Internal Revenue Bulletin 2024-24 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2024–24
June 10, 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
Rev. Rul. 2024-11, page 1459.
Interest rates: underpayments and overpayments. The
rates for interest determined under Section 6621 of the
code for the calendar quarter beginning July 1, 2024, will
be 8 percent for overpayments (7 percent in the case of a
corporation), 8 percent for underpayments, and 10 percent
for large corporate underpayments. The rate of interest
paid on the portion of a corporate overpayment exceeding
$10,000 will be 5.5 percent.
EMPLOYEE PLANS
Notice 2024-40, page 1612.
This notice sets forth updates on the corporate bond
monthly yield curve, the corresponding spot segment rates
for April 2024 used under § 417(e)(3)(D), the 24-month
average segment rates applicable for May 2024, and the
30-year Treasury rates, as reflected by the application of §
430(h)(2)(C)(iv).
EXEMPT ORGANIZATIONS
Announcement 2024-22, page 1673.
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 deduct-
ible under IRC 170(b)(1)(A).
Announcement 2024-23, page 1674.
The Internal Revenue Service has revoked its determina-
tion that Functional Health Inc qualifies as an organization
described in sections 501(c )(3) and 170(c )(2) of the Inter-
nal Revenue Code of 1986. The revocation is effective Jan-
uary 31, 2018. If a suite for declaratory judgment has been
timely filed, contributions from individuals and organizations
described in section 170(c )(2) that are otherwise allow-
able will continue to be deductible. Protection under section
7428(c ) would begin on January 1, 2018 and would end on
the date the court first determines the organization is not
described in section 170(c )(2) as more particularly set for
in section 7428(c )(1). For individual contributions, the max-
imum deduction protected is $1,000, with a husband and
wife treated as one contributor. This benefit is not extended
to any individual, in whole or in part, for the acts or omis-
sions of the organization that were the basis for revocation.
INCOME TAX
Announcement 2024-24, page 1675.
This announcement notifies taxpayers of the applicable Ref-
erence Standard 90.1 required under § 179D(c)(2) of the
Internal Revenue Code as part of the definition of energy effi-
cient commercial building property (EECBP). This announce-
ment supplements and supersedes Announcement 2023-1,
2023-3 I.R.B. 422 (2023), by affirming ASHRAE/IES Ref-
erence Standard 90.1-2022 as the applicable Reference
Standard 90.1 for EECBP placed in service after December
31, 2028, and the construction of which did not begin by
December 31, 2022.
Notice 2024-36, page 1479.
This notice clarifies and amplifies the previously established
§ 48C(e) guidance and allocation procedures published in
Notices 2023-18 and 2023-44 by announcing the second
round of credit allocations under the § 48C(e) program to
allocate approximately $6 billion of § 48C credits, with
approximately $2.4 billion in § 48C credits to be allocated
to projects located in § 48C(e) Energy Communities Census
Tracts. The notice also updates appendices A, B and C.
Appendix A and B clarify § 48C(e) program priorities for this
second round of allocations. Appendix C updates the list of
§ 48C(e) Energy Communities Census Tracts.
Finding Lists begin on page ii.

Notice 2024-39, page 1611.
This notice publishes the inflation adjustment factor for the
carbon oxide sequestration credit under § 45Q for calen-
dar year 2024. The inflation adjustment factor is used to
determine the amount of the credit allowable under § 45Q
for taxpayers that make an election under § 45Q(b)(3) to
have the dollar amounts applicable under § 45Q(a)(1) or
(2) apply. This notice also obsoletes Notice 2009-83 and
Notice 2011-25.
Notice 2024-41, page 1615.
This notice modifies the existing domestic content safe
harbor in Notice 2023-38, 2023-22 I.R.B. 872, by expand-
ing the non-exclusive list of “Applicable Projects” in “Table
2--Categorization of Applicable Project Components” from
Notice 2023-38 to include hydropower and pumped hydro-
power storage facilities, redesignating the “Utility scale pho-
tovoltaic system” Applicable Project as “Ground-mount and
rooftop photovoltaic system,” and including certain Manu-
factured Product Components for previously listed Applica-
ble Projects for the domestic content bonus credit amounts
under §§ 45, 45Y, 48, and 48E of the Internal Revenue
Code. The notice also provides a new elective safe harbor
that taxpayers may use to classify Applicable Project Com-
ponents and to calculate the Domestic Cost Percentage in
an Applicable Project to qualify for the domestic content
bonus credit amounts, and requests comments regarding
the new elective safe harbor to inform the development of
any future updates.
REG-124850-08, page 1624.
U.S. persons must report information about, and pay
income taxes with respect to, certain transactions with for-
eign trusts. U.S. persons also must report information to
the IRS when they receive large gifts, bequests, devises, or
inheritances (foreign gifts) from foreign persons. The pro-
posed regulations describe the transactions and the foreign
gifts that must be reported to the IRS, as well as identify
the U.S. persons who must report them and pay any cor-
responding income taxes. U.S. persons who fail to timely
report this information to the IRS are subject to significant
penalties, and the proposed regulations provide guidance
regarding these penalties. Additionally, U.S. persons are
treated as the owners of certain foreign trusts that have
U.S. beneficiaries. The proposed regulations explain which
foreign trusts have U.S. beneficiaries and identify the U.S.
persons who are treated as the owners of these foreign
trusts. REG-124850-08. Published May 8, 2024.

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.
June 10, 2024 Bulletin No. 2024–24

Part I
Section 6621.—
Determination of Rate of
Interes
26 CFR 301.6621-1: Interest rate.
Rev. Rul. 2024-11
Section 6621 of the Internal Reve-
nue Code establishes the interest rates
on overpayments and underpayments of
tax. Under section 6621(a)(1), the over-
payment rate is the sum of the federal
short-term rate plus 3 percentage points (2
percentage points in the case of a corpo-
ration), except the rate for the portion of
a corporate overpayment of tax exceeding
$10,000 for a taxable period is the sum
of the federal short-term rate plus 0.5 of
a percentage point. Under section 6621(a)
(2), the underpayment rate is the sum of
the federal short-term rate plus 3 percent-
age points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under section
6621(a)(2) is determined by substituting
“5 percentage points” for “3 percentage
points.” See section 6621(c) and section
301.6621-3 of the Regulations on Proce-
dure and Administration for the definition
of a large corporate underpayment and
for the rules for determining the appli-
cable date. Section 6621(c) and section
301.6621-3 are generally effective for
periods after December 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal short-
term rate for the first month in each cal-
endar quarter. Section 6621(b)(2)(A)
provides that the federal short-term rate
determined under section 6621(b)(1) for
any month applies during the first calen-
dar quarter beginning after that month.
Section 6621(b)(3) provides that the fed-
eral short-term rate for any month is the
federal short-term rate determined during
that month by the Secretary in accordance
with section 1274(d), rounded to the near-
est full percent (or, if a multiple of 1/2 of
1 percent, the rate is increased to the next
highest full percent).
Notice 88-59, 1988-1 C.B. 546,
announced that in determining the quar-
terly interest rates to be used for overpay-
ments and underpayments of tax under
section 6621, the Internal Revenue Ser-
vice will use the federal short-term rate
based on daily compounding because that
rate is most consistent with section 6621
which, pursuant to section 6622, is subject
to daily compounding.
The federal short-term rate deter-
mined in accordance with section
1274(d) during April 2024 is the rate
published in Revenue Ruling 2024-9,
2024-19 IRB 964, to take effect begin-
ning May 1, 2024. The federal short-term
rate, rounded to the nearest full percent,
based on daily compounding determined
during the month of April 2024 is 5 per-
cent. Accordingly, an overpayment rate
of 8 percent (7 percent in the case of a
corporation) and an underpayment rate
of 8 percent are established for the calen-
dar quarter beginning July 1, 2024. The
overpayment rate for the portion of a cor-
porate overpayment exceeding $10,000
for the calendar quarter beginning July 1,
2024, is 5.5 percent. The underpayment
rate for large corporate underpayments
for the calendar quarter beginning July 1,
2024, is 10 percent. These rates apply to
amounts bearing interest during that cal-
endar quarter.
Sections 6654(a)(1) and 6655(a)
(1) provide that the underpayment rate
established under section 6621 applies
in determining the addition to tax under
sections 6654 and 6655 for failure to pay
estimated tax for any taxable year. Thus,
the 8 percent rate also applies to estimated
tax underpayments for the third calendar
quarter beginning July 1, 2024. In addi-
tion, pursuant to section 6603(d)(4), the
rate of interest on section 6603 deposits is
5 percent for the third calendar quarter in
2024.
Interest factors for daily compound
interest for annual rates of 5.5 percent, 7
percent, 8 percent and 10 percent are pub-
lished in Tables 64, 67, 69 and 73 of Rev.
Proc. 95-17, 1995-1 C.B. 618, 621, 623,
and 627.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Casey R. Conrad of the Office of
the Associate Chief Counsel (Procedure
and Administration). For further informa-
tion regarding this revenue ruling, contact
Mr. Conrad at (202) 317-6844 (not a toll-
free call).
Bulletin No. 2024–24 1459 June 10, 2024

APPENDIX A
365 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013699630.0008633801250.001713784
20.000027397640.0008770911260.001727506
30.000041096650.0008908011270.001741228
40.000054796660.0009045121280.001754951
50.000068495670.0009182231290.001768673
60.000082195680.0009319341300.001782396
70.000095894690.0009456461310.001796119
80.000109594700.0009593571320.001809843
90.000123294710.0009730691330.001823566
100.000136995720.0009867811340.001837290
110.000150695730.0010004931350.001851013
120.000164396740.0010142061360.001864737
130.000178097750.0010279181370.001878462
140.000191798760.0010416311380.001892186
150.000205499770.0010553441390.001905910
160.000219201780.0010690571400.001919635
170.000232902790.0010827701410.001933360
180.000246604800.0010964841420.001947085
190.000260306810.0011101971430.001960811
200.000274008820.0011239111440.001974536
210.000287711830.0011376251450.001988262
220.000301413840.0011513391460.002001988
230.000315116850.0011650541470.002015714
240.000328819860.0011787681480.002029440
250.000342522870.0011924831490.002043166
260.000356225880.0012061981500.002056893
270.000369929890.0012199131510.002070620
280.000383633900.0012336291520.002084347
290.000397336910.0012473441530.002098074
300.000411041920.0012610601540.002111801
310.000424745930.0012747761550.002125529
320.000438449940.0012884921560.002139257
330.000452154950.0013022081570.002152985
340.000465859960.0013159251580.002166713
350.000479564970.0013296411590.002180441
360.000493269980.0013433581600.002194169
370.000506974990.0013570751610.002207898
380.0005206801000.0013707921620.002221627
390.0005343861010.0013845101630.002235356
400.0005480921020.0013982271640.002249085
410.0005617981030.0014119451650.002262815
June 10, 2024 1460 Bulletin No. 2024–24

Bulletin No. 2024–24 1461 June 10, 2024
420.0005755041040.0014256631660.002276544
430.0005892111050.0014393811670.002290274
440.0006029171060.0014531001680.002304004
450.0006166241070.0014668181690.002317734
460.0006303311080.0014805371700.002331465
470.0006440391090.0014942561710.002345195
480.0006577461100.0015079751720.002358926
490.0006714541110.0015216941730.002372657
500.0006851611120.0015354141740.002386388
510.0006988691130.0015491331750.002400120
520.0007125781140.0015628531760.002413851
530.0007262861150.0015765731770.002427583
540.0007399951160.0015902931780.002441315
550.0007537031170.0016040141790.002455047
560.0007674121180.0016177341800.002468779
570.0007811211190.0016314551810.002482511
580.0007948311200.0016451761820.002496244
590.0008085401210.0016588971830.002509977
600.0008222501220.0016726191840.002523710
610.0008359601230.001686340
620.0008496701240.001700062

June 10, 2024 1462 Bulletin No. 2024–24
366 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013661630.0008610201250.001709097
20.000027323640.0008746931260.001722782
30.000040984650.0008883661270.001736467
40.000054646660.0009020401280.001750152
50.000068308670.0009157131290.001763837
60.000081970680.0009293871300.001777522
70.000095632690.0009430611310.001791208
80.000109295700.0009567351320.001804893
90.000122958710.0009704091330.001818579
100.000136620720.0009840841340.001832265
110.000150283730.0009977581350.001845951
120.000163947740.0010114331360.001859638
130.000177610750.0010251081370.001873324
140.000191274760.0010387831380.001887011
150.000204938770.0010524591390.001900698
160.000218602780.0010661341400.001914385
170.000232266790.0010798101410.001928073
180.000245930800.0010934861420.001941760
190.000259595810.0011071621430.001955448
200.000273260820.0011208391440.001969136
210.000286924830.0011345151450.001982824
220.000300590840.0011481921460.001996512
230.000314255850.0011618691470.002010201
240.000327920860.0011755461480.002023889
250.000341586870.0011892231490.002037578
260.000355252880.0012029001500.002051267
270.000368918890.0012165781510.002064957
280.000382584900.0012302561520.002078646
290.000396251910.0012439341530.002092336
300.000409917920.0012576121540.002106025
310.000423584930.0012712911550.002119715
320.000437251940.0012849691560.002133405
330.000450918950.0012986481570.002147096
340.000464586960.0013123271580.002160786
350.000478253970.0013260061590.002174477
360.000491921980.0013396851600.002188168
370.000505589990.0013533651610.002201859
380.0005192571000.0013670441620.002215550
390.0005329251010.0013807241630.002229242
400.0005465941020.0013944041640.002242933
410.0005602621030.0014080851650.002256625
420.0005739311040.0014217651660.002270317

Bulletin No. 2024–24 1463 June 10, 2024
430.0005876001050.0014354461670.002284010
440.0006012691060.0014491271680.002297702
450.0006149391070.0014628081690.002311395
460.0006286081080.0014764891700.002325087
470.0006422781090.0014901701710.002338780
480.0006559481100.0015038521720.002352473
490.0006696181110.0015175331730.002366167
500.0006832891120.0015312151740.002379860
510.0006969591130.0015448971750.002393554
520.0007106301140.0015585801760.002407248
530.0007243011150.0015722621770.002420942
540.0007379721160.0015859451780.002434636
550.0007516431170.0015996281790.002448331
560.0007653151180.0016133111800.002462025
570.0007789861190.0016269941810.002475720
580.0007926581200.0016406781820.002489415
590.0008063301210.0016543611830.002503110
600.0008200031220.0016680451840.002516806
610.0008336751230.001681729
620.0008473481240.001695413

June 10, 2024 1464 Bulletin No. 2024–24
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 – PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATEIn 1995-1 C.B.
DAILY RATE TABLE
Before Jul. 1, 19756%Table2,pg.557
Jul. 1, 1975–Jan. 31, 19769%Table4,pg.559
Feb. 1, 1976–Jan. 31, 19787%Table3,pg.558
Feb. 1, 1978–Jan. 31, 19806%Table2,pg.557
Feb. 1, 1980–Jan. 31, 198212%Table5,pg.560
Feb. 1, 1982–Dec. 31, 198220%Table6,pg.560
Jan. 1, 1983–Jun. 30, 198316%Table37,pg.591
Jul. 1, 1983–Dec. 31, 198311%Table27,pg.581
Jan. 1, 1984–Jun. 30, 198411%Table75,pg.629
Jul. 1, 1984–Dec. 31, 198411%Table75,pg.629
Jan. 1, 1985–Dec. 31, 198513%Table31,pg.585
Jul. 1, 1985–Dec. 31, 198511%Table27,pg.581
Jan. 1, 1986–Jun. 30, 198610%Table25,pg.579
Jul. 1, 1986–Dec. 31, 19869%Table23,pg.577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 – Dec. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B. RATE
RATETABLEPGRATETABLEPG
Jan. 1, 1987–Mar. 31, 19878%215759%23577
Apr. 1, 1987–Jun. 30, 19878%215759%23577
Jul. 1, 1987–Sep. 30, 19878%215759%23577
Oct. 1, 1987–Dec. 31, 19879%2357710%25579
Jan. 1, 1988–Mar. 31, 198810%7362711%75629
Apr. 1, 1988–Jun. 30, 19889%7162510%73627
Jul. 1, 1988–Sep. 30, 19889%7162510%73627
Oct. 1, 1988–Dec. 31, 198810%7362711%75629
Jan. 1, 1989–Mar. 31, 198910%2557911%27581
Apr. 1, 1989–Jun. 30, 198911%2758112%29583
Jul. 1, 1989–Sep. 30, 198911%2758112%29583
Oct. 1, 1989–Dec. 31, 198910%2557911%27581
Jan. 1, 1990–Mar. 31, 199010%2557911%27581
Apr. 1, 1990–Jun. 30, 199010%2557911%27581
Jul. 1, 1990–Sep. 30, 199010%2557911%27581
Oct. 1, 1990–Dec. 31, 199010%2557911%27581
Jan. 1, 1991–Mar. 31, 199110%2557911%27581
Apr. 1, 1991–Jun. 30, 19919%2357710%25579
Jul. 1, 1991–Sep. 30, 19919%2357710%25579
Oct. 1, 1991–Dec. 31, 19919%2357710%25579
Jan. 1, 1992–Mar. 31, 19928%696239%71625
Apr. 1, 1992–Jun. 30, 19927%676218%69623

Bulletin No. 2024–24 1465 June 10, 2024
Jul. 1, 1992–Sep. 30, 19927%676218%69623
Oct. 1, 1992–Dec. 31, 19926%656197%67621
Jan. 1, 1993–Mar. 31, 19936%175717%19573
Apr. 1, 1993–Jun. 30, 19936%175717%19573
Jul. 1, 1993–Sep. 30, 19936%175717%19573
Oct. 1, 1993–Dec. 31, 19936%175717%19573
Jan. 1, 1994–Mar. 31, 19946%175717%19573
Apr. 1, 1994–Jun. 30, 19946%175717%19573
Jul. 1, 1994–Sep. 30, 19947%195738%21575
Oct. 1, 1994–Dec. 31, 19948%215759%23577
Jan. 1, 1995–Mar. 31, 19958%215759%23577
Apr. 1, 1995–Jun. 30, 19959%2357710%25579
Jul. 1, 1995–Sep. 30, 19958%215759%23577
Oct. 1, 1995–Dec. 31, 19958%215759%23577
Jan. 1, 1996–Mar. 31, 19968%696239%71625
Apr. 1, 1996–Jun. 30, 19967%676218%69623
Jul. 1, 1996–Sep. 30, 19968%696239%71625
Oct. 1, 1996–Dec. 31, 19968%696239%71625
Jan. 1, 1997–Mar. 31, 19978%215759%23577
Apr. 1, 1997–Jun. 30, 19978%215759%23577
Jul. 1, 1997–Sep. 30, 19978%215759%23577
Oct. 1, 1997–Dec. 31, 19978%215759%23577
Jan. 1, 1998–Mar. 31, 19988%215759%23577
Apr. 1, 1998–Jun. 30, 19987%195738%21575
Jul. 1, 1998–Sep. 30, 19987%195738%21575
Oct. 1, 1998–Dec. 31, 19987%195738%21575

June 10, 2024 1466 Bulletin No. 2024–24
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 – PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995-1 C.B.
RATETABLEPAGE
Jan. 1, 1999–Mar. 31, 19997%19573
Apr. 1, 1999–Jun. 30, 19998%21575
Jul. 1, 1999–Sep. 30, 19998%21575
Oct. 1, 1999–Dec. 31, 19998%21575
Jan. 1, 2000–Mar. 31, 20008%69623
Apr. 1, 2000–Jun. 30, 20009%71625
Jul. 1, 2000–Sep. 30, 20009%71625
Oct. 1, 2000–Dec. 31, 20009%71625
Jan. 1, 2001–Mar. 31, 20019%23577
Apr. 1, 2001–Jun. 30, 20018%21575
Jul. 1, 2001–Sep. 30, 20017%19573
Oct. 1, 2001–Dec. 31, 20017%19573
Jan. 1, 2002–Mar. 31, 20026%17571
Apr. 1, 2002–Jun. 30, 20026%17571
Jul. 1, 2002–Sep. 30, 20026%17571
Oct. 1, 2002–Dec. 31, 20026%17571
Jan. 1, 2003–Mar. 31, 20035%15569
Apr. 1, 2003–Jun. 30, 20035%15569
Jul. 1, 2003–Sep. 30, 20035%15569
Oct. 1, 2003–Dec. 31, 20034%13567
Jan. 1, 2004–Mar. 31, 20044%61615
Apr. 1, 2004–Jun. 30, 20045%63617
Jul. 1, 2004–Sep. 30, 20044%61615
Oct. 1, 2004–Dec. 31, 20045%63617
Jan. 1, 2005–Mar. 31, 20055%15569
Apr. 1, 2005–Jun. 30, 20056%17571
Jul. 1, 2005–Sep. 30, 20056%17571
Oct. 1, 2005–Dec. 31, 20057%19573
Jan. 1, 2006–Mar. 31, 20067%19573
Apr. 1, 2006–Jun. 30, 20067%19573
Jul. 1, 2006–Sep. 30, 20068%21575
Oct. 1, 2006–Dec. 31, 20068%21575
Jan. 1, 2007–Mar. 31, 20078%21575
Apr. 1, 2007–Jun. 30, 20078%21575
Jul. 1, 2007–Sep. 30, 20078%21575
Oct. 1, 2007–Dec. 31, 20078%21575
Jan. 1, 2008–Mar. 31, 20087%67621
Apr. 1, 2008–Jun. 30, 20086%65619
Jul. 1, 2008–Sep. 30, 20085%63617
Oct. 1, 2008–Dec. 31, 20086%65619
Jan. 1, 2009–Mar. 31, 20095%15569

Bulletin No. 2024–24 1467 June 10, 2024
Apr. 1, 2009–Jun. 30, 20094%13567
Jul. 1, 2009–Sep. 30, 20094%13567
Oct. 1, 2009–Dec. 31, 20094%13567
Jan. 1, 2010–Mar. 31, 20104%13567
Apr. 1, 2010–Jun. 30, 20104%13567
Jul. 1, 2010–Sep. 30, 20104%13567
Oct. 1, 2010–Dec. 31, 20104%13567
Jan. 1, 2011–Mar. 31, 20113%11565
Apr. 1, 2011–Jun. 30, 20114%13567
Jul. 1, 2011–Sep. 30, 20114%13567
Oct. 1, 2011–Dec. 31, 20113%11565
Jan. 1, 2012–Mar. 31, 20123%59613
Apr. 1, 2012–Jun. 30, 20123%59613
Jul. 1, 2012–Sep. 30, 20123%59613
Oct. 1, 2012–Dec. 31, 20123%59613
Jan. 1, 2013–Mar. 31, 20133%11565
Apr. 1, 2013–Jun. 30, 20133%11565
Jul. 1, 2013–Sep. 30, 20133%11565
Oct. 1, 2013–Dec. 31, 20133%11565
Jan. 1, 2014–Mar. 31, 20143%11565
Apr. 1, 2014–Jun. 30, 20143%11565
Jul. 1, 2014–Sep. 30, 20143%11565
Oct. 1, 2014–Dec. 31, 20143%11565
Jan. 1, 2015–Mar. 31, 20153%11565
Apr. 1, 2015–Jun. 30, 20153%11565
Jul. 1, 2015–Sep. 30, 20153%11565
Oct. 1, 2015–Dec. 31, 20153%11565
Jan. 1, 2016–Mar. 31, 20163%59613
Apr. 1, 2016–Jun. 30, 20164%61615
Jul. 1, 2016–Sep. 30, 20164%61615
Oct. 1, 2016–Dec. 31, 20164%61615
Jan. 1, 2017–Mar. 31, 20174%13567
Apr. 1, 2017–Jun. 30, 20174%13567
Jul. 1, 2017–Sep. 30, 20174%13567
Oct. 1, 2017–Dec. 31, 20174%13567
Jan. 1, 2018–Mar. 31, 20184%13567
Apr. 1, 2018–Jun. 30, 20185%15569
Jul. 1, 2018–Sep. 30, 20185%15569
Oct. 1, 2018–Dec. 31, 20185%15569
Jan. 1, 2019–Mar. 31, 20196%17571
Apr. 1, 2019–Jun. 30, 20196%17571
Jul. 1, 2019–Sep. 30, 20195%15569
Oct. 1, 2019–Dec. 31, 20195%15569
Jan. 1, 2020–Mar. 31, 20205%63617
Apr. 1, 2020–Jun. 30, 20205%63617

June 10, 2024 1468 Bulletin No. 2024–24
Jul. 1, 2020–Sep. 30, 20203%59613
Oct. 1, 2020–Dec. 31, 20203%59613
Jan. 1, 2021–Mar. 31, 20213%11565
Apr. 1, 2021–Jun. 30, 20213%11565
Jul. 1, 2021–Sep. 30, 20213%11565
Oct. 1, 2021–Dec. 31, 20213%11565
Jan. 1, 2022–Mar. 31, 20223%11565
Apr. 1, 2022–Jun. 30, 20224%13567
Jul. 1, 2022–Sep. 30, 20225%15569
Oct. 1, 2022–Dec. 31, 20226%17571
Jan. 1, 2023–Mar. 31, 20237%19573
Apr. 1, 2023–Jun. 30, 20237%19573
Jul. 1, 2023–Sep. 30, 2023 7%19573
Oct. 1, 2023–Dec. 31, 20238%21575
Jan. 1, 2024–Mar. 31, 20248%69623
Apr. 1, 2024–Jun. 30, 20248%69623
Jul. 1, 2024–Sep. 30, 20248%69623

Bulletin No. 2024–24 1469 June 10, 2024
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 – PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B.
RATETABLEPGRATETABLEPG
Jan. 1, 1999–Mar. 31, 19996%175717%19573
Apr. 1, 1999–Jun. 30, 19997%195738%21575
Jul. 1, 1999–Sep. 30, 19997%195738%21575
Oct. 1, 1999–Dec. 31, 19997%195738%21575
Jan. 1, 2000–Mar. 30, 20007%676218%69623
Apr. 1, 2000–Jun. 30, 20008%696239%71625
Jul. 1, 2000–Sep. 30, 20008%696239%71625
Oct. 1, 2000–Dec. 31, 20008%696239%71625
Jan. 1, 2001–Mar. 31, 20018%215759%23577
Apr. 1, 2001–Jun. 30, 20017%195738%21575
Jul. 1, 2001–Sep. 30, 20016%175717%19573
Oct. 1, 2001–Dec. 31, 20016%175717%19573
Jan. 1, 2002–Mar. 31, 20025%155696%17571
Apr. 1, 2002–Jun. 30, 20025%155696%17571
Jul. 1, 2002–Sep. 30, 20025%155696%17571
Oct. 1, 2002–Dec. 31, 20025%155696%17571
Jan. 1, 2003–Mar. 31, 20034%135675%15569
Apr. 1, 2003–Jun. 30, 20034%135675%15569
Jul. 1, 2003–Sep. 30, 20034%135675%15569
Oct. 1, 2003–Dec. 31, 20033%115654%13567
Jan. 1, 2004–Mar. 31, 20043%596134%61615
Apr. 1, 2004–Jun. 30, 20044%616155%63617
Jul. 1, 2004–Sep. 30, 20043%596134%61615
Oct. 1, 2004–Dec. 31, 20044%616155%63617
Jan. 1, 2005–Mar. 31, 20054%135675%15569
Apr. 1, 2005–Jun. 30, 20055%155696%17571
Jul. 1, 2005–Sep. 30, 20055%155696%17571
Oct. 1, 2005–Dec. 31, 20056%175717%19573
Jan. 1, 2006–Mar. 31, 20066%175717%19573
Apr. 1, 2006–Jun. 30, 20066%175717%19573
Jul. 1, 2006–Sep. 30, 20067%195738%21575
Oct. 1, 2006–Dec. 31, 20067%195738%21575
Jan. 1, 2007–Mar. 31, 20077%195738%21575
Apr. 1, 2007–Jun. 30, 20077%195738%21575
Jul. 1, 2007–Sep. 30, 20077%195738%21575
Oct. 1, 2007–Dec. 31, 20077%195738%21575
Jan. 1, 2008–Mar. 31, 20086%656197%67621
Apr. 1, 2008–Jun. 30, 20085%636176%65619
Jul. 1, 2008–Sep. 30, 20084%616155%63617
Oct. 1, 2008–Dec. 31, 20085%636176%65619

June 10, 2024 1470 Bulletin No. 2024–24
Jan. 1, 2009–Mar. 31, 20094%135675%15569
Apr. 1, 2009–Jun. 30, 20093%115654%13567
Jul. 1, 2009–Sep. 30, 20093%115654%13567
Oct. 1, 2009–Dec. 31, 20093%115654%13567
Jan. 1, 2010–Mar. 31, 20103%115654%13567
Apr. 1, 2010–Jun. 30, 20103%115654%13567
Jul. 1, 2010–Sep. 30, 20103%115654%13567
Oct. 1, 2010–Dec. 31, 20103%115654%13567
Jan. 1, 2011–Mar. 31, 20112%95633%11565
Apr. 1, 2011–Jun. 30, 20113%115654%13567
Jul. 1, 2011–Sep. 30, 20113%115654%13567
Oct. 1, 2011–Dec. 31, 20112%95633%11565
Jan. 1, 2012–Mar. 31, 20122%576113%59613
Apr. 1, 2012–Jun. 30, 20122%576113%59613
Jul. 1, 2012–Sep. 30, 20122%576113%59613
Oct. 1, 2012–Dec. 31, 20122%576113%59613
Jan. 1, 2013–Mar. 31, 20132%95633%11565
Apr. 1, 2013–Jun. 30, 20132%95633%11565
Jul. 1, 2013–Sep. 30, 20132%95633%11565
Oct. 1, 2013–Dec. 31, 20132%95633%11565
Jan. 1, 2014–Mar. 31, 20142%95633%11565
Apr. 1, 2014–Jun. 30, 20142%95633%11565
Jul. 1, 2014–Sep. 30, 20142%95633%11565
Oct. 1, 2014–Dec. 31, 20142%95633%11565
Jan. 1, 2015–Mar. 31, 20152%95633%11565
Apr. 1, 2015–Jun. 30, 20152%95633%11565
Jul. 1, 2015–Sep. 30, 20152%95633%11565
Oct. 1, 2015–Dec. 31, 20152%95633%11565
Jan. 1, 2016–Mar. 31, 20162%576113%59613
Apr. 1, 2016–Jun. 30, 20163%596134%61615
Jul. 1, 2016–Sep. 30, 20163%596134%61615
Oct. 1, 2016–Dec. 31, 20163%596134%61615
Jan. 1, 2017–Mar. 31, 20173%115654%13567
Apr. 1, 2017–Jun. 30, 20173%115654%13567
Jul. 1, 2017–Sep. 30, 20173%115654%13567
Oct. 1, 2017–Dec. 31, 20173%115654%13567
Jan. 1, 2018–Mar. 31, 20183%115654%13567
Apr. 1, 2018–Jun. 30, 20184%135675%15569
Jul. 1, 2018–Sep. 30, 20184%135675%15569
Oct. 1, 2018–Dec. 31, 20184%135675%15569
Jan. 1, 2019–Mar. 31, 20195%155696%17571
Apr. 1, 2019–Jun. 30, 20195%155696%17571
Jul. 1, 2019–Sep. 30, 20194%135675%15569
Oct. 1, 2019–Dec. 31, 20194%135675%15569
Jan. 1, 2020–Mar. 31, 20204%616155%63617

Bulletin No. 2024–24 1471 June 10, 2024
Apr. 1, 2020–Jun. 30, 20204%616155%63617
Jul. 1, 2020–Sep. 30, 20202%576113%59613
Oct. 1, 2020–Dec. 31, 20202%576113%59613
Jan. 1, 2021–Mar. 31, 20212%95633%11565
Apr. 1, 2021–Jun. 30, 20212%95633%11565
Jul. 1, 2021–Sep. 30, 20212%95633%11565
Oct. 1, 2021–Dec. 31, 20212%95633%11565
Jan. 1, 2022–Mar. 31, 20222%95633%11565
Apr. 1, 2022–Jun. 30, 20223%115654%13567
Jul. 1, 2022–Sep. 30, 20224%135675%15569
Oct. 1, 2022–Dec. 31, 20225%155696%17571
Jan. 1, 2023–Mar. 31, 20236%175717%19573
Apr. 1, 2023–Jun. 30, 20236%175717%19573
Jul. 1, 2023–Sep. 30, 20236%175717%19573
Oct. 1, 2023–Dec. 31, 20237%195738%21575
Jan. 1, 2024–Mar. 31, 20247%676218%69623
Apr. 1, 2024–Jun. 30, 20247%676218%69623
Jul. 1, 2024–Sep. 30, 20247%676218%69623

June 10, 2024 1472 Bulletin No. 2024–24
TABLE OF INTEREST RATES
FOR LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 – PRESENT
1995-1 C.B.
RATETABLEPG
Jan. 1, 1991–Mar. 31, 199113%31585
Apr. 1, 1991–Jun. 30, 199112%29583
Jul. 1, 1991–Sep. 30, 199112%29583
Oct. 1, 1991–Dec. 31, 199112%29583
Jan. 1, 1992–Mar. 31, 199211%75629
Apr. 1, 1992–Jun. 30, 199210%73627
Jul. 1, 1992–Sep. 30, 199210%73627
Oct. 1, 1992–Dec. 31, 19929%71625
Jan. 1, 1993–Mar. 31, 19939%23577
Apr. 1, 1993–Jun. 30, 19939%23577
Jul. 1, 1993–Sep. 30, 19939%23577
Oct. 1, 1993–Dec. 31, 19939%23577
Jan. 1, 1994–Mar. 31, 19949%23577
Apr. 1, 1994–Jun. 30, 19949%23577
Jul. 1, 1994–Sep. 30, 199410%25579
Oct. 1, 1994–Dec. 31, 199411%27581
Jan. 1, 1995–Jun. 30, 199511%27581
Apr. 1, 1995–Jun. 30, 199512%29583
Jul. 1, 1995–Sep. 30, 199511%27581
Oct. 1, 1995–Dec. 31, 199511%27581
Jan. 1, 1996–Mar. 31, 199611%75629
Apr. 1, 1996–Jun. 30, 199610%73627
Jul. 1, 1996–Sep. 30, 199611%75629
Oct. 1, 1996–Dec. 31, 199611%75629
Jan. 1, 1997–Mar. 31, 199711%27581
Apr. 1, 1997–Jun. 30, 199711%27581
Jul. 1, 1997–Sep. 30, 199711%27581
Oct. 1, 1997–Dec. 31, 199711%27581
Jan. 1, 1998–Mar. 31, 199811%27581
Apr. 1, 1998–Jun. 30, 199810%25579
Jul. 1, 1998–Sep. 30, 199810%25579
Oct. 1, 1998–Dec. 31, 199810%25579
Jan. 1, 1999–Mar. 31, 19999%23577
Apr. 1, 1999–Jun. 30, 199910%25579
Jul. 1, 1999–Sep. 30, 199910%25579
Oct. 1, 1999–Dec. 31, 199910%25579
Jan. 1, 2000–Mar. 31, 200010%73627
Apr. 1, 2000–Jun. 30, 200011%75629
Jul. 1, 2000–Sep. 30, 200011%75629
Oct. 1, 2000–Dec. 31, 200011%75629
Jan. 1, 2001–Mar. 31, 200111%27581

