Bulletin No. 2024–46

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2024–46

November 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.

INCOME TAX

Rev. Proc. 2024-31, page 1113.

This revenue procedure provides the procedures and requirements that a manufacturer of specified property must follow to

be treated as a “qualified manufacturer” (QM) under § 25C(h) of

the Internal Revenue Code. Section 25C(h)(1) provides that no

credit will be allowed under § 25C(a) with respect to any item

of specified property placed in service after December 31,

2024, unless such item is produced by a QM and the taxpayer

includes the qualified product identification number (PIN) of

such item on the taxpayer’s tax return for the taxable year. This

revenue procedure provides that a manufacturer that wishes to

become a QM must register and enter into an agreement with

the Internal Revenue Service (IRS), assign a PIN unique to each

Finding Lists begin on page ii.

item of specified property, label such items, and make periodic

written reports to the IRS of the PINs so assigned.

INCOME TAX, TAX CONVENTIONS

Notice 2024-78, page 1111.

This notice extends the transitional FATCA reporting relief

in Notice 2023-11 (with two additional requirements) and

is intended to enable the IRS to continue to collect and

analyze information relating to characteristics of accounts

maintained by Model 1 Foreign Financial Institutions (FFIs)

missing required U.S. TINs. This information will be used

to develop any permanent relief for reporting Model 1 FFIs

who continue to report with missing U.S. TINs for certain

accounts.

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 12, 2024 

Bulletin No. 2024–46

Part III

Extension of Temporary

Relief for Foreign Financial

Institutions to Report U.S.

Taxpayer Identification

Numbers

Notice 2024-78

SECTION 1. PURPOSE

This notice extends the temporary

relief provided in Notice 2023-11, subject to the procedures and requirements

of this notice, for certain foreign financial

institutions (FFIs) required to report U.S.

taxpayer identification numbers (U.S.

TINs) for certain preexisting accounts (as

defined in an applicable Model 1 intergovernmental agreement (IGA)). If an FFI in

an eligible Model 1 IGA jurisdiction (as

defined in section 3.04 of this notice)

complies with the procedures described

in this notice, then the U.S. Competent

Authority will not determine there is significant non-compliance (described in

Article 5(2) or 5(3) of the relevant IGA)

with the reporting Model 1 FFI’s obligations under the IGA solely as a result of

its failure to report U.S. TINs associated

with its preexisting accounts for the 2025,

2026, and 2027 calendar years.

The extension of the temporary relief

granted by Notice 2023-11 is intended to

enable the Internal Revenue Service (IRS)

to continue to collect and analyze additional information for accounts without

U.S. TINs. As with Notice 2023-11, to

obtain the relief provided by this notice,

the reporting Model 1 FFI must use certain codes provided by the IRS that identify features of these accounts that may

explain why the reporting Model 1 FFI

does not report a U.S. TIN and must

comply with other requirements set forth

in this notice. The IRS will continue to

use this data to enhance IRS compliance

procedures and to inform potential future

options for reporting Model 1 FFIs who

continue to be unable to obtain and report

the U.S. TIN for certain accounts. If per1

manent relief is granted in the future, it is

anticipated that the scope of the accounts

for which an FFI may obtain such relief

will be narrower than the scope of accounts

for which relief is given under this notice.

SECTION 2. BACKGROUND

Chapter 4 of subtitle A of the Internal

Revenue Code (Code) (commonly known

as the Foreign Account Tax Compliance

Act, or FATCA) requires certain FFIs to

report to the IRS information about financial accounts held by U.S. taxpayers or

foreign entities in which U.S. taxpayers

hold certain ownership interests. FATCA

was enacted to ensure U.S. taxpayers

comply with their tax obligations.

The Department of the Treasury (Treasury Department) collaborated with foreign governments to develop two alternative model intergovernmental agreements

(the Model 1 IGA and the Model 2 IGA)

to facilitate the implementation of FATCA

and avoid legal impediments under local

law that would otherwise limit an FFI’s

ability to comply with FATCA. The Model

1 IGA provides that a reporting Model 1

FFI reports certain information on its U.S.

reportable accounts to the Model 1 IGA

jurisdiction tax authority, which automatically exchanges the information with the

U.S. Competent Authority.

A reporting Model 1 FFI that complies with its reporting and registration

obligations in accordance with the IGA

is treated as complying with section 1471

of the Code. One requirement is that the

reporting Model 1 FFI reports the U.S.

TIN of each specified U.S. person that

is an account holder and, in the case of a

non-U.S. entity with one or more specified

U.S. persons who are controlling persons,

the U.S. TIN of each controlling person

for its U.S. reportable accounts (required

U.S. TINs). The U.S. TIN of a U.S. citizen is the individual’s U.S. Social Security number (SSN). Under Model 1 IGAs,

a reporting Model 1 FFI that satisfies its

reporting and registration obligations is

not subject to withholding under section

1471 of the Code unless the FFI is treated

by the IRS as a nonparticipating financial

institution.

Transitional relief was implemented to

provide time for reporting Model 1 FFIs

to obtain and report the required U.S.

TINs for preexisting accounts, including

the publication of a series of codes (TIN

Codes) a reporting Model 1 FFI could use

to populate the TIN field for certain missing required U.S. TINs.1 The TIN Codes

provide the IRS with information intended

to allow it to better understand the issues

that FFIs were facing in obtaining required

U.S. TINs.

To extend additional transitional relief,

on January 17, 2023, the IRS published

Notice 2023-11, 2023-3 I.R.B. 404, which

provided temporary relief for the 2022,

2023, and 2024 calendar years for reporting Model 1 FFIs in eligible Model 1 IGA

jurisdictions that were unable to obtain

and report required U.S. TINs for preexisting accounts. Notice 2023-11 required

these reporting Model 1 FFIs to provide

an accurate TIN Code for each account

that was missing a required U.S. TIN, in

addition to other obligations specified in

the notice.

For reporting Model 1 FFIs that complied with the requirements of Notice

2023-11, the U.S. Competent Authority

would not determine there was significant non-compliance with the obligations

under the applicable Model 1 IGA with

respect to reporting required U.S. TINs

for preexisting accounts solely because of

a failure to obtain and report each required

U.S. TIN for such accounts. This relief

was limited to reporting on preexisting

accounts. It did not apply to U.S. reportable accounts opened after the determination date specified in the applicable Model

1 IGA (new accounts), including new

accounts held by account holders of preexisting accounts.

The IRS continues to evaluate the

reported TIN Codes and other information provided by Model 1 FFIs to understand account characteristics that may

make it difficult for a reporting Model 1

FFI to obtain and report the required U.S.

TINs. However, the IRS believes addi-

Reporting FAQ 6 (as of the publication date of this notice, https://www.irs.gov/businesses/corporations/frequently-asked-questions-faqs-fatca-compliance-legal#reporting).

