Internal Revenue Bulletin 2024-36 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2024–36
September 3, 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, EMPLOYMENT
TAX, INCOME TAX, SPECIAL
ANNOUNCEMENT
Announcement 2024-30, page 581.
This announcement announces a second Voluntary Disclosure
Program for taxpayers to resolve refunds or credits for erro-
neous Employee Retention Credit claims. The announcement
explains taxpayer eligibility criteria, terms, and procedures
for taxpayers electing to participate in the second Voluntary
Disclosure Program. The announcement is intended to pro-
vide taxpayers an opportunity to efficiently resolve their civil
tax liabilities under this second Voluntary Disclosure Program
and avoid potential litigation.
EMPLOYEE PLANS
Notice 2024-62, page 570.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for July
2024 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for August 2024, and the 30-year Trea-
sury rates, as reflected by the application of § 430(h)(2)(C)(iv).
Notice 2024-63, page 573.
This notice provides guidance in the form of questions
and answers on section 110 of the SECURE 2.0 Act of
2022. Section 110 allows employers to make matching
contributions on account of employees’ qualified student
loan payments (QSLPs) under certain defined contribution
retirement plans. The notice also states that the Treasury
Department and the IRS anticipate issuing proposed reg-
ulations with respect to section 110 and requests com-
ments.
INCOME TAX
Rev. Rul. 2024-17, page 568.
Federal rates; adjusted federal rates; adjusted federal long-
term rate, and the long-term tax exempt rate. For purposes
of sections 382, 1274, 1288, 7872 and other sections of
the Code, tables set forth the rates for September 2024..
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing 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.
September 3, 2024 Bulletin No. 2024–36

Part I
Section 1274.—
Determination of Issue
Price in the Case of Certain
Debt Instruments Issued for
Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
1288, 7520, 7872.)
Rev. Rul. 2024-17
This revenue ruling provides vari-
ous prescribed rates for federal income
tax purposes for September 2024 (the
current month). Table 1 contains the
short-term, mid-term, and long-term
applicable federal rates (AFR) for the
current month for purposes of section
1274(d) of the Internal Revenue Code.
Table 2 contains the short-term, mid-
term, and long-term adjusted applica-
ble federal rates (adjusted AFR) for the
current month for purposes of section
1288(b). Table 3 sets forth the adjusted
federal long-term rate and the long-
term tax-exempt rate described in sec-
tion 382(f). Table 4 contains the appro-
priate percentages for determining the
low-income housing credit described in
section 42(b)(1) for buildings placed in
service during the current month. How-
ever, under section 42(b)(2), the appli-
cable percentage for non-federally sub-
sidized new buildings placed in service
after July 30, 2008, shall not be less
than 9%. Finally, Table 5 contains the
federal rate for determining the present
value of an annuity, an interest for life
or for a term of years, or a remainder or
a reversionary interest for purposes of
section 7520.
REV. RUL. 2024-17 TABLE 1
Applicable Federal Rates (AFR) for September 2024
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR4.57%4.52%4.49%4.48%
110% AFR5.03%4.97%4.94%4.92%
120% AFR5.49%5.42%5.38%5.36%
130% AFR5.97%5.88%5.84%5.81%
Mid-term
AFR4.02%3.98%3.96%3.95%
110% AFR 4.43%4.38%4.36%4.34%
120% AFR4.84%4.78%4.75%4.73%
130% AFR5.24%5.17%5.14%5.12%
150% AFR6.06%5.97%5.93%5.90%
175% AFR7.09%6.97%6.91%6.87%
Long-term
AFR4.37%4.32%4.30%4.28%
110% AFR4.81%4.75%4.72%4.70%
120% AFR5.25%5.18%5.15%5.12%
130% AFR5.70%5.62%5.58%5.56%
REV. RUL. 2024-17 TABLE 2
Adjusted AFR for September 2024
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR3.46%3.43%3.42%3.41%
Mid-term adjusted AFR3.04%3.02%3.01%3.00%
Long-term adjusted AFR3.31%3.28%3.27%3.26%
September 3, 2024 568 Bulletin No. 2024–36

REV. RUL. 2024-17 TABLE 3
Rates Under Section 382 for September 2024
Adjusted federal long-term rate for the current month3.31%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal
long-term rates for the current month and the prior two months.)
3.49%
REV. RUL. 2024-17 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for September 2024
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after
July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.97%
Appropriate percentage for the 30% present value low-income housing credit 3.42%
REV. RUL. 2024-17 TABLE 5
Rate Under Section 7520 for September 2024
Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,
or a remainder or reversionary interest
4.8%

Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.
Section 280G.—Golden
Parachute Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.
Section 382.—Limitation
on Net Operating Loss
Carryforwards and
Certain Built-In Losses
Following Ownership
Change
The adjusted applicable federal long-term rate
is set forth for the month of September 2024. See
Rev. Rul. 2024-17, page 568.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.
Section 468.—Special
Rules for Mining and Solid
Waste Reclamation and
Closing Costs
The applicable federal short-term rates are set
forth for the month of September 2024. See Rev.
Rul. 2024-17, page 568.
Section 482.—Allocation
of Income and Deductions
Among Taxpayers
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of September 2024. See Rev. Rul. 2024-17, page 568.
Section 7520.—Valuation
Tables
The applicable federal mid-term rates are set
forth for the month of September 2024. See Rev.
Rul. 2024-17, page 568.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term,
and long-term rates are set forth for the month of
September 2024. See Rev. Rul. 2024-17, page 568.

Bulletin No. 2024–36 569 September 3, 2024

September 3, 2024 570 Bulletin No. 2024–36
Part III
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2024-62
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used
under § 417(e)(3), and the 24-month aver-
age segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the inter-
est rate on 30-year Treasury securities
under § 417(e)(3)(A)(ii)(II) as in effect for
plan years beginning before 2008 and the
30-year Treasury weighted average rate
under § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Section 430 specifies the minimum
funding requirements that apply to sin-
gle-employer plans (except for CSEC plans
under § 414(y)) pursuant to § 412. Section
430(h)(2) specifies the interest rates that
must be used to determine a plan’s target
normal cost and funding target. Under
this provision, present value is generally
determined using three 24-month average
interest rates (“segment rates”), each of
which applies to cash flows during speci-
fied periods. To the extent provided under
§ 430(h)(2)(C)(iv), these segment rates
are adjusted by the applicable percentage
of the 25-year average segment rates for
the period ending September 30 of the
year preceding the calendar year in which
the plan year begins.
1
However, an elec-
tion may be made under § 430(h)(2)(D)
(ii) to use the monthly yield curve in place
of the segment rates.
Section 1.430(h)(2)-1(d) provides
rules for determining the monthly cor-
porate bond yield curve,
2
and § 1.430(h)
(2)-1(c) provides rules for determining
the 24-month average corporate bond
segment rates used to compute the target
normal cost and the funding target. Con-
sistent with the methodology specified in
§ 1.430(h)(2)-1(d), the monthly corporate
bond yield curve derived from July 2024
data is in Table 2024-7 at the end of this
notice. The spot first, second, and third
segment rates for the month of July 2024
are, respectively, 4.92, 5.25, and 5.59.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)
through (iii) must be adjusted pursuant to §
430(h)(2)(C)(iv) to be within the applica-
ble minimum and maximum percentages
of the corresponding 25-year average seg-
ment rates. For this purpose, any 25-year
average segment rate that is less than 5%
is deemed to be 5%. The 25-year average
segment rates for plan years beginning in
2023 and 2024 were published in Notice
2022-40, 2022-40 I.R.B. 266 and Notice
2023-66, 2023-40 I.R.B. 992, respec-
tively. The applicable minimum and max-
imum percentages are 95% and 105% for
plan years beginning in 2023 and 2024.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for August
2024 without adjustment for the 25-year
average segment rate limits are as follows:
24-Month Average Segment Rates Without 25-Year Average Adjustment
Applicable Month First Segment Second Segment Third Segment
August 2024 5.04 5.32 5.33
The adjusted 24-month average seg-
ment rates set forth in the chart below
reflect § 430(h)(2)(C)(iv) of the Code. The
24-month averages applicable for August
2024, adjusted to be within the applicable
minimum and maximum percentages of
the corresponding 25-year average seg-
ment rates in accordance with § 430(h)(2)
(C)(iv) of the Code, are as follows:
Adjusted 24-Month Average Segment Rates
For Plan Years
Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment
2023August 20245.045.325.74
2024August 20245.045.325.59
30-YEAR TREASURY SECURITIES
INTEREST RATES
Section 431 specifies the minimum
funding requirements that apply to multi-
employer plans pursuant to § 412. Section
431(c)(6)(B) specifies a minimum amount
for the full-funding limitation described in
§ 431(c)(6)(A), based on the plan’s current
liability. Section 431(c)(6)(E)(ii)(I) pro-
vides that the interest rate used to calculate
current liability for this purpose must be
no more than 5 percent above and no more
than 10 percent below the weighted aver-
age of the rates of interest on 30-year Trea-
1
Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
2
For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts
the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market.
Those enhancements are described in the preamble to TD 9986 (89 FR 2127).

