These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2024–7

February 12, 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

or in part, for the acts or omissions of the organization that

were the basis for revocation.

Rev. Rul. 2024-5, page 666.

Announcement 2024-9, page 675.

This revenue ruling holds that if one or more of a State’s

allocations, under section 305 of the Taxpayer Certainty

and Disaster Tax Relief Act of 2020, to qualified disaster

zones in 2021 or 2022 are returned after 2022, then the

returned housing credit dollar amounts are part of the overall Returned Credit Component of a State’s housing credit

ceiling in the year of return. As such, reallocations of these

returned amounts are not restricted to projects located in

qualified disaster zones.

EXEMPT ORGANIZATIONS

Announcement 2024-7, page 673.

Announcement 2024-7 contains corrections to Revenue Procedure 2024-5, 2024-5 IRB 1, which contains errors in the

user fee schedule found in Appendix A, which user fees apply

to certain requests for advance approvals.

Announcement 2024-8, page 674.

The Internal Revenue Service has revoked its determination

that Altruistic United Humanity Association qualifies as an organization described in sections 501(c )(3) and 170(c)(2) of the

Internal Revenue Code of 1986. The revocation is effective

January 1, 2018. If a suit for declaratory judgment has been

timely filed, contributions from individuals and organizations

described in section 170(c )(2) that are otherwise allowable

will continue to be deductible. Protection under section 7428(c

) would begin on January 1, 2018 and would end on the date

the court first determines the organization is not described in

section 170(c )(2) as more particularly set for in section 7428(

c)(1). For individual contributions, the maximum deduction protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in whole

Finding Lists begin on page ii.

Revocation of IRC 501(c)(3) Organizations for failure to meet

the code section requirements. Contributions made to the

organizations by individual donors are no longer deductible

under IRC 170(c).

INCOME TAX

Notice 2024-20, page 668.

The Treasury Department and the IRS intend to propose

regulations addressing the requirements for determining in

which population census tracts qualified alternative fuel vehicle refueling property must be placed in service in order to

be eligible for the alternative fuel vehicle refueling property

credit under § 30C of the Internal Revenue Code. This notice

specifies the requirements that the forthcoming proposed

regulations would set forth for qualifying as an eligible census tract for purposes of the § 30C credit and provides guidance that the forthcoming proposed regulations would set

forth on how taxpayers can verify that property satisfies the

geographic requirements of § 30C.

Notice 2024-23, page 672.

This notice provides guidance on certain distributions from

or distributions transferred to the Maryland Prepaid College Trust, a qualified tuition program within the meaning

of section 529 of the Internal Revenue Code, for taxpayers

impacted by recent system issues described in the Maryland State Treasurer’s Decision Memorandum dated July 10,

2023. Specifically, this notice provides that the 12-month limitation described in section 529(c)(3)(C)(iii) will not be treated

as applying to certain distributions described in section III of

this notice.

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.

February 12, 2024 

Bulletin No. 2024–7

Part I

Section 42.—Low-income

housing credit

26 CFR 1.42-14: Allocation rules for post-2000 State

housing credit ceiling amount.

Rev. Rul. 2024-5

ISSUE

Section 305 of the Taxpayer Certainty

and Disaster Tax Relief Act of 2020,

Public Law 116-260, div. EE, 134 Stat.

3038, 3080 (Dec. 27, 2020) (Act) authorized housing credit agencies (Agencies)

to allocate additional housing credit dollar amounts (HCDAs) in 2021 or 2022 to

buildings in one or more qualified disaster zones (as defined in section 301(2) of

the Act). If an Agency allocated HCDAs

to buildings located in qualified disaster

zones in 2021 or 2022 and some of those

amounts are returned to the Agency after

2022, may the Agency reallocate those

returned amounts, and, if so, are the reallocations restricted to buildings in a qualified disaster zone?

LAW

Under section 305(a)(1) and (2) of the

Act, for purposes of section 42 of the Internal Revenue Code (Code)1, the State housing credit ceiling for any State for each of

calendar years 2021 and 2022 is increased

by the aggregate HCDA allocated by the

State’s Agencies for the calendar year to

buildings located in any qualified disaster

zone (as defined in section 301(2) of the

Act) in the State up to an aggregate limitation as set in section 305(a)(2) of the Act

(Applicable Dollar Limitation).

Section 305(a)(4) of the Act provides

that, for purposes of determining the

unused State housing credit ceiling for

any calendar year under section 42(h)

(3)(C), any increase in the State housing

credit ceiling under section 305(a)(1) of

the Act is treated as an amount described

in section 42(h)(3)(C)(ii).

1

2

Section 42(h)(3)(C) defines the State

housing credit ceiling applicable to

any State for any calendar year to be an

amount equal to the sum of the following

four amounts—

(i) the “Unused Carryforward Component,” which is the amount of the

unused State housing credit ceiling (if

any) of such State for the preceding

calendar year,

(ii) the “Population Component,” which

is the amount equal to the greater

of—

(I) $1.75 multiplied by the State

population, or

(II) $2,000,000,2

(iii) the “Returned Credit Component,”

which is the amount of State housing

credit ceiling returned in the calendar

year, plus

(iv) the “National Pool Component,”

which is the amount (if any) allocated

under section 42(h)(3)(D) from a

national pool of unused credit to such

State by the Secretary of the Treasury

or her delegate.

