Bulletin No. 2024–27

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2024–27

July 1, 2024

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE, INCOME TAX

INCOME TAX

Notice 2024-47, page 1.

Announcement 2024-26, page 14.

Notice 2024-47 extends the relief provided in Notice 202433, which waived the estimated tax penalty imposed under

§ 6655 (for a corporation’s failure to pay estimated income

tax) to the extent attributable to the revised corporate

alternative minimum tax (CAMT) under § 55, but only with

respect to an installment of estimated tax due on April 15,

2024, or May 15, 2024, with respect to a taxable year that

began in 2024. In light of the continuing challenges associated with determining the applicability of the CAMT and the

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

the interest of sound tax administration, the relief from the

addition to tax under § 6655 provided by Notice 2024-33 is

extended to any installment of estimated tax by a corporate

taxpayer with respect to a taxable year that began in 2024

that is due on or before August 15, 2024, to the extent

attributable to the CAMT.

EMPLOYEE PLANS

Notice 2024-53, page 4.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment rates

for May 2024 used under § 417(e)(3)(D), the 24-month

average segment rates applicable for June 2024, and the

30-year Treasury rates, as reflected by the application of

§ 430(h)(2)(C)(iv).

EXEMPT ORGANIZATIONS

Announcement 2024-27, page 14.

Daystar Public Radio Inc. TIN: 59-3438641 has agreed to

the revocation of its IRC Section 501(c)(3) status effective

January 1, 2018.

Finding Lists begin on page ii.

Announcement 2024-6 provides notice of the partial suspension of the U.S.-Russia tax treaty.

Notice 2024-52, page 2.

The notice provides the applicable reference price for qualified natural gas production from qualified marginal wells

during taxable years beginning in calendar year 2024

for the purpose of determining the marginal well production credit under § 45I. The applicable reference price for

taxable years beginning in calendar year 2024 is $2.04

per 1,000 cubic feet. The notice also provides the credit

amount used for the purpose of determining the marginal

well production credit. The credit amount for taxable years

beginning in calendar year 2024 is $0.77 per 1,000 cubic

feet.

Rev. Proc. 2024-26, page 7.

This revenue procedure updates existing procedures and

provides additional procedures for qualified manufacturers to submit information regarding new clean vehicles to

ensure the vehicles satisfy the requirements of § 30D(d)

and (e) of the Internal Revenue Code for the applicable calendar year and therefore are eligible for the clean vehicle

credit under § 30D (§ 30D credit). This revenue procedure

also updates existing procedures regarding seller report

updates and rescissions. Finally, this revenue procedure

modifies section 7.03(4) of Rev. Proc. 2023-33, 2023-43

I.R.B. 1135, and modifies section 5.04 of Rev. Proc. 202338, 2023-51 I.R.B. 1544.

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.

July 1, 2024 

Bulletin No. 2024–27

Part III

Extended Relief from

Certain Additions to

Tax for Corporation’s

Underpayment of

Estimated Income Tax

under Section 6655

Notice 2024-47

SECTION 1. OVERVIEW

This notice provides a limited waiver

of the addition to tax under § 6655 of the

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

underpayment is attributable to the corporation’s corporate alternative minimum tax

(CAMT) liability under § 55, as amended

by § 10101 of Public Law 117-169, 136

Stat. 1818 (August 16, 2022), commonly

referred to as the Inflation Reduction Act

of 2022 (IRA).

SECTION 2. SCOPE

The relief provided in this notice

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

of a corporate taxpayer that is due on or

before August 15, 2024, with respect to a

taxable year that began during 2024. This

notice waives any addition to tax under

§ 6655 to the extent the amount of any

underpayment is attributable to the portion

of the CAMT liability due in that installment. Regarding installments of estimated

income tax of a corporate taxpayer (or

consolidated group) due after August 15,

2024, § 6655 applies in the normal course

and this notice does not apply, nor does

it waive the addition to tax under § 6655

to the extent the amount of any underpayment is attributable to provisions of the

Code other than § 55(a).

SECTION 3. BACKGROUND

.01 CAMT under the IRA. Section

10101 of the IRA amended § 55 to impose

1

a new CAMT based on the “adjusted

financial statement income” (AFSI) of an

applicable corporation for taxable years

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

the CAMT for a taxable year if it meets an

average annual AFSI test for one or more

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

2021 (Applicable Corporation). Section

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

an Applicable Corporation, the amount of

CAMT imposed by § 55 equals the excess

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

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

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

taxable year plus the tax imposed under

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

in the case of an Applicable Corporation,

the tentative minimum tax for the taxable

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

for the taxable year (as determined under

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

credit for the taxable year (as determined

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

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

minimum tax for the taxable year is zero.

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

announced that the Department of the

Treasury (Treasury Department) and the

Internal Revenue Service (IRS) intend to

issue forthcoming proposed regulations

addressing the application of the CAMT.

Notice 2023-7 also provided interim guidance intended to clarify the application of

certain aspects of the CAMT. Notice 202320, 2023-10 I.R.B. 523, Notice 2023-64,

2023-40 I.R.B. 974, and Notice 2024-10,

2024-3 I.R.B. 406, provided additional

interim guidance that is intended to further clarify the application of the CAMT.

Taxpayers may generally rely on the

interim guidance provided in the aforementioned notices for any taxable year

that begins before January 1, 2024, and

any taxable year that begins on or after

January 1, 2024, and ends on or before the

date proposed regulations addressing the

application of the CAMT are published

in the Federal Register. Special reliance

rules are provided in section 5 of Notice

2024-10 for the interim guidance provided

in that notice.

.02 Estimated Taxes. Section 6655(a)

imposes an addition to tax for failure by

a corporation to make a sufficient and

timely payment of estimated income tax.

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

to be paid in four installments and the

amount of any required installment is 25

percent of the required annual payment.

Generally, under § 6655(d)(1)(B), the

required annual payment is the lesser of

two amounts described in § 6655(d)(1)

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

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

tax shown on the return for the taxable

year. The amount described in § 6655(d)

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

on the taxpayer’s return for the preceding

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

and the return for such year showed a

liability for tax. However, pursuant to

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

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

(ii) may not be used to reduce the amount

of an installment payment other than the

first installment payment for the taxable

year. In special circumstances, other rules

specified in § 6655 or elsewhere may also

apply.

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

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

waiver of the addition to tax under § 6655

with respect to a corporation’s CAMT

liability under § 55 for any taxable year

that begins after December 31, 2022, and

before January 1, 2024.

On April 15, 2024, the Treasury

Department and the IRS issued Notice

2024-33, 2024-18 I.R.B. 959, which provided a limited waiver of the addition to

tax under § 6655 to the extent the amount

of any underpayment is attributable to a

portion of a corporation’s CAMT liability. The relief provided in Notice 2024-33

applied only for the purpose of calculating

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

Bulletin No. 2024–27

1

July 1, 2024

the installment of estimated tax by a corporate taxpayer that was due on or before

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

case of a fiscal year taxpayer with a taxable year beginning in February 2024),

with respect to a taxable year that began

in 2024.

SECTION 4. LIMITED WAIVER

OF ADDITION TO TAX FOR

UNDERPAYMENT OF ESTIMATED

INCOME TAX

.01 Waiver. In light of the continuing

challenges associated with determining

whether a corporation is an Applicable

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

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

the addition to tax under § 6655 that is

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

with respect to a taxable year that began

in 2024 that is due on or before August

15, 2024. Accordingly, a corporate taxpayer’s required installment of estimated

tax that is due on or before August 15,

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

prevent the imposition of an addition to

tax under § 6655. If a corporation fails to

timely pay its CAMT liability under § 55

when due, other sections of the Code may

apply; for example, additions to tax could

be imposed under § 6651 if payment of

the CAMT liability is not made by the due

date (without regard to any extension) of

the corporation’s return.