Bulletin No. 2024–36 571 September 3, 2024
sury securities during the four-year period
ending on the last day before the beginning
of the plan year. Notice 88-73, 1988-2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The rate
of interest on 30-year Treasury securities
for July 2024 is 4.46 percent. The Service
determined this rate as the average of the
daily determinations of yield on the 30-year
Treasury bond maturing in May 2054. For
plan years beginning in August 2024, the
weighted average of the rates of interest on
30-year Treasury securities and the permis-
sible range of rates used to calculate current
liability are as follows:
Treasury Weighted Average Rates
For Plan Years Beginning In30-Year Treasury Weighted AveragePermissible Range 90% to 105%
August 20243.583.22 to 3.76
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Section 1.417(e)-1(d)(3) and
Notice 2007-81 provide guidelines for
determining the minimum present value
segment rates. Pursuant to those guidelines,
the minimum present value segment rates
determined for July 2024 are as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
July 2024 4.92 5.25 5.59
DRAFTING INFORMATION
The principal author of this notice
is Tom Morgan of the Office of Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes). However, other personnel from
the IRS participated in the development
of this guidance. For further information
regarding this notice, contact Mr. Morgan
at 202-317-6700 or Tony Montanaro at
626-927-1475 (not toll-free numbers).

September 3, 2024 572 Bulletin No. 2024–36
Table 2024-7
Monthly Yield Curve for July 2024
Derived from July 2024 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.55.3920.55.5440.55.6060.55.6580.55.67
1.05.2121.05.5441.05.6061.05.6581.05.67
1.55.0521.55.5541.55.6061.55.6581.55.67
2.04.9322.05.5542.05.6062.05.6582.05.67
2.54.8422.55.5542.55.6062.55.6582.55.67
3.04.7823.05.5543.05.6163.05.6583.05.67
3.54.7523.55.5543.55.6163.55.6583.55.67
4.04.7424.05.5544.05.6164.05.6584.05.67
4.54.7424.55.5544.55.6164.55.6584.55.67
5.04.7525.05.5445.05.6165.05.6585.05.67
5.54.7825.55.5445.55.6165.55.6585.55.68
6.04.8126.05.5446.05.6166.05.6586.05.68
6.54.8526.55.5446.55.6266.55.6586.55.68
7.04.8927.05.5447.05.6267.05.6687.05.68
7.54.9327.55.5447.55.6267.55.6687.55.68
8.04.9728.05.5448.05.6268.05.6688.05.68
8.55.0228.55.5448.55.6268.55.6688.55.68
9.05.0629.05.5449.05.6269.05.6689.05.68
9.55.1029.55.5449.55.6269.55.6689.55.68
10.05.1430.05.5550.05.6370.05.6690.05.68
10.55.1730.55.5550.55.6370.55.6690.55.68
11.05.2131.05.5551.05.6371.05.6691.05.68
11.55.2431.55.5551.55.6371.55.6691.55.68
12.05.2732.05.5652.05.6372.05.6692.05.68
12.55.3032.55.5652.55.6372.55.6692.55.68
13.05.3333.05.5653.05.6373.05.6693.05.68
13.55.3633.55.5753.55.6373.55.6693.55.68
14.05.3834.05.5754.05.6374.05.6694.05.68
14.55.4034.55.5754.55.6474.55.6694.55.68
15.05.4235.05.5755.05.6475.05.6795.05.68
15.55.4435.55.5855.55.6475.55.6795.55.68
16.05.4536.05.5856.05.6476.05.6796.05.68
16.55.4736.55.5856.55.6476.55.6796.55.68
17.05.4837.05.5857.05.6477.05.6797.05.68
17.55.4937.55.5957.55.6477.55.6797.55.68
18.05.5138.05.5958.05.6478.05.6798.05.68
18.55.5138.55.5958.55.6478.55.6798.55.68
19.05.5239.05.5959.05.6479.05.6799.05.68
19.55.5339.55.5959.55.6479.55.6799.55.68
20.05.5440.05.6060.05.6580.05.67100.05.69

Bulletin No. 2024–36 573 September 3, 2024
Guidance Under Section
110 of the SECURE 2.0 Act
with Respect to Matching
Contributions Made on
Account of Qualified
Student Loan Payments
Notice 2024-63
I. PURPOSE
This notice provides guidance in
the form of questions and answers with
respect to section 110 of Division T of the
Consolidated Appropriations Act, 2023,
Pub. L. 117-328, 136 Stat. 4459 (2022),
known as the SECURE 2.0 Act of 2022
(SECURE 2.0 Act). Section 110 of the
SECURE 2.0 Act allows employers to
make matching contributions on account
of employees’ qualified student loan
payments (QSLPs) under section 401(k)
plans, section 403(b) plans, SIMPLE IRA
plans, and governmental section 457(b)
plans (QSLP matches). Section 110 of
the SECURE 2.0 Act applies to contribu-
tions made for plan years beginning after
December 31, 2023.
This notice provides guidance on
discrete issues under section 110 of the
SECURE 2.0 Act to assist plan sponsors
in implementing QSLP match programs.
The Department of the Treasury (Treasury
Department) and the Internal Revenue
Service (IRS) anticipate issuing proposed
regulations with respect to section 110 of
the SECURE 2.0 Act, and, accordingly,
invite comments on this notice and any
other aspect of section 110.
II. BACKGROUND
Section 221(d)(1) of the Internal Rev-
enue Code (the Code) defines a quali-
fied education loan as any indebtedness
incurred by a taxpayer solely to pay qual-
ified higher education expenses, subject
to the conditions of section 221(d)(1)
(A)-(C), which provide that the qualified
higher education expenses must be (i)
incurred on behalf of the taxpayer, the
taxpayer’s spouse, or any dependent of the
taxpayer as of the time the indebtedness
was incurred, (ii) paid or incurred within
a reasonable period of time before or after
the indebtedness is incurred, and (iii)
attributable to education furnished during
a period during which the recipient was an
eligible student.
Section 401(a) sets forth requirements
for a trust that forms part of a qualified
retirement plan to constitute a qualified
trust.
Section 401(k)(3) sets forth participa-
tion and nondiscrimination standards for
qualified cash or deferred arrangements
(CODAs). Section 401(k)(3)(A)(ii) pro-
vides that in order to be a qualified CODA
for a plan year, the actual deferral percent-
age (ADP) of eligible highly compensated
employees (HCEs) under the CODA may
not exceed by more than specified mar-
gins the ADP of eligible nonhighly com-
pensated employees (NHCEs) under the
CODA for the plan year.
Section 401(m) sets forth nondis-
crimination requirements with respect
to matching contributions to a defined
contribution plan. Section 401(m)(1)
provides that a defined contribution
plan is treated as meeting the require-
ments of section 401(a)(4) with respect
to the amount of any matching contribu-
tion or employee contribution for a plan
year only if the plan passes the actual con-
tribution percentage requirement of sec-
tion 401(m)(2) (the ACP test).
Section 403(b) sets forth require-
ments applicable to contributions to a
section 403(b) plan made for employees
who are performing services for a public
school of a State or a local government
or for employees of employers that are
tax-exempt organizations under section
501(c)(3). Section 403(b)(12)(A)(i) pro-
vides that the requirements of section
401(m) apply to matching contributions
made to a section 403(b) plan in the same
manner as if the plan were a qualified
retirement plan.
Section 408(p) sets forth requirements
for making employee salary reduction
contributions and nonelective employer
and matching contributions to an employ-
ee’s SIMPLE IRA pursuant to a SIMPLE
IRA plan.
Section 410(b) sets forth minimum
coverage requirements for a plan to consti-
tute a qualified trust under section 401(a).
Section 457(b) sets forth requirements
for a plan to constitute an eligible deferred
compensation plan. Section 457(b) pro-
vides that an eligible deferred compensa-
tion plan is a plan established and main-
tained by an eligible employer that covers
only individuals who perform service for
the employer, and that meets the deferral
limitations described in section 457(b)
(2). Section 457(e)(1)(A) provides that
an eligible employer is a State, a political
subdivision of a State, and any agency or
instrumentality of a State or political sub-
division of a State.
Section 4979 provides for an excise
tax on excess contributions and excess
aggregate contributions (excess contri-
butions result from a plan failing the
ADP test, and excess aggregate contri-
butions result from a plan failing the
ACP test). Section 4979(f)(1) provides
for an exception to the tax to the extent
excess contributions or excess aggregate
contributions are corrected before the
close of the first 2½ months of the fol-
lowing plan year. This correction period
is extended to the close of the first six
months of the following plan year in the
case of an eligible automatic contribu-
tion arrangement, as defined in section
414(w)(3) (EACA).
Section 1.401(m)-1(b)(4) sets forth
the exclusive rules for aggregating and
disaggregating defined contribution
plans that provide for employee con-
tributions and matching contributions.
Under § 1.401(m)-1(b)(4)(iii), a plan
is defined as a plan within the meaning
of § 1.410(b)-7(a) and (b), after applica-
tion of the mandatory disaggregation rules
of § 1.410(b)-7(c) (including disaggrega-
tion rules for plans that cover both col-
lectively bargained and non-collectively
bargained employees) and the permissive
aggregation rules of § 1.410(b)-7(d), as
modified by § 1.401(m)-1(b)(4)(v). Sec-
tion 1.410(b)-7(c)(4)(i)(A) requires that if
a plan has multiple disaggregation popula-
tions, the disaggregation populations must
be disaggregated and treated as separate
plans.
Section 1.401(m)-2(a)(4) sets forth
timing rules for taking into account
employee contributions and matching
contributions under the ACP test. Under
§ 1.401(m)-2(a)(4)(iii), a matching contri-
bution is taken into account in determining
the actual contribution ratio (as defined in
§ 1.401(m)-5) for an eligible employee for