Bulletin No. 2024–24 1473 June 10, 2024
Apr. 1, 2001–Jun. 30, 200110%25579
Jul. 1, 2001–Sep. 30, 20019%23577
Oct. 1, 2001–Dec. 31, 20019%23577
Jan. 1, 2002–Mar. 31, 20028%21575
Apr. 1, 2002–Sep. 30, 20028%21575
Jul. 1, 2002–Sep. 30, 20028%21575
Oct. 1, 2002–Dec. 31, 20028%21575
Jan. 1, 2003–Mar. 31, 20037%19573
Apr. 1, 2003–Jun. 30, 20037%19573
Jul. 1, 2003–Sep. 30, 20037%19573
Oct. 1, 2003–Dec. 31, 20036%17571
Jan. 1, 2004–Mar. 31, 20046%65619
Apr. 1, 2004–Jun. 30, 20047%67621
Jul. 1, 2004–Sep. 30, 20046%65619
Oct. 1, 2004–Dec. 31, 20047%67621
Jan. 1, 2005–Mar. 31, 20057%19573
Apr. 1, 2005–Jun. 30, 20058%21575
Jul. 1, 2005–Sep. 30, 20058%21575
Oct. 1, 2005–Dec. 31, 20059%23577
Jan. 1, 2006–Mar. 31, 20069%23577
Apr. 1, 2006–Jun. 30, 20069%23577
Jul. 1, 2006–Sep. 30, 200610%25579
Oct. 1, 2006–Dec. 31, 200610%25579
Jan. 1, 2007–Mar. 31, 200710%25579
Apr. 1, 2007–Jun. 30, 200710%25579
Jul. 1, 2007–Sep. 30, 200710%25579
Oct. 1, 2007–Dec. 31, 200710%25579
Jan. 1, 2008–Mar. 31, 20089%71625
Apr. 1, 2008–Sep. 30, 20088%69623
Jul. 1, 2008–Sep. 30, 20087%67621
Oct. 1, 2008–Dec. 31, 20088%69623
Jan. 1, 2009–Mar. 31, 20097%19573
Apr. 1, 2009–Jun. 30, 20096%17571
Jul. 1, 2009–Sep. 30, 20096%17571
Oct. 1, 2009–Dec. 31, 20096%17571
Jan. 1, 2010–Mar. 31, 20106%17571
Apr. 1, 2010–Jun. 30, 20106%17571
Jul. 1, 2010–Sep. 30, 20106%17571
Oct. 1, 2010–Dec. 31, 20106%17571
Jan. 1, 2011–Mar. 31, 20115%15569
Apr. 1, 2011–Jun. 30, 20116%17571
Jul. 1, 2011–Sep. 30, 20116%17571
Oct. 1, 2011–Dec. 31, 20115%15569
Jan. 1, 2012–Mar. 31, 20125%63617
Apr. 1, 2012–Jun. 30, 20125%63617

June 10, 2024 1474 Bulletin No. 2024–24
Jul. 1, 2012–Sep. 30, 20125%63617
Oct. 1, 2012–Dec. 31, 20125%63617
Jan. 1, 2013–Mar. 31, 20135%15569
Apr. 1, 2013–Jun. 30, 20135%15569
Jul. 1, 2013–Sep. 30, 20135%15569
Oct. 1, 2013–Dec. 31, 20135%15569
Jan. 1, 2014–Mar. 31, 20145%15569
Apr. 1, 2014–Jun. 30, 20145%15569
Jul. 1, 2014–Sep. 30, 20145%15569
Oct. 1, 2014–Dec. 31, 20145%15569
Jan. 1, 2015–Mar. 31, 20155%15569
Apr. 1, 2015–Jun. 30, 20155%15569
Jul. 1, 2015–Sep. 30, 20155%15569
Oct. 1, 2015–Dec. 31, 20155%15569
Jan. 1, 2016–Mar. 31, 20165%63617
Apr. 1, 2016–Jun. 30, 20166%65619
Jul. 1, 2016–Sep. 30, 20166%65619
Oct. 1, 2016–Dec. 31, 20166%65619
Jan. 1, 2017–Mar. 31, 20176%17571
Apr. 1, 2017–Jun. 30, 20176%17571
Jul. 1, 2017–Sep. 30, 20176%17571
Oct. 1, 2017–Dec. 31, 20176%17571
Jan. 1, 2018–Mar. 31, 20186%17571
Apr. 1, 2018–Jun. 30, 20187%19573
Jul. 1, 2018–Sep. 30, 20187%19573
Oct. 1, 2018–Dec. 31, 20187%19573
Jan. 1, 2019–Mar. 31, 20198%21575
Apr. 1, 2019–Jun. 30, 20198%21575
Jul. 1, 2019–Sep. 30, 20197%19573
Oct. 1, 2019–Dec. 31, 20197%19573
Jan. 1, 2020–Mar. 31, 20207%67621
Apr. 1, 2020–Jun. 30, 20207%67621
Jul. 1, 2020–Sep. 30, 20205%63617
Oct. 1, 2020–Dec. 31, 20205%63617
Jan. 1, 2021–Mar. 31, 20215%15569
Apr. 1, 2021–Jun. 30, 20215%15569
Jul. 1, 2021–Sep. 30, 20215%15569
Oct. 1, 2021–Dec. 31, 20215%15569
Jan. 1, 2022–Mar. 31, 20225%15569
Apr. 1, 2022–Jun. 30, 20226%17571
Jul. 1, 2022–Sep. 30, 20227%19573
Oct. 1, 2022–Dec. 31, 20228%21575
Jan. 1, 2023–Mar. 31, 20239%23577
Apr. 1, 2023–Jun. 30, 20239%23577
Jul. 1, 2023–Sep. 30, 20239%23577

Bulletin No. 2024–24 1475 June 10, 2024
Oct. 1, 2023–Dec. 31, 202310%25579
Jan. 1, 2024–Mar. 31, 202410%73627
Apr. 1, 2024–Jun. 30, 202410%73627
Jul. 1, 2024–Sep. 30, 202410%73627

June 10, 2024 1476 Bulletin No. 2024–24
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 – PRESENT
1995-1 C.B.
RATETABLEPG
Jan. 1, 1995–Mar. 31, 19956.5%18572
Apr. 1, 1995–Jun. 30, 19957.5%20574
Jul. 1, 1995–Sep. 30, 19956.5%18572
Oct. 1, 1995–Dec. 31, 19956.5%18572
Jan. 1, 1996–Mar. 31, 19966.5%66620
Apr. 1, 1996–Jun. 30, 19965.5%64618
Jul. 1, 1996–Sep. 30, 19966.5%66620
Oct. 1, 1996–Dec. 31, 19966.5%66620
Jan. 1, 1997–Mar. 31, 19976.5%18572
Apr. 1, 1997–Jun. 30, 19976.5%18572
Jul. 1, 1997–Sep. 30, 19976.5%18572
Oct. 1, 1997–Dec. 31, 19976.5%18572
Jan. 1, 1998–Mar. 31, 19986.5%18572
Apr. 1, 1998–Jun. 30, 19985.5%16570
Jul. 1, 1998–Sep. 30, 19985.5%16570
Oct. 1, 1998–Dec. 31, 19985.5%16570
Jan. 1, 1999–Mar. 31, 19994.5%14568
Apr. 1, 1999–Sep. 30, 19995.5%16570
Jul. 1, 1999–Sep. 30, 19995.5%16570
Oct. 1, 1999–Dec. 31, 19995.5%16570
Jan. 1, 2000–Mar. 31, 20005.5%64618
Apr. 1, 2000–Jun. 30, 20006.5%66620
Jul. 1, 2000–Sep. 30, 20006.5%66620
Oct. 1, 2000–Dec. 31, 20006.5%66620
Jan. 1, 2001–Mar. 31, 20016.5%18572
Apr. 1, 2001–Jun. 30, 20015.5%16570
Jul. 1, 2001–Sep. 30, 20014.5%14568
Oct. 1, 2001–Dec. 31, 20014.5%14568
Jan. 1, 2002–Mar. 31, 20023.5%12566
Apr. 1, 2002–Jun. 30, 20023.5%12566
Jul. 1, 2002–Sep. 30, 20023.5%12566
Oct. 1, 2002–Dec. 31, 20023.5%12566
Jan. 1, 2003–Mar. 31, 20032.5%10564
Apr. 1, 2003–Jun. 30, 20032.5%10564
Jul. 1, 2003–Sep. 30, 20032.5%10564
Oct. 1, 2003–Dec. 31, 20031.5%8562
Jan. 1, 2004–Mar. 31, 20041.5%56610
Apr. 1, 2004–Jun. 30, 20042.5%58612

Bulletin No. 2024–24 1477 June 10, 2024
Jul. 1, 2004–Sep. 30, 20041.5%56610
Oct. 1, 2004–Dec. 31, 20042.5%58612
Jan. 1, 2005–Mar. 31, 20052.5%10564
Apr. 1, 2005–Jun. 30, 20053.5%12566
Jul. 1, 2005–Sep. 30, 20053.5%12566
Oct. 1, 2005–Dec. 31, 20054.5%14568
Jan. 1, 2006–Mar. 31, 20064.5%14568
Apr. 1, 2006–Jun. 30, 20064.5%14568
Jul. 1, 2006–Sep. 30, 20065.5%16570
Oct. 1, 2006–Dec. 31, 20065.5%16570
Jan. 1, 2007–Mar. 31, 20075.5%16570
Apr. 1, 2007–Jun. 30, 20075.5%16570
Jul. 1, 2007–Sep. 30, 20075.5%16570
Oct. 1, 2007–Dec. 31, 20075.5%16570
Jan. 1, 2008–Mar. 31, 20084.5%62616
Apr. 1, 2008–Jun. 30, 20083.5%60614
Jul. 1, 2008–Sep. 30, 20082.5%58612
Oct. 1, 2008–Dec. 31, 20083.5%60614
Jan. 1, 2009–Mar. 31, 20092.5%10564
Apr. 1, 2009–Jun. 30, 20091.5%8562
Jul. 1, 2009–Sep. 30, 20091.5%8562
Oct. 1, 2009–Dec. 31, 20091.5%8562
Jan. 1, 2010–Mar. 31, 20101.5%8562
Apr. 1, 2010–Jun. 30, 20101.5%8562
Jul. 1, 2010–Sep. 30, 20101.5%8562
Oct. 1, 2010–Dec. 31, 20101.5%8562
Jan. 1, 2011–Mar. 31, 20110.5%*
Apr. 1, 2011–Jun. 30, 20111.5%8562
Jul. 1, 2011–Sep. 30, 20111.5%8562
Oct. 1, 2011–Dec. 31, 20110.5%*
Jan. 1, 2012–Mar. 31, 20120.5%*
Apr. 1, 2012–Jun. 30, 20120.5%*
Jul. 1, 2012–Sep. 30, 20120.5%*
Oct. 1, 2012–Dec. 31, 20120.5%*
Jan. 1, 2013–Mar. 31, 20130.5%*
Apr. 1, 2013–Jun. 30, 20130.5%*
Jul. 1, 2013–Sep. 30, 20130.5%*
Oct. 1, 2013–Dec. 31, 20130.5%*
Jan. 1, 2014–Mar. 31, 20140.5%*
Apr. 1, 2014–Jun. 30, 20140.5%*
Jul. 1, 2014–Sep. 30, 20140.5%*
Oct. 1, 2014–Dec. 31, 20140.5%*

June 10, 2024 1478 Bulletin No. 2024–24
Jan. 1, 2015–Mar. 31, 20150.5%*
Apr. 1, 2015–Jun. 30, 20150.5%*
Jul. 1, 2015–Sep. 30, 20150.5%*
Oct. 1, 2015–Dec. 31, 20150.5%*
Jan. 1, 2016–Mar. 31, 20160.5%*
Apr. 1, 2016–Jun. 30, 20161.5%56610
Jul. 1, 2016–Sep. 30, 20161.5%56610
Oct. 1, 2016–Dec. 31, 20161.5%56610
Jan. 1, 2017–Mar. 31, 20171.5%8562
Apr. 1, 2017–Jun. 30, 20171.5%8562
Jul. 1, 2017–Sep. 30, 20171.5%8562
Oct. 1, 2017–Dec. 31, 20171.5%8562
Jan. 1, 2018–Mar. 31, 20181.5%8562
Apr. 1, 2018–Jun. 30, 20182.5%10564
Jul. 1, 2018–Sep. 30, 20182.5%10564
Oct. 1, 2018–Dec. 31, 20182.5%10564
Jan. 1, 2019–Mar. 31, 20193.5%12566
Apr. 1, 2019–Jun. 30, 20193.5%12566
Jul. 1, 2019–Sep. 30, 20192.5%10564
Oct. 1, 2019–Dec. 31, 20192.5%10564
Jan. 1, 2020–Mar. 31, 20202.5%58612
Apr. 1, 2020–Jun. 30, 20202.5%58612
Jul. 1, 2020–Sep. 30, 20200.5%*
Oct. 1, 2020–Dec. 31, 20200.5%*
Jan. 1, 2021–Mar. 31, 20210.5%*
Apr. 1, 2021–Jun. 30, 20210.5%*
Jul. 1, 2021–Sep. 30, 20210.5%*
Oct. 1, 2021–Dec. 31, 20210.5%*
Jan. 1, 2022–Mar. 31, 20220.5%*
Apr. 1, 2022–Jun. 30, 20221.5%8562
Jul. 1, 2022–Sep. 30, 20222.5%10564
Oct. 1, 2022–Dec. 31, 20223.5%12566
Jan. 1, 2023–Mar. 31, 20234.5%14568
Apr. 1, 2023–Jun. 30, 20234.5%14568
Jul. 1, 2023–Sep. 30, 2023 4.5%14568
Oct. 1, 2023–Dec. 31, 20235.5%16570
Jan. 1, 2024–Mar. 31, 2024 5.5%64618
Apr. 1, 2024–Jun. 30, 20245.5%64618
Jul. 1, 2024–Sep. 30, 20245.5%64618
* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of
this Revenue Ruling.

Bulletin No. 2024–24 1479 June 10, 2024
Part III
Guidance Regarding the
2024 Allocation Round
of Qualifying Advanced
Energy Project Credit
Program under Section
48C(e)
Notice 2024-36
SECTION 1. PURPOSE
.01 This notice provides additional
guidance to clarify and amplify the pro-
cedures for the allocation of credits under
§ 48C of the Internal Revenue Code
(Code)
1
(§ 48C credits) pursuant to the
qualifying advanced energy project credit
program under § 48C(e) (§ 48C(e) pro-
gram) and announces the 2024 allocation
round of the § 48C(e) program (Round 2).
Notices 2023-18, 2023-10 I.R.B. 508, and
2023-44, 2023-25 I.R.B. 924, established
the § 48C(e) program to allocate $10 bil-
lion of § 48C credits ($4 billion of which
may be allocated only to projects located
in § 48C(e) Energy Communities Census
Tracts
2
) for qualified investments in eli-
gible qualifying advanced energy proj-
ects and provided guidance for the first
allocation round of the § 48C(e) program
(Round 1). Except as specifically pro-
vided in this notice, Round 2 will be con-
ducted in the same manner and under the
same procedures as provided under Notice
2023-18 and Notice 2023-44.
3
.02 For purposes of Round 2, Appen-
dices A, B, and C of this notice supersede
Appendices A, B, and C of Notice 2023-
44.
.03 As stated in section 1.03 of Notice
2023-18, the Department of the Treasury
(Treasury Department) and the Internal
Revenue Service (IRS) anticipate provid-
ing at least two allocation rounds under
the § 48C(e) program. During Round 1,
the Treasury Department and IRS allo-
cated approximately $4 billion of § 48C
credits, with approximately $1.5 billion in
§ 48C credits allocated to projects located
in § 48C(e) Energy Communities Cen-
sus Tracts (as defined in section 5.06 of
Notice 2023-18). For Round 2, the Trea-
sury Department and the IRS anticipate
allocating approximately $6 billion of
§ 48C credits, with approximately $2.5
billion in § 48C credits to be allocated
to projects located in § 48C(e) Energy
Communities Census Tracts. Although the
Treasury Department and the IRS intend
to allocate a total of $10 billion of § 48C
credits over the duration of the § 48C(e)
program, with not less than $4 billion of
§ 48C credits allocated to projects located
in § 48C(e) Energy Communities Cen-
sus Tracts, depending upon applications
received, the Treasury Department and
the IRS may not allocate in Round 2 all
of the approximately $2.5 billion of § 48C
credits that must be allocated to § 48C(e)
Energy Communities Census Tracts. The
Treasury Department and the IRS will
evaluate if any § 48C credits remain unal-
located at the close of Round 2 and deter-
mine if another allocation round is needed.
.04 To be considered for an allocation
of § 48C credits in Round 2, taxpayers
must first submit concept papers to the
IRS through the Qualified Advanced
Energy Project Credit Program Applicant
Portal (48C Portal), accessible at https://
eco.energy.gov/48C/, maintained by the
Department of Energy (DOE). Following
submission of a concept paper, DOE will
provide a letter encouraging or discourag-
ing the taxpayer’s submission of a joint
application for DOE recommendation and
for IRS § 48C(e) certification (§ 48C(e)
application). DOE begins the acceptance
period for a taxpayer’s § 48C(e) applica-
tion on the date of the letter of encourage-
ment or discouragement. To be considered
for the § 48C(e) program, a taxpayer’s
§ 48C(e) application must be submitted
no later than 50 calendar days after DOE
begins the acceptance period for the tax-
payer’s § 48C(e) application. The IRS will
make all Round 2 allocation decisions no
later than January 15, 2025.
SECTION 2. BACKGROUND
.01 For purposes of the § 38 general
business credit, § 46 provides that the
amount of the investment credit for any
taxable year is the sum of the credits
listed in § 46. That list includes the § 48C
credit, which was originally enacted by
§ 1302(b) of the American Recovery and
Reinvestment Act of 2009, Public Law
111-5, Division B, Title I, Subtitle D,
123 Stat. 115, 345 (February 17, 2009),
to provide an allocated credit for quali-
fied investments in qualifying advanced
energy projects.
.02 In addition to certain amendments
made by the Tax Increase Prevention Act
of 2014, Public Law 113-295, 128 Stat.
4010 (December 19, 2014), § 48C was
amended most recently by § 13501 of Pub-
lic Law 117-169, 136 Stat. 1818 (August
16, 2022), commonly known as the Infla-
tion Reduction Act of 2022 (IRA). Sec-
tion 13501(a) of the IRA added § 48C(e)
to the Code to extend the § 48C credit and
to provide an additional credit allocation
of $10 billion. Section 13501(b) of the
IRA modified the definition of a “quali-
fying advanced energy project” contained
in § 48C(c)(1)(A). Section 13501(c) and
(d) of the IRA made conforming amend-
ments to § 48C(c)(2)(A) and (f). The
amendments made by § 13501 of the IRA
became effective on January 1, 2023. See
§ 13501(e) of the IRA.
.03 Notice 2023-18 established the
§ 48C(e) program and provided initial pro-
gram guidance. Section 3 of Notice 2023-
18 provided certain definitions for pur-
poses of the § 48C(e) program, section 4 of
Notice 2023-18 described how the prevail-
ing wage and apprenticeship requirements
under § 48C(e)(5) and (6) impact the rate of
§ 48C credits allocated under the § 48C(e)
program, section 5 of Notice 2023-18 pro-
vided a general description of the § 48C(e)
program, and section 6 of Notice 2023-18
provided initial information regarding the
procedures for concept papers and § 48C(e)
applications.
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code.
2
The term “§ 48C(e) Energy Communities Census Tracts” is defined in section 5.06 of Notice 2023-18 and such tracts are listed in Appendix C of this notice.
3
Prior Notices and other relevant information about the § 48C(e) program can be found at https://www.irs.gov/credits-deductions/businesses/advanced-energy-project-credit.

June 10, 2024 1480 Bulletin No. 2024–24
.04 Section 5 of Notice 2023-18 states
that the IRS will consider a project under
the § 48C(e) program only if DOE pro-
vides a recommendation and ranking to
the IRS. As stated in section 5 of Notice
2023-18, DOE will provide a recom-
mendation only if it determines that the
project has a reasonable expectation of
commercial viability and merits a recom-
mendation based on the criteria provided
in additional § 48C(e) program guidance
later provided in Notice 2023-44.
.05 Section 4 of Notice 2023-44 states
that eligible property that is part of a § 48C
eligible project placed in service prior
to being awarded an allocation of § 48C
credits under the § 48(C)(e) program is
not eligible to receive such an allocation.
SECTION 3. ROUND 2 OF SECTION
48C(e) PROGRAM
.01 In General. For each project for
which a taxpayer seeks an allocation of
§ 48C credits in Round 2, the taxpayer
must use the 48C Portal to submit to the
IRS (1) a concept paper for DOE consid-
eration and (2) a joint application for DOE
recommendation and for IRS § 48C(e)
certification (§ 48C(e) application). If a
§ 48C(e) application does not (1) propose
a qualifying advanced energy project (as
described in Appendix A) or (2) include
all of the information required in Appen-
dix B, DOE may decline to consider the
§ 48C(e) application or request that the
applicant resubmit its § 48C(e) applica-
tion with the missing information. If DOE
does not provide a recommendation to the
IRS on the § 48C(e) application, the IRS
will not consider the § 48C(e) application.
Failure to receive an allocation in Round
1 does not preclude an applicant from
applying in Round 2.
.02 Taxpayer submissions. Taxpay-
ers must submit their concept papers and
§ 48C(e) applications through the 48C
Portal. See Appendix B for additional
information regarding the application pro-
cess.
.03 Program Timeline. Generally,
Round 2 will proceed as follows:
(1) A taxpayer submits a concept paper
through the 48C Portal. The 48C Portal
will open to accept concept paper submis-
sions no later than Tuesday, May 28, 2024.
Taxpayers must submit concept papers
prior to 5:00 PM Eastern Time, within 30
calendar days after the 48C Portal opens.
(2) DOE reviews the concept paper and
sends the taxpayer a letter encouraging or
discouraging the submission of a § 48C(e)
application. After receiving a letter of
encouragement or discouragement from
DOE, the taxpayer determines whether
to submit a § 48C(e) application. Any
taxpayer who submits a concept paper
through the 48C Portal is eligible to sub-
mit a § 48C(e) application, regardless of
DOE’s response to the taxpayer’s concept
paper.
(3) Taxpayers submit § 48C(e) applica-
tions through the 48C Portal. See Appen-
dix B for additional information.
(4) DOE reviews each § 48C(e) appli-
cation for compliance with eligibility and
other threshold requirements.
(5) If the § 48C(e) application complies
with all eligibility and threshold require-
ments, DOE conducts a technical review
of the application based on the technical
review criteria described in Appendix B.
(6) DOE provides a recommendation
to the IRS regarding the acceptance or
rejection of each § 48C(e) application and
a ranking of all § 48C(e) applications.
(7) The IRS makes a decision regard-
ing the acceptance or rejection of each
§ 48C(e) application based on DOE’s
recommendation and ranking. The IRS
notifies each taxpayer who submitted a
§ 48C(e) application of the outcome by
sending a letter allocating § 48C credits in
the case of an acceptance (Allocation Let-
ter) or a letter denying the requested allo-
cation in the case of a rejection (Denial
Letter). The IRS will make all Round 2
allocation decisions no later than January
15, 2025. In the case of an acceptance,
the amount of § 48C credits allocated to
a project will be based on the taxpayer’s
qualified investment in the qualifying
advanced energy project and whether the
taxpayer intends to apply for and receive
an allocation of § 48C credits calculated
at the 30 percent credit rate (see section
5.07 of Notice 2023-18). In the case of a
denial, a taxpayer may request a debrief-
ing with DOE regarding DOE’s review of
the taxpayer’s § 48C(e) application. The
Denial Letter will include instructions for
requesting a DOE debriefing.
(8) To be eligible to receive a § 48C
credit allocated under the § 48C(e) pro-
gram with respect to a taxpayer’s quali-
fied investment in a qualifying advanced
energy project (§ 48C Facility), the ear-
liest that the taxpayer may place in ser-
vice the § 48C Facility is after receiving
the Allocation Letter with respect to that
§ 48C Facility. See section 4 of Notice
2023-44.
(9) Within 2 years of receiving an
Allocation Letter, a taxpayer must notify
DOE that the certification requirements
have been met by submitting the required
information through the 48C Portal. See
Appendix B for additional information.
(10) DOE reviews information pro-
vided by the taxpayer evidencing that the
requirements for certification have been
met.
(11) DOE notifies the taxpayer and the
IRS if the taxpayer satisfies the certifica-
tion requirements.
(12) The IRS certifies a taxpayer’s
§ 48C Facility by sending a letter (Certifi-
cation Letter).
(13) Within 2 years of receiving the
Certification Letter, the taxpayer notifies
DOE that the § 48C Facility has been
placed in service by submitting such
information through the 48C Portal. See
Appendix B for additional information.
If the taxpayer has not placed the § 48C
Facility in service within the required
2-year period or has not notified DOE
that the § 48C Facility has been placed in
service within the required 2-year period,
then the § 48C credit allocated to the tax-
payer’s § 48C Facility is forfeited.
(14) DOE notifies the taxpayer and
the IRS that it has received the taxpay-
er’s notification that the § 48C Facility
has been placed in service or notification
that the taxpayer will not place the § 48C
Facility in service within the required
2-year period. See section 5.09 of Notice
2023-18.
(15) If the taxpayer has placed the
§ 48C Facility in service within the
required 2-year period and has notified
DOE, then the taxpayer claims the § 48C
credit on its Federal income tax return for
the taxable year in which the § 48C Facil-
ity was placed in service.
(16) If the taxpayer chooses to with-
draw a submission at any phase of the
§ 48C(e) program (whether at the con-
cept paper phase, the § 48C(e) application
phase, the post-Allocation Letter phase,

Bulletin No. 2024–24 1481 June 10, 2024
or the post-Certification Letter phase),
the taxpayer must provide a formal with-
drawal notification through the 48C Por-
tal.
SECTION 4. SECTION 48C
ADDITIONAL RULES
.01 Section 48C Energy Communi-
ties. A § 48C Facility is determined to be
located in a § 48C(e) Energy Commu-
nity Census Tract at the time that DOE
provides recommendations to the IRS. A
§ 48C Facility is treated as located within
a § 48C(e) Energy Community Census
Tract if the § 48C Facility satisfies the
Footprint Test as provided in section 6.03
of Notice 2023-44. A taxpayer can deter-
mine whether its project is located within
a § 48C(e) Energy Communities Census
Tract by referring to the list of Section
48C(e) Energy Communities Census
Tracts provided by Appendix C. Addition-
ally, a map of § 48C(e) Energy Commu-
nities Census Tracts has been provided by
the DOE and is available at www.energy.
gov/infrastructure/48C.
.02 Selection Criteria for all projects
seeking an allocation from the § 48C(e)
program. Section 48C(d)(3) lists the
selection criteria used to determine which
qualifying advanced energy projects merit
a DOE recommendation. Section 7 of
Notice 2023-44 provides additional detail
regarding these criteria, including how
the criteria are used to evaluate concept
papers and § 48C(e) applications.
SECTION 5. PAPERWORK
REDUCTION ACT
Any collection burden associated with
this notice is accounted for in OMB Con-
trol Number 1545-2151. This notice does
not alter any previously accounted for
information collection requirements and
does not create new collection require-
ments not already approved by the Office
of Management and Budget.
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Notice 2023-18 is clarified and mod-
ified. Notice 2023-44 is amplified and
superseded.
SECTION 7. DRAFTING
INFORMATION
.01 The principal author of this notice
is Alan W. Tilley of the Office of Associ-
ate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice contact Mr. Tilley on
(202) 317-6853 (not a toll-free call).
.02 Any questions or comments regard-
ing the non-tax aspects of this notice can
be submitted to DOE at 48CQuestions@
hq.doe.gov. DOE may post questions and
answers related to this notice at https://
www.energy.gov/infrastructure/48C. Any
questions or comments received under this
notice are subject to public release pursu-
ant to the Freedom of Information Act.
DOE is under no obligation to respond to,
or acknowledge receipt of, any questions
or comments submitted under this notice
and any responses provided do not consti-
tute legal advice provided by either DOE
or the IRS.

June 10, 2024 1482 Bulletin No. 2024–24
Table of Contents
1 APPENDIX A – Eligibility ...........................................................................1483
1.1 Clean Energy Manufacturing and Recycling Projects ......................................................1483
1.2 Industrial Decarbonization Projects ....................................................................1485
1.3 Critical Material Projects. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1486
2 APPENDIX B – DOE Application Process ..............................................................1487
2.1 Executive Summary ............................................................................1487
2.2 Glossary of Terms ..............................................................................1488
2.3 DOE Review Process ...........................................................................1489
2.3.1 Program Process ........................................................................1489
2.3.2 Program Key Dates ......................................................................1489
2.3.3 Program Priorities .......................................................................1489
2.4 Stage 1, Concept Paper Guidance .................................................................1490
2.4.1 Concept Paper Submission Requirements .....................................................1491
2.4.2 Concept Paper Template ..................................................................1491
2.4.3 Concept Paper Review Process Overview .....................................................1493
2.5 Stage 2, 48C(e) Application Guidance ..............................................................1494
2.5.1
Application Submission Requirements .......................................................1494
2.5.2 Application Submission Material Guidelines ..................................................1495
2.5.3 Application Review Process Overview .......................................................1501
2.6 Additional Application Materials ..................................................................1502
2.6.1 Data Sheet .............................................................................1502
2.6.2 Section 48C(e) Application Appendix Files ...................................................1503
2.7 Technical Review Criteria .......................................................................1503
2.7.1 Clean Energy Manufacturing and Critical Materials Projects ......................................1503
2.7.2 Greenhouse Gas Emissions Reduction Projects ................................................1505
2.8 Submission and Registration Information and Requirements ............................................1506
2.8.1 General Application Requirements ..........................................................1506
2.8.2 Determining an Application’s Project Category ................................................1506
2.8.3 48C Portal for Submission of Application .....................................................1507
2.8.4 Application Forms and Format of Submissions ................................................1508
2.8.5 Electronic Authorization of Applications .....................................................1508
2.8.6 Markings of Confidential Information ........................................................1508
2.9 DOE Recommendation Process ...................................................................1508
2.9.1 Program Policy Factors ...................................................................1508
2.9.2 DOE Recommendations ..................................................................1509
2.10 Post Allocation ................................................................................1509
2.10.1 Requirements for Certification .............................................................1509
2.10.2
Request for Debriefing ....................................................................1509
2.11 Questions/Comments and Informational Webinar .....................................................1509
2.11.1 Questions and Comments .................................................................1509
2.11.2 Informational Webinar ....................................................................1509
3 APPENDIX C – 48C(e) Energy Communities ............................................................1510

Bulletin No. 2024–24 1483 June 10, 2024
APPENDIX A – Eligibility
1. Qualifying Advanced Energy
Projects
THIS APPENDIX A SUPERSEDES
APPENDIX A OF NOTICE 2023-44.
For the purposes of determining eligi-
bility for the § 48C credit, a “qualifying
advanced energy project” means:
1.1 Clean Energy Manufacturing and
Recycling Projects
A qualifying advanced energy project
in this category involves re-equipping,
expanding, or establishing an industrial or
manufacturing facility. The facility must
manufacture or recycle one or more of the
specified advanced energy properties out-
lined below.
Note: If only a portion of a facility will
be used to manufacture or recycle eligible
property as described in this Appendix,
then the qualified investment proposed in
the § 48C application should only include
costs for the portion of the facility that
will be used to manufacture or recycle eli-
gible property.
a. Property designed to be used to
produce energy from the sun, water, wind,
geothermal deposits (within the meaning
of § 613(e)(2)), or other renewable
resources.
(i) Examples of eligible property
include solar panels and their compo-
nents and sub-components (e.g., solar
cells, solar glass, wafers, and polysilicon)
and their specialized support structures;
wind turbines, towers, floating offshore
platforms, and related equipment; power
electronics designed for use with eligi-
ble solar or wind property; equipment to
concentrate sunlight to generate heat for
industrial processes or to convert it to
electricity; geothermal turbines and heat
pumps; hydropower turbines; and other
products directly used to generate electri-
cal and/or thermal energy from renewable
resources, as well as the specialized com-
ponents, subcomponents, and materials
incorporated into any such eligible prop-
erty, including equipment for sensing,
communication, and control.
(ii) Examples of ineligible property
include equipment used for purposes other
than converting energy from renewable
resources into electricity, building heat,
or industrial process heat. This includes
gas turbine generator sets which burn nat-
ural gas, or boilers that heat water using
fossil fuels. Also, clean energy develop-
ment projects are ineligible. These include
power generation projects that use solar
panels, wind turbines, or hydropower tur-
bines to generate electricity.
b. Fuel cells, microturbines, or energy
storage systems and components.
(i) Examples of eligible property
include stationary batteries; stationary
hydrogen fuel cells; hydrogen storage
vessels; microturbines for combined heat
and power systems; pumps and turbines
for pumped hydropower storage systems;
and the specialized components of any
such equipment, including equipment for
sensing, communication, and control.
(ii) Examples of ineligible property
include heavy-duty gas turbines.
(iii) Note: For electric vehicle batteries
and fuel cells for vehicles see the “light-,
medium-, or heavy-duty electric or fuel
cell vehicles” project class.
c. Electric grid modernization equipment
or components.
(i) Examples of eligible property include
grid equipment for electricity delivery;
power flow, control, and conversion,
such as transformers, power electronics,
advanced cables and conductors, advanced
meters, breakers, switchgears, composite
poles, converters, medium-voltage direct
current (MVDC) and high-voltage direct
current (HVDC) lines, grid-enhancing
technologies, and electrical steel or alloys
used in transformer cores. Examples of eli-
gible property also include the specialized
components of any such grid moderniza-
tion equipment, including components for
sensing communication, and control.
(ii) Electric vehicle supply equipment
qualifies under the “light-, medium-, or
heavy-duty electric or fuel cell vehicles”
project class. Storage technologies for
grid applications qualify under the “fuel
cells, microturbines, or energy storage
systems and components” project class.
d. Property designed to capture, remove,
use, or sequester carbon oxide emissions.
(i) Examples of eligible property
include carbon capture equipment or
other property necessary to compress,
treat, process, liquefy, pump or perform
some other physical action to capture car-
bon oxide emissions, including solvents;
membranes; sorbents; chemical process-
ing equipment; compressors; monitoring
equipment; and injection equipment; and
well components such as packers, casing
strings, CO
2
-resistant concrete, steel tubu-
lars, wellhead, valves, and sensors suitable
for use in Underground Injection Control
(UIC) Class VI wells. Eligible property
also includes transportation equipment, as
in a system of gathering and distribution
infrastructure. These include pipelines,
temporary or transportation-related car-
bon oxide storage tanks, valves, sensors,
and control panels that serve in collecting
carbon oxides captured from an industrial
facility or multiple facilities for the pur-
pose of transporting that carbon oxide.
Additional examples include equipment
to convert carbon oxides through miner-
alization, thermochemical, electrochem-
ical, photochemical, plasma-assisted,
or other catalytic process approaches to
carbon-based products such as synthetic
fuels, chemicals, solid carbon products,
and inorganic materials.
(ii) Examples of ineligible property
include scrubbers for conventional air
pollutants (except those that are required
to remove pollutants upstream of carbon
capture equipment for technical perfor-
mance reasons), energy generation equip-
ment (except as related to energy recovery
at carbon capture systems), and refining
equipment. Also, facilities that install
equipment to capture, remove, use, or
sequester carbon oxide emissions are not
eligible under this category. These prop-
erties are considered deployments. The
installation of CCUS equipment at exist-
ing facilities may be eligible under the
Industrial decarbonization category (see

June 10, 2024 1484 Bulletin No. 2024–24
Section 1.2, Industrial Decarbonization
Projects).
e. Equipment designed to refine,
electrolyze, or blend any fuel, chemical,
or product which is renewable, or
low-carbon and low-emission. For the
purposes of Round 2 of the § 48C(e)
program, a qualifying advanced energy
project in this category must include
projects that manufacture or recycle
equipment used to produce the following:
(i) Renewable transportation fuel that is
(A) suitable for use as a fuel in a vehi-
cle, marine vessel, or aircraft,
(B) derived from or co-processed
with
(I) a biomass feedstock, or
(II) hydrogen produced from
renewable energy and
inputs, and
(C) not derived from palm fatty acid
distillates or fossil fuels, includ-
ing coal, natural gas, and petro-
leum.
(ii) Clean hydrogen produced with a
well-to-gate lifecycle greenhouse gas
(GHG) emissions rate of not greater
than 4 kg CO
2e
per kg H
2
, in accor-
dance with the definition of qualified
clean hydrogen under § 45V, Credit
for Production of Clean Hydrogen.
(iii) Other fuel that is
(A) derived from or co-processed
with a renewable feedstock or
achieves at least a 50 percent
reduction in lifecycle GHG
emissions in comparison with the
conventional alternative,
(B) not a transportation fuel suitable
for use in a vehicle, marine ves-
sel, or aircraft, and
(C) not derived from palm fatty acid
distillates or fossil fuels, including
coal, natural gas, and petroleum.
(iv) Product or chemical that is
(A) derived from or co-processed
with a renewable feedstock or
achieves at least a 50 percent
reduction in lifecycle GHG
emissions in comparison with the
conventional alternative,
(B) suitable for use as an industrial
feedstock, and
(C) not derived from palm fatty acid
distillates or fossil fuels, includ-
ing coal, natural gas, and petro-
leum.
(v) Examples of eligible property
include electrolyzers such as alkaline
cells, proton-exchange membrane (PEM)
cells, and solid-oxide electrolysis cells
(SOECs). Other eligible equipment
includes mixing devices, pumps, separa-
tion devices, bioprocessing equipment,
biomass preprocessing equipment, and
reactors. However, these pieces of equip-
ment must be intended for use in the pro-
duction of eligible fuels, chemicals, and
products. Examples of these fuels, chem-
icals, and products include low-emissions
ammonia, renewable biofuels, including
sustainable aviation fuel, fuels designed to
replace petroleum fuel in on-road and off-
road applications. Equipment for the pro-
duction of low-emissions chemicals, basic
organic chemicals, polymers, and resins
are also included, as long as their intended
use is demonstrated through engineering
specifications or offtake agreements.
(vi) Examples of ineligible property
include those designed to produce fuels
and chemicals derived solely from fos-
sil resources produced through conven-
tional petroleum and natural gas refining.
Additionally, facilities that manufacture
or produce fuels, chemicals, or other
industrial feedstocks, such as renewable
biofuels, hydrogen, and low-emission
ammonia, are also ineligible. These facil-
ities are considered deployment facilities.
For exceptions pertaining to deployment
facilities that produce low carbon chem-
icals and are eligible in Round 2 refer to
Section 1.1(i), Other advanced energy
property designed to reduce greenhouse
gas emissions as may be determined by
the Secretary. Furthermore, it is important
to note that a qualifying advanced energy
project must exclude any portion of a
project that involves the manufacturing or
recycling of equipment used in the refin-
ing or blending of any fuel other than fuels
described in this category.
f. Property designed to produce energy
conservation technologies (including
residential, commercial, and industrial
applications).
(i) Examples of eligible energy con-
servation property include technologies
and grid-interactive devices eligible for
residential or commercial efficiency
improvements for purposes of the § 25C
credit or the § 179D tax deduction, as well
as equipment that directly reduces net
energy use in industrial applications, such
as ultra-efficient heat pumps, insulation,
ultra-efficient hot water systems, sensors,
controls, and similar advanced efficiency
technologies.
(ii) Examples of ineligible energy
conservation property include those that
reduce electricity usage by increasing
the facility’s natural gas or other fossil
fuel usage and/or lead to increased sys-
tem-level emissions.
g. Light-, medium-, or heavy-duty
electric or fuel cell vehicles, as well as
technologies, components, or materials
for such vehicles, and associated
charging or refueling infrastructure.
(i) Examples of eligible property
include battery electric, plug-in hybrid
electric, or fuel cell cars, trucks, buses,
and other vehicles, as well as the special-
ized components of those vehicles, such
as batteries, anode and cathode compo-
nents and materials, electric drive sys-
tems, fuel cells, and other materials and
subcomponents.
(ii) Examples of eligible charging or
refueling infrastructure include electric
vehicle supply equipment (EVSE), includ-
ing EVSE with integrated energy storage,
components from the grid connection to
the vehicle, bidirectional charging equip-
ment, and components used in hydrogen
refueling stations (e.g., hydrogen com-
pressors, pumps, storage vessels, and dis-
pensing equipment).
(iii) Examples of ineligible property
include internal combustion engine vehi-
cles of all sizes, non-plug-in hybrid vehi-
cles of less than 14,000 pounds gross
vehicle weight rating, and their com-
ponents, as well as associated refueling
infrastructure, such as petroleum, lique-
fied or compressed natural gas, or ethanol
refueling stations. Examples of ineligi-
ble charging infrastructure property also
include electrical components upstream of
the charging station’s service connection
to the grid and components of charging
or refueling stations, such as signage, that
are not directly involved in the transfer of
fuel or power to the vehicle.

