Bulletin No. 2023–48

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2023–48

November 27, 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.

ADMINISTRATIVE

Rev. Proc. 2023-34, page 1287.

This revenue procedure sets forth inflation-adjusted

items for 2024 for various Code provisions as in effect

on November 9, 2023. The inflation adjusted items for

Finding Lists begin on page ii.

the Code sections set forth in section 3 of this revenue

procedure are generally determined by reference to § 1(f)

of the Code. To the extent amendments to the Code are

enacted for 2024 after November 9, 2023 taxpayers

should consult additional guidance to determine whether

these adjustments remain applicable for 2024.

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.

November 27, 2023

Bulletin No. 2023–48

Part III

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also: Part I, §§ 6011, 6662, 6662A,

6707A; 1-6011-4.)

Rev. Proc. 2023-34

Table of Contents

SECTION 1. PURPOSE��1287

SECTION 2. CHANGES��1287

SECTION 3. 2024 ADJUSTED ITEMS��1287

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Code Section1

Tax Rate Tables. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1(j)(2) (A)-(D)

Unearned Income of Minor Children Subject to the “Kiddie Tax” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1(g)

Maximum Capital Gains Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1(h)

Adoption Credit . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Child Tax Credit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Earned Income Credit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Refundable Credit for Coverage Under a Qualified Health Plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36B(f)(2)(B)

Rehabilitation Expenditures Treated as Separate New Building. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42(e)

Low-Income Housing Credit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42(h)

Employee Health Insurance Expense of Small Employers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45R

Exemption Amounts for Alternative Minimum Tax. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Alternative Minimum Tax Exemption for a Child Subject to the “Kiddie Tax” . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59(j)

Certain Expenses of Elementary and Secondary School Teachers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62(a)(2)(D)

Transportation Mainline Pipeline Construction Industry Optional Expense Substantiation Rules for

Payments to Employees Under Accountable Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62(c)

Standard Deduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

Cafeteria Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125

Qualified Transportation Fringe Benefit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132(f)

Income from United States Savings Bonds for Taxpayers Who Pay Qualified Higher Education Expenses . . . . . . . . . 135

Adoption Assistance Programs. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 137

Private Activity Bonds Volume Cap. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146(d)

Loan Limits on Agricultural Bonds. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147(c)(2)

General Arbitrage Rebate Rules. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148(f)

Safe Harbor Rules for Broker Commissions on Guaranteed Investment Contracts or Investments

Purchased for a Yield Restricted Defeasance Escrow . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148

Gross Income Limitation for a Qualifying Relative. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 152(d)(1)(B)

Election to Expense Certain Depreciable Assets. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179

Energy Efficient Commercial Buildings Deduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 179D

Qualified Business Income. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199A

Eligible Long-Term Care Premiums. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 213(d)(10)

Medical Savings Accounts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 220

Interest on Education Loans. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 221

Limitation on Use of Cash Method of Accounting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 448

Threshold for Excess Business Loss . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 461(l)

Treatment of Dues Paid to Agricultural or Horticultural Organizations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 512(d)

Insubstantial Benefit Limitations for Contributions Associated With Charitable Fund-Raising Campaigns. . . . . . . 513(h)

Special Rules for Credits and Deductions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 642

Tax on Insurance Companies Other than Life Insurance Companies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 831

Unless otherwise specified, all references to “section” or “§” references are to provisions of the Internal Revenue Code (Code).

Bulletin No. 2023–48

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November 27, 2023

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Expatriation to Avoid Tax. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 877

Tax Responsibilities of Expatriation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 877A

Foreign Earned Income Exclusion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 911

Debt Instruments Arising Out of Sales or Exchanges . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1274A

Unified Credit Against Estate Tax . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2010

Valuation of Qualified Real Property in Decedent’s Gross Estate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2032A

Annual Exclusion for Gifts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2503; 2523

Tax on Arrow Shafts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4161

Passenger Air Transportation Excise Tax. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4261

Tax on Certain Uses of Crude Oil and Petroleum Products. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4611

Reporting Exception for Certain Exempt Organizations with Nondeductible Lobbying Expenditures . . . . . . . . 6033(e)(3)

Notice of Large Gifts Received from Foreign Persons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6039F

Persons Against Whom a Federal Tax Lien Is Not Valid. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6323

Property Exempt from Levy. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6334(a)

Exempt Amount of Wages, Salary, or Other Income. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6334(d)

Interest on a Certain Portion of the Estate Tax Payable in Installments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6601(j)

Failure to File Tax Return. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6651

Failure to File Certain Information Returns, Registration Statements, etc.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6652

Other Assessable Penalties With Respect to the Preparation of Tax Returns for Other Persons. . . . . . . . . . . . . . . . . . 6695

Failure to File Partnership Return . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6698

Failure to File S Corporation Return . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6699

Failure to File Correct Information Returns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6721

Failure to Furnish Correct Payee Statements. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6722

Revocation or Denial of Passport in Case of Certain Tax Delinquencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7345

Attorney Fee Awards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7430

Periodic Payments Received Under Qualified Long-Term Care Insurance Contracts or Under Certain

Life Insurance Contracts. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7702B(d)

.63 Qualified Small Employer Health Reimbursement Arrangement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9831

SECTION 4. EFFECTIVE DATE��1298

SECTION 5. DRAFTING INFORMATION��1298

SECTION 1. PURPOSE

SECTION 2. CHANGES

This revenue procedure sets forth

inflation-adjusted items for 2024 for

various Code provisions as in effect

on November 9, 2023. The inflation

adjusted items for the Code sections set

forth in section 3 of this revenue procedure are generally determined by reference to § 1(f). To the extent amendments

to the Code are enacted for 2024 after

November 9, 2023, taxpayers should

consult additional guidance to determine

whether these adjustments remain applicable for 2024.

.01 For calendar years beginning on

or after January 1, 2023, § 13601(a)(2) of

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

16, 2022), commonly known as the Inflation

Reduction Act of 2022 (IRA), reinstates the

Hazardous Substance Superfund financing

rate for crude oil received at a United States

refinery and petroleum products entered

into the United States for consumption, use,

or warehousing under § 4611. The rate of

tax imposed by § 4611 is the sum of the

Hazardous Substance Superfund rate and

the Oil Spill Liability Trust Fund financing

November 27, 2023

1288

rate. In the case of crude oil or petroleum

products entered after December 31, 2016,

for calendar years beginning in 2023, the

rate of tax imposed by § 4611(a) is $0.254

cents a barrel.

