Internal Revenue Bulletin 2024-12 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 2024–12
March 18, 2024
HIGHLIGHTS
OF THIS ISSUE
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
Notice 2024-26, page 713.
This notice announces that withholding agents (both U.S.
and foreign persons) are administratively exempt from the
requirements to electronically file Forms 1042,
Annual With-
holding Tax Return for U.S. Source Income of Foreign Per-
sons, required to be filed in calendar year 2024. Additionally,
this notice announces that withholding agents that are for-
eign persons are administratively exempt from the require-
ments to electronically file Forms 1042 required to be filed in
calendar year 2025.
EXEMPT ORGANIZATION
Announcement 2024-14, page 719.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
INCOME TAX
Notice 2024-25, page 712.
Resident populations of the 50 states, the District of Colum-
bia, Puerto Rico, and the insular areas for purposes of deter-
mining the 2024 calendar year (1) state housing credit ceil-
ing under section 42(h) of the Code, (2) private activity bond
volume cap under section 146, and (3) private activity bond
volume limit under section 142(k) are reproduced.
Notice 2024-27, page 715.
This notice requests additional comments on any situations
in which an election under § 6417(a) could be made for a
credit that was purchased in a transfer for which an elec-
tion under § 6418(a) is made. Such sequence of events is
referred to as “chaining” in this notice.
Rev. Proc. 2024-15, page 717.
This revenue procedure sets forth the Federal income tax
treatment that may apply to certain legislatively authorized
transactions entered into by a public utility to recover speci-
fied costs through a surcharge to customers within the utili-
ty’s service area. The transactions in question involve a secu-
ritization in which the issuance of debt instruments is by a
qualifying State financing entity. The revenue procedure also
modifies Rev. Proc. 2005-62, 2005-2 C.B. 507.
Finding Lists begin on page ii.

The IRS Mission
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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.
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.
March 18, 2024 Bulletin No. 2024–12

Part III
2024 Calendar Year
Resident Population
Figures
Notice 2024-25
This notice advises State and local
housing credit agencies that allocate
low-income housing credits under § 42 of
the Internal Revenue Code, and States and
other issuers of tax-exempt private activ-
ity bonds under § 141, of the population
figures to use in calculating: (1) the 2024
calendar year population-based compo-
nent of the State housing credit ceiling
(Credit Ceiling) under § 42(h)(3)(C)(ii);
(2) the 2024 calendar year volume cap
(Volume Cap) under § 146; and (3) the
2024 volume limit (Volume Limit) under
§ 142(k)(5).
Generally, the population-based com-
ponent of both the Credit Ceiling and
the Volume Cap are determined under §
146(j), which requires determining the
population figures for any calendar year
on the basis of the most recent census esti-
mate of the resident population of a State
(or issuing authority) released by the U.S.
Census Bureau before the beginning of the
calendar year. Similarly, § 142(k)(5) bases
the Volume Limit on the State population.
Sections 42(h)(3)(H) and 146(d)(2)
require adjusting for inflation the popula-
tion-based component of the Credit Ceil-
ing and the Volume Cap. The Credit Ceil-
ing adjustment for the 2024 calendar year
is in Rev. Proc. 2023-34; 2023-48 I.R.B.
1287. Section 3.09 of Rev. Proc. 2023-34
provides that, for calendar year 2024, the
amount for calculating the Credit Ceil-
ing under § 42(h)(3)(C)(ii) is the greater
of $2.90 multiplied by the State popula-
tion, or $3,360,000. Further, section 3.20
of Rev. Proc. 2023-34 provides that the
amount for calculating the Volume Cap
under § 146(d)(1) for calendar year 2024
is the greater of $125 multiplied by the
State population, or $378,230,000.
For the 50 states, the District of Colum-
bia, and Puerto Rico, the population fig-
ures for calculating the Credit Ceiling, the
Volume Cap, and the Volume Limit for the
2024 calendar year are the resident pop-
ulation estimates released electronically
by the U.S. Census Bureau on December
19, 2023, and described in Press Release
CB23-217. For American Samoa, Guam,
the Northern Mariana Islands, and the
U.S. Virgin Islands, the population figures
for the 2024 calendar year are the 2023
midyear population figures in the U.S.
Census Bureau’s International Data Base.
For convenience, these figures are
reprinted below.