Bulletin No. 2024–24 1485 June 10, 2024
h. Hybrid vehicles with a gross vehicle
weight rating of not less than 14,000
pounds, as well as technologies,
components, or materials for such
vehicles.
(i) Examples of eligible property
include traction batteries, converters,
power electronics, and assembled hybrid
vehicles of not less than 14,000 pounds
themselves, but components and materials
must be designed for large hybrid vehicles
with a gross vehicle weight rating of not
less than 14,000 pounds, as demonstrated
through engineering specifications and/or
offtake agreements.
i. Other advanced energy property
designed to reduce greenhouse gas
emissions as may be determined by the
Secretary.
(i) Examples of eligible advanced
energy property include specialized com-
ponents and equipment for nuclear power
reactors or their fuels (e.g., including
components and equipment for fabrication
of fuels, and manufacturing of equipment
for conversion, enrichment, and deconver-
sion), and equipment used to reduce the
emissions of industrial facilities, such as
heat and process emissions. Property may
be determined to be designed to reduce
GHG emissions either through published
guidance or in the letter notifying an
applicant that the IRS has accepted the
applicant’s application for § 48C(e) certi-
fication with respect to the property.
(ii) Examples of eligible advanced
energy properties in this category include
energy-intensive materials that have a
substantially lower carbon intensity when
compared to an appropriate industry-spe-
cific benchmark. These materials must not
be derived from primary feedstocks such
as palm fatty acid distillates or fossil fuels
including coal, natural gas, and petro-
leum. Eligible projects include but are not
limited to projects that expand, re-equip,
or establish facilities for manufacturing or
recycling of low carbon cement, concrete
or components such as supplementary
cementitious materials, low carbon iron
and steel, low carbon aluminum, low car-
bon chemicals, low carbon pulp or paper,
and low carbon glass. The proposed proj-
ects should reduce carbon intensity on a
life cycle basis by at least 30% compared
to an appropriate industry-specific bench-
mark. Existing facilities are only eligible
if they re-equip or expand their produc-
tion lines to produce these materials or
increase capacity respectively; otherwise,
they do not qualify under this category.
(iii) Advanced energy property that
is designed to reduce greenhouse gas
emissions by enabling the production of
other greenhouse gas emission-reducing
advanced energy property may be eligi-
ble under this category. For such “other
advanced energy property,” which is not
designed to directly reduce GHG emis-
sions, the applicant must demonstrate
that the advanced energy property is
highly specialized equipment necessary
to strengthen U.S. resilience of critical
domestic energy supply chains and the
reduction of GHG emissions is a neces-
sary ultimate outcome from the produc-
tion of the advanced energy property. This
can be demonstrated through the appli-
cant’s proposed business plan, including
offtake agreements and any additional
market analysis or other technical spe-
cialization, to show the advanced energy
property that is produced or recycled by
the applicant’s industrial or manufacturing
facility will primarily contribute toward
reduction of GHG emissions. An example
of such “other advanced energy property”
that may be eligible is diamond wire saws
necessary in the solar technology supply
chain, so long as the applicant demon-
strates the project’s output will be used
primarily for the purpose of manufactur-
ing property designed to produce energy
from the sun.
(iv) Examples of ineligible properties
include projects that re-equip, expand, or
establish facilities that would be used for
enrichment, conversion, or deconversion
of uranium. Similarly, projects that pro-
duce uranium or procure equipment that
would be used in the enrichment, conver-
sion, or deconversion of uranium are not
eligible under this category.
1.2 Industrial Decarbonization Projects
An advanced energy project qualifies
under this category if it involves retrofit-
ting an industrial or manufacturing facil-
ity, particularly in energy-intensive sectors
such as cement, iron and steel, aluminum,
and chemicals. The retrofit must include
the installation of equipment specifically
designed to reduce greenhouse gas emis-
sions by at least 20 percent. It’s important
to note that this category is exclusively
focused on projects that upgrade the exist-
ing facilities to lower greenhouse gas
emissions through the installation of one
or more specified technologies below.
Note: Investments aimed at expanding
a facility such as those intended to increase
manufacturing capacity are not considered
eligible costs to be included as part of
qualified investment under this category.
Therefore, any such ineligible costs must
be excluded from the qualified investment
requested for projects within this category.
However, these type projects may qualify
under the section 1.1 Clean Energy Manu-
facturing and Recycling project category.
In Round 1, this project category was
referred to as “Greenhouse Gas Emissions
Reduction Projects” (as described and
defined in Appendix A of Notice 2023-
44). The updated project category name
“Industrial Decarbonization Projects” in
Round 2 is a change in terminology only;
eligibility under this project category
remains unchanged between Round 1 and
Round 2, although additional clarifica-
tions are provided below.
a. Low- or zero-carbon process heat
systems.
Examples of eligible equipment
include electric heat pumps, combined
heat and power (CHP) systems, thermal
storage technologies, and other heating
systems based on electricity, clean hydro-
gen, biomass, or waste heat recovery.
b. Carbon capture, transport, utilization,
and storage systems.
(i) Examples of eligible equipment
include carbon capture equipment neces-
sary to compress, treat, process, liquefy,
pump, or perform some other physical
action to capture carbon oxides, and spe-
cialized equipment and materials needed
for the transport and storage of carbon
oxides, including carbon dioxide pipe-
lines, monitoring equipment, and injec-
tion equipment and well components such
as packers, casing strings, CO
2
-resistant
cement, steel tubulars, well heads, valves,

June 10, 2024 1486 Bulletin No. 2024–24
and sensors suitable for use in Under-
ground Injection Control Class VI wells.
Additional examples include equipment
to convert carbon oxides through miner-
alization, thermochemical, electrochem-
ical, photochemical, plasma-assisted,
or other catalytic process approaches to
carbon-based products such as synthetic
fuels, chemicals, solid carbon products,
and inorganic materials.
(ii) Examples of ineligible property
include scrubbers for conventional air
pollutants, except those that are required
to remove pollutants upstream of carbon
capture equipment to enhance the perfor-
mance of the capture equipment; energy
generation equipment, except as related
to energy recovery at carbon capture sys-
tems; and refining equipment.
c. Energy efficiency and reduction in
waste from industrial processes.
Examples of eligible equipment
include technologies that reduce direct
fuel use, electricity use, or waste in indus-
trial applications, such as industrial heat
pumps, CHP systems, insulation, sensors,
controls, advanced recycling approaches,
smart energy management, and similar
advanced efficiency technologies.
d. Any other industrial technology
designed to reduce greenhouse gas
emissions, as determined by the
Secretary.
(i) Examples of other eligible indus-
trial technologies include electrification
of direct fuel use processes, adoption of
renewable or low-emissions fuels and
feedstocks, and other equipment replace-
ment or process redesigns that reduce
process- or fuel-related emissions or oth-
erwise contribute to reducing GHG emis-
sions by at least 20 percent.
(ii) Projects in this category may qual-
ify by installing equipment designed to
achieve a minimum of a 20 percent reduc-
tion in GHG emissions in one or more of
the following ways:
(A) Achieve a direct (Scope 1) GHG
emissions reduction of 20 percent facili-
ty-wide;
(B) Achieve an indirect fuel- or ener-
gy-related (Scope 2) GHG emissions
reduction of 20 percent facility-wide; or
(C) Achieve a direct or indirect fuel- or
energy-related GHG emissions reduction
of 20 percent at a facility subunit, such as
a particular process step or fuel combus-
tion unit.
(iii) While facilities may be eligible
under this project category by achieving
a 20 percent reduction threshold within
a particular element of their process or
emissions profile, overall combined Scope
1 and Scope 2 GHG emissions impacts for
the full qualifying facility will be taken
into account when evaluating each project
for the purposes of application scoring.
Scope 1 and Scope 2 GHG emissions are
further defined in section 2.2 of Appendix
B, Glossary of Terms.
Instructions for calculating and
demonstrating an emissions reduction
of 20 percent is provided in section
2.6.1 of Appendix B, Data Sheet.
1.3 Critical Material Projects
A qualifying advanced energy project
in this category re-equips, expands, or
establishes an industrial facility for the
processing, refining, or recycling of crit-
ical materials (as defined in § 7002(a)
of the Energy Act of 2020 (30 U.S.C.
§ 1606(a)). For purposes of this Round 2,
critical materials consist of:
a. The currently effective final list of
critical minerals as determined by the
U.S. Geological Survey (see 2022 Final
List of Critical Minerals for the list pub-
lished in 2022 available at: https://www.
energy.gov/cmm/what-are-critical-materi-
als-and-critical-minerals); and
b. Any additional critical materials as
determined by the Secretary of Energy
and for which a final determination is
posted on the DOE’s critical materials
page on or before July 31, 2023, available
at: http://www.energy.gov/criticalmateri-
als. A proposed determination was posted
at this web address prior to the publication
of this notice. Note: DOE reserves the
right to extend the deadline for concept
paper submissions based on any changes
included in the final determination.
Examples of eligible projects in this
project category include the processing of
raw ore, brines, mine tailings, end-of-life
products, waste streams, and other source
materials into critical materials. Note:
These examples have been updated with
additional clarifying language since the
publication of Notice 2023-18.
Examples of ineligible projects under
this project category include the subse-
quent physical or chemical transforma-
tion of critical materials into derivative
products, including metals manufac-
turing such as aluminum extrusion and
chemical manufacturing such as anode
and cathode materials production. How-
ever, projects involving such derivative
products may be eligible under the Clean
Energy Manufacturing and Recycling
Projects category. Note: These examples
have been updated with additional clar-
ifying language since the publication of
Notice 2023-18.

Bulletin No. 2024–24 1487 June 10, 2024
2 APPENDIX B – DOE Application Process
DOE Application Process
THIS APPENDIX B SUPERSEDES APPENDIX B OF NOTICE 2023-44.
2.1 Executive Summary
Appendix B provides guidance on the
DOE application process. The Appendix
is organized as follows:
• Section 2.2 Glossary of Terms
defines key terms used throughout the
guidance.
• Section 2.3 DOE Review Process
summarizes application process and
program priorities.
• Section 2.4 Stage 1, Concept Paper
Guidance summarizes the concept
paper submission requirements,
the concept paper template, and the
review process.
• Section 2.5 Stage 2, 48C(e) Appli-
cation Guidance summarizes the
application submission requirements,
application submission guidelines,
and the review process.
• Section 2.6 Additional Application
Materials summarizes the data sheet
and appendix files guidelines.
• Section 2.7 Technical Review Crite-
ria summarizes the criteria that DOE
will use to evaluate applications.
• Section 2.8 Submission and Regis-
tration Information and Require-
ments summarizes the logistics and
requirements for submitting applica-
tion materials.
• Section 2.9 DOE Recommenda-
tion Process describes program pol-
icy factors DOE will use to evaluate
applications.
• Section 2.10 Post Allocation
describes requirements for certifica-
tion for successful applications after
allocations have been made.
• Section 2.11 Questions/Comments
and Informational Webinar sum-
marizes how to learn more about the
48C program.
Below are the key dates for Round 2 of the
48C Program.
Table 1: Program Key Dates
Guidance Issue Date04/30/2024
DOE 48C Portal Opens for registration and
concept paper submission
May 2024, and no later than
05/28/2024
Informational WebinarNo later than 05/31/2024
Submission Deadline for Concept Papers30 calendar days after the 48C Portal
Opens for registration and concept
paper submissions at 5:00 PM
Eastern
48C Portal Opens for full application submis-
sion
Summer 2024
Submission Deadline for § 48C(e) Applica-
tions
Summer / Fall 2024; 50 calendar
days after the 48C Portal Opens to
accept full application submissions
at 11:59 PM Eastern
IRS Allocation Decision NotificationsNo later than 01/15/2025

June 10, 2024 1488 Bulletin No. 2024–24
2.2 Glossary of Terms
The following terms may be used throughout this appendix describing the DOE application process.
Disadvantaged Community
A disadvantaged community is overburdened or underserved and may be either (1) a group
of individuals living in geographic proximity (e.g., such as a census tract identified using
the Climate and Economic Justice Screening Tool), or (2) a geographically dispersed set of
individuals, where either type of group experiences common conditions.
Scope 1 Emissions
Direct greenhouse gas emissions that occur from sources at the facility associated with the
proposed project (e.g., emissions from fuel combustion or chemical processes).
Scope 2 Emissions
Indirect greenhouse gas emissions that are associated with the use of energy or fuel at the
facility, but do not occur at the facility (e.g., emissions from a power plant that generates
electricity for the facility).
Scope 3 Emissions
Indirect greenhouse gas emissions that are associated with the facility’s activities and
products but are not covered in Scope 1 or 2, including emissions from the products them-
selves in their ultimate use, transportation, or other aspects of the value chain upstream or
downstream from the facility.
Specified Advanced Energy Prop-
erty
A specific category of property listed in 48C(c)(1)(A) and described in further detail in
section 1.1 of Appendix A, Clean Energy Manufacturing and Recycling Projects. Clean
Energy Manufacturing and Recycling Projects under § 48C(e) must either produce or recy-
cle one or more specified advanced energy properties. For example, solar glass would be
considered a specified advanced energy property covered under section 1.1(a) of Appendix
A.
Facility Product
The equipment, materials, or other products produced in the facility associated with the
proposed project and typically sold or leased after production. Facilities may have more
than one facility product. Under the Clean Energy Manufacturing and Recycling Project
category, the specified advanced energy property of a clean energy manufacturing project
is likely to be the facility’s primary product/output. In contrast, the specified advanced
energy property of a clean energy recycling project is an input to the proposed facility,
while the facility product/output is typically one or more materials extracted in the recy-
cling process. In a Critical Materials Recycling Project the qualified critical material
is the input to the proposed facility while facility product/output is the project’s specified
advanced energy property. Facility products from Industrial Decarbonization Projects do
not need to be specified advanced energy property.
Registered Apprenticeship Pro-
gram
A Registered Apprenticeship Program (RAP) is an apprenticeship that has been validated
by the Department of Labor or State Apprenticeship Agency.
Collective Bargaining Agreement
A legally enforceable, written contract between a union representing a group of employees
and an employer in a workplace.
Project Labor Agreement
A Project Labor Agreement (PLA) is a pre-hire collective bargaining agreement negoti-
ated between one or more construction unions and one or more construction employers
(contractors/project owners) that establish the terms and conditions of employment for a
specific construction project.
Community Benefits Agreement
Community Benefits Agreements are contracts between employers/developers/contractors/
project owners and community organizations (including but not limited to unions). These
agreements, which can be in the manufacturing sector, the construction sector, or other
industries, may include provisions related to affordable housing, pollution reduction, or
other community priorities. Community Benefits Agreements are unique to each com-
munity and their terms will reflect the varied interest of their signatories. Some Commu-
nity Benefits Agreements are Collective Bargaining Agreements between the contractor/
employer and one or more unions setting terms and conditions of employment—others
are not. If a Community Benefits Agreement is not a Collective Bargaining Agreement, it
cannot set out terms related to wages, rates of pay, hours of employment, or conditions of
work.

Bulletin No. 2024–24 1489 June 10, 2024
2.3 DOE Review Process
2.3.1 Program Process
A two-stage technical evaluation pro-
cess will be used for submissions:
• Stage 1: Concept Paper.
• Stage 2: § 48C(e) Application.
In Stage 1, concept paper submission
application materials will be available
for applicants to download from the 48C
portal and concept paper submissions will
be accepted in the 48C portal beginning
no later than May 28, 2024. DOE will
only consider concept papers that are
submitted by 5:00 PM Eastern Time,
30 days after the 48C portal opens.
Section 48C(e) applications for Round 2
allocations will not be considered by DOE
unless a Round 2 concept paper submis-
sion is received from an applicant by the
specified deadline. Potential applicants
will not be able to begin concept papers or
submit concept papers for Round 2 after
the deadline.
In Stage 2, following DOE’s review of
concept papers and transmission of letters
encouraging or discouraging the applicant
to continue in the process, the 48C portal
will reopen to receive § 48C(e) application
submissions for subsequent evaluation by
DOE. The date on which DOE will begin
accepting § 48C(e) applications and the
deadline by which they must be submitted
will be conveyed to applicants through the
48C portal at a later date.
In each stage, DOE will review the
submitted materials for compliance and
eligibility, and perform a thorough, con-
sistent, and objective examination based
on technical review criteria and other fac-
tors, as described below.
After Stage 2 evaluations of § 48C(e)
applications are complete, DOE will
transmit allocation recommendations to
the IRS for final consideration. The IRS
will notify applicants of final allocation
decisions for Round 2 no later than Jan-
uary 15, 2025.
In conducting its review, DOE may
utilize assistance and advice from quali-
fied personnel from other federal agencies
and/or contractors. DOE will obtain con-
flict of interest/non-disclosure acknowl-
edgements from and administer required
trainings in advance for all reviewers to
assure that application information will be
kept confidential and shall be used only
for reviewing purposes, in accordance
with applicable requirements. Reviewers
will be required to report all personal and
organizational conflicts of interest.
DOE reserves the right to request clari-
fications and/or supplemental information
from some or all applicants submitting
applications through written submissions.
DOE may determine whether to rec-
ommend or not recommend an application
to the IRS at any time after the § 48C(e)
application has been received, without
further exchanges or discussions with the
applicant.
2.3.2 Program Key Dates
Table 2: Program Key Dates
Guidance Issue Date04/30/2024
DOE 48C Portal Opens for registration and con-
cept paper submission
May 2024, and no later than
05/28/2024
Informational WebinarNo later than 05/31/2024
Submission Deadline for Concept Papers30 calendar days after the 48C Portal
Opens for registration and concept
paper submissions at 11:59 PM
Eastern
48C Portal Opens for full application submissionSummer 2024
Submission Deadline for § 48C(e) ApplicationsSummer / Fall 2024; 50 calendar
days after the 48C Portal Opens to
accept full application submissions
at 11:59 PM Eastern
IRS Allocation Decision NotificationsNo later than 01/15/2025
2.3.3 Program Priorities
There are three qualifying advanced
energy project categories (defined in
Appendix A): Clean Energy Manufac-
turing and Recycling Projects, Industrial
Decarbonization Projects, and Critical
Material Projects. Note that in Round 1,
the Industrial Decarbonization Project
category was referred to as “Greenhouse
Gas Emissions Reduction Projects”; the
updated project category name in Round
2 is a change in terminology only, and it is
designed to avoid confusion with the sec-
ond technical review criterion (detailed
below).
It is the applicant’s responsibility to
determine the most applicable qualify-
ing advanced energy project category,
according to the guidance in Section
2.8.2, Determining an Application’s
Project Category. For all three project
categories, eligible applications will be
evaluated by DOE against the four tech-
nical review criteria reflecting overall
program objectives:
• Criterion 1: Commercial Viability
• Criterion 2: Greenhouse Gas Emis-
sions Impacts

June 10, 2024 1490 Bulletin No. 2024–24
• Criterion 3: Strengthening U.S. Sup-
ply Chains and Domestic Manufac-
turing for a Net-Zero Economy
• Criterion 4: Workforce and Commu-
nity Engagement
A taxpayer with a qualified investment
in any of the projects described as eligible
in Appendix A of this guidance may apply
for a § 48C(e) allocation. In determining
whether to recommend a project for an
allocation, DOE will consider whether the
proposed project is located in § 48C(e)
Energy Communities Census Tracts, as
defined in section 5.06 of Notice 2023-18.
In Round 2, DOE anticipates recommend-
ing approximately $2.5 billion in § 48C
credits to projects located in these com-
munities.
DOE has identified the following prior-
ity areas for Round 2. Guidance for future
rounds under § 48C(e) may include differ-
ent priority areas.
When evaluating Clean Energy Man-
ufacturing and Recycling Projects, DOE
will take into consideration whether the
project addresses the following energy
supply chain and manufacturing priority
areas. These priority areas have been iden-
tified based on analytical criteria includ-
ing an assessment of current and antici-
pated supply chain gaps in areas eligible
under § 48C(e):
Round 2 Priority Areas (in alphabeti-
cal order):
• Clean Hydrogen: Manufacturing of
electrolyzers, fuel cells, and associ-
ated components (including gas dif-
fusion layers, bipolar plates, power
electronics, membrane electrode
assemblies and stacks, and cata-
lysts).
• Electric Grid: Manufacturing of dis-
tribution and large power transform-
ers and associated subcomponents,
materials (including grain-oriented
electrical steel, amorphous steel),
power electronics, HVDC cables,
HV circuit breakers, and other grid
components and equipment (includ-
ing MVDC/HVDC converter station
components and switchgears).
• Electric Heat Pumps: Manufacturing
of air-source or geothermal (ground-
source) heat pump components and
systems, particularly heat pumps for
industrial or networked applications
and/or those utilizing low-GWP refrig-
erants (such as natural refrigerants).
• Electric Vehicles**: Manufacturing
of power electronics (including semi-
conductors, modules, and circuits for
EV motor traction drives, on-board
EV chargers, DC/DC converters, and
EV charging stations), permanent
magnets, and specific battery compo-
nents (separators, electrolyte salts and
solvents, cathode and anode active
materials and precursors). Manufac-
turing of capital equipment for bat-
tery manufacturing. Manufacturing
of sub-components and components
specific to medium- and/or heavy-
duty (MDV/HDV) electric vehicles
and final assembly of MDV/HDV
electric vehicles.
• Energy-intensive materials that have
a substantially lower carbon inten-
sity when compared to an appropriate
industry-specific benchmark: Manu-
facturing or recycling of low carbon
cement, concrete or components such
as supplementary cementitious mate-
rials, low carbon iron and steel, and
low carbon aluminum
• Nuclear Energy: Manufacturing of
specialized components and equip-
ment for nuclear power reactors or
their fuels (including fabrication of
fuels, and manufacturing of equip-
ment for conversion, enrichment, and
deconversion), for both existing reac-
tors and new reactor deployments.
• Solar Energy**: Polysilicon, wafer
production facilities, ingot and wafer
production tools, and solar rolled
glass production facilities.
• Sustainable Aviation Fuels: Manu-
facturing of equipment needed for
low-carbon aviation fuel production
(including feedstock handling equip-
ment and pre-treatment reactors).
• Wind Energy**: Component produc-
tion facilities and specialized steel
production, particularly for offshore
wind, such as monopile-grade steel
and towers; recycling of wind com-
ponents, particularly blades; offshore
wind electrical balance of system
component manufacturing, including
submarine cables (AC and DC), large
power transformers, and HVDC con-
verter stations and converter station
components.
Federal Register : Section 45X
Advanced Manufacturing Production
Credit ** The production of some products
under this section may be eligible for tax
credits under § 45X and receiving an allo-
cation under § 48C(e) may preclude an
applicant from receiving tax credits under
that program. Applicants are encouraged
to evaluate which program may be most
beneficial to their project before submit-
ting a concept paper for consideration
under § 48C(e).
When evaluating Critical Material
Manufacturing and Recycling Projects,
DOE will take into consideration whether
the project processes, refines, or recycles
critical materials as determined by the
Secretary of Energy, as described in sec-
tion 1.3(b) of Appendix A.
When evaluating Industrial Decarbon-
ization Projects, DOE will give priority
to projects that deeply reduce emissions
to levels significantly below a reason-
able domestic industry average (on a sec-
tor-specific basis) and the 20% reduction
eligibility requirement stated in section
1.2 of Appendix A, Industrial Decarbon-
ization Projects. DOE will give priority
to Industrial Decarbonization Projects
that advance the commercial viability
and uptake of replicable decarbonization
efforts in major industrial applications
(e.g., cement, iron and steel, aluminum,
chemicals, and other energy-intensive
manufacturing sectors), including inno-
vative solutions, and to projects that align
with one or more cross-cutting indus-
trial decarbonization techniques, such as
energy efficiency, electrification, low-car-
bon fuels, feedstocks, and energy sources
(LCFFES), material efficiency or substi-
tution, and carbon capture utilization and
storage (CCUS).
2.4 Stage 1, Concept Paper Guidance
The first stage of DOE review requires
applicants to submit concept papers
describing the proposed project. This sec-
tion describes the information applicants
must include in concept papers and the
format of the submission. Concept papers
will undergo a multi-step evaluation by
DOE. Applicants who applied in Round
1 and were not selected for an allocation
are eligible to submit a concept paper in
Round 2.

Bulletin No. 2024–24 1491 June 10, 2024
2.4.1 Concept Paper Submission
Requirements
This section outlines the format of the
concept paper submission. See Appen-
dix A for a description of the eligibility
requirements for the § 48C credit under
this notice. See Section 2.7, Technical
Review Criteria, for a description of the
technical review criteria that will be used
to evaluate submitted concept papers.
The purpose of the concept paper stage
is to save applicants the considerable
time and expense of preparing § 48C(e)
applications for proposed projects that are
unlikely to be selected for recommenda-
tion. The concept paper must conform to
the following requirements:
• Concept paper must be written in
English.
• Use Times New Roman typeface,
a black font, and a font size of 11
points or larger (except in figures and
tables). A symbol font may be used to
insert Greek letters or special char-
acters; the font size requirement still
applies.
• The control number must be promi-
nently displayed on the upper right
corner of the header of every page.
Page numbers must be included in the
footer of every page.
• Each must be submitted in Adobe
PDF format unless stated otherwise.
Each concept paper should be limited
to unique property within a distinct qual-
ifying advanced energy project that does
not overlap with a qualifying advanced
energy project in any other application
submitted by the same applicant:
• For applicants applying under the
Clean Energy Manufacturing and
Recycling Project category, or the
Critical Materials Project category,
the applicant may submit more
than one application involving the
same facility. However, the quali-
fied investment for each project at
the same facility may not overlap in
Round 2.
• For applicants applying under the
Industrial Decarbonization Project
category, the applicant may submit
only one application at the same facil-
ity in Round 2.
If projects involve more than one qual-
ifying advanced energy project listed in
Appendix A, then applicants must choose
a primary specified advanced energy
property for their project. The entire
concept paper submission includes two
components: a template (there are unique
forms for Clean Energy Manufacturing
and Recycling Projects/Critical Materials
Projects and Industrial Decarbonization
Projects) and a data sheet.
Note: The maximum file size that
can be uploaded to the 48C portal is 25
MB. Files in excess of 25 MB cannot be
uploaded, and hence cannot be submitted
for review. If a file exceeds 25 MB but
is still within the maximum page limit,
it must be broken into parts and denoted
to that effect in the naming convention
of the file. For example: “[ControlNum-
ber]-ConceptPaper_Part_1.pdf”, “[Con-
trolNumber]-ConceptPaper_Part_2.pdf.
The full list of required files for con-
cept paper submission is illustrated in the
following table.
Table 3: Files Required for Concept Paper Submission
ComponentFile FormatMaximum
Pages
File Name
Concept Paper Template
(either the Clean Energy Manufacturing and Recycling
Projects/Critical Materials Projects Template or the Industrial
Decarbonization Projects Template)
PDF5[ControlNumber]-
ConceptPaper.pdf
Concept Paper Data SheetMS ExcelN/A[ControlNumber]-CP-
DataSheet.xlsx
For all files, “[ControlNumber]”
should be replaced by the application’s
control number. For example, for a control
number of 1234, the file would be named,
“1234-ConceptPaper.pdf”.
2.4.2 Concept Paper Template
At the Concept Paper stage, applicants
may be asked to respond to the following
questions in their submission. Additional
questions may be added to this list when
Concept Paper submissions open. In addi-
tion, applicants will be asked to submit an
Excel data sheet.
2.4.2.1 Clean Energy Manufacturing
and Recycling and Critical Materials
Projects Concept Paper Template
• Project Overview and Schedule
o Describe your company and project
team, including key personnel and
any subcontractors on the project.
o Describe whether the proj-
ect will establish, re-equip, or
expand a facility; whether the
facility will support the man-
ufacturing, processing, refin-
ing, or recycling of specified
advanced energy property; and
the extent to which innovative
equipment and/or processes will
be employed.
o Describe the status of the proj-
ect and provide any additional

June 10, 2024 1492 Bulletin No. 2024–24
details that are helpful to under-
stand the project schedule.
o List local, state, and/or federal
permits that are required for
this project and specify which
of these permits you already
possess. For any permits you
have yet to obtain, describe the
remaining steps and provide
an estimated timeline for their
acquisition.
• Commercial Viability
o Describe the specified primary
advanced energy property that
will be produced by the facility,
including how many units of
specified advanced energy prop-
erty will be produced annually
and any technological or cost
advantages over product compet-
itors.
o Provide an estimate of annual
market demand for the facility’s
product over the next 5 to 10
years.
o Describe the primary or target
customers for your facility’s
product and the details of any
existing offtake agreements or
other demand commitments
(e.g., with whom, for how many
units, and for how long).
o Describe the different sources of
financing for this project, differ-
entiating between secured financ-
ing and planned or expected
financing. Describe the capital
structure (e.g., debt/equity ratio)
if multiple sources of capital will
be used. If financing using the
company’s own funds, specify
the amount of cash available to
support this project.
o Describe anticipated legal, finan-
cial, engineering, procurement,
construction, and operational
risk(s) that the project may expe-
rience. Explain what actions the
project team will implement to
mitigate these risks and achieve
execution and commercial suc-
cess.
• Strengthening U.S. Supply Chains
and Domestic Manufacturing for a
Net-Zero Economy
o Describe the supply chain seg-
ment that your project’s specified
advanced energy property will
contribute to. Explain whether
your project will mitigate current
challenges that the U.S. is expe-
riencing in maintaining a secure
domestic supply chain, based on
where the product is manufac-
tured today and a comparison
between the proposed manufac-
turing capacity and current and
projected market demand.
• Greenhouse Gas Emissions Impacts
o Describe the impact of your
facility’s product and/or the tech-
nologies the product will enable
on greenhouse gas emissions.
• Workforce and Community Engage-
ment
o Provide the anticipated geo-
graphical location of the eligible
manufacturing, processing, refin-
ing, or recycling facility, includ-
ing the census tract the project
is located in. Explain why you
selected the project site.
o Does the location qualify as a
48C energy community? (see
Appendix C for the full list of
48C energy community Census
tracts)
o Does the location or community
qualify as a disadvantaged com-
munity according to the Climate
and Economic Justice Screening
Tool (CEJST)?
o Does the location or community
qualify as a disadvantaged com-
munity according to a different
federal, state, or local data tool?
If yes, indicate which one(s).
o If located in an energy commu-
nity, describe the extent to which
the project will (1) support tran-
sition opportunities for work-
ers in the coal, automotive, and
other energy sectors, and (2) use
existing infrastructure in energy
transition communities.
o Describe the extent to which the
project will secure job quality
(e.g., wages, benefits, health and
safety at the workplace, affirma-
tive support of collective bar-
gaining).
o Describe what labor and commu-
nity engagement has been com-
pleted and/or is planned. Sum-
marize any formal agreements
that are planned or have been
executed (e.g., Project Labor
Agreements, Community Bene-
fits Agreements, Collective Bar-
gaining Agreements).
o Describe any pollutants that the
project will introduce to the local
community, and explain what
specific, measurable steps the
project is taking beyond com-
pliance with environmental law
to mitigate local environmental
impact.
2.4.2.2 Industrial Decarbonization
Projects Concept Paper Template
• Project Overview and Schedule
o Describe your company and
project team, including key per-
sonnel and any subcontractors on
the project.
o Describe the retrofit project,
including the equipment, tech-
nologies, or approaches the proj-
ect will use to reduce greenhouse
gas emissions from the industrial
or manufacturing facility (e.g.,
low- or zero-carbon process heat
systems, energy efficiency equip-
ment, etc.). Explain the extent to
which innovative equipment and/
or processes will be employed.
o Describe the status of the proj-
ect and provide any additional
details that are helpful to under-
stand the project schedule.
o List local, state, and/or federal
permits that are required for this
project. Specify which of these
permits you already possess.
For any permits you have yet
to obtain, provide an estimated
timeline for their acquisition.
• Greenhouse Gas Emissions Impacts
o Describe the impacts of the
project on the facility’s Scope 1
greenhouse gas emissions.
o Describe the impacts of the
project on the facility’s Scope 2
greenhouse gas emissions.
o Explain how the project will
achieve a 20% reduction in green-
house gas emissions, including
interactions between Scope 1
and Scope 2 emissions (e.g., due

