Internal Revenue Bulletin 2024-46 (PDF rendition): IRS Notices

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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.
Finding Lists begin on page ii.
HIGHLIGHTS
OF THIS ISSUE
Bulletin No. 2024–46
November 12, 2024
INCOME TAX
Rev. Proc. 2024-31, page 1113.
This revenue procedure provides the procedures and require-
ments 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
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.

November 12, 2024 Bulletin No. 2024–46
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The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
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Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial 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 sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of inter-
nal 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 rul-
ings 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, disbar-
ment 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.

Bulletin No. 2024–46 1111 November 12, 2024
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, sub-
ject 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 intergov-
ernmental 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 sig-
nificant non-compliance (described in
Article 5(2) or 5(3) of the relevant IGA)
with the reporting Model 1 FFI’s obliga-
tions 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 addi-
tional 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 cer-
tain codes provided by the IRS that iden-
tify 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 per-
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 finan-
cial 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 (Trea-
sury Department) collaborated with for-
eign governments to develop two alterna-
tive 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 automat-
ically exchanges the information with the
U.S. Competent Authority.
A reporting Model 1 FFI that com-
plies 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. citi-
zen is the individual’s U.S. Social Secu-
rity 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 miss-
ing 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 report-
ing Model 1 FFIs in eligible Model 1 IGA
jurisdictions that were unable to obtain
and report required U.S. TINs for preex-
isting 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 com-
plied with the requirements of Notice
2023-11, the U.S. Competent Authority
would not determine there was signifi-
cant 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. report-
able accounts opened after the determina-
tion date specified in the applicable Model
1 IGA (new accounts), including new
accounts held by account holders of pre-
existing accounts.
The IRS continues to evaluate the
reported TIN Codes and other informa-
tion provided by Model 1 FFIs to under-
stand 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-
1
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).

November 12, 2024 1112 Bulletin No. 2024–46
tional information from TIN Code report-
ing in more calendar years is necessary
to develop future potential compliance
options. The IRS has also concluded that
certain additional data points are neces-
sary to ensure sufficient individual iden-
tifiers 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 require-
ments 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-com-
pliance 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. Sec-
tion 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 pre-
existing 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 require-
ments of this notice or Notice 2023-11, as
applicable. Further, nothing in this notice
or Notice 2023-11 prevents the U.S. Com-
petent 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 preex-
isting 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 calen-
dar 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 report-
ing 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 search-
able account information contains a for-
eign taxpayer identification number (or
functional equivalent) assigned to a tax-
payer 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 speci-
fied 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 sec-
tion, the only requirement is that the city
and country of residence of the specified
U.S. person must be included in Address-
Fix.
.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 require-
ment 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 Depart-
ment’s Joint FATCA FAQs (as of the
publication date of this notice, https://
travel.state.gov/content/travel/en/inter-
national-travel/while-abroad/Joint-
Foreign-Account-Tax-Compliance-
FATCA-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 proce-
dures (as of the publication date
of this notice, https://www.irs.
gov/individuals/international-
taxpayers/relief-procedures-for-
certain-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 fol-
lowed 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 documen-
tation 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 eligi-
ble for the relief described in this section
2
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).

Bulletin No. 2024–46 1113 November 12, 2024
with respect to reporting for a particular
calendar year or other appropriate report-
ing 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 compli-
ance 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 Com-
petent Authority Arrangements with the
U.S. Competent Authority, to implement
an IGA, amend an Annex II to an IGA,
or exchange country-by-country informa-
tion.
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 spon-
sor, 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 con-
tained 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 col-
lections are included with the OMB con-
trol number 1545-2246.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
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 (Inter-
national). For further information regard-
ing 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 manu-
facturer of specified property must follow
to be treated as a “qualified manufacturer”
(QM) under § 25C(h) of the Internal Rev-
enue 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 identifi-
cation 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 spec-
ified 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 Infla-
tion Reduction Act of 2022 (IRA), which
renamed this provision the “energy effi-
cient 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 subsec-
tion (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 improve-
ments 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 sec-
tion 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 cat-
egories 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
1
Unless otherwise specified, all “Section” or “§” references are to sections of the Code.