Resident Population Figur
es
Alabama 5,108,468
Alaska 733,406
American Samoa 44,620
Arizona 7,431,344
Arkansas 3,067,732
California 38,965,193
Colorado 5,877,610
Connecticut 3,617,176
Delaware 1,031,890
District of Columbia 678,972
Florida 22,610,726
Georgia 11,029,227
Guam 169,330
Hawaii 1,435,138
Idaho 1,964,726
Illinois 12,549,689
Indiana 6,862,199
Iowa 3,207,004
Kansas 2,940,546
Kentucky 4,526,154
Louisiana 4,573,749
Maine 1,395,722
Maryland 6,180,253
Massachusetts 7,001,399
Michigan 10,037,261
Minnesota 5,737,915
Mississippi 2,939,690
Missouri 6,196,156
Montana 1,132,812
March 18, 2024 712 Bulletin No. 2024–12

Nebraska 1,978,379
Nevada 3,194,176
New Hampshire 1,402,054
New Jersey 9,290,841
New Mexico 2,114,371
New York 19,571,216
North Carolina 10,835,491
North Dakota 783,926
Northern Mariana Islands 51,295
Ohio 11,785,935
Oklahoma 4,053,824
Oregon 4,233,358
Pennsylvania 12,961,683
Puerto Rico 3,205,691
Rhode Island 1,095,962
South Carolina 5,373,555
South Dakota 919,318
Tennessee 7,126,489
Texas 30,503,301
Utah 3,417,734
Vermont 647,464
Virginia 8,715,698
Virgin Islands, U.S. 104,917
Washington 7,812,880
West Virginia 1,770,071
Wisconsin 5,910,955
Wyoming 584,057
The principal authors of this notice are
Waheed M. Olayan, Office of the Associ-
ate Chief Counsel (Passthroughs and Spe-
cial Industries), and David White, Office
of the Associate Chief Counsel (Financial
Institutions and Products). For further
information regarding this notice, please
contact Waheed M. Olayan at (202) 317-
4137 (not a toll-free number).
Administrative Exemption
from Requirement to
Electronically File Form
1042,
Annual Withholding
Tax Return for U.S. Source
Income of Foreign Persons
Notice 2024-26
SECTION 1. PURPOSE
This notice announces that withhold-
ing agents (both U.S. and foreign persons)
are administratively exempt from the
requirements to electronically file Forms
1042, Annual Withholding Tax Return for
U.S. Source Income of Foreign Persons,
required to be filed in calendar year 2024.
Additionally, this notice announces that
withholding agents that are foreign per-
sons are administratively exempt from the
requirements to electronically file Forms
1042 required to be filed in calendar year
2025. These administrative exemptions
are intended to promote effective and effi-
cient tax administration.
SECTION 2. BACKGROUND
Section
1
1.1461-1(b) requires a with-
holding agent to file a withholding tax
return on Form 1042 for income paid
during the preceding calendar year that
the withholding agent is required to report
on Form 1042-S, Foreign Person’s U.S.
Source Income Subject to Withholding. A
withholding agent must file Form 1042 on
or before March 15 of the calendar year
following the year in which the income
was paid. See §1.1474-1(c) for a with-
holding agent’s obligation to report chap-
ter 4 reportable amounts on Form 1042.
Section 6011(e)(1) provides that the
Secretary of the Treasury or her dele-
gate (Secretary) shall prescribe regula-
tions providing standards for determining
which returns must be filed on magnetic
media (which includes electronic filing).
Section 6011(e)(2) provides that in pre-
scribing regulations, the Secretary shall
not require any person to file returns on
magnetic media unless such person is
required to file at least the applicable num-
ber of returns during the calendar year.
Before calendar year 2021, the applicable
number of returns for most filers was 250.
On July 1, 2019, the President signed into
law the Taxpayer First Act (TFA), Public
Law 116-25, 133 Stat. 981 (2019). Section
2301 of the TFA amended section 6011(e)
by adding to it a new paragraph 5, which
authorizes the issuance of regulations that
decrease, in accordance with the TFA, the
threshold number of returns a taxpayer is
required to file during a year at, or above,
which the taxpayer is required to file elec-
tronically. Under the TFA, for calendar
1
Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code, the Income Tax Regulations (26 CFR part 1), or the Procedure and Administration
Regulations (26 CFR part 301).
Bulletin No. 2024–12 713 March 18, 2024

March 18, 2024 714 Bulletin No. 2024–12
years after 2021, the applicable number of
returns is 10.
On February 23, 2023, the Department
of the Treasury (Treasury Department)
and the Internal Revenue Service (IRS)
published final regulations in the Federal
Register (TD 9972, 88 FR 11754) (final
regulations) on electronic-filing rules for
certain returns and other documents that
implemented the amendments to section
6011(e) made by the TFA. The final reg-
ulations include a provision for the elec-
tronic-filing of Forms 1042 that amended
§1.1461-1 and added §301.6011-15,
which require a withholding agent, except
an individual, estate, or trust, to electron-
ically file Form 1042 if the withholding
agent is required to file 10 or more returns
of any type during the same calendar year
in which Form 1042 is required to be filed.
Section 301.6011-15 also requires a with-
holding agent that is a partnership with
more than 100 partners to file Form 1042
electronically regardless of the number of
returns the partnership is required to file
during the calendar year. Additionally,
the final regulations amended §§1.1474-1
and 301.1474-1 to require a withholding
agent that is a financial institution to file
Form 1042 electronically without regard
to the number of returns it is required to
file during the calendar year.
The final regulations also authorize
the Commissioner of Internal Revenue
(Commissioner) to provide exemptions
from the electronic-filing requirements to
promote effective and efficient tax admin-
istration. See §§301.1474-1(b)(2) and
301.6011-15(b)(2). The final regulations
provide that the electronic-filing require-
ments apply to Forms 1042 required to be
filed for taxable years ending on or after
December 31, 2023. Accordingly, the final
regulations require withholding agents to
apply these requirements beginning with
Forms 1042 due on or after March 15,
2024.
