Bulletin No. 2024–18

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Bulletin No. 2024–18

April 29, 2024

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.

ADMINISTRATIVE, INCOME TAX

EMPLOYEE PLANS

Notice 2024-33, page 959.

Notice 2024-34, page 960.

Notice 2024-33 provides limited relief to CAMT taxpayers

from the addition to tax under § 6655 of the Internal Revenue Code (Code) for failure to pay estimated income tax

with respect to its CAMT liability under § 55 of the Code for

the 2024 first quarterly installment of estimated income tax

due on or before April 15, 2024 (or on or before May 15,

2024, for taxpayers with taxable years beginning in February

2024).

Finding Lists begin on page ii.

This notice sets forth updates on the corporate bond monthly

yield curve, the corresponding spot segment rates for March

2024 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2024, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)

(iv).

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 29, 2024 

Bulletin No. 2024–18

Part III

Relief from Certain

Additions to Tax

for Corporation’s

Underpayment of

Estimated Income Tax

under Section 6655

Notice 2024-33

SECTION 1. OVERVIEW

This notice provides a limited waiver

of the addition to tax under § 6655 of the

Internal Revenue Code (Code)1 for underpayment of estimated income tax by a corporation to the extent the amount of any

underpayment is attributable to a portion

of a corporation’s corporate alternative

minimum tax (CAMT) liability under

§ 55, as amended by § 10101 of Public

Law 117-169, 136 Stat. 1818 (August 16,

2022), commonly referred to as the Inflation Reduction Act of 2022 (IRA).

SECTION 2. SCOPE

The relief provided in this notice

applies only for the purpose of calculating the installment of estimated income

tax of a corporate taxpayer that is due on

or before April 15, 2024 or, in the case of

a fiscal year taxpayer with a taxable year

beginning in February 2024, May 15,

2024, with respect to a taxable year that

began during 2024. This notice waives

any addition to tax under § 6655 to the

extent the amount of any underpayment

is attributable to the portion of the CAMT

liability due in that installment. Regarding

calculating the amounts of installments of

estimated income tax of a corporate taxpayer (or consolidated group) due after

April 15, 2024, or after May 15, 2024 (in

the case of a fiscal year taxpayer with a

taxable year beginning in February 2024),

§ 6655 applies in the normal course, and

this notice does not apply, nor does it

waive the addition to tax under § 6655 to

the extent the amount of any underpay-

1

ment is attributable to provisions of the

Code other than §§ 55(a) and (b)(2), 56A,

and 59(k) and (l).

SECTION 3. BACKGROUND

.01 CAMT under the IRA. Section

10101 of the IRA amended § 55 to impose

a new CAMT based on the “adjusted

financial statement income” (AFSI) of an

applicable corporation for taxable years

beginning after December 31, 2022. Pursuant to § 59(k)(1), in general, a corporation is an applicable corporation subject to

the CAMT for a taxable year if it meets an

average annual AFSI test for one or more

taxable years that (i) are before that taxable year and (ii) end after December 31,

2021 (Applicable Corporation). Section

55(a) provides that, for the taxable year of

an Applicable Corporation, the amount of

CAMT imposed by § 55 equals the excess

(if any) of (i) the tentative minimum tax

for the taxable year, over (ii) the sum of the

regular tax, as defined in § 55(c), for the

taxable year plus the tax imposed under

§ 59A. Section 55(b)(2)(A) provides that,

in the case of an Applicable Corporation,

the tentative minimum tax for the taxable

year is the excess of (i) 15 percent of AFSI

for the taxable year (as determined under

§ 56A), over (ii) the CAMT foreign tax

credit for the taxable year (as determined

under § 59(l)). In the case of any corporation that is not an Applicable Corporation,

§ 55(b)(2)(B) provides that the tentative

minimum tax for the taxable year is zero.

Notice 2023-7, 2023-3 I.R.B. 390,

announced that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue

forthcoming proposed regulations addressing the application of the CAMT. Notice

2023-7 also provided interim guidance

intended to clarify the application of certain aspects of the CAMT. Notice 2023-20,

2023-10 I.R.B. 523, Notice 2023-64, 202340 I.R.B. 974, and Notice 2024-10, 2024-3

I.R.B. 406, provided additional interim

guidance that is intended to further clarify

the application of the CAMT. Taxpayers

may generally rely on the interim guidance

provided in the aforementioned notices for

any taxable year that begins before January

1, 2024, and any taxable year that begins

on or after January 1, 2024, and ends on

or before the date proposed regulations

addressing the application of the CAMT

are published in the Federal Register. Special reliance rules are provided in section 5

of Notice 2024-10 for the interim guidance

provided in that notice.