Section 1.42-14(d)(1) further provides

that the Returned Credit Component of

the State housing credit ceiling of a State

for any calendar year equals the HCDA

returned during the calendar year that

was validly allocated within the State in

a prior calendar year to any project that

does not become a qualified low-income

housing project within the period required

by section 42, or as required by the terms

of the allocation. The Returned Credit

Component also includes credit allocated

in a prior calendar year that is returned as

a result of the cancellation of an allocation

by mutual consent or by a State’s determination that the amount allocated is not

necessary for the financial feasibility of

the project.

Section 1.42-14(g) sets forth the stacking order regarding how credit is treated

as allocated from the various components

of the State housing credit ceiling. Specifically, the first credit allocated for any

calendar year is treated as credit from the

Unused Carryforward Component of the

State housing credit ceiling for the calendar

year. After all of the credit in the Unused

Carryforward Component has been allocated, any credit allocated is treated as

allocated from the sum of the Population,

Returned Credit, and National Pool Components of the State housing credit ceiling.

Notice 2021-45, 2021-31 I.R.B. 170,

identified the 11 States and Puerto Rico

that had qualified disaster zones, along

with the State populations residing in

each. It also contained a list of counties

and parishes located within the qualified

disaster zones.

IRS Announcement 2022-27, 2022-51

I.R.B. 559, reminded Agencies that unless

an allocation was in 2021 and 2022, it

would fail to increase a State’s housing

credit ceiling.

ANALYSIS

Under section 305(a)(1) of the Act, a

State’s housing credit ceiling is increased

in calendar years 2021 and 2022 to reflect

the aggregate HCDAs that are allocated

by the State to buildings located in any

qualified disaster zone in the State. The

aggregate increases for both years, however, may not exceed the Applicable Dollar Limitation. Section 305(a)(4) of the

Act provides that the increase is taken

into account in the Population Component of a State’s housing credit ceiling

for the purpose of determining the unused

State housing credit ceiling for any calendar year. Thus, the housing credit ceiling

increase resulting from a valid allocation

under the Act joins with the otherwise-determined Population Component of a

State’s housing credit ceiling in the year

of allocation.

The need for an increase in the State’s

housing credit ceiling for the year of allocation implies that a qualified disaster zone

allocation comes out of the State’s housing

credit ceiling for the allocation year. Without the increase, a qualified disaster zone

allocation would reduce the credit ceiling

amounts available to the State for other

projects in that year. Consistent with sec-

Unless otherwise specified, all "section" or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

An annual cost of living adjustment applies to both elements of the Population Component under section 42(h)(3)(H).

February 12, 2024

666

Bulletin No. 2024–7

tion 42(h)(3)(C)(iii) and § 1.42-14(d)(1) in

all years, the Returned Credit Component

for any year is the amount of State housing credit ceiling allocated in a prior year

that is returned in the calendar year at issue.

Because the Act treats the disaster allocations as coming out of the allocation-year

ceiling, any such allocation that is returned

in 2023 or after meets the requirements in

section 42(h)(3)(C)(iii) and § 1.42-14(d)

(1). As such, the returned allocation is part

of the Returned Credit Component of a

State’s housing credit ceiling in the year of

return and may be reallocated.

Other than increasing the State’s 2021

and 2022 housing credit ceiling, section

305 of the Act ascribes no special attributes to HCDA allocations to qualified

disaster zones. After their allocation, these

HCDAs have no statutory attributes that

distinguish them from any other allocations that had been made from the allocation-year ceiling. Put differently, the

Act provides for the increase in the credit

ceiling and indicates where the increase is

taken account for purposes of the stacking

order, but does not provide rules for how

Bulletin No. 2024–7

a State should reallocate these amounts if

they are returned after 2022.

The Act’s silence about returned allocations suggests that the normal returned

credit rules under section 42 apply to these

returned allocations as well. Further, there

is an indication that the Act affirmatively

intended for normal section 42 rules to

apply after a valid allocation to a qualified disaster zone. Because section 305(a)

(4) of the Act provides that the increase in

the credit ceiling is part of the Population

Component for determining the Unused

Carryforward Component for the next

year, it indicates an intent to apply the

general stacking order of the rules under

§ 1.42-14(g). For example, this would

mean that a State’s allocations would first

reduce the State’s current year Unused

Carryforward Component (regardless

of whether to a qualified disaster zone)

before reducing the other components of

a State’s housing credit ceiling. Therefore, under the Act, the regular section

42 returned credit rules would apply to a

returned allocation that was validly allocated in a prior calendar year.

667

HOLDING

If one or more of a State’s allocations

to qualified disaster zones in 2021 or 2022

are returned after 2022, then the returned

HCDAs are part of the overall Returned

Credit Component of a State’s housing

credit ceiling in the year of return. As such,

reallocations of these returned amounts

are not restricted to projects located in

qualified disaster zones.

The analysis in this revenue ruling

applies only for purposes of determining

the validity of reallocations of HCDAs

whose previous allocations had increased

a State’s housing credit ceiling under section 305 of the Act.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Dillon Taylor of the Office of

Associate Chief Counsel (Passthroughs &

Special Industries). For further information regarding this revenue ruling, contact

Dillon Taylor at (202) 317-4137 (not a

toll-free number).