Since the publication of the final reg-
ulations, the IRS has received feedback
from withholding agents noting chal-
lenges in transitioning to the procedures
necessary for filing Forms 1042 electron-
ically. Among the concerns expressed
are the limited number of Approved IRS
Modernized e-File Business Providers
for Form 1042, coupled with difficulties
accessing the schema and business rules
for filing Form 1042 electronically. For
withholding agents that do not rely on
Modernized e-File Business Providers
for their electronic-filing requirements,
the feedback notes that additional time
is needed to upgrade their systems for
filing Forms 1042 on the IRS’s Modern-
ized e-File platform. Withholding agents
requested a deferral of the Form 1042
electronic-filing requirements in light of
these concerns. Additionally, withholding
agents noted challenges specific to foreign
persons filing Forms 1042 with respect to
implementing the authentication require-
ments necessary for accessing the IRS’s
Modernized e-File platform.
SECTION 3. ADMINISTRATIVE
EXEMPTION FROM
REQUIREMENTS TO FILE
CERTAIN FORMS 1042
ELECTRONICALLY
.01 Administrative Exemption from
Requirement for Withholding Agents to
File Forms 1042 Electronically During
Calendar Year 2024
As described in section 2 of this notice,
pursuant to certain provisions in the rel-
evant Treasury regulations, the Com-
missioner may provide an exemption
from the requirement to electronically
file Form 1042 in the interest of effec-
tive and efficient tax administration. As a
result, withholding agents (both U.S. and
foreign persons) are not required to file
Forms 1042 electronically during calen-
dar year 2024. Specifically, pursuant to
§§1.1461-1(i) and 301.6011-15(b)(2), a
withholding agent required to file Form
1042 that is not a financial institution and
is required to file at least 10 returns (as
determined under §301.6011-15(d)(5))
in 2024 is administratively exempt from
the requirement to electronically file Form
1042 during calendar year 2024. Addi-
tionally, pursuant to §§1.1461-1(i) and
301.6011-15(b)(2), a partnership required
to file Form 1042 that has more than 100
partners is administratively exempt from
the requirement to electronically file Form
1042 during calendar year 2024. Finally,
pursuant to §§1.1474-1(e) and 301.1474-
1(b)(2), a financial institution required to
file Form 1042 is administratively exempt
from the requirement to file Form 1042
electronically during calendar year 2024.
A Form 1042 timely submitted on paper
in calendar year 2024 will not be a failure
to file Form 1042, and, therefore, no addi-
tion to tax under section 6651(a)(1) will
apply with respect to an otherwise valid
Form 1042 timely submitted on paper in
calendar year 2024 (with no electronic-fil-
ing waiver request required).
.02 Additional Administrative Exemp-
tion from Requirement for Foreign With-
holding Agents to File Forms 1042 Elec-
tronically During Calendar Year 2025
As described in section 2 of this notice,
pursuant to certain provisions in rele-
vant Treasury regulations, the Commis-
sioner may provide an exemption from
the requirement to electronically file
Form 1042 in the interest of effective and
efficient tax administration. As a result,
withholding agents that are foreign per-
sons are not required to file Forms 1042
electronically during calendar year 2025.
Specifically, pursuant to §§1.1461-1(i)
and 301.6011-15(b)(2), a foreign person
required to file Form 1042 that is not a
financial institution and is required to file
at least 10 returns (as determined under
§301.6011-15(d)(5)) in 2025 is admin-
istratively exempt from the requirement
to electronically file Form 1042 during
calendar year 2025. Additionally, pursu-
ant to §§1.1461-1(i) and 301.6011-15(b)
(2), a foreign partnership required to file
Form 1042 that has more than 100 part-
ners is administratively exempt from the
requirement to electronically file Form
1042 during calendar year 2025. Finally,
pursuant to §§1.1474-1(e) and 301.1474-
1(b)(2), a foreign financial institution
required to file Form 1042 is adminis-
tratively exempt from the requirement
to electronically file Form 1042 during
calendar year 2025. A Form 1042 timely
submitted on paper by a foreign person in
calendar year 2025 will not be a failure to
file Form 1042, and, therefore, no addition
to tax under section 6651(a)(1) will apply
with respect to an otherwise valid Form
1042 timely submitted on paper by a for-
eign person in calendar year 2025 (with no
electronic-filing waiver request required).
SECTION 4. DRAFTING
INFORMATION
The principal author of this notice is W.
Shawver Adams of the Office of Associate

Bulletin No. 2024–12 715 March 18, 2024
Chief Counsel (International). For further
information regarding this notice con-
tact W. Shawver Adams at (202) 317-5132
(not a toll-free number).
