# Bulletin No. 2023–14

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3Aa1bb53e777eeb738

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

HIGHLIGHTS
OF THIS ISSUE




Bulletin No. 2023–14
April 3, 2023

These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.

EMPLOYEE PLANS

INCOME TAX

Notice 2023-25, page 629.

Rev. Rul. 2023-6, page 627.

This notice sets forth updates on the corporate bond
monthly yield curve, the corresponding spot segment rates
for March 2023 used under § 417(e)(3)(D), the 24-month
average segment rates applicable for March 2023, and the
30-year Treasury rates, as reflected by the application of §
430(h)(2)(C)(iv).

EXEMPT ORGANIZATIONS
Announcement 2023-8, page 632.
Revocation of IRC 501(c)(3) Organizations for failure to
meet the code section requirements. Contributions made to
the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).

Finding Lists begin on page ii.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for April 2023.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.

Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede,
revoke, modify, or amend any of those previously published
in the Bulletin. All published rulings apply retroactively unless
otherwise indicated. Procedures relating solely to matters
of internal management are not published; however, statements of internal practices and procedures that affect the
rights and duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.

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.

April 3, 2023 

Bulletin No. 2023–14

Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7872.)

Rev. Rul. 2023-6
This revenue ruling provides various
prescribed rates for federal income tax

Annual
AFR
110% AFR
120% AFR
130% AFR

4.86%
5.35%
5.84%
6.34%

AFR
110% AFR
120% AFR
130% AFR
150% AFR
175% AFR

4.15%
4.57%
4.99%
5.41%
6.27%
7.32%

AFR
110% AFR
120% AFR
130% AFR

4.02%
4.43%
4.84%
5.24%

Short-term adjusted AFR
Mid-term adjusted AFR
Long-term adjusted AFR

Bulletin No. 2023–14

purposes for April 2023 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable federal rates (AFR) for the current month
for purposes of section 1274(d) of the
Internal Revenue Code. Table 2 contains
the short-term, mid-term, and longterm adjusted applicable federal rates
(adjusted AFR) for the current month
for purposes of section 1288(b). Table
3 sets forth the adjusted federal longterm rate and the long-term tax-exempt
rate described in section 382(f). Table
4 contains the appropriate percentages

for determining the low-income housing credit described in section 42(b)(1)
for buildings placed in service during
the current month. However, under
section 42(b)(2), the applicable percentage for non-federally subsidized
new buildings placed in service after
July 30, 2008, shall not be less than
9%. Finally, Table 5 contains the federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.

REV. RUL. 2023-6 TABLE 1
Applicable Federal Rates (AFR) for April 2023
Period for Compounding
Semiannual
Quarterly
Short-term
4.80%
4.77%
5.28%
5.25%
5.76%
5.72%
6.24%
6.19%
Mid-term
4.11%
4.09%
4.52%
4.49%
4.93%
4.90%
5.34%
5.30%
6.17%
6.12%
7.19%
7.13%
Long-term
3.98%
3.96%
4.38%
4.36%
4.78%
4.75%
5.17%
5.14%

Annual
3.67%
3.14%
3.04%

REV. RUL. 2023-6 TABLE 2
Adjusted AFR for April 2023
Period for Compounding
Semiannual
3.64%
3.12%
3.02%

627

Quarterly
3.62%
3.11%
3.01%

Monthly
4.75%
5.22%
5.69%
6.16%
4.08%
4.48%
4.88%
5.28%
6.09%
7.08%
3.95%
4.34%
4.73%
5.12%

Monthly
3.61%
3.10%
3.00%

April 3, 2023

REV. RUL. 2023-6 TABLE 3
Rates Under Section 382 for April 2023
Adjusted federal long-term rate for the current month
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)

3.04%
3.04%

REV. RUL. 2023-6 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for April 2023
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July
30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit
7.95%
Appropriate percentage for the 30% present value low-income housing credit
3.41%
REV. RUL. 2023-6 TABLE 5
Rate Under Section 7520 for April 2023
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a
remainder or reversionary interest

Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of April 2023. See Rev.
Rul. 2023-6, page 627.

Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of April 2023. See Rev. Rul.
2023-6, page 627.

Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

5.00%

Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term,
mid-term, and long-term rates are set forth for the
month of April 2023. See Rev. Rul. 2023-6, page
627.

Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of April 2023. See Rev. Rul.
2023-6, page 627.

