Internal Revenue Bulletin 2014-25

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb14-25.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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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

Announcement 2014–25, page 1103. This document contains corrections to final regulations (TD 9662) that were published in the Federal Register on Monday, March 31, 2014 (79 FR 17860) relating to section 3504 of the Internal Revenue Code (Code) providing circumstances under which a person (payor) is designated to perform the acts required of an employer and is liable for employment taxes with respect to wages or compensation paid by the payor to individuals performing services for the payor’s client pursuant to a service agreement between the payor and the client.

Finding Lists begin on page ii. Index for July through June begins on page iv.

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.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

June 16, 2014 Bulletin No. 2014–25

Designation of Payor to Perform Acts Required of an Employer; Correction

Announcement 2014–25

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Correcting amendment.

SUMMARY: This document contains corrections to final regulations (TD 9662) that were published in the Federal Reg- ister on Monday, March 31, 2014 (79 FR 17860) relating to section 3504 of the Internal Revenue Code (Code) providing circumstances under which a person (payor) is designated to perform the acts required of an employer and is liable for employment taxes with respect to wages or compensation paid by the payor to individuals performing services for the payor’s client pursuant to a service agreement between the payor and the client.

DATES: This correction is effective on June 2, 2014 and is applicable March 31, 2014.

FOR FURTHER INFORMATION CONTACT: Jeanne Royal Singley at (202) 317-6798 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

The final regulations that are subject of this document are under section 3504 of the Internal Revenue Code.

Need for Correction

As published, final regulations (TD 9662) contain errors that may prove to be misleading and are in need of clarification.

Correction of Publication

Accordingly, 26 CFR part 31 is corrected by making the following correcting amendments:

PART 31—EMPLOYMENT TAXES AND COLLECTION OF INCOME TAX AT THE SOURCE

Paragraph 1. The authority citation for part 31 continues to read in part as follows:

Authority: 26 U.S.C. 7805 - -

§ 31.3504–2 [Corrected]

Par. 2. In § 31.3504–2, paragraph (e)(9) Example 9. the language “Corporation U” is removed and the language “Corporation V” is added in its place. d

Martin V. Franks Chief, Publications and

Regulations Branch, Legal Processing Division,

Associate Chief Counsel (Procedure and Administration) .

(Filed by the Office of the Federal Register on May 30, 2014, 8:45 a.m., and published in the issue of the Federal Register for June 2, 2014, 79 F.R. 31219)

Bulletin No. 2014–25 1103 June 16, 2014

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

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.

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 sub

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.

stance 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.

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. 2014–25 i June 16, 2014

Numerical Finding List ¹

Bulletins 2014–1 through 2014–25

Announcements

2014-1, 2014-2 I.R.B. 393 2014-2, 2014-4 I.R.B. 448 2014-4, 2014-7 I.R.B. 523 2014-05, 2014-6 I.R.B. 507 2014-06, 2014-6 I.R.B. 508 2014-07, 2014-6 I.R.B. 508 2014-08, 2014-6 I.R.B. 508 2014-09, 2014-6 I.R.B. 508 2014-10, 2014-6 I.R.B. 508 2014-11, 2014-6 I.R.B. 508 2014-12, 2014-6 I.R.B. 509 2014-13, 2014-10 I.R.B. 620 2014-14, 2014-16 I.R.B. 948 2014-15, 2014-16 I.R.B. 973 2014-16, 2014-17 I.R.B. 983 2014-17, 2014-18 I.R.B. 1007 2014-18, 2014-17 I.R.B. 983 2014-19, 2014-17 I.R.B. 984 2014-20, 2014-20 I.R.B. 1027 2014-21, 2014-20 I.R.B. 1030 2014-22, 2014-22 I.R.B. 1071 2014-23, 2014-22 I.R.B. 1072 2014-24, 2014-23 I.R.B. 1086 2014-25, 2014-25 I.R.B. 1103