Bulletin No. 2024–24 1493 June 10, 2024
to electrification). Estimate the
greenhouse gas emissions reduc-
tions that will be achieved by the
project in both absolute (e.g.,
million metric tons per year) and
percentage terms.
o Provide an estimate of the level-
ized cost of measured reduction
in GHG emissions, based on total
project costs.
• Strengthening U.S. Supply Chains
and Domestic Manufacturing for a
Net-Zero Economy
o Describe the extent to which the
employed equipment, technol-
ogies, or approaches could be
applied to reduce greenhouse gas
emissions beyond the specific
project location, within or across
sectors.
• Commercial Viability
o Describe the facility’s out-
puts, including how many units
are produced annually today.
Explain any anticipated impacts
of the retrofit project on annual
production from the facility.
o Describe the primary or target
customers for your facility’s
products and the details of any
existing offtake agreements or
other demand commitments for
the lower-carbon product (e.g.,
with whom, for how many units,
and for how long).
o Describe how the retrofit proj-
ect will impact the price of your
product and provide an estimated
price of your facility’s products
after the project is completed.
Describe how the price of your
lower-carbon product will com-
pare to similar technologies or
materials in the same market
segment, including conventional
and lower-carbon products.
o Describe the different sources of
financing for this project, differ-
entiating between secured financ-
ing and planned or expected
financing. Describe the capital
structure (e.g. debt/equity ratio)
if multiple sources of capital will
be used. If financing using the
company’s own funds, specify
the amount of cash available to
support this project.
o Describe anticipated legal, finan-
cial, engineering, procurement,
construction, and operational
risk(s) that the project may expe-
rience. Explain what actions the
project team will implement to
mitigate these risks and achieve
execution and commercial suc-
cess.
• Workforce and Community Engage-
ment
o Provide the anticipated geo-
graphical location of the proj-
ect, including the census tract
(see Appendix C) the project is
located in.
o Does the location or community
qualify as a disadvantaged com-
munity according to the Climate
and Economic Justice Screening
Tool (CEJST)?
o Does the location or community
qualify as a disadvantaged com-
munity according to a different
federal, state, or local data tool?
If yes, indicate which one(s).
o Does the location qualify as a
48C energy community?
o If located in an energy commu-
nity, describe the extent to which
the project will (1) support tran-
sition opportunities for work-
ers in the coal, automotive, and
other energy sectors, and (2) use
existing infrastructure in energy
transition communities.
o Describe the impact of the proj-
ect on jobs at the facility, includ-
ing jobs associated with the ret-
rofit and the extent to which the
retrofit will retain or create jobs
in manufacturing.
o Describe the extent to which the
project will secure job quality
(e.g., wages, benefits, health and
safety at the workplace, affirma-
tive support of collective bar-
gaining).
o Describe what labor and commu-
nity engagement has been com-
pleted and/or is planned. Sum-
marize any formal agreements
that are planned or have been
executed (e.g., Project Labor
Agreements, Community Bene-
fits Agreements, Collective Bar-
gaining Agreements).
o Describe any pollutants that the
project will introduce to the local
community, and explain what spe-
cific, measurable steps the project
is taking beyond compliance with
environmental law to mitigate
local environmental impact.
2.4.3 Concept Paper Review Process
Overview
2.4.3.1 Compliance and Eligibility
Review
DOE will carry out an initial compliance
review for concept papers to determine that
(1) eligibility requirements have been met,
(2) the required information has been sub-
mitted, (3) the proposed project is techni-
cally valid, and (4) all mandatory require-
ments of this notice are satisfied. As part of
this review, DOE will determine whether
the proposed project meets the definition
of a qualifying advanced energy project, as
described in Appendix A.
If a concept paper fails to meet com-
pliance or eligibility requirements or fails
to provide sufficient information for eval-
uation, DOE reserves the right to request
clarifications and/or missing information
from some or all applicants through writ-
ten submissions provided to DOE in a
timely manner. Concept papers that fail to
meet the compliance or eligibility require-
ments or do not provide sufficient infor-
mation for evaluation will be considered
non-responsive and will receive a discour-
agement letter.
2.4.3.2 Technical Review
After the concept paper compliance
and eligibility review, DOE will perform
a technical review process based on four
technical review criteria:
• Criterion 1: Commercial Viability.
• Criterion 2: Greenhouse Gas Emis-
sions Impacts.
• Criterion 3: Strengthening U.S. Sup-
ply Chains and Domestic Manufac-
turing for a Net-Zero Economy.
• Criterion 4: Workforce and Commu-
nity Engagement.
See complete details of the technical
review criteria in Section 2.7, Technical

June 10, 2024 1494 Bulletin No. 2024–24
Review Criteria. All technical review cri-
teria will be used in a thorough, consis-
tent, and objective examination to develop
scores for ranking applications and deter-
mining merit of each proposed project.
The review of the Commercial Viability
criterion will additionally inform eligi-
bility by determining whether the project
has a reasonable expectation of commer-
cial viability, as described in § 48C(d)(3)
(A). The information requested for each
criterion will vary based on the qualify-
ing advanced energy project category, as
detailed in Section 2.7, Technical Review
Criteria.
2.4.3.3 Final Outcome for Concept
Papers
Following the compliance, eligibility,
and technical reviews, DOE may also
consider program policy factors when
determining the final portfolio of recom-
mendations (see Section 2.9, DOE Rec-
ommendation Process).
After this review, DOE will issue a
letter to applicants either encouraging
them to submit a § 48C(e) application
or discouraging them from submitting a
§ 48C(e) application.
An applicant that receives a dis-
couragement letter may still submit a
§ 48C(e) application in accordance with
the § 48C(e) program and additional
guidance. Receiving a discouragement
letter in response to a submitted concept
paper does not disqualify a taxpayer from
submitting a § 48C(e) application but
represents DOE’s feedback that the proj-
ect, as proposed, is unlikely to receive a
recommendation based on the informa-
tion provided in the concept paper. DOE
expects to transmit encouragement and
discouragement letters to applicants in the
summer of 2024.
Following the encouragement and dis-
couragement notifications, DOE will pub-
lish a summary of general feedback based
on the concept paper review process.
2.5 Stage 2, 48C(e) Application
Guidance
The second evaluation stage will con-
sist of a review of § 48C(e) applications
submitted after the concept paper stage.
Sections 2.6, Additional Application
Materials, 2.8, Submission and Regis-
tration Information and Requirements,
and 2.9, DOE Recommendation Process
describe the information about the sub-
mission process and additional instruc-
tions for applicants. Applicants may not
submit a § 48C(e) application unless they
submitted a concept paper by the specified
deadline.
The deadline for § 48C(e) applications
will be communicated to applicants in the
encouragement and discouragement let-
ters and posted on the 48C portal.
2.5.1 Application Submission
Requirements
This section outlines the format of the
§ 48C(e) application submission. Section
48C(e) applications should be formatted
and arranged as described in this sec-
tion. Strict adherence is required. Content
requirements for § 48C(e) applications
and the technical review criteria used by
DOE to evaluate them are listed in Section
2.7, Technical Review Criteria.
The applicant’s Control Number is
used throughout the submitted files.
The control number is a unique iden-
tifier generated by the 48C portal for
your application and will be deter-
mined by the system when the appli-
cant first begins your application pro-
cess.
Section 48C(e) applications must con-
form to the following requirements:
1. All § 48C(e) applications must be
written in English.
2. All pages must be formatted to fit on
8-1/2 by 11-inch paper with margins
not less than one inch on every side.
Use Times New Roman typeface,
a black font, and a font size of 11
points or larger (except in figures and
tables). A symbol font may be used to
insert Greek letters or special char-
acters; the font size requirement still
applies.
3. References must be included as foot-
notes or endnotes in a font size of 10
or larger. Footnotes and endnotes are
counted toward the maximum page
requirement.
4. The Control Number, which is the
same number used for the concept
paper, must be prominently displayed
on the upper right corner of the header
of every page. Page numbers must be
included in the footer of every page.
5. Cash flow models should be submit-
ted as a Microsoft Excel spreadsheet
and must include calculation formu-
las and assumptions.
6. All § 48C(e) applications must be
submitted in Adobe PDF format
unless stated otherwise.
Each § 48C(e) application should be
limited to a unique project with a dis-
tinct qualified investment. If projects
involve more than one specified advanced
energy property listed in Appendix A, then
applicants must choose a primary speci-
fied advanced energy property for their
project. The entire § 48C(e) application
submission includes five components: a
narrative, a workforce and community
engagement plan, a business entity certifi-
cation, a data sheet, and appendices.
The § 48C(e) application narrative
must not exceed 30 pages when printed
using the formatting requirements set
forth above and single spaced. Pages in
excess of the page limitation will not be
considered for review. No material may
be incorporated by reference as a means
to circumvent the page limitation. Section
48C(e) application narratives should be
submitted in Adobe PDF format with the
file name [ControlNumber]-48CApplica-
tion.pdf.
The workforce and community
engagement portion of the § 48C(e)
application will be submitted in a sep-
arate file and must not exceed 5 pages
when printed using the formatting
requirements set forth above and single
spaced. Pages in excess of the page limita-
tion will not be considered for review. No
material may be incorporated by reference
as a means to circumvent the page limita-
tion. The § 48C(e) application workforce
and community engagement plan should
be submitted as a separate file in Adobe
PDF format with the file name [Control-
Number]-App-WCE.pdf.
The 48C Business Entity Certification,
which supports DOE’s Due Diligence
Review, should be completed and submit-
ted as a separate file using the provided
template or a comparable format including
the same substantive information. Appli-
cants must submit the file as a PDF with
the file name [ControlNumber]-Busines-
sEntityCertification.pdf.

Bulletin No. 2024–24 1495 June 10, 2024
The 48C Application Data Sheet should
be completed and submitted as a separate
Excel document with the file name [Con-
trolNumber]-App-DataSheet.xlsx. Addi-
tional instructions for completing the 48C
Application Data Sheet are included in
Section 2.6, Additional Application Mate-
rials.
Any supporting documents should
be uploaded as separate, individual files,
preferably in Adobe PDF format. Con-
tent provided as appendices do not count
towards any page limits described above.
Note: The maximum file size that
can be uploaded to the 48C portal is 25
MB. Files in excess of 25 MB cannot be
uploaded, and hence cannot be submitted
for review. If a file exceeds 25 MB but is
still within the maximum page limit, it
must be broken into parts and denoted to
that effect. For example: “48CApplication
_Part_1.pdf”, “48CApplication_Part_2.
pdf”.
The full list of required files for
§ 48C(e) application submission is illus-
trated in the following table.
Table 4: Files Required for § 48C(e) Application Submission
ComponentFile FormatMaximum PagesFile Name
Section 48C(e) ApplicationPDF30[ControlNumber]-48CApplication.pdf
Section 48C(e) Application Workforce and
Community Engagement Plan
PDF5[ControlNumber]-App-WCE.pdf
Business Entity CertificationPDFN/A[ControlNumber]-
BusinessEntityCertification.pdf
48C Application Data SheetMS ExcelN/A[ControlNumber]-App-DataSheet.xlsx
Appendix FilesVariousN/A[ControlNumber]-Appendix-[FileTitle].
[format]
(e.g. 1234-Appendix-1.pdf)
For all files, “[ControlNumber]”
should be replaced by the application’s
control number. For example, for a control
number of 1234, the file would be named,
“1234-ConceptPaper.pdf”.
See Sections 2.6, Additional Applica-
tion Materials and 2.8, Submission and
Registration Information and Require-
ments for information on which support-
ing documents should be submitted as
appendix materials.
2.5.2 Application Submission Material
Guidelines
The following subsections contain
detailed guidance for content require-
ments for each project category—Clean
Energy Manufacturing and Recycling
Projects, Industrial Decarbonization
Projects, and Critical Material Projects—
for the § 48C(e) application stage. Appli-
cants should complete their application
package using only the guidance in this
section for their application’s project cat-
egory. The Workforce and Community
Engagement application guidelines
apply to and are consistent across all
project types.
2.5.2.1 Clean Energy and Critical
Materials Manufacturing and Recycling
Projects
Company Overview
Describe your company, your team on
the project, and prior experience produc-
ing proposed product(s).
Project Summary
• Describe the proposed facility, includ-
ing anticipated number of employees,
and geographic location.
• Indicate the objectives of the invest-
ment or project, including:
o Whether the project will estab-
lish, re-equip, or expand a facil-
ity.
o The specified advanced energy
property or project, and whether
the facility will manufacture, pro-
cess, refine, or recycle the speci-
fied advanced energy property.
If the project involves more than
one specified advanced energy
property, indicate the project’s
primary advanced energy prop-
erty, and any additional advanced
energy properties the project will
produce or recycle.
o In the case of a recycling proj-
ect, describe the facility’s prod-
ucts and the clean energy supply
chains they will support.
• Describe the equipment and processes
employed at the proposed facility to
manufacture or recycle the proposed
advanced energy property.
o If the proposed project re-equips
or expands an existing facility,
describe clearly what the pro-
posed project will add or change
in the existing facility.
o Provide a list of the anticipated
eligible property that will make
up the qualified investment of the
qualifying advanced energy proj-
ect.
• Describe any significant changes to
the project that have occurred since
the concept paper stage.
Project Management and Timeline
• Provide a project schedule from
construction through operation and

June 10, 2024 1496 Bulletin No. 2024–24
achieving full production capacity,
which demonstrates how certifica-
tion requirements will be met within
two (2) years of receiving an alloca-
tion decision from the IRS, and how
the project will be placed in service
within two (2) years of such certifica-
tion.
• Describe plans or strategies in place
to ensure sufficient provision of cru-
cial resources required for the proj-
ect’s successful execution.
• Summarize status of the Engineering,
Procurement, Construction Agree-
ments, and Operations and Mainte-
nance Agreements.
Siting and Permitting
• Explain the rationale for selecting the
project site and illustrate the site can
fully meet all environmental, water
supply, transmission interconnection,
and other necessary requirements.
• Summarize the status and plans,
including timeline to secure all
required permits such as all federal,
state, and local permits, including
environmental authorizations (if
applicable) or reviews necessary to
commence construction of the proj-
ect.
Risk Management Plan
• Identify project risks or challenges—
including legal, financial, engineer-
ing, procurement, construction, and
operational risks—and any relevant
mitigation strategies.
• Include a discussion of natural disas-
ters (e.g., earthquakes), climate
impacts and extreme weather patterns
(e.g., tornadoes, hurricanes, heat and
freezing temperatures, drought, wild-
fire, and floods) that may impact the
resilience/sustainability of the proj-
ect.
Financial Information
• Submit a cash flow model detailing
investments in and cash flows antic-
ipated over the facility’s expected
lifetime, including a description of
the methodology and all assumptions
used.
• Describe the payback period, net
present value (NPV), adjusted pres-
ent value (APV) and break-even anal-
ysis for the project and other financial
metrics including return on invest-
ment and return on assets.
• Estimate the project’s amount that
will be treated as a qualified invest-
ment (as determined under § 48C)
if the project is certified to receive
a credit. The applicant may use any
reasonable methodology and assump-
tions in estimating this amount.
• Describe the amount of equity that
will be invested in the project, includ-
ing the sources of such equity and
their strengths.
• Describe the amount of total debt
obligations that will be incurred and
the funding sources of all such debt.
• Describe any local, state, or other fed-
eral incentives or funds that are being
pursued or have been awarded for the
proposed project, such as grants, loan
guarantees, or tax credits.
o Include a description of any
instances where any federal
agencies or non-federal govern-
mental entities have entered into
an arrangement as a customer or
offtaker of the project’s products
or services, or other federal con-
tracts, including acquisitions,
leases, and other arrangements,
that may indirectly support the
applicant’s proposed project.
Market Information
• Describe the markets your products
will serve, including the existing
product market size and company
market share in dollars and volume,
and growth potential for the next 5 to
10 years.
• Discuss the current and anticipated
competitiveness of your product in
the next 5 to 10 years, including com-
peting products and competitors. Pro-
vide the estimated cost of your facil-
ity’s product and how it compares
to similar technologies or materials
in the same market segment, includ-
ing new and recycled products. This
should be expressed in the same units
as annual production (e.g., $/watt, $/
kilowatt-hour, and $/ton), and appli-
cants should include the absolute dif-
ference and percentage change from
a reasonable domestic industry aver-
age.
• Discuss your sales forecast, includ-
ing details of any offtake agreements
you may have to support your project.
Identify confirmed or potential cus-
tomers who will purchase, lease, or
otherwise use the facility’s product.
Levelized Cost Information
• For the facility’s product, discuss the
levelized cost of generated or stored
energy (LCOE), or of GHG emis-
sions abatement (LCEA), based on
costs of the full supply chain. The
reported LCOE/LCEA should assume
that the facility’s products are part of
a final clean energy installation and,
where appropriate, be based on the
financial and resource assumptions
provided in the 48C Application Data
Sheet. LCOE should be expressed in
nominal terms and should not include
any federal, state, or other financial
incentives. The following informa-
tion should be provided as documen-
tation:
o Brief description of the method-
ology used as the basis for the
calculation.
o Identification and brief ratio-
nale for the source of key values
used in the calculation, including
capital or first costs, operating
and maintenance costs, prices of
commodity fuels or feedstocks,
and carbon emissions associated
with the operation of the end-use
energy product.
o Justification for any use of a
resource-related parameter (e.g.,
capacity factor) different than the
national averages provided in the
data sheet.
o In the case of LCEA, identifica-
tion and brief rationale for the
key values associated with the
baseline energy mix, including
the cost of generation and carbon
emissions.
o Explanation of any factors
impacting the levelized cost
that could not be quantified
and included in the calculation,

Bulletin No. 2024–24 1497 June 10, 2024
and their potential directional
effect on the resulting cost (i.e.,
increase or decrease).
Explanation of any relationship
between the cost of the manufactured
property and the performance of the end
use energy product.
Management Plan
Provide the following information for
the company and key management team
members:
• Describe the ownership structure of
the company, including all beneficia-
ries.
• List key management and senior per-
sonnel for the project, including the
names, positions or titles, qualifica-
tions, and relevant experience.
• Describe the unique capabilities and
expertise of the applicant and any
major project partners.
• Include debt or equity sponsors, con-
tractors/vendors (if known), and any
other counterparty that the applicant
believes will enable the project to be
successful, as well as the prior expe-
rience of the applicant and any major
project partners in similar undertak-
ings to the proposed project.
• Summarize any pending or threatened
action, suit, proceeding, or investiga-
tion, including any action or proceed-
ing by or before any governmental
authority, that relates to the senior/
key personnel, and the status of any
appeals.
• Describe any corporate health indi-
cators, including legal claims or lia-
bilities, planned debt restructuring,
planned corporate actions, and other
factors that could negatively affect
the likelihood of project completion.
End Product GHG Emissions Impacts
• Describe the end-use application
of the facility’s products and how
their use will avoid or reduce GHG
emissions. Provide any details about
the innovation and performance of
the end product (e.g., efficiency,
range, and economic life) that indi-
cate its ability to facilitate deeper
GHG emissions reductions than
leading competitors or incumbents.
Quantitative information regarding
GHG emissions reductions enabled
by the facility’s product in typical
use should be provided in the Data
Sheet.
o Note: For applicants applying
for other advanced energy proj-
ects under section 1.1.i.(ii) of
Appendix A, Other advanced
energy property designed to
reduce greenhouse gas emis-
sions as may be determined by
the Secretary, applicants must
demonstrate a reduction of GHG
emissions is an outcome of the
manufacture of the advanced
energy property.
• Depending on the nature and applica-
tion of the advanced energy property,
applicants may choose to include the
following information:
o For facilities that produce critical
materials, components of a large
specified advanced energy prod-
uct (e.g., blade in a wind tower),
or technologies that provide indi-
rect GHG emissions reductions
(e.g., grid components, stor-
age, or charging infrastructure),
applicants should qualitatively
describe the emissions impacts
of the clean energy technologies
that are enabled by the facili-
ty’s products. Applicants should
include internal or external anal-
ysis to substantiate indirect emis-
sions benefits.
o In the case of advanced energy
property that reduces GHG
emissions relative to incumbent
technologies (e.g., clean vehi-
cle technologies compared to
conventional vehicle technolo-
gies), applicants should describe
the assumptions associated
with their estimated emissions
impacts, including anticipated
market shares, relative emissions
intensities, etc.
o In the case of recycling projects,
applicants should qualitatively
describe how the facility’s prod-
ucts are expected to reduce emis-
sions through their use and by
reducing raw material needs or
emissions associated with end-
of-life.
o In the case of advanced energy
projects under section 1.1i of
Appendix A, Other advanced
energy property designed to
reduce greenhouse gas emissions
as may be determined by the
Secretary, “low carbon energy
intensive materials,” applicants
should report emissions and
carbon intensity levels using
facility-specific, material/prod-
uct-specific cradle-to-gate Type
III (third-party verified) Envi-
ronmental Product Declarations
(EPDs), in line with the specifi-
cations found in EPA’s interim
determination for the Buy Clean
initiative for those relevant prod-
ucts.
1
The projects should reduce
carbon intensity on a life cycle
basis by at least 30% compared
to an appropriate industry-spe-
cific benchmark.
GHG Emissions from the Facility
• Qualitatively and quantitatively char-
acterize the anticipated sources of
Scope 1 or Scope 2 GHG emissions
(defined in Section 2.2, Glossary of
Terms) in the manufacturing, pro-
cessing, refining, or recycling pro-
cess. Emissions estimates should
be provided in the 48C Application
Data Sheet using the methodology
described in Section 2.6, Additional
Application Materials where avail-
able, input assumptions should be
justified with publicly available data
and engineering studies. Explain any
significant differences between direct
emissions from the facility and indus-
try averages.
1
https://www.epa.gov/system/files/documents/2023-01/2022.12.22%20Interim%20Determination%20on%20Low%20Carbon%20Materials%20under%20IRA%2060503%20and%20
60506_508.pdf

June 10, 2024 1498 Bulletin No. 2024–24
• Provide any details about the man-
ufacturing, processing, refining, or
recycling process (e.g., efficiency,
lifetime, electrification, low-carbon
fuels, etc.) that indicate its poten-
tial to result in lower emissions than
leading competitors or incumbents.
Wherever possible, the applicant
should substantiate assessments of
process improvements with descrip-
tions of recent analysis or engineering
studies.
Describe any planned efforts to mit-
igate GHG emissions of the proposed
facility.
Impact on U.S. Supply Chains and
Domestic Manufacturing
• Indicate whether production from the
facility covers multiple supply chain
segments—processed material, sub-
components, components, systems/
end products—and how those seg-
ments interact.
• Indicate whether the facility’s prod-
ucts will be used in multiple speci-
fied advanced energy technologies
(e.g., wind, solar, and electric grid) or
multiple sectors (e.g., transportation,
industry, and electricity). Reference
any offtake or sales arrangements
provided in the Commercial Viability
section to justify the end-use applica-
tions.
• For Critical Material projects,
describe whether the facility’s prod-
ucts align with U.S. federal, state,
or local domestic content require-
ments, such as those in the § 30D tax
credit. Reference any offtake or sales
arrangements provided in the Com-
mercial Viability Criterion section to
justify the end-use applications.
• In the 48C Application Data Sheet,
submit the relevant production capac-
ity information for the facility’s out-
puts and justify each in the § 48C(e)
Application narrative.
o Annual production capacity
includes yield loss and through-
put data wherever applicable and
possible.
o Manufacturing Contribution
identifies the value added in the
production of the facility’s out-
put, as a fraction. Applicants
should transparently state and
justify current and future pricing
assumptions for all significant
value chain segments, including
the product produced at the pro-
posed facility.
o Share of Facility Output rep-
resents the portion of the facility
output that was used in the pro-
duction of eligible clean energy
products as opposed to other
applications. Where possible,
applicants manufacturing mul-
tiple products (or products with
multiple applications) should uti-
lize offtake or sales agreements
to demonstrate the portion that
will go to eligible applications.
o Deployed product lifetime rep-
resents the service lifetime of the
facility’s output (not the lifetime
of the facility itself). The appli-
cant should provide and substan-
tiate assumptions with market
reports and/or field data, where
relevant.
Supply Chain Resilience
• Describe how your facility’s products
will help build resilience of domes-
tic supply chains that are critical for
energy products that facilitate prog-
ress towards a net-zero economy,
from raw materials to end-of-life. For
instance, critical materials producers
intending to serve the battery market
should indicate the extent to which
their project supports the electric
vehicle or stationary energy storage
supply chains, as opposed to con-
sumer electronics.
• Describe key inputs needed for your
manufacturing or recycling process.
Describe any known sources for your
inputs, including indicating domestic
sources and any current or anticipated
supply chain vulnerabilities.
Workforce and Community Engagement
(as a separate PDF document)
In a separate PDF document, describe
your plan for contributing to job creation
and ensuring project viability, timely com-
pletion, and ultimate success by fostering
a stable and supportive workforce and host
community. The following sub-sections
outline specific content to be included in
the separate PDF document, all of which
apply to all project types. Applicants
are encouraged to use Specific, Measur-
able, Achievable, Relevant, and Timely
(SMART) milestones wherever possible
and where relevant.
Job Creation and Workforce Continuity
• Describe the applicant’s approach to
creating and maintaining high-qual-
ity jobs for both new and incumbent
workers. Characterize and estimate
the number and quality of jobs your
project will create (e.g., mechanics
and construction workers).
o Include both direct and indirect
jobs both during completion of
the project (the credit period)
and during operation of the facil-
ity after it is placed in service and
any indicators of job quality.
• Describe partnerships with appren-
ticeship readiness programs, regis-
tered apprenticeship programs, or
community-based workforce training
and support organizations serving
displaced industrial workers.
o Include the coal, other energy,
and automotive sectors, and oth-
ers facing systematic barriers to
employment to facilitate partici-
pation in the project’s construc-
tion and operations.
• Summarize the applicant’s plan to
attract, train, and retain a skilled and
well-qualified workforce both during
construction/completion of the proj-
ect (the credit period) and during
operations/production activities of
the facility after it is placed in service.
o A collective bargaining agree-
ment, labor-management part-
nership, or other similar agree-
ment would provide evidence
of such a plan. Alternatively,
or additionally, applicants may
describe:
 Wages, benefits, and other
worker supports to be pro-
vided as benchmarked at or
above prevailing wages for
construction and the upper
quartile of wages for the

Bulletin No. 2024–24 1499 June 10, 2024
occupation and industry for
operations/production
2
;
 Commitments to invest in
workforce education and
training, including measures
to reduce attrition, increase
productivity from a commit-
ted and engaged workforce,
and support the develop-
ment of a resilient, skilled,
and stable workforce for the
project, including specific
efforts to recruit, train, and
retain workers underrepre-
sented in the sector, local
workers, and others fac-
ing systematic barriers to
employment with measur-
able goals to achieve these
outcomes; and
 Efforts to engage employees
in the design and execution
of workplace safety and
health plans.
• Describe employer commitments to
support employees’ ability to orga-
nize, bargain collectively, and partic-
ipate, through labor organizations of
their choosing, in decisions that affect
them. This could include remaining
neutral during any union organizing
campaigns, permitting union recogni-
tion through card check (as opposed
to requiring union elections), willing-
ness to enter into binding arbitration
to settle first contracts, refraining
from holding captive audience meet-
ings, or other supportive measures.
Ensuring Timely Project Completion
Through Workforce and Community
Engagement
Describe current and planned agree-
ments, partnerships or other efforts to
engage with community and labor stake-
holders, including as it relates to strength-
ening support of the community, work-
force recruitment and retention, and the
ability to execute the project on schedule
and with adequate workforce.
• Provide a comprehensive list of stake-
holders that the project has engaged
or plans to engage from local gov-
ernments, Tribal governments, labor
unions, and community-based orga-
nizations.
• Describe current and planned efforts
to engage with listed stakeholders,
including as it relates to the ability to
complete the project in a timely and
effective manner and with adequate
workforce.
• Describe current and planned efforts
to ensure availability of the work-
force needed to successfully complete
the project and place it in service in
a timely manner, including through
training programs that serve workers
currently underrepresented in the sec-
tor.
• Describe any activities to strengthen
support of the community such as
through benefit-sharing agreements,
consideration of environmental
impact, and use of local resources.
Discussions should reference any
existing or draft agreements, commit-
ments or plans to develop agreements
such as Good Neighbor Agreements/
Community Benefits Agreements,
Collective Bargaining Agreements,
Project Labor Agreements or Com-
munity Workforce Agreements.
Existing agreements must be pro-
vided in the submission package as
appendix files.
Energy Community Transition
Describe the extent to which the project
will support energy communities.
• Describe specific actions to support
energy communities, including tran-
sition opportunities for workers in the
coal, other energy, and automotive
sectors. Discussion should reference
engagement with unions, workforce
boards, and/or community-based
workforce training and support orga-
nizations serving displaced industrial
workers.
• If applicable, include discussion on
plans to repurpose existing infrastruc-
ture/assets that have been abandoned
due to the closing of a coal mine or
coal plant.
Local Environmental Impacts
Describe the impact of your project on
local air, water, and/or land quality, as
well as any efforts to mitigate local pollu-
tion and waste.
• Discuss any anticipated negative and
cumulative environmental impacts
of the project, including impacts on
local air, water, and/or land quality.
Describe any efforts to mitigate local
pollution and waste.
• Determine whether the location or
community qualifies as a disad-
vantaged community according to
the Climate and Economic Justice
Screening Tool (CEJST).
• Within the context of cumulative
environmental impacts, applicants
should use the U.S. Environmental
Protection Agency’s Environmen-
tal Justice Screening and Mapping
(EJSCREEN) tool (https://www.epa.
gov/ejscreen) to quantitatively dis-
cuss existing environmental impacts
in the project area.
• If anticipated project benefits will
flow to an applicable disadvantaged
community, identify applicable bene-
fits that are quantifiable, measurable,
and trackable, such as:
1. A decrease in energy burden;
2. A decrease in environmental
exposure and burdens;
3. An increase in access to low-cost
capital;
4. An increase in high-quality job
creation, the clean energy job
pipeline, and job training for
individuals;
5. Increases in clean energy enter-
prise creation and contracting
(e.g., through investment in
underserved and underrepre-
sented businesses);
6. Increases in energy democracy,
including community ownership;
7. Increased parity in clean energy
technology access and adoption;
and
8. An increase in energy resilience.
• Discuss how the project will maxi-
mize all the benefits listed above.
2
See BLS data on these wage rates here: List of SOC Occupations (bls.gov)

June 10, 2024 1500 Bulletin No. 2024–24
• Describe how and when anticipated
benefits are expected to flow to the
disadvantaged community. For exam-
ple, will the benefits be provided
directly within the disadvantaged
communities identified, or are the
benefits expected to flow in another
way? Further, will the benefits flow
during project development or after
project completion, and how will
applicant track benefits delivered?
2.5.2.2 Industrial Decarbonization
Projects
Company Overview
Describe your company, your team on
the project, prior experience retrofitting
technologies to reduce GHG emission,
and any company commitments related to
reducing GHG emissions from manufac-
turing, industrial, or recycling facilities.
Project Summary
• Describe the eligible industrial or
manufacturing facility to be retrofit-
ted, including, anticipated number
of employees, geographical location,
baseline emissions compared to peers
in your industry.
• Include a detailed description of the
equipment and processes employed at
the proposed facility.
• Indicate which technologies or pro-
cesses will be pursued to reduce the
facility’s GHG emissions by at least
20%, including low- or zero-carbon
process heating systems; carbon cap-
ture, transport, utilization, or storage
systems; energy efficiency and reduc-
tion in waste; or other industrial tech-
nology.
• Estimate the project’s anticipated
emissions reductions in both absolute
and percentage terms (relative to your
facility’s baseline emissions). Indi-
cate whether the retrofit project will
achieve the required 20% reduction
in (a) Scope 1 emissions (defined
in Section 2.2, Glossary of Terms),
Scope 2 emissions (defined in Sec-
tion 2.2, Glossary of Terms), or total
(Scope 1 and Scope 2) emissions, and
(b) subunit emissions or facility wide
emissions.
• Describe any significant changes to
the project scope that have occurred
since the concept paper stage.
Project Management and Timeline
• Provide a project schedule from
construction through operation and
achieving full production capacity,
which demonstrates how certification
requirements will be met within two
(2) years of receiving an allocation
decision from the IRS, and how the
project will be placed in service within
two (2) years of such certification.
• Describe plans or strategies in place
to ensure sufficient provision of cru-
cial resources required for the proj-
ect’s successful execution.
• Summarize status, engineering, pro-
curement, construction agreements,
and Operations and Maintenance
Agreements.
Siting and Permitting
• Explain the rationale for selecting
the project site and illustrate that the
site can fully meet all environmental,
water supply, transmission intercon-
nection, and other necessary require-
ments.
• Summarize the status and plans to
secure all required permits such as
all federal, state, and local permits,
including environmental authoriza-
tions (if applicable) or reviews neces-
sary to commence construction of the
project.
Risk Management Plan
• Identify project risks or challenges
and any relevant mitigation strate-
gies.
• Include a discussion of natural disas-
ters (e.g., earthquakes), climate
impacts and extreme weather patterns
(e.g., tornadoes, hurricanes, heat and
freezing temperatures, drought, wild-
fire, and floods) that may impact the
resilience/sustainability of the project.
Financial Information
• Describe the financial viability of the
project and provide supporting met-
rics such as payback period, net pres-
ent value (NPV), or return on invest-
ment and return on assets.
• Estimate the project‘s qualified
investment (as determined under
§ 48C) if the project is certified to
receive a credit. The applicant may
use any reasonable methodology
and assumptions in estimating this
amount.
• Calculate the levelized cost of mea-
sured reduction in GHG emissions
(based on costs of the full supply
chain) that will be enabled by the
project. Instructions for calculating
levelized cost metrics are provided in
Section 2.6, Additional Application
Materials.
• Explain the methodology and assump-
tions used in the § 48C(e) application
narrative.
Market Information
• Discuss the current and anticipated
competitiveness of your product in
the next 5 to 10 years, after retrofit-
ting and how it compares to similar
technologies or materials in the same
market segment, including conven-
tional and lower-carbon products.
This should be expressed in the same
units as annual production (e.g., $/
watt, $/kilowatt-hour, and $/ton) per
the instructions in the 48C Applica-
tion Data Sheet. Applicants should
include the absolute difference and
percentage change from a reasonable
domestic industry average.
Management Plan
Provide the following information for
the company and key management team
members:
• Describe the ownership structure of
the company, including all beneficia-
ries.
• List key management and senior per-
sonnel for the project, including the
names, positions or titles, qualifica-
tions, and relevant experience.
• Describe the unique capabilities and
expertise of the applicant and any
major project partners.
• Include debt or equity sponsors, con-
tractors/vendors (if known), and any