Section 7872.—Treatment
of Loans With BelowMarket Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
April 2023. See Rev. Rul. 2023-6, page 627.

April 3, 2023

628

Bulletin No. 2023–14

Part III
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2023-25
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest rate on 30-year Treasury securities
under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to single-employer plans (except for CSEC plans
under § 414(y)) pursuant to § 412. Section

Applicable Month
March 2023

430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under
this provision, present value is generally
determined using three 24-month average
interest rates (“segment rates”), each of
which applies to cash flows during specified periods. To the extent provided under
§ 430(h)(2)(C)(iv), these segment rates
are adjusted by the applicable percentage
of the 25-year average segment rates for
the period ending September 30 of the
year preceding the calendar year in which
the plan year begins.1 However, an election may be made under § 430(h)(2)(D)
(ii) to use the monthly yield curve in place
of the segment rates.
Notice 2007-81, 2007-44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Consistent with the methodology specified in
Notice 2007-81, the monthly corporate
bond yield curve derived from February
2023 data is in Table 2023-2 at the end
of this notice. The spot first, second, and

third segment rates for the month of February 2023 are, respectively, 4.99, 5.12,
and 4.96.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant
to § 430(h)(2)(C)(iv) to be within the
applicable minimum and maximum percentages of the corresponding 25-year
average segment rates. For this purpose,
any 25-year average segment rate that is
less than 5% is deemed to be 5%. The
25-year average segment rates for plan
years beginning in 2022 and 2023 were
published in Notice 2021-54, 2021-41
I.R.B. 457 and Notice 2022-40, 2022-40
I.R.B. 266, respectively. The applicable
minimum and maximum percentages are
95% and 105% for a plan year beginning
in 2022 or 2023.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for March
2023 without adjustment for the 25-year
average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment
First Segment
Second Segment
2.50
3.83

The adjusted 24-month average segment rates set forth in the chart below reflect
§ 430(h)(2)(C)(iv) of the Code. The

24-month averages applicable for March
2023, adjusted to be within the applicable
minimum and maximum percentages of

Third Segment
4.06

the corresponding 25-year average segment rates in accordance with § 430(h)(2)
(C)(iv) of the Code, are as follows:

Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning In

Applicable Month

First Segment

Second Segment

Third Segment

2022

March 2023

4.75

5.18

5.92

2023

March 2023

4.75

5.00

5.74

30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum funding requirements that apply

to multiemployer plans pursuant to §
412. Section 431(c)(6)(B) specifies a
minimum amount for the full-funding limitation described in § 431(c)(6)
(A), based on the plan’s current liabil-

ity. Section 431(c)(6)(E)(ii)(I) provides
that the interest rate used to calculate
current liability for this purpose must
be no more than 5 percent above and
no more than 10 percent below the

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
1

Bulletin No. 2023–14

629

April 3, 2023

weighted average of the rates of interest
on 30-year Treasury securities during
the four-year period ending on the last
day before the beginning of the plan
year. Notice 88-73, 1988-2 C.B. 383,
provides guidelines for determining the

weighted average interest rate. The rate
of interest on 30-year Treasury securities for February 2023 is 3.80 percent.
The Service determined this rate as
the average of the daily determinations
of yield on the 30-year Treasury bond

maturing in November 2052. For plan
years beginning in March 2023, the
weighted average of the rates of interest
on 30-year Treasury securities and the
permissible range of rates used to calculate current liability are as follows:

For Plan Years Beginning In

Treasury Weighted Average Rates
30-Year Treasury Weighted Average

Permissible Range 90% to 105%

March 2023

2.53

2.27 to 2.65

under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007-81 provides guidelines for determining the minimum

present value segment rates. Pursuant to
that notice, the minimum present value
segment rates determined for February
2023 are as follows:

MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates

Month
February 2023

Minimum Present Value Segment Rates
First Segment
Second Segment
4.99
5.12

DRAFTING INFORMATION
The principal author of this notice
is Tom Morgan of the Office of Associ-

April 3, 2023

ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development

630

Third Segment
4.96

of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Tony Montanaro at
626-927-1475 (not toll-free numbers).