Notices

2014-1, 2014-2 I.R.B. 270 2014-2, 2014-3 I.R.B. 407 2014-3, 2014-3 I.R.B. 408 2014-4, 2014-2 I.R.B. 274 2014-5, 2014-2 I.R.B. 276 2014-6, 2014-2 I.R.B. 279 2014-7, 2014-4 I.R.B. 445 2014-8, 2014-5 I.R.B. 452 2014-9, 2014-5 I.R.B. 455 2014-10, 2014-9 I.R.B. 605 2014-11, 2014-13 I.R.B. 880 2014-12, 2014-9 I.R.B. 606 2014-13, 2014-10 I.R.B. 616 2014-14, 2014-13 I.R.B. 881 2014-15, 2014-12 I.R.B. 661 2014-16, 2014-14 I.R.B. 920 2014-17, 2014-13 I.R.B. 881 2014-18, 2014-15 I.R.B. 926 2014-19, 2014-17 I.R.B. 979 2014-20, 2014-16 I.R.B. 937 2014-21, 2014-16 I.R.B. 938 2014-22, 2014-16 I.R.B. 940 2014-23, 2014-16 I.R.B. 942 2014-24, 2014-16 I.R.B. 942 2014-25, 2014-17 I.R.B. 981 2014-27, 2014-18 I.R.B. 987 2014-28, 2014-18 I.R.B. 990

Notices—Continued

2014-29, 2014-18 I.R.B. 991 2014-31, 2014-20 I.R.B. 1006 2014-32, 2014-20 I.R.B. 1006 2014-33, 2014-21 I.R.B. 1033 2014-34, 2014-23 I.R.B. 1069 2014-35, 2014-23 I.R.B. 1072 2014-36, 2014-22 I.R.B. 1058 2014-37, 2014-24 I.R.B. 1100 2014-38, 2014-24 I.R.B. 1100

Proposed Regulations

REG–15489,0–03 2014-6 I.R.B. 504 REG–15942,0–04 2014-2 I.R.B. 374 REG–14446,8–05 2014-6 I.R.B. 474 REG–16319,5–05 2014-15 I.R.B. 930 REG–11930,5–11 2014-8 I.R.B. 524 REG–14097,4–11 2014-3 I.R.B. 438 REG–12153,4–12 2014-6 I.R.B. 473 REG–12270,6–12 2014-11 I.R.B. 647 REG–13436,1–12 2014-13 I.R.B. 895 REG–13698,4–12 2014-2 I.R.B. 378 REG–11335,0–13 2014-3 I.R.B. 440 REG–13096,7–13 2014-13 I.R.B. 884 REG–13123,9–13 2014-22 I.R.B. 1069 REG–14103,6–13 2014-7 I.R.B. 516 REG–14317,2–13 2014-2 I.R.B. 383 REG–15076,0–13 2014-23 I.R.B. 1078 REG–10864,1–14 2014-15 I.R.B. 928

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 2014-15, 2014-5 I.R.B. 456 2014-16, 2014-9 I.R.B. 606 2014-17, 2014-12 I.R.B. 661 2014-18, 2014-7 I.R.B. 513 2014-19, 2014-10 I.R.B. 619 2014-20, 2014-9 I.R.B. 614 2014-21, 2014-11 I.R.B. 641 2014-22, 2014-11 I.R.B. 646 2014-23, 2014-12 I.R.B. 685 2014-24, 2014-13 I.R.B. 879 2014-25, 2014-15 I.R.B. 927 2014-28, 2014-16 I.R.B. 944 2014-30, 2014-20 I.R.B. 1009

Revenue Procedures—Continued

2014-31, 2014-20 I.R.B. 1009 2014-32, 2014-23 I.R.B. 1073 2014-33, 2014-22 I.R.B. 1065

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 2014-4, 2014-5 I.R.B. 449 2014-6, 2014-7 I.R.B. 510 2014-8, 2014-11 I.R.B. 624 2014-9, 2014-17 I.R.B. 975 2014-10, 2014-14 I.R.B. 906 2014-11, 2014-14 I.R.B. 906 2014-12, 2014-15 I.R.B. 923 2014-13, 2014-19 I.R.B. 1003 2014-15, 2014-24 I.R.B. 1095 2014-16, 2014-24 I.R.B. 1097 2014-17, 2014-24 I.R.B. 1093

Treasury Decisions

9649, 2014-2 I.R.B. 265 9650, 2014-3 I.R.B. 394 9651, 2014-4 I.R.B. 441 9652, 2014-12 I.R.B. 655 9653, 2014-6 I.R.B. 460 9654, 2014-6 I.R.B. 461 9655, 2014-9 I.R.B. 541 9656, 2014-11 I.R.B. 626 9657, 2014-13 I.R.B. 687 9658, 2014-13 I.R.B. 748 9659, 2014-12 I.R.B. 653 9660, 2014-13 I.R.B. 842 9661, 2014-13 I.R.B. 855 9662, 2014-16 I.R.B. 933 9663, 2014-22 I.R.B. 1038 9664, 2014-22 I.R.B. 1045 9665, 2014-22 I.R.B. 1050

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.