Bulletin No. 2024–24 1501 June 10, 2024
other counterparty that the applicant
believes will enable the project to be
successful, as well as the prior expe-
rience of the applicant and any major
project partners in similar undertak-
ings to the proposed project.
• Summarize any pending or threatened
action, suit, proceeding, or investiga-
tion, including any action or proceed-
ing by or before any governmental
authority, that relates to the senior/
key personnel, and the status of any
appeals.
• Describe any corporate health indi-
cators, including legal claims or
liabilities, planned debt restructur-
ing, planned corporate actions, and
other factors that could negatively
affect the likelihood of project com-
pletion.
GHG Emissions from the Facility
• Describe the portions of the industrial
or manufacturing process that will be
re-equipped by the project, the nature
of the improvements, and how the
improvements drive emissions reduc-
tions. Include a description of the
extent to which best-in-class technol-
ogies are deployed.
• Describe and quantify the Scope 1
and Scope 2 GHG emissions (defined
in Section 2.2, Glossary of Terms) of
the facility immediately before and
after the retrofit project, including
interactions between Scope 1 and
Scope 2 emissions (e.g., electrifi-
cation projects may reduce Scope 1
emissions but increase Scope 2 emis-
sions). Express post-retrofit emis-
sions reductions in both absolute and
relative (% reduction) terms, where
the latter must be at least 20%.
• Applicants should report emissions
levels using facility-specific, mate-
rial/product-specific cradle-to-gate
Type III (third-party verified) Envi-
ronmental Product Declarations
(EPDs), in line with the specifications
found in EPA’s interim determination
for the Buy Clean initiative for those
relevant products.
3
• Emissions should be calculated
and submitted in the 48C Applica-
tion Data Sheet, which is based on
the EPA Greenhouse Gas Report-
ing Protocol and EPA’s Simplified
GHG Emissions Calculator (https://
www.epa.gov/climateleadership/
simplified-ghg-emissions-calcula-
tor). Large industrial facilities with
existing GHGRP reports should
also submit their GHG emissions
figures from the most recent calen-
dar year, expressed in metric tons
of CO
2
equivalent. Explain any sig-
nificant differences between direct
emissions from the facility and a
reasonable domestic industry aver-
age.
Supply Chain Resilience
• Describe the extent to which the
equipment used to facilitate the GHG
emissions reductions at your facil-
ity is produced domestically. For
instance, a project utilizing carbon
capture equipment should explain
whether they are sourcing from
domestic CCUS companies or manu-
facturers.
• Describe how your project will
help strengthen resilience of critical
domestic supply chains that facil-
itate progress towards a net-zero
economy, including by spurring or
fulfilling the growing demand for
low-carbon construction materials,
such as those covered in the Buy
Clean Initiative.
• Describe the extent to which the
retrofit project employs innovative
solutions that can enhance U.S. lead-
ership and industrial competitiveness.
Include the use of advanced industrial
or manufacturing approaches.
Workforce and Community Engagement
(as a separate PDF document)
See the application material requirements
in Section 2.5.2.1, Clean Energy and Crit-
ical Materials Manufacturing and Recy-
cling Projects above.
2.5.3 Application Review Process
Overview
2.5.3.1 Compliance and Eligibility
Review
DOE will carry out an initial compli-
ance review for § 48C(e) applications to
determine that (1) the eligibility require-
ments have been met, (2) the required
information has been submitted, (3) the
proposed project is technically valid, and
(4) all mandatory requirements of this
notice are satisfied. As part of this review,
DOE will determine whether the proposed
project meets the definition of a qualifying
advanced energy project, as described in
Appendix A.
If a § 48C(e) application fails to meet
compliance or eligibility requirements
or fails to provide sufficient information
for evaluation, DOE reserves the right
to request clarifications and/or missing
information from some or all applicants
through written submissions provided to
DOE in a timely manner. Section 48C(e)
applications that fail to meet the compli-
ance and eligibility requirements or do not
provide sufficient information for evalu-
ation will be considered non-responsive,
and DOE will recommend a denial of
allocation without proceeding to technical
review.
2.5.3.2 Technical Review
After the § 48C(e) application compli-
ance and eligibility review, DOE will per-
form a technical review process based on
four technical review criteria:
• Criterion 1: Commercial Viability
• Criterion 2: Greenhouse Gas Emis-
sions Impacts
• Criterion 3: Strengthening U.S. Sup-
ply Chains and Domestic Manufac-
turing for a Net-Zero Economy
• Criterion 4: Workforce and Commu-
nity Engagement
See complete details of the technical
review criteria for § 48C(e) applications
in Section 2.7, Technical Review Criteria
of this appendix. All technical review cri-
teria will be used in a thorough, consis-
3
https://www.epa.gov/system/files/documents/2023-01/2022.12.22%20Interim%20Determination%20on%20Low%20Carbon%20Materials%20under%20IRA%2060503%20and%20
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June 10, 2024 1502 Bulletin No. 2024–24
tent, and objective examination to develop
scores for ranking applications and deter-
mining merit of each proposed project.
The review of the Commercial Viability
criterion will additionally inform eligi-
bility by determining whether the project
has a reasonable expectation of commer-
cial viability, as required by § 48C(d)(3)
(A). The information requested for each
criterion will vary based on the qualify-
ing advanced energy project category, as
detailed in Section 2.7, Technical Review
Criteria.
2.5.3.3 Due Diligence Review
To ensure the § 48C(e) program sup-
ports strengthening and securing U.S. sup-
ply chains and domestic manufacturing to
the greatest extent possible, DOE may
conduct a due diligence review to deter-
mine if an applicant has a connection with
an entity that could put these goals at risk.
2.5.3.4 Final Recommendation for
§ 48C(e) Applications
Following the compliance, eligibility,
and technical reviews, DOE may also
consider program policy factors and the
results of the due diligence review when
determining the final portfolio of recom-
mendations (see Section 2.9.1, Program
Policy Factors).
2.6 Additional Application Materials
2.6.1 Data Sheet
To capture and process informa-
tion submitted in the concept paper and
§ 48C(e) application, applicants are
required to fill out and submit the supple-
mentary Concept Paper Data Sheet and
48C Application Data Sheet, respectively.
The above sections on content and form of
concept papers and § 48C(e) applications
indicate which categories of information
will be captured in the data sheet. This
section provides explanations and exam-
ples on select terms for which the appli-
cant may benefit from additional informa-
tion. This list is not exhaustive, and there
will be unique questions for each project
category within the Data Sheet template
for the concept paper and § 48C(e) appli-
cation stages. Refer to the Data Sheet for
specific information requested relevant
to your project.
Applicants should substantiate in their
narrative any data which is inputted into
either Data Sheet. It is essential that appli-
cants conform to this process in order to
ensure a competitive review of all appli-
cations.
2.6.1.1 Levelized Cost
The 48C Application Data Sheet for
Clean Energy Manufacturing and Recy-
cling projects requires applicants to iden-
tify their levelized cost of energy (LCOE)
and/or emissions abatement (LCEA). The
48C Application Data Sheet will provide
stock information, such as inflation rates,
taxes and insurance, and depreciation.
LCOE should be expressed in nominal
terms and should not include any fed-
eral, state, or other financial incentives.
Further, plant and related cost values and
prices of commodity fuels or feedstocks
used in the calculation should reflect cur-
rent national wholesale averages where
possible.
The following information should be
provided as documentation:
• Brief description of the methodology
used as the basis for the calculation.
This methodology should be a com-
monly accepted industry standard.
• Identification and brief rationale for
the source of key values used in the
calculation, including capital or first
costs, operating and maintenance
costs, prices of commodity fuels or
feedstocks, and carbon emissions
associated with the operation of the
end-use energy product.
• Justification for any use of a
resource-related parameter (e.g.,
capacity factor) different than the
national averages provided.
• In the case of LCEA, identification
and brief rationale for the key values
associated with the baseline energy
mix, including the cost of generation
and carbon emissions.
• Explanation of any factors impact-
ing the levelized cost that could not
be quantified and included in the
calculation, and their potential direc-
tional effect on the resulting cost (i.e.,
increase or decrease).
• Explanation of any relationship
between the cost of the manufactured
property and the performance of the
end use energy product.
• If possible, an “unimproved” level-
ized cost calculation that does not
reflect the input of the manufactured
property (e.g., relies on the competi-
tive standard of the day), based on the
same financial and resource assump-
tions used in the “improved” calcula-
tion.
If the applicant chooses to provide
an LCOE or LCEA value for the closest
comparable end use energy product from
a published study, the following informa-
tion should be provided as documentation:
• Explanation of why a value either
could not be calculated or was not
appropriate to calculate for the end-
use energy product.
• Brief description of the methodology
used in the cited study.
• Identification of key assumptions
used in the study, including the year
basis for which the cost is reported (if
the cost is reported in real terms; e.g.,
$2011), the year of costs and prices of
fuel commodities, the year to which
the end cost value is referenced (e.g.,
could be a future year), the extent of
technology improvement assumed for
the comparable end use energy prod-
uct, the regional extent of the base-
line assumed (e.g., global, the United
States, or a region of United States),
the carbon emissions associated with
the baseline energy mix and the end-
use energy product, the key finan-
cial assumptions (e.g., interest rates,
taxes, and incentives included), and
the resource-related parameters (e.g.,
capacity factors).
• Explanation of how the above
assumptions differ from those pro-
vided above for guiding the calcu-
lation of the cost of abatement, and
the potential directional effect of
these differences on the study’s cost
value (i.e., if the aforementioned
assumptions required for cost of
abatement calculation had been
used, explain whether the study’s
cost value likely have increased or
decreased).

Bulletin No. 2024–24 1503 June 10, 2024
2.6.2 Section 48C(e) Application
Appendix Files
In the § 48C(e) application stage, the
applicant is required to include the follow-
ing appendix materials and may include
others at their discretion:
• Cashflow model for project economic
evaluation
• If the project involves process
improvement: Copy of internal or
external analysis or engineering stud-
ies to substantiate assessments of
process improvements. An example
would be a front-end engineering and
design (FEED) study for an industrial
retrofit project.
• Operations and Maintenance Agree-
ments
• A letter of approval for the project from
the controlling shareholders or board
of directors explicitly indicated their
commitment to financing the project
supported by an attachment of a certi-
fied project Engineering, Procurement
and Construction (EPC) contract.
• Copy of site plan, together with evi-
dence that applicant owns or controls
a site. Examples of evidence would
include a deed, or an executed con-
tract to purchase or lease the site.
• Copy of audited financial statements
for the applicant and other projected
funding sources for the most recently
ended three (3) fiscal years, and the
unaudited quarterly interim financial
statements for the current fiscal year.
If all three years of audited statements
are not available, provide all available
statements and any additional docu-
ments that provide similar evidence
of corporate health.
• Lists of all federal, state, and local
permits, including environmental
authorizations or reviews, necessary
to commence construction.
• Any existing equity or debt fund-
ing commitments or expressions of
interest from equity or debt financing
sources for the project.
• Expressions of interest or commit-
ment letters from potential customers.
• Offtake agreements (optional).
• Diagrams, schematics, and/or images
(e.g., process flow diagrams) to
clearly illustrate the proposed facility
or proposed changes to an existing
facility.
• Workforce and Community Engage-
ment Agreements, such as Good
Neighbor Agreements/Community
Benefits Agreements, Collective Bar-
gaining Agreements, Project Labor
Agreements or Community Work-
force Agreements.
• Resumes for key management and
senior personnel for the project, pref-
erably submitted as a single Adobe
PDF document labeled Resumes.pdf.
• For energy-intensive materials that
have a substantially lower car-
bon intensity projects: A life cycle
assessment showing at least a 30%
reduction in the carbon intensity of
the product compared to the indus-
try standard, using facility-specific,
material/product-specific cradle-to-
gate Type III (third-party verified)
Environmental Product Declarations
(EPDs), in line with the specifications
found in EPA’s interim determination
for the Buy Clean initiative for those
relevant products.
4
2.7 Technical Review Criteria
2.7.1 Clean Energy Manufacturing and
Critical Materials Projects
This section describes the technical
review criteria that DOE will use to evalu-
ate Clean Energy Manufacturing and Crit-
ical Materials Projects. The criteria below
will apply for both concept papers and
applications. Applicants should ONLY
extend their materials to address itali-
cized criteria during the § 48C(e) appli-
cation, consistent with the application
materials requested. Italicized criteria
will not be considered during the con-
cept paper stage.
2.7.1.1 Criterion 1: Commercial
Viability
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• Project schedule and time from certi-
fication to completion:
o Readiness to proceed with the
proposed project and reasonable-
ness of the timeframe required
for construction and commis-
sioning of the project;
o The extent to which tasks are
well described and important
risks and mitigation strategies
are identified and addressed; and
o Readiness to proceed with the
proposed project as evidenced
by firmness of site selection
and progress towards secur-
ing required permits, contracts,
reviews, agreements, and mile-
stones for each identified task.
• Strength of the proposed business
plan, including:
o The potential for commercial
deployment, based on estimates
of market share, market growth
potential, and price competitive-
ness of the product.
o The source and certainty of fund-
ing for the equity that will be
invested in the project, including
private financing, DOE funding,
state and local incentives, and
other sources.
o The degree to which proposed
budget is realistic based on
spending plan and contingencies.
o The degree to which the invest-
ment is profitable, based on the
project economics as described
in cash flow analysis of the proj-
ect.
o The strength of key arrange-
ments, such as financing, acqui-
sition/supply strategy, and power
purchase agreements for the pro-
posed project, as well as offtake
(sales) arrangements for the
facility’s products.
o The levelized cost of generated
or stored energy, or of measured
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June 10, 2024 1504 Bulletin No. 2024–24
reduction in energy consumption
or GHG emission (or similar
metric) for the facility’s products,
compared to similar technolo-
gies or materials within the same
market segment.
• Strength of the proposed manage-
ment plan, including the manage-
ment team’s track record of success
in areas relevant to the project and
corporate health of the applicant.
In assessing each item above, the fol-
lowing will be considered: (a) the com-
prehensiveness, specificity, and accuracy
of the information and plans provided, (b)
the reasonableness of assumptions used
in making estimations and projections,
and (c) the extent to which the applicant
demonstrates an understanding of rele-
vant risks and the quality of the strategies
put forward to mitigate and manage those
risks.
2.7.1.2 Criterion 2: Greenhouse Gas
Emissions Impacts
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• End Product: The extent to which
the end product will help avoid or
reduce anthropogenic GHG emis-
sion and contribute to reaching the
national target of net-zero emissions
by 2050. For Critical Materials Proj-
ects, this includes the extent to which
there is clear evidence that the pro-
duced critical material(s) will be used
in the manufacturing of clean energy
technologies that are needed in a net-
zero economy. For low carbon ener-
gy-intensive materials, this includes
the extent to which the technologies
used to reduce production emissions
contribute to reaching the national
target of net-zero emissions. Pref-
erence will be given to projects that
result in products in the lowest 20
percent of embodied greenhouse gas
emissions when compared to similar
products, in line with EPA’s interim
determination for what constitutes
“substantially lower” embodied emis-
sions for the Buy Clean initiative for
those relevant materials.
5
• Facility: The extent to which the proj-
ect plan minimizes GHG emissions
from the facility itself through best-
in-class technologies or approaches
that exceed those of incumbents or
competitors, including activities to
monitor facility emissions and energy
use.
• Upstream Supply Chain: The extent
that the project plan includes strat-
egies to reduce emissions in the
upstream supply chain (e.g., through
contracts with low-emissions suppli-
ers).
2.7.1.3 Criterion 3: Strengthening
U.S. Supply Chains and Domestic
Manufacturing for a Net-Zero Economy
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• Filling supply chain gap: The degree
to which a project’s product addresses
a critical gap in the supply chain of
technologies needed to achieve net-
zero emissions. (For projects involv-
ing critical materials, evaluation will
also consider the extent to which the
project proposes to produce materi-
als listed in the USGS/DOE Critical
Materials assessment or demonstrates
cost competitiveness through the pro-
duction of a combination of critical
and non-critical materials).
• Federal tax credit efficiency: the
extent to which federal tax credit
support for the project will effec-
tively enhance the development of the
domestic supply chain and manufac-
turing and expedite the deployment of
clean energy products. This includes:
o 48C credit impact: The extent to
which project demonstrates the
need for 48C program support,
describing how the resources
will be leveraged, potentially
including but not limited to
increased output (as represented
by added capacity per tax credit
requested), minimized waste,
optimized manufacturing pro-
cesses, decreased product price,
or improved product project eco-
nomics; and
o Support expansion of domes-
tic supply chains: The extent
to which the project expands
manufacturing and acceler-
ates deployment of clean energy
products, as demonstrated by
whether the proposed product
will be used in the production of
one or more clean energy prod-
ucts or technologies, domestic
versus international production
today, and capacity added com-
pared to market gap.
In the case of recycling projects, these
technical review criteria will be evaluated
based on which materials are produced at
the recycling facility and evidence that
those produced materials will serve as
inputs to clean energy supply chains.
2.7.1.4 Criterion 4: Workforce and
Community Engagement
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• Job Creation and Workforce Continu-
ity:
o The number of domestic jobs
created (both direct and indi-
rect) (a) during completion of the
project (the credit period) and (b)
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Bulletin No. 2024–24 1505 June 10, 2024
during operations of the facil-
ity after it is placed in service,
including jobs within energy
communities (if applicable)
attained by locals or individuals
previously employed by the local
or regional coal industry.
o The quality of new and/or
retained jobs in construction
and in operations/production
(both hired directly and by third
parties) including wages and
employer-sponsored benefits for
all classifications, employment
statuses (i.e. full-time, part-time,
contractor), health and safety
programs and standards, and
phases of work.
o The extent to which the appli-
cant engaged key stakeholders
to develop partnerships to bet-
ter serve local and underrepre-
sented workers through training
and support that may include a
collective bargaining agreement,
labor-management partnership,
registered apprenticeship or
pre-apprenticeship programs, or
detailed workforce development
and continuity plans.
o The extent to which the project
guarantees employees the ability
to organize, bargain collectively,
and participate, through labor
organizations of their choosing,
in decisions that affect them and
that contribute to the effective
conduct of business and facil-
itates amicable settlements of
any potential disputes between
employees and employers, pro-
viding assurances of project effi-
ciency, continuity, and multiple
public benefits.
o The extent to which job qual-
ity and workforce continuity
commitments are formalized in
agreements for each phase of the
project that may include Project
Labor Agreements, Community
Workforce Agreements, Collec-
tive Bargaining Agreements,
or Community Benefits Agree-
ments that include conditions of
employment.
o The extent to which applicant
demonstrates sufficient supply of
appropriately skilled labor, and
an effective plan to minimize the
risk of labor disputes or disrup-
tions.
• Ensuring Timely Project Completion
Through Workforce and Community
Engagement:
o The extent of current and planned
efforts to engage community and
labor stakeholders and degree to
which these engagements have
led to or are likely to lead to
formal agreements (e.g., project
labor agreements, collective bar-
gaining agreements, community
benefits agreements).
o The extent to which the applicant
demonstrates community and
labor engagement to date that
results in support of the commu-
nity for the proposed project and
availability and continuity of the
necessary workforce.
o The extent to which the appli-
cant has a clear and appropri-
ately robust plan to engage with
labor unions, Tribal entities,
and community-based organiza-
tions that support or work with
disadvantaged communities
and other affected stakeholders
and the degree to which these
engagements have led to or are
likely to lead to formal agree-
ments.
o The extent to which the applicant
has considered accountability
to affected workers and com-
munity stakeholders, including
those most vulnerable to project
activities with a plan to publicly
share Workforce and Community
Engagement commitments.
• Energy Community Transition:
o The extent to which the appli-
cation includes specific actions
to support energy communities,
including transition opportuni-
ties for workers in the coal, other
energy, and automotive sectors
into clean energy sectors.
o The extent to which a project will
utilize existing local and regional
resources that previously sup-
ported the local or regional coal
industry or repurpose existing
infrastructure/assets that have
been abandoned due to closing
of a coal mines or coal plant.
• Local Environmental Impacts:
o The extent to which the proposed
project accounts for its environ-
mental impact to the surrounding
community by having clear plans
to avoid or reduce local air pollu-
tion, land contamination, and/or
water contamination.
o The extent to which the applica-
tion identifies specific, measur-
able benefits for disadvantaged
communities, including energy
communities, and how negative
environmental impacts affect-
ing disadvantaged communities
would be mitigated.
2.7.2 Industrial Decarbonization
Projects
This section describes the technical
review criteria that DOE will use to eval-
uate Industrial Decarbonization Projects.
The criteria below will apply for both con-
cept papers and applications. Applicants
should ONLY extend their materials to
address italicized criteria during the
§ 48C(e) application, consistent with
the application materials requested.
Italicized criteria will not be considered
during the concept paper stage.
2.7.2.1 Criterion 1: Commercial
Viability
See the description of the Commercial
Viability criterion in Section 2.7.1.1, Cri-
terion 1: Commercial Viability.
2.7.2.2 Criterion 2: Greenhouse Gas
Emissions Impacts
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• Avoided Emissions: The extent
to which the described emissions
reductions are comprehensive, spe-
cific, reasonable, and significant
(based on combined Scope 1 and

June 10, 2024 1506 Bulletin No. 2024–24
Scope 2 emissions) and correspond
to at least a 20% reduction in GHG
emissions, accounting for any antic-
ipated changes to the facility’s pro-
duction volumes. Preference will
be given to projects that result in
products in the lowest 20 percent of
embodied greenhouse gas emissions
when compared to similar products,
in line with EPA’s interim determi-
nation for what constitutes “substan-
tially lower” embodied emissions
for the Buy Clean initiative for those
relevant materials.
6
• Cost of Avoided Emissions: The
extent to which the project achieves a
low levelized cost of measured reduc-
tion in GHG emissions (based on
capital expenditures and/or tax credit
dollars requested).
• Technology Innovation: The extent
to which the project uses current
best-in-class industrial or manufac-
turing approaches and innovative,
low-emissions equipment, fuels, feed-
stocks, or processes.
• Scalability: The extent to which the
project will contribute to the achieve-
ment of net-zero emissions in the U.S.
by 2050, including the potential for
the approach to be applied beyond
the specific project location.
2.7.2.3 Criterion 3: Strengthening
U.S. Supply Chains and Domestic
Manufacturing for a Net-Zero Economy
Applicants should ONLY extend
their materials to address italicized cri-
teria during the § 48C(e) application,
consistent with the application materi-
als requested. Italicized criteria will not
be considered during the concept paper
stage.
• The extent to which the proposed
project enhances U.S. leadership
in low emissions manufacturing as
demonstrated by implementing inno-
vative technologies such as install-
ing energy efficient equipment that
improve the U.S. competitive edge in
low carbon manufacturing processes.
• The extent to which the project will
advance the commercial viability and
uptake of replicable, cross-cutting
decarbonization approaches in major
industrial applications such as energy
efficiency, electrification, LCFFES,
material efficiency or substitution,
and CCUS.
2.7.2.4 Criterion 4: Workforce and
Community Engagement
See the description of the Workforce
and Community Engagement criterion in
Section 2.7.1.4, Criterion 4: Workforce
and Community Engagement.
2.8 Submission and Registration
Information and Requirements
2.8.1 General Application
Requirements
Applicants must submit a concept
paper at Stage 1 and a § 48C(e) applica-
tion at Stage 2. All submitted materials
must be prepared in accordance with the
guidance in this notice to provide a stan-
dard basis for review and to ensure that
each application will be uniform as to for-
mat and sequence.
Concept papers and § 48C(e) applica-
tions should clearly address each of the
eligibility requirements and applicable
technical review criteria to demonstrate
the applicant’s capability, knowledge, and
experience regarding the requirements
described herein.
Applicants should fully address the
requirements of Notice 2023-18, Notice
2023-44 and this notice and not rely on any
presumed background knowledge. DOE
will discourage a concept paper or recom-
mend the rejection of a § 48C(e) applica-
tion that does not follow the instructions
regarding the organization and content
when the nature of the deviation and/or
omission precludes meaningful review of
the project.
All concept papers and § 48C(e)
applications must be submitted through
the 48C portal to be considered for DOE
recommendation under this notice.
Concept papers and § 48C(e) appli-
cations received after the stated dead-
lines will not be reviewed or considered
for DOE recommendation.
2.8.2 Determining an Application’s
Project Category
Eligible projects under the § 48C(e)
program, as described in Appendix A, are
classified into three overarching project
categories: Clean Energy Manufacturing
and Recycling Projects, Industrial Decar-
bonization Projects, and Critical Material
Projects. Before developing application
materials, an applicant must determine
which qualifying advanced energy project
category is most applicable to their proj-
ect.
Section 2.5, Stage 2, 48C(e) Applica-
tion Guidance, of this guidance contains
instructions for content requirements for
all project categories. Section 2.7, Tech-
nical Review Criteria of this guidance
contains instructions for technical review
criteria specific to each project category.
Applicants should only complete their
application package using the appropriate
guidance in Section 2.5, Stage 2, 48C(e)
Application Guidance, corresponding to
the applicant’s self-determined qualify-
ing advanced energy project category. It
is incumbent upon the applicant to ade-
quately justify their determination of
project category through application nar-
ratives.
The following table may assist appli-
cants in determining the qualifying
advanced energy project category most
appropriate for their proposed project.
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Bulletin No. 2024–24 1507 June 10, 2024
Table 5: Determining the qualifying advanced energy project category.
Project CategoryThis Category Includes...Application
Materials
Technical Review
Criteria
Clean Energy
Manufacturing and
Recycling
• Facilities that produce one or more specified
advanced energy properties, or its components
or materials, described in Appendix A, Section
1.1, Clean Energy Manufacturing and Recycling
Projects; or
• Facilities that recycle one or more specified
advanced energy properties described in Appendix
A, Section 1.1, Clean Energy Manufacturing and
Recycling Projects.
Section 2.5Section 2.7.1
Industrial
Decarbonization
• Projects at existing industrial or manufacturing
facilities that reduce GHG emissions by at least
20%.
• Note: Facilities are not required to produce
products or materials with energy applications or
those described in Appendix A, Section 1.1, Clean
Energy Manufacturing and Recycling Projects
and Appendix A, Section 1.3, Critical Material
Projects.
Section 2.5Section 2.7.2
Critical Materials • Facilities that process, refine, or recycle one or
more critical materials described in Appendix
A, Section 1.3, Critical Material Projects.
Section 2.5Section 2.7.1
2.8.3 48C Portal for Submission of
Application
The 48C portal will provide a single
interface for applicants through all steps of
the § 48C(e) application process, includ-
ing concept paper submission, receipt of
concept paper feedback, § 48C(e) appli-
cation submission, receipt of an allocation
or denial letter from the IRS, submission
of evidence documents to DOE for cer-
tification, receipt of a certification letter
from the IRS, submission of notification
to DOE that the project has been placed in
service or otherwise disposed, and receipt
of notification from the IRS that the appli-
cant may claim the credit.
Files required for submission of con-
cept papers, including concept paper
templates and data sheets, are avail-
able for applicants at https://eco.energy.
gov/48C/ on the date of this notice. DOE
cannot accept any application mate-
rials outside of the formal 48C portal,
including via email. The 48C portal will
be open for registration and submission
of concept papers no later than May 28,
2024.
2.8.3.1 Submission of Application
All § 48C(e) application materials
must be submitted through the 48C portal
at https://eco.energy.gov/48C/ to be con-
sidered by DOE. Section 48C(e) applica-
tions submitted by any other means will
not be accepted. Note: The 48C portal
website address has been modified since
Notice 2023-44 was published, and the
address specified in this guidance must
be used.
The applicant will receive an auto-
mated response when the concept paper
or § 48C(e) application is received. This
will serve as confirmation of receipt. Do
not reply to the automated response. It is
the responsibility of the applicant to ver-
ify successful transmission prior to the
concept paper and § 48C(e) application
deadlines.
In order to submit concept papers and
§ 48C(e) applications, all applicants must
register an account in the 48C portal at
https://eco.energy.gov/48C/ . It is recom-
mended that each applicant organization
designate a primary contact point respon-
sible for each submission. The primary
user may specify an additional contact
within their organization who may regis-
ter in the portal as a backup user.
Potential applicants will be required
to have an ID.me account to access the
48C portal. As part of the 48C portal
registration process, new users will be
directed to create an account in ID.me.
Note: The email address associated with
ID.me must match the email address
associated with the 48C portal account.
For more information, refer to the 48C
Login Guide, which will be available in
the Manuals section of the 48C portal at
https://eco.energy.gov/48C/ no later than
May 28, 2024.
2.8.3.2 Help with 48C Portal
Applicants may email 48CQuestions@
hq.doe.gov for questions regarding the
registration process or submitting your
application on the 48C portal.
For questions regarding other non-tax
aspects of the § 48C(e) program unrelated
to the 48C portal, see Section 2.11, Ques-
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June 10, 2024 1508 Bulletin No. 2024–24
2.8.4 Application Forms and Format of
Submissions
Applicants must log in to the 48C por-
tal to download all required forms and
submit concept papers and § 48C(e) appli-
cations to be considered for a § 48C(e)
credit allocation. The applicant will have
the opportunity to re-submit revised appli-
cation materials for any reason as long as
the revision is submitted by the specified
deadline.
2.8.5 Electronic Authorization of
Applications
Submission of § 48C(e) application
materials through electronic systems used
by DOE, including the 48C portal or its
successor, will constitute the authorized
representative’s approval and electronic
signature.
2.8.6 Markings of Confidential
Information
If elements of a § 48C(e) application
contain information the taxpayer consid-
ers to be trade secrets, confidential, priv-
ileged, or otherwise exempt from disclo-
sure under the Freedom of Information
Act (FOIA, 5 U.S.C. § 552), the taxpayer
may assert a claim of exemption at the
time of application by placing the follow-
ing text on the first page of the § 48C(e)
application, and specifying the page or
pages of the § 48C(e) application to be
restricted:
“Pages [list applicable pages] of this
document may contain trade secrets,
confidential, proprietary, or privileged
information that is exempt from pub-
lic disclosure. Such information shall
be used or disclosed only for evalua-
tion purposes. The Government may
use or disclose any information that is
not appropriately marked or otherwise
restricted, regardless of source. [End of
Notice]”
The header and footer of every page that
contains confidential, proprietary, or priv-
ileged information must be marked as fol-
lows: “Contains Trade Secrets, Confiden-
tial, Proprietary, or Privileged Information
Exempt from Public Disclosure.” In addi-
tion, each line or paragraph containing
proprietary, privileged, or trade secret
information must be clearly marked with
double brackets or highlighting.
2.9 DOE Recommendation Process
The final outcome of each stage of
the DOE review process is to develop a
recommendation and ranking (DOE rec-
ommendation) of projects. DOE will pro-
vide a recommendation and ranking for a
project only if it determines that the appli-
cation meets all requirements described
in this guidance, and that the project is
eligible, has a reasonable expectation of
commercial viability, merits a recommen-
dation, and supports program policy fac-
tors when considering the full portfolio of
recommended projects.
2.9.1 Program Policy Factors
In addition to the criteria described in
Section 2.7, Technical Review Criteria
DOE may also consider the following pro-
gram policy factors when determining the
DOE recommendation.
• The degree to which the proposed
project contributes to a portfolio that
optimizes the use of available credit
amounts to address existing or antici-
pated gaps, vulnerabilities, or oppor-
tunities and to expand domestic man-
ufacturing capacity in priority supply
chains in a timely manner.
• The degree to which the proposed
project contributes to a portfolio
that efficiently uses available credit
amounts to enable significant addi-
tional reductions in industrial GHG
emissions, such as projects with low
levelized cost of abatement of GHG
emissions and those that are close to
the margins of being cost effective
but would not be without support of
the 48C program.
• The degree to which the proposed
project contributes to a portfolio that
enhances American industrial and
manufacturing competitiveness in a
global net-zero economy.
• The degree to which the proposed
project exhibits technological and
product diversity when compared to
other projects recommended for allo-
cation.
• The degree to which the proposed
project contributes to portfolio diver-
sity within a project category and
across project categories.
• The degree to which the proposed
project contributes to a portfolio that
supports a diversity of organizational
sizes, including small- and medi-
um-sized manufacturers.
• The degree to which the proposed
project is likely to contribute to a
long-term, place-based, coordinated,
and collaborative regional economic
development strategy.
• The degree to which the project will
contribute to follow-on supply chain
investments in the region.
• The degree to which the proposed
project, or group of projects, repre-
sent a desired geographic distribu-
tion, when compared to other projects
recommended for allocation.
• The degree to which the proposed
project will accelerate transforma-
tional technological advances in areas
that industry by itself is not likely to
undertake because of financial uncer-
tainty.
• The degree to which the proposed
project contributes to a portfolio of
recommended projects with at least
40% of credits allocated to projects in
energy communities, as described in
§ 48C(e)(2).
• The degree to which the proposed
project, and other projects recom-
mended for allocation, contributes to
the total portfolio meeting the goals
reflected in the Workforce and Com-
munity Engagement technical review
criterion.
• The degree to which the proposed
project has broad public support
from the communities most directly
impacted by the project.
• The degree to which the project con-
tributes to a portfolio that meets the
goals reflected in the Workforce and
Community Engagement technical
review criterion by producing addi-
tional benefits to communities, par-
ticularly disadvantaged communities,
such as reducing co-pollutants and
other environmental (e.g., air and
water) burdens.

Bulletin No. 2024–24 1509 June 10, 2024
2.9.2 DOE Recommendations
2.9.2.1 Concept Paper
Recommendations
For the concept paper stage, the DOE
recommendation will include all projects
that are encouraged to submit a § 48C(e)
application. Projects that are not included
in the DOE recommendation will receive
a letter of discouragement. An applicant
that receives a letter of discouragement
in response to a submitted concept paper
may still submit a § 48C(e) application in
accordance with this guidance. Receiving
such a letter does not disqualify an appli-
cant from submitting a § 48C(e) applica-
tion but represents DOE’s feedback that
the project is unlikely to receive a recom-
mendation based on the information pro-
vided in the concept paper.
2.9.2.2 Section 48C(e) Application
Recommendations
For the § 48C(e) application stage, the
DOE recommendation will include the
portfolio of projects that help to achieve
the goals of the program. This recommen-
dation will be based on a combination
of the numeric score from the technical
review process, as well as the application
of the above program policy factors.
2.10 Post Allocation
2.10.1 Requirements for Certification
As described in this notice, applica-
tions receiving allocation letters must
provide evidence that they have met the
requirements for certification, such as all
permits necessary to commence construc-
tion and any other documents that sup-
port metrics on production capacity, job
creation, GHG emissions reduction, and
overall commercial viability of the proj-
ect. Applicants will upload documents
providing this evidence to the 48C portal
not later than 2 years from the date the
IRS notified the applicant that they have
received an allocation.
DOE’s recommendation is based in
part on commitments and other claims
stated by the applicant in the § 48C(e)
application. The evidence provided by the
applicant for certification must therefore
also include documents demonstrating
that any commitments or other claims in
the § 48C(e) application have been met.
These documents could include Com-
munity Benefits Agreements, collective
bargaining agreements, contracts, offtake
agreements, or any other commitments
or arrangements claimed in the § 48C(e)
applications that may have had an impact
on the evaluation of the application. Doc-
uments already provided as appendices in
the § 48C(e) application do not need to be
submitted again for certification. Addi-
tional documents may be required, which
will be shared at or after the time of allo-
cation.
2.10.2 Request for Debriefing
Upon receiving a denial letter from the
IRS, applicants can request a debriefing
with DOE on its review of the § 48C(e)
application. The denial letter will include
instructions for requesting a debriefing.
Upon request, DOE will offer a
debriefing to an applicant that sub-
mitted a § 48C(e) application (after
submitting a concept paper and being
encouraged to submit such § 48C(e)
application) and subsequently, was not
allocated a credit in Round 2 of the
§ 48C(e) program. Debriefings will not
be available to applicants that receive
a letter of discouragement. Debrief-
ings will be held by DOE after the
application period ends. Requests for
a debriefing must be received by DOE
no later than 30 business days from
the date of the Denial Letter issued to
the applicant. The sole purpose of the
debriefing is to provide DOE’s impres-
sion of the strengths and weaknesses
of the rejected § 48C(e) application to
enable applicants to improve § 48C(e)
applications for future rounds of the
§ 48C(e) program or § 48C credit allo-
cation programs.
2.11 Questions/Comments and
Informational Webinar
2.11.1 Questions and Comments
Any questions or comments regarding
the non-tax aspects of this notice can be
submitted to the Department of Energy
at 48CQuestions@hq.doe.gov. DOE may
post questions and answers related to this
notice in the Frequently Asked Questions
(FAQs) section at https://www.energy.
gov/infrastructure/48C. Any questions
or comments received under this notice
are subject to public release pursuant to
the Freedom of Information Act. DOE
is under no obligation to respond to, or
acknowledge receipt of, any questions or
comments submitted under this notice and
any responses provided do not constitute
legal advice provided by either DOE or
the IRS.
Questions related to the 48C portal
should be directed to 48CQuestions@
hq.doe.gov. This includes questions about
account registration or using the portal.
Questions regarding application materi-
als, eligibility, the DOE review process, or
other programmatic questions not about
the portal should not be sent to this email
address.
2.11.2 Informational Webinar
DOE will conduct one or more infor-
mational webinars during the application
process. They will be held before the due
date for the § 48C(e) application.
Attendance is not mandatory and will
not positively or negatively impact the
review of any applicant submissions. As
the webinar will be open to all applicants
who wish to participate, applicants should
refrain from asking questions or commu-
nicating information that would reveal
confidential and/or proprietary informa-
tion specific to their project.
The informational webinar will be held
no later than May 31, 2024. Additional
information including a link for registra-
tion can be found at https://www.energy.
gov/infrastructure/48C .