September 3, 2024 574 Bulletin No. 2024–36
a plan year or applicable year only if (a)
the matching contribution is allocated to
the employee’s account under the terms of
the plan as of a date within that year,
(b) the matching contribution is made
on account of (or the matching contribution
is allocated on the basis of) the employ-
ee’s elective deferrals or employee contri-
butions for that year, and (c) the matching
contribution is actually paid to the trust no
later than the end of the 12-month period
immediately following the year that con-
tains that date.
Section 110(a) of the SECURE 2.0
Act added section 401(m)(4)(A)(iii) of
the Code, which amends the definition
of matching contributions to include
employer contributions made to a defined
contribution plan on account of an
employee’s QSLP.
Section 110(b) of the SECURE 2.0
Act added section 401(m)(4)(D) of the
Code, which defines a QSLP as a pay-
ment that was made by an employee in
repayment of a qualified education loan
(as defined in section 221(d)(1)) incurred
by the employee to pay qualified higher
education expenses, subject to the section
401(m)(4)(D)(i) amount limitation and
the section 401(m)(4)(D)(ii) certification
requirement.
Pursuant to section 401(m)(4)(D)(i),
the amount of an employee’s aggregate
qualified education loan payments for a
year that can be QSLPs cannot exceed an
amount equal to the limitation applicable
under section 402(g) for the year (or, if an
employee’s compensation under section
415(c)(3) for the year is less than the lim-
itation applicable under section 402(g) for
the year, the employee’s compensation),
reduced by the employee’s elective defer-
rals for the year.
Pursuant to section 401(m)(4)(D)(ii),
for a qualified education loan payment
to be a QSLP, the employee making the
qualified education loan payment must
certify annually to the employer making
the matching contribution that payment
has been made on the loan.
For purposes of a QSLP, the term qual-
ified higher education expenses means the
cost of attendance (as defined in section
472 of the Higher Education Act of 1965,
as in effect on the day before the date of
the enactment of the Taxpayer Relief Act
of 1997) at an eligible educational insti-
tution (as defined in section 221(d)(2) of
the Code).
Section 110(c) of the SECURE 2.0
Act added section 401(m)(13) of the
Code, which provides, in part, that QSLP
matches shall be treated as matching
contributions if the following require-
ments of section 401(m)(13)(A)(i)-(iv)
are satisfied: (i) a plan provides match-
ing contributions on account of elective
deferrals (elective deferral matches) at
the same rate it provides QSLP matches;
(ii) the plan provides QSLP matches only
on behalf of employees otherwise eligi-
ble to receive elective deferral matches;
(iii) under the plan, all employees who
are eligible to receive elective deferral
matches are eligible to receive QSLP
matches; and (iv) the plan provides that
QSLP matches vest in the same man-
ner as elective deferral matches. Sec-
tion 401(m)(13)(B)(i) provides that, for
purposes of section 401(m)(13)(A)(iii),
section 401(a)(4), and section 410(b),
QSLP matches shall not fail to be treated
as available to an employee solely
because the employee does not have
debt incurred under a qualified education
loan. In addition, section 401(m)(13)
(B)(iv) provides that the elective defer-
rals of employees who receive QSLP
matches may be tested separately from
the elective deferrals of other employ-
ees for purposes of the ADP test of sec-
tion 401(k)(3)(A)(ii). Section 401(m)
(13)(C) states that an employer may rely
on an employee certification of payment
under section 401(m)(4)(D)(ii).
Section 110(d) of the SECURE 2.0 Act
added section 408(p)(2)(F) of the Code,
which provides that an arrangement under
a SIMPLE IRA plan shall not fail to be
a qualified salary reduction agreement
solely because QSLPs are treated as elec-
tive employer contributions (pursuant to
section 408(p)(2)(A)(i)(I)) under the plan.
Section 408(p)(2)(F) includes rules for
SIMPLE IRAs that include a QSLP match
feature that are generally analogous to the
QSLP match rules in section 401(m)(4)
(D) and 401(m)(13).
Section 110(e) of the SECURE 2.0 Act
amended section 403(b)(12)(A) of the
Code to provide that whether a section
403(b) plan offers a QSLP match shall
not be taken into account for purposes of
determining whether the plan satisfies the
universal availability requirement of sec-
tion 403(b)(12)(A)(ii).
Section 110(f) of the SECURE 2.0 Act
amended section 457(b) of the Code to
state, in part, that a section 457(b) plan
maintained by an employer described in
section 457(e)(1)(A) (governmental sec-
tion 457(b) plan) shall not fail to be an eli-
gible deferred compensation plan merely
because that plan, or a section 401(a)
or 403(b) plan maintained by the same
employer, adopts a QSLP match feature as
described in section 401(m)(13).
Section 110(g) of the SECURE 2.0 Act
provides for the Secretary of the Treasury
(or the Secretary’s delegate) to prescribe
regulations for purposes of implementing
section 110, including regulations:
(1) permitting a plan to make QSLP
matches at a different frequency than
matching contributions are otherwise
made under the plan, provided that the
frequency is not less than annually;
(2) permitting employers to establish
reasonable procedures to claim QSLP
matches under the plan, including an
annual deadline (not earlier than three
months after the close of each plan year)
by which a claim must be made; and
(3) promulgating model amendments
which plans may adopt to implement
QSLP matches for purposes of sections
401(m), 408(p), 403(b), and 457(b) of the
Code.
III. GUIDANCE ON SECTION 110
OF THE SECURE 2.0 ACT
A. QSLP Match Overview
Q. A-1: What is a QSLP?
A. A-1: A QSLP is a payment (1) made
by an employee during a plan year in
repayment of a qualified education loan
incurred by the employee to pay for qual-
ified higher education expenses of the
employee, the employee’s spouse, or the
employee’s dependent, (2) that does not
exceed, when aggregated with other such
payments for the year, the section 401(m)
(4)(D)(i) amount limitation for the plan
year, and (3) certified for the plan year by
the employee in a manner that satisfies
the section 401(m)(4)(D)(ii) certification
requirement.
For a qualified education loan to be
treated as incurred by an employee, the