February 12, 2024

Part III

Guidance on Satisfying the

Geographical Requirements

of the Section 30C

Alternative Fuel Vehicle

Refueling Property Credit

Notice 2024-20

SECTION 1. PURPOSE

The Department of the Treasury

(Treasury Department) and the Internal Revenue Service (IRS) intend

to propose regulations (forthcoming

proposed regulations) addressing the

requirements for determining in which

population census tracts qualified alternative fuel vehicle refueling property

must be placed in service, in order to be

eligible for the alternative fuel vehicle

refueling property credit under § 30C

(§ 30C credit) of the Internal Revenue

Code (Code), as amended by § 13404

of Public Law 117-169, 136 Stat. 1818

(August 16, 2022), commonly known

as the Inflation Reduction Act of 2022

(IRA).1 Sections 2 and 3 of this notice

provide relevant background and definitions, respectively, with respect to the

§ 30C credit. Section 4 of this notice

specifies the requirements that the forthcoming proposed regulations would

set forth for qualifying as an eligible

census tract for purposes of the § 30C

credit. Section 5 of this notice provides

guidance that the forthcoming proposed

regulations would set forth on how taxpayers can verify that property satisfies

the geographic requirements of § 30C(c)

(3)). Until the issuance of the forthcoming proposed regulations, taxpayers may

rely on sections 4 and 5 of this notice. In

addition, this notice includes Appendices A and B,2 which list population census tracts that, under the rules intended

to be proposed, the Treasury Department

and the IRS have determined are eligible

census tracts.

SECTION 2. BACKGROUND

.01 Section 30C was originally enacted

by § 1342(a) of the Energy Policy Act

of 2005, Public Law 109-58, 119 Stat.

1049 (Aug. 8, 2005), to provide a credit

for the cost of qualified alternative fuel

vehicle refueling property. Section 30C

has been amended several times since its

enactment, most recently by § 13404 of

the IRA, which extended the § 30C credit

(as in effect prior to the IRA) for qualified

alternative fuel vehicle refueling property placed in service after December 31,

2021, and modified the § 30C credit, as

described below, effective with respect to

qualified alternative fuel vehicle refueling

property placed in service after December

31, 2022, and on or before December 31,

2032.

.02 The amount of the § 30C credit is

treated as a personal credit or a general

business credit depending on the character of the property. In general, the §

30C credit is a nonrefundable personal

credit allowable under subpart B of part

IV of subchapter A of chapter 1 of the

Code. However, the amount of the § 30C

credit that is attributable to property that

is of a character subject to an allowance

for depreciation (depreciable property)

is treated under § 30C(d)(1) as a current

year business credit under § 38(b) instead

of being allowed under § 30C(a).

.03 The IRA modified § 30C in several

ways. First, the IRA modified the limitation on the § 30C credit so that it no longer applies per location and instead applies

per single item of qualified alternative fuel

vehicle refueling property and increased

the limitation for depreciable property. The

§ 30C credit with respect to any single item

of qualified alternative fuel vehicle refueling property placed in service by the taxpayer during the taxable year is limited to

$100,000 in the case of depreciable property, and $1,000 in any other case.

.04 Second, the IRA added a requirement that qualified alternative fuel vehicle refueling property must be placed in

service in an eligible census tract. An eligible census tract is any population census tract that is a low-income community

as described in § 45D(e) or that is not an

urban area.

.05 Third, the IRA clarified that property will not fail to be treated as qualified

alternative fuel vehicle refueling property

solely because such property can charge

the battery of a motor vehicle propelled

by electricity and can discharge electricity

from such battery to an electric load external to such motor vehicle.

.06 Fourth, the IRA modified the definition of qualified alternative fuel vehicle

refueling property to include depreciable

property designed to charge two- and

three-wheeled motor vehicles manufactured primarily for use on public streets,

roads, or highways and that are propelled

by electricity.

.07 Fifth, the IRA modified the credit

amount for depreciable qualified alternative fuel vehicle refueling property from

30 percent to 6 percent and provided an

enhanced credit amount for such property that is part of a qualified alternative

fuel vehicle refueling project. A qualified

alternative fuel vehicle refueling project is

a project (1) that meets certain prevailing

wage and apprenticeship requirements or

(2) for which the construction began prior

to January 29, 2023.

.08 Separately, the IRA allows an applicable entity (as defined in § 6417(d)(1)

(A)) to make an election under § 6417 to

be treated as making a payment against the

tax imposed by subtitle A of the Code (for

the taxable year with respect to which an

applicable credit (as defined in § 6417(b))

was determined) equal to the amount of

the applicable credit. The amount of a

§ 30C credit, to the extent treated under

§ 30C(d)(1) as a general business credit

under § 38, is an applicable credit. The

IRA also permits an eligible taxpayer to

make an election under § 6418 to transfer

all or a portion of the § 30C credit determined with respect to such taxpayer for

any taxable year to an unrelated taxpayer.

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

Appendix A can be found at https://www.irs.gov/pub/irs-drop/appendix-a-list-of-2015-census-tract-boundary-30c-eligible-tracts-v2-1-4-2024.pdf. Appendix B can be found at https://www.

irs.gov/pub/irs-drop/appendix-b-list-of-2020-census-tract-boundary-30c-eligible-tracts-v2-1-4-2024.pdf.

1

2

February 12, 2024

668

Bulletin No. 2024–7

SECTION 3. GENERAL

DEFINITIONS

.01 Qualified Alternative Fuel Vehicle

Refueling Property. “Qualified alternative

fuel refueling property” means property

that meets the requirements of § 30C(c)

(1).

.02 Placed in Service.

(1) Depreciable property. Qualified

alternative fuel vehicle refueling property

that is depreciable property is considered

placed in service in the earlier of the following taxable years:

(a) The taxable year in which, under

the taxpayer’s depreciation practice, the

period for depreciation with respect to

such property begins; or

(b) The taxable year in which such

property is placed in a condition or state

of readiness and availability for a specifically assigned function, whether in a trade

or business or in the production of income.