Request for Comments
on Situations in Which a
Section 6417(a) Election
Could Be Made for Credits
Purchased in Transfers
Under Section 6418(a)
Notice 2024-27
SECTION I. PURPOSE
This notice requests additional com-
ments on any situations in which an elec-
tion under § 6417(a) of the Internal Rev-
enue Code (Code)
1
could be made for a
credit that was purchased in a transfer
for which an election under § 6418(a) is
made. Such sequence of events is referred
to as “chaining” in this notice. Comments
regarding chaining will inform the ongo-
ing review by the Department of the Trea-
sury (Treasury Department) and the Inter-
nal Revenue Service (IRS) of the tax credit
transfer market for eligible credits under §
6418(f)(1) and any potential future rules
that would be consistent with the statutory
framework, as well as the legislative pur-
poses, of §§ 6417 and 6418.
SECTION II. BACKGROUND
Sections 6417 and 6418 of the Code
were enacted by § 13801 of Public Law
117-169, 136 Stat. 2003 (August 16,
2022), commonly known as the Inflation
Reduction Act of 2022 (IRA), to provide
two novel credit monetization mecha-
nisms. Generally, § 6417 allows appli-
cable entities to elect to treat the amount
of applicable credits defined in § 6417(b)
for a taxable year as a payment of such an
amount of Federal income tax made by the
applicable entity to the IRS rather than a
credit against their Federal income tax lia-
bilities. Generally, § 6418 permits eligible
taxpayers defined in § 6418(f)(2) (trans-
feror taxpayers) to elect to transfer the use
of eligible credits defined in § 6418(f)(1)
(transferred credits) to unrelated taxpayers
in exchange for cash.
On October 24, 2022, the Treasury
Department and the IRS published Notice
2022-50, 2022-43 I.R.B. 325 to, among
other things, request general comments on
questions arising under new §§ 6417 and
6418, and to inform development of future
guidance implementing §§ 6417 and 6418.
In response to Notice 2022-50, multiple
stakeholders asked that regulations clarify
whether chaining is permissible.
On June 21, 2023, the Treasury Depart-
ment and the IRS published two sets of
proposed regulations, as well as tempo-
rary regulations, in the Federal Regis-
ter. The first set of proposed regulations
(REG-101607-23; 88 FR 40528) provided
guidance on § 6417 (§ 6417 Proposed
Regulations). The second set of proposed
regulations (REG-101610-23; 88 FR
40496) provided guidance on § 6418 (§
6418 Proposed Regulations). The tempo-
rary regulations (TD 9975; 88 FR 40086)
in §§ 1.6417-5T and 1.6418-4T imple-
ment the pre-filing registration process
also described in proposed §§ 1.6417-5
and 1.6418-4.
After noting that multiple stakehold-
ers asked that regulations clarify whether
applicable entities may engage in chain-
ing by making an election under § 6417(a)
for tax credits purchased in the transfer
market, the § 6417 Proposed Regulations
proposed that such chaining would not be
permissible and sought further comment
on the issue. The preamble to the § 6417
Proposed Regulations noted several
potential obstacles to permitting chaining
and requested comments on limited situa-
tions in which exceptions to this proposed
rule may be appropriate because they are
consistent with the text, design, and intent
of the IRA, while also ensuring that such
exceptions are not subject to fraud or
abuse.
On March 5, 2024, final regulations
under § 6417 (TD 9988) were filed for
public inspection (§ 6417 Final Regula-
tions). The § 6417 Final Regulations adopt
the position of the Treasury Department
and the IRS set forth in the § 6417 Pro-
posed Regulations on chaining, express-
ing the view that §§ 6417 and 6418, when
read together, are most straightforwardly
understood as creating two separate,
mutually exclusive regimes regarding
credit monetization. While the Treasury
Department and the IRS acknowledged
in the preamble to the § 6417 Final Reg-
ulations that no specific language in §§
6417 or 6418 directly prohibits chaining,
not permitting chaining allows for more
straightforward application of the statute
as a whole. The Treasury Department and
the IRS also remain concerned about the
administrability of chaining and poten-
tial for fraud and abuse. Thus, the § 6417
Final Regulations do not permit chaining.
SECTION III. REQUEST FOR
COMMENTS
As discussed in section II of this notice,
the § 6417 Final Regulations reflect the
current view of the Treasury Department
and the IRS that chaining is impermissi-
ble under §§ 6417 and 6418. This view is
based, in part, on the text “determined with
respect to” in both statutes, which is more
straightforwardly interpreted as requiring
an applicable entity to own the underlying
applicable credit property and conduct the
activities for which the applicable credit
is “determined with respect to,” or in the
case of the credit that is determined under
§ 45X (§ 45X credit), for which owner-
ship of applicable credit property is not
required, requiring an applicable entity to
be considered the taxpayer with respect to
which the § 45X credit is determined.
The Treasury Department and the IRS
recognize that a robust market for trans-
ferred credits (credit transfer market) that
helps support a broad array of projects and
investment is consistent with Congress’s
intent in enacting the IRA. There are early
indications that a robust market for trans-
ferring credits under § 6418 is forming
under the current rule; however, the market
is relatively nascent, economic conditions
are strong, and allowing chaining could
further increase demand in and access to
that market. The Treasury Department and
the IRS will continue to evaluate whether
1
Unless otherwise specified, all “Section” or “§” references are to sections of the Code and the Income Tax Regulations (26 CFR part 1).