Bulletin No. 2024–36 575 September 3, 2024
employee who makes a payment on the
qualified education loan must have a legal
obligation to make the payment under the
terms of the loan. In general, a cosigner
has a legal obligation to make payments
under the terms of a loan, but, unless the
primary borrower defaults under a loan,
a guarantor does not have a legal obli-
gation to make payments under the loan.
For example, if an eligible employee is a
cosigner on a qualified education loan for
the employee’s dependent, both the eligi-
ble employee and the dependent may have
a legal obligation to make payments under
the terms of the loan. However, only the
individual who makes payments under
the qualified education loan can receive
a QSLP match on account of those pay-
ments.
Q. A-2: What plans may include a
QSLP match feature?
A. A-2: A QSLP match feature may
be added to a section 401(k) plan, a sec-
tion 403(b) plan, a SIMPLE IRA plan
under section 408(p), or a governmen-
tal section 457(b) plan. In general, this
notice describes the QSLP match rules by
referring to statutory language applicable
to plans other than SIMPLE IRAs. For
QSLP match rules specific to SIMPLE
IRA plans, see Q&A E-1 of this notice.
Q. A-3: What is an employee’s maxi-
mum QSLP for a year?
A. A-3: An employee’s maximum
QSLP for a year is described below for
section 401(k) and section 403(b) plans,
and for governmental section 457(b)
plans. For QSLP match rules specific to
SIMPLE IRA plans, see Q&A E-1 of this
notice.
(1) Section 401(k) and section 403(b)
plans
Pursuant to the QSLP definition in
section 401(m)(4)(D), an employee’s
qualified education loan payments can
be QSLPs in a section 401(k) or section
403(b) plan only to the extent such pay-
ments in the aggregate for a year do not
exceed an amount equal to the limita-
tion applicable under section 402(g) (or,
if lesser, the employee’s compensation
as described under section 415(c)(3)),
reduced by the employee’s elective defer-
rals for the year.
(2) Governmental section 457(b) plans
Although the limitation applicable
under section 402(g) and the term elec-
tive deferrals are not applicable to sec-
tion 457(b) plans, the reference to sec-
tion 402(g) in section 401(m)(4)(D)
1

provides the dollar amount used in lim-
iting a QSLP, and a similar concept of
salary deferrals applies to section 457(b)
plans. Accordingly, for purposes of cal-
culating the maximum QSLPs for an
employee for a year in a governmental
section 457(b) plan, the amount of the
employee’s salary deferrals under the gov-
ernmental section 457(b) plan for the year
is the amount that is subtracted from the
limitation applicable under section 402(g)
(or, if lesser, the employee’s compensa-
tion as described under section 415(c)(3)).
The limitation under section 402(g) is the
same dollar amount as the applicable dol-
lar limit under section 457(e)(15)(A).
Q. A-4: May a plan include provisions
that limit QSLP matches to only certain
qualified education loans, such as qual-
ified education loans for an employee’s
own education, for a particular degree pro-
gram (e.g., Bachelor of Arts, Juris Doctor,
or Master of Business Administration), or
for attendance at a particular school?
A. A-4: No. Section 401(m)(13)(A)
(iii) provides that all employees (except
as described in Q&A A-5 of this notice)
eligible to receive matching contributions
on account of elective deferrals must be
eligible to receive matching contributions
on account of “qualified student loan pay-
ments.”
The reference in section 401(m)(13)
(A)(iii) to qualified student loan payments
is to qualified student loan payments that
satisfy the definition in section 401(m)
(4)(D) (as described in Q&A A-1 of this
notice). Pursuant to section 401(m)(4)
(D), a qualified student loan payment is a
payment that was made by an employee
in repayment of a qualified education loan
incurred by the employee. A plan that
includes a definition of QSLP that cov-
ers only a subset of employees who have
made qualified education loan payments
will violate the requirement in section
401(m)(13)(A)(iii) that QSLP matches be
available to all employees who are eligi-
ble for elective deferral matches.
2
Thus,
for example, a plan cannot limit QSLP
matches to qualified education loan pay-
ments for an employee’s own education,
for a particular degree program, or for
attendance at a particular school.
Q. A-5: May a plan with a QSLP match
feature include provisions that exclude
employees from receiving QSLP matches
even though those employees are eligible
to receive elective deferral matches, or
may a plan with a QSLP match feature
include provisions that exclude employees
from receiving elective deferral matches
even though those employees are eligible
to receive QSLP matches?
A. A-5: No. Pursuant to section 401(m)
(13)(A)(iii), all employees eligible to
receive elective deferral matches under a
plan with a QSLP match feature must be
eligible to receive QSLP matches. Also,
pursuant to section 401(m)(13)(A)(ii),
a plan with a QSLP match feature must
provide QSLP matches only on behalf
of employees eligible to receive elec-
tive deferral matches. Thus, a plan with
a QSLP match feature may not include
provisions that exclude employees from
receiving QSLP matches if those employ-
ees are eligible to receive elective deferral
matches, and a plan with a QSLP match
feature may not include provisions that
exclude employees from receiving elec-
tive deferral matches if those employees
are eligible to receive QSLP matches.
In general, this requirement of uniform
treatment for elective deferral matches
and QSLP matches applies to all employ-
ees covered by a plan, so that employees
may not be excluded from QSLP matches
on an individual employer, business
unit, division, location, or other similar
basis. However, for purposes of determin-
ing what constitutes a plan under section
401(m)(13)(A), the disaggregation rules
1
Section 401(m)(13), through its reference to QSLP matches, incorporates for governmental section 457(b) plans the provisions of section 401(m)(4)(D).
2
Section 401(m)(13)(B)(i) provides, in part, that for purposes of section 401(m)(13)(A)(iii), QSLP matches “shall not fail to be treated as available to an employee solely because the employee
does not have debt incurred under a qualified education loan.” However, section 401(m)(13)(B)(i) does not provide similar “shall not fail to be treated as available” language for an employee
who has debt incurred under a qualified education loan but is excluded from eligibility for a QSLP match under plan terms. Accordingly, if all employees with qualified education loans are
not eligible for a QSLP match under plan terms, the plan’s QSLP match will not be treated as being available to all employees under section 401(m)(13)(A)(iii).

