Internal Revenue Bulletin 2014-39

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb14-39.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.

INCOME TAX

Rev. Proc. 2014–53, page 573. This revenue procedure provides domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Internal Revenue Code for taxable years beginning after December 31, 2012.

Finding Lists begin on page ii. Index for July through September 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.

September 22, 2014 Bulletin No. 2014–39

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of tax liability (Also: 842(b))

Rev. Proc. 2014–53

This revenue procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Internal Revenue Code for taxable years beginning after December 31, 2012. Instructions are provided for computing foreign insurance companies’ liabilities for the estimated tax and installment payments of estimated tax for taxable years beginning after December 31, 2012. For more specific guidance regarding the computation of the amount of net investment income to be included by a foreign insurance company on its U.S. income tax return, see Notice 89–96, 1989–2 C.B. 417. For the domestic asset/ liability percentage and domestic investment yield, as well as instructions for computing foreign insurance companies’ liabilities for estimated tax and installment payments of estimated tax for taxable years beginning after December 31, 2011, see Rev. Proc. 2013–33, 2013–38 I.R.B. 209.

DOMESTIC ASSET/LIABILITY PERCENTAGES FOR 2013. The Secretary determines the domestic asset/liability per

centage separately for life insurance companies and property and liability insurance companies. For the first taxable year beginning after December 31, 2012, the relevant domestic asset/liability percentages are:

[134.6] percent for foreign life insurance companies, and

[188.4] percent for foreign property and liability insurance companies.

.02 DOMESTIC INVESTMENT YIELDS FOR 2013. The Secretary is required to prescribe separate domestic investment yields for foreign life insurance companies and for foreign property and liability insurance companies. For the first taxable year beginning after December 31, 2012, the relevant domestic investment yields are:

[4.2] percent for foreign life insurance companies, and

[4.1] percent for foreign property and liability insurance companies.

.03 SOURCE OF DATA FOR 2013. The section 842(b) percentages to be used for the 2013 tax year are based on tax return data following the same methodology used for the 2012 year.

ESTIMATED TAXES

To compute estimated tax and the installment payments of estimated tax due for taxable years beginning after December 31, 2012, a foreign insurance company must compute its estimated tax payments by adding to its income other than net investment income the greater of (i) its net investment income as determined under section 842(b)(5), that is actually ef

fectively connected with the conduct of a trade or business within the United States for the relevant period, or (ii) the minimum effectively connected net investment income under section 842(b) that would result from using the most recently available domestic asset/liability percentage and domestic investment yield. Thus, for installment payments due after the publication of this revenue procedure, the domestic asset/liability percentages and the domestic investment yields provided in this revenue procedure must be used to compute the minimum effectively connected net investment income. However, if the due date of an installment is less than 20 days after the date this revenue procedure is published in the Internal Revenue Bulletin, the asset/liability percentages and domestic investment yields provided in Rev. Proc. 2013–33 may be used to compute the minimum effectively connected net investment income for such installment. For further guidance in computing estimated tax, see Notice 89–96.

This revenue procedure is effective for taxable years beginning after December 31, 2012.

INFORMATION

The principal author of this revenue procedure is Sheila Ramaswamy of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Sheila Ramaswamy at (202) 317-6938 (not a toll free number).

Bulletin No. 2014–39 573 September 22, 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. 2014–39 i September 22, 2014

Numerical Finding List ¹

Bulletins 2014–27 through 2014–39

Announcements:

2014-2, 2014-28 I.R.B. 120 2014-28, 2014-34 I.R.B. 391 2014-29, 2014-35 I.R.B. 452

Notices:

2014-40, 2014-27 I.R.B. 100 2014-41, 2014-27 I.R.B. 97 2014-42, 2014-34 I.R.B. 387 2014-43, 2014-31 I.R.B. 249 2014-44, 2014-32 I.R.B. 270 2014-45, 2014-34 I.R.B. 388 2014-46, 2014-36 I.R.B. 520 2014-47, 2014-36 I.R.B. 522 2014-48, 2014-36 I.R.B. 523

Proposed Regulations:

REG-104579-13, 2014-33 I.R.B. 370 REG-120756-13, 2014-31 I.R.B. 252 REG-105067-14, 2014-34 I.R.B. 391 REG-110948-14, 2014-30 I.R.B. 239 REG-121542-14, 2014-28 I.R.B. 119 REG-107012-14, 2014-33 I.R.B. 371 REG-123286-14, 2014-33 I.R.B. 377 REG-209459-78, 2014-31 I.R.B. 253 129507-14, 2014-38 I.R.B. 561 129786-14, 2014-38 I.R.B. 562

Revenue Procedures:

2014-26, 2014-27 I.R.B. 26 2014-27, 2014-27 I.R.B. 41 2014-29, 2014-28 I.R.B. 105 2014-37, 2014-33 I.R.B. 363 2014-38, 2014-29 I.R.B. 132 2014-39, 2014-29 I.R.B. 151 2014-40, 2014-30 I.R.B. 229 2014-41, 2014-33 I.R.B. 364 2014-42, 2014-29 I.R.B. 193 2014-43, 2014-32 I.R.B. 273 2014-44, 2014-32 I.R.B. 274 2014-45, 2014-34 I.R.B. 388 2014-46, 2014-33 I.R.B. 367 2014-47, 2014-35 I.R.B. 393 2014-48, 2014-36 I.R.B. 527 2014-49, 2014-37 I.R.B. 535 2014-50, 2014-37 I.R.B. 540 2014-51, 2014-37 I.R.B. 543 2014-52, 2014-38 I.R.B. 560 2014-53, 2014-39 I.R.B. 573

Revenue Rulings:

2014-14, 2014-27 I.R.B. 12 2014-19, 2014-32 I.R.B. 266

Revenue Rulings—Continued:

2014-20, 2014-28 I.R.B. 101 2014-21, 2014-34 I.R.B. 381 2014-22, 2014-37 I.R.B. 523 2014-24, 2014-37 I.R.B. 529

Treasury Decisions:

9664, 2014-32 I.R.B. 254 9668, 2014-27 I.R.B. 1 9669, 2014-28 I.R.B. 103 9670, 2014-29 I.R.B. 121 9671, 2014-29 I.R.B. 124 9672, 2014-30 I.R.B. 196 9673, 2014-30 I.R.B. 212 9674, 2014-30 I.R.B. 225 9675, 2014-31 I.R.B. 242 9676, 2014-32 I.R.B. 260 9677, 2014-31 I.R.B. 241 9678, 2014-32 I.R.B. 262 9679, 2014-32 I.R.B. 267 9680, 2014-32 I.R.B. 254 9681, 2014-33 I.R.B. 340 9682, 2014-33 I.R.B. 342 9683, 2014-33 I.R.B. 330 9684, 2014-33 I.R.B. 345 9685, 2014-34 I.R.B. 379 9686, 2014-34 I.R.B. 382 9687, 2014-36 I.R.B. 486 9688, 2014-36 I.R.B. 482 9689, 2014-36 I.R.B. 456 9690, 2014-38 I.R.B. 548 9691, 2014-38 I.R.B. 547

1A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2014–01 through 2014–26 is in Internal Revenue Bulletin 2014–26, dated June 30, 2014.

September 22, 2014 ii Bulletin No. 2014–39

Finding List of Current Actions on Previously Published Items ¹

Bulletins 2014–27 through 2014–39

Announcements:

2012-11 Supplemented by Ann. 2014-2, 2014-28 I.R.B. 120

2013-11 Supplemented by Ann. 2014-2, 2014-28 I.R.B. 120

2010-41 Obsoleted by Rev. Proc. 2014-43, 2014-32 I.R.B. 273

Revenue Procedures:

1981-38 Superseded by Rev. Proc. 2014-42, 2014-29 I.R.B. 193

93-37 Modified and Superseded by Rev. Proc. 2014-43, 2014-32 I.R.B. 273

1981-38 Modified by Rev. Proc. 2014-42, 2014-29 I.R.B. 193

2000-12 Superseded by Rev. Proc. 2014-39, 2014-29 I.R.B. 151

2002-55 Revoked by Rev. Proc. 2014-39, 2014-29 I.R.B. 151

2003-64 Superseded by Rev. Proc. 2014-47, 2014-35 I.R.B. 393

2004-21 Superseded by Rev. Proc. 2014-47, 2014-35 I.R.B. 393

2005-77 Superseded by Rev. Proc. 2014-47, 2014-35 I.R.B. 393

2011-14 Modified by Rev. Proc. 2014-48, 2014-36 I.R.B. 527

2011-16 Superseded by Rev. Proc. 2014-51, 2014-37 I.R.B. 543

Revenue Procedures—Continued:

2011-16 Modified by Rev. Proc. 2014-51, 2014-51 I.R.B. 543

2012-38 Superseded by Rev. Proc. 2014-27, 2014-27 I.R.B. 26

2012-46 Superseded by Rev. Proc. 2014-26, 2014-27 I.R.B. 41

2014-4 Amplified by Rev. Proc. 2014-40, 2014-30 I.R.B. 229

2014-5 Amplified by Rev. Proc. 2014-40, 2014-30 I.R.B. 229

2014-8 Amplified by Rev. Proc. 2014-40, 2014-30 I.R.B. 229

2014-9 Amplified by Rev. Proc. 2014-40, 2014-30 I.R.B. 229

2014-10 Amplified by Rev. Proc. 2014-40, 2014-30 I.R.B. 229

2014-13 Modified by Rev. Proc. 2014-38, 2014-29 I.R.B. 132

2014-13 Superseded by Rev. Proc. 2014-38, 2014-29 I.R.B. 132

2014-16 Superseded by Rev. Proc. 2014-51, 2014-37 I.R.B. 543

2014-16 Modified by Rev. Proc. 2014-51, 2014-37 I.R.B. 543

Revenue Rulings:

2008-40 Modified by Rev. Rul. 2014-24, 2014-37 I.R.B. 529

2011-1 Modified by Rev. Rul. 2014-24, 2014-37 I.R.B. 529

2012-6 Modified by Rev. Rul. 2014-24, 2014-37 I.R.B. 529

Notices:

2013-11 Modified by Notice 2014-48, 2014-36 I.R.B. 523

2013-23 Modified by Notice 2014-48, 2014-36 I.R.B. 523

2013-28 Modified by Notice 2014-48, 2014-36 I.R.B. 523

2013-29 Modified by Notice 2014-46, 2014-36 I.R.B. 520

2013-29 Clarified by Notice 2014-46, 2014-36 I.R.B. 520

2013-32 Modified by Notice 2014-48, 2014-36 I.R.B. 523

2013-37 Modified by Notice 2014-48, 2014-36 I.R.B. 523

2013-51 Obsoleted by Notice 2014-42, 2014-34 I.R.B. 387

2013-60 Modified by Notice 2014-46, 2014-36 I.R.B. 520

2013-60 Clarified by Notice 2014-46, 2014-36 I.R.B. 520

2014-44 Supplemented by Notice 2014-45, 2014-34 I.R.B. 388

Treasury Decisions:

2005-47 Obsoleted by T.D. 9668 2014-27 I.R.B. 1

2010-51 Obsoleted by T.D. 9684 2014-33 I.R.B. 345

2010-71 Obsoleted by T.D. 9684 2014-33 I.R.B. 345

2011-6 Obsoleted by T.D. 9684 2014-33 I.R.B. 345

2011-9 Obsoleted by T.D. 9684 2014-33 I.R.B. 345

1A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2014–01 through 2014–26 is in Internal Revenue Bulletin 2014–26, dated June 30, 2014.

Bulletin No. 2014–39 iii September 22, 2014

Internal Revenue Bulletins 2014–27 through 2014–39

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

AJCA–Section 6707 and the Penalty for Failure to Furnish

Information Regarding Reportable Transactions by Material Advisors (TD 9686) 34, 382 Announcement to Discontinue the Internal Revenue Bulletin

Index (Ann 27) 28, 120 Annual Filing Season Program (RP 42) 29, 193 Disclosure to Census Bureau (REG–120756–13) 31, 252 Disclosure to Census Bureau (TD 9677) 31, 241 Information reporting by passport applicants (TD 9679) 32, 267 Low-Income Housing Tax Credit (RP 52) 38, 560 Procedures to void backup withholding (RP 43) 32, 273 Proposed Regulations:

26 CFR part 301 is amended, section 301.6103(j)(1)–1 is amended, section 301.6103(j)(1)–1T added (REG–120756–13) 31, 252 Regulations Governing Practice Before the Internal Revenue