March 18, 2024 716 Bulletin No. 2024–12
potential chaining rules would be consis-
tent with the statutory framework, as well
as the legislative purposes, of §§ 6417
and 6418. At the same time, the Treasury
Department and the IRS will be review-
ing administrability challenges associated
with elective payment elections and trans-
fer elections and will be carefully moni-
toring for fraud and improper payments,
which could undermine the credit transfer
market. To that end, the Treasury Depart-
ment and the IRS request comments that
address the following specific questions:
.01 Impacts on credit transfer mar-
ket. If chaining were ultimately permit-
ted, how would it specifically impact the
credit transfer market? Would demand for
transferred credits significantly increase?
How would the cost of transferred cred-
its be affected? Some commenters have
suggested that chaining would increase
market participation. Commenters are
requested to provide specific examples
of entities that lack access to the current
transfer market and transactions that could
be entered into should chaining be permit-
ted.
.02 “Determined with respect to”
interpretation
(1) How can the language in § 6417(a)
and § 6418(a) regarding a credit being
“determined with respect to” an applica-
ble entity or transferor taxpayer be reason-
ably interpreted to refer to a taxpayer that
does not own the underlying applicable
credit property and conduct the activities
giving rise to the credit or, in the case of a
§ 45X credit (in which case ownership of
applicable credit property is not required),
be considered the taxpayer with respect to
which the § 45X credit is determined?
(2) How should basis reduction and
recapture rules under §§ 6417(g) and
6418(g)(3) work in the case of a chain-
ing rule if credits that are purchased by
an applicable entity must be treated as
“determined with respect to” an applica-
ble entity for that purpose?
.03 Administrability challenges
(1) Under § 1.6418-4T, a transferor tax-
payer will complete pre-filing registration
without identifying a transferee taxpayer.
Under proposed § 1.6418-2, a transferee
taxpayer may file a tax return and claim a
transferred credit on its tax return before
or after a transferor taxpayer files its own
return, so long as the transferee taxpayer
has the pre-filing registration number for
the eligible credit property and a transfer
election statement. Different rules would
be necessary should the Treasury Depart-
ment and the IRS conclude chaining is
allowable. If chaining were permissible,
the Treasury Department and the IRS
would potentially propose that a trans-
feror taxpayer could not obtain a pre-fil-
ing registration number for the eligible
credit property without first identifying
the transferee taxpayer. There may also
be impacts on the time at which a trans-
feree taxpayer can file its tax return for the
“chained” transferred credit, including the
possibility that a transferee taxpayer could
be prohibited from obtaining the trans-
ferred credit until the transferor taxpayer
files its own return. The Treasury Depart-
ment and the IRS seek comments on how
a potential rule requiring identification of
a transferee taxpayer during a transferor
taxpayer’s pre-filing registration process
would impact taxpayers and how the IRS
could administer such a system.
(2) Can the statutory text of §§ 6417
and 6418 be interpreted to allow for chain-
ing for any particular type(s) or group(s)
of taxpayers, or for certain situations? If
so, what type(s) or group(s) of taxpay-
ers and in which scenarios should such
taxpayers be allowed to “chain”? What
clear and objective factors could crite-
ria for determining eligibility be based
on, and how administrable for taxpayers
and the IRS would compliance with such
criteria be? What additional information
and documentation would be needed for
the IRS to identify chaining-eligible and
chaining-ineligible taxpayers through the
pre-filing registration process?
(3) Can the statutory text of §§ 6417
and 6418 be reasonably interpreted to limit
application of both an excessive credit
transfer addition to tax under § 6418(g)
(2) and an excessive payment addition to
tax under § 6417(d)(6) to a taxpayer that is
both an applicable entity under § 6417 and
a transferee taxpayer under § 6418?
(4) In what ways could the IRS limit
the risk for fraudulent elective payment
elections with respect to transferred cred-
its? For example, how could the IRS limit
the risk that an entity would make an elec-
tion under § 6417(a) for a purportedly
transferred credit and receive payment,
and then dissolve?
(5) In the case of a chaining rule, the
IRS would need to conduct additional dil-
igence of applicable entities and electing
taxpayers, as well as transferor taxpayers,
during the pre-filing registration process.
How could such additional diligence
avoid being treated as a determination
or an examination by the IRS, such that
the provisions of § 7605(b) are not impli-
cated?
.04 Other issues
(1) If chaining is permitted generally,
what rules should apply with respect to the
transferred credits for which the election
under § 6417(a) is made for multiple years
(the credits under §§ 45, 45Q, 45V, and
45Y)?
(2) The elective payment election with
regard to the credits under §§ 45, 45Q,
45V, and 45Y must be made in the tax-
able year the facility is placed in service
under § 6417(d)(3)(B), (C), (D), and (E).