(2) Non-depreciable property. Qualified alternative fuel vehicle refueling

property that is non-depreciable property

is considered placed in service when it is

installed at the principal residence of the

taxpayer and is operational.

.03 Low-Income Community Census

Tract. A “low-income community census tract” is a population census tract

described in section 4.03 of this notice.

.04 Non-Urban Census Tract. A

“non-urban census tract” is a population

census tract as described in section 4.04

of this notice.

.05 2020 Non-Urban Census Tracts.

The term “2020 non-urban census tracts”

is defined in section 4.04 of this notice.

.06 2011-2015 NMTC Tracts. The term

“2011-2015 NMTC tracts” is defined in

section 4.03 of this notice.

.07 2016-2020 NMTC tracts. The term

“2016-2020 NMTC tracts” is defined in

section 4.03 of this notice.

.08 2015 Census Tract Boundaries.

The term “2015 census tract boundaries”

is defined in section 4.03 of this notice.

.09 2020 Census Tract Boundaries.

The term “2020 census tract boundaries”

is defined in section 4.03 of this notice.

.10 GEOID. A “GEOID” is a numeric

identifier associated with a geographic area.

.11 11-digit census tract GEOID.

An “11-digit census tract GEOID” is a

GEOID defined by the U.S. Bureau of the

Census (Census Bureau) and comprised

of a 2-digit state GEOID, 3-digit county

GEOID, and 6-digit census tract GEOID.

The 11-digit census tract GEOID provides

a unique identifier for each population

census tract in the United States, including

tracts in the U.S. territories. The 11-digit

census tract GEOIDs may vary for any

individual latitude/longitude point based

on different census tract boundary delineation dates over time.

SECTION 4. ELIGIBLE CENSUS

TRACTS

.01 Eligible Census Tracts Generally.

(1) Section 30C(c)(3) requires qualified

alternative fuel vehicle refueling property

to be placed in service in an eligible census tract in order to be eligible for the §

30C credit. An eligible census tract is any

population census tract that qualifies as a

low-income community as described in §

45D(e), or that is not an urban area. Consistent with § 30C(c)(3), the forthcoming

proposed regulations would define eligible census tract to include low-income

community census tracts and non-urban

census tracts.

(2) Section 30C(e)(3) provides generally that property used outside the United

States does not qualify for the § 30C

credit by excluding property described

in § 50(b)(1), which provides generally

that property used predominantly outside

the United States does not qualify for a

credit to which § 50 applies. Section 50(b)

(1)(B) provides an exception for property described in § 168(g)(4) that would

allow property used predominantly in a

territory of the United States to qualify

for the § 30C credit. Section 168(g)(4)

describes, among other things, property

that is owned by a domestic corporation

or by a United States citizen (other than a

citizen entitled to the benefits of § 931 or

§ 933) and that is used predominantly in a

territory (also referred to as a possession)

of the United States by such a corporation

or such a citizen, or by a corporation created or organized in, or under the law of,

a territory of the United States. Because

§ 30C(e)(3) allows for certain qualified

alternative fuel vehicle refueling property

to be used predominantly in a territory of

the United States, eligible census tracts

include low-income community census

tracts and non-urban census tracts located

in a territory of the United States.

.02 Census Bureau Terminology: Census Blocks, Population Census Tracts,

Census Tract Boundaries, and Urban

Areas.

(1) Census block. A “census block” is

the smallest geographic area for which

the Census Bureau collects and tabulates

decennial census data.

(2) Population Census Tract. A “population census tract” is defined by the

Census Bureau as small-area geographic

divisions of a county or statistically equivalent entity defined for the tabulation

and presentation of data from the decennial census and selected other statistical

programs.3 Population census tracts are

comprised of census blocks. The Census

Bureau assigns to each population census tract a unique 11-digit census tract

GEOID.

(3) Census Tract Boundaries. The

Census Bureau delineates census tract

boundaries largely based on population

and housing density. For each decennial census, census tract boundaries are

drawn to satisfy specific statistical measures. Boundaries generally follow visible and identifiable features but may also

follow nonvisible legal boundaries. The

most recent decennial census was conducted in 2020 (2020 Census). Census

tract boundaries generally do not change

between decennial censuses but may do

so based on legal changes in geographic

areas. Consequently, the Census Bureau

releases updated delineations of census

tract boundaries every year. The Census

Bureau provides mapping files for each

year to reflect the census tract boundaries

in that year.4

3

See U.S. Department of Commerce, Bureau of the Census, “Census Tracts for the 2020 Census—Final Criteria,” 83 F.R. 56277 (Nov. 14, 2018), available at https://www.federalregister.gov/

documents/2018/11/13/2018-24567/census-tracts-for-the-2020-census-final-criteria.

4

See U.S. Department of Commerce, Bureau of the Census, “TIGER/Line Shapefiles,” available at https://www.census.gov/geographies/mapping-files/time-series/geo/tiger-line-file.html.

Bulletin No. 2024–7

669

February 12, 2024

(4) Urban Area. The Census Bureau

determines urban areas based on densely

developed territory encompassing residential, commercial, and other non-residential urban land uses. The Census

Bureau delineates urban areas after each

decennial census by applying specified

criteria to decennial census and other data.

.03 Low-Income Community Census

Tracts.

(1) Under § 30C(c)(3)(B)(i), an eligible census tract includes any population

census tract that is described in § 45D(e),

which defines the term “low-income community” for purposes of the new markets

tax credit under § 45D (NMTC). In general, § 45D(e)(1) defines a low-income

community as any population census tract

for which the poverty rate is at least 20 percent based on the relevant American Community Survey (ACS) 5-year estimate.