Service (REG–138367–06) (TD 9668) 27, 1 Regulations:

31 CFR 10.1, revised; 10.3, revised; 10.22, revised; 10.31, revised; 10.35, revised; 10.36, revised; 10.37, revised; 10.52, revised; 10.81, revised; 10.82, revised; 10.91, revised. (TD 9668) 27, 1 26 CFR 301.6109–4, added; 1.6042–4, amended; 1.6043–4, amended; 1.6044–5, amended; 1.6045–2, amended; 1.6045–3, amended; 1.6045–4, amended; 1.6045–5, amended; 1.6049–6, amended; 1.6050A–1, amended; 1.6050E–1, amended; 1.6050N–1, amended; 1.6050P–1, amended; 1.6050S–1, amended; 1.6050S–3, amended (TD 9675) 31, 242 26 CFR part 301 is amended, section 301.6103(j)(1)–1 is amended, section 301.6103(j)(1)–1T added (TD 9677) 31, 241 26 CFR part 301, amended; 26 CFR 301.6039E–1 added (TD 9679) 32, 267 26 CFR 301.6707–1, added; 301.6707–1T, removed; Rev. Proc. 2007–21, sections 4.04, 4.05, and 4.06 superseded; material advisor penalty for failure to furnish information regarding reportable transactions (TD 9686) 34, 382

Substitute Forms Preparation for Certain Information Returns

(RP 27) 27, 41 Substitute Forms Preparation for Certain Information Returns

(RP 44) 32, 274 Truncated Taxpayer Identification Numbers (TD 9675) 31, 242

Group Trusts (RR 24) 37, 529 Individual Retirement Account Rollover Limitations (REG–

209459–78) 31, 253 Longevity Annuity Contracts (TD 9673) 30, 212 Proposed Regulations:

26 CFR 408, Individual Retirement Accounts (REG–209459– 78) 31, 253 Regulations:

26 CFR 54.9815–2708, as amended (TD 9671) 29, 174 26 CFR 1.401(a)(9)–5, amended; 1.401(a)(9)–6, amended; 1.403(b)–6, amended; 1.408–8, amended; 1.408A–6, amended; 1.6047–2, added (TD 9673) 30, 212 Rules relating to 90 day waiting period limitation (TD 9671) 29, 174 Weighted average interest rates

Segment rates for June 2014 (Notice 41) 27, 97 Segment rates for July 2014 (Notice 43) 31, 249 Segment rates for August 2014 (Notice 48) 36, 523

Extending religious and family member FICA and FUTA excep tions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121 Method of accounting for gains and losses on shares in certain

money market funds; broker returns with respect to sales of shares in money market funds (REG–107012–14) 33, 371 Publications:

1223, General Rules and Specifications for Substitute Forms W–2c and W–3c (RP29) 28, 105 4436, General Rules and Specifications for Substitute Form 941 and Schedule B (Form 941), and Schedule R (RP 26) 27, 26 Summons Interview Regulations Under Section 7602 (REG–

121542–14) (TD 9669) 28, 103 Regulations:

26 CFR 301.7602–1 is amended to add new paragraph (b)(3) pertaining to summons interviews. (TD 9669) 28, 103 26 CFR 1.1361–4, amended; 1.1361–4T, removed; 31.3121(b)(3)–1, amended; 31.3121(b)(3)–1T, removed; 31.3127–1, added; 31.3127–1T, removed; 31.3306(c)(5)–1, amended; 31.3306(c)(5)–1T, removed; 301.7701–2, amended; 301.7701–2T, removed; extending religious and family member FICA and FUTA exceptions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121 26 CFR 1.446–7 added; 1.6045–1 amended; method of accounting for gains and losses on shares in certain money market funds; broker returns with respect to sales of shares in money market funds (REG–107012–14) 33, 371

September 22, 2014 iv Bulletin No. 2014–39

Section 2032A.—Valuation of Certain Farm, Etc., Real Property

(RR 21) 34, 381 Summons Interview Regulations Under Section 7602 (REG–

121542–14) (TD 9669) 28, 103 Regulations:

26 CFR 301.7602–1 is amended to add new paragraph (b)(3) pertaining to summons interviews. (TD 9669) 28, 103

Alternative process for religious objections to providing contracep tive coverage under section 9815 (REG–129507–14) 38, 561 Alternative process for religious objections to providing contra ceptive coverage under section 9815 (TD 9690) 38, 548 Branded Prescription Drug Fee (REG–123286–14) 33, 377 Branded Prescription Drug Fee (TD 9684) 33, 345 Branded Prescription Drug Fee (Notice 42) 34, 387 Definition of �eligible organization� under section 9815, regard ing coverage of preventive services, including contraceptive coverage (REG–129786–14) 38, 562 Extending religious and family member FICA and FUTA excep tions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121 Section 9010 of the ACA; health insurance providers fee (Notice

47. 36, 522 Summons Interview Regulations Under Section 7602 (REG–

121542–14) (TD 9669) 28, 103 Proposed Regulations:

26 CFR 54.9815–2713A is revised; accommodations in connection with coverage of preventive health services under section 9815 (REG–129507–14) 38, 561 26 CFR 54.9815–2713A(a) amended; accommodations in connection with coverage of preventive health services under section 9815 (REG–129786–14) 38, 562 Regulations:

26 CFR 301.7602–1 is amended to add new paragraph (b)(3) pertaining to summons interviews. (TD 9669) 28, 103 26 CFR 1.1361–4, amended; 1.1361–4T, removed; 31.3121(b)(3)–1, amended; 31.3121(b)(3)–1T, removed; 31.3127–1, added; 31.3127–1T, removed; 31.3306(c)(5)–1, amended; 31.3306(c)(5)–1T, removed; 301.7701–2, amended; 301.7701–2T, removed; extending religious and family member FICA and FUTA exceptions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121 26 CFR 54.9815–2708, as amended (TD 9671) 29, 121 26 CFR 51.2(e)(3), amended; (REG–123286–14) 33, 377 26 CFR 54.9815–2713A(b), (c)(1), and (c)(2)(i) introductory text amended; 54.9815–2713A(f) and 54.9815–2713AT added; accommodations in connection with coverage of preventive health services under section 9815 (TD 9690) 38, 548 Rules relating to 90 day waiting period limitation (TD 9671) 29,

121

Streamlined Application for Recognition of Exemption Under

Section 501(c)(3) (RP 2014–40) 30, 229 Streamlined process for 501(c)(3) recognition (REG–110948–

14. 30, 225 Streamlined process for 501(c)(3) recognition (TD 9674) 30, 225 Regulations:

26 CFR 1.501(c)–1 amended 1. 501(a)–1T added; 1.501(c)(3)–1 amended, 1.501(c)(3)–1T added; and 1.508–1 amended, 1.508–1T added (REG–110948–14)(TD 9674) 30, 225

Summons Interview Regulations Under Section 7602 (REG–

121542–14) (TD 9669) 28, 103 Regulations:

26 CFR 301.7602–1 is amended to add new paragraph (b)(3) pertaining to summons interviews (REG–121542–14) (TD 9669) 28, 103

Accounting method change, retail inventory method (RP 48) 36, 132 AJCA–Section 6707 and the Penalty for Failure to Furnish

Information Regarding Reportable Transactions by Material Advisors (TD 9686) 34, 382 Allocation and Apportionment of Interest Expense (TD 9676) 32, 260 Awards for Information Relating to Detecting Underpayments of

Tax or Violations of the Internal Revenue Laws (TD 9687) 36, 486 Basis of indebtedness of S corporations to their shareholders (TD

9682. 33, 342 Credit for carbon dioxide Sequestration (Notice 40) 27, 100 Debt that is a position in personal property that is part of a

straddle (TD 9691) 38, 547 Disciplinary actions involving attorneys, certified public accoun tants, enrolled agents, and enrolled actuaries, enrolled retirement plan agents, and appraisers (ANN 29) 35, 452 Disclosure to Census Bureau (REG–120756–13) 31, 252 Disclosure to Census Bureau (TD 9677) 31, 241 Dispositions of property subject to depreciation under section

168 (TD 9689) 36, 456 FFI Agreement for Participating FFI and Reporting Model 2 FFI

(RP 38) 29, 132 Foreign Earned Income Exclusion (Ann 2014–28) 34, 391 Foreign tax credit guidance under section 901 (m) (Notice 44) 32, 391 Foreign tax credit guidance under section 901 (m) (Notice 45)