Bulletin No. 2023–14

Table 2023-2
Monthly Yield Curve for February 2023
Derived from February 2023 Data
Maturity
0.5
1.0
1.5
2.0
2.5
3.0
3.5
4.0
4.5
5.0
5.5
6.0
6.5
7.0
7.5
8.0
8.5
9.0
9.5
10.0
10.5
11.0
11.5
12.0
12.5
13.0
13.5
14.0
14.5
15.0
15.5
16.0
16.5
17.0
17.5
18.0
18.5
19.0
19.5
20.0

Yield
5.18
5.15
5.12
5.07
5.01
4.95
4.90
4.86
4.83
4.82
4.83
4.85
4.88
4.91
4.95
4.99
5.03
5.06
5.10
5.13
5.15
5.18
5.20
5.21
5.22
5.23
5.24
5.24
5.24
5.23
5.23
5.22
5.21
5.20
5.19
5.18
5.17
5.16
5.15
5.14

Maturity
20.5
21.0
21.5
22.0
22.5
23.0
23.5
24.0
24.5
25.0
25.5
26.0
26.5
27.0
27.5
28.0
28.5
29.0
29.5
30.0
30.5
31.0
31.5
32.0
32.5
33.0
33.5
34.0
34.5
35.0
35.5
36.0
36.5
37.0
37.5
38.0
38.5
39.0
39.5
40.0

Bulletin No. 2023–14

Yield
5.13
5.12
5.11
5.10
5.09
5.08
5.07
5.07
5.06
5.05
5.04
5.04
5.03
5.03
5.02
5.02
5.01
5.01
5.00
5.00
5.00
4.99
4.99
4.98
4.98
4.98
4.97
4.97
4.97
4.97
4.96
4.96
4.96
4.95
4.95
4.95
4.95
4.94
4.94
4.94

Maturity
40.5
41.0
41.5
42.0
42.5
43.0
43.5
44.0
44.5
45.0
45.5
46.0
46.5
47.0
47.5
48.0
48.5
49.0
49.5
50.0
50.5
51.0
51.5
52.0
52.5
53.0
53.5
54.0
54.5
55.0
55.5
56.0
56.5
57.0
57.5
58.0
58.5
59.0
59.5
60.0

Yield
4.94
4.94
4.93
4.93
4.93
4.93
4.93
4.92
4.92
4.92
4.92
4.92
4.92
4.91
4.91
4.91
4.91
4.91
4.91
4.91
4.90
4.90
4.90
4.90
4.90
4.90
4.90
4.89
4.89
4.89
4.89
4.89
4.89
4.89
4.89
4.89
4.88
4.88
4.88
4.88

631

Maturity
60.5
61.0
61.5
62.0
62.5
63.0
63.5
64.0
64.5
65.0
65.5
66.0
66.5
67.0
67.5
68.0
68.5
69.0
69.5
70.0
70.5
71.0
71.5
72.0
72.5
73.0
73.5
74.0
74.5
75.0
75.5
76.0
76.5
77.0
77.5
78.0
78.5
79.0
79.5
80.0

Yield
4.88
4.88
4.88
4.88
4.88
4.88
4.88
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.87
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.86
4.85
4.85
4.85
4.85
4.85

Maturity
80.5
81.0
81.5
82.0
82.5
83.0
83.5
84.0
84.5
85.0
85.5
86.0
86.5
87.0
87.5
88.0
88.5
89.0
89.5
90.0
90.5
91.0
91.5
92.0
92.5
93.0
93.5
94.0
94.5
95.0
95.5
96.0
96.5
97.0
97.5
98.0
98.5
99.0
99.5
100.0

Yield
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.85
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.84
4.83

April 3, 2023

Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2023-8
Table of Contents
The Internal Revenue Service has
revoked its determination that the
organizations listed below qualify as organizations described in sections 501(c)(3)
and 170(c)(2) of the Internal Revenue
Code of 1986.

NAME OF ORGANIZATION

Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not precluded
from disallowing a deduction for any
contributions made after an organization
ceases to qualify under section 170(c)(2)
if the organization has not timely filed a
suit for declaratory judgment under section 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.

Effective Date of
Revocation

Mama Friends of Earth
APHA Zone 5 Coordinating Committee
Neilia LaValle Philanthropies

April 3, 2023

1/1/2019
1/1/2018
5/1/2018

632

If on the other hand a suit for declaratory judgment has been timely filed,
contributions from individuals and organizations described in section 170(c)(2)
that are otherwise allowable will continue
to be deductible. Protection under section
7428(c) would begin on April 3, 2023 and
would end on the date the court first determines the organization is not described
in section 170(c)(2) as more particularly
set for in section 7428(c)(1). For individual contributors, the maximum deduction
protected is $1,000, with a husband and
wife treated as one contributor. This benefit is not extended to any individual, in
whole or in part, for the acts or omissions
of the organization that were the basis for
revocation.