.02 The Hazardous Substance Superfund

financing rate described in section 2.01 of

this revenue procedure is adjusted for inflation for calendar years beginning in 2024.

SECTION 3. 2024 ADJUSTED ITEMS

.01 Tax Rate Tables. For taxable years

beginning in 2024, the tax rate tables

under § 1 are as follows:

Bulletin No. 2023–48

TABLE 1 - Section 1(j)(2)(A) – Married Individuals Filing Joint Returns and Surviving Spouses

If Taxable Income Is:

Not over $23,200

Over $23,200 but

not over $94,300

Over $94,300 but

not over $201,050

Over $201,050 but

not over $383,900

Over $383,900 but

not over $487,450

Over $487,450 but

not over $731,200

Over $731,200

The Tax Is:

10% of the taxable income

$2,320 plus 12% of

the excess over $23,200

$10,852 plus 22% of

the excess over $94,300

$34,337 plus 24% of

the excess over $201,050

$78,221 plus 32% of

the excess over $383,900

$111,357 plus 35% of

the excess over $487,450

$196,669.50 plus 37% of

the excess over $731,200

TABLE 2 - Section 1(j)(2)(B) – Heads of Households

If Taxable Income Is:

Not over $16,550

Over $16,550 but

not over $63,100

Over $63,100 but

not over $100,500

Over $100,500 but

not over $191,950

Over $191,950 but

not over $243,700

Over $243,700 but

not over $609,350

Over $609,350

The Tax Is:

10% of the taxable income

$1,655 plus 12% of

the excess over $16,550

$7,241 plus 22% of

the excess over $63,100

$15,469 plus 24% of

the excess over $100,500

$37,417 plus 32% of

the excess over $191,950

$53,977 plus 35% of

the excess over $243,700

$181,954.50 plus 37% of

the excess over $609,350

TABLE 3 - Section 1(j)(2)(C) – Unmarried Individuals (other than Surviving Spouses and Heads of Households)

If Taxable Income Is:

Not over $11,600

Over $11,600 but

not over $47,150

Over $47,150 but

not over $100,525

Over $100,525 but

not over $191,950

Over $191,950 but

not over $243,725

Over $243,725 but

not over $609,350

Over $609,350

Bulletin No. 2023–48

The Tax Is:

10% of the taxable income

$1,160 plus 12% of

the excess over $11,600

$5,426 plus 22% of

the excess over $47,150

$17,168.50 plus 24% of

the excess over $100,525

$39,110.50 plus 32% of

the excess over $191,950

$55,678.50 plus 35% of

the excess over $243,725

$183,647.25 plus 37% of

the excess over $609,350

1289

November 27, 2023

TABLE 4 - Section 1(j)(2)(D) – Married Individuals Filing Separate Returns

If Taxable Income Is:

Not over $11,600

Over $11,600 but

not over $47,150

Over $47,150 but

not over $100,525

Over $100,525 but

not over $191,950

Over $191,950 but

not over $243,725

Over $243,725 but

not over $365,600

Over $365,600

The Tax Is:

10% of the taxable income

$1,160 plus 12% of

the excess over $11,600

$5,426 plus 22% of

the excess over $47,150

$17,168.50 plus 24% of

the excess over $100,525

$39,110.50 plus 32% of

the excess over $191,950

$55,678.50 plus 35% of

the excess over $243,725

$98,334.75 plus 37% of

the excess over $365,600

TABLE 5 - Section 1(j)(2)(E) – Estates and Trusts

If Taxable Income Is:

Not over $3,100

Over $3,100 but

not over $11,150

Over $11,150 but

not over $15,200

Over $15,200

.02 Unearned Income of Minor

Children Subject to the “Kiddie Tax”.

For taxable years beginning in 2024, the

amount in § 1(g)(4)(A)(ii)(I), which is

used to reduce the net unearned income

reported on the child’s return that is subject to the “kiddie tax,” is $1,300. This

$1,300 amount is the same as the amount

provided in § 63(c)(5)(A), as adjusted for

The Tax Is:

10% of the taxable income

$310 plus 24% of

the excess over $3,100

$2,242 plus 35% of

the excess over $11,150

$3,659.50 plus 37% of

the excess over $15,200

inflation. The same $1,300 amount is used

for purposes of § 1(g)(7) to determine

whether a parent may elect to include a

child’s gross income in the parent’s gross

income and to calculate the “kiddie tax.”

For example, one of the requirements

for the parental election is that a child’s

gross income is more than the amount

referenced in § 1(g)(4)(A)(ii)(I) but less

Filing Status

Married Individuals Filing Joint Returns and Surviving Spouse

Married Individuals Filing Separate Returns

Heads of Household

All Other Individuals

Estates and Trusts

.04 Adoption Credit. For taxable years

beginning in 2024, under § 23(a)(3) the

credit allowed for an adoption of a child

with special needs is $16,810. For taxable

November 27, 2023

Maximum Zero Rate

Amount

$94,050

$47,025

$63,000

$47,025

$3,150

years beginning in 2024, under § 23(b)

(1) the maximum credit allowed for other

adoptions is the amount of qualified adoption expenses up to $16,810. The available

1290

than 10 times that amount; thus, a child’s

gross income for 2024 must be more than

$1,300 but less than $13,000.

.03 Maximum Capital Gains Rate

(§1(h), §1(j)(5)). For taxable years beginning in 2024, the maximum zero rate

amounts and maximum 15 percent rate

amounts under § 1(j)(5)(B), as adjusted

for inflation, are as follows:

Maximum 15% Rate

Amount

$583,750

$291,850

$551,350

$518,900

$15,450

adoption credit begins to phase out under

§ 23(b)(2)(A) for taxpayers with modified adjusted gross income in excess of

$252,150 and is completely phased out for

Bulletin No. 2023–48

taxpayers with modified adjusted gross

income of $292,150 or more. See section

3.19 of this revenue procedure for the

adjusted items relating to adoption assistance programs.