Bulletin No. 2024–46

1111

November 12, 2024

tional information from TIN Code reporting in more calendar years is necessary

to develop future potential compliance

options. The IRS has also concluded that

certain additional data points are necessary to ensure sufficient individual identifiers are reported where required U.S.

TINs are missing. Accordingly, section 3

of this notice provides an additional three

calendar years of the temporary relief

from the U.S. TIN reporting requirements for preexisting accounts provided

the reporting Model 1 FFI in an eligible

Model 1 IGA jurisdiction complies with

the requirements of this notice.

SECTION 3. EXTENSION OF

TEMPORARY U.S. TIN RELIEF

.01 Extension of relief for reporting on

certain preexisting accounts that are U.S.

reportable accounts

This notice extends, for calendar years

2025, 2026, and 2027, the temporary relief

provided in Notice 2023-11 for reporting

Model 1 FFIs required to report U.S. TINs

for certain preexisting accounts, subject

to the conditions set forth in this notice.

Reporting Model 1 FFIs that comply with

sections 3.02 and 3.03 of this notice will

not be treated as in significant non-compliance with their obligations under an

applicable Model 1 IGA solely because of

the failure to report a required U.S. TIN

with respect to a preexisting account. Section 3.04 of this notice limits this relief

to reporting Model 1 FFIs that are in an

eligible jurisdiction that makes good faith

efforts to increase the likelihood that U.S.

citizens residing in that jurisdiction will

report their U.S. TINs to the FFIs and that

takes other steps specified in section 3.04.

This relief is limited to reporting on

preexisting accounts. It does not apply

to U.S. reportable accounts opened after

the determination date specified in the

applicable Model 1 IGA, including new

accounts held by account holders of preexisting accounts.

Nothing in this notice prevents the

U.S. Competent Authority from finding

significant non-compliance by reporting

Model 1 FFIs that do not report required

U.S. TINs for preexisting accounts and

that do not comply with the relief requirements of this notice or Notice 2023-11, as

applicable. Further, nothing in this notice

or Notice 2023-11 prevents the U.S. Competent Authority from finding significant

non-compliance due to a failure to satisfy

an obligation under the applicable Model

1 IGA other than a failure to obtain and

report each required U.S. TIN for preexisting accounts.

.02 Requirements for reporting Model

1 FFIs

To obtain the relief for preexisting

accounts described in section 3.01 of this

notice for the 2025, 2026, and 2027 calendar years, for each U.S. reportable account

(including new accounts) with a missing

required U.S. TIN, the reporting Model 1

FFI must do the following:

(1) obtain and report the date of birth of

each account holder that is an individual

and controlling person whose U.S. TIN is

not reported;

(2) annually request from each account

holder any missing required U.S. TIN, as

described in further detail in section 3.03

below;

(3) annually search electronically

searchable data maintained by the reporting Model 1 FFI for any missing required

U.S. TINs;

(4) report an accurate TIN Code for

each account that is missing a required

U.S. TIN;

(5) if the FFI’s electronically searchable account information contains a foreign taxpayer identification number (or

functional equivalent) assigned to a taxpayer by its country of residence (FTIN),

report an FTIN for each specified U.S.

person that is missing a required U.S.

TIN; and

(6) using the AddressFix element, as

described further below, report the city

and country of residence for each specified U.S. person with a missing required

U.S. TIN.

The AddressFix element is intended to

be used generally for all address reporting.

To ensure conformity of data reporting

and the IRS’s ability to process reported

data, reporting Model 1 FFIs should use

AddressFix for all address information to

the extent possible and may use Address-

Free as a supplemental element. However,

to comply with requirement (6) of this section, the only requirement is that the city

and country of residence of the specified

U.S. person must be included in AddressFix.

.03 Annual request for missing required

U.S. TINs

Reporting Model 1 FFIs must also make

annual requests for missing required U.S.

TIN information. To satisfy the requirement to make an annual request from each

account holder for missing required U.S.

TINs, reporting Model 1 FFIs must use the

method of communication that is, in the

FFI’s reasonable judgment, most likely to

reach the account holder. In addition, the

communication must include either of the

following:

• the web address of the State Department’s Joint FATCA FAQs (as of the

publication date of this notice, https://

travel.state.gov/content/travel/en/international-travel/while-abroad/JointForeign-Account-Tax-ComplianceFATCA-FAQ.html),2 or

• (i) a copy of the FAQs described in the

preceding bullet and (ii) either

o a copy of the relief procedures

provided by the IRS for certain

former citizens, or

o the web address for such procedures (as of the publication date

of this notice, https://www.irs.

gov/individuals/internationaltaxpayers/relief-procedures-forcertain-former-citizens).

FFIs seeking to obtain relief under

this notice for the 2025, 2026, and 2027

calendar years must retain records of the

policies and procedures adopted to satisfy

this requirement and documentation that

those policies and procedures were followed to establish its compliance with the

requirements of this section until the end

of calendar year 2031. To obtain the relief

described in this notice, the FFI must also

retain until 2031 any records or documentation adopted in previous years for the

purpose of obtaining relief under Notice

2023-11 to the extent applicable.

.04 Eligible Model 1 IGA jurisdictions

For a reporting Model 1 FFI to be eligible for the relief described in this section

The Joint FATCA FAQs provide information on how to obtain an SSN, how to renounce U.S. citizenship, and relevant U.S. tax consequences (including a link to the IRS’s relief procedures

for certain former U.S. citizens). Additionally, FFIs may wish to include a direct link for U.S. citizens and residents seeking to obtain a U.S. TIN (as of the publication date of this notice,

https://www.ssa.gov/foreign/foreign.htm).

2

November 12, 2024

1112

Bulletin No. 2024–46

with respect to reporting for a particular

calendar year or other appropriate reporting period, the applicable Model 1 IGA

jurisdiction must make good faith efforts,

by the date that is nine months after the

end of the calendar year to which the

information relates, to do the following:

(1) Encourage U.S. citizens resident in

the jurisdiction to provide U.S. TINs to

FFIs when requested;

(2) Take measures to enforce compliance by reporting Model 1 FFIs identified

by the U.S. Competent Authority to the

Model 1 IGA jurisdiction as potentially

non-compliant;

(3) Encourage FFIs located in a Model

1 IGA jurisdiction to not discriminate

against U.S. citizens that do provide a

U.S. TIN; and

(4) If notified by the U.S. Competent

Authority, take steps to conclude Competent Authority Arrangements with the

U.S. Competent Authority, to implement

an IGA, amend an Annex II to an IGA,

or exchange country-by-country information.