.02 Instructions to be modified.

Affected taxpayers must file Form 2220

with their Federal income tax return, even

if they owe no estimated tax penalty, to

avoid a penalty notice. The instructions to

Form 2220, Underpayment of Estimated

Tax by Corporations, will be modified

to provide specific instructions on how

to avoid a penalty notice. The instructions also will clarify that no addition to

tax will be imposed under § 6655 based

on a corporation’s failure to make an estimated tax payment of its CAMT liability

under § 55, for an installment of estimated tax with respect to a taxable year

that began in 2024 that is due on or before

August 15, 2024, and that a taxpayer may

exclude such amounts when calculating

July 1, 2024

the amount of its required annual payment

on Form 2220 for purposes of calculating

the installments of estimated tax for which

relief is provided. The modified instructions will be posted on https://www.irs.

gov.

amount is determined using the 2024

inflation adjustment factor of 1.5447 and

the applicable reference price of $2.04 per

Mcf. The credit amount for taxable years

beginning in calendar year 2024 is $0.77

per Mcf.

SECTION 5. APPLICABILITY DATE

SECTION 2. BACKGROUND

The waiver of the addition to tax

imposed by § 6655 described in section

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

before August 15, 2024.

Section 45I(a), as it relates to qualified natural gas production, provides that,

for purposes of § 38, the MWC for any

taxable year is an amount equal to the

product of (1) the credit amount and (2)

the qualified natural gas production that is

attributable to the taxpayer.

Section 45I(c)(1) provides that “qualified natural gas production” means

domestic natural gas produced from a

qualified marginal well. Section 45I(c)(3)

(A) provides that a qualified marginal well

is a domestic well (i) the production from

which during the taxable year is treated as

marginal production under § 613A(c)(6),

or (ii) which, during the taxable year, (I)

has average production of not more than

25 barrel-of-oil equivalents per day, and

(II) produces water at a rate not less than

95 percent of total well effluent.

Section 613A(c)(6)(D) and (E) provide that “marginal production” means

domestic natural gas produced during

any taxable year from a property which

is a stripper well property for the calendar

year in which the taxable year begins. A

“stripper well property” is, with respect to

any calendar year, any property producing

not more than 15 barrel equivalents per

day, determined by dividing the average

daily production of domestic crude oil

and domestic natural gas from producing

wells on the property for such calendar

year by the number of such wells.

Section 45I(c)(2)(A) provides that

generally only the first 1,095 barrels or

barrel-of-oil equivalents (as defined in

§ 45K(d)(5)) produced during the taxable

year qualify for the MWC. This limitation

is proportionately reduced in the case of a

short taxable year or in the case of a well

that is not capable of production each day

of a taxable year. See § 45I(c)(2)(B). The

number of wells on which a taxpayer may

claim the MWC is not limited.

Section 45I(d)(2) provides that to claim

the credit a taxpayer must hold an operating interest in the qualified marginal well

SECTION 6. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice is

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

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

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

Reference Price for Section

45I Credit for Production of

Natural Gas from Marginal

Wells During Taxable Years

Beginning in Calendar Year

2024

Notice 2024-52

SECTION 1. PURPOSE

This notice provides the applicable

reference price for qualified natural gas

production from qualified marginal wells

during taxable years beginning in calendar year 2024 for the purpose of determining the marginal well production credit

(MWC) under § 45I of the Internal Revenue Code. The applicable reference price

for taxable years beginning in calendar

year 2024 is $2.04 per 1,000 cubic feet

(Mcf).

This notice also provides the credit

amount used for the purpose of determining the MWC for taxable years beginning in calendar year 2024. The credit

2

Bulletin No. 2024–27

producing the natural gas to which the

credit relates. Under § 45I(d)(1), if a well is

owned by more than one owner and the natural gas production exceeds the limitation

under § 45I(c)(2), the qualifying natural gas

production attributable to the taxpayer is

determined on the basis of the ratio which

the taxpayer’s revenue interest in the production bears to the aggregate of the revenue interests of all operating interest owners

in the production. Finally, § 45I(d)(3) provides that the MWC is not allowable if the

taxpayer is also eligible to claim the § 45K

nonconventional sources credit for the taxable year, unless the taxpayer elects not to

claim the credit under § 45K for the well.

For purposes of § 45I(a)(1), the credit

amount is 50 cents (adjusted for inflation)

per Mcf of qualified natural gas production (tentative credit amount). See § 45I(b)

(1)(B) and (b)(2)(B).

Section 45I(b)(2)(A) and (B) provide

that the tentative credit amount (adjusted

for inflation) is reduced (but not below

zero) to the extent that the applicable

reference price exceeds $1.67 (adjusted

for inflation). More specifically, § 45I(b)

(2)(A) provides that the tentative credit

amount (adjusted for inflation) is reduced

by an amount which bears the same ratio

to the tentative credit amount (adjusted

for inflation) as the excess (if any) of

the applicable reference price over $1.67

(adjusted for inflation), bears to $0.33

(adjusted for inflation). As a result, the

MWC is not available if the applicable

reference price for qualified natural gas

production is $2.00 (adjusted for inflation)

or more.

Section 45I(b)(2)(A) also provides that

the applicable reference price for a taxable

year is the reference price for the calendar

year preceding the calendar year in which

the taxable year begins. Section 45I(b)(2)

(C)(ii) provides that the term “reference

price” means, with respect to any calendar

year, in the case of qualified natural gas

production, the Secretary’s estimate of the

annual average wellhead price per Mcf for

all domestic natural gas.

Section 45I(b)(2)(B) provides that in

the case of any taxable year beginning

in a calendar year after 2005, each of

the dollar amounts contained in § 45I(b)

(2)(A) will be increased to an amount

equal to such dollar amount multiplied

by the inflation adjustment factor for

such calendar year (determined under

§ 43(b)(3)(B) by substituting “2004”

for “1990”).

SECTION 3. INFLATION

ADJUSTMENT FACTOR AND

REFERENCE PRICE

.01 Inflation Adjustment. The inflation

adjustment factor under § 45I(b)(2)(B) for

calendar year 2024 is 1.5447.

.02 Reference Price. The Secretary’s

estimate of the calendar year 2023 annual

average wellhead price per Mcf for all

domestic natural gas under § 45I(b)(2)

(C)(ii) was calculated by applying the

Producer Price Index commodity index

for “Natural Gas from the Wellhead”

(WPU053101051)1 published by the

Bureau of Labor Statistics (BLS) as part

of its Producer Price Index program, to

the 2023 annual average wellhead price

($5.57) published in Notice 2023-58,

2023-34 I.R.B. 536. The annual Producer

Price Index commodity index for natural

gas published by the BLS was 173.206 in

2022 and 63.423 in 2023, which implies

a ratio of 2023 to 2022 average wellhead

prices of 0.366 (63.423/173.206). Therefore, the Secretary’s estimate of the calendar year 2023 annual average wellhead

price per Mcf for all domestic natural gas

is $2.04 per Mcf (0.366 × $5.57 per Mcf).

The one-cent difference is due to rounding.

For years after 2023, the Secretary

intends to continue calculating the reference price by application of the Producer Price Index commodity index

for “Natural Gas from the Wellhead”

(WPU053101051) published by the BLS

to the previous year’s reference price.