November 12, 2024 1114 Bulletin No. 2024–46
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 gen-
eral $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 natu-
ral 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 num-
ber 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 manu-
facturer of specified property that enters
into an agreement with the Secretary of
the Treasury or the Secretary of the Trea-
sury’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 man-
ufacturer or by such other method as the
Secretary may provide (PIN assignment
requirement),
(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 informa-
tion as the Secretary may require with
respect to the items of specified property
to which such product identification num-
bers 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 sky-
lights) 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 fur-
nace 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 tax-
payer, 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 Decem-
ber 31, 2022, and before January 1, 2027,
meets or exceeds 2021 Energy Star certi-
fied efficiency criteria, and is rated by the
manufacturer for use with fuel blends at
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 Decem-
ber 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 eligi-
ble fuel.
(d) Any improvement to, or replace-
ment 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 prop-
erty, and
(iv) enables the installation and use of
any qualified energy efficiency improve-
ments or any qualified energy property
described in § 25C(d)(2)(A) through (C).
.03 Proposed Regulations. In con-
junction with the publication of this rev-
enue procedure, the Department of the
Treasury (Treasury Department) and the
IRS are publishing a notice of proposed
rulemaking (REG-118264-23) in the Fed-
eral Register (89 F.R. 85099) under § 25C
(proposed regulations). The proposed reg-
ulations would provide rules for manu-
facturers 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 rev-
enue 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 geo-
graphic areas of the United States. The

Bulletin No. 2024–46 1115 November 12, 2024
term “relevant geographic climate zone”
refers to the applicable climate zone for
the applicable specified product. Energy
Star is a voluntary labeling and rating pro-
gram administered by the U.S. Environ-
mental 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 con-
sortium consisting primarily of utility effi-
ciency 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 manufac-
turer of specified property must enter into
an agreement with the IRS. Except as pro-
vided in section 4.02 of this revenue pro-
cedure, 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 rep-
resentative 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 informa-
tion to complete the manufacturer’s appli-
cation and enter into an agreement (QM
Registration Application and Agreement)
on the manufacturer’s behalf. The autho-
rized representative will need an account
on https://www.irs.gov to verify the man-
ufacturer’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 repre-
sentative must execute the manufacturer’s
QM Registration Application and Agree-
ment on the IRS Energy Credits Online
Portal. Specifically, the representative
must provide the following information
and make the following certifications:
(a) The manufacturer’s name and busi-
ness address;
(b) The authorized representative’s
telephone number and email address;
(c) The manufacturer’s Taxpayer Iden-
tification Number (TIN) or Employer
Identification Number (EIN);
(d) A listing of the categories of spec-
ified property that the manufacturer pro-
duces or intends to produce. (The appli-
cation 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 manufac-
turer 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 guid-
ance), and that the manufacturer agrees to
submit required periodic written reports to
the IRS of the PINs assigned in the man-
ner 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 consol-
idated income tax return; and
(h) Such other information and certifi-
cations 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 autho-
rized representative must sign the QM
Registration Application and Agreement,
and also must include the following state-
ment, 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 represen-
tative must execute this signature elec-
tronically within the IRS Energy Credits
Online Portal.
(4) Requirement for Multiple Manufac-
turers.
(a) In general. If more than one man-
ufacturer participates in the production of
the same product that is specified prop-
erty, 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 man-
ufacturers providing that a different one
of the manufacturers is required to reg-
ister 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 assem-
bles 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 agree-
ment with the IRS to become the QM with
respect to the window.
(5) Special Requirement for Manu-
facturers of Enabling Property. A manu-
facturer that produces enabling property
2

must follow the registration, application,
and written agreement process described
in this section 4, even if the manufacturer
produces no other type of specified prop-
erty, despite modified requirements with
respect to enabling property elsewhere in
this revenue procedure.
(6) Special Requirements for Certain
Manufacturers of Heat Pumps. A manu-
2
Defined in § 1.25C-1(b)(6) of the proposed regulations.

November 12, 2024 1116 Bulletin No. 2024–46
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 sec-
tion 4, even if the manufacturer produces
no other type of specified property, despite
modified requirements with respect to
heat pumps elsewhere in this revenue pro-
cedure.
(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 Appli-
cation 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 Agree-
ment, the IRS will notify the manufac-
turer if the manufacturer’s registration is
accepted or rejected. If the IRS accepts the
QM Registration Application and Agree-
ment, the IRS will send a certification to
the manufacturer’s authorized represen-
tative 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 pub-
lish 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 pro-
duced 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 Agree-
ment by April 30, 2025, will be deemed
to have been a QM as of December 31,
2024, provided such QM Registration
Application and Agreement is validated
by the IRS. Accordingly, for a manufac-
turer 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 Reg-
istration. The IRS may suspend or revoke
a QM registration in the IRS’s sole discre-
tion if the IRS concludes that the manu-
facturer 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 pub-
lished 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 represen-
tative 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 Rejec-
tion, Suspension or Revocation of QM sta-
tus. 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 Agree-
ment, 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 Cred-
its Online Portal and filing a final QM
Report, as provided in section 7.12 of
this revenue procedure. The secure mes-
sage must state that the QM is terminat-
ing 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 sta-
tus 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 assign-
ment 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 proce-
dure, QMs must assign a 17-character PIN
unique to each item of specified property.
The PIN for each item of specified prop-
erty is made up of three parts and may
contain alphanumeric characters (includ-
ing 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-charac-
ter QM Code. When the IRS validates a
QM Registration Application and Agree-
ment, 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 Prod-
uct 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 prop-
erty and, if applicable, the relevant geo-
graphic 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-
3
The letters I and O may not be used because they are easily mistaken for the numbers 1 and 0.