Section 45D(e)(1) further provides that

a tract not located within a metropolitan

area constitutes a low-income community

if the median family income for such tract

does not exceed 80 percent of statewide

median family income. It additionally

provides that a tract located within a metropolitan area is a low-income community

if the median family income for such tract

does not exceed 80 percent of the greater

of the statewide median family income

or the metropolitan area median family income. Section 45D(e)(2) provides

that certain targeted populations (within

the meaning of § 103(20) of the Riegle

Community Development and Regulatory Improvement Act of 1994 (12 U.S.C.

4702(20)) may be treated as low-income

communities. Section 45D(e)(3) describes

the appropriate areas not within population census tracts that are used to determine poverty rates and median family

income. Section 45D(e)(4) describes certain population census tracts with a population of less than 2,000 that are treated as

a low-income community for purposes of

the NMTC. Finally, § 45D(e)(5) describes

population census tracts located within a

high migration rural county.

(2) After consultation with the Community Development Financial Institu-

tions Fund (CDFI Fund), which jointly

administers § 45D with the IRS, the

Treasury Department and the IRS cannot

identify with verifiable accuracy the population census tracts that currently meet

the requirements of § 45D(e)(2) and (4).

Accordingly, the Treasury Department

and the IRS intend to request comments

on whether and how such population census tracts could be accurately identified to

qualify as eligible census tracts in future

guidance. Furthermore, the Treasury

Department and the IRS have concluded

that areas described in § 45D(e)(3) do not

qualify as eligible census tracts because

they are not population census tracts as

required by § 30C(c)(3)(B)(i).

(3) Low-income community population census tracts are determined by the

CDFI Fund. The CDFI Fund determines

these population census tracts based in

part on ACS 5-year estimates, which are

published by the Census Bureau. The

CDFI Fund updates the NMTC determination of “low-income community”

census tracts approximately every five

years based on the updated ACS 5-year

estimates. Prior to September 1, 2023,

the NMTC low-income community census tracts were based on 2011-2015 ACS

5-year estimates (2011-2015 NMTC

tracts), which use the 2015 delineation

of census tract boundaries (2015 census

tract boundaries). On September 1, 2023,

the NMTC low-income community census tracts were updated to be based on the

2016-2020 ACS 5-year estimates (20162020 NMTC tracts), which use the 2020

delineation of census tract boundaries

(2020 census tract boundaries).5

(4) For purposes of the NMTC, prior

to September 1, 2023, taxpayers had to

look to the 2011-2015 NMTC tracts to

determine which population census tracts

were low-income communities. After a

data update, CDFI Fund provides a oneyear transition period. Therefore, between

September 1, 2023, and August 31, 2024,

taxpayers can look to either the 2011-2015

NMTC or the 2016-2020 NMTC tracts to

determine which population census tracts

are low-income communities for the

NMTC. On or after September 1, 2024,

taxpayers must look to the 2016-2020

NMTC tracts to determine which population census tracts are low-income communities for the NMTC.

(5) For purposes of § 30C(c)(3)(B)

(i)(I), the Treasury Department and the

IRS intend to propose regulations that

will designate population census tracts as

low-income community census tracts. For

qualified alternative fuel vehicle refueling property that is placed in service after

December 31, 2022, and before January 1,

2025, the Treasury Department and the IRS

intend to provide guidance stating that a

taxpayer may utilize either the 2011-2015

NMTC tracts or the 2016-2020 NMTC

tracts to determine if property is placed

in service in a low-income community.

This transition period is largely consistent

with the transition period for purposes of

the NMTC. However, the period in which

a taxpayer may make a determination

based on either NMTC determination and

related census tract boundary delineation

for purposes of the § 30C credit would

be extended to include the periods from

January 1, 2023, to August 31, 2023, and

from September 1, 2024, to December 31,

2024, so that taxpayers could rely on the

same NMTC determination and relevant

census tract boundary delineation for all

property placed in service in the same calendar year. This transition period will be

applicable only for purposes of the § 30C

credit.

.04 Non-Urban Census Tracts. Under

§ 30C(c)(3)(B)(ii), the term “urban area”

means a population census tract that

has been designated as an urban area by

the Secretary of Commerce in the most

recent decennial census. However, as of

the 2020 Census (the most recent decennial census), the Census Bureau defines

urban areas on the basis of census blocks

and not on the basis of population census

tracts.6 For purposes of § 30C(c)(3)(B)(i)

(II), the Treasury Department and the IRS

intend to propose regulations providing

that any population census tract in which

at least 10 percent of the census blocks

are not designated as urban areas would

U.S. Department of Treasury, CDFI Fund, “2016-2020 American Community Survey (ACS) Data Frequently Asked Questions,” available at https://www.cdfifund.gov/sites/cdfi/files/202309/NMTC_LIC_FAQs_2020_ACS_Sept1_2023.pdf.

6

U.S. Department of Commerce, Bureau of the Census, “2020 Census Qualifying Urban Areas and Final Criteria Clarifications, 87 F.R. 80114 (December 29, 2022),” available at https://

www.federalregister.gov/documents/2022/12/29/2022-28286/2020-census-qualifying-urban-areas-and-final-criteria-clarifications.