SECTION 4. PAPERWORK

REDUCTION ACT

The Paperwork Reduction Act of 1995

(44 U.S.C. 3501-3520) requires that a

federal agency obtain the approval of

the Office of Management and Budget

(OMB) before collecting information

from the public, whether such collection

of information is mandatory, voluntary,

or required to obtain or retain a benefit. A

federal agency may not conduct or sponsor, and a person is not required to respond

to, a collection of information unless the

collection of information displays a valid

control number.

The collections of information contained within this notice are detailed in

sections 3.02 and 3.03. These collections

are necessary to provide temporary relief

to FFIs required to report U.S. TINs for

certain preexisting accounts. These collections are included with the OMB control number 1545-2246.

Books or records relating to a collection of information must be retained as

long as their contents may become material in the administration of any internal

1

revenue law. Generally, tax returns and

tax return information are confidential, as

required by section 6103 of the Code.

SECTION 5. DRAFTING

INFORMATION

The principal authors of this notice

are Ellen Hancock and Sarah Stein of the

Office of Associate Chief Counsel (International). For further information regarding this notice, contact Ellen Hancock at

(202) 317-5460 or Sarah Stein at (202)

317-4917 (not a toll-free number).

Rev. Proc. 2024-31

SECTION 1. PURPOSE

This revenue procedure provides the

procedures and requirements that a manufacturer of specified property must follow

to be treated as a “qualified manufacturer”

(QM) under § 25C(h) of the Internal Revenue Code (Code).1 Section 25C(h)(1)

provides that no credit will be allowed

under § 25C(a) with respect to any item of

specified property placed in service after

December 31, 2024, unless such item

is produced by a QM and the taxpayer

includes the qualified product identification number (PIN) of such item on the

taxpayer’s tax return for the taxable year.

This revenue procedure provides that a

manufacturer that wishes to become a QM

must register and enter into an agreement

with the Internal Revenue Service (IRS),

assign a PIN unique to each item of specified property, label such items, and make

periodic written reports to the IRS of the

PINs so assigned.

SECTION 2. BACKGROUND

.01 Inflation Reduction Act Changes to

§ 25C.

(1) Congress originally enacted § 25C

in § 1333(a) of the Energy Policy Act

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

594, 1026 (August 8, 2005) to provide a

“nonbusiness energy property credit” for

the purchase and installation of certain

energy efficient improvements in a tax-

payer’s principal residence (§ 25C credit).

Congress amended § 25C several times,

most recently by § 13301 of Public Law

117-169, 136 Stat. 1818, 1941 (August

16, 2022), commonly known as the Inflation Reduction Act of 2022 (IRA), which

renamed this provision the “energy efficient home improvement credit.”

(2) Former § 25C expired with respect

to any property placed in service after

December 31, 2021. Section 13301(i) of

the IRA provides that except as otherwise

provided in § 13301(i)(2) and (3), the IRA

amendments to § 25C apply to property

placed in service after December 31, 2022.

Section 13301(i)(2) of the IRA provides

that the amendments made by § 13301(a)

of the IRA apply to property placed in

service after December 31, 2021. Section

13301(a) of the IRA extended the § 25C

credit with respect to any property placed

in service through December 31, 2032.

Section 13301(i)(3) of the IRA provides

that the amendments made by § 13301(g)

of the IRA apply to property placed in

service after December 31, 2024. Section

13301(g) of the IRA amended § 25C by

redesignating former subsection (h) as

subsection (i) and inserting a new subsection (h), which is described in section 2.02

of this revenue procedure.

(3) Section 25C, as amended by §

13301(b) and (f) of the IRA, allows an

individual taxpayer (taxpayer) for the

taxable year a credit equal to 30 percent

of the total amount paid or incurred by

the taxpayer during such taxable year

for qualified energy efficiency improvements installed during such taxable year,

residential energy property expenditures,

and home energy audits. As amended by

§ 13301(c) of the IRA, the amount of the §

25C credit generally is limited under section 25C(b)(1) to $1,200 with respect to

any taxpayer for any taxable year. Within

this $1,200 limitation, § 25C(b) sets forth

further annual limitations for certain categories of improvements. Section 25C(b)

(2) provides that the credit allowed under

§ 25C(a)(2) is limited to $600 with respect

to any taxpayer for any taxable year with

respect to any item of qualified energy

property. Section 25C(b)(3) provides that

the credit allowed under § 25C(a)(1) with

respect to any taxpayer for any taxable

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

Bulletin No. 2024–46

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November 12, 2024

year is limited to $600 in the aggregate

with respect to all exterior windows and

skylights. Section 25C(b)(4) provides that

the credit allowed under § 25C(a)(1) with

respect to any taxpayer for any taxable

year is limited to $250 in the case of any

exterior door and $500 in the aggregate

with respect to all exterior doors. Section

25C(b)(6) limits the credit allowed under

§ 25C(a)(3) for a home energy audit to

$150. Additionally, notwithstanding the

general $1,200 annual limitation (and

the internal limitations within the general $1,200 annual limitation), § 25C(b)

(5) provides that the credit allowed under

§ 25C(a)(2) with respect to any taxpayer

for any taxable year is limited to $2,000

in the aggregate with respect to amounts

paid or incurred for an electric or natural

gas heat pump water heater described in

§ 25C(d)(2)(A)(i), an electric or natural gas heat pump described in § 25C(d)

(2)(A)(ii), and a biomass stove or boiler

described in § 25C(d)(2)(B).

.02 Section 25C(h) Requirements.

(1) Section 25C(h)(1) provides that no

§ 25C credit is allowed with respect to

any item of specified property placed in

service after December 31, 2024, unless—

(a) such item is produced by a QM, and

(b) the taxpayer includes the PIN of

such item on the tax return for the taxable

year.

(2) Section 25C(h)(2) defines the term

“qualified product identification number”

as, with respect to any item of specified

property, the product identification number that the QM assigned to such item

pursuant to the methodology referred to in

§ 25C(h)(3).

(3) Section 25C(h)(3) defines the term

“qualified manufacturer” as any manufacturer of specified property that enters

into an agreement with the Secretary of

the Treasury or the Secretary of the Treasury’s delegate (Secretary) that provides

that such manufacturer will—

(a) assign a product identification

number to each item of specified property

produced by such manufacturer, using a

methodology that will ensure that such

number (including any alphanumeric)

is unique to each such item, by using

numbers or letters unique to such manufacturer or by such other method as the

Secretary may provide (PIN assignment

requirement),

November 12, 2024

(b) label such item with such product

identification number in such manner as

the Secretary may provide (PIN labeling

requirement), and

(c) make periodic written reports to

the Secretary (at such times and in such

manner as the Secretary may provide)

of the product identification numbers so

assigned and including such information as the Secretary may require with

respect to the items of specified property

to which such product identification numbers were so assigned (periodic written

report requirement) (collectively, QM PIN

requirements).