.02 Estimated Taxes. Section 6655(a)

imposes an addition to tax for failure by

a corporation to make a sufficient and

timely payment of estimated income tax.

Sections 6655(c) and (d)(1)(A) generally provide that, in the case of a corporation, estimated income tax is required

to be paid in four installments and the

amount of any required installment is 25

percent of the required annual payment.

Generally, under § 6655(d)(1)(B), the

required annual payment is the lesser of

two amounts described in §§ 6655(d)(1)

(B)(i) and (ii). The amount described in

§ 6655(d)(1)(B)(i) is 100 percent of the

tax shown on the return for the taxable

year. The amount described in § 6655(d)

(1)(B)(ii) is 100 percent of the tax shown

on the taxpayer’s return for the preceding

taxable year, so long as the preceding taxable year was a full twelve months long

and the return for such year showed a

liability for tax. However, pursuant to

§ 6655(d)(2), in the case of a large corporation (as defined under § 6655(g)(2)), the

amount described in § 6655(d)(1)(B)(ii)

may not be used to reduce the amount of

an installment payment other than the first

installment payment for the taxable year.

In special circumstances, other rules specified in section 6655 or elsewhere may

also apply.

On June 7, 2023, the Treasury Department and the IRS issued Notice 2023-42,

2023-26 I.R.B. 1085, which provided a

waiver of the addition to tax under § 6655

with respect to a corporation’s CAMT

liability under § 55 for any taxable year

that begins after December 31, 2022, and

before January 1, 2024.

Unless otherwise specified, all “section” or “§” references are to sections of the Code.

Bulletin No. 2024–18

959

April 29, 2024

SECTION 4. LIMITED WAIVER

OF ADDITION TO TAX FOR

UNDERPAYMENT OF ESTIMATED

INCOME TAX

.01 Waiver. In light of the continuing

challenges associated with determining

whether a corporation is an Applicable

Corporation and the amount of a corporation’s CAMT liability under § 55, and

in the interest of sound tax administration, the IRS will waive the portion of

the addition to tax under § 6655 that is

attributable to a corporation’s CAMT liability for the installment of estimated tax

that is due on or before April 15, 2024, or

May 15, 2024 (in the case of a fiscal year

taxpayer with a taxable year beginning in

February 2024). Accordingly, while some

corporate taxpayers may have already

made an installment of estimated tax, a

corporate taxpayer’s required installment

of estimated tax that is due on or before

April 15, 2024, or on or before May 15,

2024 (in the case of a fiscal year taxpayer

with a taxable year beginning in February

2024), need not include amounts attributable to its CAMT liability under § 55 to

prevent the imposition of an addition to

tax under § 6655. If a corporation fails to

timely pay its CAMT liability under § 55

when due, other sections of the Code may

apply; for example, additions to tax could

be imposed under § 6651 if payment of

the CAMT liability is not made by the due

date (without regard to any extension) of

the corporation’s return.

.02 Instructions to be modified.

Affected taxpayers must file Form 2220

with their Federal income tax return, even

if they owe no estimated tax penalty, to

avoid a penalty notice. The instructions to

Form 2220, Underpayment of Estimated

Tax by Corporations, will be modified to

provide specific instructions on how to

avoid a penalty notice. The instructions

also will clarify that no addition to tax

will be imposed under § 6655 based on a

corporation’s failure to make an estimated

tax payment of its CAMT liability under

§ 55 for the installment of estimated tax

that is due on or before April 15, 2024, or

on or before May 15, 2024 (in the case of

a fiscal year taxpayer with a taxable year

beginning in February 2024), and that a

taxpayer may exclude such amounts when

calculating the amount of its required

annual payment on Form 2220. The modified instructions will be posted on https://

www.irs.gov.

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).

SECTION 5. APPLICABILITY DATE

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC plans

under § 414(y)) pursuant to § 412. Section

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.