September 3, 2024 576 Bulletin No. 2024–36
under § 1.410(b)-7(c)(4), including with
respect to collectively bargained employ-
ees, apply. Thus, a plan may include a
QSLP match feature that applies only to
non-collectively bargained employees
without violating section 401(m)(13)(A)
(ii) and (iii).
Example 1: Plan X is a section 401(k) plan. As
an eligibility condition for Plan X’s QSLP match,
employees must remain employed through the QSLP
match allocation date or through the last day of the
plan year, but that condition is not included for the
plan’s elective deferral match. This eligibility condi-
tion on Plan X’s QSLP match, which is not included
for the plan’s elective deferral match, causes Plan X
to violate section 401(m)(13)(A)(iii).
Example 2: Plan Y is a section 403(b) plan. As
an eligibility condition on Plan Y’s elective deferral
match, employees must remain employed through
the elective deferral match allocation date or through
the last day of the plan year, but that condition is not
included for the plan’s QSLP match. This eligibility
condition on Plan Y’s elective deferral match, which
is not included for the plan’s QSLP match, causes
Plan Y to violate section 401(m)(13)(A)(ii).
Example 3: Plan Z is a section 401(k) plan. Plan
Z covers both collectively bargained employees and
non-collectively bargained employees, and provides
elective deferral matches to all covered employees.
However, Plan Z only provides QSLP matches to
non-collectively bargained employees. Because the
portion of Plan Z that covers non-collectively bar-
gained employees and the portion of Plan Z that
does not cover collectively bargained employees
are treated as separate plans for purposes of section
401(m)(13)(A)(iii), the exclusion of collectively bar-
gained employees from Plan Z’s QSLP match does
not cause Plan Z to violate section 401(m)(13)(A)
(iii).
Q. A-6: May a QSLP match contributed
for a plan year be based on a qualified edu-
cation loan payment that was made during
a different plan year?
A. A-6: No. Only an employee’s qual-
ified education loan payments that were
made during a plan year are eligible to be
counted for purposes of the employee’s
QSLP match for that plan year.
3
This result
is consistent with the timing rules for tak-
ing into account matching contributions
for ACP testing under § 1.401(m)-2(a)(4)
(iii).
Example 1: Even if a calendar-year plan has a
final QSLP match claim deadline with respect to Plan
Year 1 that is April 1 of Plan Year 2, an employee
who does not make any QSLPs in Plan Year 1 and
makes a QSLP on March 1 of Plan Year 2 is not eli-
gible for a QSLP match for Plan Year 1.
Example 2: If a fiscal year plan has a plan year
that begins on July 1 of Plan Year 2, an employee
cannot receive a QSLP match for Plan Year 2 on
account of a qualified education loan payment that
was made in June of the calendar year that includes
July 1 of Plan Year 2.
B. Employee Certification of QSLPs
Q. B-1: For an employee’s qualified
education loan payment to be a QSLP,
must the employee certify that the pay-
ment satisfies the requirements to be a
QSLP?
A. B-1: Yes. A qualified education
loan payment is a QSLP only if the
section 401(m)(4)(D)(ii) certification
requirement is satisfied with respect to
that payment. A plan may require a sep-
arate certification for each qualified edu-
cation loan payment intended to qualify
as a QSLP or permit an annual certifica-
tion that applies for all qualified educa-
tion loan payments intended to qualify as
QSLPs for a year.
Q. B-2: What items of information
about a qualified education loan payment
must be received by a plan for the QSLP
certification requirement to be satisfied?
A. B-2: To satisfy the section 401(m)
(4)(D)(ii) certification requirement with
respect to a qualified education loan pay-
ment, the following items of informa-
tion must be received by a plan (includ-
ing a third-party service provider acting
on behalf of the plan): (1) the amount
of the loan payment; (2) the date of the
loan payment; (3) that the payment was
made by the employee; (4) that the loan
being repaid is a qualified education loan
and was used to pay for qualified higher
education expenses of the employee,
the employee’s spouse, or the employ-
ee’s dependent; and (5) that the loan was
incurred by the employee.
The section 401(m)(4)(D)(ii) certifi-
cation requirement for any required item
of information may be satisfied through
affirmative certification by the employee.
Alternatively, the section 401(m)(4)(D)
(ii) certification requirement with respect
to the amount of the loan payment in item
(1), the date of the loan payment in item
(2), and the confirmation of the employee
as payor in item (3) may be treated as sat-
isfied through independent verification by
the employer or through passive certifica-
tion by the employee. The confirmation
that the loan being repaid is a qualified
education loan in item (4) and incurred by
the employee in item (5) can be certified
only through affirmative certification by
the employee. One method of satisfying
the affirmative certification requirement
for items (4) and (5) is through loan reg-
istration whereby an employee provides
information to the plan regarding items
(4) and (5) before the first loan payment
is made for which the employee claims a
QSLP match.
For purposes of this notice, indepen-
dent verification means a method of certi-
fication by which a plan is able to validate
the accuracy of items (1), (2), and (3).
For example, the independent verification
requirement with respect to items (1), (2),
and (3), including the requirement that the
loan payment be made by the employee,
is satisfied if an employer allows an
employee to make qualified education
loan payments through payroll deduction.
For purposes of this notice, passive
certification means a method of certifica-
tion by which (i) an employee provides
written information about a qualified
education loan to a plan regarding items
(4) and (5), (ii) information about items
(1) and (2) is provided from the lender to
the plan, including through an employer,
(iii) the plan notifies the employee of the
information (including, if the plan uses
passive certification with respect to item
(3), a statement that the employer assumes
that item (3) has been satisfied), and (iv)
the employee is given a reasonable period
to correct the information included in the
employee notice. The employer does not
have an obligation to inquire whether item
(3) has been satisfied, so that the employer
may assume item (3) has been satisfied
unless the employer has actual knowledge
to the contrary. The employee is treated as
certifying the information provided in the
employee notice if the employee does not
correct the information within the reason-
able period.
Example 1: Affirmative Certification, With or
Without Registration
Plan W is a section 401(k) plan that includes a
QSLP match feature. Under Plan W, an employee
3
Section 110(h) of the SECURE 2.0 Act indicates that the amendments made by section 110 shall apply to contributions made for plan years beginning after December 31, 2023. As a result, a
QSLP match cannot be made on account of qualified education loan payments paid on or before December 31, 2023 (or, for non-calendar year plans that have adopted a QSLP match feature,
before the first day of the plan year that includes the QSLP match if that date is later).

Bulletin No. 2024–36 577 September 3, 2024
must make an annual affirmative certification that
includes all five items of information needed to
submit a QSLP match claim and does not require
any additional documentation to verify that infor-
mation. If an employee provides the annual affir-
mative certification with respect to a QSLP match
claim, the section 401(m)(4)(D)(ii) certification
requirement is satisfied with respect to that QSLP
match claim.
Alternatively, if Plan W were to require that
items (4) and (5) be affirmatively certified one time
pursuant to a loan registration and that items (1),
(2), and (3) be affirmatively certified annually, the
section 401(m)(4)(D)(ii) certification requirement
would be satisfied with respect to a QSLP match
claim if an employee were to provide the required
initial loan registration and annual affirmative certifi-
cations with respect to the QSLP match claim.
Example 2: Registration and Independent Verifi-
cation Through Payroll Deduction
Plan X is a section 403(b) plan that includes a
QSLP match feature, and, under the plan, qualified
education loan payments must be made through pay-
roll deduction. To receive a QSLP match under Plan
X, an employee must register a qualified education
loan with the employer. This registration satisfies
the certification requirement for items (4) and (5). In
addition, because, under the plan, qualified education
loan payments must be made through payroll deduc-
tion, which validates the accuracy of items (1), (2),
and (3), the certification requirement for items (1),
(2), and (3) is treated as satisfied through indepen-
dent verification.
Example 3: Registration and Passive Certifica-
tion
Plan Y is a governmental section 457(b) plan
that includes a QSLP match feature. To receive a
QSLP match under Plan Y, an employee must regis-
ter a qualified education loan with a third-party ser-
vice provider. This registration satisfies the certifi-
cation requirement for items (4) and (5). In addition,
the third-party service provider receives informa-
tion from the qualified education loan lender about
items (1) and (2), but does not receive information
about item (3) (because the qualified education
loan lender is not able to provide information about
the source of repayments to the third-party service
provider). The third-party service provider notifies
the employee of the information received from the
lender about items (1) and (2), provides a statement
to the employee that the employer assumes that
item (3) has been satisfied (and the employer does
not have actual knowledge to the contrary), and
provides the employee with a reasonable period to
correct items (1), (2), and (3). If the employee does
not correct information about items (1), (2), and (3)
within a reasonable period, the certification require-
ment for items (1), (2), and (3) is treated as satisfied
through passive certification.
Q. B-3: Do the items of information
required to satisfy the section 401(m)(4)
(D)(ii) certification requirement need to
be received annually by a plan?
A. B-3: Information about items (1),
(2), and (3) must be received annually by a
plan. Information about item (4) and item
(5) does not need to be received annually
by a plan if the employee registers the
loan with the plan. However, if a quali-
fied education loan is refinanced or the
information contained in items (4) and (5)
otherwise changes, updated information
must be received by the plan about items
(4) and (5), for example, through re-regis-
tration of the loan, in order for the section
401(m)(4)(D)(ii) certification requirement
to be satisfied.
C. QSLP Match Reasonable
Procedures
Q. C-1: What administrative proce-
dures may a plan establish to implement a
QSLP match feature?
A. C-1: A plan may establish any rea-
sonable administrative procedures to
implement a QSLP match feature. Whether
procedures are reasonable is based on all
relevant facts and circumstances, includ-
ing whether QSLP matches are effectively
available to all eligible employees and
whether the procedures promote com-
pliance with QSLP match requirements.
Reasonable procedures include, but are
not limited to, the procedures described in
this notice.
Q. C-2: What administrative proce-
dures may a plan establish with respect to
QSLP match claim deadlines?
A. C-2: A plan may establish a single
QSLP match claim deadline for a plan
year or multiple deadlines (including, but
not limited to, quarterly deadlines) for
QSLP match claim submissions, provided
that each QSLP match claim deadline is
reasonable. As described in Q&A C-1 of
this notice, whether a plan’s QSLP match
claim deadline is reasonable is based on
all relevant facts and circumstances. In
determining whether a deadline is rea-
sonable, relevant facts and circumstances
include whether employees have a rea-
sonable opportunity to collect and fur-
nish claim submission documentation. An
annual deadline that is three months after
the end of a plan year is an example of a
reasonable deadline.
4