(4) Section 25C(h)(4) defines the term

“specified property” as—

(a) any “qualified energy property,”

and

(b) exterior windows (including skylights) and exterior doors described in

§ 25C(c)(3)(B) and (C).

(5) Section 25C(d)(2) defines the term

“qualified energy property” as any of the

following:

(a) Any of the following that meet or

exceed the highest efficiency tier (not

including any advanced tier) established

by the Consortium for Energy Efficiency

that is in effect as of the beginning of the

calendar year in which the property is

placed in service:

(i) An electric or natural gas heat pump

water heater.

(ii) An electric or natural gas heat

pump.

(iii) A central air conditioner.

(iv) A natural gas, propane, or oil water

heater.

(v) A natural gas, propane, or oil furnace or hot water boiler.

(b) A biomass stove or boiler that—

(i) uses the burning of biomass fuel to

heat a dwelling unit located in the United

States and used as a residence by the taxpayer, or to heat water for use in such a

dwelling unit, and

(ii) has a thermal efficiency rating of at

least 75 percent (measured by the higher

heating value of the fuel).

(c) Any oil furnace or hot water boiler

that—

(i) is placed in service after December 31, 2022, and before January 1, 2027,

meets or exceeds 2021 Energy Star certified efficiency criteria, and is rated by the

manufacturer for use with fuel blends at

1114

least 20 percent of the volume of which

consists of an eligible fuel (defined in

§ 25C(d)(3)) (eligible fuel), or

(ii) is placed in service after December 31, 2026, achieves an annual fuel

utilization efficiency rate of not less than

90, and is rated by the manufacturer for

use with fuel blends at least 50 percent of

the volume of which consists of an eligible fuel.

(d) Any improvement to, or replacement of, a panelboard, sub-panelboard,

branch circuits, or feeders that—

(i) is installed in a manner consistent

with the National Electric Code,

(ii) has a load capacity of not less than

200 amps,

(iii) is installed in conjunction with—

(I) any qualified energy efficiency

improvements, or

(II) any qualified energy property

described in § 25C(d)(2)(A) through (C)

for which a § 25C credit is allowed for

expenditures with respect to such property, and

(iv) enables the installation and use of

any qualified energy efficiency improvements or any qualified energy property

described in § 25C(d)(2)(A) through (C).

.03 Proposed Regulations. In conjunction with the publication of this revenue procedure, the Department of the

Treasury (Treasury Department) and the

IRS are publishing a notice of proposed

rulemaking (REG-118264-23) in the Federal Register (89 F.R. 85099) under § 25C

(proposed regulations). The proposed regulations would provide rules for manufacturers of specified property to register

to be qualified manufacturers and satisfy

certain other requirements, and rules for

taxpayers to calculate the credit.

SECTION 3. DEFINITIONS

.01 Generally. Terms used in this revenue procedure and not otherwise defined

in this revenue procedure have the same

meaning as in § 25C and the proposed

regulations thereunder, and will have the

same meaning as in the final regulations

thereunder (once issued).

.02 Relevant Geographic Climate

Zone. Exterior windows, skylights, doors,

and heat pumps are subject to different

efficiency requirements in different geographic areas of the United States. The

Bulletin No. 2024–46

term “relevant geographic climate zone”

refers to the applicable climate zone for

the applicable specified product. Energy

Star is a voluntary labeling and rating program administered by the U.S. Environmental Protection Agency that determines

the applicable climate zones for exterior

windows, skylights, and doors. See https://

www.energystar.gov. The Consortium for

Energy Efficiency (CEE), a nonprofit consortium consisting primarily of utility efficiency program administrators across the

United States and Canada, determines the

applicable climate zones for heat pumps.

See https://cee1.org.

SECTION 4. QM REGISTRATION

AND WRITTEN AGREEMENT

.01 Registration, Application, and

Agreement with the IRS.

(1) General Overview. To become a

QM as defined in § 25C(h)(3), a manufacturer of specified property must enter into

an agreement with the IRS. Except as provided in section 4.02 of this revenue procedure, manufacturers are not QMs until

they have entered into and attested to an

agreement as described in section 4.01(2)

and (3) of this revenue procedure that has

been validated by the IRS.

(2) Manufacturer Registration and QM

Written Agreement through IRS Energy

Credits Online Portal. An individual representative of the manufacturer who is

authorized to bind the manufacturer in

matters involving agreements with the IRS

(authorized representative) must register

through the IRS Energy Credits Online

Portal and provide the required information to complete the manufacturer’s application and enter into an agreement (QM

Registration Application and Agreement)

on the manufacturer’s behalf. The authorized representative will need an account

on https://www.irs.gov to verify the manufacturer’s business tax information and

to register the manufacturer. Help related

to the IRS identity verification process can

be found on the sign-in page or at www.

irs.gov/registerhelp. The authorized representative must execute the manufacturer’s

QM Registration Application and Agreement on the IRS Energy Credits Online

2

Portal. Specifically, the representative

must provide the following information

and make the following certifications:

(a) The manufacturer’s name and business address;

(b) The authorized representative’s

telephone number and email address;

(c) The manufacturer’s Taxpayer Identification Number (TIN) or Employer

Identification Number (EIN);

(d) A listing of the categories of specified property that the manufacturer produces or intends to produce. (The application will provide a menu of property

categories from which the manufacturer

must select one or more categories.);

(e) A certification that the manufacturer

produces specified property as defined in

§ 25C(h)(4);

(f) A certification that the manufacturer agrees to assign a PIN to each item

of specified property produced by such

manufacturer using the methodology

described in section 5 of this revenue

procedure (or any successor guidance),

that the manufacturer agrees to label each

item of specified property with a PIN in

the manner described in section 6 of this

revenue procedure (or any successor guidance), and that the manufacturer agrees to

submit required periodic written reports to

the IRS of the PINs assigned in the manner described in section 7 of this revenue

procedure (or any successor guidance);

(g) If the manufacturer is filing as part

of a consolidated group, the name and

EIN of the corporation filing the consolidated income tax return; and

(h) Such other information and certifications that the IRS Energy Credits Online

Portal may require. The IRS may update

the required information and certifications

in guidance, on https://www.irs.gov, or via

the IRS Energy Credits Online Portal.

(3) Penalties of Perjury. The authorized representative must sign the QM

Registration Application and Agreement,

and also must include the following statement, signed under penalties of perjury:

“Under penalties of perjury, I declare that

I have examined this QM Registration

Application and Agreement, including

any and all accompanying documents, and

to the best of my knowledge, the facts pre-

sented in this application are true, correct,

and complete.” The authorized representative must execute this signature electronically within the IRS Energy Credits

Online Portal.

(4) Requirement for Multiple Manufacturers.

