200 112.88 Japan Atsugi 39,700 108.77 Japan Camp Zama 39,700 108.77 Japan Chiba-Ken 39,700 108.77 Japan Fussa 39,700 108.77 Japan Gifu 74,300 203.56 Japan Haneda 39,700 108.77 Japan Iwakuni 31,400 86.03 Japan Kanagawa-Ken 39,700 108.77 Japan Komaki 74,300 203.56 Japan Machidi-Shi 39,700 108.77 Japan Misawa 31,700 86.85 Japan Nagoya 74,300 203.56 Japan Okinawa Prefecture 56,000 153.42 Japan Osaka-Kobe 90,664 248.39 Japan Sagamihara 39,700 108.77 Japan Saitama-Ken 39,700 108.77 Japan Sasebo 32,200 88.22 Japan Tachikawa 39,700 108.77 Japan Tokyo 89,000 243.84 Japan Tokyo-to 39,700 108.77 Japan Yokohama 47,400 129.86 Japan Yokosuka 46,100 126.30 Japan Yokota 37,400 102.47 Jerusalem Jerusalem 49,000 134.25 Jerusalem West Bank 49,000 134.25 Kazakhstan Almaty 48,000 131.51 Korea Camp Carroll 31,600 86.58 Korea Camp Colbern 54,200 148.49 Korea Camp Market 59,300 162.47 Korea Camp Mercer 54,200 148.49 Korea K-16 59,300 162.47 Korea Kimhae 31,700 86.85 Korea Kimpo Airfield 59,300 162.47 Korea Munsan 33,900 92.88 Korea Osan AB 39,200 107.40 Korea Pohang 31,900 87.40 Korea Pusan 31,700 86.85 Korea Pyongtaek 42,200 115.62 Korea Seoul 59,300 162.47 Korea Suwon 59,300 162.47 Korea Taegu 36,000 98.63 Korea Tongduchon 35,200 96.44 Korea Uijongbu 32,700 89.59 Korea Waegwan 31,600 86.58 Korea All cities other than Ammo Depot #9, Camp Carroll, Camp Colbern, Camp Market, Camp Mercer, Changwon, Chinhae, Chunchon, K-16, Kimhae, Kimpo Airfield, Kunsun, Kwangju, Munsan, Osan AB, Pusan, Pyongtaek, Seoul, Suwon, Taegu, Tongduchon, Uijongbu, and Waegwan 31,900 87.40 Kuwait Kuwait City 64,400 176.44 Kuwait All cities other than Kuwait City 57,700 158.08 Luxembourg Luxembourg 40,100 109.86 Macedonia Skopje 35,400 96.99 Malaysia Kuala Lumpur 46,200 126.58 Malaysia All cities other than Kuala Lumpur 33,700 92.33 Malta Malta 55,100 150.96 Mexico Merida 37,900 103.84 Mexico Mexico City 47,900 131.23 Mexico Monterrey 33,200 90.96 Mexico All cities other than Ciudad Juarez, Cuernavaca, Guadalajara, Hermosillo, Matamoros, Mazatlan, Merida, Metapa, Mexico City, Monterrey, Nogales, Nuevo Laredo, Reynosa, Tapachula, Tijuana, Tuxtla Gutierrez, and Veracruz 39,400 107.95 Mozambique Maputo 39,500 108.22 Namibia Windhoek 32,100 87.95 Netherlands Amsterdam 52,900 144.93 Netherlands Aruba 36,000 98.63 Netherlands Brunssum 35,900 98.36 Netherlands Eygelshoven 35,900 98.36 Netherlands Hague, The 58,400 160.00 Netherlands Heerlen 35,900 98.36 Netherlands Hoensbroek 35,900 98.36 Netherlands Hulsberg 35,900 98.36 Netherlands Kerkrade 35,900 98.36 Netherlands Landgraaf 35,900 98.36 Netherlands Maastricht 35,900 98.36 Netherlands Papendrecht 35,200 96.44 Netherlands Rotterdam 35,200 96.44 Netherlands Schaesburg 35,900 98.36 Netherlands Schinnen 35,900 98.36 Netherlands Schiphol 52,900 144.93 Netherlands Ypenburg 58,400 160.00 Netherlands All cities other than Amsterdam, Aruba, Brunssum, Coevorden, Eygelshoven, The Hague, Heerlen, Hoensbroek, Hulsberg, Kerkrade, Landgraaf, Maastricht, Margraten, Papendrecht, Rotterdam, Schaesburg, Schinnen, Schiphol, and Ypenburg 34,700 95.07 Netherlands Antilles Curacao 45,800 125.48 New Zealand Auckland 35,700 97.81 New Zealand Christchurch 32,100 87.95 New Zealand Wellington 33,800 92.60 Nicaragua Managua 31,800 87.12 Nigeria Abuja 36,000 98.63 Norway Oslo 36,100 98.90 Oman Muscat 41,300 113.15 Panama Panama City 39,500 108.22 Peru Lima 39,100 107.12 Philippines Cavite 33,500 91.78 Philippines Manila 37,380 102.41 Portugal Alverca 44,800 122.74 Portugal Lisbon 44,800 122.74 Qatar Al Udeid (in All Cities) 32,400 88.77 Qatar Doha 45,888 125.72 Qatar All cities