Q. C-3: Must a plan require that an
employee submit verification in support of
an employee’s certification under section
401(m)(4)(D)(ii) that a qualified educa-
tion loan payment is a QSLP?
A. C-3: No. Pursuant to section 401(m)
(13)(C), it is a reasonable procedure for a
plan to rely on an employee’s annual cer-
tification that a qualified education loan
payment satisfies the requirements to be
a QSLP, without requiring any supporting
verification.
A plan may, however, require verifica-
tion that an employee’s qualified education
loan payment satisfies the requirements to
be a QSLP, provided that the verification
is made pursuant to established reasonable
procedures. As described in Q&A C-1 of
this notice, whether a plan’s QSLP verifi-
cation procedures are reasonable is based
on all relevant facts and circumstances.
In determining whether verification pro-
cedures are reasonable, relevant facts and
circumstances include whether the verifi-
cation procedures are reasonably available
to a particular employee or for a particular
qualified education loan.
Accordingly, a plan may establish rea-
sonable procedures that require indepen-
dent verification that an employee has
made payments during a plan year on a
qualified education loan, or passive certi-
fication by the employee. However, a plan
may not establish independent verification
or passive certification procedures that are
not reasonably available with respect to a
particular employee. For example, a plan
may require independent verification of a
payment based on the transfer of loan data
to the plan’s third-party service provider
only if the plan permits an employee who
does not have the ability to transfer loan
data to a plan’s third-party service pro-
vider to verify the employee’s qualified
education loan payment by other reason-
able means, such as by submission of can-
celled checks or qualified education loan
statements.
4
The Treasury Department and the IRS received comments expressing concern about the potential for the imposition of section 4979 excise taxes on excess contributions and excess aggregate
contributions as a result of QSLP matches claimed after the 2½-month correction deadline under section 4979. Plans that adopt a QSLP match feature may avoid this excise tax concern by
either adopting EACA provisions or adopting reasonable QSLP match claim deadlines that are earlier than 2½ months after the end of a plan year.

September 3, 2024 578 Bulletin No. 2024–36
D. QSLP ADP Testing
Q. D-1: For a plan that includes a
QSLP match feature, how is optional sep-
arate ADP testing applied pursuant to sec-
tion 401(m)(13)(B)(iv)?
A. D-1: A plan that includes a QSLP
match feature may apply ADP testing
pursuant to section 401(m)(13)(B)(iv) by
applying a single ADP test for all employ-
ees or by applying a separate ADP test for
employees who receive QSLP matches
and a main ADP test that includes employ-
ees who do not receive QSLP matches. A
plan that applies a separate ADP test for
employees who receive QSLP matches
may use either of the methods described
below (Method 1 or Method 2). These
alternative methods provide testing flex-
ibility so that section 401(m)(13)(B)
(iv) provides ADP testing relief without
regard to whether employees who both
receive QSLP matches and make elective
deferrals include differing proportions of
HCEs and NHCEs and without regard to
whether the HCEs and NHCEs included
in this group of employees have differing
deferral percentages. For example, the
separate ADP test under Method 1 may
be helpful if NHCEs who receive QSLP
matches have a higher deferral percentage
than HCEs who receive QSLP matches,
while the separate ADP test under Method
2 may be helpful if HCEs who receive
QSLP matches have a higher deferral per-
centage than NHCEs who receive QSLP
matches.
Method 1: Employees who are tested
separately include all employees who
receive QSLP matches, without regard
to whether they also make elective defer-
rals. Employees who do not receive QSLP
matches are not included in this sepa-
rate ADP test, but instead, are taken into
account under the main ADP test. The
elective deferrals of the employees who
receive QSLP matches and also make
elective deferrals are taken into account
in performing the separate test and are
excluded from the main ADP test.
Method 2: Employees who are tested
separately include all employees who
receive QSLP matches, without regard to
whether they also make elective deferrals.
However, unlike the separate test under
Method 1, the elective deferrals of the
employees who receive QSLP matches
and also make elective deferrals (along
with the elective deferrals of employees
who do not receive QSLP matches) are
taken into account in performing the main
ADP test and are disregarded in perform-
ing the separate ADP test.
The following chart summarizes,
and highlights the differences between,
Method 1 and Method 2:
Method 1Method 2
Main ADP
test
• Testing includes employees who do not receive
QSLP matches.
• Testing includes only elective deferrals for employ-
ees who do not receive QSLP matches.
• Testing includes employees who do not receive
QSLP matches and employees who both receive
QSLP matches and make elective deferrals.
• Testing includes elective deferrals for employees
who both receive QSLP matches and make elective
deferrals.
Separate
ADP Test
• Testing includes employees who receive QSLP
matches.
• Testing includes elective deferrals for employees
who both receive QSLP matches and make elective
deferrals.
• Testing includes employees who receive QSLP
matches.
• Testing excludes elective deferrals for employees
who both receive QSLP matches and make elective
deferrals.
E. Miscellaneous Issues
Q. E-1: How do the QSLP match rules
apply to SIMPLE IRA plans?
A. E-1: In general, the QSLP match
rules described in this notice with respect
to section 401(k), 403(b), and governmen-
tal 457(b) plans apply in a similar man-
ner to a QSLP match feature in a SIM-
PLE IRA plan. For example, although
section 401(m)(13)(C) does not apply to
SIMPLE IRA plans, a SIMPLE IRA plan
may rely on an employee’s certification
that a qualified education loan payment
satisfies the requirements to be a QSLP
and may adopt other reasonable proce-
dures described in Q&A C-3 to determine
that a qualified education loan payment is
a QSLP.
However, the QSLP match rules
described in this notice that relate to
requirements that do not apply to SIM-
PLE IRA plans (for example, rules relat-
ing to the treatment of QSLP matches for
purposes of nondiscrimination testing,
including separate ADP testing described
in Q&A D-1 of this notice) do not apply to
a QSLP match feature in a SIMPLE IRA
plan.
In addition, an employee’s maximum
QSLPs for a year with respect to a SIMPLE
IRA plan are determined differently from
other plans. Pursuant to section 408(p)(2)
(F)(i), an employee’s qualified education
loan payments can be QSLPs in a SIM-
PLE IRA plan only to the extent such pay-
ments do not exceed the applicable dollar
amount under section 408(p)(2)(E) (after
application of section 414(v)) for the year,
or, if lesser, the employee’s compensation
(as defined in section 415(c)(3)), reduced
by any other elective employer contribu-
tions the employee elected for the year
pursuant to section 408(p)(2)(A)(i)(I)).
Q. E-2: May a QSLP match feature be
added as a mid-year change to a safe har-
bor plan, as described in Notice 2016-16,
2016-7 I.R.B. 318?
A. E-2: Yes. A QSLP match feature
may be added as a mid-year change to a
safe harbor plan (that is, a safe harbor plan
described in section 401(k)(12), 401(k)
(13), 401(m)(11), or 401(m)(12)), pro-
vided that the notice and election oppor-
tunity conditions in section III.C of Notice
2016-16 are satisfied. Further, a mid-year
change to a safe harbor plan to add a QSLP