.05 Child Tax Credit. For taxable years

beginning in 2024, the amount used in

§ 24(d)(1)(A) to determine the amount of

credit under § 24 that may be refundable

is $1,700.

.06 Earned Income Credit.

(1) In general. For taxable years beginning in 2024, the following amounts are

used to determine the earned income

credit under § 32(b). The “earned income

amount” is the amount of earned income

at or above which the maximum amount

of the earned income credit is allowed.

The “threshold phaseout amount” is the

amount of adjusted gross income (or, if

greater, earned income) above which the

maximum amount of the credit begins

to phase out. The “completed phaseout

amount” is the amount of adjusted gross

income (or, if greater, earned income) at

or above which no credit is allowed. The

Item

Earned Income Amount

Maximum Amount of Credit

Threshold Phaseout Amount (Married Filing Jointly)

Completed Phaseout Amount (Married Filing Jointly)

Threshold Phaseout Amount (All other filing statuses)

Completed Phaseout Amount (All other filing statuses)

The instructions for the Form 1040

series provide tables showing the amount

of the earned income credit for each type

of taxpayer.

(2) Excessive Investment Income.

For taxable years beginning in 2024, the

If the household income

(expressed as a percent of

poverty line) is:

Less than 200%

At least 200% but less than 300%

At least 300% but less than 400%

.08

Rehabilitation

Expenditures

Treated as Separate New Building. For

calendar year 2024, the per low-income

unit qualified basis amount under § 42(e)

(3)(A)(ii)(II) is $8,300.

.09 Low-Income Housing Credit. For

calendar year 2024, the amount used under

§ 42(h)(3)(C)(ii) to calculate the State

housing credit ceiling for the low-income

One

$12,390

$4,213

$29,640

$56,004

$22,720

$49,084

Bulletin No. 2023–48

Number of Qualifying Children

Two

Three or More

$17,400

$6,960

$7,830

$29,640

$62,688

$66,819

$22,720

$55,768

$59,899

earned income tax credit is not allowed

under § 32(i) if the aggregate amount

of certain investment income exceeds

$11,600.

.07 Refundable Credit for Coverage

Under a Qualified Health Plan. For

The limitation amount for

unmarried individuals

(other than surviving spouses

and heads of household) is:

$375

$950

$1,575

housing credit is the greater of (1) $2.90

multiplied by the State population, or

(2) $3,360,000.

.10 Employee Health Insurance

Expense of Small Employers. For taxable years beginning in 2024, the dollar

amount in effect under § 45R(d)(3)(B)

is $32,400. This amount is used under

§ 45R(c) for limiting the small employer

Joint Returns or Surviving Spouses

Unmarried Individuals (other than Surviving Spouses)

Married Individuals Filing Separate Returns

Estates and Trusts

1291

threshold phaseout amounts and the completed phaseout amounts shown in the

table below for married taxpayers filing a

joint return include the increase provided

in § 32(b)(2)(B), as adjusted for inflation

for taxable years beginning in 2024. The

threshold phaseout amounts and the completed phaseout amounts shown in the

table below for taxpayers with all other

filing statuses also apply to married taxpayers who are not filing a joint return

and satisfy the special rules for separated

spouses in § 32(d).

None

$8,260

$632

$17,250

$25,511

$10,330

$18,591

taxable years beginning in 2024, the limitation on tax imposed under § 36B(f)(2)

(B) for excess advance credit payments is

determined using the following table:

The limitation amount for

all other taxpayers is:

$750

$1,900

$3,150

health insurance credit and under § 45R(d)

(1)(B) for determining who is an eligible

small employer for purposes of the credit.

.11 Exemption Amounts for Alternative

Minimum Tax. For taxable years beginning in 2024, the exemption amounts

under § 55(d)(1) are:

$133,300

$85,700

$66,650

$29,900

November 27, 2023

For taxable years beginning in 2024,

under § 55(b)(1), the excess taxable

income above which the 28 percent tax

rate applies is:

Married Individuals Filing Separate Returns

All Other Taxpayers

For taxable years beginning in 2024,

the amounts used under § 55(d)(2) to

determine the phaseout of the exemption

amounts are:

Joint Returns or Surviving Spouses

Unmarried Individuals (other than Surviving Spouses)

Married Individuals Filing Separate Returns

Estates and Trusts

.12

Alternative

Minimum

Tax

Exemption for a Child Subject to the

“Kiddie Tax.” For taxable years beginning in 2024, for a child to whom the

§ 1(g) “kiddie tax” applies, the exemption amount under §§ 55(d) and 59(j) for

purposes of the alternative minimum tax

under § 55 may not exceed the sum of (1)

the child’s earned income for the taxable

year, plus (2) $9,250.

.13 Certain Expenses of Elementary

and Secondary School Teachers. For

taxable years beginning in 2024, under

§ 62(a)(2)(D) the amount of the deduction allowed under § 162 that consists of

$116,300

$232,600

Threshold Phaseout Amount

$1,218,700

$609,350

$99,700

expenses paid or incurred by an eligible

educator in connection with books, supplies (other than nonathletic supplies for

courses of instruction in health or physical education), computer equipment

(including related software and services)

and other equipment, and supplementary

materials used by the eligible educator in

the classroom is $300.

.14 Transportation Mainline Pipeline

Construction Industry Optional Expense

Substantiation Rules for Payments to

Employees Under Accountable Plans. For

calendar year 2024, an eligible employer

may pay certain welders and heavy

equipment mechanics an amount up to $22

per hour for rig-related expenses that are

deemed substantiated under an accountable plan if paid in accordance with Rev.

Proc. 2002-41, 2002-1 C.B. 1098. If the

employer provides fuel or otherwise reimburses fuel expenses, an amount up to $13

per hour is deemed substantiated if paid

under Rev. Proc. 2002-41.

.15 Standard Deduction.