In instances in which A (a transferor tax-
payer) and B (a transferee taxpayer) have
differing taxable years, A places a facility
in service before B’s taxable year begins,
and A subsequently transfers an eligible
credit arising from production at the facil-
ity to B, if chaining is permitted generally,
should B be permitted to make a § 6417(a)
election with regard to the transferred
credit?
(3) Section 6418(a) does not permit
transfers between related parties. The
§ 6418 Proposed Regulations would also
provide for anti-abuse rules for situa-
tions in which a transaction is intended to
decrease the transferor taxpayer’s gross
income or increase a transferee taxpayer’s
deductions. See proposed § 1.6418-2(e)
(4). An example of when the anti-abuse
rule may apply is a transaction in which a
transferor taxpayer undercharges for ser-
vices to a customer who is also purchas-
ing credits from the transferor taxpayer as
a transferee taxpayer at an inflated price.
How should this dynamic inform a poten-
tial chaining rule? What safeguards would
be necessary for a chaining rule to prevent
the avoidance of any Federal tax liability
beyond the intent of § 6418?
SECTION IV. SUBMISSION OF
COMMENTS
.01 Deadline. Written comments should
be submitted by December 1, 2024.

Bulletin No. 2024–12 717 March 18, 2024
.02 Form and manner. The subject line
for the comments should include a refer-
ence to
Notice 2024-27. All commenters
are strongly encouraged to submit com-
ments electronically. However, comments
may be submitted in one of two ways:
(a) Electronically via the Federal
eRulemaking Portal at https://www.
regulations.gov/ (type IRS-2024-0008
in the search field on the regulations.gov
homepage to find this notice and submit
comments); or
(b) By mail to: Internal Revenue Ser-
vice, CC:PA:01:PR (Notice 2024-27),
Room 5203, P.O. Box 7604, Ben Franklin
Station, Washington, D.C., 20044.
.03 Publication of comments. The Trea-
sury Department and the IRS will publish
for public availability any comment sub-
mitted electronically and on paper to its
public docket on https://www.regulations.
gov.
SECTION V. DRAFTING
INFORMATION
The principal author of this notice is
the Office of the Associate Chief Coun-
sel (Passthrough and Special Industries).
However, other personnel from the Trea-
sury Department and the IRS participated
in its development. For further informa-
tion regarding this notice, contact Waheed
Olayan at (202) 317-4137 (not a toll-free
number).
26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability. (Also: Part 1, §§ 61, 451, 1001.)
Rev. Proc. 2024-15
SECTION 1. PURPOSE
This revenue procedure sets forth the
manner in which a public utility may treat
certain legislatively authorized transac-
tions entered into by the public utility to
recover specified costs through a non-by-
passable surcharge to customers within the
utility’s historic service area. Specifically,
this revenue procedure addresses a securi-
tization that involves the issuance of debt
instruments by a qualifying State financ-
ing entity, as defined below. This revenue
procedure also modifies Rev. Proc. 2005-
62, 2005-2 C.B. 507, to expand the defini-
tion of “public utility” to include all public
utilities, not just investor-owned utilities,
and to change the definition of a “quali-
fying securitization” to allow payments to
be provided at least annually.
SECTION 2. BACKGROUND
.01 Rev. Proc. 2005-62 provides that
if a public utility company is authorized
by State legislation to enter into a trans-
action to recover certain costs through a
“qualifying securitization” (as defined in
section 5.04 of that revenue procedure),
the public utility will be treated as not
recognizing gross income upon (1) the
receipt of a financing order that creates
an intangible property right in the amount
of the specified costs that may be recov-
ered through securitization; (2) the receipt
of cash or other valuable consideration
in exchange for the transfer of that prop-
erty right to the financing entity that is
wholly owned, directly or indirectly, by
the utility; or (3) the receipt of cash or
other valuable consideration in exchange
for securitized instruments issued by the
financing entity that is wholly owned,
directly or indirectly, by the utility. Rev.
Proc. 2005-62 further provides that the
securitized instruments issued under such
a qualifying securitization will be treated
as obligations of the public utility and the
non-bypassable charges are gross income
to the utility recognized under the utility’s
usual method of accounting.
.02 For purposes of Rev. Proc. 2005-
62, a “qualified securitization” is defined
as an issuance of any bonds, notes, other
evidences of indebtedness, or certificates
of participation or beneficial interest that
(1) is secured by the intangible property
right to collect charges for the recovery
of specified costs and such other assets, if
any, of the financing entity that is wholly
owned, directly or indirectly, by the util-
ity; (2) is issued by a financing entity that
is wholly owned, directly or indirectly, by
the utility that is initially capitalized by
the utility in such a way that equity inter-
ests in the financing entity are at least 0.5
percent of the aggregate principal amount
of the non-equity interests issued; and (3)
provides for payments on a quarterly or
semi-annual basis. Accordingly, the tax
treatment permitted in Rev. Proc. 2005-
62 applies only if the financing entity is
wholly owned, directly or indirectly, by
the utility. For a wholly owned entity that
is disregarded as an entity separate from
the public utility, the activities of the
entity are treated in the same manner as a
sole proprietorship, branch, or division of
the public utility under §§301.7701-2 and
301.7701-3 of the Procedure and Admin-
istration Regulations.