(a) In general. If more than one manufacturer participates in the production of

the same product that is specified property, only one manufacturer may be the

QM with respect to such product. Only the

manufacturer whose production results in

the product becoming specified property

must register with the IRS to become a

QM with respect to such property, absent

an agreement otherwise among such manufacturers providing that a different one

of the manufacturers is required to register with the IRS to become a QM with

respect to the property. Any manufacturer

that agrees to become a QM with respect

to the property must retain a copy of the

agreement in the manufacturer’s books

and records.

(b) Example. Manufacturers A and

B are in involved in the production of a

glass window. In the chain of production,

A cuts the glass to the desired dimensions,

and cleans and seals the panes of glass. B

cuts and welds the frames. A then assembles the frames and glass into an exterior

window that meets the requirements of

specified property. Because A’s process of

assembling the frames and glass results in

the window becoming specified property,

absent an agreement between A and B

under which B is required to register with

the IRS to become a QM with respect to

the window, A must enter into an agreement with the IRS to become the QM with

respect to the window.

(5) Special Requirement for Manufacturers of Enabling Property. A manufacturer that produces enabling property2

must follow the registration, application,

and written agreement process described

in this section 4, even if the manufacturer

produces no other type of specified property, despite modified requirements with

respect to enabling property elsewhere in

this revenue procedure.

(6) Special Requirements for Certain

Manufacturers of Heat Pumps. A manu-

Defined in § 1.25C-1(b)(6) of the proposed regulations.

Bulletin No. 2024–46

1115

November 12, 2024

facturer that produces only the indoor unit

of a heat pump, but does not manufacture

outdoor units of a heat pump, must follow

the registration, application, and written

agreement process described in this section 4, even if the manufacturer produces

no other type of specified property, despite

modified requirements with respect to

heat pumps elsewhere in this revenue procedure.

(7) Validation. After the manufacturer

submits a complete QM Registration

Application and Agreement through the

IRS Energy Credits Online Portal, the IRS

will validate the QM Registration Application and Agreement, taking into account

the manufacturer’s North American

Industry Classification System (NAICS)

Code. In the event the manufacturer fails

the validation process, or the IRS requires

missing or supplemental information or

certifications, the IRS will contact the

manufacturer’s authorized representative.

(8) Acceptance, QM Code and List of

QMs. After reviewing a manufacturer’s

QM Registration Application and Agreement, the IRS will notify the manufacturer if the manufacturer’s registration is

accepted or rejected. If the IRS accepts the

QM Registration Application and Agreement, the IRS will send a certification to

the manufacturer’s authorized representative through the IRS Energy Credits

Online Portal. The IRS also will assign

and issue a unique 4-character QM Code to

the manufacturer through the IRS Energy

Credits Online Portal. The IRS will publish a list of QMs and the date that their

application was accepted on https://www.

irs.gov. Except as provided in section 4.02

of this revenue procedure, no § 25C credit

is allowed for any specified property produced by a manufacturer prior to the date

that the IRS accepts a manufacturer as a

QM, as such property is not considered

produced by a QM under § 25C(h)(1)(A).

Any manufacturer entering into a QM

Registration Application and Agreement

agrees to have its name listed as a QM on

https://www.irs.gov.

.02 Special Registration Procedure for

2025. Any manufacturer that submits its

QM Registration Application and Agreement by April 30, 2025, will be deemed

to have been a QM as of December 31,

3

2024, provided such QM Registration

Application and Agreement is validated

by the IRS. Accordingly, for a manufacturer that meets the requirements of the

Special Registration Procedure for 2025,

any specified property produced by such

manufacturer on or after January 1, 2025,

and on or before April 30, 2025, will be

deemed to have been produced by a QM.

.03 Suspension or Revocation of Registration. The IRS may suspend or revoke

a QM registration in the IRS’s sole discretion if the IRS concludes that the manufacturer is not in compliance with the PIN

assignment requirement in section 5 of

this revenue procedure, the PIN labeling

requirement in section 6 of this revenue

procedure, or the periodic written report

requirement in section 7 of this revenue

procedure, or other QM requirements published in the Internal Revenue Bulletin, on

https://www.irs.gov, or via the IRS Energy

Credits Online Portal. The IRS will notify

the manufacturer’s authorized representative that the QM registration has been

suspended or revoked. The list of QMs

published by the IRS will be updated to

reflect suspensions and revocations.

.04 Administrative Review of a Rejection, Suspension or Revocation of QM status. If the IRS rejects a QM Registration

Application and Agreement or if the IRS

revokes or suspends a manufacturer’s QM

registration status, then the manufacturer

may request administrative review of the

IRS’s determination by the IRS. During

the period that such review is pending, the

manufacturer will not be a QM. Any IRS

determination relating to the rejection of a

QM Registration Application and Agreement, or the revocation or suspension of

a manufacturer’s QM registration status is

not subject to administrative appeal to the

IRS Independent Office of Appeals.

.05 Voluntary Discontinuance of QM

status. A QM may discontinue its QM

status by sending a secure message to

the IRS through the IRS Energy Credits Online Portal and filing a final QM

Report, as provided in section 7.12 of

this revenue procedure. The secure message must state that the QM is terminating its QM status and provide the date

that the final QM Report will be filed.

The IRS will process such requests, and

the QM’s status will be discontinued as

of the date the final QM report is filed

through the IRS Energy Credits Online

Portal. A QM that discontinues its QM

status will no longer be included on the

list of QMs published by the IRS. The

IRS will publicize discontinued QM status information on https://www.irs.gov.

All PINs reported in the final QM Report,

or in QM Reports filed previously by the

QM, will continue to be valid PINs for

purposes of the § 25C credit despite the

discontinued QM status.

SECTION 5. PIN ASSIGNMENT

REQUIREMENT

.01 In General. To satisfy the PIN

assignment requirement in § 25C(h)(3)

(A), QMs must employ the PIN assignment system described in this section 5

(PIN Assignment System).

.02 Specifics of the PIN Assignment

System. Except as provided in sections

5.03 through 5.06 of this revenue procedure, QMs must assign a 17-character PIN

unique to each item of specified property.

The PIN for each item of specified property is made up of three parts and may

contain alphanumeric characters (including the common digits 0 to 9 and capital

letters A to Z, other than I or O,3 but not

special characters such as *, &, @, etc.):

(1) Part 1: QM Code. The first part of

the PIN is the manufacturer’s four-character QM Code. When the IRS validates a

QM Registration Application and Agreement, the IRS will assign a QM Code to

the QM.

(2) Part 2: Product Code. The second

part of the PIN is one character (that is,

character 5 of the PIN) and is a “Product

Code.” The Product Code is assigned by

the QM in accordance with a list of Product Codes on https://www.irs.gov, on the

IRS Energy Credits Online Portal, or in

future published guidance. This character

represents the category of specified property and, if applicable, the relevant geographic climate zone.