Bulletin No. 2024–36 579 September 3, 2024
match feature is not a prohibited mid-year
change, as described in Section III.D of
Notice 2016-16.
Q. E-3: May a plan provide for QSLP
matches to be contributed at a different
frequency than elective deferral matches?
A. E-3: Yes. A plan may provide for
QSLP matches to be contributed at a
different frequency than elective defer-
ral matches, provided that QSLP match
contributions are required to be contrib-
uted not less frequently than annually. In
addition, a plan may provide for QSLP
matches to be contributed at a different
frequency than elective deferral matches
without violating the requirement under
section 401(m)(13)(A)(i) that the plan
provide elective deferral matches at the
same rate as QSLP matches. For example,
a section 401(k) plan that includes a QSLP
match feature may provide for QSLP
matches to be contributed once each year
and for elective deferral matches to be
contributed on a biweekly payroll basis.
Q. E-4: In the event an employee’s cer-
tification of a QSLP is determined to be
incorrect, must a match based on that cer-
tification be corrected?
A. E-4: No. Even if an employee’s
certification of a QSLP is determined to
be incorrect, a match based on that certi-
fication does not need to be corrected. If
a match based on an incorrect certifica-
tion is not corrected, it may be treated as
a QSLP match. However, a QSLP match
is permitted to be corrected to the extent
an employee’s certification of a QSLP is
determined to be incorrect, provided that
all QSLP matches made under similar
circumstances are corrected. For exam-
ple, if an employee’s QSLP match for a
plan year is corrected because the qual-
ified education loan on which the QSLP
match was based is later forgiven (causing
the employee’s certification of a QSLP to
be incorrect), all QSLP matches for the
plan year must be corrected to the extent
qualified education loans on which QSLP
matches were based are later forgiven.
The option not to correct an employee’s
QSLP match based on an incorrect certi-
fication, as described in this Q&A E-4 of
this notice, does not apply with respect to
an operational failure in administering a
QSLP match feature, including a failure to
satisfy the section 401(m)(4)(D)(ii) certi-
fication requirement.
Q. E-5: Are plans required to provide
for contributions of QSLP matches on a
rolling basis as employees submit QSLP
claims (similar to the timing of contribu-
tions under section 125 flexible spending
accounts)?
A. E-5: No. Plans may, but are not
required to, provide for contributions
of QSLP matches on a rolling basis. For
example, plans may provide for contribu-
tions of QSLP matches for a plan year to
be made at the same time for all employ-
ees receiving QSLP matches for the plan
year.
Q. E-6: How does section 409A apply
to a nonqualified deferred compensation
(NQDC) plan that is linked to a plan with
a QSLP match feature?
A. E-6: Sections 1.409A-2(a)(9) and
1.409A-3(j)(5) provide relief with respect
to the election-timing and anti-acceler-
ation rules of section 409A for certain
changes in the amount credited under an
NQDC plan that result from an employ-
ee’s action or inaction with respect to
elective deferrals and certain other con-
tributions to a qualified employer plan
(as defined in § 1.409A-1(a)(2)). For
purposes of these election-timing and
anti-acceleration rules, an employee’s
action or inaction with respect to QSLPs
will be treated as an action or inaction
with respect to elective deferrals. The
Treasury Department and the IRS antic-
ipate issuing proposed regulations
under section 409A that will conform
§§ 1.409A-2(a)(9)(iv) and 1.409A-3(j)
(5)(iv).
IV. APPLICABILITY DATE
This notice applies for plan years
beginning after December 31, 2024.
For plan years beginning before Janu-
ary 1, 2025, a plan sponsor may rely on
a good faith, reasonable interpretation
of section 110 of the SECURE 2.0 Act.
The guidance in this notice is an exam-
ple of a good faith, reasonable interpre-
tation of section 110 of the SECURE
2.0 Act.
V. REQUEST FOR COMMENTS
The Treasury Department and the
IRS anticipate issuing proposed regula-
tions with respect to section 110 of the
SECURE 2.0 Act and, accordingly, invite
comments and suggestions regarding the
matters discussed in this notice and, gen-
erally, on section 110 of the SECURE 2.0
Act. In particular, the Treasury Depart-
ment and the IRS request comments on:
(1) Whether additional guidance would
be helpful relating to passive certification
or independent verification;
(2) Whether, for a plan that provides
for QSLP matches to be made more fre-
quently than annually, guidance would be
helpful in the case of an employee who
receives a QSLP match early in a year
before it is known whether subsequent
elective deferrals will reduce the employ-
ee’s maximum QSLP for the year;
(3) Whether additional examples of
reasonable procedures would be helpful
with respect to QSLP matches;
(4) Whether additional guidance
would be helpful concerning the applica-
tion of the QSLP rules to SIMPLE IRA
plans; and
(5) Whether additional guidance
would be helpful concerning the applica-
tion of the QSLP rules to SIMPLE 401(k)
plans.
Comments should be submitted in
writing on or before October 18, 2024,
and should include a reference to Notice
2024-63. Comments submitted after Octo-
ber 18, 2024, will be considered if doing
so will not delay the issuance of proposed
regulations with respect to section 110 of
the SECURE 2.0 Act. Comments may be
submitted electronically via the Federal
eRulemaking Portal at www.regulations.
gov (type “IRS Notice 2024-63” in the
search field on the Regulations.gov home
page to find this notice and submit com-
ments). Alternatively, comments may be
submitted by mail to: Internal Revenue
Service, Attn: CC:PA:LPD:PR (Notice
2024-63), Room 5203, P.O. Box 7604,
Ben Franklin Station, Washington, D.C.
20044.
The Treasury Department and the IRS
will publish for public availability any
comment submitted electronically or on
paper to its public docket.
VI. PAPERWORK REDUCTION ACT
The collection of information con-
tained in this notice will be submitted to
the Office of Management and Budget in

September 3, 2024 580 Bulletin No. 2024–36
accordance with the Paperwork Reduction
Act (PRA) (44 U.S.C. 3507) under OMB
control number 1545-1669. An agency
may not conduct or sponsor, and a person
is not required to respond to, a collection
of information unless the collection of
information displays a valid OMB control
number.
The collections of information in this
notice are contained in Q&A B-1, Q&A
B-2, Q&A B-3, Q&A C-3, and Q&A E-1
of this notice. This information will be
used by plan administrators to administer
QSLP match programs. The third-party
disclosures and recordkeeping require-
ments will be submitted to OMB for
review and approval in accordance with 5
CFR 1320.10.
The likely respondents are employees
who are participants in plans that adopt a
QSLP match feature and administrators of
plans that adopt a QSLP match feature.
Estimated number of respondents:
158,000 to 617,000.
Estimated frequency of responses:
Annually.
Estimated average time per response:
.25 hours.
Estimated total annual burden: 39,500
to 154,250 hours.
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.
VII. DRAFTING INFORMATION
The principal author of this notice
is Isaac Stein of the Office of Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employ-
ment Taxes). For further information
regarding this notice, contact Isaac Stein
at (202) 317-6320 (not a toll-free num-
ber).

Bulletin No. 2024–36 581 September 3, 2024
Part IV
Second Employee
Retention Credit Voluntary
Disclosure Program
Announcement 2024-30
Section 1. Purpose and Scope
The Internal Revenue Service (IRS)
announces a second ERC Voluntary Dis-
closure Program for employers (partic-
ipants) to resolve erroneous claims for
credit or refund involving the Employee
Retention Credit (ERC). The ERC is a
refundable tax credit intended for busi-
nesses and tax-exempt organizations that
continued paying employees during the
COVID-19 pandemic if their operations
were fully or partially suspended due to
a government order, they experienced the
required decline in gross receipts, or they
were a recovery startup business during
the relevant eligibility periods.
Since the enactment of legislation
authorizing ERC claims, the IRS has had
concerns about scams and potential fraud
regarding such claims given false and mis-
leading public advertisements and scams
taking advantage of taxpayers. Those that
filed for and erroneously received the ERC
face enforcement action from the IRS and
are subject to assessment and collection
procedures. The IRS believes that it would
prevail in litigation to recover credits or
refunds of erroneous ERC claims and that
the imposition of appropriate penalties
and interest would be upheld by a court.
The IRS is offering employers an oppor-
tunity to resolve their civil tax liabilities
under this second ERC Voluntary Disclo-
sure Program and avoid potential civil lit-
igation, penalties, and interest.
In Announcement 2024-3, 2024-2
I.R.B. 364, the IRS announced the first
ERC Voluntary Disclosure Program,
which ended on March 22, 2024. More
than 2,600 taxpayers applied to the first
ERC Voluntary Disclosure Program to
resolve their improper ERC claims and
avoid civil penalties and unnecessary
litigation. Participants included common
law employers who used a third-party
payer to claim the ERC on their behalf.
The first ERC Voluntary Disclosure Pro-
gram included settlement of the ERC for
purposes of a participant’s employment
tax obligations by eliminating their eligi-
bility for the ERC while allowing a par-
ticipant to retain 20% of the claimed ERC
amount. Because the ERC reduces the
income tax expense for qualified wages
under rules similar to section 280C of the
Internal Revenue Code (Code), the first
ERC Voluntary Disclosure Program also
resolved the issue of the corresponding
adjustment to income tax expense for
participants.
This second ERC Voluntary Disclosure
Program also includes the settlement of
the ERC for purposes of a participant’s
employment tax obligations by eliminat-
ing their eligibility for the ERC. However,
participants in this second ERC Voluntary
Disclosure Program are allowed to retain
15% of the claimed ERC amount. Par-
ticipation in the second ERC Voluntary
Disclosure Program is limited to ERC
claims filed for the 2021 Tax Period(s)
and includes common law employers who
used a third-party payer to claim the ERC
on their behalf. This second ERC Volun-
tary Disclosure Program also resolves the
issue of the corresponding adjustment to
income tax expense for participants. The
second ERC Voluntary Disclosure Pro-
gram, like the first, is intended to settle
erroneous, yet non-willful ERC claims.
Taxpayers subject to potential criminal
liability should utilize the IRS Criminal
Investigation Voluntary Disclosure Prac-
tice.
Section 2. Eligibility
Any participant that has claimed the
ERC for tax periods in 2021 and has
received a credit or refund prior to August
15, 2024, is eligible to participate in this
second ERC Voluntary Disclosure Pro-
gram, provided that:
(1) The participant is not under criminal
investigation and they have not been
notified that the IRS intends to com-
mence a criminal investigation;
(2) The IRS has not received information
from a third party alerting the IRS
to the participant’s noncompliance,
nor has the IRS acquired information
directly related to the noncompliance
from an enforcement action;
(3) The participant is not under an
employment tax examination by the
IRS for any tax period(s) for which
the taxpayer is applying for this sec-
ond ERC Voluntary Disclosure Pro-
gram;
(4) The participant has not been notified
by the IRS that the ERC they received
is being recaptured for any tax peri-
od(s) for which the taxpayer is apply-
ing for this second ERC Voluntary
Disclosure Program
1
; and
(5) The participant has not previously
received notice and demand for
repayment of all or part of the claimed
ERC.
A participant that claimed the ERC
using a third-party payer (such as an agent
under section 3504 of the Code, a profes-
sional employer organization, or a certi-
fied professional employer organization)
that claimed the ERC for the participant
on an employment tax return filed under
the third-party payer’s own employer
identification number (EIN) rather than
the EIN of the participant, may participate
in this second ERC Voluntary Disclosure
Program, but the third-party payer must
submit the application described in Sec-
tion 4 of this announcement on the partic-
ipant’s behalf.
Section 3. Terms of Second ERC
Voluntary Disclosure Program
The terms of this second ERC Volun-
tary Disclosure Program are as follows:
(1) Employment Tax Adjustments – The
participant is not eligible for, or enti-
tled to, any ERC, including both the
refundable and non-refundable por-
tions, for the tax period(s) at issue.
(2) The participant will remit back to the
Department of the Treasury 85% of
the claimed ERC, including both the
refundable and non-refundable por-
tions.
1
The IRS notifies an employer of ERC recapture by issuing a Letter 6577-C, Employee Retention Credit (ERC) Recapture.