June 10, 2024 1510 Bulletin No. 2024–24
APPENDIX C
Section 48C(e) Energy Communities Census Tracts
Census tracts that have ever had, since December 31, 1999, a closed coal mine or have ever had, since December 31, 2009, a
retired coal-fired electric generating unit, and directly adjoining tracts, except for census tracts with applicants that previ-
ously received a § 48C credit allocation prior to the date of enactment of the IRA.
This Appendix C supersedes Appendix C of Notice 2023-44
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
AlabamaBaldwin County01003010100Directly adjoining
AlabamaBibb County01007010001Mine closure, Directly adjoining
AlabamaBibb County01007010005Directly adjoining
AlabamaBibb County01007010006Mine closure, Directly adjoining
AlabamaBibb County01007010007Directly adjoining
AlabamaBibb County01007010008Mine closure, Directly adjoining
AlabamaBibb County01007010009Directly adjoining
AlabamaBibb County01007010010Directly adjoining
AlabamaBibb County01007010011Directly adjoining
AlabamaBlount County01009050104Directly adjoining
AlabamaBlount County01009050200Directly adjoining
AlabamaBlount County01009050502Directly adjoining
AlabamaBlount County01009050601Directly adjoining
AlabamaBlount County01009050603Directly adjoining
AlabamaBlount County01009050701Directly adjoining
AlabamaBlount County01009050702Mine closure
AlabamaCherokee County01019955701Directly adjoining
AlabamaCherokee County01019956101Directly adjoining
AlabamaChilton County01021060404Directly adjoining
AlabamaClarke County01025957901Directly adjoining
AlabamaClarke County01025957902Directly adjoining
AlabamaClarke County01025958003Directly adjoining
AlabamaColbert County01033020500Directly adjoining
AlabamaColbert County01033020600Directly adjoining
AlabamaColbert County01033020901Directly adjoining
AlabamaColbert County01033020902Generating unit retirement
AlabamaColbert County01033021000Directly adjoining
AlabamaCullman County01043965501Directly adjoining
AlabamaCullman County01043965502Directly adjoining
AlabamaCullman County01043965600Directly adjoining
AlabamaCullman County01043965700Mine closure, Directly adjoining
AlabamaDeKalb County01049960101Directly adjoining
AlabamaDeKalb County01049960102Directly adjoining
AlabamaDeKalb County01049960200Mine closure, Directly adjoining
AlabamaDeKalb County01049960301Directly adjoining
AlabamaDeKalb County01049960303Directly adjoining

Bulletin No. 2024–24 1511 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
AlabamaDeKalb County01049960401Directly adjoining
AlabamaDeKalb County01049960402Mine closure
AlabamaDeKalb County01049960500Directly adjoining
AlabamaDeKalb County01049960900Directly adjoining
AlabamaDeKalb County01049961100Directly adjoining
AlabamaDeKalb County01049961200Directly adjoining
AlabamaDeKalb County01049961400Directly adjoining
AlabamaFayette County01057020000Directly adjoining
AlabamaFayette County01057020100Directly adjoining
AlabamaFayette County01057020300Directly adjoining
AlabamaFayette County01057020400Mine closure, Directly adjoining
AlabamaFranklin County01059973100Directly adjoining
AlabamaFranklin County01059973702Directly adjoining
AlabamaFranklin County01059973703Directly adjoining
AlabamaJackson County01071950101Directly adjoining
AlabamaJackson County01071950102Mine closure, Directly adjoining
AlabamaJackson County01071950200Directly adjoining
AlabamaJackson County01071950301Mine closure, Directly adjoining
AlabamaJackson County01071950302Generating unit retirement, Directly adjoining
AlabamaJackson County01071950400Directly adjoining
AlabamaJackson County01071950601Directly adjoining
AlabamaJackson County01071950901Directly adjoining
AlabamaJackson County01071951000Mine closure, Directly adjoining
AlabamaJackson County01071951101Directly adjoining
AlabamaJefferson County01073011206Directly adjoining
AlabamaJefferson County01073011301Directly adjoining
AlabamaJefferson County01073011303Directly adjoining
AlabamaJefferson County01073011304Mine closure, Directly adjoining
AlabamaJefferson County01073011401Directly adjoining
AlabamaJefferson County01073011402Mine closure, Directly adjoining
AlabamaJefferson County01073011500Directly adjoining
AlabamaJefferson County01073011600Mine closure, Directly adjoining
AlabamaJefferson County01073011704Mine closure, Directly adjoining
AlabamaJefferson County01073011706Directly adjoining
AlabamaJefferson County01073011707Directly adjoining
AlabamaJefferson County01073011708Directly adjoining
AlabamaJefferson County01073011710Directly adjoining
AlabamaJefferson County01073012001Directly adjoining
AlabamaJefferson County01073012103Directly adjoining
AlabamaJefferson County01073012104Mine closure, Directly adjoining
AlabamaJefferson County01073012200Directly adjoining
AlabamaJefferson County01073012302Mine closure, Directly adjoining
AlabamaJefferson County01073012304Directly adjoining

June 10, 2024 1512 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
AlabamaJefferson County01073012307Directly adjoining
AlabamaJefferson County01073012403Directly adjoining
AlabamaJefferson County01073012500Directly adjoining
AlabamaJefferson County01073014001Directly adjoining
AlabamaJefferson County01073014002Directly adjoining
AlabamaJefferson County01073014104Directly adjoining
AlabamaJefferson County01073014106Mine closure, Directly adjoining
AlabamaJefferson County01073014107Directly adjoining
AlabamaJefferson County01073014207Directly adjoining
AlabamaLamar County01075030000Mine closure
AlabamaLamar County01075030101Directly adjoining
AlabamaLamar County01075030102Directly adjoining
AlabamaLauderdale County01077011200Directly adjoining
AlabamaMarion County01093964001Mine closure, Directly adjoining
AlabamaMarion County01093964002Directly adjoining
AlabamaMarion County01093964100Directly adjoining
AlabamaMarion County01093964300Directly adjoining
AlabamaMarion County01093964401Directly adjoining
AlabamaMarion County01093964402Directly adjoining
AlabamaMarion County01093964500Mine closure, Directly adjoining
AlabamaMarion County01093964600Directly adjoining
AlabamaMarion County01093964701Directly adjoining
AlabamaMarion County01093964702Mine closure, Directly adjoining
AlabamaMobile County01097005702Directly adjoining
AlabamaMobile County01097005800Generating unit retirement
AlabamaMobile County01097005900Directly adjoining
AlabamaMobile County01097006000Directly adjoining
AlabamaRandolph County01111000200Directly adjoining
AlabamaShelby County01117030337Directly adjoining
AlabamaShelby County01117030350Directly adjoining
AlabamaShelby County01117030405Directly adjoining
AlabamaShelby County01117030406Directly adjoining
AlabamaShelby County01117030407Directly adjoining
AlabamaShelby County01117030408Mine closure, Directly adjoining
AlabamaShelby County01117030607Directly adjoining
AlabamaShelby County01117030610Directly adjoining
AlabamaShelby County01117030611Mine closure, Directly adjoining
AlabamaShelby County01117030613Directly adjoining
AlabamaTuscaloosa County01125010101Directly adjoining
AlabamaTuscaloosa County01125010102Mine closure, Directly adjoining
AlabamaTuscaloosa County01125010104Directly adjoining
AlabamaTuscaloosa County01125010105Directly adjoining
AlabamaTuscaloosa County01125010203Directly adjoining

Bulletin No. 2024–24 1513 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
AlabamaTuscaloosa County01125010500Directly adjoining
AlabamaTuscaloosa County01125010601Mine closure, Directly adjoining
AlabamaTuscaloosa County01125010603Directly adjoining
AlabamaTuscaloosa County01125010604Directly adjoining
AlabamaTuscaloosa County01125010703Directly adjoining
AlabamaTuscaloosa County01125010706Mine closure, Directly adjoining
AlabamaTuscaloosa County01125010707Directly adjoining
AlabamaTuscaloosa County01125010802Directly adjoining
AlabamaTuscaloosa County01125010803Directly adjoining
AlabamaTuscaloosa County01125010804Directly adjoining
AlabamaWalker County01127020100Mine closure, Directly adjoining
AlabamaWalker County01127020200Directly adjoining
AlabamaWalker County01127020302Directly adjoining
AlabamaWalker County01127020400Directly adjoining
AlabamaWalker County01127020600Directly adjoining
AlabamaWalker County01127020700Directly adjoining
AlabamaWalker County01127020801Directly adjoining
AlabamaWalker County01127020802Mine closure, Directly adjoining
AlabamaWalker County01127020900Mine closure, Directly adjoining
AlabamaWalker County01127021000Mine closure, Directly adjoining
AlabamaWalker County01127021100Mine closure, Directly adjoining
AlabamaWalker County01127021200Mine closure, Directly adjoining
AlabamaWalker County01127021300Mine closure, Directly adjoining
AlabamaWalker County01127021400Mine closure, Directly adjoining
AlabamaWalker County01127021500Mine closure, Generating unit retirement,
Directly adjoining
AlabamaWalker County01127021600Mine closure, Directly adjoining
AlabamaWalker County01127021700Mine closure, Directly adjoining
AlabamaWalker County01127021800Mine closure, Directly adjoining
AlabamaWalker County01127021900Mine closure, Directly adjoining
AlabamaWashington County01129044000Directly adjoining
AlabamaWashington County01129044100Generating unit retirement
AlabamaWashington County01129044200Directly adjoining
AlabamaWashington County01129044300Directly adjoining
AlabamaWinston County01133965501Directly adjoining
AlabamaWinston County01133965502Directly adjoining
AlabamaWinston County01133965503Directly adjoining
AlabamaWinston County01133965601Mine closure, Directly adjoining
AlabamaWinston County01133965602Directly adjoining
AlabamaWinston County01133965700Directly adjoining
AlabamaWinston County01133965800Mine closure, Directly adjoining
AlabamaWinston County01133965900Mine closure, Directly adjoining
AlaskaFairbanks North Star Borough02090001501Directly adjoining
AlaskaFairbanks North Star Borough02090001700Directly adjoining

June 10, 2024 1514 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
AlaskaFairbanks North Star Borough02090001902Directly adjoining
AlaskaFairbanks North Star Borough02090980100Generating unit retirement
ArizonaApache County04001970201Directly adjoining
ArizonaApache County04001970300Directly adjoining
ArizonaApache County04001970502Directly adjoining
ArizonaCoconino County04005001500Directly adjoining
ArizonaCoconino County04005002000Directly adjoining
ArizonaCoconino County04005002101Directly adjoining
ArizonaCoconino County04005002102Directly adjoining
ArizonaCoconino County04005942201Directly adjoining
ArizonaCoconino County04005942202Generating unit retirement
ArizonaMohave County04015950103Directly adjoining
ArizonaMohave County04015951404Directly adjoining
ArizonaMohave County04015951601Directly adjoining
ArizonaMohave County04015951602Directly adjoining
ArizonaMohave County04015951702Directly adjoining
ArizonaNavajo County04017940014Directly adjoining
ArizonaNavajo County04017940015Directly adjoining
ArizonaNavajo County04017942300Directly adjoining
ArizonaNavajo County04017960100Directly adjoining
ArizonaNavajo County04017960200Directly adjoining
ArizonaNavajo County04017960400Directly adjoining
ArizonaNavajo County04017960500Generating unit retirement, Directly adjoining
ArizonaNavajo County04017960600Directly adjoining
ArizonaNavajo County04017963300Generating unit retirement, Directly adjoining
ArizonaNavajo County04017963400Directly adjoining
ArizonaNavajo County04017963800Directly adjoining
ArizonaNavajo County04017964202Directly adjoining
ArkansasCrittenden County05035030602Directly adjoining
ArkansasFranklin County05047950201Directly adjoining
ArkansasJohnson County05071951700Directly adjoining
ArkansasJohnson County
05071951800Mine closure
ArkansasJohnson County05071951900Directly adjoining
ArkansasJohnson County05071952000Directly adjoining
ArkansasLogan County05083950100Directly adjoining
ArkansasLogan County05083950200Directly adjoining
ArkansasScott County05127950100Directly adjoining
ArkansasSebastian County05131010102Directly adjoining
ArkansasSebastian County05131010202Directly adjoining
ArkansasSebastian County05131010301Directly adjoining
ArkansasSebastian County05131010303Mine closure, Directly adjoining
ArkansasSebastian County05131010304Mine closure, Directly adjoining
CaliforniaInyo County06027000800Directly adjoining

Bulletin No. 2024–24 1515 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
CaliforniaKern County06029000102Directly adjoining
CaliforniaKern County06029000104Directly adjoining
CaliforniaKern County06029000105Directly adjoining
CaliforniaKern County06029000106Directly adjoining
CaliforniaKern County06029000201Directly adjoining
CaliforniaKern County06029000300Directly adjoining
CaliforniaKern County06029000400Directly adjoining
CaliforniaKern County06029000601Directly adjoining
CaliforniaKern County06029000702Directly adjoining
CaliforniaKern County06029000800Directly adjoining
CaliforniaKern County06029000902Directly adjoining
CaliforniaKern County06029000914Directly adjoining
CaliforniaKern County06029003900Directly adjoining
CaliforniaKern County06029004605Directly adjoining
CaliforniaKern County06029005103Generating unit retirement, Directly adjoining
CaliforniaKern County06029005104Directly adjoining
CaliforniaKern County06029005205Directly adjoining
CaliforniaKern County06029005206Directly adjoining
CaliforniaKern County06029005207Directly adjoining
CaliforniaKern County06029005208Generating unit retirement, Directly adjoining
CaliforniaKern County06029005300Directly adjoining
CaliforniaKern County06029005410Directly adjoining
CaliforniaKern County06029005509Directly adjoining
CaliforniaKern County06029006500Directly adjoining
CaliforniaRiverside County06065030104Directly adjoining
CaliforniaRiverside County06065040101Directly adjoining
CaliforniaRiverside County06065042300Directly adjoining
CaliforniaSan Bernardino County06071003606Directly adjoining
CaliforniaSan Bernardino County06071003609Directly adjoining
CaliforniaSan Bernardino County06071003612Directly adjoining
CaliforniaSan Bernardino County06071004001Directly adjoining
CaliforniaSan Bernardino County06071004003Directly adjoining
CaliforniaSan Bernardino County06071004004Generating unit retirement
CaliforniaSan Bernardino County06071006601Directly adjoining
CaliforniaSan Bernardino County06071007107Directly adjoining
CaliforniaSan Bernardino County06071008901Generating unit retirement
CaliforniaSan Bernardino County06071010300Directly adjoining
CaliforniaSan Bernardino County06071011602Directly adjoining
CaliforniaSan Bernardino County06071012500Directly adjoining
CaliforniaSan Bernardino County06071025000Directly adjoining
CaliforniaSan Joaquin County06077002100Directly adjoining
CaliforniaSan Joaquin County06077002201Directly adjoining
CaliforniaSan Joaquin County06077002202Directly adjoining

June 10, 2024 1516 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
CaliforniaSan Joaquin County06077002300Directly adjoining
CaliforniaSan Joaquin County06077002800Generating unit retirement
CaliforniaSan Joaquin County06077003700Directly adjoining
CaliforniaSan Joaquin County06077003803Directly adjoining
CaliforniaTulare County06107002701Directly adjoining
CaliforniaTulare County06107004301Directly adjoining
CaliforniaTulare County06107004500Directly adjoining
ColoradoAdams County08001008802Directly adjoining
ColoradoAdams County08001008901Directly adjoining
ColoradoAdams County08001009001Directly adjoining
ColoradoAdams County08001009003Directly adjoining
ColoradoAdams County08001009004Directly adjoining
ColoradoAdams County08001009103Directly adjoining
ColoradoAdams County08001009104Directly adjoining
ColoradoAdams County08001009307Directly adjoining
ColoradoAdams County08001009553Directly adjoining
ColoradoAdams County08001015000Generating unit retirement
ColoradoArapahoe County08005005551Directly adjoining
ColoradoArapahoe County08005005701Directly adjoining
ColoradoBaca County08009964600Directly adjoining
ColoradoBaca County08009964700Directly adjoining
ColoradoBent County08011966702Directly adjoining
ColoradoBoulder County08013012207Directly adjoining
ColoradoBoulder County08013012208Directly adjoining
ColoradoBoulder County08013012603Directly adjoining
ColoradoBoulder County08013012701Directly adjoining
ColoradoBoulder County08013012705Directly adjoining
ColoradoBoulder County08013012707Generating unit retirement
ColoradoBoulder County08013012708Directly adjoining
ColoradoBoulder County08013012709Directly adjoining
ColoradoBoulder County08013012710Directly adjoining
ColoradoBoulder County08013012801Directly adjoining
ColoradoBoulder County08013012802Directly adjoining
ColoradoBoulder County08013012903Directly adjoining
ColoradoBoulder County08013013003Directly adjoining
ColoradoCostilla County08023972700Directly adjoining
ColoradoCuster County08027970101Directly adjoining
ColoradoCuster County08027970102Directly adjoining
ColoradoDelta County08029964600Mine closure, Directly adjoining
ColoradoDelta County08029964700Directly adjoining
ColoradoDelta County08029964800Directly adjoining
ColoradoDelta County08029965001Directly adjoining
ColoradoDelta County08029965002Directly adjoining

Bulletin No. 2024–24 1517 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
ColoradoDelta County08029965202Directly adjoining
ColoradoDenver County08031001402Directly adjoining
ColoradoDenver County08031001403Directly adjoining
ColoradoDenver County08031001500Directly adjoining
ColoradoDenver County08031004602Directly adjoining
ColoradoDenver County08031004603Directly adjoining
ColoradoDenver County08031015600Generating unit retirement
ColoradoDenver County08031015700Directly adjoining
ColoradoDolores County08033000100Directly adjoining
ColoradoEl Paso County08041001500Directly adjoining
ColoradoEl Paso County08041001600Directly adjoining
ColoradoEl Paso County08041001700Directly adjoining
ColoradoEl Paso County08041002200Directly adjoining
ColoradoEl Paso County08041002300Generating unit retirement
ColoradoEl Paso County08041002802Directly adjoining
ColoradoEl Paso County08041003001Directly adjoining
ColoradoFremont County08043978100Directly adjoining
ColoradoFremont County08043978200Directly adjoining
ColoradoFremont County08043978300Mine closure
ColoradoFremont County08043978400Directly adjoining
ColoradoFremont County08043978500Directly adjoining
ColoradoFremont County08043978600Directly adjoining
ColoradoFremont County08043978800Directly adjoining
ColoradoFremont County08043979001Directly adjoining
ColoradoFremont County08043979002Directly adjoining
ColoradoFremont County08043979100Directly adjoining
ColoradoFremont County08043979200Generating unit retirement
ColoradoFremont County08043979400Directly adjoining
ColoradoFremont County08043980100Directly adjoining
ColoradoFremont County08043980300Directly adjoining
ColoradoGarfield County08045951901Directly adjoining
ColoradoGarfield County08045952003Directly adjoining
ColoradoGarfield County08045952100Mine closure, Directly adjoining
ColoradoGunnison County08051963601Directly adjoining
ColoradoGunnison County08051963800Directly adjoining
ColoradoGunnison County08051963900Mine closure, Directly adjoining
ColoradoHinsdale County08053973100Directly adjoining
ColoradoHuerfano County08055960902Directly adjoining
ColoradoJefferson County08059009806Directly adjoining
ColoradoJefferson County08059009842Directly adjoining
ColoradoJefferson County08059009852Directly adjoining
ColoradoJefferson County08059009854Directly adjoining
ColoradoJefferson County08059009855Directly adjoining

June 10, 2024 1518 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
ColoradoJefferson County08059009857Directly adjoining
ColoradoJefferson County08059009901Generating unit retirement
ColoradoJefferson County08059010001Directly adjoining
ColoradoJefferson County08059980800Directly adjoining
ColoradoKiowa County08061960100Directly adjoining
ColoradoLa Plata County08067940400Directly adjoining
ColoradoLa Plata County08067970701Mine closure
ColoradoLa Plata County08067970703Directly adjoining
ColoradoLa Plata County08067970705Directly adjoining
ColoradoLa Plata County08067970900Directly adjoining
ColoradoLa Plata County08067971000Directly adjoining
ColoradoLa Plata County08067971100Directly adjoining
ColoradoLas Animas County08071000100Directly adjoining
ColoradoLas Animas County08071000200Directly adjoining
ColoradoLas Animas County08071000300Mine closure, Directly adjoining
ColoradoLas Animas County08071000400Directly adjoining
ColoradoLas Animas County08071000500Generating unit retirement
ColoradoLas Animas County08071000800Directly adjoining
ColoradoMesa County08077001102Directly adjoining
ColoradoMesa County08077001200Directly adjoining
ColoradoMesa County08077001302Directly adjoining
ColoradoMesa County08077001303Directly adjoining
ColoradoMesa County08077001402Directly adjoining
ColoradoMesa County08077001403Directly adjoining
ColoradoMesa County08077001404Directly adjoining
ColoradoMesa County08077001502Directly adjoining
ColoradoMesa County08077001504Directly adjoining
ColoradoMesa County08077001600Directly adjoining
ColoradoMesa County08077001702Generating unit retirement, Directly adjoining
ColoradoMesa County08077001703Directly adjoining
ColoradoMesa County08077001705Directly adjoining
ColoradoMesa County
08077001706Directly adjoining
ColoradoMesa County08077001800Mine closure, Directly adjoining
ColoradoMesa County08077001900Mine closure, Directly adjoining
ColoradoMoffat County08081000300Directly adjoining
ColoradoMoffat County08081000600Mine closure, Directly adjoining
ColoradoMontezuma County08083941100Directly adjoining
ColoradoMontezuma County08083969000Directly adjoining
ColoradoMontezuma County08083969100Directly adjoining
ColoradoMontrose County08085966100Mine closure, Generating unit retirement,
Directly adjoining
ColoradoMontrose County08085966201Directly adjoining
ColoradoMontrose County08085966202Directly adjoining
ColoradoMontrose County08085966501Directly adjoining

Bulletin No. 2024–24 1519 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
ColoradoMontrose County08085966602Directly adjoining
ColoradoOuray County08091967601Directly adjoining
ColoradoOuray County08091967602Directly adjoining
ColoradoPitkin County08097000101Directly adjoining
ColoradoPitkin County08097000102Directly adjoining
ColoradoProwers County08099000100Directly adjoining
ColoradoProwers County08099000200Directly adjoining
ColoradoProwers County08099000300Directly adjoining
ColoradoProwers County08099000600Directly adjoining
ColoradoProwers County08099000700Generating unit retirement
ColoradoPueblo County08101002804Directly adjoining
ColoradoPueblo County08101003103Directly adjoining
ColoradoPueblo County08101003104Directly adjoining
ColoradoPueblo County08101003105Directly adjoining
ColoradoPueblo County08101003106Generating unit retirement
ColoradoPueblo County08101003200Directly adjoining
ColoradoRio Blanco County08103951100Directly adjoining
ColoradoRio Blanco County08103951200Directly adjoining
ColoradoRoutt County08107000100Directly adjoining
ColoradoRoutt County08107000200Directly adjoining
ColoradoRoutt County08107000300Mine closure, Directly adjoining
ColoradoRoutt County08107000400Directly adjoining
ColoradoRoutt County08107000500Directly adjoining
ColoradoRoutt County08107000800Directly adjoining
ColoradoSaguache County08109977600Directly adjoining
ColoradoSan Juan County08111972600Directly adjoining
ColoradoSan Miguel County08113968103Directly adjoining
ColoradoSan Miguel County08113968200Directly adjoining
ColoradoTeller County08119010203Directly adjoining
ConnecticutFairfield County09001070400Directly adjoining
ConnecticutFairfield County09001070500Directly adjoining
ConnecticutFairfield County
09001070600Generating unit retirement
ConnecticutFairfield County09001070900Directly adjoining
ConnecticutFairfield County09001071200Directly adjoining
ConnecticutFairfield County09001071300Directly adjoining
ConnecticutFairfield County09001071600Directly adjoining
ConnecticutFairfield County09001073900Directly adjoining
ConnecticutFairfield County09001074000Directly adjoining
ConnecticutFairfield County09001074400Directly adjoining
ConnecticutFairfield County09001257200Directly adjoining
ConnecticutNew London County09011693600Directly adjoining
ConnecticutNew London County09011693700Directly adjoining
ConnecticutNew London County09011695201Directly adjoining

June 10, 2024 1520 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
ConnecticutNew London County09011701200Directly adjoining
ConnecticutNew London County09011870501Directly adjoining
ConnecticutNew London County09011870502Generating unit retirement
DelawareNew Castle County10003990100Directly adjoining
DelawareSussex County10005050601Directly adjoining
DelawareSussex County10005050604Directly adjoining
DelawareSussex County10005050703Directly adjoining
DelawareSussex County10005051308Directly adjoining
DelawareSussex County10005051400Directly adjoining
DelawareSussex County10005051501Directly adjoining
DelawareSussex County10005051502Generating unit retirement
DelawareSussex County10005051702Directly adjoining
District of
Columbia
District of Columbia11001007301Directly adjoining
District of
Columbia
District of Columbia11001010900Directly adjoining
FloridaBay County12005000201Directly adjoining
FloridaBay County12005000203Directly adjoining
FloridaBay County12005000204Generating unit retirement
FloridaBay County12005000402Directly adjoining
FloridaBay County12005001403Directly adjoining
FloridaBay County12005001404Directly adjoining
FloridaBay County12005001501Directly adjoining
FloridaBay County12005002500Directly adjoining
FloridaBay County12005002609Directly adjoining
FloridaBay County12005002703Directly adjoining
FloridaBay County12005002706Directly adjoining
FloridaBay County12005002709Directly adjoining
FloridaBay County12005002710Directly adjoining
FloridaCalhoun County12013010100Directly adjoining
FloridaCitrus County12017450305Directly adjoining
FloridaCitrus County12017450401Directly adjoining
FloridaCitrus County12017450402Generating unit retirement
FloridaCitrus County12017450501Directly adjoining
FloridaCitrus County12017990000Directly adjoining
FloridaClay County12019031500Directly adjoining
FloridaDuval County12031000101Directly adjoining
FloridaDuval County12031010101Directly adjoining
FloridaDuval County12031010104Generating unit retirement
FloridaDuval County12031010105Directly adjoining
FloridaDuval County12031010106Directly adjoining
FloridaDuval County12031010202Generating unit retirement
FloridaDuval County12031010203Directly adjoining
FloridaDuval County12031010204Directly adjoining

Bulletin No. 2024–24 1521 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
FloridaDuval County12031010307Directly adjoining
FloridaDuval County12031010402Directly adjoining
FloridaDuval County12031014601Directly adjoining
FloridaDuval County12031014703Directly adjoining
FloridaGadsden County12039020400Directly adjoining
FloridaHillsborough County12057013604Directly adjoining
FloridaHillsborough County12057013801Generating unit retirement
FloridaHillsborough County12057013802Directly adjoining
FloridaHillsborough County12057013803Directly adjoining
FloridaHillsborough County12057013804Directly adjoining
FloridaHillsborough County12057014106Directly adjoining
FloridaHillsborough County12057014117Directly adjoining
FloridaHillsborough County12057014119Directly adjoining
FloridaHillsborough County12057990000Directly adjoining
FloridaJackson County12063210901Generating unit retirement
FloridaJackson County12063210902Directly adjoining
FloridaJackson County12063211000Directly adjoining
FloridaLevy County12075970700Directly adjoining
FloridaLiberty County12077950202Directly adjoining
FloridaMartin County12085001803Directly adjoining
FloridaMartin County12085001804Generating unit retirement
FloridaMartin County12085001805Directly adjoining
FloridaMartin County12085001806Directly adjoining
FloridaPolk County12105010300Directly adjoining
FloridaPolk County12105011300Directly adjoining
FloridaPolk County12105011400Directly adjoining
FloridaPolk County12105011501Directly adjoining
FloridaPolk County12105011502Generating unit retirement
FloridaPolk County12105011605Directly adjoining
FloridaPolk County12105011606Directly adjoining
FloridaPolk County12105012207Directly adjoining
FloridaPolk County12105012209Directly adjoining
FloridaPolk County12105012304Directly adjoining
FloridaPutnam County12107950100Generating unit retirement
FloridaPutnam County12107950202Directly adjoining
FloridaPutnam County12107950600Directly adjoining
FloridaPutnam County12107950700Directly adjoining
FloridaPutnam County12107951000Directly adjoining
FloridaSt. Johns County12109990100Directly adjoining
FloridaWalton County12131950501Directly adjoining
FloridaWalton County12131950610Directly adjoining
GeorgiaBaldwin County13009970202Directly adjoining
GeorgiaBaldwin County13009970301Directly adjoining

June 10, 2024 1522 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
GeorgiaBurke County13033950102Directly adjoining
GeorgiaButts County13035150102Directly adjoining
GeorgiaCarroll County13045910800Directly adjoining
GeorgiaCarroll County13045910900Directly adjoining
GeorgiaCarroll County13045911202Directly adjoining
GeorgiaChatham County13051010601Directly adjoining
GeorgiaChatham County13051010603Directly adjoining
GeorgiaChatham County13051010701Generating unit retirement, Directly adjoining
GeorgiaChatham County13051010702Directly adjoining
GeorgiaChatham County13051010703Directly adjoining
GeorgiaChatham County13051010704Directly adjoining
GeorgiaChatham County13051010811Directly adjoining
GeorgiaChatham County13051980000Directly adjoining
GeorgiaChattooga County13055010600Directly adjoining
GeorgiaCobb County13067031213Directly adjoining
GeorgiaCobb County13067031214Generating unit retirement
GeorgiaCobb County13067031215Directly adjoining
GeorgiaCobb County13067031314Directly adjoining
GeorgiaCoweta County13077170101Generating unit retirement
GeorgiaCoweta County13077170102Directly adjoining
GeorgiaCoweta County13077170200Directly adjoining
GeorgiaCoweta County13077170303Directly adjoining
GeorgiaCoweta County13077170304Directly adjoining
GeorgiaDougherty County13095000101Directly adjoining
GeorgiaDougherty County13095000102Directly adjoining
GeorgiaDougherty County13095000200Directly adjoining
GeorgiaDougherty County13095010302Directly adjoining
GeorgiaDougherty County13095010602Directly adjoining
GeorgiaDougherty County13095010900Directly adjoining
GeorgiaDougherty County13095011000Generating unit retirement
GeorgiaDougherty County13095011200Generating unit retirement
GeorgiaDougherty County13095011300Directly adjoining
GeorgiaDougherty County13095011600Directly adjoining
GeorgiaEffingham County13103030303Directly adjoining
GeorgiaEffingham County13103030306Directly adjoining
GeorgiaEffingham County13103030307Directly adjoining
GeorgiaEffingham County13103030308Directly adjoining
GeorgiaEffingham County13103030309Generating unit retirement, Directly adjoining
GeorgiaFloyd County13115000300Directly adjoining
GeorgiaFloyd County13115000402Directly adjoining
GeorgiaFloyd County13115001200Directly adjoining
GeorgiaFloyd County13115001301Directly adjoining
GeorgiaFloyd County13115001302Directly adjoining

Bulletin No. 2024–24 1523 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
GeorgiaFloyd County13115001400Generating unit retirement
GeorgiaFloyd County13115002000Directly adjoining
GeorgiaFloyd County13115002100Directly adjoining
GeorgiaFulton County13121008701Directly adjoining
GeorgiaFulton County13121008801Directly adjoining
GeorgiaFulton County13121008802Directly adjoining
GeorgiaFulton County13121008903Directly adjoining
GeorgiaFulton County13121010402Directly adjoining
GeorgiaHancock County13141480300Directly adjoining
GeorgiaHeard County13149970100Directly adjoining
GeorgiaHeard County13149970200Generating unit retirement
GeorgiaHeard County13149970300Directly adjoining
GeorgiaJasper County13159010503Directly adjoining
GeorgiaJones County13169030101Directly adjoining
GeorgiaJones County13169030200Directly adjoining
GeorgiaLee County13177020101Directly adjoining
GeorgiaMitchell County13205090100Directly adjoining
GeorgiaMonroe County13207050101Directly adjoining
GeorgiaMonroe County13207050102Generating unit retirement
GeorgiaMonroe County13207050200Directly adjoining
GeorgiaMonroe County13207050302Directly adjoining
GeorgiaPutnam County13237960101Directly adjoining
GeorgiaPutnam County13237960301Directly adjoining
GeorgiaPutnam County13237960302Generating unit retirement
GeorgiaWorth County13321950100Directly adjoining
GeorgiaWorth County13321950201Directly adjoining
GeorgiaWorth County13321950500Directly adjoining
HawaiiHonolulu County15003008502Directly adjoining
HawaiiHonolulu County15003008610Directly adjoining
HawaiiHonolulu County15003980300Generating unit retirement
HawaiiHonolulu County15003990001Directly adjoining
IllinoisAdams County17001010200Directly adjoining
IllinoisBond County17005951200Directly adjoining
IllinoisBond County17005951400Directly adjoining
IllinoisBrown County17009970400Directly adjoining
IllinoisBureau County17011965000Directly adjoining
IllinoisBureau County17011965500Directly adjoining
IllinoisCalhoun County17013951200Directly adjoining
IllinoisCass County17017960100Directly adjoining
IllinoisCass County17017960200Directly adjoining
IllinoisCass County17017960300Directly adjoining
IllinoisChampaign County17019010400Directly adjoining
IllinoisChampaign County17019010702Directly adjoining

June 10, 2024 1524 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisChampaign County17019010800Directly adjoining
IllinoisClark County17023060100Directly adjoining
IllinoisClark County17023060400Directly adjoining
IllinoisClay County17025971900Directly adjoining
IllinoisColes County17029000100Directly adjoining
IllinoisCook County17031301600Directly adjoining
IllinoisCook County17031301702Directly adjoining
IllinoisCook County17031301801Directly adjoining
IllinoisCook County17031301803Directly adjoining
IllinoisCook County17031310200Directly adjoining
IllinoisCook County17031310300Directly adjoining
IllinoisCook County17031310400Directly adjoining
IllinoisCook County17031310500Directly adjoining
IllinoisCook County17031310600Directly adjoining
IllinoisCook County17031310700Directly adjoining
IllinoisCook County17031310800Directly adjoining
IllinoisCook County17031310900Directly adjoining
IllinoisCook County17031330200Directly adjoining
IllinoisCook County17031520100Directly adjoining
IllinoisCook County17031520400Directly adjoining
IllinoisCook County17031520500Directly adjoining
IllinoisCook County17031550100Directly adjoining
IllinoisCook County17031560100Directly adjoining
IllinoisCook County17031570100Directly adjoining
IllinoisCook County17031570200Directly adjoining
IllinoisCook County17031580200Directly adjoining
IllinoisCook County17031580300Directly adjoining
IllinoisCook County17031600600Directly adjoining
IllinoisCook County17031600700Directly adjoining
IllinoisCook County17031814200Directly adjoining
IllinoisCook County17031825700Directly adjoining
IllinoisCook County17031830500Generating unit retirement
IllinoisCook County17031840200Directly adjoining
IllinoisCook County17031840300Directly adjoining
IllinoisCook County17031840400Directly adjoining
IllinoisCook County17031840800Directly adjoining
IllinoisCook County17031841100Directly adjoining
IllinoisCook County17031841200Directly adjoining
IllinoisCook County17031841300Directly adjoining
IllinoisCook County17031841900Directly adjoining
IllinoisCook County17031843200Generating unit retirement
IllinoisCook County17031843500Directly adjoining
IllinoisCrawford County17033880100Generating unit retirement