(3) Part 3: Item Number. The last

twelve characters of the PIN (that is,

characters 6 through 17 of the PIN) must

represent the specific “Item Number” that

is unique to each item of specified prop-

The letters I and O may not be used because they are easily mistaken for the numbers 1 and 0.

November 12, 2024

1116

Bulletin No. 2024–46

erty. The QM may choose any twelve

alphanumeric characters (including the

common digits 0 to 9 and capital letters

A to Z, other than I or O, but not special

characters such as *, &, @, etc.) for the

Item Number, provided that the result is

a unique Item Number, and provided that

the Item Number does not employ leading zeroes. The IRS encourages QMs to

employ nonsequential characters.

.03 Specified Property Placed in Service During the 2025 Calendar Year.

Notwithstanding section 5.02 of this revenue procedure, for all specified property placed in service on or after January

1, 2025, and before January 1, 2026, a

QM can satisfy the § 25C(h)(3)(A) PIN

assignment requirement with its QM Code

in lieu of its PIN. For specified property

placed in service in 2025, taxpayers may

use the QM code in lieu of a PIN.

.04 Enabling Property. For enabling

property, regardless of whether the

enabling property is placed in service

after December 31, 2025, a QM can satisfy the § 25C(h)(3)(A) PIN assignment

requirement by using its QM Code in lieu

of its PIN, and taxpayers claiming the section 25C credit may use the QM Code in

lieu of a PIN. Nothing in section 5.04 of

this revenue procedure negates the need

for the QM to provide a 17-digit PIN as

described in section 5.02 of this revenue

procedure for other specified property,

or for the taxpayer to provide a 17-digit

PIN as described in section 5.02 of this

revenue procedure for any other specified

property, including enabled property, on

the taxpayer’s tax return.

.05 Heat Pumps. With respect to a

heat pump that meets the requirements of

§ 25C(d)(2)(ii), only the outdoor unit of

such heat pump must be assigned a PIN;

QMs can satisfy the QM PIN requirements

without assigning a PIN to the indoor unit

of such heat pump. Nothing in section

5.05 of this revenue procedure negates

the need for a manufacturer to register to

be a QM under section 4 of this revenue

procedure, despite modified requirements

applicable to QMs elsewhere in this revenue procedure.

.06 Timing of PIN Assignment Requirement in section 5.02. A QM must assign

PINs described in section 5.02 of this revenue procedure to each item of specified

property that they produce beginning on

Bulletin No. 2024–46

January 1, 2026, while the item is in the

QM’s possession. For items of property

that the QM produces before January 1,

2026, the QM may, but is not required to,

assign PINs in accordance with section

5.02 of this revenue procedure, during the

manufacturing process, or after items are

no longer in the QM’s possession, provided that the QM furnishes the PINs to

taxpayers within the time frames set forth

in section 6 of this revenue procedure.

.07 Examples. The following are example of PINs that satisfy the PIN Assignment System requirements.

(1) XYZ Corp manufactures energy

efficient windows that meet the relevant

standards in the northern climate zone to

qualify for the § 25C credit. On January 6,

2025, XYZ Corp’s authorized representative timely and properly executes and submits a QM Registration Application and

Agreement on behalf of XYZ Corp. On

February 3, 2025, the IRS notifies XYZ

Corp that the IRS validated XYZ Corp’s

QM Registration Application and Agreement and assigned “A1A1” as the company’s QM Code.

(2) During the 2025 taxable year, XYZ

Corp manufactures a line of energy efficient windows that meets the relevant

standards in the northern climate zone to

qualify for the § 25C credit for the 2025

taxable year. XYZ Corp calls this product

line the Red window models. In the 2025

taxable year, XYZ Corp sold 2,500 Red

windows, and received 2,000 requests for

PINs from taxpayers. XYZ Corp must

provide the QM Code, “A1A1,” to those

taxpayers in the 2025 taxable year. If any

of the Red windows are placed in service

in the 2026 taxable year or later, assuming the windows still qualify for the § 25C

credit, then XYZ Corp must provide taxpayers with the 17-digit PIN as described

in section 5.02 of this revenue procedure.

(3) In the 2026 taxable year, XYZ Corp

manufactures two lines of energy efficient

windows that meet the relevant standards

in the northern climate zone to qualify for

the § 25C credit. XYZ Corp calls these

product lines, respectively, the Blue and

White window models. XYZ Corp manufactures 10,000 Blue windows and 10,000

White windows in 2026, or 20,000 windows in total. The Product Code for both

lines of XYZ Corp’s windows is “2,”

based on the northern climate zone.

1117

(4) XYZ Corp assigns PINs to its items

of specified property while they are still in

XYZ Corp’s possession, as follows:

(a) Characters 1 through 4 of the PIN

for each of the 20,000 windows are the

characters in the company’s QM Code,

“A1A1.”

(b) Character 5 of the PIN is “2” representing each window’s Product Code.

(c) XYZ Corp assigns Item Numbers

“BLUE12345000”

through

“BLUE22344000” as characters 6 through

17 of the PIN for the 10,000 Blue windows

and Item Numbers “WHITE5678900”

through “WHITE6678800” as characters

6 through 17 of the PIN for the 10,000

White windows.

(5) For example, XYZ Corp will assign

the PIN “A1A12BLUE12345000” to the

first 2026 taxable year Blue window to

which XYZ Corp assigns a PIN and the

PIN “A1A12WHITE5740100” to the

613th 2026 taxable year White window to

which XYZ Corp assigns a PIN.

SECTION 6. PIN LABELING

REQUIREMENT

.01 In General. To satisfy the PIN labeling requirement in § 25C(h)(3)(B), a QM

must label each item of specified property

with a PIN using a method allowed in this

section 6, and must furnish the PIN to taxpayers in accordance with this section 6.

.02 Method of Labeling. QMs may

choose the method for labeling products,

provided that the PIN is furnished to the

taxpayer in the time frame set forth in

section 6.03 of this revenue procedure.

For example, a QM may add the PIN to

the item of specified property by affixing

a label to the product or by etching the

PIN on the product itself. Alternatively, a

QM may affix a label containing the PIN

to the item’s packaging, print the PIN

directly on the packaging, or include a

document containing the PIN inside the

item’s packaging. The IRS urges QMs

not to place a product’s PIN on the exterior packaging of the product, which

could cause difficulties in the administration of the section 25C credit through

misuse of PINs. For property that is no

longer in a QM’s control, a QM may

provide a website where taxpayers may

obtain a PIN by entering their purchase

information.

November 12, 2024

.03 Time to Furnish PINs to Taxpayers;

No Prerequisites to Receiving the PIN.