other than Doha 32,400 88.77 Romania Bucharest 41,200 112.88 Russia Moscow 108,000 295.89 Russia Saint Petersburg 60,000 164.38 Russia Sakhalin Island 77,500 212.33 Russia Vladivostok 77,500 212.33 Russia Yekaterinburg 47,400 129.86 Rwanda Kigali 31,500 86.30 Saudi Arabia Jeddah 30,667 84.02 Saudi Arabia Riyadh 40,000 109.59 Singapore Singapore 80,500 220.55 Slovenia Ljubljana 51,400 140.82 South Africa Pretoria 39,300 107.67 Spain Barcelona 40,600 111.23 Spain Madrid 59,700 163.56 Spain Rota 36,500 100.00 Spain Valencia 34,300 93.97 Suriname Paramaribo 33,000 90.41 Switzerland Bern 65,600 179.73 Switzerland Geneva 93,300 255.62 Switzerland Zurich 39,219 107.45 Switzerland All cities other than Bern, Geneva and Zurich 32,900 90.14 Taiwan Taipei 46,188 126.54 Tanzania Dar Es Salaam 44,000 120.55 Thailand Bangkok 59,000 161.64 Trinidad and Tobago Port of Spain 54,500 149.32 Turkey Izmir-Cigli 31,600 86.58 Turkey Yamanlar 31,600 86.58 Ukraine Kiev 72,000 197.26 United Arab Emirates Abu Dhabi 49,687 136.13 United Arab Emirates Dubai 57,174 156.64 United Kingdom Basingstoke 41,099 112.60 United Kingdom Bath 41,000 112.33 United Kingdom Bracknell 62,100 170.14 United Kingdom Bristol 33,100 90.68 United Kingdom Brookwood 37,200 101.92 United Kingdom Cambridge 36,100 98.90 United Kingdom Caversham 73,800 202.19 United Kingdom Cheltenham 43,900 120.27 United Kingdom Croughton 38,000 104.11 United Kingdom Fairford 35,900 98.36 United Kingdom Farnborough 54,700 149.86 United Kingdom Felixstowe 34,800 95.34 United Kingdom Gibraltar 44,616 122.24 United Kingdom Harrogate 39,200 107.40 United Kingdom High Wycombe 62,100 170.14 United Kingdom Huntingdon 37,200 101.92 United Kingdom Kemble 35,900 98.36 United Kingdom Lakenheath 47,900 131.23 United Kingdom Liverpool 32,600 89.32 United Kingdom London 72,600 198.90 United Kingdom Loudwater 57,200 156.71 United Kingdom Menwith Hill 39,200 107.40 United Kingdom Mildenhall 47,900 131.23 United Kingdom Oxfordshire 36,400 99.73 United Kingdom Plymouth 36,400 99.73 United Kingdom Portsmouth 36,400 99.73 United Kingdom Reading 62,100 170.14 United Kingdom Rochester 37,400 102.47 United Kingdom Samlesbury 37,200 101.92 United Kingdom Southampton 44,200 121.10 United Kingdom Surrey 48,402 132.61 United Kingdom Waterbeach 37,300 102.19 United Kingdom Wiltshire 34,700 95.07 United Kingdom All cities other than Basingstoke, Bath, Belfast, Birmingham, Bracknell, Bristol, Brookwood, Brough, Cambridge, Caversham, Chelmsford, Cheltenham, Chicksands, Croughton, Dunstable, Edinburgh, Edzell, Fairford, Farnborough, Felixstowe, Ft. Halstead, Gibraltar, Glenrothes, Greenham Common, Harrogate, High Wycombe, Huntingdon, Hythe, Kemble, Lakenheath, Liverpool, London, Loudwater, Menwith Hill, Mildenhall, Nottingham, Oxfordshire, Plymouth, Portsmouth, Reading, Rochester, Samlesbury, Southampton, Surrey, Waterbeach, Welford, West Byfleet, and Wiltshire 37,200 101.92 Venezuela Caracas 57,000 156.16 Vietnam Hanoi 46,800 128.22 Vietnam Ho Chi Minh City 42,000 115.07 SECTION 4. OPTION TO APPLY 2018 ADJUSTED LIMITATIONS TO 2017 TAXABLE YEAR For some locations, the limitation on housing expenses provided in Section 3 of this notice may be higher than the limitation on housing expenses provided in the “Table of Adjusted Limitations for 2017” in Notice 2017–21. A qualified individual incurring housing expenses in such a location during 2017 may apply the adjusted limitation on housing expenses provided in Section 3 of this notice for 2017 in lieu of the amounts provided in the “Table of Adjusted Limitations for 2017” in Notice 2017–21 (and