SECTION 4. CALCULATION OF

CREDIT AMOUNT

Under § 45I(b)(1)(B) and (2)(B), the

tentative credit amount used to calculate

the MWC for taxable years beginning

in calendar year 2024 is $0.77 per Mcf

($0.50 × 1.5447 inflation adjustment factor). However, to determine the credit

amount for purposes of § 45I(a)(1), the

tentative credit amount must be reduced

as provided by § 45I(b)(2).

Specifically, pursuant to § 45I(b)(2)

(A), the tentative credit amount is reduced

(but not below zero) by an amount (the

Reduction Amount) which bears the same

ratio to such amount as (i) the excess (if

any) of the applicable reference price over

$2.58 ($1.67 × 1.5447 inflation adjustment factor), bears to (ii) $0.51 ($0.33 ×

1.5447 inflation adjustment factor). The

Reduction Amount (as adjusted for inflation) is computed as follows:

Reduction Amount

Applicable Reference Price – $2.58

=

Tentative Credit Amount

$0.51

Reduction Amount

$2.04 – $2.58

=

$0.77

$0.51

The Reduction Amount is $- 0.82

(($2.04 - $2.58) ÷ $0.51 × $0.77), which

is less than zero and therefore the tentative credit amount ($0.77) is not

reduced.

1

SECTION 5. EFFECTIVE DATE

This notice is effective for qualified

natural gas production during taxable

years beginning in calendar year 2024.

SECTION 6. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice is

David Villagrana of the Office of Associ-

https://data.bls.gov/cgi-bin/srgate. The BLS publishes indexes and not actual or average prices.

Bulletin No. 2024–27

3

July 1, 2024

ate Chief Counsel (Passthroughs & Special Industries). For further information

regarding this notice contact Mr. Villagrana at (202) 317-5138 (not a toll-free

number).

YIELD CURVE AND SEGMENT

RATES

Section 430 specifies the minimum

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

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

430(h)(2) specifies the interest rates that

must be used to determine a plan’s target

normal cost and funding target. Under this

provision, present value is generally determined using three 24-month average interest rates (“segment rates”), each of which

applies to cash flows during specified periods. To the extent provided under § 430(h)

(2)(C)(iv), these segment rates are adjusted

by the applicable percentage of the 25-year

average segment rates for the period ending

September 30 of the year preceding the calendar year in which the plan year begins.1

However, an election may be made under

§ 430(h)(2)(D)(ii) to use the monthly yield

curve in place of the segment rates.

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

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

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

the 24-month average corporate bond

segment rates used to compute the target

normal cost and the funding target. Consistent with the methodology specified in

Update for Weighted

Average Interest Rates,

Yield Curves, and

Segment Rates

Notice 2024-53

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

under § 417(e)(3), and the 24-month

average segment rates under § 430(h)

(2) of the Internal Revenue Code. In

addition, this notice provides guidance

as to the interest rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)

(II) as in effect for plan years beginning

before 2008 and the 30-year Treasury

weighted average rate under § 431(c)

(6)(E)(ii)(I).

Applicable Month

June 2024

§ 1.430(h)(2)-1(d), the monthly corporate

bond yield curve derived from May 2024

data is in Table 2024-5 at the end of this

notice. The spot first, second, and third

segment rates for the month of May 2024

are, respectively, 5.18, 5.41, and 5.62.

The 24-month average segment rates

determined under § 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant

to § 430(h)(2)(C)(iv) to be within the

applicable minimum and maximum percentages of the corresponding 25-year

average segment rates. For this purpose,

any 25-year average segment rate that is

less than 5% is deemed to be 5%. The

25-year average segment rates for plan

years beginning in 2023 and 2024 were

published in Notice 2022-40, 2022-40

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

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

minimum and maximum percentages are

95% and 105% for plan years beginning

in 2023 and 2024.

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate

bond segment rates applicable for June

2024 without adjustment for the 25-year

average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment

First Segment

Second Segment

4.93

5.27

The adjusted 24-month average segment rates set forth in the chart below

reflect § 430(h)(2)(C)(iv) of the Code. The

24-month averages applicable for June

2024, adjusted to be within the applicable

minimum and maximum percentages of

Third Segment

5.26

the corresponding 25-year average segment rates in accordance with § 430(h)(2)

(C)(iv) of the Code, are as follows:

Adjusted 24-Month Average Segment Rates

For Plan Years

Beginning In

Applicable Month

First Segment

Second Segment

Third Segment

2023

June 2024

4.93

5.27

5.74

2024

June 2024

4.93

5.27

5.59

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount

of the full funding limitation under § 433(c)(7)(C)).

2

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

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

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

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July 1, 2024

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Bulletin No. 2024–27

30-YEAR TREASURY SECURITIES

INTEREST RATES

Section 431 specifies the minimum

funding requirements that apply to multiemployer plans pursuant to § 412. Section 431(c)(6)(B) specifies a minimum

amount for the full-funding limitation

described in § 431(c)(6)(A), based on the

plan’s current liability. Section 431(c)

(6)(E)(ii)(I) provides that the interest

rate used to calculate current liability for

this purpose must be no more than 5 percent above and no more than 10 percent

below the weighted average of the rates

of interest on 30-year Treasury securities during the four-year period ending

on the last day before the beginning of

the plan year. Notice 88-73, 1988-2 C.B.

383, provides guidelines for determining the weighted average interest rate.

The rate of interest on 30-year Treasury

securities for May 2024 is 4.62 percent.

The Service determined this rate as the

average of the daily determinations

of yield on the 30-year Treasury bond

maturing in February 2054 determined

each day through May 8, 2024 and the

yield on the 30-year Treasury bond

maturing in May 2054 determined each

day for the balance of the month. For

plan years beginning in June 2024, the

weighted average of the rates of interest

on 30-year Treasury securities and the

permissible range of rates used to calculate current liability are as follows:

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

June 2024

3.46

3.11 to 3.63

under § 417(e)(3)(D) are segment rates

computed without regard to a 24-month

average. Section 1.417(e)-1(d)(3) and

Notice 2007-81 provide guidelines for

determining the minimum present value

segment rates. Pursuant to those guidelines,

the minimum present value segment rates

determined for May 2024 are as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

May 2024

Minimum Present Value Segment Rates

First Segment

Second Segment

5.18

5.41

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2024–27

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

5

Third Segment

5.62

of this guidance. For further information

regarding this notice, contact Mr. Morgan

at 202-317-6700 or Tony Montanaro at

626-927-1475 (not toll-free numbers).