Section 1.430(h)(2)-1(d) provides

rules for determining the monthly corporate bond yield curve,2 and § 1.430(h)

(2)-1(c) provides rules for determining

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 § 1.430(h)(2)-1(d), the monthly

corporate bond yield curve derived from

March 2024 data is in Table 2024-3 at the

end of this notice. The spot first, second,

and third segment rates for the month of

March 2024 are, respectively, 4.99, 5.19,

and 5.37.

The 24-month average segment rates

determined

under

§ 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant

The waiver of the addition to tax

imposed by § 6655 described in section

4.01 of this notice applies to the installment of estimated tax that is due on or

before April 15, 2024, or on or before

May 15, 2024 (in the case of a fiscal year

taxpayer with a taxable year beginning in

February 2024).

SECTION 6. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice is

Alexander Wu of the Office of the Associate Chief Counsel (Procedure and Administration). Other personnel from the Treasury Department and the IRS participated

in its development. For further information, please contact Alexander Wu at (202)

317-6845 (not a toll-free number).

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

Notice 2024-34

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

YIELD CURVE AND SEGMENT

RATES

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)).

2

For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts

the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market.

Those enhancements are described in the preamble to TD 9986 (89 FR 2127).

1

April 29, 2024

960

Bulletin No. 2024–18

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

Applicable Month

April 2024

years beginning in 2023 and 2024 were

published in Notice 2022-40, 2022-40

I.R.B. 266 and Notice 2023-66, 2023-40

I.R.B. 992, respectively. The applicable

minimum and maximum percentages are

95% and 105% for plan years beginning

in 2023 and 2024.

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate

bond segment rates applicable for April

2024 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

4.75

5.18

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 April

2024, adjusted to be within the applicable

minimum and maximum percentages of

Third Segment

5.16

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

2023

April 2024

4.75

5.18

5.74

2024

April 2024

4.75

5.18

5.59

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 liability. Section 431(c)(6)(E)(ii)(I) pro-

vides 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

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 March 2024 is 4.36 percent. The

Service determined this rate as the average of the daily determinations of yield

on the 30-year Treasury bond maturing

in February 2054. For plan years beginning in April 2024, 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%

April 2024

3.32

2.99 to 3.49

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 pres-

ent value segment rates. Pursuant to that

notice, the minimum present value segment rates determined for March 2024 are

as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

March 2024

Bulletin No. 2024–18

Minimum Present Value Segment Rates

First Segment

Second Segment

4.99

5.19

961

Third Segment

5.37

April 29, 2024

DRAFTING INFORMATION

The principal author of this notice is

Tom Morgan of the Office of Associ-

April 29, 2024

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

962

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 number).

Bulletin No. 2024–18

Table 2024-3

Monthly Yield Curve for March 2024

Derived from March 2024 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

5.46

5.29

5.14

5.02

4.93

4.86

4.82

4.80

4.79

4.79

4.81

4.83

4.86

4.90

4.94

4.97

5.01

5.05

5.08

5.12

5.15

5.18

5.20

5.23

5.25

5.27

5.29

5.30

5.32

5.33

5.34

5.35

5.36

5.37

5.37

5.38

5.38

5.39

5.39

5.39

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. 2024–18

Yield

5.39

5.39

5.39

5.38

5.38

5.38

5.38

5.37

5.37

5.37

5.36

5.36

5.36

5.36

5.35

5.35

5.35

5.35

5.35

5.35

5.35

5.35

5.36

5.36

5.36

5.36

5.36

5.36

5.36

5.36

5.36

5.36

5.37

5.37

5.37

5.37

5.37

5.37

5.37

5.37

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

5.37

5.37

5.37

5.37

5.37

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.38

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

963

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

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.39

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

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

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.40

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

5.41

April 29, 2024

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. 2024–18

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 29, 2024

Numerical Finding List1

Bulletin 2024–18

Announcements:

2024-1, 2024-02 I.R.B. 363

2024-3, 2024-02 I.R.B. 364

2024-5, 2024-05 I.R.B. 635

2024-6, 2024-05 I.R.B. 635

2024-4, 2024-06 I.R.B. 665

2024-7, 2024-07 I.R.B. 673

2024-8, 2024-07 I.R.B. 674

2024-9, 2024-07 I.R.B. 675

2024-12, 2024-08 I.R.B. 676

2024-11, 2024-08 I.R.B. 683

2024-13, 2024-10 I.R.B. 710

2024-10, 2024-11 I.R.B. 711

2024-14, 2024-12 I.R.B. 719

2024-15, 2024-15 I.R.B. 876

2024-16, 2024-16 I.R.B. 909

2024-17, 2024-16 I.R.B. 932

2024-19, 2024-17 I.R.B. 950

Notices:

2024-1, 2024-02 I.R.B. 314

2024-2, 2024-02 I.R.B. 316

2024-3, 2024-02 I.R.B. 338

2024-4, 2024-02 I.R.B. 343

2024-5, 2024-02 I.R.B. 347

2024-6, 2024-02 I.R.B. 348

2024-7, 2024-02 I.R.B. 355

2024-8, 2024-02 I.R.B. 356

2024-9, 2024-02 I.R.B. 358

2024-11, 2024-02 I.R.B. 360

2024-10, 2024-03 I.R.B. 406

2024-12, 2024-05 I.R.B. 616

2024-13, 2024-05 I.R.B. 618

2024-16, 2024-05 I.R.B. 622

2024-18, 2024-05 I.R.B. 625

2024-19, 2024-05 I.R.B. 627

2024-21, 2024-06 I.R.B. 659

2024-22, 2024-06 I.R.B. 662

2024-20, 2024-07 I.R.B. 668

2024-23, 2024-07 I.R.B. 672

2024-24, 2024-10 I.R.B. 707

2024-25, 2024-12 I.R.B. 712

2024-26, 2024-12 I.R.B. 713

2024-27, 2024-12 I.R.B. 715

2024-28, 2024-13 I.R.B. 720

2024-29, 2024-14 I.R.B. 751

2024-31, 2024-15 I.R.B. 869

2024-30, 2024-16 I.R.B. 878

2024-32, 2024-16 I.R.B. 897

2024-33, 2024-18 I.R.B. 959

2024-34, 2024-18 I.R.B. 960

Proposed Regulations:

REG-118492-23, 2024-02 I.R.B. 366

REG-107423-23, 2024-03 I.R.B. 411

REG-121010-17, 2024-05 I.R.B. 636

REG-101552-24, 2024-13 I.R.B. 741

REG-117631-23, 2024-14 I.R.B. 754

REG-108761-22, 2024-16 I.R.B. 933

REG-117542-22, 2024-16 I.R.B. 942

REG-123379-22, 2024-16 I.R.B. 952

Revenue Procedures:

2024-1, 2024-01 I.R.B. 1

2024-2, 2024-01 I.R.B. 119

2024-3, 2024-01 I.R.B. 143

2024-4, 2024-01 I.R.B. 160

2024-5, 2024-01 I.R.B. 262

2024-7, 2024-01 I.R.B. 303

2024-8, 2024-04 I.R.B. 479

2024-9, 2024-05 I.R.B. 628

2024-12, 2024-09 I.R.B. 677

2024-13, 2024-09 I.R.B. 678

2024-14, 2024-09 I.R.B. 682

2024-15, 2024-12 I.R.B. 717

2024-11, 2024-13 I.R.B. 721

2024-17, 2024-15 I.R.B. 873

2024-18, 2024-15 I.R.B. 874

2024-19, 2024-16 I.R.B. 899

Revenue Rulings:

2024-1, 2024-02 I.R.B. 307

2024-2, 2024-02 I.R.B. 311

2024-3, 2024-06 I.R.B. 646

2024-5, 2024-07 I.R.B. 666

2024-4, 2024-10 I.R.B. 686

2024-6, 2024-10 I.R.B. 688

2024-7, 2024-14 I.R.B. 749

2024-8, 2024-16 I.R.B. 877

Treasury Decisions:

9984, 2024-03 I.R.B. 386

9985, 2024-05 I.R.B. 573

9986, 2024-05 I.R.B. 610

9987, 2024-06 I.R.B. 648

9988, 2024-15 I.R.B. 794

9989, 2024-15 I.R.B. 850

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin

2023–52, dated December 26, 2023.

1

April 29, 2024

ii

Bulletin No. 2024–18

Finding List of Current Actions on

Previously Published Items1

Bulletin 2024–18

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin

2023–52, dated December 26, 2023.

1

Bulletin No. 2024–18

iii

April 29, 2024

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.

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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