Bulletin No. 2024–24 1525 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisCrawford County17033880200Directly adjoining
IllinoisCrawford County17033880300Directly adjoining
IllinoisCrawford County17033880500Directly adjoining
IllinoisCrawford County17033880600Directly adjoining
IllinoisDouglas County17041952000Mine closure, Directly adjoining
IllinoisDouglas County17041952100Directly adjoining
IllinoisDouglas County17041952400Directly adjoining
IllinoisEdgar County17045070100Directly adjoining
IllinoisEdgar County17045070200Directly adjoining
IllinoisEdgar County17045070500Directly adjoining
IllinoisEdwards County17047956900Directly adjoining
IllinoisEdwards County17047957000Directly adjoining
IllinoisEffingham County17049950100Directly adjoining
IllinoisEffingham County17049950500Directly adjoining
IllinoisFayette County17051950700Directly adjoining
IllinoisFranklin County17055040100Directly adjoining
IllinoisFranklin County17055040200Directly adjoining
IllinoisFranklin County17055040400Directly adjoining
IllinoisFranklin County17055040500Directly adjoining
IllinoisFranklin County17055040700Directly adjoining
IllinoisFranklin County17055040800Mine closure, Directly adjoining
IllinoisFranklin County17055040900Directly adjoining
IllinoisFranklin County17055041000Directly adjoining
IllinoisFranklin County17055041100Directly adjoining
IllinoisFranklin County17055041200Directly adjoining
IllinoisFulton County17057952800Directly adjoining
IllinoisFulton County17057952900Directly adjoining
IllinoisFulton County17057953000Directly adjoining
IllinoisFulton County17057953100Directly adjoining
IllinoisFulton County17057953200Directly adjoining
IllinoisFulton County17057953500Directly adjoining
IllinoisFulton County17057953600Directly adjoining
IllinoisFulton County17057953700Generating unit retirement, Directly adjoining
IllinoisFulton County17057953800Directly adjoining
IllinoisFulton County17057953900Directly adjoining
IllinoisGallatin County17059972700Mine closure, Directly adjoining
IllinoisGallatin County17059972800Mine closure, Directly adjoining
IllinoisGreene County17061973800Directly adjoining
IllinoisHamilton County17065973200Directly adjoining
IllinoisHancock County17067953700Directly adjoining
IllinoisHancock County17067954300Directly adjoining
IllinoisHardin County17069970900Directly adjoining
IllinoisHardin County17069971000Directly adjoining

June 10, 2024 1526 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisJackson County17077010100Directly adjoining
IllinoisJackson County17077010200Mine closure, Directly adjoining
IllinoisJackson County17077010400Directly adjoining
IllinoisJackson County17077010800Directly adjoining
IllinoisJackson County17077010900Directly adjoining
IllinoisJackson County17077011200Directly adjoining
IllinoisJackson County17077011600Directly adjoining
IllinoisJasper County17079977300Directly adjoining
IllinoisJasper County17079977400Directly adjoining
IllinoisJasper County17079977500Generating unit retirement
IllinoisJefferson County17081050100Directly adjoining
IllinoisJefferson County17081050300Mine closure, Directly adjoining
IllinoisJefferson County17081050400Directly adjoining
IllinoisJefferson County17081050500Directly adjoining
IllinoisJefferson County17081051100Directly adjoining
IllinoisJo Daviess County17085020200Directly adjoining
IllinoisJohnson County17087977600Directly adjoining
IllinoisJohnson County17087977700Directly adjoining
IllinoisJohnson County17087977800Directly adjoining
IllinoisKnox County17095000100Directly adjoining
IllinoisKnox County17095000200Directly adjoining
IllinoisKnox County17095001200Directly adjoining
IllinoisKnox County17095001400Directly adjoining
IllinoisKnox County17095001600Mine closure
IllinoisLake County17097861701Directly adjoining
IllinoisLake County17097861702Directly adjoining
IllinoisLake County17097862100Directly adjoining
IllinoisLake County17097862200Generating unit retirement
IllinoisLake County17097862300Directly adjoining
IllinoisLake County17097862401Directly adjoining
IllinoisLake County17097862402Directly adjoining
IllinoisLake County17097866000Directly adjoining
IllinoisLake County17097990000Directly adjoining
IllinoisLaSalle County17099964100Directly adjoining
IllinoisLawrence County17101880800Directly adjoining
IllinoisMcDonough County17109010200Directly adjoining
IllinoisMcDonough County17109010300Directly adjoining
IllinoisMcDonough County17109011000Directly adjoining
IllinoisMcDonough County17109011100Mine closure, Directly adjoining
IllinoisMacoupin County17117956000Directly adjoining
IllinoisMacoupin County17117956100Mine closure
IllinoisMacoupin County17117956200Directly adjoining
IllinoisMacoupin County17117956300Directly adjoining

Bulletin No. 2024–24 1527 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisMadison County17119401200Directly adjoining
IllinoisMadison County17119401300Directly adjoining
IllinoisMadison County17119401500Directly adjoining
IllinoisMadison County17119402100Directly adjoining
IllinoisMadison County17119402200Directly adjoining
IllinoisMadison County17119402300Directly adjoining
IllinoisMadison County17119402400Generating unit retirement
IllinoisMadison County17119402500Directly adjoining
IllinoisMadison County17119402600Directly adjoining
IllinoisMarshall County17123961100Directly adjoining
IllinoisMarshall County17123961200Directly adjoining
IllinoisMarshall County17123961300Directly adjoining
IllinoisMason County17125956400Directly adjoining
IllinoisMason County17125956500Directly adjoining
IllinoisMason County17125956600Generating unit retirement
IllinoisMason County17125956700Directly adjoining
IllinoisMassac County17127970100Generating unit retirement, Directly adjoining
IllinoisMassac County17127970200Directly adjoining
IllinoisMassac County17127970300Directly adjoining
IllinoisMassac County17127970400Directly adjoining
IllinoisMenard County17129010300Directly adjoining
IllinoisMonroe County17133600102Directly adjoining
IllinoisMonroe County17133600402Directly adjoining
IllinoisMonroe County17133600502Directly adjoining
IllinoisMontgomery County17135957400Directly adjoining
IllinoisMontgomery County17135957500Directly adjoining
IllinoisMontgomery County17135957600Directly adjoining
IllinoisMontgomery County17135957900Directly adjoining
IllinoisMontgomery County17135958000Generating unit retirement
IllinoisMorgan County17137951400Generating unit retirement
IllinoisMorgan County17137951500Directly adjoining
IllinoisMorgan County17137951600Directly adjoining
IllinoisMorgan County17137951700Directly adjoining
IllinoisMorgan County17137951800Directly adjoining
IllinoisMorgan County17137951900Directly adjoining
IllinoisMorgan County17137952000Generating unit retirement
IllinoisMorgan County17137952100Directly adjoining
IllinoisMorgan County17137952200Directly adjoining
IllinoisPeoria County17143000200Directly adjoining
IllinoisPeoria County17143000300Directly adjoining
IllinoisPeoria County17143000600Directly adjoining
IllinoisPeoria County17143000900Directly adjoining
IllinoisPeoria County17143003800Directly adjoining

June 10, 2024 1528 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisPeoria County17143003900Directly adjoining
IllinoisPeoria County17143004000Directly adjoining
IllinoisPeoria County17143004600Directly adjoining
IllinoisPeoria County17143004801Directly adjoining
IllinoisPeoria County17143004802Directly adjoining
IllinoisPeoria County17143004901Generating unit retirement, Directly adjoining
IllinoisPeoria County17143004902Directly adjoining
IllinoisPeoria County17143005000Directly adjoining
IllinoisPeoria County17143005100Generating unit retirement
IllinoisPerry County17145030100Directly adjoining
IllinoisPerry County17145030200Directly adjoining
IllinoisPerry County17145030300Mine closure, Directly adjoining
IllinoisPerry County17145030400Mine closure, Directly adjoining
IllinoisPerry County17145030500Directly adjoining
IllinoisPerry County17145030600Mine closure, Directly adjoining
IllinoisPike County17149952400Directly adjoining
IllinoisPike County17149952500Directly adjoining
IllinoisPike County17149952600Directly adjoining
IllinoisPike County17149952700Directly adjoining
IllinoisPike County17149952800Generating unit retirement
IllinoisPope County17151971200Directly adjoining
IllinoisPope County17151971300Directly adjoining
IllinoisPulaski County17153971000Directly adjoining
IllinoisPutnam County17155954500Directly adjoining
IllinoisPutnam County17155954600Generating unit retirement
IllinoisRandolph County17157950500Directly adjoining
IllinoisRandolph County17157950600Directly adjoining
IllinoisRandolph County17157950700Mine closure, Generating unit retirement,
Directly adjoining
IllinoisRandolph County17157950800Directly adjoining
IllinoisRandolph County17157950900Directly adjoining
IllinoisRandolph County17157951000Directly adjoining
IllinoisRandolph County17157951100Directly adjoining
IllinoisRichland County17159977900Directly adjoining
IllinoisRichland County17159978300Directly adjoining
IllinoisRock Island County17161020302Directly adjoining
IllinoisRock Island County17161020400Directly adjoining
IllinoisRock Island County17161020600Generating unit retirement, Directly adjoining
IllinoisRock Island County17161020700Directly adjoining
IllinoisRock Island County17161020800Directly adjoining
IllinoisRock Island County17161021400Directly adjoining
IllinoisRock Island County17161024103Directly adjoining
IllinoisSt. Clair County17163504002Directly adjoining
IllinoisSaline County17165955100Directly adjoining

Bulletin No. 2024–24 1529 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisSaline County17165955500Directly adjoining
IllinoisSaline County17165955600Mine closure, Directly adjoining
IllinoisSaline County17165955700Mine closure, Directly adjoining
IllinoisSaline County17165955800Directly adjoining
IllinoisSaline County17165955900Directly adjoining
IllinoisSaline County17165956000Directly adjoining
IllinoisSaline County17165956100Directly adjoining
IllinoisSaline County17165956200Mine closure, Directly adjoining
IllinoisSangamon County17167000600Directly adjoining
IllinoisSangamon County17167002400Directly adjoining
IllinoisSangamon County17167002500Directly adjoining
IllinoisSangamon County17167002700Directly adjoining
IllinoisSangamon County17167003000Directly adjoining
IllinoisSangamon County17167003100Generating unit retirement
IllinoisSangamon County17167003201Directly adjoining
IllinoisSangamon County17167003203Directly adjoining
IllinoisSangamon County17167003300Directly adjoining
IllinoisSangamon County17167003400Directly adjoining
IllinoisSangamon County17167003500Directly adjoining
IllinoisSangamon County17167003901Directly adjoining
IllinoisSangamon County17167003902Directly adjoining
IllinoisSchuyler County17169970100Mine closure, Directly adjoining
IllinoisSchuyler County17169970200Directly adjoining
IllinoisSchuyler County17169970300Directly adjoining
IllinoisScott County17171970600Directly adjoining
IllinoisScott County17171970700Directly adjoining
IllinoisTazewell County17179020100Directly adjoining
IllinoisTazewell County17179020400Directly adjoining
IllinoisTazewell County17179020500Directly adjoining
IllinoisTazewell County17179020800Directly adjoining
IllinoisTazewell County17179020900Directly adjoining
IllinoisTazewell County
17179021802Directly adjoining
IllinoisUnion County17181950100Directly adjoining
IllinoisVermilion County17183000100Directly adjoining
IllinoisVermilion County17183000200Generating unit retirement
IllinoisVermilion County17183000300Directly adjoining
IllinoisVermilion County17183000500Directly adjoining
IllinoisVermilion County17183000600Directly adjoining
IllinoisVermilion County17183000700Directly adjoining
IllinoisVermilion County17183000800Directly adjoining
IllinoisVermilion County17183000900Directly adjoining
IllinoisVermilion County17183001300Directly adjoining
IllinoisVermilion County17183010100Directly adjoining

June 10, 2024 1530 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisVermilion County17183010300Generating unit retirement
IllinoisVermilion County17183010400Directly adjoining
IllinoisVermilion County17183010500Directly adjoining
IllinoisVermilion County17183010600Directly adjoining
IllinoisVermilion County17183010701Directly adjoining
IllinoisVermilion County17183010702Directly adjoining
IllinoisVermilion County17183010800Directly adjoining
IllinoisVermilion County17183010900Mine closure, Directly adjoining
IllinoisVermilion County17183011000Mine closure, Directly adjoining
IllinoisVermilion County17183011100Directly adjoining
IllinoisWabash County17185957200Mine closure, Directly adjoining
IllinoisWabash County17185957300Directly adjoining
IllinoisWabash County17185957400Directly adjoining
IllinoisWabash County17185957500Directly adjoining
IllinoisWashington County17189950100Directly adjoining
IllinoisWashington County17189950200Directly adjoining
IllinoisWashington County17189950300Directly adjoining
IllinoisWashington County17189950400Mine closure, Directly adjoining
IllinoisWayne County17191954900Directly adjoining
IllinoisWhite County17193958000Directly adjoining
IllinoisWhite County17193958100Directly adjoining
IllinoisWhite County17193958200Mine closure, Directly adjoining
IllinoisWhite County17193958300Directly adjoining
IllinoisWhite County17193958400Directly adjoining
IllinoisWill County17197880202Directly adjoining
IllinoisWill County17197880203Directly adjoining
IllinoisWill County17197880426Directly adjoining
IllinoisWill County17197880428Directly adjoining
IllinoisWill County17197880502Directly adjoining
IllinoisWill County17197880503Directly adjoining
IllinoisWill County17197880508Directly adjoining
IllinoisWill County
17197880509Directly adjoining
IllinoisWill County17197880510Directly adjoining
IllinoisWill County17197880511Directly adjoining
IllinoisWill County17197880602Directly adjoining
IllinoisWill County17197880901Directly adjoining
IllinoisWill County17197884101Generating unit retirement
IllinoisWill County17197884103Directly adjoining
IllinoisWilliamson County17199020100Mine closure, Directly adjoining
IllinoisWilliamson County17199020201Directly adjoining
IllinoisWilliamson County17199020202Directly adjoining
IllinoisWilliamson County17199020300Directly adjoining
IllinoisWilliamson County17199020600Directly adjoining

Bulletin No. 2024–24 1531 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IllinoisWilliamson County17199020700Directly adjoining
IllinoisWilliamson County17199020801Mine closure, Directly adjoining
IllinoisWilliamson County17199020802Mine closure, Directly adjoining
IllinoisWilliamson County17199020900Directly adjoining
IllinoisWilliamson County17199021002Directly adjoining
IllinoisWilliamson County17199021200Directly adjoining
IllinoisWilliamson County17199021300Directly adjoining
IllinoisWilliamson County17199021400Mine closure, Generating unit retirement,
Directly adjoining
IndianaCass County18017950900Directly adjoining
IndianaCass County18017951200Directly adjoining
IndianaCass County18017951400Directly adjoining
IndianaCass County18017951500Generating unit retirement
IndianaCass County18017951600Directly adjoining
IndianaCass County18017951700Directly adjoining
IndianaClay County18021040300Directly adjoining
IndianaClay County18021040400Directly adjoining
IndianaClay County18021040500Mine closure, Directly adjoining
IndianaClay County18021040600Mine closure, Directly adjoining
IndianaDaviess County18027954300Directly adjoining
IndianaDaviess County18027954400Mine closure, Directly adjoining
IndianaDaviess County18027954501Directly adjoining
IndianaDaviess County18027954502Mine closure, Directly adjoining
IndianaDaviess County18027954600Directly adjoining
IndianaDaviess County18027954700Directly adjoining
IndianaDaviess County18027954800Directly adjoining
IndianaDaviess County18027954900Directly adjoining
IndianaDearborn County18029080301Generating unit retirement
IndianaDearborn County18029080302Directly adjoining
IndianaDearborn County18029080400Directly adjoining
IndianaDearborn County18029080500Directly adjoining
IndianaDubois County18037953200Mine closure, Directly adjoining
Indiana
Dubois County18037953301Directly adjoining
IndianaDubois County18037953302Directly adjoining
IndianaDubois County18037953400Generating unit retirement, Directly adjoining
IndianaDubois County18037953500Directly adjoining
IndianaDubois County18037953701Mine closure, Directly adjoining
IndianaDubois County18037953702Directly adjoining
IndianaDubois County18037953800Directly adjoining
IndianaFloyd County18043070500Directly adjoining
IndianaFloyd County18043070600Generating unit retirement
IndianaFloyd County18043070700Directly adjoining
IndianaFloyd County18043070801Directly adjoining
IndianaFloyd County18043071104Directly adjoining

June 10, 2024 1532 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IndianaFloyd County18043071200Directly adjoining
IndianaGibson County18051050100Directly adjoining
IndianaGibson County18051050201Directly adjoining
IndianaGibson County18051050202Directly adjoining
IndianaGibson County18051050300Mine closure, Directly adjoining
IndianaGibson County18051050401Mine closure, Directly adjoining
IndianaGibson County18051050402Mine closure, Directly adjoining
IndianaGibson County18051050501Directly adjoining
IndianaGibson County18051050502Directly adjoining
IndianaGreene County18055954701Directly adjoining
IndianaGreene County18055954702Directly adjoining
IndianaGreene County18055954800Directly adjoining
IndianaGreene County18055954900Mine closure, Directly adjoining
IndianaGreene County18055955000Directly adjoining
IndianaGreene County18055955100Directly adjoining
IndianaGreene County18055955200Directly adjoining
IndianaGreene County18055955300Mine closure, Directly adjoining
IndianaGreene County18055955400Directly adjoining
IndianaHarrison County18061060601Directly adjoining
IndianaJasper County18073100800Generating unit retirement
IndianaJasper County18073100901Directly adjoining
IndianaJasper County18073101000Directly adjoining
IndianaJasper County18073101200Directly adjoining
IndianaKnox County18083955000Directly adjoining
IndianaKnox County18083955100Mine closure, Generating unit retirement,
Directly adjoining
IndianaKnox County18083955201Directly adjoining
IndianaKnox County18083955202Directly adjoining
IndianaKnox County18083955700Directly adjoining
IndianaKnox County18083955800Mine closure, Directly adjoining
IndianaKnox County18083955900Directly adjoining
IndianaLake County18089010203Directly adjoining
Indiana
Lake County18089010302Directly adjoining
IndianaLake County18089010304Generating unit retirement
IndianaLake County18089011000Directly adjoining
IndianaLake County18089020100Directly adjoining
IndianaLake County18089020200Directly adjoining
IndianaLake County18089020300Generating unit retirement
IndianaLake County18089020400Directly adjoining
IndianaLake County18089021000Directly adjoining
IndianaLake County18089030100Directly adjoining
IndianaLake County18089030300Directly adjoining
IndianaLake County18089030400Directly adjoining
IndianaLake County18089030500Directly adjoining

Bulletin No. 2024–24 1533 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IndianaLake County18089030700Directly adjoining
IndianaLake County18089030900Directly adjoining
IndianaLake County18089040100Directly adjoining
IndianaLake County18089990000Directly adjoining
IndianaLaPorte County18091042900Directly adjoining
IndianaMartin County18101950100Directly adjoining
IndianaMartin County18101950200Directly adjoining
IndianaMartin County18101950300Directly adjoining
IndianaMiami County18103952100Directly adjoining
IndianaMiami County18103952200Directly adjoining
IndianaMiami County18103952300Directly adjoining
IndianaMiami County18103952400Generating unit retirement
IndianaMiami County18103952500Directly adjoining
IndianaMiami County18103952700Directly adjoining
IndianaMontgomery County18107956800Directly adjoining
IndianaMontgomery County18107956900Directly adjoining
IndianaMontgomery County18107957000Generating unit retirement
IndianaMontgomery County18107957200Directly adjoining
IndianaMorgan County18109510500Directly adjoining
IndianaMorgan County18109510701Directly adjoining
IndianaMorgan County18109510703Generating unit retirement
IndianaMorgan County18109510704Directly adjoining
IndianaMorgan County18109510800Directly adjoining
IndianaMorgan County18109510900Directly adjoining
IndianaMorgan County18109511001Directly adjoining
IndianaOwen County18119955600Directly adjoining
IndianaOwen County18119955701Directly adjoining
IndianaOwen County18119955702Mine closure, Directly adjoining
IndianaOwen County18119955900Directly adjoining
IndianaParke County18121030100Directly adjoining
IndianaParke County18121030200Directly adjoining
IndianaParke County
18121030300Directly adjoining
IndianaParke County18121030401Mine closure
IndianaParke County18121030402Directly adjoining
IndianaPerry County18123952300Directly adjoining
IndianaPerry County18123952400Directly adjoining
IndianaPike County18125953900Mine closure, Directly adjoining
IndianaPike County18125954000Directly adjoining
IndianaPike County18125954100Mine closure, Generating unit retirement,
Directly adjoining
IndianaPike County18125954200Mine closure, Directly adjoining
IndianaPorter County18127050302Directly adjoining
IndianaPorter County18127051102Directly adjoining
IndianaPorter County18127980001Directly adjoining

June 10, 2024 1534 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IndianaPorter County18127980002Generating unit retirement
IndianaPorter County18127990000Directly adjoining
IndianaPosey County18129040100Directly adjoining
IndianaPosey County18129040200Directly adjoining
IndianaPosey County18129040300Directly adjoining
IndianaPosey County18129040400Generating unit retirement, Directly adjoining
IndianaPosey County18129040500Generating unit retirement, Directly adjoining
IndianaPosey County18129040600Directly adjoining
IndianaPosey County18129040700Directly adjoining
IndianaPulaski County18131959100Directly adjoining
IndianaPulaski County18131959200Directly adjoining
IndianaPutnam County18133956100Directly adjoining
IndianaPutnam County18133956600Directly adjoining
IndianaSpencer County18147952701Directly adjoining
IndianaSpencer County18147952702Mine closure, Directly adjoining
IndianaSpencer County18147952800Directly adjoining
IndianaSpencer County18147952900Directly adjoining
IndianaSpencer County18147953000Directly adjoining
IndianaSpencer County18147953100Directly adjoining
IndianaStarke County18149954200Directly adjoining
IndianaSullivan County18153050101Mine closure, Directly adjoining
IndianaSullivan County18153050102Mine closure, Directly adjoining
IndianaSullivan County18153050200Directly adjoining
IndianaSullivan County18153050301Directly adjoining
IndianaSullivan County18153050302Directly adjoining
IndianaSullivan County18153050400Mine closure, Directly adjoining
IndianaSullivan County18153050501Directly adjoining
IndianaSullivan County18153050502Mine closure, Directly adjoining
IndianaVanderburgh County18163010404Directly adjoining
IndianaVanderburgh County18163010406Directly adjoining
IndianaVanderburgh County18163010502Directly adjoining
IndianaVanderburgh County
18163010701Directly adjoining
IndianaVermillion County18165020400Directly adjoining
IndianaVigo County18167000300Directly adjoining
IndianaVigo County18167000900Directly adjoining
IndianaVigo County18167001000Directly adjoining
IndianaVigo County18167010201Directly adjoining
IndianaVigo County18167010202Directly adjoining
IndianaVigo County18167010300Mine closure, Generating unit retirement
IndianaVigo County18167010400Directly adjoining
IndianaVigo County18167010601Directly adjoining
IndianaVigo County18167010602Directly adjoining
IndianaVigo County18167010702Mine closure, Directly adjoining

Bulletin No. 2024–24 1535 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IndianaVigo County18167010703Directly adjoining
IndianaVigo County18167010704Directly adjoining
IndianaVigo County18167011000Directly adjoining
IndianaVigo County18167011202Directly adjoining
IndianaWarren County18171951100Directly adjoining
IndianaWarrick County18173030100Mine closure, Directly adjoining
IndianaWarrick County18173030200Mine closure, Directly adjoining
IndianaWarrick County18173030300Directly adjoining
IndianaWarrick County18173030400Directly adjoining
IndianaWarrick County18173030501Mine closure, Directly adjoining
IndianaWarrick County18173030502Mine closure, Directly adjoining
IndianaWarrick County18173030601Directly adjoining
IndianaWarrick County18173030602Directly adjoining
IndianaWarrick County18173030703Mine closure
IndianaWarrick County18173030704Directly adjoining
IndianaWarrick County18173030706Directly adjoining
IndianaWarrick County18173030707Directly adjoining
IndianaWarrick County18173030709Directly adjoining
IndianaWarrick County18173030801Directly adjoining
IowaAllamakee County19005960100Generating unit retirement, Directly adjoining
IowaAllamakee County19005960200Directly adjoining
IowaAllamakee County19005960400Directly adjoining
IowaAllamakee County19005960500Directly adjoining
IowaCedar County19031450400Directly adjoining
IowaCedar County19031450500Directly adjoining
IowaClayton County19043070400Directly adjoining
IowaClayton County19043070500Directly adjoining
IowaDubuque County19061000100Generating unit retirement, Directly adjoining
IowaDubuque County19061000300Directly adjoining
IowaDubuque County19061000400Directly adjoining
IowaDubuque County19061000500Directly adjoining
IowaDubuque County
19061000600Directly adjoining
IowaDubuque County19061000701Directly adjoining
IowaDubuque County19061000702Directly adjoining
IowaDubuque County19061000801Directly adjoining
IowaDubuque County19061001104Directly adjoining
IowaDubuque County19061010103Generating unit retirement, Directly adjoining
IowaDubuque County19061010104Directly adjoining
IowaDubuque County19061010600Directly adjoining
IowaLinn County19113000800Directly adjoining
IowaLinn County19113000902Directly adjoining
IowaLinn County19113001102Directly adjoining
IowaLinn County19113001200Directly adjoining

June 10, 2024 1536 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IowaLinn County19113001300Generating unit retirement
IowaLinn County19113001400Directly adjoining
IowaLinn County19113001800Directly adjoining
IowaLinn County19113001900Directly adjoining
IowaLinn County19113002900Directly adjoining
IowaLinn County19113003003Directly adjoining
IowaLinn County19113003004Generating unit retirement
IowaLinn County19113003005Directly adjoining
IowaLinn County19113010700Directly adjoining
IowaMarion County19125030101Directly adjoining
IowaMarion County19125030202Directly adjoining
IowaMarion County19125030300Generating unit retirement
IowaMarshall County19127950100Directly adjoining
IowaMarshall County19127950400Directly adjoining
IowaMarshall County19127950500Directly adjoining
IowaMarshall County19127950600Directly adjoining
IowaMarshall County19127950900Generating unit retirement
IowaMarshall County19127951000Directly adjoining
IowaMills County19129040201Directly adjoining
IowaMills County19129040202Directly adjoining
IowaMonona County19133960100Directly adjoining
IowaMonona County19133960200Directly adjoining
IowaMuscatine County19139050100Generating unit retirement
IowaMuscatine County19139050200Directly adjoining
IowaMuscatine County19139050700Directly adjoining
IowaPottawattamie County19155021400Directly adjoining
IowaPottawattamie County19155021602Directly adjoining
IowaPottawattamie County19155031300Directly adjoining
IowaPottawattamie County19155031400Directly adjoining
IowaPottawattamie County19155031601Directly adjoining
IowaPottawattamie County19155031602Directly adjoining
IowaPottawattamie County
19155031800Directly adjoining
IowaPottawattamie County19155031900Generating unit retirement
IowaScott County19163010103Directly adjoining
IowaScott County19163010300Directly adjoining
IowaScott County19163010401Directly adjoining
IowaScott County19163013300Directly adjoining
IowaScott County19163013400Directly adjoining
IowaScott County19163013500Directly adjoining
IowaScott County19163013702Generating unit retirement, Directly adjoining
IowaScott County19163013705Directly adjoining
IowaScott County19163013706Directly adjoining
IowaWoodbury County19193003100Directly adjoining

Bulletin No. 2024–24 1537 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
IowaWoodbury County19193003200Directly adjoining
IowaWoodbury County19193003301Directly adjoining
IowaWoodbury County19193003302Directly adjoining
IowaWoodbury County19193003500Generating unit retirement
IowaWoodbury County19193003600Directly adjoining
IowaWoodbury County19193940200Directly adjoining
IowaWright County19197680200Directly adjoining
IowaWright County19197680500Generating unit retirement
KansasAllen County20001952600Directly adjoining
KansasAnderson County20003953700Directly adjoining
KansasBourbon County20011955600Directly adjoining
KansasBourbon County20011955700Mine closure
KansasBourbon County20011955800Directly adjoining
KansasBourbon County20011955900Directly adjoining
KansasCherokee County20021958100Directly adjoining
KansasCherokee County20021958200Directly adjoining
KansasCherokee County20021958300Directly adjoining
KansasCherokee County20021958400Generating unit retirement, Directly adjoining
KansasCherokee County20021958500Directly adjoining
KansasCherokee County20021958600Directly adjoining
KansasCrawford County20037956600Directly adjoining
KansasCrawford County20037956700Directly adjoining
KansasCrawford County20037957601Directly adjoining
KansasDouglas County20045000100Directly adjoining
KansasDouglas County20045000501Directly adjoining
KansasDouglas County20045000603Directly adjoining
KansasDouglas County20045000604Directly adjoining
KansasDouglas County20045001400Directly adjoining
KansasDouglas County20045001500Generating unit retirement, Directly adjoining
KansasJefferson County20087020101Directly adjoining
KansasJefferson County20087020102Directly adjoining
KansasJefferson County
20087020300Directly adjoining
KansasLabette County20099950600Directly adjoining
KansasLabette County20099950800Directly adjoining
KansasLinn County20107955101Directly adjoining
KansasLinn County20107955102Directly adjoining
KansasLinn County20107955200Mine closure, Directly adjoining
KansasMiami County20121100400Directly adjoining
KansasNeosho County20133951600Directly adjoining
KansasShawnee County20177000900Directly adjoining
KansasShawnee County20177003002Directly adjoining
KansasShawnee County20177003100Directly adjoining
KansasShawnee County20177003901Generating unit retirement, Directly adjoining

June 10, 2024 1538 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KansasShawnee County20177003902Directly adjoining
KentuckyAnderson County21005950102Directly adjoining
KentuckyBallard County21007950100Directly adjoining
KentuckyBell County21013960100Mine closure, Directly adjoining
KentuckyBell County21013960200Directly adjoining
KentuckyBell County21013960300Mine closure, Directly adjoining
KentuckyBell County21013960400Mine closure, Directly adjoining
KentuckyBell County21013960500Mine closure, Directly adjoining
KentuckyBell County21013960600Mine closure, Directly adjoining
KentuckyBell County21013960700Mine closure, Directly adjoining
KentuckyBell County21013960800Mine closure, Directly adjoining
KentuckyBell County21013961100Mine closure, Directly adjoining
KentuckyBoone County21015070403Directly adjoining
KentuckyBoone County21015070405Directly adjoining
KentuckyBoone County21015070502Directly adjoining
KentuckyBoyd County21019030900Directly adjoining
KentuckyBoyd County21019031001Directly adjoining
KentuckyBoyd County21019031004Directly adjoining
KentuckyBoyd County21019031101Directly adjoining
KentuckyBoyd County21019031102Directly adjoining
KentuckyBoyd County21019031200Directly adjoining
KentuckyBoyle County21021930100Directly adjoining
KentuckyBracken County21023950200Directly adjoining
KentuckyBreathitt County21025920200Mine closure, Directly adjoining
KentuckyBreathitt County21025920301Directly adjoining
KentuckyBreathitt County21025920302Directly adjoining
KentuckyBreathitt County21025920500Mine closure, Directly adjoining
KentuckyBreathitt County21025920600Mine closure, Directly adjoining
KentuckyBreathitt County21025920700Mine closure, Directly adjoining
KentuckyBreathitt County21025920800Mine closure, Directly adjoining
KentuckyBreckinridge County21027960400Directly adjoining
KentuckyButler County
21031930100Mine closure, Directly adjoining
KentuckyButler County21031930200Directly adjoining
KentuckyButler County21031930301Directly adjoining
KentuckyButler County21031930302Directly adjoining
KentuckyButler County21031930400Directly adjoining
KentuckyButler County21031930500Mine closure, Directly adjoining
KentuckyCaldwell County21033920100Directly adjoining
KentuckyCaldwell County21033920302Directly adjoining
KentuckyCampbell County21037051901Directly adjoining
KentuckyCarter County21043960200Directly adjoining
KentuckyCarter County21043960300Directly adjoining
KentuckyCarter County21043960400Mine closure

Bulletin No. 2024–24 1539 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyCarter County21043960500Directly adjoining
KentuckyCarter County21043960601Directly adjoining
KentuckyCarter County21043960602Directly adjoining
KentuckyCarter County21043960700Mine closure, Directly adjoining
KentuckyChristian County21047200902Directly adjoining
KentuckyChristian County21047201000Mine closure, Directly adjoining
KentuckyChristian County21047201100Directly adjoining
KentuckyClark County21049020103Directly adjoining
KentuckyClark County21049020105Directly adjoining
KentuckyClark County21049020400Directly adjoining
KentuckyClark County21049020500Generating unit retirement
KentuckyClark County21049020600Directly adjoining
KentuckyClay County21051950100Mine closure, Directly adjoining
KentuckyClay County21051950201Mine closure, Directly adjoining
KentuckyClay County21051950202Mine closure, Directly adjoining
KentuckyClay County21051950301Mine closure, Directly adjoining
KentuckyClay County21051950302Mine closure, Directly adjoining
KentuckyClay County21051950400Mine closure, Directly adjoining
KentuckyClay County21051950500Mine closure, Directly adjoining
KentuckyClay County21051950600Mine closure, Directly adjoining
KentuckyCrittenden County21055930100Directly adjoining
KentuckyDaviess County21059000100Directly adjoining
KentuckyDaviess County21059000200Directly adjoining
KentuckyDaviess County21059000401Directly adjoining
KentuckyDaviess County21059000402Directly adjoining
KentuckyDaviess County21059000600Directly adjoining
KentuckyDaviess County21059001300Mine closure, Directly adjoining
KentuckyDaviess County21059001401Generating unit retirement
KentuckyDaviess County21059001402Directly adjoining
KentuckyDaviess County21059001501Directly adjoining
KentuckyDaviess County21059001502Mine closure, Directly adjoining
KentuckyDaviess County21059001601Directly adjoining
KentuckyDaviess County21059001602Directly adjoining
KentuckyDaviess County21059001701Directly adjoining
KentuckyDaviess County21059001703Directly adjoining
KentuckyDaviess County21059001800Mine closure, Directly adjoining
KentuckyElliott County21063920101Directly adjoining
KentuckyElliott County21063920102Mine closure, Directly adjoining
KentuckyElliott County21063920200Mine closure, Directly adjoining
KentuckyEstill County21065920100Directly adjoining
KentuckyEstill County21065920400Directly adjoining
KentuckyFayette County21067003701Directly adjoining
KentuckyFayette County21067003918Directly adjoining

June 10, 2024 1540 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyFayette County21067004007Directly adjoining
KentuckyFloyd County21071920100Mine closure, Directly adjoining
KentuckyFloyd County21071920200Mine closure, Directly adjoining
KentuckyFloyd County21071920301Mine closure, Directly adjoining
KentuckyFloyd County21071920302Mine closure, Directly adjoining
KentuckyFloyd County21071920401Mine closure, Directly adjoining
KentuckyFloyd County21071920402Mine closure, Directly adjoining
KentuckyFloyd County21071920500Mine closure, Directly adjoining
KentuckyFloyd County21071920600Mine closure, Directly adjoining
KentuckyFloyd County21071920700Mine closure, Directly adjoining
KentuckyFloyd County21071920801Mine closure, Directly adjoining
KentuckyFloyd County21071920802Mine closure, Directly adjoining
KentuckyFloyd County21071920900Mine closure, Directly adjoining
KentuckyFloyd County21071921001Mine closure, Directly adjoining
KentuckyFloyd County21071921002Mine closure, Directly adjoining
KentuckyFranklin County21073070703Directly adjoining
KentuckyFranklin County21073071001Directly adjoining
KentuckyGarrard County21079970101Directly adjoining
KentuckyGarrard County21079970102Directly adjoining
KentuckyGrayson County21085950600Directly adjoining
KentuckyGrayson County21085950700Directly adjoining
KentuckyGreenup County21089040100Directly adjoining
KentuckyGreenup County21089040202Directly adjoining
KentuckyGreenup County21089040300Directly adjoining
KentuckyGreenup County21089040400Mine closure, Directly adjoining
KentuckyGreenup County21089040502Directly adjoining
KentuckyGreenup County21089040700Directly adjoining
KentuckyHancock County21091960100Directly adjoining
KentuckyHancock County21091960200Generating unit retirement
KentuckyHancock County21091960300Directly adjoining
KentuckyHarlan County21095970100Mine closure, Directly adjoining
KentuckyHarlan County21095970200Mine closure, Directly adjoining
KentuckyHarlan County21095970300Mine closure, Directly adjoining
KentuckyHarlan County21095970400Mine closure, Directly adjoining
KentuckyHarlan County21095970500Mine closure, Directly adjoining
KentuckyHarlan County21095970600Mine closure, Directly adjoining
KentuckyHarlan County21095970700Mine closure, Directly adjoining
KentuckyHarlan County21095970800Directly adjoining
KentuckyHarlan County21095970900Mine closure, Directly adjoining
KentuckyHarlan County21095971000Mine closure, Directly adjoining
KentuckyHarlan County21095971300Mine closure, Directly adjoining
KentuckyHenderson County21101020602Directly adjoining
KentuckyHenderson County21101020701Directly adjoining