Bulletin No. 2024–46 1117 November 12, 2024
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 lead-
ing zeroes. The IRS encourages QMs to
employ nonsequential characters.
.03 Specified Property Placed in Ser-
vice During the 2025 Calendar Year.
Notwithstanding section 5.02 of this rev-
enue procedure, for all specified prop-
erty 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 sat-
isfy the § 25C(h)(3)(A) PIN assignment
requirement by using its QM Code in lieu
of its PIN, and taxpayers claiming the sec-
tion 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 reve-
nue procedure.
.06 Timing of PIN Assignment Require-
ment in section 5.02. A QM must assign
PINs described in section 5.02 of this rev-
enue procedure to each item of specified
property that they produce beginning on
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, pro-
vided 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 exam-
ple of PINs that satisfy the PIN Assign-
ment 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 representa-
tive timely and properly executes and sub-
mits 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 Agree-
ment and assigned “A1A1” as the compa-
ny’s QM Code.
(2) During the 2025 taxable year, XYZ
Corp manufactures a line of energy effi-
cient 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, assum-
ing the windows still qualify for the § 25C
credit, then XYZ Corp must provide tax-
payers 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 manu-
factures 10,000 Blue windows and 10,000
White windows in 2026, or 20,000 win-
dows in total. The Product Code for both
lines of XYZ Corp’s windows is “2,”
based on the northern climate zone.
(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” repre-
senting each window’s Product Code.
(c) XYZ Corp assigns Item Num-
bers “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
613
th
2026 taxable year White window to
which XYZ Corp assigns a PIN.
SECTION 6. PIN LABELING
REQUIREMENT
.01 In General. To satisfy the PIN label-
ing 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 tax-
payers 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 exte-
rior packaging of the product, which
could cause difficulties in the adminis-
tration 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 1118 Bulletin No. 2024–46
.03 Time to Furnish PINs to Taxpayers;
No Prerequisites to Receiving the PIN.
(1) In general. For specified prop-
erty placed in service on or after Janu-
ary 1, 2025, and before January 1, 2026,
in order to comply with the PIN label-
ing 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 pur-
chase 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 manu-
facturer 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 tax-
payers 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 tax-
payers 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
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 man-
ufacturer 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 reve-
nue 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 Num-
ber (except as provided in section 7.05 of
this revenue procedure), and
(b) such item’s month and year of man-
ufacture;
(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 accom-
panying documents, signed by an individ-
ual authorized to bind the QM in matters
involving agreements with the IRS, in the
following form: “Under penalties of per-
jury, I declare that I have examined this
certification, including any and all accom-
panying documents, and that to the best of
my knowledge, the facts presented in sup-
port 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 spec-
ified property for purposes of the § 25C
credit.
.05 Specified Property Placed in Ser-
vice 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 pro-
vide 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 pro-
duced 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 fre-
quently than once per quarter.
.09 Format of QM Reports. QMs
must submit their QM Reports electroni-
cally using the template that the IRS will
make available on the IRS Energy Cred-
its Online Portal. The IRS will not accept
QM Reports submitted in any other for-
mat. 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 1119 November 12, 2024
.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 miss-
ing 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 quali-
fies 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.
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 pub-
lic, 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 infor-
mation 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 spec-
ified 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 man-
ufacturer 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 prac-
tice that would impose no additional bur-
den on respondents. Therefore, the record-
keeping 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 neces-
sary 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 asso-
ciated 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 Indus-
tries). However, other personnel from the
Treasury Department and the IRS par-
ticipated in its development. For further
information regarding this revenue pro-
cedure, call the energy security guidance
contact number at (202) 317-5254 (not a
toll-free number).

Bulletin No. 2024–46 i 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 pub-
lished 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished 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 pub-
lished ruling that is not considered deter-
minative 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 sub-
stance 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 rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings 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.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

November 12, 2024 ii Bulletin No. 2024–46
Numerical Finding List
1
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
1
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.

Bulletin No. 2024–46 iii November 12, 2024
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2024–46
1
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.

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