(1) In general. For taxable years beginning in 2024, the standard deduction

amounts under § 63(c)(2) are as follows:

Filing Status

Married Individuals Filing Joint Returns and Surviving Spouses (§ 1(j)(2)(A))

Heads of Households (§ 1(j)(2)(B))

Unmarried Individuals (other than Surviving Spouses and Heads of Households) (§ 1(j)(2)(C))

Married Individuals Filing Separate Returns (§ 1(j)(2)(D))

(2) Dependent. For taxable years

beginning in 2024, the standard deduction

amount under § 63(c)(5) for an individual who may be claimed as a dependent

by another taxpayer cannot exceed the

greater of (1) $1,300, or (2) the sum of

$450 and the individual’s earned income.

(3) Aged or blind. For taxable years

beginning in 2024, the additional standard

deduction amount under § 63(f) for the

aged or the blind is $1,550. The additional

standard deduction amount is increased to

$1,950 if the individual is also unmarried

and not a surviving spouse.

November 27, 2023

.16 Cafeteria Plans. For taxable years

beginning in 2024, the dollar limitation

under § 125(i) on voluntary employee salary reductions for contributions to health

flexible spending arrangements is $3,200.

If the cafeteria plan permits the carryover

of unused amounts, the maximum carryover amount is $640.

.17 Qualified Transportation Fringe

Benefit. For taxable years beginning

in 2024, the monthly limitation under

§ 132(f)(2)(A) regarding the aggregate

fringe benefit exclusion amount for transportation in a commuter highway vehicle

1292

Complete Phaseout Amount

$1,751,900

$952,150

$875,950

$219,300

Standard Deduction

$29,200

$21,900

$14,600

and any transit pass is $315. The monthly

limitation under § 132(f)(2)(B) regarding

the fringe benefit exclusion amount for

qualified parking is $315.

.18 Income from United States Savings

Bonds for Taxpayers Who Pay Qualified

Higher Education Expenses. For taxable years beginning in 2024, the exclusion under § 135, regarding income from

United States savings bonds for taxpayers who pay qualified higher education

expenses, begins to phase out for modified

adjusted gross income above $145,200

for joint returns and $96,800 for all other

Bulletin No. 2023–48

returns. The exclusion is completely

phased out for modified adjusted gross

income of $175,200 or more for joint

returns and $111,800 or more for all other

returns.

.19 Adoption Assistance Programs.

For taxable years beginning in 2024,

under § 137(a)(2), the amount that can

be excluded from an employee’s gross

income for the adoption of a child with

special needs is $16,810. For taxable years

beginning in 2024, under § 137(b)(1) the

maximum amount that can be excluded

from an employee’s gross income for the

amounts paid or expenses incurred by an

employer for qualified adoption expenses

furnished pursuant to an adoption assistance program for adoptions by the

employee is $16,810. The amount excludable from an employee’s gross income

begins to phase out under § 137(b)(2)

(A) for taxpayers with modified adjusted

gross income in excess of $252,150 and

is completely phased out for taxpayers

with modified adjusted gross income of

$292,150 or more. (See section 3.04 of

this revenue procedure for the adjusted

items relating to the adoption credit.)

.20 Private Activity Bonds Volume

Cap. For calendar year 2024, the amounts

used under § 146(d) to calculate the State

ceiling for the volume cap for private

activity bonds is the greater of (1) $125

multiplied by the State population, or (2)

$378,230,000.

.21 Loan Limits on Agricultural

Bonds. For calendar year 2024, the loan

limit amount on agricultural bonds under

§ 147(c)(2)(A) for first-time farmers is

$649,400.

.22 General Arbitrage Rebate Rules.

For bond years ending in 2024, the amount

of the computation credit determined

under § 1.148-3(d)(4) of the Income Tax

Regulations is $2,070.

.23 Safe Harbor Rules for Broker

Commissions on Guaranteed Investment

Contracts or Investments Purchased for a

Yield Restricted Defeasance Escrow. For

calendar year 2024, under § 1.148-5(e)(2)

(iii)(B)(1) of the Income Tax Regulations,

a broker’s commission or similar fee for

the acquisition of a guaranteed investment

contract or investments purchased for a

yield restricted defeasance escrow is reasonable if (1) the amount of the fee that

the issuer treats as a qualified administrative cost does not exceed the lesser of

(A) $49,000, and (B) 0.2 percent of the

computational base (as defined in § 1.1485(e)(2)(iii)(B)(2)) or, if more, $5,000; and

(2) for any issue, the issuer does not treat

more than $138,000 in brokers’ commissions or similar fees as qualified administrative costs for all guaranteed investment

contracts and investments for yield

restricted defeasance escrows purchased

with gross proceeds of the issue.

.24 Gross Income Limitation for a

Qualifying Relative. For taxable years

beginning in 2024, the exemption amount

referenced in § 152(d)(1)(B) is $5,050.

.25 Election to Expense Certain

Depreciable Assets. For taxable years

Filing Status

Married Individuals Filing Joint Returns

Married Individuals Filing Separate Returns

All Other Returns

.28 Eligible Long-Term Care Premiums.

For taxable years beginning in 2024, the

Threshold amount

$383,900

$191,950

limitations under § 213(d)(10), regarding eligible long-term care premiums

Attained Age Before the Close of the Taxable Year

40 or less

More than 40 but not more than 50

More than 50 but not more than 60

More than 60 but not more than 70

More than 70

Bulletin No. 2023–48

beginning in 2024, under § 179(b)(1), the

aggregate cost of any § 179 property that

a taxpayer elects to treat as an expense

cannot exceed $1,220,000 and under

§ 179(b)(5)(A), the cost of any sport utility vehicle that may be taken into account

under § 179 cannot exceed $30,500.

Under § 179(b)(2), the $1,220,000 limitation under § 179(b)(1) is reduced (but

not below zero) by the amount by which

the cost of § 179 property placed in service during the 2024 taxable year exceeds

$3,050,000.

.26 Energy Efficient Commercial

Building Deduction. For taxable years

beginning in 2024, the applicable dollar value used to determine the maximum allowance of the deduction under

§ 179D(b)(2) is $0.57 increased (but not

above $1.13) by $0.02 for each percentage

point by which the total annual energy and

power costs for the buildings are certified

to be reduced by a percentage greater than

25 percent. For taxable years beginning in

2024, the applicable dollar value used to

determine the increased deduction amount

for certain property under § 179D(b)(3) is

$2.83 increased (but not above $5.65) by

$0.11 for each percentage point by which

the total annual energy and power costs

for the building are certified to be reduced

by a percentage greater than 25 percent.