(1) In general. For specified property placed in service on or after January 1, 2025, and before January 1, 2026,

in order to comply with the PIN labeling requirement, a QM must provide its

QM Code (which will be accepted by

the IRS in lieu of a PIN with respect to

this period only) to taxpayers who purchase items of specified property by no

later than the date– (i) when the taxpayer

places the specified property in service,

(ii) when the taxpayer requests a PIN

from the QM, or (iii) when the manufacturer becomes a QM, whichever is

latest. For specified property placed in

service on or after January 1, 2026, in

order to comply with the PIN labeling

requirement, a QM must make its PINs

available to the taxpayer no later than the

date when the taxpayer either places the

specified property in service, or requests

a PIN from the QM, whichever is later.

For any specified property produced in

calendar year 2025 and placed in service

on or after January 1, 2026, and to which

only a QM Code has been assigned, the

QM must make the full 17-digit PIN

available to the taxpayer upon request by

the taxpayer.

(2) No Prerequisites to Receive a

PIN. A QM may not set prerequisites to

a taxpayer receiving a PIN that are not

required to verify the purchase of the

specified property, such as requiring taxpayers to sign up for promotional emails,

texts, or other communications from

the QM, its related entities, or partners.

However, PINs may be provided through

the mail, online, through email, or other

means of electronic delivery. PINs may

be provided in conjunction with a formal

registration for a warranty provided that

the taxpayer can easily obtain the PIN

without completing the formal warranty

registration.

.04 Enabling Property. For enabling

property, regardless of whether the

enabling property is placed in service

after December 31, 2025, the § 25C(h)

(3)(B) PIN labeling requirement is met

if the QM furnishes its QM Code to taxpayers who purchase items of enabling

property. Nothing in section 6.04 of this

revenue procedure negates the need for

a taxpayer to provide the PIN of the

November 12, 2024

enabled property on the taxpayer’s tax

return.

.05 PIN Labeling for Heat Pumps.

Because only the outdoor unit of a heat

pump that meets the requirements of §

25C(d)(2)(ii) must be assigned a PIN,

manufacturers are not required to label

the indoor unit of a heat pump. Nothing

in section 6.05 of this revenue procedure

negates the need for a manufacturer to

register to be a QM under section 4 of

this revenue procedure, even if the manufacturer only produces indoor units of a

heat pump, despite modified requirements

applicable to those QMs elsewhere in this

revenue procedure.

SECTION 7. PERIODIC WRITTEN

REPORT REQUIREMENT

.01 In General. To meet the periodic

written report requirement in § 25C(h)(3)

(C), a QM must submit periodic reports

(QM Reports) to the IRS electronically

through the IRS Energy Credits Online

Portal, in the time and manner described

in this section 7.

.02 General Information to Include

in the QM Report. Except as provided in

sections 7.05 through 7.07 of this revenue procedure, a QM must include certain

general information in every QM Report,

including:

(1) the QM’s name, address, and TIN

or EIN;

(2) for each item of specified property

that the QM produced during the period

covered by the QM Report,

(a) such item’s full PIN, including its

QM Code, Product Code, and Item Number (except as provided in section 7.05 of

this revenue procedure), and

(b) such item’s month and year of manufacture;

(3) such other information as the IRS

may provide on https://www.irs.gov, on

the IRS Energy Credits Online Portal, or

in published guidance.

.03 Attestation. Each QM Report must

include a declaration, applicable to the

certification, statements, and any accompanying documents, signed by an individual authorized to bind the QM in matters

involving agreements with the IRS, in the

following form: “Under penalties of perjury, I declare that I have examined this

certification, including any and all accom-

1118

panying documents, and that to the best of

my knowledge, the facts presented in support of this certification are true, correct,

and complete.”

.04 Year of Manufacture. For QM

Reports, the year of manufacture is the

year in which the property becomes specified property for purposes of the § 25C

credit.

.05 Specified Property Placed in Service During the 2025 Calendar Year. For

specified property placed in service on or

after January 1, 2025, and before January

1, 2026, to satisfy the requirement to provide each item’s full PIN under section

7.02(2)(a) of this revenue procedure, the

QM Report only has to include the QM

Code that was provided to taxpayers in

accordance with sections 5.03 and 6.03(1)

of this revenue procedure.

.06 Exception for Enabling Property. A

QM is not required to submit QM Reports

for enabling property.

.07 Exception for Indoor Units of Heat

Pumps. A QM is not required to submit

QM Reports for the indoor units of heat

pumps.

.08 Time to File QM Reports.

(1) For items of specified property that

leave a QM’s control and enter the stream

of commerce on or after January 1, 2025,

and before January 1, 2026, only one QM

Report is required, and a QM must file that

report by January 15, 2026. A QM may

submit multiple QM Reports once the

IRS Energy Credits Online Portal begins

accepting QM Reports.

(2) For items of specified property produced on or after January 1, 2026, a QM

must file QM Reports by the fifteenth day

of the calendar month following the end

of the calendar quarter in which an item

of specified property leaves its control and

enters the stream of commerce (January

15, April 15, July 15, and October 15). A

QM may submit QM Reports more frequently than once per quarter.

.09 Format of QM Reports. QMs

must submit their QM Reports electronically using the template that the IRS will

make available on the IRS Energy Credits Online Portal. The IRS will not accept

QM Reports submitted in any other format. In considering how frequently to file

QM Reports, QMs should consult the IRS

Energy Credits Online Portal for current

file format and size limitations.

Bulletin No. 2024–46

.10 Updating and Rescinding QM

Reports. If a QM wishes to update or

rescind certain information on a QM

report for a scrivener’s error or missing PIN, the QM must do so through

the IRS Energy Credits Online Portal

as promptly as possible after its original

submission.

.11 IRS Acknowledgement of QM

Reports. Any acknowledgment that the

IRS provides in response to a QM Report,

such as an acknowledgement of receipt,

does not constitute an IRS determination

that any item of specified property qualifies for the § 25C credit or a verification of

any statement in the QM Report.

.12 Final QM Report for Voluntary

Discontinuance. A QM that discontinues

its QM status as provided in section 4.05

of this revenue procedure must submit

a final QM Report with the IRS through

the IRS Energy Credits Online Portal.

The final QM Report must account for

all remaining specified property produced

by the QM and assigned a PIN, and not

reported to the IRS in prior QM Reports,

until the date the final QM Report is filed.

The QM must check the box marking the

final QM Report as final.

Bulletin No. 2024–46

SECTION 8. PAPERWORK

REDUCTION ACT

.01 The Paperwork Reduction Act of 1995

(44 U.S.C. 3501 - 3520) (PRA) requires that

a Federal agency obtain the approval of the

Office of Management and Budget (OMB)

before collecting information from the public, whether such collection of information is

mandatory, voluntary, or required to obtain

or retain a benefit. A Federal agency may

not conduct or sponsor, and a person is not

required to respond to, a collection of information unless the collection of information

displays a valid control number.