July 1, 2024

Table 2024-5

Monthly Yield Curve for May 2024

Derived from April 2024 Data

Maturity

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

7.5

8.0

8.5

9.0

9.5

10.0

10.5

11.0

11.5

12.0

12.5

13.0

13.5

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

18.5

19.0

19.5

20.0

Yield

5.55

5.42

5.30

5.20

5.13

5.07

5.04

5.02

5.01

5.02

5.03

5.06

5.09

5.12

5.16

5.19

5.23

5.27

5.30

5.33

5.36

5.39

5.42

5.44

5.47

5.49

5.50

5.52

5.53

5.55

5.56

5.57

5.57

5.58

5.59

5.59

5.60

5.60

5.60

5.61

July 1, 2024

Maturity

20.5

21.0

21.5

22.0

22.5

23.0

23.5

24.0

24.5

25.0

25.5

26.0

26.5

27.0

27.5

28.0

28.5

29.0

29.5

30.0

30.5

31.0

31.5

32.0

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

38.0

38.5

39.0

39.5

40.0

Yield

5.61

5.61

5.61

5.61

5.61

5.61

5.61

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.60

5.61

5.61

5.61

5.61

5.61

5.61

5.61

5.61

5.61

5.62

5.62

5.62

5.62

5.62

5.62

5.62

5.62

Maturity

40.5

41.0

41.5

42.0

42.5

43.0

43.5

44.0

44.5

45.0

45.5

46.0

46.5

47.0

47.5

48.0

48.5

49.0

49.5

50.0

50.5

51.0

51.5

52.0

52.5

53.0

53.5

54.0

54.5

55.0

55.5

56.0

56.5

57.0

57.5

58.0

58.5

59.0

59.5

60.0

Yield

5.62

5.62

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.63

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.64

5.65

5.65

5.65

5.65

6

Maturity

60.5

61.0

61.5

62.0

62.5

63.0

63.5

64.0

64.5

65.0

65.5

66.0

66.5

67.0

67.5

68.0

68.5

69.0

69.5

70.0

70.5

71.0

71.5

72.0

72.5

73.0

73.5

74.0

74.5

75.0

75.5

76.0

76.5

77.0

77.5

78.0

78.5

79.0

79.5

80.0

Yield

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.65

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

Maturity

80.5

81.0

81.5

82.0

82.5

83.0

83.5

84.0

84.5

85.0

85.5

86.0

86.5

87.0

87.5

88.0

88.5

89.0

89.5

90.0

90.5

91.0

91.5

92.0

92.5

93.0

93.5

94.0

94.5

95.0

95.5

96.0

96.5

97.0

97.5

98.0

98.5

99.0

99.5

100.0

Yield

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.66

5.67

5.67

5.67

5.67

5.67

Bulletin No. 2024–27

26 CFR 1.30D-3(d), 26 CFR 1.30D-6(d)(2)(ii). Submission of Information by Qualified Manufacturers

of New Clean Vehicles and Dealers and Sellers of

New Clean Vehicles and Previously-Owned Clean

Vehicles.

(Also Part I, §§ 25E and 30D.)

Rev. Proc. 2024-26

SECTION 1. PURPOSE

This revenue procedure updates existing procedures and provides additional

procedures for qualified manufacturers to

submit information regarding new clean

vehicles to ensure the vehicles satisfy the

requirements of § 30D(d) and (e) of the

Internal Revenue Code (Code)1 for the

applicable calendar year and therefore are

eligible for the clean vehicle credit under

§ 30D (§ 30D credit). This revenue procedure also updates existing procedures

regarding seller report updates and rescissions. Finally, this revenue procedure

modifies section 7.03(4) of Rev. Proc.

2023-33, 2023-43 I.R.B. 1135, and modifies sections 5.04 and 5.06 of Rev. Proc.

2023-38, 2023-51 I.R.B. 1544.

SECTION 2. BACKGROUND

.01 Overview. This section provides an

overview of this revenue procedure and

relevant background. Section 3 of this

revenue procedure provides definitions

applicable to this revenue procedure. Section 4 of this revenue procedure provides

updated procedures with respect to the

compliant-battery ledger for purposes of

§ 30D, provides a new procedure for the

submission of the report for the transition

rule for impracticable-to-trace battery

materials, and modifies section 5.06 of

Rev. Proc. 2023-38. Section 5 of this revenue procedure provides procedures relevant to the critical minerals and battery

components requirements of § 30D(e) and

the upfront review of such requirements.

Section 6 of this revenue procedure provides updated procedures on updating and

rescinding seller reports under § 30D(d)

(1)(H).

.02 Section 30D Clean Vehicle Credit.

(1) Section 30D was enacted by

§ 205(a) of the Energy Improvement

1

and Extension Act of 2008, Division B

of Public Law 110-343, 122 Stat. 3765,

3835 (October 3, 2008), to provide a

credit for purchasing and placing in service new qualified plug-in electric drive

motor vehicles. Section 30D has been

amended several times since its enactment, most recently by § 13401 of Public

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

2022), commonly known as the Inflation

Reduction Act of 2022 (IRA). In general,

the amendments made by § 13401 of the

IRA to § 30D apply to vehicles placed in

service after December 31, 2022, except

as provided in § 13401(k)(2) through (5)

of the IRA.

(2) Section 30D(a) allows a credit

for the taxable year with respect to each

new clean vehicle placed in service by a

taxpayer during the taxable year. Section

30D(b) provides a maximum credit of

$7,500 per vehicle, consisting of $3,750

if certain critical minerals requirements

are met and $3,750 if certain battery

components requirements are met. These

requirements are described in § 30D(e)(1)

and (2), respectively.

(3) Section 13401(k)(3) of the IRA

provides that the critical minerals requirement described in § 30D(e)(1) (Critical

Minerals Requirement) and the battery components requirement described

in § 30D(e)(2) (Battery Components

Requirement) apply to vehicles placed

in service after the date on which proposed guidance with respect to the Critical Minerals and the Battery Components

Requirements is issued by the Secretary

of the Treasury or her delegate (Secretary). On April 17, 2023, the Department

of the Treasury (Treasury Department)

and the Internal Revenue Service (IRS)

issued a Notice of Proposed Rulemaking

in the Federal Register (88 F.R. 23370),

which constitutes that proposed guidance. Thus, the Critical Minerals and

Battery Components Requirements apply

to vehicles placed in service on or after

April 18, 2023.

.03 IRS Final Regulations. On May 6,

2024, the Treasury Department and the

IRS published TD 9995 in the Federal

Register (89 FR 37706) (final regulations).

The final regulations provide guidance

under §§ 25E, 30D, and 6213, as amended

by §§ 13401, 13402, and 13301(f)(4), (g)

(2), and 13403(b)(2), respectively, of the

IRA.

.04 Revenue Procedures.

(1) Rev. Proc. 2022-42, 2022-52 I.R.B.

565, in relevant part, established procedures for qualified manufacturers to enter

into written agreements with the IRS in

accordance with §§ 30D(d)(1)(C) and

30D(d)(3). Sections 4.01 and 4.02 of Rev.

Proc. 2022-42 provided, respectively,

information regarding the contents of the

written agreement that a manufacturer

must enter into with the IRS to become a

qualified manufacturer, and the contents

of the written reports submitted by the

qualified manufacturer to the IRS.

(2) Rev. Proc. 2023-33, in relevant

part, superseded sections 6.01 and 6.02 of

Rev. Proc. 2022-42, and provided updated

information on written agreements to be

submitted by manufacturers to the IRS to

become qualified manufacturers, as well

as the method for qualified manufacturers

to submit monthly reports, beginning January 1, 2024.

(3) Rev. Proc. 2023-38, in relevant

part, established procedural rules for qualified manufacturers of new clean vehicles

to comply with the reporting, certification, and attestation requirements regarding the excluded entity restriction, under

which the IRS, with analytical assistance

from the Department of Energy (DOE),

will review compliance with the excluded

entity restrictions of § 30D(d)(7). Section

5.01 of Rev. Proc. 2023-38 provided that,

for calendar years beginning January 1,

2025, for vehicles to qualify for the § 30D

credit, the qualified manufacturer must

provide information to the IRS to establish a compliant-battery ledger for each

year. The compliant-battery ledger for a

calendar year tracks a qualified manufacturer’s anticipated supply of batteries that

are FEOC-compliant for such a calendar

year. See § 1.30D-2(b)(11) and (22) for

definitions of the terms “compliant-battery ledger” and “FEOC-compliant.” Rev.