.27 Qualified Business Income. For taxable years beginning in 2024, the threshold

amounts under § 199A(e)(2) and phase-in

range amounts under § 199A(b)(3)(B) and

§ 199A(d)(3)(A) are:

1293

Phase-in range amount

$483,900

$241,950

includible in the term “medical care”, as

adjusted for inflation, are as follows:

Limitation on Premiums

$470

$880

$1,760

$4,710

$5,880

November 27, 2023

.29 Medical Savings Accounts.

(1) Self-only coverage. For taxable

years beginning in 2024, the term “high

deductible health plan” as defined in

§ 220(c)(2)(A) means, for self-only coverage, a health plan that has an annual

deductible that is not less than $2,800

and not more than $4,150, and under

which the annual out-of-pocket expenses

required to be paid (other than for premiums) for covered benefits do not exceed

$5,550.

(2) Family coverage. For taxable

years beginning in 2024, the term “high

deductible health plan” means, for family

coverage, a health plan that has an annual

deductible that is not less than $5,550

and not more than $8,350, and under

which the annual out-of-pocket expenses

required to be paid (other than for premiums) for covered benefits do not exceed

$10,200.

.30 Interest on Education Loans. For

taxable years beginning in 2024, the

$2,500 maximum deduction for interest

paid on qualified education loans under

§ 221 begins to phase out under § 221(b)

(2)(B), as adjusted for inflation, for taxpayers with modified adjusted gross income

in excess of $80,000 ($165,000 for joint

returns), and is completely phased out for

taxpayers with modified adjusted gross

income of $95,000 or more ($195,000 or

more for joint returns).

.31 Limitation on Use of Cash Method

of Accounting. For taxable years beginning in 2024, a corporation or partnership

meets the gross receipts test of § 448(c)

for any taxable year if the average annual

gross receipts of such entity for the 3-taxable-year period ending with the taxable

year which precedes such taxable year

does not exceed $30,000,000.

.32 Threshold for Excess Business

Loss. For taxable years beginning in 2024,

in determining a taxpayer’s excess business loss, the amount under § 461(l)(3)

(A)(ii)(II) is $305,000 ($610,000 for joint

returns).

.33 Treatment of Dues Paid

Agricultural

Horticultural

Organizations. For taxable years beginning in 2024, the limitation under § 512(d)

(1), regarding the exemption of annual

dues required to be paid by a member to

an agricultural or horticultural organization, is $201.

November 27, 2023

.34 Insubstantial Benefit Limitations for

Contributions Associated with Charitable

Fund-Raising Campaigns.

(1) Low cost article. For taxable years

beginning in 2024, for purposes of defining the term “unrelated trade or business”

for certain exempt organizations under

§ 513(h)(2), “low cost articles” are articles

costing $13.20 or less.

(2) Other insubstantial benefits. For

taxable years beginning in 2024, under

§ 170, the $5, $25, and $50 guidelines in

section 3 of Rev. Proc. 90-12, 1990-1 C.B.

471 (as amplified by Rev. Proc. 92-49,

1992-1 C.B. 987, and modified by Rev.

Proc. 92-102, 1992-2 C.B. 579), for the

value of insubstantial benefits that may be

received by a donor in return for a contribution, without causing the contribution

to fail to be fully deductible, are $13.20,

$66.00 and $132.00, respectively.

.35 Special Rules for Credits and

Deductions. For taxable years beginning

in 2024, the amount of the deduction

under § 642(b)(2)(C)(i) is $5,000.

.36 Tax on Insurance Companies Other

than Life Insurance Companies. For

taxable years beginning in 2024, under

§ 831(b)(2)(A)(i) the amount of the limit

on net written premiums or direct written premiums (whichever is greater) is

$2,800,000 to elect the alternative tax for

certain small companies under § 831(b)

(1) to be taxed only on taxable investment

income.

.37 Expatriation to Avoid Tax. For

calendar year 2024, under § 877A(g)(1)

(A), unless an exception under § 877A(g)

(1)(B) applies, an individual is a covered

expatriate if the individual’s “average

annual net income tax” under § 877(a)

(2)(A) for the five taxable years ending

before the expatriation date is more than

$201,000.

.38 Tax Responsibilities of Expatriation.

For taxable years beginning in 2024, the

amount that would be includible in the

gross income of a covered expatriate by

reason of § 877A(a)(1) is reduced (but

not below zero) by $866,000 pursuant to

§ 877A(a)(3).

.39 Foreign Earned Income Exclusion.

For taxable years beginning in 2024, the

foreign earned income exclusion amount

under § 911(b)(2)(D)(i) is $126,500.

.40 Debt Instruments Arising Out of

Sales or Exchanges. For calendar year

1294

2024, a qualified debt instrument under

§ 1274A(b) has stated principal that does

not exceed $7,098,600, and a cash method

debt instrument under § 1274A(c)(2)

has stated principal that does not exceed

$5,070,500.

.41 Unified Credit Against Estate Tax.

For an estate of any decedent dying in

calendar year 2024, the basic exclusion

amount is $13,610,000 for determining

the amount of the unified credit against

estate tax under § 2010.

.42 Valuation of Qualified Real

Property in Decedent’s Gross Estate. For

an estate of a decedent dying in calendar

year 2024, if the executor elects to use

the special use valuation method under

§ 2032A for qualified real property, the

aggregate decrease in the value of qualified real property resulting from electing

to use § 2032A for purposes of the estate

tax cannot exceed $1,390,000.

.43 Annual Exclusion for Gifts.

(1) For calendar year 2024, the first

$18,000 of gifts to any person (other than

gifts of future interests in property) are

not included in the total amount of taxable

gifts under § 2503 made during that year.

(2) For calendar year 2024, the first

$185,000 of gifts to a spouse who is not

a citizen of the United States (other than

gifts of future interests in property) are

not included in the total amount of taxable

gifts under §§ 2503 and 2523(i)(2) made

during that year.