5

February 12, 2024

670

Bulletin No. 2024–7

be a “non-urban census tract.” The Treasury Department and the IRS also intend

to use the 2020 census tract boundaries,

and the Census Bureau’s determination of

urban areas using the 2020 Census. Thus,

these “2020 non-urban census tracts”

would be eligible census tracts for purposes of § 30C. The Treasury Department

and the IRS believe that this definition is

consistent with the purpose of § 30C of

providing a credit to alternative vehicle

fuel refueling property placed in service

in non-urban areas. The Treasury Department and the IRS received a number of

comments on the appropriate threshold of

urban blocks, and the 10-percent threshold is within the range suggested by commenters.

.05 Anticipated Update for Low-income Community Census Tracts. Low-income community census tracts will be

updated for purposes of the § 30C credit

upon future releases of NMTC census

tract determinations by the CDFI Fund.

The Treasury Department and the IRS

anticipate that an updated set of NMTC

tracts will be released by the CDFI Fund in

approximately late 2028 (NMTC updated

census tracts). The 2016-2020 NMTC

tracts are anticipated to remain eligible

locations for the § 30C credit through

2029, after which the NMTC updated census tracts would provide the determination

of low-income community census tracts.

After the NMTC updated census tracts are

released, the Treasury Department and the

IRS anticipate providing guidance reflecting the updated set of low-income community census tracts.

.06 Potential Update for Non-urban Census Tracts. The Census Bureau

released the 2020 determinations of urban

areas in 2023; therefore, the Treasury

Department and the IRS anticipate that

the 2030 determinations of urban areas

may not be released until 2033. In the

event that the Census Bureau releases the

determinations of the 2030 urban areas

earlier than January 1, 2033, the Treasury

Department and the IRS anticipate provid-

ing guidance reflecting the updated set of

non-urban census tracts. Until that time,

taxpayers should use the 2020 non-urban

census tracts to determine eligibility for

the § 30C credit.

SECTION 5. DETERMINING

WHETHER A PROPERTY IS

LOCATED IN AN ELIGIBLE

CENSUS TRACT

.01 Eligible Census Tracts.

(1) Appendix A lists the eligible low-income community census tracts using the

2011-2015 NMTC tracts with the 2015

census tract boundaries. Appendix A

can be found at https://www.irs.gov/pub/

irs-drop/appendix-a-list-of-2015-censustract-boundary-30c-eligible-tracts-v2-14-2024.pdf. Appendix B lists the eligible low-income community census tracts

using the 2016-2020 NMTC tracts and

2020 non-urban census tracts, both with the

2020 census tract boundaries. Appendix B

can be found at https://www.irs.gov/pub/

irs-drop/appendix-b-list-of-2020-censustract-boundary-30c-eligible-tracts-v2-14-2024.pdf.

(2) Qualified alternative fuel refueling

property placed in service after December

31, 2022, and before January 1, 2025, will

be considered placed in service in an eligible census tract, and thus eligible for the

§ 30C credit, if the 11-digit census tract

GEOID for the population census tract in

which it is placed in service is listed in the

applicable appendix, either Appendix A or

Appendix B.

(3) Qualified alternative fuel refueling

property placed in service after December

31, 2024, and before January 1, 2030, will

be considered placed in service in an eligible census tract, and thus eligible for the

§ 30C credit, if the 11-digit census tract

GEOID for the population census tract in

which it is placed in service is listed in

Appendix B.

(4) The latitude and longitude of an

eligible property may provide a different

11-digit census tract GEOID under the

2015 and 2020 census tract boundaries. In

such cases, a location is only in an eligible

census tract if the relevant 11-digit census

tract GEOID is listed in the appendix specific to the relevant census tract boundary

year. Thus, in such cases, a location is only

in an eligible census tract if its 11-digit

census tract GEOID under the 2015 tract

boundaries is listed in Appendix A. Similarly, in such cases, a location is only in an

eligible census tract if its 11-digit census

tract GEOID under the 2020 boundaries is

listed in Appendix B.

.02 Determining 11- digit census tract

GEOID for properties placed in service

before January 1, 2030.

(1) The population census tract boundaries are pertinent for taxpayers in identifying the relevant 11-digit census tract

GEOID. For property placed in service

after December 31, 2022, and before January 1, 2025, both the 2015 census tract

boundaries and the 2020 census tract

boundaries are relevant. For property

placed in service on or after January 1,

2025, and before January 1, 2030, only the

2020 census tract boundaries are relevant.

As noted above, the latitude and longitude

of an eligible property may provide a different 11-digit census tract GEOID under

the 2015 and 2020 census tract boundaries.

(2) Taxpayers can determine the

11-digit census tract GEOID of a location

under the 2015 census tract boundaries by

using the CDFI mapping tool available via

https://www.cdfifund.gov/cims. 7

(3) Taxpayers can determine the 11-digit

census tract GEOID of a location under

the 2020 census tract boundaries using the

Census Geocoder, available via https://

geocoding.geo.census.gov/geocoder/

geographies/address?form or of a latitude

and longitude point at https://geocoding.

geo.census.gov/geocoder/geographies/

coordinates?form. 8

.03 Reliance. Until the issuance of

the forthcoming proposed regulations,

taxpayers may rely on this notice and its

appendices for purposes of determining

On that page, choose “CDFI,” which should take the user to a page titled “CDFI Public Viewer.” In the left-hand side column, choose “Layers.” Under “CIMS Layers,” put a checkmark

in the box next to “2015 CDFI Tract” and remove all checkboxes from other CIMS Layers. Specifically, uncheck the “2020 CDFI Tract” box. Type in your address or latitude and longitude

in the “Search Addresses” bar at the top. This will take you to the tract of the location you entered. If you left click your mouse, the 11-digit population census tract identifier (that is, the

GEOID) will appear.