Proc. 2023-38 also superseded certain

provisions of Rev. Proc. 2022-42 and Rev.

Proc. 2023-33 not relevant to this revenue

procedure.

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

Bulletin No. 2024–27

7

July 1, 2024

SECTION 3. DEFINITIONS

.01 In General. Except as provided in

section 3.02 of this revenue procedure,

terms used in this revenue procedure have

the same meaning as provided in §§ 25E,

30D, and 45W, and § 1.30D-2.

.02 IRS Energy Credits Online Portal.

For purposes of this revenue procedure,

the term “IRS Energy Credits Online Portal” refers to the registration portal that

manufacturers and sellers must use to register as a qualified manufacturer, seller, or

registered dealer. A link to the site is available on https://www.irs.gov. Any successor portal or successor site address will be

announced and made available on https://

www.irs.gov.

SECTION 4. COMPLIANTBATTERY LEDGER FOR

PURPOSES OF § 30D

.01 Introduction. For calendar years

beginning January 1, 2025, for new clean

vehicles to qualify for the § 30D credit,

the qualified manufacturer must provide

information to the IRS and the DOE to

establish a compliant-battery ledger for

each calendar year. The compliant-battery ledger for a qualified manufacturer

for a calendar year is a ledger established

under the rules of § 1.30D-6(d) that tracks

the number of FEOC-compliant batteries for such calendar year. The procedure

for qualified manufacturers to establish a

compliant-battery ledger, as well as the

procedure to increase or reduce the battery-compliant ledger, is provided in section 5 of Rev. Proc. 2023-38. See § 1.30D6(b) for rules related to the due diligence

the qualified manufacturer must conduct

with respect to all battery components

and applicable critical minerals (and associated constituent materials) that are relevant to determining whether such components or minerals are FEOC-compliant.

.02 Upfront Review of Projected Number of FEOC-Compliant Batteries.

(1) In general. To establish a compliant-battery ledger, the qualified manufacturer must submit the attestation of the

projected number of FEOC-compliant

batteries and other information described

§ 1.30D-6(d) and section 5.03 of Rev.

Proc. 2023-38 (collectively, the submission) for upfront review to the DOE

July 1, 2024

through a method provided by the DOE.

The IRS will make a determination with

respect to the submission, with analytical

assistance from the DOE, and notify the

qualified manufacturer of its determination. As part of the IRS determination process, DOE will review the submission by

the manufacturer; conduct analysis based

on such submission, its own expertise, and

independent research; and provide that

analysis to the IRS.

A template report and workbook will

be made available by the IRS or the DOE

prior to July 1 of the year prior to the calendar year for which the compliant-battery

ledger is being established. Qualified manufacturers are encouraged to submit the

requisite information using the template

report and template workbook to ensure

a more streamlined review process. While

qualified manufacturers are not required

to use the template workbook, they must

submit a workbook spreadsheet. The formulas in the workbook spreadsheet submitted by the qualified manufacturer must

be visible and not converted into calculated values.

(2) Report for transition rule for

impracticable-to-trace battery materials.

(a) Section 1.30D-6(b)(2) provides that

for any new clean vehicle for which the

qualified manufacturer provides a periodic

written report before January 1, 2027, the

due diligence requirement of § 1.30D-6(b)

(1) may be satisfied by excluding impracticable-to-trace battery materials, as defined

in § 1.30D-2(b)(25). To use this transition

rule, a qualified manufacturer must submit

a report during the upfront review process

described in § 1.30D-6(d)(2)(ii) for each

year it seeks to use the transition rule.

(b) The report must demonstrate how

the qualified manufacturer will comply

with the FEOC restriction of § 30D(d)

(7) and § 1.30D-6 for vehicles placed in

service after December 31, 2026, at the

latest, including information about efforts

made to date to secure a FEOC-compliant

supply of these battery materials once the

transition rule is no longer in effect. The

qualified manufacturer must submit the

report described in this section 4.02 of this

revenue procedure for upfront review to

the DOE through a method provided by

the DOE.

(c) The report must contain the following information:

8

(i) For any applicable critical mineral on the list of impracticable-to-trace

battery materials for which the qualified

manufacturer intends to rely on the transition rule, an explanation of how the

qualified manufacturer anticipates complying with the FEOC restrictions and

conducting due diligence with respect to

that material by the end of the transition

rule period.

(ii) Within this explanation, a list

of current suppliers for from which

the qualified manufacturer purchases

impracticable-to-trace battery materials, and the expected total quantity of

impracticable-to-trace battery materials

that will be used in vehicles for which

the qualified manufacturer anticipates

providing a periodic written report in the

upcoming calendar year. With respect to

future suppliers:

(aa) If available, the names of suppliers

of impracticable-to-trace battery materials with which the qualified manufacturer

has signed an offtake agreement, and the

quantity of supply under that agreement.

Indicate whether these agreements would

or would not satisfy expected demand for

30D-eligible vehicles beginning in 2027.

(bb) The names of suppliers of

impracticable-to-trace battery materials

with which the qualified manufacturer

has not yet signed offtake agreements

but have entered into formal discussions

for supply, and the year that supply

would be provided. Provide the status of

each such agreement, including material

qualification, joint development agreements (if any), legal review, and financial review.

(cc) Documentation that demonstrates

meaningful efforts and progress to secure

a FEOC-compliant supply of impracticable-to-trace battery materials for use in

the qualified manufacturer’s vehicles after

the transition period, such as memoranda

of understanding, letters of commitment,

joint press releases, qualification processes, and/or offtake agreements. Letters

of intent will not be considered to demonstrate meaningful progress.

(dd) An explanation of how these suppliers will increase the qualified manufacturer’s ability to conduct due diligence as

to this applicable critical mineral.

(ee) If available, a list of entities that

extract, process, or recycle impractica-

Bulletin No. 2024–27

ble-to-trace battery materials upstream

of the suppliers with which the qualified

manufacturer has an offtake agreement or

formal discussions.

(ff) If available, a description of the due

diligence practices of the suppliers with

which the qualified manufacturer has an

offtake agreement or formal discussions.

(iii) If the supply of battery materials

in signed offtake agreements and agreements under discussion is insufficient to

support the anticipated number of vehicles for which the qualified manufacturer

anticipates providing a periodic written

report beginning in 2027, an explanation

of how the qualified manufacturer plans to

address that.

(d) The DOE will review the information submitted by the qualified manufacturer and make any requests for additional

information from the qualified manufacturer within 45 days of the submission,

unless a longer period is agreed to by the

qualified manufacturer and the DOE. The

qualified manufacturer must respond to the

request for additional information within

21 days of receipt of such request unless a

longer period is agreed to by the qualified

manufacturer and the DOE. The DOE will

notify the IRS of its analysis within 90

days of the qualified manufacturer’s submission, and whether the information submitted in the report is sufficient. The IRS

will then make a determination within 30

days and notify the qualified manufacturer

whether it satisfied the report requirement.

.03 Modification of section 5.06 of Rev.

Proc. 2023-38. Section 5.06 of Rev. Proc.

2023-38 is modified to read as follows:

.06 Submission of 2024 information. The qualified manufacturer must

submit the information and attestations described in sections 5.03(1) and

5.03(3) through 5.03(5) of Revenue

Procedure 2023-38 with respect to

vehicles that have been placed in service or are expected to be placed in

service during calendar year 2024, by

September 1, 2024. However, the submission of the information related to

vehicles that have been or are expected

to be placed in service in calendar year

2024 is not required to include information related to applicable critical

minerals and associated constituent

materials.