June 16, 2014 ii Bulletin No. 2014–25

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2014–1 through 2014–25

Announcements:

2007-44 Modified by Ann. 2014-4, 2014-7 I.R.B. 523

2011-49 Modified by Ann. 2014-4, 2014-7 I.R.B. 523

Notices:

2002-23 Superseded by

2003-37 Obsoleted by

REG-163195-05 2014-15 I.R.B. 930

2006-87, 2006-2 C.B. 766 Superseded by

2007-25, 2007-1 C.B. 760 Superseded by

2007-59 Obsoleted by

REG-163195-05 2014-15 I.R.B. 930

2007-77, 2007-2 C.B. 735 Superseded by

2008-107, 2008-2 C.B. 1266 Superseded by

2009-78 Superseded by

T.D. 9654 2014-6 I.R.B. 461

2010-27, 2010-1 C.B. 531 Superseded by Notice 2014-29, 2014-18 I.R.B. 991

Notices—Continued:

2010-27, 2010-1 C.B. 531 Superseded by Notice 2014-29, 2014-18 I.R.B. 991

2011-14 Modified by Rev. Proc. 2014-33, 2014-22 I.R.B. 1065

2013-1 Modified by Notice 2014-22, 2014-16 I.R.B. 940

2013-1 Modified by Notice 2014-38, 2014-24 I.R.B. 1100

2013-13 Obsoleted by REG-163195-05 2014-15 I.R.B. 930

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

2014-22 Superseded by Notice 2014-38, 2014-24 I.R.B. 1100

Revenue Procedures:

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

2004-42 Obsoleted by REG-163195-05 2014-15 I.R.B. 930

2004-43 Obsoleted by REG-163195-05 2014-15 I.R.B. 930

2011-4 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B. 661

2011-14 Modified by Rev. Proc. 2014-16, 2014-9 I.R.B. 606

2011-14 Clarified by Rev. Proc. 2014-16, 2014-9 I.R.B. 606

2011-14 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B. 661

Revenue Procedures—Continued:

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

2012-14 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B. 661

2012-19 Modified by Rev. Proc. 2014-16, 2014-9 I.R.B. 606

2012-19 Superseded by Rev. Proc. 2014-16, 2014-9 I.R.B. 606

2012-20 Modified by Rev. Proc. 2014-17, 2014-12 I.R.B. 661

2012-20 Superseded by Rev. Proc. 2014-17, 2014-12 I.R.B. 661

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

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. 2014–25 iii June 16, 2014

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

2013-22 Modified by Rev. Proc. 2014-28, 2014-16 I.R.B. 944

2013-24 Obsoleted by Rev. Proc. 2014-23, 2014-12 I.R.B. 685

2013-27 Obsoleted by Rev. Proc. 2014-23, 2014-12 I.R.B. 685

2013-28 Obsoleted by Rev. Proc. 2014-31, 2014-20 I.R.B. 1009

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

2014-1 Amplified by Rev. Proc. 2014-18, 2014-7 I.R.B. 513

2014-1 I.R.B. 111 Amplified by Rev. Proc. 2014-24, 2014-13 I.R.B. 879

2014-3 Amplified by Rev. Proc. 2014-18, 2014-7 I.R.B. 513

2014-3 I.R.B 111 Amplified by Rev. Proc. 2014-24, 2014-13 I.R.B. 879

2014-4 Modified by Rev. Proc. 2014-19, 2014-10 I.R.B. 619

Proposed Regulations:

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

Revenue Rulings:

2005-40 Distinguished by Rev. Rul. 2014-15, 2014-24 I.R.B. 1095

2005-48 (2005-2 CB 259) Obsoleted by T.D. 9659 2014-12 I.R.B. 653

Revenue Rulings—Continued:

2013-17 Amplified by Notice 2014-19, 2014-17 I.R.B. 979

2013-17 Amplified by Notice 2014-25, 2014-17 I.R.B. 981

2002-89 Distinguished by Rev. Rul. 2014-15, 2014-24 I.R.B. 1095

Treasury Decision:

9644 Correction by Ann. 2014-18, 2014-17 I.R.B. 983

9644 Correction by Ann. 2014-19, 2014-17 I.R.B. 984

June 16, 2014 iv Bulletin No. 2014–25

Internal Revenue Bulletins 2014–1 through 2014–25

The abbreviation and number in parenthesis following the index entry refer to the specific item; numbers in roman and italic type following the parentheses refer to the Internal Revenue Bulletin in which the item may be found and the page number on which it appears.

Key to Abbreviations: Ann Announcement CD Court Decision DO Delegation Order EO Executive Order PL Public Law PTE Prohibited Transaction Exemption RP Revenue Procedure RR Revenue Ruling SPR Statement of Procedural Rules TC Tax Convention TD Treasury Decision TDO Treasury Department Order

Average area purchase price safe-harbors guidance for 2014 (RP 31)

20, 1009 Consolidated returns; d failure to p[roperly include subsidiary

(RP 24) 13, 879 Extension of time to file estate tax return to elect portability of a

deceased spousal unused exclusion amount under section 2010(c)(5)(A). (RP 18) 7, 513 Method change procedures for dispositions of tangible deprecia ble property (RP 17) 12, 661 Maximum Vehicle Values for which the special valuation rules

of regulations section 1.61–21(d) and (e) may be used (Notice 11) 13, 880 Minimum essential coverage, information reporting (TD 9660)

13, 842 Regulations:

26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR 1.6081–8 amended. 26 CFR 301.6011–2 amended. 26 CFR 301.6721–1 amended. 26 CFR 1.6011–8 amended. 26 CFR 301.6722–1 amended; minimum essential coverage, information reporting (TD 9660) 13, 842 Per Capita Payments from Proceeds of Settlements of Indian

Tribal Trust Cases (Notice 22) 16, 940 Per Capita Payments from Proceeds of Settlements of Indian

Tribal Trust Cases (Notice 38) 24, 1100 Virtual Currency (Notice 21) 16, 938

Definition of a substantial risk of forfeiture (TD 9659) 12, 653 Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111 Excepted benefits (REG–143172–13) 2, 383

Final rules to implement the 90-day waiting period limitation

(TD 9656) 11, 626 Letter rulings:

And determination letters:

Areas which will not be issued from Associate Chief

Counsel and Division counsel (TE/GE) (RP 3) 1, 111 Exemption application determination letter rulings under

sections 501 and 521 (RP 9) 1, 281 And general information letters; procedures (RP 4) 1, 125 User fees, request for letter rulings (RP 8) 1, 242 Letter rulings and general information letters (RP 4) 1, 125 Letter rulings or determination letters (RP 1) 1, 1 Proposed rules to clarify length of reasonable and bona fide

employment-based orientation period, consistent with the 90day waiting period limitation (REG–122706–12) 11, 647 Qualification, determination letters (RP 6) 1, 198 Qualified plans:

Application of the Windsor Decision and Rev. Rul. 2013–17

(Notice 19) 17, 979 Determination Letters (RP 19) 10, 619 Discrimination (Notice 5) 2, 276 Filing Requirements (Notice 35) 23, 1072 Filing Requirements (RP 32) 23, 1073 Mid-Year Amendments (Notice 37) 24, 1100 Opinion letters (Ann 4) 7, 523 Opinion letters (Ann 16) 17, 523 Qualified retirement plans covered compensation, permitted dis parity (RR 3) 2, 259 Qualified retirement plans

Rollovers (RR 9) 17, 975 Proposed Regulation:

26 CFR 54.9815–2708, amended; REG–122706–12) 11, 647 Removal of the Qualified Payment Card Agent Program (REG–

163195–05) 15, 930 Request for Information Regarding Provider Non-Discrimination

(REG–108641–14) 15, 928 Rulings and determination letters, user fees (RP 8) 1, 242 Technical advice memorandum or TAM (RP 2) 1, 90 Technical advice procedures (RP 5) 1, 169 Full funding limitations, weighted average interest rates, segment

rates for:

January 2014 (Notice 8) 5, 452 Weighted average interest rates

Segment rates for February 2014 (Notice 13) 10, 616 Segment rates for March 2014 (Notice 16) 14, 920 Segment rates for March 2014 (Notice 27) 18, 987 Segment rates for May 2014 (Notice 34) 23, 1069

Definitions and Reporting Requirements for Shareholders of

Passive Foreign Investment Companies; Corrected; Reg– 112966–10 (Ann 25) 25, 1103 Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111

Bulletin No. 2014–25 v June 16, 2014

Employment tax liability of agents authorized under section 3504

(TD 9649) 2, 265 Employment tax obligations of a third party that enters into a

service agreement with an employer to take on the employer’s employment tax responsibilities (TD 9662) 16, 933 Letter rulings or determination letters (RP 1) 1, 1 Proposed Regulation:

26 CFR 54.9815–2708, amended; REG–122706–12) 11, 647 Regulations:

26 CFR 31–3504–2, added; employment tax obligations of a third party that enters into a service agreement with an employer to take on the employer’s employment tax responsibilities (TD 9662) 16, 933 26 CFR 1.83–3 is revised; definition of a substantial risk of forfeiture (TD 9659) 12, 653 26 CFR 54,9801–1, thru–6, amended; 26 CFR 54.9802–1, amended; 26 CFR 54.9815–2708, added; 26 CFR 54.9831–1, amended (TD 9656) 12, 626 Technical Advice Memorandum (TAM) (RP 2) 1, 90 Virtual Currency (Notice 21) 16, 90

Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111 Extension of time to file estate tax return to elect portability of a

deceased spousal unused exclusion amount under section 2010(c)(5)(A) (RP 18) 7, 513 Letter rulings or determination letters (RP 1) 1, 1 Technical Advice Memorandum (TAM) (RP 2) 1, 90

Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111 Final rules to implement the 90-day waiting period limitation

(TD 9656) 11, 626 Information reporting by applicable large employers on health

insurance coverage offered under employer-sponsored plans (TD 9661) 13, 855 Interim guidance regarding supporting organizations (Notice 4)

2, 274 Letter rulings or determination letters (RP 1) 1, 1 Notice for ACA Section 9010 Health Insurance Providers Fee

and expatriate plans (Notice 14) 16, 942 Proposed rules to clarify length of reasonable and bona fide

employment-based orientation period, consistent with the 90day waiting period limitation (REG–122706–12) 11, 647 Proposed Regulation:

26 CFR 54.9815–2708, amended; REG–122706–12) 11, 647 Regulations:

301.6056–1, –2, added; Information reporting by applicable large employers on health insurance coverage offered under employer-sponsored plans (TD 9661) 13, 855 26 CFR 54,9801–1, thru–6, amended; 26 CFR 54.9802–1, amended; 26 CFR 54.9815–2708, added; 26 CFR 54.9831–1, amended (TD 9656) 12, 626 Technical Advice Memorandum (TAM) (RP 2) 1, 90

Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111 Form 990 Revenue Procedure update to revoke Revenue Proce dure 79–6 (RP 22) 11, 646 Interim guidance regarding supporting organizations (Notice 4)

2, 274 Letter rulings:

And determination letters:

Areas which will not be issued from Associate Chief

Counsel and Division counsel (TE/GE) (RP 3) 1, 111 Exemption application determination letter rulings under

sections 501 and 521 (RP 9) 1, 281 And general information letters; procedures (RP 4) 1, 125 User fees, request for letter rulings (RP 8) 1, 242 Letter rulings (RP 10) 2, 293 ; (RP 9) 2, 281 Letter rulings or determination letters (RP 1) 1, 1 Proposed procedures for charitable hospitals to correct and dis close failures to meet section 501(r) (Notice 3) 3, 408 Reliance on proposed regulations for tax-exempt hospitals

(Notice 2) 3, 407 Rulings and determination letters, user fees (RP 8) 1, 242 Technical Advice Memorandum (TAM) (RP 2) 1, 90 Technical advice procedures (RP 5) 1, 169

Accounting method change, sales-base royalties and vendor al lowances (RP 33) 22, 1065 Acquiring Corporation for Purposes of Section 381 (REG–