as set forth in the Instructions to Form 2555, Foreign Earned Income, for 2017). The Treasury Department and the IRS anticipate that future annual notices providing adjustments to housing expense limitations will make a similar option available to qualified individuals that incur housing expenses in the immediately preceding year. For example, when adjusted housing expense limitations for 2019 are issued, it is expected that taxpayers will be permitted to apply those adjusted limitations to the 2018 taxable year. SECTION 5. Filing Prior Year or Amended Tax Returns Notice 2011–8, 2011–8 I.R.B. 503; Notice 2012–19, 2012–10 I.R.B. 440; Notice 2013–31, 2013–21 I.R.B. 1099; Notice 2014–29, 2014–18 I.R.B. 991; Notice 2015–33, 2015–18 I.R.B. 934; Notice 2016–21, 2016–12 I.R.B. 465; and Notice 2017–21, 2017–13 I.R.B. 1026 are relisted to assist those individuals who are filing prior year or amended tax returns. SECTION 6. EFFECT ON OTHER DOCUMENTS This notice supersedes Notice 2006–87, 2006–43 I.R.B. 766; Notice 2007–25, 2007–12 I.R.B. 760; Notice 2007–77, 2007–40 I.R.B. 735; Notice 2008–107, 2008–50 I.R.B. 1265; Notice 2010–27, 2010–15 I.R.B. 531; Notice 2011–8, 2011–8 I.R.B. 503; Notice 2012–19, 2012–10 I.R.B. 440; Notice 2013–31, 2013–21 I.R.B. 1099; Notice 2014–29, 2014–18 I.R.B. 991; Notice 2015–33, 2015–18 I.R.B. 934; Notice 2016–21, 2016–12 I.R.B. 465; and Notice 2017–21, 2017–13 I.R.B. 1026. SECTION 7. EFFECTIVE DATE This notice is effective for taxable years beginning on or after January 1, 2018. However, as provided in Section 4, a taxpayer may apply the 2018 adjusted housing limitations contained in Section 3 of this notice to his or her taxable year beginning in 2017. SECTION 8. DRAFTING INFORMATION The principal author of this notice is Kate Y. Hwa of the Office of Associate Chief Counsel (International). For further information regarding this notice contact Kate Y. Hwa on (202) 317-6934 (not a toll-free number). Rev. Proc. 2018–23 SECTION 1. PURPOSE .01 This revenue procedure provides information to any individual who failed to meet the eligibility requirements of section 911(d)(1) of the Internal Revenue Code because adverse conditions in a foreign country precluded the individual from meeting those requirements. .02 The Internal Revenue Service previously has listed countries for which the eligibility requirements of section 911(d)(1) of the Code are waived under section 911(d)(4) because of adverse conditions in those countries. See Rev. Proc. 2017–26, 2017–13, I.R.B. 1036. SECTION 2. BACKGROUND .01 Sections 911(a) of the Code allows a “qualified individual,” as defined in section 911(d)(1), to exclude from gross income the individual’s foreign earned income and the housing cost amount. .02 Section 911(d)(1) of the Code defines the term “qualified individual” as an individual whose tax home is in a foreign country and who is (A) a citizen of the United States and establishes to the satisfaction of the Secretary of the Treasury that the individual has been a bona fide resident of a foreign country or countries for an uninterrupted period that includes an entire taxable year, or (B) a citizen or resident of the United States who, during any period of 12 consecutive months, is present in a foreign country or countries during at least 330 full days. .03 Section 911(d)(4) of the Code provides an exception to the eligibility requirements of section 911(d)(1). An individual will be treated as a qualified individual with respect to a period in which the individual was a bona fide resident of, or was present in, a foreign country if the