.44 Tax on Arrow Shafts. For calendar year 2024, the tax imposed under

§ 4161(b)(2)(A) on the first sale by the

manufacturer, producer, or importer of

any shaft of a type used in the manufacture of certain arrows is $0.62 per shaft.

.45 Passenger Air Transportation

Excise Tax. For calendar year 2024, the

tax under § 4261(b)(1) on the amount paid

for each domestic segment of taxable air

transportation is $5.00. For calendar year

2024, the tax under § 4261(c)(1) on any

amount paid (whether within or without

the United States) for any international air

transportation, if the transportation begins

or ends in the United States, generally is

$22.20. Under § 4261(c)(3), however, a

lower rate of tax applies under § 4261(c)

(1) to a domestic segment beginning or

ending in Alaska or Hawaii, and the tax

applies only to departures. For calendar

year 2024, the rate of tax is $11.10.

Bulletin No. 2023–48

.46 Tax on Certain Uses of Crude Oil

and Petroleum Products. For calendar year

2024, the tax imposed under § 4611(a) on

crude oil received at a United States refinery and petroleum products entered into

the United States for consumption, use, or

warehousing is $0.26 cents per barrel.

.47 Reporting Exception for Certain

Exempt Organizations with Nondeductible

Lobbying Expenditures. For taxable years

beginning in 2024, the annual per person, family, or entity dues limitation to

qualify for the reporting exception under

§ 6033(e)(3) (and section 5.05 of Rev.

Proc. 98-19, 1998-1 C.B. 547), regarding

certain exempt organizations with nondeductible lobbying expenditures, is $140 or

less.

.48 Notice of Large Gifts Received

from Foreign Persons. For taxable years

beginning in 2024, § 6039F authorizes the

Secretary of the Treasury or her delegate

to require recipients of gifts from certain

foreign persons to report these gifts if the

aggregate value of gifts received in the

taxable year exceeds $19,570.

.49 Persons Against Whom a Federal

Tax Lien Is Not Valid. For calendar year

2024, a federal tax lien is not valid against

(1) certain purchasers under § 6323(b)

(4) who purchased personal property in

a casual sale for less than $1,900, or (2)

a mechanic’s lienor under § 6323(b)(7)

who repaired or improved certain residential property if the contract price with the

owner is not more than $9,520.

.50 Property Exempt from Levy. For

calendar year 2024, the value of property

exempt from levy under § 6334(a)(2) (fuel,

provisions, furniture, and other household

personal effects, as well as arms for personal use, livestock, and poultry) cannot

exceed $11,390. The value of property

exempt from levy under § 6334(a)(3)

(books and tools necessary for the trade,

business, or profession of the taxpayer)

cannot exceed $5,700.

.51 Exempt Amount of Wages, Salary,

or Other Income. For taxable years beginning in 2024, the dollar amount used to

calculate the amount determined under

§ 6334(d)(4)(B) is $5,000.

Scenario

Organization (§ 6652(c)(1)(A))

Daily Penalty

$25

$125

$10

$25

Maximum Penalty

Lesser of $12,500 or 5%

of gross receipts of the

organization for the year

$63,500

$6,000

$12,500

No Limit

Daily Penalty

$10

$25

$125

Maximum Penalty

$6,000

$12,500

$63,500

Daily Penalty

$125

Maximum Penalty

$63,500

$12,500

Organization with gross receipts exceeding $1,274,000 (§ 6652(c)(1)(A))

Managers (§ 6652(c)(1)(B))

Public inspection of annual returns and reports (§ 6652(c)(1)(C))

Public inspection of applications for exemption and notice of status (§ 6652(c)

(1)(D))

(2) for failure to file a return required

under § 6034 (relating to returns by certain

.52 Interest on a Certain Portion of the

Estate Tax Payable in Installments. For an

estate of a decedent dying in calendar year

2024, the dollar amount used to determine

the “2-percent portion” (for purposes of

calculating interest under § 6601(j)) of the

estate tax extended as provided in § 6166

is $1,850,000.

.53 Failure to File Tax Return. In the

case of any return required to be filed

in 2025, the amount of the addition to

tax under § 6651(a) for failure to file an

income tax return within 60 days of the

due date of such return (determined with

regard to any extensions of time for filing)

will not be less than the lesser of $510 or

100 percent of the amount required to be

shown as tax on such return.

.54 Failure to File Certain Information

Returns, Registration Statements, etc. For

returns required to be filed in 2025, the

penalty amounts under § 6652(c) are:

(1) for failure to file a return required

under § 6033(a)(1) (relating to returns by

exempt organization) or § 6012(a)(6) (relating to returns by exempt organizations):

trusts) or § 6043(b) (relating to terminations, etc., of exempt organizations):

Scenario

Organization or trust (§ 6652(c)(2)(A))

Managers (§ 6652(c)(2)(B))

Split-Interest Trust (§ 6652(c)(2)(C)(ii))

Any trust with gross income exceeding $318,500 (§ 6652(c)(2)(C)(ii))

(3) for failure to file a disclosure required under § 6033(a)(2):

Scenario

Tax–exempt entity (§ 6652(c)(3)(A))

Failure to comply with written demand (§ 6652(c)(3)(B)(ii))

Bulletin No. 2023–48

1295

November 27, 2023

.55 Other Assessable Penalties With

Respect to the Preparation of Tax Returns

for Other Persons. In the case of any failure relating to a return or claim for refund

Scenario

Failure to furnish copy to taxpayer (§ 6695(a))

Failure to sign return (§ 6695(b))

Failure to furnish identifying number (§ 6695(c))

Failure to retain copy or list (§ 6695(d))

Failure to file correct information returns (§ 6695(e))

Negotiation of check (§ 6695(f))

Failure to be diligent in determining eligibility for head of household filing status,

child tax credit, American Opportunity tax credit, and earned income credit

(§ 6695(g))

.56 Failure to File Partnership Return.

In the case of any return required to be

filed in 2025, the dollar amount used to

determine the amount of the penalty under

§ 6698(b)(1) is $245.

