HIGHLIGHTS Bulletin No. 2016–16 OF THIS ISSUE

1 HIGHLIGHTSOF THIS ISSUET hese synopses are intended only as aids to the reader inidentifying the subject matter covered. They may not berelied upon as authoritative TAXA nnouncement 2016 12, page Announcement is issued pursuant to 521(b) of Pub. 170, the Ticket to Work and Work Incentives Improve-ment Act of 1999, which requires the Secretary of the Trea-sury to report annually to the public concerning advance pric-ing agreements (APAs) and the Advance Pricing and MutualAgreement Program (APMA Program), formerly known as theAdvance Pricing Agreement Program (APA Program).

2 The firstreport covered calendar years 1991 through 1999. Subse-quent reports covered each calendar year 2000 through 2014separately. This seventeenth report describes the experience,structure, and activities of the APMA Program during calendaryear 2015. It does not provide guidance regarding the appli-cation of the arm s length Proc. 2016 23, page revenue procedure provides the depreciation deductionlimitations for owners of passenger automobiles (includingtrucks and vans) first placed in service during calendar year2016 and amounts to be included in income by lessees ofpassenger automobiles first leased during calendar year revenue procedure also provides revised tables of depre-ciation limitations and lessee inclusion amounts for passengerautomobiles first placed in service or first leased during 2015and to which the 50 percent additional first year depreciationdeduction TAXREG 103380 05.

3 Page proposed regulations provide guidance on the manufac-turers tax on tires and the retail tax on tractors, trucks, andtrailers under sections 4051, 4052, 4071 and 4072 of theCode. These proposed regulations would also replace most ofthe temporary section 145 regulations and reflect statutorychanges and court Relating to Court Decisions is on the page following the Lists begin on page No. 2016 16 April 18, 2016 The IRS MissionProvide America s taxpayers top-quality service by helpingthem understand and meet their tax responsibilities and en-force the law with integrity and fairness to internal revenue Bulletin is the authoritative instrument ofthe Commissioner of internal revenue for announcing officialrulings and procedures of the internal revenue Service and forpublishing Treasury Decisions, Executive Orders, Tax Conven-tions, legislation, court decisions.

4 And other items of generalinterest. It is published is the policy of the Service to publish in the Bulletin allsubstantive rulings necessary to promote a uniform applicationof the tax laws, including all rulings that supersede, revoke,modify, or amend any of those previously published in theBulletin. All published rulings apply retroactively unless other-wise indicated. Procedures relating solely to matters of internalmanagement are not published; however, statements of inter-nal practices and procedures that affect the rights and dutiesof taxpayers are rulings represent the conclusions of the Service onthe application of the law to the pivotal facts stated in therevenue ruling.

5 In those based on positions taken in rulings totaxpayers or technical advice to Service field offices, identify-ing details and information of a confidential nature are deletedto prevent unwarranted invasions of privacy and to comply withstatutory and procedures reported in the Bulletin do not have theforce and effect of Treasury Department Regulations, but theymay be used as precedents. Unpublished rulings will not berelied on, used, or cited as precedents by Service personnel inthe disposition of other cases.

6 In applying published rulings andprocedures, the effect of subsequent legislation, regulations,court decisions, rulings, and procedures must be considered,and Service personnel and others concerned are cautionedagainst reaching the same conclusions in other cases unlessthe facts and circumstances are substantially the Bulletin is divided into four parts as follows:Part I. 1986 part includes rulings and decisions based on provisions ofthe internal revenue Code of II. Treaties and Tax part is divided into two subparts as follows: Subpart A, TaxConventions and Other Related Items, and Subpart B, Legisla-tion and Related Committee III.

7 Administrative, Procedural, and the extent practicable, pertinent cross references to thesesubjects are contained in the other Parts and Subparts. Alsoincluded in this part are Bank Secrecy Act Administrative Rul-ings. Bank Secrecy Act Administrative Rulings are issued bythe Department of the Treasury s Office of the Assistant Sec-retary (Enforcement).Part IV. Items of General part includes notices of proposed rulemakings, disbar-ment and suspension lists, and last Bulletin for each month includes a cumulative index forthe matters published during the preceding months.

8 Thesemonthly indexes are cumulated on a semiannual basis, and arepublished in the last Bulletin of each semiannual contents of this publication are not copyrighted and may be reprinted freely. A citation of the internal revenue Bulletin as the source would be 18, 2016 Bulletin No. 2016 16 Actions Relating to Decisions of the Tax CourtIt is the policy of the internal RevenueService to announce at an early datewhether it will follow the holdings in cer-tain cases. An Action on Decision is thedocument making such an Action on Decision will be issued atthe discretion of the Service only on un-appealed issues decided adverse to thegovernment.

9 Generally, an Action on De-cision is issued where its guidance wouldbe helpful to Service personnel workingwith the same or similar issues. Unlike aTreasury Regulation or a revenue Ruling,an Action on Decision is not an affirma-tive statement of Service position. It is notintended to serve as public guidance andmay not be cited as on Decisions shall be reliedupon within the Service only as conclu-sions applying the law to the facts in theparticular case at the time the Action onDecision was issued.

10 Caution should beexercised in extending the recommenda-tion of the Action on Decision to similarcases where the facts are different. More-over, the recommendation in the Actionon Decision may be superseded by newlegislation, regulations, rulings, cases, orActions on to 1991, the Service publishedacquiescence or nonacquiescence only incertain regular Tax Court opinions. TheService has expanded its acquiescenceprogram to include other civil tax caseswhere guidance is determined to be help-ful. Accordingly, the Service now mayacquiesce or nonacquiesce in the holdingsof memorandum Tax Court opinions, aswell as those of the United States DistrictCourts, Claims Court, and Circuit Courtsof Appeal.