individual left the country during a period for which the Secretary of the Treasury, after consultation with the Secretary of State, determines that individuals were required to leave because of war, civil unrest, or similar adverse conditions that precluded the normal conduct of business. An individual must establish that but for those conditions the individual could reasonably have been expected to meet the eligibility requirements. SECTION 3. APPLICATION .01 For 2016, in addition to the determination with respect to South Sudan described in Rev. Proc. 2017–26, the Secretary of the Treasury, in consultation with the Secretary of State, has determined that war, civil unrest, or similar adverse conditions precluded the normal conduct of business in the following country beginning on the specified date: Country Date of Departure On or After Turkey October 29, 2016 Accordingly, for purposes of section 911 of the Code, an individual who left Turkey on or after October 29, 2016, will be treated as a qualified individual with respect to the period during which that individual was present in, or was a bona fide resident of, Turkey if the individual establishes a reasonable expectation that he or she would have met the requirements of section 911(d) but for those conditions. .02 To qualify for relief under section 911(d)(4) of the Code, an individual must have established residency, or have been physically present, in the foreign country on or before the date that the Secretary of the Treasury determines that individuals were required to leave the foreign country. Accordingly, individuals who were first physically present or established residency in Turkey after October 29, 2016, are not eligible to qualify for the exception provided in section 911(d)(4) of the Code for taxable year 2016. .03 For 2017, the Secretary of the Treasury, in consultation with the Secretary of State, has determined that no country has experienced war, civil unrest, or similar adverse conditions that precluded the normal conduct of business. Therefore, no country is listed in this revenue procedure for section 911 purposes for tax year 2017. SECTION 4. EFFECT ON OTHER DOCUMENTS Previously issued revenue procedures under section 911(d)(4) remain in full force and effect. However, Rev. Proc. 2017–26, 2017–13, I.R.B. 1036, is supplemented. SECTION 5. INQUIRIES A taxpayer who needs assistance on how to claim this exclusion, or on how to file an amended return, should consult the section under the heading Foreign Earned Income Exclusion at https://www.irs.gov/individuals/international-taxpayers/us-citizens-and-resident-aliens-abroad ; consult the section under the heading How to Get Tax Help at the same web address; or contact a local IRS office. SECTION 6. DRAFTING INFORMATION The principal author of this revenue procedure is Kate Y. Hwa of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Kate Y. Hwa on (202) 317-6934 (not a toll free number). 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 2018–17 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 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 2018-28 2018-16 I.R.B. 2018-16 492 2018-29 2018-16 I.R.B. 2018-16 495 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 Proposed Regulations: Article Issue Link Page REG-119514-15 2018-04 I.R.B. 2018-04 325 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 2018-23 2018-17 I.R.B. 2018-17 516 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 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 2018–17 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.