.57 Failure to File S Corporation

Return. In the case of any return required

(2) for persons with average annual

gross receipts for the most recent three

November 27, 2023

Maximum

Penalty

$31,500

No limit

(1) for persons with average annual

gross receipts for the most recent three

taxable years of more than $5,000,000, for

failure to file correct information returns:

Penalty Per Return

$330

$60

$130

Calendar Year Maximum

$3,987,000

$664,500

$1,993,500

taxable years of $5,000,000 or less, for

failure to file correct information returns:

Scenario

General Rule (§ 6721(d)(1)(A))

Corrected on or before 30 days after required filing date (§ 6721(d)(1)(B))

Corrected after 30th day but on or before August 1, 2025 (§ 6721(d)(1)(C))

(3) for failure to file correct information returns due to intentional disregard

Per Return or Claim for

Refund

$60

$60 per return and item

in return

$635 per check

$635 per failure

to be filed in 2025, the dollar amount used

to determine the amount of the penalty

under § 6699(b)(1) is $245.

.58 Failure to File Correct Information

Returns. In the case of any failure relating

to a return required to be filed in 2025, the

penalty amounts under § 6721 are:

Scenario

General Rule (§ 6721(a)(1))

Corrected on or before 30 days after required filing date (§ 6721(b)(1))

Corrected after 30th day but on or before August 1, 2025 (§ 6721(b)(2))

filed in 2025, the penalty amounts under

§ 6695 are:

Penalty Per Return

$330

$60

$130

Calendar Year Maximum

$1,329,000

$232,500

$664,500

of the filing requirement (or the correct

information reporting requirement):

1296

Bulletin No. 2023–48

Scenario

Penalty Per Return

Return other than a return required to be filed under

§§ 6045(a), 6041A(b), 6050H, 6050I, 6050J, 6050K, or

6050L (§ 6721(e)(2)(A))

Return required to be filed under §§ 6045(a), 6050K, or

6050L (§ 6721(e)(2)(B))

Greater of (i) $660, or (ii) 10% of aggregate

amount of items required to be reported

correctly

Greater of (i) $660, or (ii) 5% of aggregate

amount of items required to be reported

correctly

Greater of (i) $33,220, or (ii) amount of cash

received up to $132,500

Greater of (i) $660, or (ii) 10% of the value

of the benefit of any contract with respect to

which information is required to be included on

the return

Return required to be filed under § 6050I(a) (§ 6721(e)(2)(C))

Return required to be filed under § 6050V (§ 6721(e)(2)(D))

.59 Failure to Furnish Correct Payee

Statements. In the case of any failure

relating to a statement required to be furnished in 2025, the penalty amounts under

§ 6722 are:

No limit

Penalty Per Statement

$330

$60

Calendar Year Maximum

$3,987,000

$664,500

$130

$1,993,500

Penalty Per Statement

$330

$60

Calendar Year Maximum

$1,329,000

$232,500

$130

$664,500

statement (or the correct information

reporting requirement):

Scenario

Penalty Per Statement

Payee statement other than a statement required under §§ 6045(b),

6041A(e) (in respect of a return required under § 6041A(b)),

6050H(d), 6050J(e), 6050K(b), or 6050L(c) (§ 6722(e)(2)(A))

Payee statement required under §§ 6045(b), 6050K(b), or 6050L(c)

(§ 6722(e)(2)(B))

Bulletin No. 2023–48

No limit

years of $5,000,000 or less, for failure to

furnish correct payee statements:

Scenario

General Rule (§ 6722(d)(1)(A))

Corrected on or before 30 days after required furnishing date

(§ 6722(d)(1)(B))

Corrected after 30th day but on or before August 1, 2025 (§ 6722(d)

(1)(C))

(3) for failure to furnish correct payee

statements due to intentional disregard

of the requirement to furnish a payee

No limit

(1) for persons with average annual

gross receipts for the most recent three

taxable years of more than $5,000,000, for

failure to furnish correct payee statements:

Scenario

General Rule (§ 6722(a)(1))

Corrected on or before 30 days after required furnishing date

(§ 6722(b)(1))

Corrected after 30th day but on or before August 1, 2025 (§ 6722(b)

(2))

(2) for persons with average annual

gross receipts for the most recent 3 taxable

Calendar Year

Maximum

No limit

1297

Calendar Year

Maximum

No limit

Greater of (i) $660, or (ii) 10% of

aggregate amount of items required

to be reported correctly

Greater of (i) $660, or (ii) 5% of

No limit

aggregate amount of items required

to be reported correctly

November 27, 2023

.60 Revocation or Denial of Passport

in Case of Certain Tax Delinquencies.

For calendar year 2024, the amount of a

serious delinquent tax debt under § 7345

is $62,000.

.61 Attorney Fee Awards. For fees

incurred in calendar year 2024, the attorney fee award limitation under § 7430(c)

(1)(B)(iii) is $240 per hour.

.62 Periodic Payments Received Under

Qualified Long-Term Care Insurance

Contracts or Under Certain Life Insurance

Contracts. For calendar year 2024, the

stated dollar amount of the per diem limitation under § 7702B(d)(4), regarding

periodic payments received under a qualified long-term care insurance contract or

periodic payments received under a life

insurance contract that are treated as paid

by reason of the death of a chronically ill

individual, is $410.

.63 Qualified Small Employer Health

Reimbursement Arrangement. For taxable years beginning in 2024, to qualify

as a qualified small employer health reimbursement arrangement under § 9831(d),

the arrangement must provide that the total

amount of payments and reimbursements

November 27, 2023

for any year cannot exceed $6,150

($12,450 for family coverage).

SECTION 4. EFFECTIVE DATE

.01 General Rule. Except as provided

in section 4.02 of this revenue procedure,

this revenue procedure applies to taxable

years beginning in 2024.