September 3, 2024 582 Bulletin No. 2024–36
(3) The participant will not be required
to repay any overpayment interest
received. If the participant makes full
payment of 85% of the claimed ERC
prior to executing the closing agree-
ment, no underpayment interest will
apply. If the IRS approves a request
for an alternative payment arrange-
ment such as an installment agree-
ment, interest may apply from the
agreement date.
(4) Income Tax Effects – Because the
settlement eliminates a participant’s
eligibility for and/or entitlement to
all of the claimed ERC, participants
are not required to reduce wage
expense with respect to any of the
previously claimed ERC. Conse-
quently, if they had not previously
reduced wage expense by any of the
claimed ERC, participants need not
file amended returns or Administra-
tive Adjustment Requests (AARs) to
reduce wage expense. Correspond-
ingly, if they had previously reduced
wage expense by any of the claimed
ERC, participants should not reduce
wage expense by any of the claimed
ERC if they file an amended return
or AAR adjusting the previous
reduction to wage expense. Pursuant
to the settlement, a participant has no
income with respect to the resolution
of the employment tax obligation by
remittance of payment of only 85%
of the claimed ERC, including both
the refundable and non-refundable
portions.
(5) Preparer/Advisor Information – If a
return preparer or advisor assisted or
advised the participant with any por-
tion of the claim for credit or refund,
the participant will provide the name,
address, and phone number of the
preparer(s) or advisor(s) who assisted
with the claim for credit or refund and
a description of services provided by
the preparer or advisor.
(6) Application of Penalties – The IRS
will not assert civil penalties related
to the underpayment of employment
tax attributable to the claimed ERC
against a participant of this ERC
Voluntary Disclosure Program under
Announcement 2024-30 that remits
full payment of 85% of the claimed
ERC prior to executing the closing
agreement.
(7) The participant will execute a closing
agreement, as more fully described in
Section 4(3) of this announcement.
Section 4. Procedures for Participants
in the Second ERC Voluntary
Disclosure Program
(1) Form 15434, Application for
Employee Retention Credit Voluntary Dis-
closure Program
Participants in this second ERC Vol-
untary Disclosure Program must notify
the IRS of their election by completing
and submitting Form 15434, Application
for Employee Retention Credit Voluntary
Disclosure Program, on or before 11:59
pm local time on November 22, 2024.
Participants must submit Form 15434
and any required attachments electroni-
cally via the Document Upload Tool at
irs.gov/DUT.
Form 15434 must be prepared under
penalties of perjury and:
(a) Include the taxpayer’s name, tax-
payer identification number, current
address, and daytime telephone num-
ber. If a practitioner will represent the
taxpayer, the practitioner must pro-
vide a completed Form 2848, Power
of Attorney and Declaration of Rep-
resentative;
(b) Identify the tax period(s) for which
the ERC was claimed, the form on
which the ERC was claimed, and
the full amount of the ERC claimed,
including both the amounts that were
refundable and non-refundable;
(c) If the ERC was claimed for the first
or second quarters of tax year 2021,
a completed, signed ERC Voluntary
Disclosure Program Form SS-10,
Consent to Extend the Time to Assess
Employment Taxes, for the 2021 Tax
Period(s), is required to be submitted
with Form 15434;
(d) If the ERC was claimed by a third-
party payer on behalf of the partic-
ipant, as described in Section 2, the
third-party payer must attach a copy
of the relevant pages of the Sched-
ule R (Form 941), Allocation Sched-
ule for Aggregate Form 941 Filers,
that was attached to each Form 941,
Employer’s Quarterly Federal Tax
Return, on which the third-party
payer claimed the ERC for the partic-
ipant; and
(e) If a return preparer or advisor assisted
with the claim for credit or refund,
include the name, address, and phone
number of the preparer(s) and advi-
sor(s) who assisted with the claim for
credit or refund and a description of
services provided by the preparer or
advisor.
(2) Payment
Form 15434 will help a participant
calculate how much they will be required
to pay to the Department of the Treasury
under the terms of the second ERC Volun-
tary Disclosure Program.
A participant should use the Electronic
Federal Tax Payment System (EFTPS) to
submit an online payment(s). Payment
should be made separately for each tax
period upon submission of Form 15434.
In EFTPS, participants should select
the form they filed their employment
tax return on, such as Form 941 (Form
15434 is not an option in EFTPS). Then,
participants should select “Audit Adjust-
ment” and “Advance Payment of Tax
Deficiency” for “Tax Type.” Participants
should not make a single, lump-sum pay-
ment for multiple tax periods to ensure
such payments are accurately credited
to the correct tax period. Full payment
of the liabilities under this second ERC
Voluntary Disclosure Program should be
made by the date the closing agreement
described in subsection (3) is executed
by the participant. Participants who are
unable to remit full payment of the 85%
of claimed ERC may be considered for
an alternative payment arrangement such
as an installment agreement, pending
approval.
(3) Closing Agreement
After receiving the requested informa-
tion, the IRS will prepare a closing agree-
ment under section 7121 of the Code in
accordance with the terms of the settle-
ment.
The IRS will mail the closing agree-
ment to the participant who must sign
and return it to the IRS within 10 days of
the date of mailing by the IRS. The IRS
may grant an extension for good cause to
participants who request additional time

Bulletin No. 2024–36 583 September 3, 2024
within the 10-day period. Full payment
of the liabilities under this second ERC
Voluntary Disclosure Program should be
made by the date the closing agreement
is executed by the participant.
As discussed in Section 4(2), partic-
ipants who are unable to remit full pay-
ment of the liabilities under this second
ERC Voluntary Disclosure Program may
be considered for an alternative payment
arrangement such as an installment agree-
ment, pending approval.
(4) Other Matters
(a) Denial of a participant’s request to
participate in this second ERC Volun-
tary Disclosure Program is not sub-
ject to judicial review or administra-
tive appeal.
(b) Execution of a closing agreement
under this second ERC Voluntary Dis-
closure Program does not preclude the
IRS from investigating any associated
criminal conduct or recommending
prosecution for violation of any crim-
inal statute and does not provide any
immunity from prosecution.
CONTACT INFORMATION
The principal author of this announce-
ment is Michael Franklin of the Office of
the Associate Chief Counsel (Procedure
and Administration). If you need help
completing Form 15434, have questions
on the status of your ERC Voluntary
Disclosure Program application, or have
other ERC Voluntary Disclosure Program
related questions, contact the ERC Volun-
tary Disclosure hotline at 414-231-2222
(not a toll-free number).

Bulletin No. 2024–36 i September 3, 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.

September 3, 2024 ii Bulletin No. 2024–36
Numerical Finding List
1
Bulletin 2024–36
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
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
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
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
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
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
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. 2024–36 iii September 3, 2024
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2024–36
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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