.02 Section 4.01(4)(a) of this revenue

procedure provides that, where there are

multiple manufacturers in an item of specified property’s chain of production, the

manufacturers may agree that a certain

manufacturer will enter into an agreement

with the IRS. This provision includes a

recordkeeping requirement that the manufacturer entering into the agreement

must retain a copy of the agreement in the

manufacturer’s books and records. This

recordkeeping requirement is expected to

be a usual and customary business practice that would impose no additional bur-

1119

den on respondents. Therefore, the recordkeeping requirement would not require

OMB approval under 5 CFR 1320.3(b)(2).

.03 Sections 4, 6, and 7 of this revenue

procedure mention third-party disclosure

and reporting requirements that are necessary to ensure that specified property meets

the requirements for the § 25C credit. In

accordance with the Paperwork Reduction

Act (44 U.S.C. 3507), these collections of

information are included within the associated regulation and have been submitted

to the Office of Management and Budget

under OMB Control Number 1545-NEW

under PRA procedures 5 CFR 1320.11.

SECTION 9. DRAFTING

INFORMATION

The principal author of this revenue

procedure is the Office of Associate Chief

Counsel (Passthroughs & Special Industries). However, other personnel from the

Treasury Department and the IRS participated in its development. For further

information regarding this revenue procedure, call the energy security guidance

contact number at (202) 317-5254 (not a

toll-free number).

November 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. 2024–46

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.

November 12, 2024

Numerical Finding List1

Bulletin 2024–46

Announcements:

2024-26, 2024-27 I.R.B. 14

2024-27, 2024-27 I.R.B. 14

2024-28, 2024-28 I.R.B. 39

2024-29, 2024-29 I.R.B. 71

2024-31, 2024-34 I.R.B. 533

2024-32, 2024-35 I.R.B. 535

2024-30, 2024-36 I.R.B. 581

2024-39, 2024-39 I.R.B. 639

2024-34, 2024-41 I.R.B. 758

2024-35, 2024-43 I.R.B. 1013

2024-36, 2024-44 I.R.B. 1073

Notices:

2024-47, 2024-27 I.R.B. 1

2024-52, 2024-27 I.R.B. 2

2024-53, 2024-27 I.R.B. 4

2024-54, 2024-28 I.R.B. 24

2024-55, 2024-28 I.R.B. 31

2024-56, 2024-29 I.R.B. 64

2024-57, 2024-29 I.R.B. 67

2024-58, 2024-30 I.R.B. 120

2024-59, 2024-32 I.R.B. 348

2024-60, 2024-34 I.R.B. 515

2024-61, 2024-34 I.R.B. 520

2024-62, 2024-36 I.R.B. 570

2024-63, 2024-36 I.R.B. 573

2024-64, 2024-39 I.R.B. 632

2024-65, 2024-39 I.R.B. 633

2024-66, 2024-40 I.R.B. 682

2024-67, 2024-41 I.R.B. 726

2024-68, 2024-41 I.R.B. 729

2024-69, 2024-41 I.R.B. 733

2024-70, 2024-43 I.R.B. 1001

2024-72, 2024-43 I.R.B. 1005

2024-73, 2024-43 I.R.B. 1007

2024-71, 2024-44 I.R.B. 1026

2024-75, 2024-44 I.R.B. 1026

2024-74, 2024-45 I.R.B. 1089

2024-76, 2024-45 I.R.B. 1089

2024-77, 2024-45 I.R.B. 1093

2024-78, 2024-46 I.R.B. 1111

Proposed Regulations:

REG-124593-23, 2024-28 I.R.B. 40

REG-109032-23, 2024-31 I.R.B. 332

REG-120137-19, 2024-31 I.R.B. 336

REG-119283-23, 2024-32 I.R.B. 351

REG-102161-23 2024-33 I.R.B. 502

REG-103529-23, 2024-33 I.R.B. 512

REG-105128-23, 2024-35 I.R.B. 536

REG-108920-24, 2024-38 I.R.B. 607

REG-111629-23, 2024-39 I.R.B. 640

Proposed Regulations:—Continued

REG-106851-21, 2024-40 I.R.B. 684

REG-116787-23, 2024-40 I.R.B. 709

REG-119683-22, 2024-40 I.R.B. 716

REG-118269-23, 2024-41 I.R.B. 761

REG-112129-23, 2024-42 I.R.B. 787

REG-113628-21, 2024-44 I.R.B. 1074

Revenue Procedures:

2024-26, 2024-27 I.R.B. 7

2024-29, 2024-30 I.R.B. 121

2024-30, 2024-30 I.R.B. 183

2024-27, 2024-31 I.R.B. 300

2024-28, 2024-31 I.R.B. 326

2024-32, 2024-34 I.R.B. 523

2024-34, 2024-38 I.R.B. 604

2024-35, 2024-39 I.R.B. 638

2024-36, 2024-41 I.R.B. 737

2024-37, 2024-41 I.R.B. 755

2024-38, 2024-43 I.R.B. 1010

2024-33, 2024-44 I.R.B. 1030

2024-39, 2024-45 I.R.B. 1097

2024-40, 2024-45 I.R.B. 1100

2024-31, 2024-46 I.R.B. 1113

Revenue Rulings:

2024-13, 2024-28 I.R.B. 18

2024-14, 2024-28 I.R.B. 18

2024-15, 2024-32 I.R.B. 340

2024-16, 2024-35 I.R.B. 534

2024-17, 2024-36 I.R.B. 568

2024-18, 2024-37 I.R.B. 584

2024-20, 2024-40 I.R.B. 646

2024-21, 2024-41 I.R.B. 724

2024-22, 2024-43 I.R.B. 980

2024-23, 2024-43 I.R.B. 981

2024-24, 2024-45 I.R.B. 1086

Treasury Decisions:

10002, 2024-29 I.R.B. 56

9999, 2024-30 I.R.B. 72

10000, 2024-31 I.R.B. 185

10003, 2024-32 I.R.B. 342

10001, 2024-33 I.R.B. 412

10004, 2024-33 I.R.B. 489

9998, 2024-34 I.R.B. 412

10005, 2024-34 I.R.B. 510

9991, 2024-40 I.R.B. 646

10007, 2024-43 I.R.B. 981

9994, 2024-44 I.R.B. 1014

10008, 2024-45 I.R.B. 1082

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 30, 2024.

1

November 12, 2024

ii

Bulletin No. 2024–46

Finding List of Current Actions on

Previously Published Items1

Bulletin 2024–46

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 30, 2024.

1

Bulletin No. 2024–46

iii

November 12, 2024

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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