34, 270 Information reporting by passport applicants (TD 9679) 32, 267 Insurance; effectively connected income (RP 53) 39, 573 Interest:

Investment:

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

2014 (RR 20) 28, 101 Federal short-term, mid-term, and long-term rates for: Au gust 2014 (RR 19) 32, 266 Federal short-term, mid-term, and long-term rates for: Sep tember 2014 (RR 22) 37, 533

Bulletin No. 2014–39 v September 22, 2014

Money market funds and the wash sale rules (RP 45) 34, 388 Premium Tax Credit (REG–104579–13) 33, 370 Premium Tax Credit (RP 37) 33, 363 Premium Tax Credit (RP 41) 33, 364 Premium Tax Credit (TD 9683) 33, 330 Production Tax Credit, Investment Tax Credit, Beginning of

Construction (Notice 46) 36, 520 Proposed Regulations:

26 CFR part 301 is amended, section 301.6103(j)(1)–1 is amended, section 301.6103(j)(1)–1T added (REG– 120756–13) 31, 252 26 C.F.R. 1.382–3(j)(17), modified; 1.382–3T(j)(17), added, segregation rules for public groups of shareholders (REG– 105067–14) 34, 391 Publications:

1223, General Rules and Specifications for Substitute Forms W–2c and W–3c (RP 29) 28, 105 4436, General Rules and Specifications for Substitute Form 941 and Schedule B (Form 941), and Schedule R (RP 26) 27, 26 Qualified Intermediary (QI) Agreement (RP 39) 29, 151 Qualified residential rental projects (RP–105272–13) (RP 50) 37, 540 Regulations:

31 CFR 10.1, revised; 10.3, revised; 10.22, revised; 10.31, revised; 10.35, revised; 10.36, revised; 10.37, revised; 10.52, revised; 10.81, revised; 10.82, revised; 10.91, revised (TD 9668) 27, 1 26 CFR 301.7602–1 is amended to add new paragraph (b)(3) pertaining to summons interviews (REG–121542–14) (TD 9669) 28, 103 26 CFR 1.45R–0, added; 1.45R–1, added; 1.45R–2, added; 1.45R–3, added; 1.45R–4, added; 1.45R–5, added; tax credit for employee health insurance expenses of small employers (TD 9672) 30, 196 26 CFR 301.6109–4, added; 1.6042–4, amended; 1.6043–4, amended; 1.6044–5, amended; 1.6045–2, amended; 1.6045–3, amended; 1.6045–4, amended; 1.6045–5, amended; 1.6049–6, amended; 1.6050A–1, amended; 1.6050E–1, amended; 1.6050N–1, amended; 1.6050P–1, amended; 1.6050S–1, amended; 1.6050S–3, amended (TD 9675) 31, 242 26 CFR 1.67–4, amended (TD 9667) 32, 254 26 CFR part 301 is amended, section 301.6103(j)(1)–1 is amended, section 301.6103(j)(1)–1T added (TD 9677) 31, 241 26 CFR 1.861–9 amended, 1.861–11 amended; (TD 9676) 32, 260 26 CFR 1.1092(b)–6, added; 1.1092(b)–6T, removed; 1.1092(b)–3T, amended; (TD 9678) 32, 262 26 CFR part 301, amended; 26 CFR 301.6039E–1 added (TD 9679) 32, 267 26 CFR 1.174–2 amended; (TD 9680) 32, 254 26 CFR 1.36B–2T, 26 CFR 1.36B–3T, 1.36B–4T, added; 26 CFR 1.36B–2, 26 CFR 1.36B–3, 1.36B–4, amended; 26 CFR 1.162(l)–1 and 26 CFR 1.162(l)–1T, added. (REG– 104579–13) 33, 370