8

In the “Benchmark” drop-down menu, choose “Public_AR_Census2020.” In the “Vintage” drop-down menu, choose “Census2020_Current.” The 11-digit population census tract identifier

is in the GEOID under “Census Tracts.” Further instructions to use the Census Geocoder are available via https://www2.census.gov/data/api-documentation/Address%20Search%20-%20

Geocoder%20and%20TIGERweb/How%20to%20Find%20Geo%20Info%20from%20Address.pdf.

7

Bulletin No. 2024–7

671

February 12, 2024

whether qualified alternative fuel vehicle

property has been placed in service in an

eligible census tract. In addition, until the

issuance of the forthcoming proposed regulations, the IRS will administer § 30C in

a manner consistent with the appendices

and related rules described in this notice.

SECTION 6. CONTACT

INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

(Passthroughs & Special Industries). For

further information regarding this notice

contact the Office of Associate Chief

Counsel (Passthroughs & Special Industries) at (202) 317-6853 (not a toll-free

number).

Certain Maryland Prepaid

College Trust Distributions

Excluded from Gross

Income

Notice 2024-23

SECTION I. PURPOSE

This notice provides guidance on certain distributions from or distributions

transferred to the Maryland Prepaid College Trust (MPCT), a qualified tuition

program within the meaning of section

529 of the Internal Revenue Code (section

529 program),1 for taxpayers impacted by

recent system issues described in the Maryland State Treasurer’s Decision Memorandum dated July 10, 2023 (Memorandum).2

Specifically, this notice provides that the

12-month limitation described in section

529(c)(3)(C)(iii) will not be treated as

applying to certain distributions described

in section III of this notice.

SECTION II. BACKGROUND

Generally, any distribution from a section 529 program is includable in the gross

income of the distributee under section

529(c)(3)(A) to the extent not otherwise

excluded from gross income under another

provision of chapter 1 of the Code. Section 529(c)(6) imposes an additional tax

on distributions includable in gross income

equal to 10 percent of the amount that is

so includable. Section 529(c)(3)(C)(i)(I),

however, excludes from gross income any

portion of a distribution from a section 529

program that, within 60 days of such distribution, is transferred to another section 529

program for the benefit of the designated

beneficiary (qualified rollover). Section

529(c)(3)(C)(iii) allows only one tax-free

qualified rollover in a 12-month period.

In recent years, MPCT has experienced

accounting discrepancies, administrative

issues, and inconsistencies concerning the

interest rate to apply to certain distributions out of MPCT accounts, as described

more fully in the Memorandum.3 To protect trust assets while system issues were

resolved, the state agency administering

MPCT froze access to MPCT interest

earnings beginning in April 2022. System

access has since been restored, and on July

10, 2023, the Maryland State Treasurer

announced a final decision that provided

retroactive interest earnings for affected

MPCT account holders. However, due

to the unique and unanticipated circumstances described in the Memorandum,

many taxpayers had already executed

a qualified rollover out of MPCT. After

the Maryland State Treasurer announced

the decision to credit retroactive interest

to affected MPCT account holders, some

taxpayers who had previously executed a

qualified rollover from an MPCT account

to another qualified state tuition program

may wish to execute a second rollover

back to the MPCT, to the extent permitted

by Maryland law. In addition, Chapter 113

of the 2023 Laws of Maryland established

a claims resolution process for account

holders affected by the system issues. Settlement of a claim must “be conditioned

on an agreement of the account holder to

transfer all funds in the account to any other

qualified state tuition program.”4 If any of

these taxpayers execute a second rollover

within 12 months of a qualified rollover

out of or back into MPCT, however, the

amount so transferred may be includable

in the gross income of the designated

beneficiary under section 529(c)(3)(A)

and may be subject to additional tax under

section 529(c)(6) due to the application of

section 529(c)(3)(C)(iii).

SECTION III. GRANT OF RELIEF

Due to the nature of the above-described system issues, the Department of

the Treasury and the Internal Revenue

Service will grant the following relief as

a matter of sound tax administration: If

section 529(c)(3)(C)(iii) would apply to

deny treatment as a qualified rollover to

any portion of a distribution from or a distribution transferred to an MPCT account

for a designated beneficiary before January 1, 2025, and if that distribution was

preceded by a qualified rollover from an

MPCT account for the benefit of the same

designated beneficiary occurring after

December 31, 2021, then that distribution

will be treated as a qualified rollover to

which section 529(c)(3)(C)(i)(I) applies

notwithstanding section 529(c)(3)(C)(iii).

SECTION IV. DRAFTING

INFORMATION

The principal author of this notice is

Elliot DiGioia of the Office of Associate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). For further information regarding

this notice contact Elliot DiGioia at (202)

317-6836 (not a toll-free number).

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

Decision Memorandum with Respect to Maryland Prepaid College Trust, Md. State Treasurer, https://www.treasurer.state.md.us/media/178937/final%20decision%20document%20

07072023.pdf.

3

Details described in this paragraph are taken from the Memorandum.

4

Md. Code Ann., Educ. § 18-1917(f)(l) (2023).

1

2

February 12, 2024

672

Bulletin No. 2024–7

CORRECTIONS TO

REVENUE PROCEDURE

2024-5, SCHEDULE OF

USER FEES IN APPENDIX A

Announcement 2024-7

This announcement contains corrections to Revenue Procedure 2024-5,

2024-5 IRB 1, which omitted the effective

dates for certain changes to the user fees

in the user fee schedule.