.03 Some States have enacted legis-
lation to allow a public utility to engage
in transactions similar to those described
in Rev. Proc. 2005-62. However, in these
transactions, a qualifying State financ-
ing entity serves as a financing vehicle
to securitize the rights of the public util-
ity created by the financing order. The
treatment provided in Rev. Proc. 2005-62
would not apply to such a securitization
transaction because the qualifying State
financing entity is not wholly owned,
directly or indirectly, by the public utility,
but instead is a separate entity unrelated to
the public utility.
SECTION 3. SCOPE
Section 5 of this revenue procedure
applies to public utilities that, pursuant
to qualifying securitization financing leg-
islation, receive an irrevocable financing
order from an appropriate State agency
that determines the amount of certain
specified costs the utility will be permitted
to recover through a qualifying State secu-
ritization of an intangible property right
created by the special legislation. Section
6 of this revenue procedure modifies the
definitions of public utility and qualifying
securitization in Rev. Proc. 2005-62.
SECTION 4. DEFINITIONS
.01 PUBLIC UTILITY
For purposes of this revenue proce-
dure, the terms “public utility” or “utility”
refer to any utility company (electric or
non-electric) that is
subject to the regu-
latory authority of a State public utility
commission or other appropriate State
agency.
.02 QUALIFYING STATE FINANC-
ING ENTITY
For purposes of this revenue proce-
dure, the term “qualifying State financing
entity” means an entity that is designated

March 18, 2024 718 Bulletin No. 2024–12
pursuant to a qualifying securitization
financing legislation as a financing entity
and that is a State, political subdivision
thereof, or other organization authorized
to issue debt on behalf of a State or politi-
cal subdivision thereof.
.03 QUALIFYING SECURITIZA-
TION FINANCING LEGISLATION
For purposes of this revenue proce-
dure, the term “qualifying securitization
financing legislation” means legislation
that--
(1) Is enacted by a State to facilitate
the recovery of certain specified costs
incurred by a public utility;
(2) Authorizes the public utility to
apply for, and authorizes the public util-
ity commission or other appropriate State
agency to issue, a financing order deter-
mining the amount of specified costs the
public utility will be allowed to recover;
(3) Provides that pursuant to the financ-
ing order, the public utility acquires an
intangible property right to charge, collect,
and receive amounts necessary to provide
for the full recovery of the specified costs
determined to be recoverable, and assures
that the charges are non-bypassable and
will be paid by customers within the pub-
lic utility’s historic service territory who
receive utility goods or services through
the public utility’s transmission and dis-
tribution system, even if those customers
elect to purchase these goods or services
from a third party;
(4) Guarantees that neither the State
nor any of its agencies has the authority
to rescind or amend the financing order,
to revise the amount of specified costs, or
in any way to reduce or impair the value
of the intangible property right, except as
may be contemplated by periodic adjust-
ments authorized by such legislation;
(5) Provides procedures assuring that
the sale, assignment, or other transfer
of the intangible property right from the
public utility to a qualifying State financ-
ing entity will be perfected under State
law as an absolute transfer of the public
utility’s right, title, and interest in the
property; and
(6) Authorizes the securitization of the
intangible property right to recover the
fixed amount of specified costs through
the issuance of debt instruments by a qual-
ifying State financing entity pursuant to an
indenture, contract, or other agreement.
.04 SPECIFIED COSTS
For purposes of this revenue proce-
dure, the term “specified costs” means
those costs identified by the State legis-
lature as appropriate for recovery through
the securitization mechanism of the qual-
ifying securitization financing legislation.
.05 QUALIFYING STATE SECURI-
TIZATION
For purposes of this revenue procedure,
the term “qualifying State securitization”
means an issuance of debt instruments
that--
(1) Is secured by the intangible prop-
erty right to collect charges for the recov-
ery of specified costs and such other
assets, if any, of a public utility;
(2) Is issued by a qualifying State
financing entity; and
(3) Provides for payments on at least an
annual basis.
SECTION 5. APPLICATION
.01 The public utility will be treated as
not recognizing gross income upon--
(1) The receipt of a financing order that
creates an intangible property right in the
amount of the specified costs that may be
recovered through securitization;
(2) The receipt of cash or other valuable
consideration in exchange for the transfer
of that property right to a qualifying State
financing entity;
(3) The receipt by the qualifying State
financing entity of cash or other valuable
consideration in exchange for the debt issued
by the qualifying State financing entity; or
(4) The receipt by the public utility
of the proceeds of the debt issued by the
qualifying State financing entity.
.02 The payments of the public utility to
the qualifying State financing entity pur-
suant to the securitized debt instruments
described in section 4.05 of this revenue
procedure will be treated as payments on
obligations of the public utility.
.03 The non-bypassable charges will be
treated as gross income of the public util-
ity recognized under the public utility’s
usual method of accounting.
SECTION 6. MODIFICATIONS TO
REV. PROC. 2005-62
.01 Modification to the definition of
public utility. Section 5.01 of Rev. Proc.