Bulletin No. 2024–27

SECTION 5. CRITICAL MINERALS

AND BATTERY COMPONENTS

REQUIREMENTS FOR PURPOSES

OF § 30D

.01 Introduction.

(1) Section 30D(e)(1)(A) provides that

with respect to a vehicle, the Critical Minerals Requirement with respect to the battery from which the electric motor of such

vehicle draws electricity is satisfied if the

percentage of the value of the applicable

critical minerals (as defined in § 45X(c)

(6)) contained in such battery that were

(i) extracted or processed in the United

States, or in any country with which the

United States has a free trade agreement

(FTA) in effect, or (ii) recycled in North

America, is equal to or greater than the

applicable percentage (as certified by the

qualified manufacturer, in such form or

manner as prescribed by the Secretary).

The applicable percentage for the Critical Minerals Requirement is set forth in

§ 30D(e)(1)(B)(i) through (v) and varies

based on when the vehicle is placed in service. Treasury regulations further provide

that the Critical Minerals Requirement is

met if the qualifying critical mineral content of the clean vehicle battery is equal to

or greater than the applicable critical minerals percentage (as defined in § 30D(e)(1)

(B) and § 1.30D-3(a)(2)), as certified by

the qualified manufacturer, in such form

or manner as prescribed by the Secretary.

See § 1.30D-3(a)(1). If the Critical Minerals Requirement is met with respect to a

new clean vehicle, such vehicle is eligible

for a $3,750 credit amount, as provided in

§ 30D(b)(2).

(2) Section 30D(e)(2)(A) provides

that with respect to a vehicle, the Battery

Components Requirement with respect to

the battery from which the electric motor

of such vehicle draws electricity is satisfied if the percentage of the value of the

components contained in such battery

that were manufactured or assembled in

North America is equal to or greater than

the applicable percentage (as certified by

the qualified manufacturer, in such form

or manner as prescribed by the Secretary).

The applicable percentage for the Battery

Components Requirement is set forth in

§ 30D(e)(2)(B)(i) through (vi) and varies

based on when the vehicle is placed in service. Treasury regulations further provide

9

that the Battery Components Requirement

is met if the qualifying battery component content of the clean vehicle battery is

equal to or greater than the applicable battery components percentage (as defined

in § 1.30D-3(b)(2)), as certified by the

qualified manufacturer, in such form or

manner as prescribed by the Secretary. See

§ 1.30D-3(b)(1). If the Battery Components Requirement is met with respect to a

new clean vehicle, such vehicle is eligible

for a $3,750 credit amount, as provided in

§ 30D(b)(3).

.02 Reporting requirements.

(1) For new clean vehicles anticipated

to be placed in service after December 31,

2024, the qualified manufacturer must provide information to the DOE to establish

that the Critical Minerals Requirement has

been met for each calendar year in order

for the qualified manufacturer to certify

such vehicles as eligible for the $3,750

credit amount described in § 30D(b)(2).

This information and supporting documentation (as described in § 1.30D-3(d))

for a calendar year must support a qualified manufacturer’s qualifying critical

mineral content of a clean vehicle battery

(as defined in § 1.30D-3(c)(1)(iii)) for

such calendar year. For vehicles placed in

service in calendar year 2024, the qualified manufacturer is not required to provide information to comply with the Critical Minerals Requirement.

(2) For new clean vehicles anticipated

to be placed in service after December

31, 2024, the qualified manufacturer must

provide information to the DOE to establish that the Battery Components Requirement has been met for each calendar year

in order for the qualified manufacturer to

certify such vehicles for the $3,750 credit

amount described in § 30D(b)(3). This

information and supporting documentation (as described in § 1.30D-3(d)) for

a calendar year must support a qualified

manufacturer’s qualifying battery component content of a clean vehicle battery (as

defined in § 1.30D-3(c)(2)(iii)) for such

calendar year. For vehicles placed in service in calendar year 2024, the qualified

manufacturer is not required to provide

information to comply with the Battery

Components Requirement, but the qualified manufacturer must submit information to the DOE regarding FEOC-compliance of battery components as provided

July 1, 2024

in § 1.30D-6(e) and section 5.06 of Rev.

Proc. 2023-38.

(3) To comply with the Critical Minerals Requirement for a calendar year, the

qualified manufacturer must do the following: (i) determine the qualifying mineral content with respect to a clean vehicle

battery in accordance with section 5.03(1)

of this revenue procedure; (ii) certify that

the qualifying critical mineral content of a

clean vehicle battery is equal to or greater

than the applicable critical minerals percentage for such year; and (iii) submit a

compliance report in accordance with

section 5.04 of this revenue procedure.

To comply with the Battery Components

Requirement for a calendar year, the qualified manufacturer must (i) determine the

qualifying battery component content

with respect to a clean vehicle battery in

accordance with section 5.03(2) of this

revenue procedure; (ii) certify that the

qualifying battery component content of a

clean vehicle battery is equal to or greater

than the applicable battery component

percentage for such year; and (iii) submit

a compliance report in accordance with

section 5.04 of this revenue procedure.

(4) The requirements of this section

5.02 of this revenue procedure are in

addition to the submissions required to

establish the compliant-battery ledger of

FEOC-compliant batteries (as defined

in § 1.30D-2(b)(11)), as provided for

in § 1.30D-6(d), section 5 of Rev. Proc.

2023-38, and section 4 of this revenue

procedure. The attestations, certifications,

and documentation described in section

5.04 of this revenue procedure showing

compliance with the Critical Minerals

Requirement or the Battery Components

Requirement should be submitted with the

submissions required to establish the compliant-battery ledger of FEOC-compliant

batteries. Any information submitted

regarding FEOC compliance may also be

used by the DOE and the IRS to evaluate a

qualified manufacturer’s compliance with

the Critical Minerals Requirement and

the Battery Components Requirement as

detailed in this revenue procedure.

.03 Determination of Qualifying Critical Mineral Content and Qualifying Battery Component Content.

(1) For any vehicle for which the qualified manufacturer intends to make the

certification described in section 5.02(1),

July 1, 2024

the qualified manufacturer must determine the qualifying critical mineral content with respect to a clean vehicle battery,

as described in § 1.30D-3(a)(3)). For new

clean vehicles for which the qualified

manufacturer submitted a periodic written

report on or after May 6, 2024, and before

January 1, 2027, qualifying critical mineral content with respect to a clean vehicle

battery may be calculated in accordance

with the temporary safe harbor described

in § 1.30D-3(a)(4).

(2) For any vehicle for which the qualified manufacturer intends to make the

certification described in section 5.02(2),

the qualified manufacturer must determine

the qualifying battery component content

with respect to a clean vehicle battery, as

described in § 1.30D-3(b)(3).

.04 Documentation and attestations to

be provided to the DOE.

(1) The qualified manufacturer must

submit to the DOE a compliance report,

including supporting documentation in

relation to applicable critical minerals and

battery components, as described in section 5.04(2) of this revenue procedure, and

make attestations, under penalty of perjury, as described in section 5.04(3) of this

revenue procedure. For any vehicle for

which the qualified manufacturer intends

to make the certification described section 5.02(1) of this revenue procedure, the

compliance report must contain the information described in section 5.04(2)(a)-(c).