.02 Calendar Year Rule. This revenue procedure applies to transactions or

events occurring in calendar year 2024 for

purposes of sections 3.08 (rehabilitation

expenditures treated as separate new building), 3.09 (low-income housing credit),

3.14 (transportation mainline pipeline construction industry optional expense substantiation rules for payments to employees

under accountable plans), 3.20 (private

activity bonds volume cap), 3.21 (loan

limits on agricultural bonds), 3.22 (general

arbitrage rebate rules), 3.23 (safe harbor

rules for broker commissions on guaranteed investment contracts or investments

purchased for a yield restricted defeasance

escrow), 3.37 (expatriation to avoid taxes),

3.40 (debt instruments arising out of sales

or exchanges), 3.41 (unified credit against

1298

estate tax), 3.42 (valuation of qualified real

property in decedent’s gross estate), 3.43

(annual exclusion for gifts), 3.44 (tax on

arrow shafts), 3.45 (passenger air transportation excise tax), 3.46 (tax on certain uses

of crude oil and petroleum products), 3.49

(persons against whom a federal tax lien

is not valid), 3.50 (property exempt from

levy), 3.52 (interest on a certain portion of

the estate tax payable in installments), 3.60

(revocation or denial of passport in case

of certain tax delinquencies), 3.61 (attorney fee awards), and 3.62 (periodic payments received under qualified long-term

care insurance contracts or under certain

life insurance contracts) of this revenue

procedure.

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Kyle Walker of the Office

of Associate Chief Counsel (Income Tax

& Accounting). For further information

regarding this revenue procedure, contact

Mr. Walker at (202) 317-4718 (not a tollfree number).

Bulletin No. 2023–48

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. 2023–48

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.

November 27, 2023

Numerical Finding List1

Bulletin 2023–48

Announcements:

2023-18, 2023-30 I.R.B. 366

2023-19, 2023-30 I.R.B. 367

2023-20, 2023-30 I.R.B. 368

2023-17, 2023-31 I.R.B. 412

2023-21, 2023-31 I.R.B. 413

2023-22, 2023-32 I.R.B. 429

2023-23, 2023-34 I.R.B. 569

2023-24, 2023-35 I.R.B. 661

2023-25, 2023-37 I.R.B. 821

2023-26, 2023-37 I.R.B. 822

2023-28, 2023-37 I.R.B. 823

2023-29, 2023-41 I.R.B. 1064

2023-30, 2023-45 I.R.B. 1236

2023-31, 2023-46 I.R.B. 1251

2023-32, 2023-47 I.R.B. 1258

2023-33, 2023-47 I.R.B. 1261

Notices:

2023-29, 2023-29 I.R.B. 1

2023-45, 2023-29 I.R.B. 317

2023-47, 2023-29 I.R.B. 318

2023-37, 2023-30 I.R.B. 359

2023-50, 2023-30 I.R.B. 361

2023-51, 2023-30 I.R.B. 362

2023-54, 2023-31 I.R.B. 382

2023-53, 2023-32 I.R.B. 424

2023-55, 2023-32 I.R.B. 427

2023-57, 2023-34 I.R.B. 560

2023-58, 2023-34 I.R.B. 563

2023-59, 2023-34 I.R.B. 564

2023-52, 2023-35 I.R.B. 650

2023-61, 2023-35 I.R.B. 651

2023-62, 2023-37 I.R.B. 817

2023-56, 2023-38 I.R.B. 824

2023-63, 2023-39 I.R.B. 919

2023-64, 2023-40 I.R.B. 974

2023-66, 2023-40 I.R.B. 992

2023-68, 2023-41 I.R.B. 1060

2023-65, 2023-42 I.R.B. 1067

2023-67, 2023-42 I.R.B. 1074

2023-69, 2023-42 I.R.B. 1079

2023-71, 2023-44 I.R.B. 1191

2023-70, 2023-45 I.R.B. 1228

2023-72, 2023-45 I.R.B. 1228

2023-73, 2023-45 I.R.B. 1232

2023-75, 2023-47 I.R.B. 1256

Proposed Regulations:—Continued

REG-109348-22, 2023-35 I.R.B. 662

REG-120727-21, 2023-36 I.R.B. 670

REG-122793-19, 2023-38 I.R.B. 829

REG-100908-23, 2023-39 I.R.B. 931

REG-115559-23, 2023-42 I.R.B. 1082

REG-106203-23, 2023-43 I.R.B. 1143

REG-113064-23, 2023-43 I.R.B. 1144

REG-117614-14, 2023-44 I.R.B. 1193

REG-127391-16, 2023-44 I.R.B. 1214

REG-103525-23, 2023-46 I.R.B. 1252

REG-115762-23, 2023-47 I.R.B. 1262

REG-120727-21, 2023-47 I.R.B. 1285

Revenue Procedures:

2023-31, 2023-25 I.R.B. 386

2023-26, 2023-33 I.R.B. 486

2023-27, 2023-35 I.R.B. 655

2023-17, 2023-37 I.R.B. 819

2023-30, 2023-40 I.R.B. 995

2023-31, 2023-40 I.R.B. 1057

2023-32, 2023-41 I.R.B. 1064

2023-35, 2023-42 I.R.B. 1079

2023-28, 2023-43 I.R.B. 1092

2023-33, 2023-43 I.R.B. 1135

2023-34, 2023-48 I.R.B. 1287

Revenue Rulings:

2023-13, 2023-32 I.R.B. 413

2023-14, 2023-33 I.R.B. 484

2023-15, 2023-34 I.R.B. 559

2023-16, 2023-37 I.R.B. 796

2023-17, 2023-37 I.R.B. 798

2023-18, 2023-40 I.R.B. 972

2023-19, 2023-41 I.R.B. 1059

2023-20, 2023-45 I.R.B. 1221

Treasury Decisions:

9976, 2023-30 I.R.B. 354

9977, 2023-31 I.R.B. 375

9978, 2023-32 I.R.B. 415

9979, 2023-35 I.R.B. 602

9980, 2023-43 I.R.B. 1087

9981, 2023-44 I.R.B. 1174

9982, 2023-45 I.R.B. 1223

9983, 2023-46 I.R.B. 1237

Proposed Regulations:

REG-124123-22, 2023-30 I.R.B. 369

REG-124930-21, 2023-31 I.R.B. 431

REG-120730-21, 2023-33 I.R.B. 491

REG-134420-10, 2023-34 I.R.B. 571

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 27, 2023.

November 27, 2023

Bulletin No. 2023–48

Finding List of Current Actions on

Previously Published Items1

Bulletin 2023–48

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 27, 2023.

Bulletin No. 2023–48

iii

November 27, 2023

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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