Revenue Procedure 2024-5, as published on January 2, 2024, (2024-5 IRB 1),

omitted the effective dates for changes to

the user fees that apply to certain requests

for advance approvals. Rev. Proc. 2024-5

sets forth procedures for issuing determination letters on issues under the jurisdiction of the Director, Exempt Organizations Rulings and Agreements, including

determination letters relating to certain

advance approvals. This announcement

corrects Appendix A, paragraphs (9), (10),

and (11) of Rev. Proc. 2024-5.

Paragraphs (9) Section 4942(g)(2) set

asides – advance approval (Form 8940),

(10) Section 4945 advance approval of

organization’s grant making procedures

(Form 8940), and (11) Section 4945(f)

advance approval of voter registration

activities (Form 8940) did not specify the

effective dates for increases in the applicable user fees from $2,500 to $3,500.

Paragraphs (9), (10), and (11) of

Appendix A of Rev. Proc 2024-5 now read

as follows:

(9) Section 4942(g)(2) set asides – advance approval (Form 8940)

(a) Submissions prior to July 1, 2024

(b) Submissions on or after July 1, 2024

(10) Section 4945 advance approval of organization's grant making procedures (Form 8940)

(a) Submissions prior to July 1, 2024

(b) Submissions on or after July 1, 2024

(11) Section 4945(f) advance approval of voter registration activities (Form 8940)

(a) Submissions prior to July 1, 2024

(b) Submissions on or after July 1, 2024

Effect on Other Documents

Drafting Information

Revenue Procedure 2024-5, 2024-5

IRB 1, is corrected.

The principal author of this Revenue

Procedure is Peter A. Holiat of the Office

of Associate Chief Counsel (Employee

Bulletin No. 2024–7

673

$2,500

$3,500

$2,500

$3,500

$2,500

$3,500

Benefits, Exempt Organizations, and

Employment Taxes). For additional information, please contact Mr. Holiat at 202–

317–4541 (not a toll-free number).

February 12, 2024

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2024-8

The Internal Revenue Service has

revoked its determination that the organization listed below qualifies as an organization

described in sections 501(c)(3) and 170(c)

(2) of the Internal Revenue Code of 1986.

Generally, the IRS will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the IRS is not precluded from disallowing a deduction for

any contributions made after an organization ceases to qualify under section 170(c)

(2) if the organization has not timely filed

a suit for declaratory judgment under section 7428 and if the contributor (1) had

knowledge of the revocation of the ruling

or determination letter, (2) was aware that

such revocation was imminent, or (3) was

in part responsible for or was aware of the

activities or omissions of the organization

that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed,

contributions from individuals and organizations described in section 170(c)(2)

that are otherwise allowable will con-

NAME OF ORGANIZATION

ALTRUISTIC UNITED HUMANITY ASSOCIATION

February 12, 2024

tinue to be deductible. Protection under

section 7428(c) would begin on January

1, 2018 and would end on the date the

court first determines the organization is

not described in section 170(c)(2) as more

particularly set for in section 7428(c)(1).

For individual contributors, the maximum

deduction protected is $1,000, with a husband and wife treated as one contributor.

This benefit is not extended to any individual, in whole or in part, for the acts or

omissions of the organization that were

the basis for revocation.

The Following organization is no longer qualified as an organization exempt

from income tax under Internal Revenue

Code (the “Code”) Section 501(a) as an

organization described in Section 501(c)

(3) of the Code:

EFFECTIVE DATE OF REVOCATION

1/1/2018

674

LOCATION

PORTERVILLE CA

Bulletin No. 2024–7

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2024-9

The Internal Revenue Service has

revoked its determination that the organization listed below qualifies as an organization

described in sections 501(c)(3) and 170(c)

(2) of the Internal Revenue Code of 1986.

Generally, the IRS will not disallow

deductions for contributions made to a

listed organization on or before the date

of announcement in the Internal Revenue

Bulletin that an organization no longer

qualifies. However, the IRS is not precluded from disallowing a deduction for

any contributions made after an organization ceases to qualify under section 170(c)

(2) if the organization has not timely filed

a suit for declaratory judgment under section 7428 and if the contributor (1) had

knowledge of the revocation of the ruling

or determination letter, (2) was aware that

such revocation was imminent, or (3) was

in part responsible for or was aware of the

activities or omissions of the organization

that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed,

contributions from individuals and organizations described in section 170(c)

(2) that are otherwise allowable will

NAME OF ORGANIZATION

West Los Angeles Obedience Training Club Inc

Bulletin No. 2024–7

continue to be deductible. Protection

under section 7428(c) would begin on

________________ and would end on the

date the court first determines the organization is not described in section 170(c)

(2) as more particularly set for in section

7428(c)(1). For individual contributors,

the maximum deduction protected is

$1,000, with a husband and wife treated

as one contributor. This benefit is not

extended to any individual, in whole or in

part, for the acts or omissions of the organization that were the basis for revocation.

The Following organization is no longer qualified as an organization exempt

from income tax under Internal Revenue

Code (the “Code”) Section 501(a) as an

organization described in Section 501(c)

(3) of the Code:

EFFECTIVE DATE OF REVOCATION

1/1/2020

675

LOCATION

Los Angeles, CA

February 12, 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. 2024–7

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.

February 12, 2024

Numerical Finding List1

Bulletin 2024–7

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

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

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

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

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

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

1

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.

February 12, 2024

ii

Bulletin No. 2024–7

Finding List of Current Actions on

Previously Published Items1

Bulletin 2024–7

1

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.

Bulletin No. 2024–7

iii

February 12, 2024

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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