Definition of Terms

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 deter# Abbreviations

The following abbreviations in current use and formerly used will appear in ma- terial published in the Bulletin.

A —Individual. Acq. —Acquiescence. B —Individual. BE —Beneficiary. BK —Bank. B.T.A. —Board of Tax Appeals. C —Individual. C.B. —Cumulative Bulletin. CFR —Code of Federal Regulations. CI —City. COOP —Cooperative. Ct.D. —Court Decision. CY —County. D —Decedent. DC —Dummy Corporation. DE —Donee. Del. Order —Delegation Order. DISC —Domestic International Sales Corporation. DR —Donor. E —Estate. EE —Employee. E.O. —Executive Order. ER —Employer.

minative 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Superseded describes a situation where the new ruling does nothing more than restate the substance and situation of a previously published ruling (or rulings).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

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.

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.

Revenue rulings and revenue proce- dures (hereinafter referred to as “rul- ings”) that have an effect on previous rulings use the following defined terms to describe the effect:

PTE —Prohibited Transaction Exemption. Pub. L. —Public Law. REIT —Real Estate Investment Trust. Rev. Proc. —Revenue Procedure. Rev. Rul. —Revenue Ruling. S —Subsidiary. S.P.R. —Statement of Procedural Rules. Stat. —Statutes at Large. T —Target Corporation. T.C. —Tax Court. T.D. —Treasury Decision. TFE —Transferee. TFR —Transferor. T.I.R. —Technical Information Release. TP —Taxpayer. TR —Trust. TT —Trustee. U.S.C. —United States Code. X —Corporation. Y —Corporation. Z —Corporation.

Bulletin No. 2014–3 i January 13, 2014

Numerical Finding List ¹

Bulletins 2014–1 through 2014–3

Announcements

2014-1, 2014-2 I.R.B. 393

Notices

2014-1, 2014-2 I.R.B. 270 2014-4, 2014-2 I.R.B. 274 2014-5, 2014-2 I.R.B. 276 2014-6, 2014-2 I.R.B. 279 2014-2, 2014-3 I.R.B. 407 2014-3, 2014-3 I.R.B. 408

Proposed Regulations

REG-159420-04, 2014-2 I.R.B. 374 REG-140974-11, 2014-3 I.R.B. 438 REG-136984-12, 2014-2 I.R.B. 378 REG-113350-13, 2014-3 I.R.B. 440 REG-143172-13, 2014-2 I.R.B. 383

Revenue Procedures

2014-1, 2014-1 I.R.B. 1 2014-2, 2014-1 I.R.B. 90 2014-3, 2014-1 I.R.B. 111 2014-4, 2014-1 I.R.B. 125 2014-5, 2014-1 I.R.B. 169 2014-6, 2014-1 I.R.B. 198 2014-7, 2014-1 I.R.B. 238 2014-8, 2014-1 I.R.B. 242 2014-9, 2014-2 I.R.B. 281 2014-10, 2014-2 I.R.B. 293 2014-11, 2014-3 I.R.B. 411 2014-12, 2014-3 I.R.B. 415 2014-13, 2014-3 I.R.B. 419 2014-14, 2014-2 I.R.B. 295

Revenue Rulings

2014-1, 2014-2 I.R.B. 263 2014-2, 2014-2 I.R.B. 255 2014-3, 2014-2 I.R.B. 259

Treasury Decisions

9649, 2014-2 I.R.B. 265 9650, 2014-3 I.R.B. 394

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23, 2013.

January 13, 2014 ii Bulletin No. 2014–3

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2014–1 through 2014–3

Notices:

2006-109 Modified by Notice 2014-4, 2014-2 I.R.B. 274

2013-17 Amplified by Notice 2014-1, 2014-2 I.R.B. 270

Revenue Procedures:

2003-49 Modified and superseded by Rev. Proc. 2014-14, 2014-2 I.R.B. 295

2011-44 Modified and Superseded by Rev. Proc. 2014-11, 2014-3 I.R.B. 411

2011-49 Modified by Rev. Proc. 2014-6, 2014-1 I.R.B. 198

2013-1 Superseded by Rev. Proc. 2014-1, 2014-1 I.R.B. 1

2013-2 Superseded by Rev. Proc. 2014-2, 2014-1 I.R.B. 90

2013-3 Superseded by Rev. Proc. 2014-3, 2014-1 I.R.B. 111

2013-4 Superseded by Rev. Proc. 2014-4, 2014-1 I.R.B. 125

2013-5 Superseded by Rev. Proc. 2014-5, 2014-1 I.R.B. 169

2013-6 Superseded by Rev. Proc. 2014-6, 2014-1 I.R.B. 198

2013-7 Superseded by Rev. Proc. 2014-7, 2014-1 I.R.B. 238

2013-8 Superseded by Rev. Proc. 2014-8, 2014-1 I.R.B. 242

Revenue Procedures—Continued:

2013-9 Superseded by Rev. Proc. 2014-9, 2014-2 I.R.B. 281

2013-10 Superseded by Rev. Proc. 2014-10, 2014-2 I.R.B. 293

2013-32 Superseded in part by Rev. Proc. 2014-1, 2014-1 I.R.B. 1, and Rev. Proc. 2014-3, 2014-1 I.R.B. 111

Proposed Regulations:

209054-87 A portion withdrawn by REG-113350-13 2014-3 I.R.B. 440

1A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2013–27 through 2013–52 is in Internal Revenue Bulletin 2013–52, dated December 23, 2013.

Bulletin No. 2014–3 iii January 13, 2014