Internal Revenue Bulletin 2021-20

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb21-20.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.

This Announcement is being issued to provide notification to all consumers of the Internal Revenue Bulletin, that there were no articles submitted for publication in IRB 2021-20, dated Monday, May 17, 2021.

Finding Lists begin on page ii.

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 Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.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.

May 17, 2021 Bulletin No. 2021–20

This Announcement is being issued to provide notification to all consumers of the Internal Revenue Bulletin, that there were no articles submitted for publication in IRB 2021-20, dated Monday, May 17, 2021.

Bulletin No. 2021–20 1155 May 17, 2021

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.

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.

where a ruling mentions a previously pub- the 1986 Code and regulations the same Suspended is used in rare situations to lished ruling and points out an essential position published under the 1939 Code show that the previous published rulings difference between them. and regulations. The term is also used will not be applied pending some future

Modified is used where the substance when it is desired to republish in a single action such as the issuance of new or of a previously published position is being ruling a series of situations, names, etc., amended regulations, the outcome of caschanged. Thus, if a prior ruling held that a that were previously published over a es in litigation, or the outcome of a Serprinciple applied to A but not to B, and the period of time in separate rulings. If the vice study.

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

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.

Bulletin No. 2021–20 i May 17, 2021

Numerical Finding List ¹

Bulletin 2021–20

AOD:

2021-1, 2021-15 I.R.B. 985

Announcements:

2021-01, 2021-04 I.R.B. 506 2021-02, 2021-08 I.R.B. 892 2021-03, 2021-08 I.R.B. 892 2021-04, 2021-09 I.R.B. 895 2021-05, 2021-13 I.R.B. 965 2021-06, 2021-15 I.R.B. 1011 2021-07, 2021-15 I.R.B. 1061 2021-08, 2021-18 I.R.B. 1146 2021-09, 2021-20 I.R.B. 1155

Notices:

2021-01, 2021-02 I.R.B. 315 2021-03, 2021-02 I.R.B. 316 2021-04, 2021-02 I.R.B. 319 2021-02, 2021-03 I.R.B. 478 2021-05, 2021-03 I.R.B. 479 2021-07, 2021-03 I.R.B. 482 2021-09, 2021-05 I.R.B. 678 2021-06, 2021-06 I.R.B. 822 2021-08, 2021-06 I.R.B. 823 2021-11, 2021-06 I.R.B. 827 2021-12, 2021-06 I.R.B. 828 2021-13, 2021-06 I.R.B. 832 2021-10, 2021-07 I.R.B. 888 2021-15, 2021-10 I.R.B. 898 2021-16, 2021-10 I.R.B. 907 2021-18, 2021-11 I.R.B. 911 2021-19, 2021-11 I.R.B. 920 2021-20, 2021-11 I.R.B. 922 2021-17, 2021-14 I.R.B. 984 2021-21, 2021-15 I.R.B. 986 2021-22, 2021-15 I.R.B. 987 2021-23, 2021-16 I.R.B. 1113 2021-25, 2021-17 I.R.B. 1118 2021-24, 2021-18 I.R.B. 1122 2021-27, 2021-18 I.R.B. 1125 2021-28, 2021-18 I.R.B. 1130 2021-29, 2021-19 I.R.B. 1149 2021-30, 2021-19 I.R.B. 1149

Proposed Regulations:

REG-130081-19, 2021-02 I.R.B. 321 REG-114615-16, 2021-03 I.R.B. 489 REG-111950-20, 2021-05 I.R.B. 683 REG-115057-20, 2021-05 I.R.B. 714 REG-121095-19, 2021-18 I.R.B. 1131

Revenue Procedures:

2021-01, 2020-01 I.R.B. 1 2021-02, 2020-01 I.R.B. 116 2021-03, 2020-01 I.R.B. 140 2021-04, 2020-01 I.R.B. 157 2021-05, 2020-01 I.R.B. 250 2021-07, 2020-01 I.R.B. 290 2021-09, 2020-03 I.R.B. 485 2021-08, 2020-04 I.R.B. 502 2021-10, 2020-04 I.R.B. 503 2021-12, 2020-05 I.R.B. 681 2021-11, 2020-06 I.R.B. 833 2021-15, 2020-08 I.R.B. 891 2021-17, 2020-15 I.R.B. 991 2021-18, 2020-15 I.R.B. 1007 2021-19, 2020-15 I.R.B. 1008 2021-21, 2020-17 I.R.B. 1118 2021-20, 2020-19 I.R.B. 1150 2021-20, 2020-23 I.R.B. 1153

Revenue Rulings:

2021-01, 2021-02 I.R.B. 294 2021-02, 2021-04 I.R.B. 495 2021-03, 2021-05 I.R.B. 674 2021-04, 2021-06 I.R.B. 724 2021-05, 2021-10 I.R.B. 896 2021-06, 2021-12 I.R.B. 946 2021-07, 2021-14 I.R.B. 982 2021-08, 2021-18 I.R.B. 1120

Treasury Decisions:

9925, 2021-02 I.R.B. 296 9940, 2021-02 I.R.B. 311 9932, 2021-03 I.R.B. 345 9939, 2021-03 I.R.B. 376 9941, 2021-03 I.R.B. 396 9942, 2021-03 I.R.B. 450 9937, 2021-04 I.R.B. 495 9936, 2021-05 I.R.B. 508 9943, 2021-05 I.R.B. 577 9945, 2021-05 I.R.B. 627 9946, 2021-06 I.R.B. 726 9947, 2021-06 I.R.B. 748 9948, 2021-06 I.R.B. 801 9938, 2021-07 I.R.B. 838 9944, 2021-16 I.R.B. 1062

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2020.

May 17, 2021 ii Bulletin No. 2021–20

Finding List of Current Actions on Previously Published Items ¹

Bulletin 2021–20

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin 2020–52, dated December 27, 2020.

Bulletin No. 2021–20 iii May 17, 2021

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