2005-62 is modified to read as follows:
.01 PUBLIC UTILITY
For purposes of this revenue procedure,
the terms “public utility” or “utility”
refer to any utility company (electric or
non-electric) that is subject to the regu-
latory authority of a State public utility
commission or other appropriate State
agency.
.02 Modification to the definition of
qualifying securitization. Section 5.04(3)
of Rev. Proc. 2005-62 is modified to read
as follows:
(3) Provides for payments on at least an
annual basis.
SECTION 7. EFFECT ON OTHER
DOCUMENTS
This document modifies Rev. Proc.
2005-62.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective on
or after February 29, 2024. Taxpayers may
apply this revenue procedure to securiti-
zations issued before February 29, 2024.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Brian Choi of the Office of
the Associate Chief Counsel (Financial
Institutions and Products). For further
information regarding this revenue pro-
cedure, contact Mr. Choi at 202-317-3154
(not a toll-free number).

Bulletin No. 2024–12 719 March 18, 2024
Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2024-14
Table of Contents
The Internal Revenue Service has
revoked its determination that the organi-
zations listed below qualify as organiza-
tions 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 pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section 170(c)
(2) if the organization has not timely filed
a suit for declaratory judgment under sec-
tion 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 declar-
atory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will con-
tinue to be deductible. Protection under
section 7428(c) would begin on March
18, 2024 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 hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
Name Of OrganizationEffective Date of RevocationLocation
Uplifting Her Inc.1/1/2020Highlands, CA and Fresno, CA

Bulletin No. 2024–12 i March 18, 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.

March 18, 2024 ii Bulletin No. 2024–12
Numerical Finding List
1
Bulletin 2024–12
Announcements:
2024-1, 2024-02 I.R.B. 363
2024-3, 2024-02 I.R.B. 364
2024-5, 2024-05 I.R.B. 635
2024-6, 2024-05 I.R.B. 635
2024-4, 2024-06 I.R.B. 665
2024-7, 2024-07 I.R.B. 673
2024-8, 2024-07 I.R.B. 674
2024-9, 2024-07 I.R.B. 675
2024-12, 2024-08 I.R.B. 676
2024-11, 2024-08 I.R.B. 683
2024-13, 2024-10 I.R.B. 710
2024-10, 2024-11 I.R.B. 711
2024-14, 2024-12 I.R.B. 719
Notices:
2024-1, 2024-02 I.R.B. 314
2024-2, 2024-02 I.R.B. 316
2024-3, 2024-02 I.R.B. 338
2024-4, 2024-02 I.R.B. 343
2024-5, 2024-02 I.R.B. 347
2024-6, 2024-02 I.R.B. 348
2024-7, 2024-02 I.R.B. 355
2024-8, 2024-02 I.R.B. 356
2024-9, 2024-02 I.R.B. 358
2024-11, 2024-02 I.R.B. 360
2024-10, 2024-03 I.R.B. 406
2024-12, 2024-05 I.R.B. 616
2024-13, 2024-05 I.R.B. 618
2024-16, 2024-05 I.R.B. 622
2024-18, 2024-05 I.R.B. 625
2024-19, 2024-05 I.R.B. 627
2024-21, 2024-06 I.R.B. 659
2024-22, 2024-06 I.R.B. 662
2024-20, 2024-07 I.R.B. 668
2024-23, 2024-07 I.R.B. 672
2024-24, 2024-10 I.R.B. 707
2024-25, 2024-12 I.R.B. 712
2024-26, 2024-12 I.R.B. 713
2024-27, 2024-12 I.R.B. 715
Proposed Regulations:
REG-118492-23, 2024-02 I.R.B. 366
REG-107423-23, 2024-03 I.R.B. 411
REG-121010-17, 2024-05 I.R.B. 636
Revenue Procedures:
2024-1, 2024-01 I.R.B. 1
2024-2, 2024-01 I.R.B. 119
2024-3, 2024-01 I.R.B. 143
2024-4, 2024-01 I.R.B. 160
Revenue Procedures:—Continued
2024-5, 2024-01 I.R.B. 262
2024-7, 2024-01 I.R.B. 303
2024-8, 2024-04 I.R.B. 479
2024-9, 2024-05 I.R.B. 628
2024-12, 2024-09 I.R.B. 677
2024-13, 2024-09 I.R.B. 678
2024-14, 2024-09 I.R.B. 682
2024-15, 2024-12 I.R.B. 717
Revenue Rulings:
2024-1, 2024-02 I.R.B. 307
2024-2, 2024-02 I.R.B. 311
2024-3, 2024-06 I.R.B. 646
2024-5, 2024-07 I.R.B. 666
2024-4, 2024-10 I.R.B. 686
2024-6, 2024-10 I.R.B. 688
Treasury Decisions:
9984, 2024-03 I.R.B. 386
9985, 2024-05 I.R.B. 573
9986, 2024-05 I.R.B. 610
9987, 2024-06 I.R.B. 648
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 26, 2023.

Bulletin No. 2024–12 iii March 18, 2024
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2024–12
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 26, 2023.

Internal Revenue Service
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