26 CFR 1.195–2, added; 26 CFR 1.708–1, amended; 26 CFR 1.709–1, amended. (TD 9681) 33, 340 26 CFR 1.1366–2(a), added new paragraph (a)(2) and moved current (a)(2) through (a)(6) to (a)(3) through (a)(7), respectively; basis of indebtedness of S corporations to their shareholders (TD 9682) 33, 342 26 CFR 1.36B–2T, 26 CFR 1.36B–3T, 1.36B–4T added, 26 CFR 1.36B–2, 26 CFR 1.36B–3, 1.36B–4, amended, 26 CFR 1.162(l)–1 and 26 CFR 1.162(l)–1T added, (TD 9683) 33, 330 26 C.F.R. 1.382–3(j)(17), modified; 1.382–3T(j)(17), added, segregation rules for public groups of shareholders (TD 9685) 34, 379 26 CFR 301.6707–1, added; 301.6707–1T, removed; Rev. Proc. 2007–21, sections 4.04, 4.05, and 4.06 superseded; material advisor penalty for failure to furnish information regarding reportable transactions (TD 9686) 34, 382 26 CFR 301.7623–1, revised; 26 CFR 301.7623–4, added; 26 CFR 301.7623–2, added; 26 CFR 301.6103(h)(4)–1, added 26 CFR 301.7623–3, added; (TD 9687) 36, 486 26 CFR 1.471–8 amended (TD 9688) 36, 482 26 CFR 1.168(i)–8 added; 1.165–2, 1.168(i)–0, 1.168(i)–1, 1.168(i)–7, 1.263(a)–3, 1.1016–3 amended; 1.168(i)–0T, 1.168(i)–1T, 1.168(i)–8T removed; dispositions of property subject to depreciation under section 168 (TD 9689) 36, 456 26 CFR 1.1092(d)–1, amended; 1.1092(d)–1T, removed; debt that is a position in personal property that is part of a straddle (TD 9691) 38, 547 Regulations Governing Practice Before the Internal Revenue

Service (REG–138367–06) (TD 9668) 27, 1 REIT Distressed Debt (RP 51) 37, 543 Research and experimental expenditures (TD 9680) 32, 254 Retail inventory method (TD 9688) 36, 482 Tax Credit for Employee Health Insurance Expenses of Small

Employers (TD 9672) 30, 196 Temporary relief from certain requirements of § 42 (Rev. Proc.

2014–39) (RP 49) 37, 535 Truncated Taxpayer Identification Numbers (TD 9675) 31, 242 Section 67 Limitations on Estates or Trusts; Change of Effective

Date (TD 9664) 32, 254 Section 5000A national average premium for a bronze level of

coverage (RP 46) 33, 367 Segregation rules for public groups of shareholders, (REG–

105067–14) 34, 391 Segregation rules for public groups of shareholders, (TD 9685)

34, 379 Substitute Forms Preparation for Certain Information Returns

(RP 27) 27, 379 Substitute Forms Preparation for Certain Information Returns

(RP 44) 32, 41 Summons Interview Regulations Under Section 7602 (REG–

121542–14) (TD 9669) 28, 103 Unamortized organization and syndication expenses following a

partnership technical termination (TD 9681) 33, 340

September 22, 2014 vi Bulletin No. 2014–39

Underpayment and overpayments, quarter beginning: July 1,

2014 (RR 14) 27, 12 Unrealized gain or loss treatment upon establishment of an

identified mixed straddle (TD 9678) 32, 262 Withholding Foreign Partnership and Trust Agreements (RP 47)

35, 393

Extending religious and family member FICA and FUTA excep tions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121 Regulations:

26 CFR 1.1361–4, amended; 1.1361–4T, removed; 31.3121(b)(3)–1, amended; 31.3121(b)(3)–1T, removed; 31.3127–1, added; 31.3127–1T, removed; 31.3306(c)(5)–1, amended; 31.3306(c)(5)–1T, removed; 301.7701–2, amended; 301.7701–2T, removed; extending religious and family member FICA and FUTA exceptions to disregarded entities; regulations regarding the indoor tanning services excise tax and disregarded entities (TD 9670) 29, 121

Annual Filing Season Program (RP 42) 29, 193 Procedures to Avoid Backup Withholding (RP 43) 32, 273

Bulletin No. 2014–39 vii September 22, 2014

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.

Internal Revenue Bulletins are available annually as part of Publication 1796 (Tax Products CD-ROM). The CD-ROM can be purchased from National Technical Information Service (NTIS) on the Internet at www.irs.gov/cdorders (discount for online orders) or by calling 1-877-233-6767. The first release is available in mid-December and the final release is available in late January.

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.