LOCATION
Phoenixville, PA
Altoona, IA
Huntington Beach, CA

Bulletin No. 2023–14

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
­effect:
Amplified describes a situation where
no change is being made in a prior published position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is being made clear because the language has
caused, or may cause, some confusion. It
is not used where a position in a prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously published ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the

new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cases in litigation, or the outcome of a Service study.

Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.

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

Bulletin No. 2023–14

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.

i

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.

April 3, 2023

Numerical Finding List1
Bulletin 2023–14

Announcements:
2023-2, 2023-2 I.R.B. 344
2023-1, 2023-3 I.R.B. 422
2023-3, 2023-5 I.R.B. 447
2023-4, 2023-7 I.R.B. 470
2023-5, 2023-9 I.R.B. 499
2023-6, 2023-9 I.R.B. 501
2023-8, 2023-14 I.R.B. 632

AOD:
2023-1, 2023-10 I.R.B. 502
2023-2, 2023-11 I.R.B. 529

Notices:
2023-4, 2023-2 I.R.B. 321
2023-5, 2023-2 I.R.B. 324
2023-6, 2023-2 I.R.B. 328
2023-8, 2023-2 I.R.B. 341
2023-1, 2023-3 I.R.B. 373
2023-2, 2023-3 I.R.B. 374
2023-3, 2023-3 I.R.B. 388
2023-7, 2023-3 I.R.B. 390
2023-9, 2023-3 I.R.B. 402
2023-10, 2023-3 I.R.B. 403
2023-11, 2023-3 I.R.B. 404
2023-12, 2023-6 I.R.B. 450
2023-13, 2023-6 I.R.B. 454
2023-16, 2023-8 I.R.B. 479
2023-17, 2023-10 I.R.B. 505
2023-18, 2023-10 I.R.B. 508
2023-20, 2023-10 I.R.B. 523
2023-19, 2023-11 I.R.B. 560
2023-21, 2023-11 I.R.B. 563
2023-22, 2023-12 I.R.B. 569
2023-23, 2023-13 I.R.B. 571
2023-24, 2023-13 I.R.B. 571
2023-26, 2023-13 I.R.B. 577
2023-25, 2023-14 I.R.B. 629

Revenue Procedures:—Continued
2023-8, 2023-3 I.R.B. 407
2023-10, 2023-3 I.R.B. 411
2023-11, 2023-3 I.R.B. 417
2023-14, 2023-6 I.R.B. 466
2023-9, 2023-7 I.R.B. 471
2023-13, 2023-13 I.R.B. 581
2023-17, 2023-13 I.R.B. 604
2023-18, 2023-13 I.R.B. 605
2023-19, 2023-13 I.R.B. 626

Revenue Rulings:
2023-1, 2023-2 I.R.B. 309
2023-3, 2023-6 I.R.B. 448
2023-4, 2023-9 I.R.B. 480
2023-5, 2023-10 I.R.B. 503
2023-6, 2023-14 I.R.B. 627

Treasury Decisions:
9970, 2023-2 I.R.B. 311
9771, 2023-3 I.R.B. 346
9772, 2023-11 I.R.B. 530
9773, 2023-11 I.R.B. 557

Proposed Regulations:
REG-100442-22, 2023-3 I.R.B. 423
REG-146537-06, 2023-3 I.R.B. 436
REG-114666-22, 2023-4 I.R.B. 437
REG 122286-18, 2023-11 I.R.B. 565

Revenue Procedures:
2023-1, 2023-1 I.R.B. 1
2023-2, 2023-1 I.R.B. 120
2023-3, 2023-1 I.R.B. 144
2023-4, 2023-1 I.R.B. 162
2023-5, 2023-1 I.R.B. 265
2023-7, 2023-1 I.R.B. 305
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin
2022–52, dated December 27, 2022.
1

April 3, 2023

ii

Bulletin No. 2023–14

Finding List of Current Actions on
Previously Published Items1
Bulletin 2023–14

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2022–27 through 2022–52 is in Internal Revenue Bulletin
2022–52, dated December 27, 2022.
1

Bulletin No. 2023–14

iii

April 3, 2023

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Aa1bb53e777eeb738. Public record. Not legal advice.