131239–13) 22, 1069 Adequate disclosure revenue procedure (RP 15) 5, 456 Advance Pricing and Mutual Agreement Program (Ann 14) 16,

948 Allocation of section 47 credits by a partnership to its partners

(RP 12) 3, 415 Allocation of section 752 recourse liabilities among related par ties (REG–136984–12) 2, 378 Amount of the life insurance reserves taken into account under

§ 807 of the Internal Revenue Code for variable contracts (RR 7) 9, 539 Areas in which rulings will not be issued; Associate Chief

Counsel (International) (RP 7) 1, 238 Average area purchase price safe-harbors guidance for 2014

(RP 31) 20, 1009 Basis in assets of tax exempt trusts (REG–154890–03) 6, 504 Bond premium carryforward (TD 9653) 6, 460 Cafeteria plans, FSA reimbursements, and HSA contribution

limits for same-sex spouses (Notice 1) 2, 270 2014 Census Count (Notice 12) 9, 606 Contribution of built-in lost property to a partnership; mandatory

basis adjustments in the event of a substantial built-in loss or substantial basis reduction; modification of basis allocation rules (REG–144468–05) 6, 474

June 16, 2014 vi Bulletin No. 2014–25

Current refunding of Recovery Zone facility bonds (Notice 9) 5,

455 Declaratory judgement suits (Ann 5) 6, 507 ; (Ann 6) 6, 507 ;

(Ann 7) 6, 508 ; (Ann 8) 6, 508 ; (Ann 9) 6, 508 ; (Ann 10) 6, 508 ; (Ann 12) 6, 509 Definition of a substantial risk of forfeiture (TD 9659) 12, 653 Definitions applicable to U.S. persons owning interests in passive

foreign investment companies (REG–113350–13) 3, 440 Depreciation, asset class, ethanol plants (RR 17) 24, 641 Depreciation deduction, limitations on certain automobiles

(RP 21) 11, 641 Determination of housing cost eligible exclusion or deduction for

2014 (Notice 29) 18, 991 Determination of ownership in a passive foreign investment

company; annual filing requirements for shareholders of passive foreign investment companies; filing requirements for constructive owners in certain foreign corporations (REG–140974–11) 3, 438 ; (TD 9650) 3, 394

correction (Ann 22) 22, 1071 Determining stock ownership for purposes of whether an

entity is a surrogate foreign corporation (TD 9654) 6, 461 ; (REG–121534–12) 6, 473 Discharge of indebtedness secured by real property (RP 20) 9,

614 Disciplinary actions involving attorneys, certified public ac countants, enrolled agents, and enrolled actuaries (Ann 13) 10, 620 Disciplinary actions involving attorneys, certified public accoun tants, enrolled agents, and enrolled actuaries (Ann 20) 20, 1027 Domestic areas in which the Service will not issue letter rulings

or determination letters (RP 3) 1, 111 Equity-linked instruments and dividend equivalents (Notice 14)

13, 881 FATCA financial institution registration update (Ann 1) 2, 393 FATCA IGA and registration update (Ann 17) 18, 1001 Final FFI agreement for participating FFI and reporting Model 2

FFI (RP 13) 3, 419 Foreign Earned Income Exclusion (RP 25) 15, 927 Further guidance on FATCA implementation and related with holding provisions (Notice 33) 21, 1033 2014 – 2015 Guidance Priority List- Solicitation Notice (Notice 18) 15, 926 Guidance regarding reinstatement following auto revocation of

tax-exempt status under section 6033(j) (RP 11) 3, 411 Income tax treatment of per capita payments made from funds held

in trust by the Secretary of the Interior (Notice 17) 13, 881 2015 Inflation adjusted amounts for Health Savings Accounts (HSAs) (RP 30) 20, 1009 Inflation Adjustment Factors (Notice 36) 22, 1058 Information reporting by foreign financial institutions and with holding on payments to foreign financial institutions and other foreign entities (REG–130967–13) 13, 884 Information reporting by foreign financial institutions and with holding on payments to foreign financial institutions and other foreign entities (TD 9657) 13, 687

Interest:

Investment:

Federal short-term, mid-term, and long-term rates for:

January 2014 (RR 1) 2, 263 February 2014 (RR 6) 7, 510 March 2014 (RR 8) 11, 624 April 2014 (RR 12) 15, 923 May 2014 (RR 13) 19, 1003 June 2014 (RR 16) 24, 1097 Intra-group gross receipts (REG–159420–04) 2, 374 Insurance tax, insurance companies, interest rate tables (RR 4) 5, 449 Letter rulings or determination letters (RP 1) 1, 1 Low-Income Housing Credit (Notice 15) 12, 661 Maximum Vehicle Values for which the special valuation rules

of regulations section 1.61–21(d) and (e) may be used (Notice 11) 13, 880 Method change procedures for dispositions of tangible deprecia ble property (RP 17) 12, 661 Minimum essential coverage, information reporting (TD 9660)

13, 842 Net investment income tax; TD 9644 Correction (Ann 2014–18)

17, 983 Net investment income tax; TD 9644 Correction (Ann 2014–19)

17, 984 Postponement of deadline for § 165(i) election for losses attrib utable to September 2013 major flooding in Colorado (Notice 20) 16, 937 Premium tax credit (TD 9663) 22, 1038 Principal residence, treatment of National Mortgage Settlement

payments (RR 2) 2, 255 Qualified census tracts (RP 14) 2, 295 Real Estate Investment Trust (REG–150760–13) 23, 1078 Refundable Credit For Coverage Under a Qualified Health Plan,

Definition and Rules Relating to Applicable Taxpayer (Notice 23) 16, 942 Regarding disguised sales, generally (REG–119305–11) 8, 524 Removal of the Qualified Payment Card Agent Program (REG–

163195–05) 15, 930 Retiree Health Benefits Provided Through Employer’s Wholly Owned Subsidiary (RR–15) 24, 1095 26 CFR 1.6045–1T: Returns of information of brokers and barter exchanges (temporary), correction to TD 9658 (Ann 21) 20, 1030 Revocations, exempt organization (Ann 11) 6, 508 Sales-bases royalties and vendor allowances (TD 9652) 12, 655 2013 Section 45K Inflation Adjustment Factor - Nonconventional Fuel source Credit (Notice 25) 17, 981 Section 67 Limitations on Estates or Trusts (REG–128224–06)

22, 1046 Shared responsibility for employers regarding health coverage

(TD 9655) 9, 541 Shared responsibility payment for not maintaining minimum

essential coverage (REG–141036–13) 7, 541 Standard Industry Fare Level (SIFL) (RR 10) 14, 906 Tangible property regulations method change guidance (RP 16)

9, 606

Bulletin No. 2014–25 vii June 16, 2014

Tax Treatment of Qualified Retirement Plan Payment of Acci dent or Health Insurance Premiums (TD 9665) 22, 1050 Technical Advice Memorandum (TAM) (RP 2) 1, 90 Transition relief for the tax credit for employee health insurance

expenses of certain small employers (Notice 6) 2, 279 Transition relief under section 5000A for certain individuals

without minimum essential coverage (Notice 10) 9, 605 Treatment of Income from certain government bonds held by

certain active banks for purposes of the passive foreign investment company (PFIC) rules (Notice 31) 20, 1006 Treatment of Property Used To Acquire Parent Stock or Secu rities in Certain Triangular Reorganizations Involving Foreign Corporations (Notice 32) 20, 1006 Treatment of U.S. persons that own stock of passive foreign

investment companies through certain organizations and accounts that are tax exempt (Notice 28) 18, 990 Underpayment and overpayments, quarter beginning: April 1,

2014 (RR 11) 14, 906 Virtual Currency (Notice 21) 16, 938 Withholding of tax on certain U.S. source income paid to foreign

persons and revision of information reporting and backup withholding regulations (REG–134361–12) 13, 895 Withholding of tax on certain U.S. source income paid to foreign

persons and revision of information reporting and backup withholding regulations (TD 9658) 13, 748 Proposed Regulations:

26 CFR 1.856–10 added; 1.856–3 modified: definition of real estate investment trust real property (REG–150760–13) 23, 1078 26 CFR 301.6724–1(c)(6), amended; 26 CFR 31.3406(g)– 1(f), 26 CFR 301.6724–1(e)(1)(vi)(H), and 26 CFR 301.6724–1(f)(5)(vii), removed;removal of the qualified payment ard agent program (REG–163195–05) 15, 930 26 CFR 1.1471–0, amended; 26 CFR 1.1471–1, amended; 26 CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26 CFR 1.1471–4, amended; 26 CFR 1.1471–5, amended; 26 CFR 1.1471–6, amended; 26 CFR 1.1472–1, amended; 26 CFR 1.1473–1, amended; 26 CFR 1474–1, amended; 26 CFR 1.1474–6, amended. (Reg–130967–13) 13, 930 26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26 CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26 CFR 1.441–6, amended; 26 CFR 1.1441.7, amended; 26 CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26 CFR 1.6041–1, amended; 26 CFR 1.6041–4, amended; 26 CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26 CFR 1.6045–1, amended; 26 CFR 1.6049–4, amended; 26 CFR 1.6049–5, amended; 26 CFR 31.3406(g)–1, amended; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3, amended; Withholding of tax on certain U.S. source income paid to foreign persons and revision of information reporting and backup withholding regulations (REG– 134361–12) 13, 895

Regulations:

26 CFR 1.67–4, added; 1.67–4T, removed (TD 9664) 22, 1045 26 CFR 1.83–3 is revised; definition of a substantial risk of forfeiture (TD 9659) 12, 653 26 CFR 1.263A–0, thru–3, amended; 1.471–3 amended; sales-base royalties and vendor allowances (TD 9652) 12, 655 26 CFR 1.36B–0 amended (TD 9663) 22, 1022 26 CFR 1.36B–5 amended (TD 9663) 22, 1022 26 CFR 1.6055–1 added. 26 CFR 1.6055–2 added. 26 CFR 1.6081–8 amended. 26 CFR 301.6011–2 amended. 26 CFR 301.6721–1 amended. 26 CFR 1.6011–8 amended. 26 CFR 301.6722–1 amended. (TD 9660) 13, 842 26 CFR 1.72–15, amended, 26 CFR 1.105–4, removed, 26 CFR 1.105–6, removed, 26 CFR 1.106–1, amended, 26 CFR 1.401–1, amended, 26 CFR 1.402(c)–2, amended; Tax Treatment of Qualified Retirement Plan Payment of Accident or Health Insurance Premiums (TD 9665) 22, 1050 26 CFR 1.1471–0, amended; 26 CFR 1.1471–1, amended; 26 CFR 1.147–2, amended; 26 CFR 1.1471–3, amended; 26 CFR 1.1471–4, amended; 26 CFR 1.1471–5, amended; 26 CFR 1.1471–6, amended; 26 CFR 1.1472–1, amended; 26 CFR 1.1473–1, amended; 26 CFR 1474–1, amended; 26 CFR 1.1474–6, amended. (TD 9657) 13, 687 26 CFR 1.871–14, amended; 26 CFR 1.1441–1, amended; 26 CFR 1.1441–3, amended; 26 CFR 1.1441–5, amended; 26 CFR 1.441–6, amended; 26 CFR 1.1441.7, amended; 26 CFR 1.1461–1, amended; 26 CFR 1.1461–2, amended; 26 CFR 1.6041–1, amended; 26 CFR 1.6041–4, amended; 26 CFR 1.6042–2, amended; 26 CFR 1.6042–3, amended; 26 CFR 1.6045–1, amended; 26 CFR 1.6049–4, amended; 26 CFR 1.6049–5, amended; 26 CFR 31.3406(g)–1, amended; 26 CFR 31.3406(h)–2, amended; 26 CFR 301.6402–3, amended; Withholding of tax on certain U.S. source income paid to foreign persons and revision of information reporting and backup withholding regulations, correction to (TD 9658) 20, 1030 13, 748

Advance Pricing and Mutual Agreement Program (Ann 14) 16,

948

Kuwait Reciprocal Exemption for income from the international

operation of aircraft (Ann 24) 23, 1086

June 16, 2014 viii Bulletin No. 2014–25

Official Business Penalty for Private Use, $300

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/ .

The contents of the weekly Bulletins were consolidated semiannually into permanent, indexed, Cumulative Bulletins through the 2008–2 edition.

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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 IRS Bulletin Unit, SE:W:CAR:MP:P:SPA, Washington, DC 20224.