For any vehicle for which the qualified

manufacturer intends to make the certification described section 5.02(2) of this

revenue procedure, the compliance report

must contain the information described in

section 5.04(2)(a), (b) and (d). The qualified manufacturer may make separate submissions for each group of vehicles over

which the manufacturer averages the qualifying critical mineral content calculation

as described in § 1.30D-3(a)(3)(iv) or the

qualifying battery component content

calculation described in § 1.30D-3(b)(3)

(iv), provided the qualified manufacturer

specifies in its submission the group of

such vehicles to which such submissions

relates.

(2) Compliance report. The compliance report must contain the following

information:

(a) A description of measures taken to

exercise due diligence and the approach

10

taken to determine compliance with the

requirements of § 30D(e).

(b) If available, independent analysis

or audit of compliance factors prior to

the submission of information showing

compliance with the Critical Minerals

Requirement or the Battery Components

Requirement, as applicable, to the DOE,

including identification of the auditor or

analyst and the auditor or analyst’s expertise for performing such analysis.

(c) For purposes of the Critical Minerals Requirement:

(i) The location for extraction, processing, and recycling of each procurement

chain of each applicable critical mineral

and constituent material contained in the

clean vehicle battery.

(ii) The value added by extraction, processing, or recycling, including:

(I) The share of total value added by

extraction activities that occurred in the

United States or a country with which the

United States has a free trade agreement

(FTA location).

(II) The share of total value added by

processing activities that occurred in the

United States or FTA location.

(III) The share of total value added by

recycling activities in North America.

(iii) The value of each applicable critical mineral contained in the clean vehicle

battery.

(iv) A calculation of the qualifying critical mineral content.

(d) For purposes of the Battery Components Requirement:

(i) The incremental value of each North

American battery component as defined in

§ 1.30D-3(c)(2)(ii).

(ii) The incremental value of each battery component contained in a clean vehicle battery.

(iii) The location of manufacturing and

assembly of each battery component.

(iv) A calculation of the qualifying battery component content.

(3) Attestations. The qualified manufacturer must make the following attestations under penalty of perjury:

(a) An attestation that the qualified

manufacturer has exercised due diligence

to determine that the applicable critical

minerals or battery components, as applicable, as relating to new clean vehicles

that the qualified manufacturer intends to

certify to the IRS, are compliant with the

Bulletin No. 2024–27

Critical Minerals Requirement or the Battery Components Requirement.

(b) An attestation that if any material

changes occur with respect to any information provided in section 5.04(2) of this

revenue procedure, the qualified manufacturer will report this information to the

DOE as provided in section 5.05 of this

revenue procedure.

(4) An attestation that the information

submitted is true and correct to the best

of the knowledge of the qualified manufacturer’s representative, who is currently

authorized to bind the qualified manufacturer in these matters.

.05 Upfront Review of Compliance with

the Critical Minerals Requirement and the

Battery Components Requirement.

(1) For new clean vehicles expected

to be placed in service after December

31, 2024, to establish compliance with

the Critical Minerals Requirement or

the Battery Components Requirement,

the qualified manufacturer must submit the documentation and attestations

described in section 5.04 of this revenue

procedure for upfront review to the DOE

through a method provided by the DOE.

See § 1.30D-3(d). A template report and

workbook will be made available by the

IRS or DOE prior to July 1 of the year

prior to the calendar year for which compliance is being established; the template report and workbook are the same

templates referenced in section 4.02 of

this revenue procedure. Qualified manufacturers are encouraged to submit the

requisite information using the template

report and template workbook to ensure a

more streamlined review process. While

qualified manufacturers are not required

to use the template workbook, they must

submit a workbook spreadsheet. The

formulas in the workbook spreadsheet

submitted by the qualified manufacturer

must be visible and not converted into

calculated values.

(2) As part of the IRS determination

process, DOE will review submissions

by the manufacturer; conduct analysis based on such submissions, its own

expertise, and independent research; and

provide that analysis to the IRS. The IRS

will make a determination with respect

to the submission, with analytical assistance from the DOE, and notify the qualified manufacturer of its determination

Bulletin No. 2024–27

regarding compliance with the Critical

Minerals Requirement or the Battery

Components Requirement for purposes

of the qualified manufacturer’s certifications to the IRS.

(3) If a qualified manufacturer submits

the information to the DOE by July 1 of the

year prior to the calendar year for which

compliance is being established, the DOE

will review the information submitted by

the qualified manufacturer and make any

requests for additional information from

the qualified manufacturer within 45 days

of the submission, unless a longer period

is agreed to by the qualified manufacturer

and the DOE.

(a) The DOE may request additional

information from the qualified manufacturer. The qualified manufacturer must

respond to the request for additional information within 21 days of receipt of such

request unless a longer period is agreed

to by the qualified manufacturer and the

DOE.

(b) The DOE will notify the IRS of

its analysis no later than October 1 of the

calendar year prior to the calendar year

for which the qualified manufacturer is

seeking to make certifications regarding

compliance with the Critical Minerals

Requirement and the Battery Components

Requirement. The IRS will then make a

determination concerning compliance and

share its determination with the qualified

manufacturer no later than October 31.

(4) If a qualified manufacturer makes

its submission regarding compliance with

the Critical Minerals Requirement and the

Battery Components Requirement after

July 1 of the year prior to the calendar

year for which compliance is being established, the DOE will review and provide

its analysis, and the IRS, in consultation

with the DOE, will make determinations

on a rolling basis.

.06 Right to Administrative Review.

If, on the basis of the DOE’s analysis or

otherwise, the IRS determines that a qualified manufacturer failed to meet the Critical Minerals Requirement or the Battery

Components Requirement, the qualified

manufacturer will have 21 days from the

date of the IRS’s electronic notification

of its determination to request administrative review of the DOE’s analysis and

IRS’s determination. If the qualified manufacturer requests administrative review,

11

it may submit additional information to

the DOE regarding compliance with the

relevant requirements. Once the DOE

determines such additional information is

complete, the DOE will provide the IRS

with an updated analysis within 21 days.

The IRS will make a final determination

concerning compliance within 21 days of

receipt of the DOE’s analysis of the qualified manufacturer’s request for administrative review and any additional information submitted during the administrative

review.

.07 Failure to establish compliance. If,

after the administrative review described

in section 5.06 of this revenue procedure

if applicable, the IRS determines that the

documentation or attestations for a new

clean vehicle or group of vehicles contain

inaccurate or insufficient information or

information that does not support compliance with the Critical Minerals Requirement or the Battery Components Requirement, the IRS will notify the qualified

manufacturer electronically in writing,

and:

(1) In the case of a new clean vehicle

that has not been placed in service for

which the qualified manufacturer has submitted a periodic written report certifying compliance with the requirements of

§ 30D(e):

(i) In the case of a vehicle for which

documentation and information does not

support compliance with the Critical Minerals Requirement, such vehicle will not

be eligible for the $3,750 credit amount

described in § 30D(b)(2);

(ii) In the case of a vehicle for which

documentation and information does

not support compliance with the Battery

Components Requirement, such vehicle

will not be eligible for the $3,750 credit

amount described in § 30D(b)(3);

(2) In the case of a new clean vehicle

that has not been placed in service for

which the qualified manufacturer has not

submitted a periodic written report certifying compliance with the requirement of

§ 30D(e):

(i) In the case of a vehicle for which

documentation and information does not

support compliance with the Critical Minerals Requirement, the qualified manufacturer may not certify that such vehicle

is eligible for the $3,750 credit amount

described in § 30D(b)(2);

July 1, 2024

(ii) In the case of a vehicle for which

documentation and information does

not support compliance with the Battery

Components Requirement, the qualified manufacturer may not certify that

such vehicle is eligible for $3,750 credit

amount described in § 30D(b)(3).

SECTION 6. SELLER REPORTS

.01 Seller reports generally. Section

1.30D-2(b)(46) provides that the term

“seller report” means the report described

in § 30D(d)(1)(H) that the seller of a new

clean vehicle provides to the taxpayer and

the IRS in the manner provided in, and

containing the information described in,

guidance published in the Internal Revenue Bulletin (see § 601.601 of the Statement of Procedural Rules (26 CFR Part

601)). Section 1.30D-2(b)(46) further provides that the seller report must be transmitted to the IRS electronically, and that

the term “seller report” does not include

a report rejected by the IRS due to the

information contained therein not matching IRS records. Section 1.25E-1(b)(18)

provides the same definition for purposes

of section 25E. Section 7.03(1) through

(3) of Rev. Proc. 2023-33 provides procedural rules related to the time and manner

of filing seller reports, the requirement to

furnish copies of seller reports, and IRS

rejection of seller reports.

.02 Updating and Rescinding Seller

Reports.

(1) Error on seller report. If the seller

of a new clean vehicle discovers that

information on the seller report is incorrect, the seller must notify the IRS of the

error by submitting updated information

in the manner specified in the instructions

on the IRS Energy Credits Online Portal

as promptly as possible after the discovery of the error. The IRS will acknowledge submission of the updated information and will notify the seller of whether

the updated information is accepted or

rejected by the IRS. The seller must notify

the taxpayer listed on the seller report

within 3 calendar days of submitting the

updated information to the IRS, and provide the buyer a copy of the updated timeof-sale report. If the IRS rejects the seller’s submission of updated information,

the seller must also notify the taxpayer

July 1, 2024

listed on the seller report within 3 calendar

days of such rejection.

(2) Cancelled sale. If the sale of a new

clean vehicle is cancelled before the vehicle is placed in service, the seller must

rescind the seller report in the manner

specified in the instructions on the IRS

Energy Credits Online Portal as promptly

as possible after the sale is cancelled. The

IRS will acknowledge rescission of the

seller report. The seller must notify the

buyer within 3 calendar days of rescinding

the seller report and provide the buyer a

copy of the IRS acknowledgement that the

seller report has been rescinded. If the IRS

rejects the seller’s attempted rescission of

the seller report, the seller must also notify

the buyer within 3 calendar days of such

rejection.

(3) Vehicle Return. If a buyer returns

a vehicle to the seller within 30 days of

placing such vehicle in service, the seller

must update the seller report in the manner specified in the instructions on the IRS

Energy Credits Online Portal. The IRS will

acknowledge submission of the report of

the vehicle return. The seller must notify

the buyer within 3 calendar days of the

update to the seller report and provide the

buyer a copy of the IRS acknowledgement

that the seller report has been updated.

.03 Repayment of Advance Payment

of § 30D Credit in the event of cancelled

sale, vehicle return, or other error. If the

seller receives an advance payment of the

§ 30D credit with respect to a new clean

vehicle that is returned within 30 days

to the seller or with respect to which the

sale is cancelled, the seller must return the

amount received as an advance payment

in the manner specified in the instructions

on the IRS Energy Credits Online Portal. If the seller receives an advance payment of the § 30D credit with respect to a

new clean vehicle that was paid in error,

regardless of the nature of the error, the

seller must return the amount received as

an advance payment in the manner specified in the instructions on the IRS Energy

Credits Online Portal.

SECTION 7. EFFECT ON OTHER

DOCUMENTS

.01 Section 4.02(2) of this revenue procedure modifies section 5.04 of Rev. Proc.

12

2023-38, regarding the transition rule for

impracticable-to-trace battery materials.

.02 Section 4.03 of this revenue procedure modifies section 5.06 of Rev. Proc.

2023-38, regarding the submission of

FEOC-compliance information for vehicles the qualified manufacturer intends

to make available to be placed in service

during calendar year 2024.

.03 Section 6.02 of this revenue procedure modifies section 7.03(4) of Rev. Proc.

2023-33, providing information for sellers

and dealers of qualified new and previously-owned clean vehicles to update and

rescind seller reports in the event of an

error in the seller report, a cancelled sale,

or a vehicle return.

SECTION 8. PAPERWORK

REDUCTION ACT

.01 The collection of information contained in this revenue procedure has been

submitted, and will be submitted, to the

Office of Management and Budget in

accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control

numbers 1545-2137 and 1545-2311. An

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 OMB

control number.

.02 The collection requirements in

sections 4, 5, and 6 of this revenue procedure were previously approved by OMB

under control numbers 1545-2311 and

1545-2137. This revenue procedure does

not change these collection requirements

and their associated burdens. This information is collected and retained to ensure

that vehicles meet the requirements for

the § 30D credit. This information will be

used to determine whether the vehicle for

which the credit is claimed by a taxpayer

qualifies for the § 30D credit. The collection of information is voluntary to obtain

a benefit. The likely respondents are corporations and partnerships.

.03 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

revenue law. Generally, tax returns and

tax return information are confidential, as

required by § 6103.

Bulletin No. 2024–27

SECTION 10. DRAFTING

INFORMATION

The principal author of this revenue

procedure is the Office of Associate Chief

Bulletin No. 2024–27

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

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

information regarding this revenue pro-

13

cedure, call the energy security guidance

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

toll-free number).

July 1, 2024

Part IV

Announcement Regarding

the Suspension of the

United States-Russia Tax

Treaty

Announcement 2024-26

The United States provided formal

notice to the Russian Federation on June

17, 2024, to confirm the suspension of

the operation of paragraph 4 of Article

1 and Articles 5-21 and 23 of the Convention between the United States of

America and the Russian Federation for

the Avoidance of Double Taxation and

the Prevention of Fiscal Evasion with

Respect to Taxes on Income and Capital, signed at Washington on June 17,

1992 (Convention), as well as the operation of its accompanying Protocol, by

mutual agreement. See Press Release,

United States’ Notification of Suspension, By Mutual Agreement, of the 1992

Tax Convention with Russia (June 17,

2024), https://home.treasury.gov/news/

press-releases/jy2410.

This action responds to notification

by the Russian Federation on August 8,

2023, of its desire to suspend paragraph

4 of Article 1 and Articles 5-21 and 23

of the Convention, as well as the Protocol.

The suspension will take effect both for

taxes withheld at source and in respect of

other taxes on August 16, 2024, and will

continue until otherwise decided by the

two governments.

For further information regarding this

announcement contact the Office of Associate Chief Counsel (International) at

(202) 317-3800 (not a toll-free number).

Deletions From Cumulative

List of Organizations,

Contributions to Which are

Deductible Under Section

170 of the Code

Announcement 2024-27

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 organiza-

NAME OF ORGANIZATION

EFFECTIVE DATE OF

REVOCATION

LOCATION

1/1/2018

TITUSVILLE FL

DAYSTAR PUBLIC RADIO INC.

July 1, 2024

tion 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 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 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:

14

Bulletin No. 2024–27

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. 2024–27

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.

July 1, 2024

Numerical Finding List1

Bulletin 2024–27

Announcements:

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

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

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

Revenue Procedures:

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

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

July 1, 2024

ii

Bulletin No. 2024–27

Finding List of Current Actions on

Previously Published Items1

Bulletin 2024–27

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. 2024–27

iii

July 1, 2024

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

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