Bulletin No. 2024–24 1541 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyHenderson County21101020703Directly adjoining
KentuckyHenderson County21101020704Mine closure, Directly adjoining
KentuckyHenderson County21101020800Mine closure, Directly adjoining
KentuckyHenderson County21101020901Directly adjoining
KentuckyHenderson County21101020902Directly adjoining
KentuckyHopkins County21107970100Mine closure, Directly adjoining
KentuckyHopkins County21107970200Mine closure, Directly adjoining
KentuckyHopkins County21107970301Directly adjoining
KentuckyHopkins County21107970302Directly adjoining
KentuckyHopkins County21107970400Directly adjoining
KentuckyHopkins County21107970500Mine closure, Directly adjoining
KentuckyHopkins County21107970600Mine closure, Directly adjoining
KentuckyHopkins County21107970700Mine closure, Directly adjoining
KentuckyHopkins County21107970800Directly adjoining
KentuckyHopkins County21107970900Directly adjoining
KentuckyHopkins County21107971000Directly adjoining
KentuckyHopkins County21107971100Directly adjoining
KentuckyHopkins County21107971300Mine closure, Directly adjoining
KentuckyJackson County21109960101Mine closure, Directly adjoining
KentuckyJackson County21109960102Mine closure, Directly adjoining
KentuckyJackson County21109960200Directly adjoining
KentuckyJackson County21109960301Mine closure, Directly adjoining
KentuckyJackson County21109960302Mine closure, Directly adjoining
KentuckyJefferson County21111000400Directly adjoining
KentuckyJefferson County21111000800Directly adjoining
KentuckyJefferson County21111012103Directly adjoining
KentuckyJefferson County21111012407Directly adjoining
KentuckyJefferson County21111012409Directly adjoining
KentuckyJefferson County21111012412Directly adjoining
KentuckyJefferson County21111012413Directly adjoining
KentuckyJefferson County21111012503Directly adjoining
KentuckyJefferson County21111012702Directly adjoining
KentuckyJefferson County21111012703Generating unit retirement
KentuckyJessamine County21113060402Directly adjoining
KentuckyJohnson County21115960100Mine closure, Directly adjoining
KentuckyJohnson County21115960200Mine closure, Directly adjoining
KentuckyJohnson County21115960300Mine closure, Directly adjoining
KentuckyJohnson County21115960401Mine closure, Directly adjoining
KentuckyJohnson County21115960402Mine closure, Directly adjoining
KentuckyJohnson County21115960500Mine closure, Directly adjoining
KentuckyJohnson County21115960600Mine closure, Directly adjoining
KentuckyKnott County21119960100Mine closure, Directly adjoining
KentuckyKnott County21119960200Mine closure, Directly adjoining

June 10, 2024 1542 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyKnott County21119960300Mine closure, Directly adjoining
KentuckyKnott County21119960400Mine closure, Directly adjoining
KentuckyKnott County21119960500Mine closure, Directly adjoining
KentuckyKnox County21121930100Mine closure, Directly adjoining
KentuckyKnox County21121930200Mine closure, Directly adjoining
KentuckyKnox County21121930300Mine closure, Directly adjoining
KentuckyKnox County21121930401Mine closure, Directly adjoining
KentuckyKnox County21121930402Directly adjoining
KentuckyKnox County21121930501Mine closure, Directly adjoining
KentuckyKnox County21121930502Mine closure, Directly adjoining
KentuckyKnox County21121930602Mine closure, Directly adjoining
KentuckyKnox County21121930603Directly adjoining
KentuckyKnox County21121930604Mine closure, Directly adjoining
KentuckyKnox County21121930700Mine closure, Directly adjoining
KentuckyLaurel County21125970100Mine closure, Directly adjoining
KentuckyLaurel County21125970201Directly adjoining
KentuckyLaurel County21125970202Directly adjoining
KentuckyLaurel County21125970300Directly adjoining
KentuckyLaurel County21125970400Directly adjoining
KentuckyLaurel County21125970500Mine closure, Directly adjoining
KentuckyLaurel County21125970600Directly adjoining
KentuckyLaurel County21125970700Directly adjoining
KentuckyLaurel County21125970800Directly adjoining
KentuckyLaurel County21125970900Mine closure, Directly adjoining
KentuckyLaurel County21125971001Directly adjoining
KentuckyLaurel County21125971003Directly adjoining
KentuckyLaurel County21125971004Directly adjoining
KentuckyLaurel County21125971101Directly adjoining
KentuckyLaurel County21125971104Directly adjoining
KentuckyLawrence County21127930101Generating unit retirement, Directly adjoining
KentuckyLawrence County21127930102Mine closure, Directly adjoining
KentuckyLawrence County21127930200Mine closure, Directly adjoining
KentuckyLawrence County21127930300Mine closure, Directly adjoining
KentuckyLawrence County21127930400Mine closure, Directly adjoining
KentuckyLawrence County21127930500Mine closure, Directly adjoining
KentuckyLee County21129950100Mine closure, Directly adjoining
KentuckyLee County21129950200Mine closure, Directly adjoining
KentuckyLee County21129950300Directly adjoining
KentuckyLeslie County21131920101Mine closure, Directly adjoining
KentuckyLeslie County21131920102Mine closure, Directly adjoining
KentuckyLeslie County21131920200Mine closure, Directly adjoining
KentuckyLeslie County21131920300Mine closure, Directly adjoining
KentuckyLetcher County21133950100Mine closure, Directly adjoining

Bulletin No. 2024–24 1543 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyLetcher County21133950201Mine closure, Directly adjoining
KentuckyLetcher County21133950202Mine closure, Directly adjoining
KentuckyLetcher County21133950300Mine closure, Directly adjoining
KentuckyLetcher County21133950401Mine closure, Directly adjoining
KentuckyLetcher County21133950403Mine closure, Directly adjoining
KentuckyLetcher County21133950404Mine closure, Directly adjoining
KentuckyLetcher County21133950500Mine closure, Directly adjoining
KentuckyLetcher County21133950601Mine closure, Directly adjoining
KentuckyLetcher County21133950602Mine closure, Directly adjoining
KentuckyLewis County21135930100Directly adjoining
KentuckyLewis County21135930300Directly adjoining
KentuckyLewis County21135930400Directly adjoining
KentuckyLogan County21141960200Directly adjoining
KentuckyMcCracken County21145031401Directly adjoining
KentuckyMcCracken County21145031501Generating unit retirement, Directly adjoining
KentuckyMcCracken County21145031502Directly adjoining
KentuckyMcCreary County21147960100Directly adjoining
KentuckyMcCreary County21147960200Directly adjoining
KentuckyMcCreary County21147960301Directly adjoining
KentuckyMcCreary County21147960302Directly adjoining
KentuckyMcCreary County21147960401Directly adjoining
KentuckyMcCreary County21147960402Mine closure, Directly adjoining
KentuckyMcLean County21149970100Directly adjoining
KentuckyMcLean County21149970200Mine closure, Directly adjoining
KentuckyMcLean County21149970500Mine closure, Directly adjoining
KentuckyMadison County21151010101Directly adjoining
KentuckyMadison County21151010104Directly adjoining
KentuckyMagoffin County21153970100Mine closure, Directly adjoining
KentuckyMagoffin County21153970201Directly adjoining
KentuckyMagoffin County21153970202Mine closure, Directly adjoining
KentuckyMagoffin County21153970300Mine closure, Directly adjoining
KentuckyMagoffin County21153970400Mine closure, Directly adjoining
KentuckyMartin County21159950100Mine closure, Directly adjoining
KentuckyMartin County21159950201Mine closure, Directly adjoining
KentuckyMartin County21159950202Mine closure, Directly adjoining
KentuckyMartin County21159950300Mine closure, Directly adjoining
KentuckyMason County21161960100Directly adjoining
KentuckyMenifee County21165960100Directly adjoining
KentuckyMercer County21167960100Directly adjoining
KentuckyMercer County21167960400Directly adjoining
KentuckyMercer County21167960500Generating unit retirement
KentuckyMorgan County21175950100Mine closure, Directly adjoining
KentuckyMorgan County21175950200Directly adjoining

June 10, 2024 1544 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyMorgan County21175950300Directly adjoining
KentuckyMorgan County21175950400Mine closure, Directly adjoining
KentuckyMorgan County21175950500Directly adjoining
KentuckyMuhlenberg County21177960100Mine closure, Directly adjoining
KentuckyMuhlenberg County21177960201Directly adjoining
KentuckyMuhlenberg County21177960202Generating unit retirement, Directly adjoining
KentuckyMuhlenberg County21177960300Mine closure, Directly adjoining
KentuckyMuhlenberg County21177960400Mine closure, Directly adjoining
KentuckyMuhlenberg County21177960500Directly adjoining
KentuckyMuhlenberg County21177960600Mine closure, Directly adjoining
KentuckyMuhlenberg County21177960700Generating unit retirement, Directly adjoining
KentuckyMuhlenberg County21177960800Directly adjoining
KentuckyMuhlenberg County21177960900Directly adjoining
KentuckyOhio County21183920100Mine closure, Directly adjoining
KentuckyOhio County21183920200Mine closure, Directly adjoining
KentuckyOhio County21183920300Directly adjoining
KentuckyOhio County21183920400Directly adjoining
KentuckyOhio County21183920501Directly adjoining
KentuckyOhio County21183920502Mine closure, Directly adjoining
KentuckyOhio County21183920600Mine closure, Directly adjoining
KentuckyOhio County21183920700Mine closure, Directly adjoining
KentuckyOwsley County21189930100Mine closure, Directly adjoining
KentuckyOwsley County21189930200Mine closure, Directly adjoining
KentuckyPendleton County21191930101Directly adjoining
KentuckyPerry County21193970300Mine closure, Directly adjoining
KentuckyPerry County21193970400Mine closure, Directly adjoining
KentuckyPerry County21193970501Mine closure, Directly adjoining
KentuckyPerry County21193970502Directly adjoining
KentuckyPerry County21193970601Mine closure, Directly adjoining
KentuckyPerry County21193970602Directly adjoining
KentuckyPerry County21193970700Mine closure, Directly adjoining
KentuckyPerry County21193970800Mine closure, Directly adjoining
KentuckyPerry County21193970900Mine closure, Directly adjoining
KentuckyPerry County21193971000Mine closure, Directly adjoining
KentuckyPike County21195930100Mine closure, Directly adjoining
KentuckyPike County21195930201Mine closure, Directly adjoining
KentuckyPike County21195930202Mine closure, Directly adjoining
KentuckyPike County21195930301Mine closure, Directly adjoining
KentuckyPike County21195930302Directly adjoining
KentuckyPike County21195930400Mine closure, Directly adjoining
KentuckyPike County21195930500Mine closure, Directly adjoining
KentuckyPike County21195930600Mine closure, Directly adjoining
KentuckyPike County21195930700Mine closure, Directly adjoining

Bulletin No. 2024–24 1545 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyPike County21195930800Mine closure, Directly adjoining
KentuckyPike County21195930900Mine closure, Directly adjoining
KentuckyPike County21195931000Mine closure, Directly adjoining
KentuckyPike County21195931101Mine closure, Directly adjoining
KentuckyPike County21195931102Mine closure, Directly adjoining
KentuckyPike County21195931200Mine closure, Directly adjoining
KentuckyPike County21195931300Mine closure, Directly adjoining
KentuckyPike County21195931400Mine closure, Directly adjoining
KentuckyPike County21195931500Mine closure, Directly adjoining
KentuckyPike County21195931600Mine closure, Directly adjoining
KentuckyPike County21195931700Mine closure, Directly adjoining
KentuckyPike County21195931800Mine closure, Directly adjoining
KentuckyPike County21195931900Mine closure, Directly adjoining
KentuckyPowell County21197970101Directly adjoining
KentuckyPulaski County21199930102Directly adjoining
KentuckyPulaski County21199930404Directly adjoining
KentuckyPulaski County21199930802Directly adjoining
KentuckyPulaski County21199930900Mine closure
KentuckyPulaski County21199931000Directly adjoining
KentuckyPulaski County21199931101Directly adjoining
KentuckyPulaski County21199931103Mine closure
KentuckyPulaski County21199931104Directly adjoining
KentuckyRockcastle County21203950300Directly adjoining
KentuckyRockcastle County21203950400Directly adjoining
KentuckyRowan County21205950400Directly adjoining
KentuckyTrigg County21221970100Directly adjoining
KentuckyUnion County21225950100Mine closure, Directly adjoining
KentuckyUnion County21225950201Mine closure, Directly adjoining
KentuckyUnion County21225950202Mine closure, Directly adjoining
KentuckyUnion County21225950300Mine closure, Directly adjoining
KentuckyWayne County21231920702Directly adjoining
KentuckyWebster County21233960100Mine closure, Generating unit retirement,
Directly adjoining
KentuckyWebster County21233960200Directly adjoining
KentuckyWebster County21233960300Mine closure, Directly adjoining
KentuckyWebster County21233960400Mine closure, Directly adjoining
KentuckyWhitley County21235920100Directly adjoining
KentuckyWhitley County21235920200Mine closure, Directly adjoining
KentuckyWhitley County21235920301Directly adjoining
KentuckyWhitley County21235920302Mine closure, Directly adjoining
KentuckyWhitley County21235920401Directly adjoining
KentuckyWhitley County21235920402Directly adjoining
KentuckyWhitley County21235920501Mine closure, Directly adjoining
KentuckyWhitley County21235920502Mine closure, Directly adjoining

June 10, 2024 1546 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
KentuckyWhitley County21235920601Directly adjoining
KentuckyWhitley County21235920602Mine closure, Directly adjoining
KentuckyWhitley County21235920700Mine closure, Directly adjoining
KentuckyWhitley County21235920800Mine closure, Directly adjoining
KentuckyWolfe County21237930100Mine closure, Directly adjoining
KentuckyWolfe County21237930200Directly adjoining
KentuckyWoodford County21239050103Directly adjoining
KentuckyWoodford County21239050104Directly adjoining
KentuckyWoodford County21239050107Directly adjoining
KentuckyWoodford County21239050200Directly adjoining
KentuckyWoodford County21239050300Generating unit retirement
KentuckyWoodford County21239050400Directly adjoining
LouisianaBienville Parish22013970300Directly adjoining
LouisianaBienville Parish22013970400Directly adjoining
LouisianaBossier Parish22015011002Directly adjoining
LouisianaCaddo Parish22017024002Directly adjoining
LouisianaDe Soto Parish22031950101Directly adjoining
LouisianaDe Soto Parish22031950102Directly adjoining
LouisianaDe Soto Parish22031950200Directly adjoining
LouisianaDe Soto Parish22031950300Mine closure, Generating unit retirement,
Directly adjoining
LouisianaDe Soto Parish22031950400Directly adjoining
LouisianaDe Soto Parish22031950600Directly adjoining
LouisianaDe Soto Parish22031950700Directly adjoining
LouisianaNatchitoches Parish22069000100Directly adjoining
LouisianaNatchitoches Parish22069000200Directly adjoining
LouisianaNatchitoches Parish22069000300Directly adjoining
LouisianaRed River Parish22081960100Mine closure, Directly adjoining
LouisianaRed River Parish22081960300Directly adjoining
MarylandAllegany County24001001401Directly adjoining
MarylandAllegany County24001001502Directly adjoining
MarylandAllegany County24001001503Directly adjoining
MarylandAllegany County24001001600Directly adjoining
MarylandAllegany County24001001700Directly adjoining
MarylandAllegany County24001001800Mine closure, Directly adjoining
MarylandAllegany County24001001900Mine closure, Directly adjoining
MarylandAllegany County24001002000Directly adjoining
MarylandAllegany County24001002100Mine closure, Directly adjoining
MarylandAllegany County24001002200Mine closure, Generating unit retirement,
Directly adjoining
MarylandAnne Arundel County24003730101Directly adjoining
MarylandAnne Arundel County24003730102Generating unit retirement
MarylandAnne Arundel County24003730204Directly adjoining
MarylandAnne Arundel County24003730206Directly adjoining

Bulletin No. 2024–24 1547 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MarylandAnne Arundel County24003731308Directly adjoining
MarylandAnne Arundel County24003731309Directly adjoining
MarylandAnne Arundel County24003751102Directly adjoining
MarylandAnne Arundel County24003751103Directly adjoining
MarylandAnne Arundel County24003990000Directly adjoining
MarylandBaltimore County24005451801Directly adjoining
MarylandBaltimore County24005451802Directly adjoining
MarylandBaltimore County24005451803Generating unit retirement
MarylandCalvert County24009860200Directly adjoining
MarylandCalvert County24009860600Directly adjoining
MarylandCalvert County24009860701Directly adjoining
MarylandCharles County24017850201Generating unit retirement
MarylandCharles County24017850202Directly adjoining
MarylandCharles County24017850300Directly adjoining
MarylandCharles County24017850400Directly adjoining
MarylandCharles County24017850802Directly adjoining
MarylandCharles County24017851100Directly adjoining
MarylandCharles County24017851200Generating unit retirement
MarylandCharles County24017851301Directly adjoining
MarylandCharles County24017851401Directly adjoining
MarylandCharles County24017851402Directly adjoining
MarylandCharles County24017851403Directly adjoining
MarylandCharles County24017990000Directly adjoining
MarylandFrederick County24021752201Directly adjoining
MarylandFrederick County24021752302Directly adjoining
MarylandGarrett County24023000100Directly adjoining
MarylandGarrett County24023000200Directly adjoining
MarylandGarrett County24023000300Mine closure, Directly adjoining
MarylandGarrett County24023000400Mine closure, Directly adjoining
MarylandGarrett County24023000501Directly adjoining
MarylandGarrett County24023000502Directly adjoining
MarylandGarrett County24023000601Mine closure, Directly adjoining
MarylandGarrett County24023000602Directly adjoining
MarylandGarrett County24023000700Mine closure, Directly adjoining
MarylandMontgomery County24031700400Directly adjoining
MarylandMontgomery County24031700500Generating unit retirement
MarylandMontgomery County24031700604Directly adjoining
MarylandMontgomery County24031700611Directly adjoining
MarylandPrince George's County24033800800Directly adjoining
MarylandPrince George's County24033800900Generating unit retirement
MarylandPrince George's County24033801003Directly adjoining
MarylandSt. Mary's County24037875202Directly adjoining
MarylandSt. Mary's County24037875300Directly adjoining

June 10, 2024 1548 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MarylandWashington County24043001001Directly adjoining
MarylandWashington County24043001002Directly adjoining
MarylandWashington County24043010802Generating unit retirement
MarylandWashington County24043010803Directly adjoining
MarylandWashington County24043010901Directly adjoining
MarylandWashington County24043010902Directly adjoining
MarylandWashington County24043011700Directly adjoining
MarylandBaltimore city24510250500Directly adjoining
MassachusettsBristol County25005640300Directly adjoining
MassachusettsBristol County25005640400Directly adjoining
MassachusettsBristol County25005640500Directly adjoining
MassachusettsBristol County25005641000Directly adjoining
MassachusettsBristol County25005642000Directly adjoining
MassachusettsBristol County25005642100Directly adjoining
MassachusettsBristol County25005644101Directly adjoining
MassachusettsBristol County25005644200Generating unit retirement
MassachusettsBristol County25005645101Directly adjoining
MassachusettsBristol County25005645102Directly adjoining
MassachusettsEssex County25009203200Directly adjoining
MassachusettsEssex County25009203301Directly adjoining
MassachusettsEssex County25009203302Directly adjoining
MassachusettsEssex County25009204300Directly adjoining
MassachusettsEssex County25009204400Generating unit retirement
MassachusettsEssex County25009204500Directly adjoining
MassachusettsEssex County25009217402Directly adjoining
MassachusettsEssex County25009217500Directly adjoining
MassachusettsEssex County25009217602Directly adjoining
MassachusettsEssex County25009990100Directly adjoining
MassachusettsHampden County25013811700Directly adjoining
MassachusettsHampden County25013811800Directly adjoining
MassachusettsHampden County25013811900Generating unit retirement
MassachusettsHampden County25013812001Directly adjoining
MassachusettsHampden County25013812002Directly adjoining
MassachusettsHampden County25013812101Directly adjoining
MassachusettsHampshire County25015821101Directly adjoining
MassachusettsHampshire County25015821300Directly adjoining
MassachusettsHampshire County25015821400Directly adjoining
MassachusettsHampshire County25015822300Directly adjoining
MassachusettsHampshire County25015822401Directly adjoining
MichiganBay County26017285100Directly adjoining
MichiganBay County26017285201Directly adjoining
MichiganBay County26017285202Generating unit retirement
MichiganBay County26017285900Directly adjoining

Bulletin No. 2024–24 1549 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MichiganBay County26017990000Directly adjoining
MichiganBranch County26023950100Directly adjoining
MichiganBranch County26023950800Directly adjoining
MichiganCalhoun County26025003000Directly adjoining
MichiganCalhoun County26025003100Directly adjoining
MichiganDelta County26041970400Directly adjoining
MichiganDelta County26041970500Directly adjoining
MichiganDelta County26041970700Directly adjoining
MichiganDelta County26041970800Directly adjoining
MichiganDelta County26041970900Generating unit retirement
MichiganDelta County26041971000Directly adjoining
MichiganDelta County26041971100Directly adjoining
MichiganDelta County26041990000Directly adjoining
MichiganEaton County26045020102Directly adjoining
MichiganEaton County26045020103Directly adjoining
MichiganEaton County26045020201Directly adjoining
MichiganEaton County26045020202Directly adjoining
MichiganEaton County26045020302Directly adjoining
MichiganEaton County26045020303Generating unit retirement
MichiganEaton County26045020305Directly adjoining
MichiganEaton County26045020306Directly adjoining
MichiganEaton County26045021401Directly adjoining
MichiganHillsdale County26059050200Directly adjoining
MichiganHillsdale County26059050300Generating unit retirement
MichiganHillsdale County26059050400Directly adjoining
MichiganHillsdale County26059050500Directly adjoining
MichiganHuron County26063950200Directly adjoining
MichiganHuron County26063950900Directly adjoining
MichiganHuron County26063951200Generating unit retirement
MichiganHuron County26063990000Directly adjoining
MichiganIngham County26065000400Directly adjoining
MichiganIngham County26065001703Directly adjoining
MichiganIngham County26065002000Directly adjoining
MichiganIngham County26065003400Directly adjoining
MichiganIngham County26065003500Directly adjoining
MichiganIngham County26065006700Directly adjoining
MichiganIngham County26065006800Directly adjoining
MichiganIngham County26065007000Directly adjoining
MichiganIngham County26065980200Generating unit retirement
MichiganJackson County26075006403Directly adjoining
MichiganMarquette County26103000200Directly adjoining
MichiganMarquette County26103000300Directly adjoining
MichiganMarquette County26103000500Directly adjoining

June 10, 2024 1550 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MichiganMarquette County26103000600Generating unit retirement
MichiganMarquette County26103000700Directly adjoining
MichiganMarquette County26103001100Directly adjoining
MichiganMarquette County26103001300Directly adjoining
MichiganMarquette County26103002801Directly adjoining
MichiganMarquette County26103002802Generating unit retirement
MichiganMarquette County26103002901Directly adjoining
MichiganMarquette County26103990000Directly adjoining
MichiganMenominee County26109960500Directly adjoining
MichiganMenominee County26109960600Directly adjoining
MichiganMenominee County26109960700Generating unit retirement
MichiganMenominee County26109990000Directly adjoining
MichiganMonroe County26115832600Directly adjoining
MichiganMonroe County26115833600Directly adjoining
MichiganMonroe County26115833700Generating unit retirement
MichiganMonroe County26115990000Directly adjoining
MichiganMuskegon County26121000900Directly adjoining
MichiganMuskegon County26121001000Generating unit retirement
MichiganMuskegon County26121001500Directly adjoining
MichiganMuskegon County26121001600Directly adjoining
MichiganMuskegon County26121001700Directly adjoining
MichiganMuskegon County26121001800Generating unit retirement
MichiganMuskegon County26121001901Directly adjoining
MichiganMuskegon County26121002300Directly adjoining
MichiganMuskegon County26121003200Directly adjoining
MichiganMuskegon County26121003300Directly adjoining
MichiganMuskegon County26121003400Directly adjoining
MichiganMuskegon County26121004200Directly adjoining
MichiganMuskegon County26121990000Directly adjoining
MichiganOntonagon County26131970100Directly adjoining
MichiganOntonagon County26131970200Generating unit retirement
MichiganOntonagon County26131970300Directly adjoining
MichiganOntonagon County26131990100Directly adjoining
MichiganOttawa County26139020600Directly adjoining
MichiganOttawa County26139020900Generating unit retirement
MichiganOttawa County26139021000Directly adjoining
MichiganOttawa County26139021100Directly adjoining
MichiganOttawa County26139021203Directly adjoining
MichiganOttawa County26139024901Directly adjoining
MichiganOttawa County26139024902Generating unit retirement
MichiganOttawa County26139025101Directly adjoining
MichiganSt. Clair County26147620000Directly adjoining
MichiganSt. Clair County26147637100Directly adjoining

Bulletin No. 2024–24 1551 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MichiganSt. Clair County26147637200Directly adjoining
MichiganSt. Clair County26147637300Generating unit retirement
MichiganSt. Clair County26147640100Directly adjoining
MichiganSt. Clair County26147640200Directly adjoining
MichiganSt. Clair County26147641000Directly adjoining
MichiganSt. Clair County26147642000Directly adjoining
MichiganSt. Clair County26147643000Generating unit retirement
MichiganSt. Clair County26147644000Directly adjoining
MichiganSanilac County26151970100Directly adjoining
MichiganSanilac County26151970200Directly adjoining
MichiganSanilac County26151990000Directly adjoining
MichiganTuscola County26157000300Directly adjoining
MichiganTuscola County26157990000Directly adjoining
MichiganWayne County26163524600Directly adjoining
MichiganWayne County26163579100Directly adjoining
MichiganWayne County26163579200Directly adjoining
MichiganWayne County26163594401Directly adjoining
MichiganWayne County26163596100Directly adjoining
MichiganWayne County26163596300Directly adjoining
MichiganWayne County26163597000Directly adjoining
MichiganWayne County26163982301Generating unit retirement
MichiganWayne County26163982302Directly adjoining
MichiganWayne County26163984100Directly adjoining
MichiganWayne County26163985600Generating unit retirement
MichiganWayne County26163987000Directly adjoining
MinnesotaBenton County27009020202Directly adjoining
MinnesotaBenton County27009020205Directly adjoining
MinnesotaBenton County27009020206Generating unit retirement
MinnesotaBenton County27009020300Directly adjoining
MinnesotaBenton County27009021103Directly adjoining
MinnesotaBenton County27009021104Directly adjoining
MinnesotaCass County27021960100Directly adjoining
MinnesotaCook County27031480101Directly adjoining
MinnesotaCook County27031480102Generating unit retirement
MinnesotaCook County27031480200Directly adjoining
MinnesotaCook County27031990000Directly adjoining
MinnesotaCrow Wing County27035950901Directly adjoining
MinnesotaCrow Wing County27035951000Directly adjoining
MinnesotaCrow Wing County27035951100Directly adjoining
MinnesotaCrow Wing County27035951200Generating unit retirement
MinnesotaCrow Wing County27035951301Directly adjoining
MinnesotaCrow Wing County27035951303Directly adjoining
MinnesotaCrow Wing County27035951304Directly adjoining

June 10, 2024 1552 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MinnesotaDakota County27037060710Directly adjoining
MinnesotaDakota County27037060711Directly adjoining
MinnesotaDakota County27037060714Directly adjoining
MinnesotaDakota County27037060721Directly adjoining
MinnesotaDakota County27037060725Directly adjoining
MinnesotaDakota County27037060737Directly adjoining
MinnesotaDakota County27037060738Directly adjoining
MinnesotaDakota County27037060747Directly adjoining
MinnesotaDakota County27037060748Generating unit retirement
MinnesotaHennepin County27053025100Directly adjoining
MinnesotaHennepin County27053025301Directly adjoining
MinnesotaHennepin County27053025801Directly adjoining
MinnesotaHouston County27055020200Directly adjoining
MinnesotaHouston County27055020900Directly adjoining
MinnesotaItasca County27061480301Directly adjoining
MinnesotaItasca County27061480302Directly adjoining
MinnesotaItasca County27061480701Directly adjoining
MinnesotaItasca County27061480702Generating unit retirement
MinnesotaItasca County27061480801Directly adjoining
MinnesotaItasca County27061480804Directly adjoining
MinnesotaItasca County27061480805Directly adjoining
MinnesotaItasca County27061480902Directly adjoining
MinnesotaItasca County27061940000Directly adjoining
MinnesotaLake County27075370101Directly adjoining
MinnesotaOlmsted County27109000100Directly adjoining
MinnesotaOlmsted County27109000200Directly adjoining
MinnesotaOlmsted County27109000500Directly adjoining
MinnesotaOlmsted County27109000600Generating unit retirement
MinnesotaOlmsted County27109001301Directly adjoining
MinnesotaOlmsted County27109001401Directly adjoining
MinnesotaOlmsted County27109001502Directly adjoining
MinnesotaOlmsted County27109001503Directly adjoining
MinnesotaOlmsted County27109001601Directly adjoining
MinnesotaOlmsted County27109002300Directly adjoining
MinnesotaOtter Tail County27111960800Directly adjoining
MinnesotaOtter Tail County27111960900Directly adjoining
MinnesotaOtter Tail County27111961000Directly adjoining
MinnesotaOtter Tail County27111961100Generating unit retirement
MinnesotaOtter Tail County27111961700Directly adjoining
MinnesotaSherburne County27141030201Directly adjoining
MinnesotaSherburne County27141030202Directly adjoining
MinnesotaSherburne County27141030302Directly adjoining
MinnesotaSherburne County27141030406Directly adjoining

Bulletin No. 2024–24 1553 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MinnesotaSherburne County27141030407Generating unit retirement
MinnesotaSherburne County27141030408Directly adjoining
MinnesotaSherburne County27141030410Directly adjoining
MinnesotaStearns County27145010101Directly adjoining
MinnesotaStearns County27145010103Directly adjoining
MinnesotaWabasha County27157490100Directly adjoining
MinnesotaWabasha County27157490200Directly adjoining
MinnesotaWright County27171100203Directly adjoining
MinnesotaWright County27171100205Directly adjoining
MinnesotaWright County27171100300Directly adjoining
MississippiDeSoto County28033070101Directly adjoining
MississippiForrest County28035000800Directly adjoining
MississippiForrest County28035010601Directly adjoining
MississippiKemper County28069030100Directly adjoining
MississippiKemper County28069030200Mine closure
MississippiLamar County28073020203Directly adjoining
MississippiLamar County28073020204Directly adjoining
MississippiLamar County28073020206Directly adjoining
MississippiLamar County28073020303Generating unit retirement
MississippiLamar County28073020304Directly adjoining
MississippiLamar County28073020305Directly adjoining
MississippiLamar County28073020402Directly adjoining
MississippiLauderdale County28075010205Directly adjoining
MississippiLauderdale County28075010301Directly adjoining
MississippiLauderdale County28075010304Directly adjoining
MississippiMonroe County28095950101Directly adjoining
MississippiMonroe County28095950501Directly adjoining
MississippiMonroe County28095950502Directly adjoining
MississippiNeshoba County28099010101Directly adjoining
MississippiNeshoba County28099010102Directly adjoining
MississippiNeshoba County28099010600Directly adjoining
MississippiNewton County28101050100Directly adjoining
MississippiNoxubee County28103950100Directly adjoining
MississippiNoxubee County28103950200Directly adjoining
MississippiWinston County28159950500Directly adjoining
MissouriBarton County29011960200Directly adjoining
MissouriBates County29013070100Directly adjoining
MissouriBates County29013070200Mine closure, Directly adjoining
MissouriBates County29013070300Directly adjoining
MissouriBates County29013070400Directly adjoining
MissouriBenton County29015460702Directly adjoining
MissouriBoone County29019000200Directly adjoining
MissouriBoone County29019000700Directly adjoining

June 10, 2024 1554 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MissouriBoone County29019000900Generating unit retirement
MissouriBoone County29019001001Directly adjoining
MissouriBoone County29019001402Directly adjoining
MissouriBoone County29019001507Directly adjoining
MissouriBoone County29019002100Directly adjoining
MissouriCallaway County29027070200Directly adjoining
MissouriCallaway County29027070602Directly adjoining
MissouriCallaway County29027070701Directly adjoining
MissouriCass County29037061100Directly adjoining
MissouriChristian County29043020202Directly adjoining
MissouriChristian County29043020207Directly adjoining
MissouriChristian County29043020307Directly adjoining
MissouriClay County29047021401Directly adjoining
MissouriClay County29047021403Directly adjoining
MissouriClay County29047021601Directly adjoining
MissouriClay County29047021602Generating unit retirement, Directly adjoining
MissouriClay County29047021701Directly adjoining
MissouriClay County29047021704Directly adjoining
MissouriClay County29047021811Directly adjoining
MissouriClay County29047022301Directly adjoining
MissouriCole County29051020198Directly adjoining
MissouriGasconade County29073960200Directly adjoining
MissouriGreene County29077003801Directly adjoining
MissouriGreene County29077004002Directly adjoining
MissouriGreene County29077004003Generating unit retirement
MissouriGreene County29077004004Directly adjoining
MissouriGreene County29077004005Directly adjoining
MissouriGreene County29077004108Directly adjoining
MissouriGreene County29077004109Directly adjoining
MissouriHenry County29083950200Directly adjoining
MissouriHenry County29083950300Directly adjoining
MissouriHenry County29083950400Generating unit retirement
MissouriHenry County29083950500Directly adjoining
MissouriHenry County29083950600Directly adjoining
MissouriJackson County29095014902Directly adjoining
MissouriJackson County29095014903Directly adjoining
MissouriJackson County29095015000Generating unit retirement, Directly adjoining
MissouriJackson County29095015100Directly adjoining
MissouriJackson County29095017700Directly adjoining
MissouriJasper County29097011202Directly adjoining
MissouriJasper County29097011301Directly adjoining
MissouriJasper County29097011302Directly adjoining
MissouriJasper County29097011502Directly adjoining

Bulletin No. 2024–24 1555 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MissouriJasper County29097012201Generating unit retirement, Directly adjoining
MissouriJasper County29097012202Directly adjoining
MissouriJefferson County29099700111Directly adjoining
MissouriJefferson County29099700115Directly adjoining
MissouriLafayette County29107090100Directly adjoining
MissouriMontgomery County29139970300Directly adjoining
MissouriNewton County29145020601Directly adjoining
MissouriOsage County29151490100Generating unit retirement
MissouriOsage County29151490200Directly adjoining
MissouriOsage County29151490300Directly adjoining
MissouriPhelps County29161890401Generating unit retirement
MissouriPhelps County29161890402Directly adjoining
MissouriPhelps County29161890500Directly adjoining
MissouriPhelps County29161890700Directly adjoining
MissouriPhelps County29161890800Directly adjoining
MissouriPike County29163460100Directly adjoining
MissouriPike County29163460200Generating unit retirement
MissouriPike County29163460300Directly adjoining
MissouriPike County29163460400Directly adjoining
MissouriPike County29163460500Directly adjoining
MissouriRalls County29173470100Directly adjoining
MissouriRalls County29173470200Directly adjoining
MissouriRay County29177080300Directly adjoining
MissouriSt. Charles County29183310100Directly adjoining
MissouriSt. Clair County29185480100Directly adjoining
MissouriSt. Clair County29185480300Directly adjoining
MissouriSt. Louis County29189220445Directly adjoining
MissouriSt. Louis County29189220446Directly adjoining
MissouriSt. Louis County29189220451Directly adjoining
MissouriSt. Louis County29189220452Generating unit retirement
MissouriSaline County29195090200Directly adjoining
MissouriSaline County29195090300Generating unit retirement
MissouriSaline County29195090400Directly adjoining
MissouriSaline County29195090500Directly adjoining
MissouriSaline County29195090600Directly adjoining
MissouriVernon County29217950200Directly adjoining
MissouriVernon County29217950500Directly adjoining
MontanaBig Horn County30003000100Directly adjoining
MontanaBig Horn County30003940400Directly adjoining
MontanaBig Horn County30003940500Directly adjoining
MontanaBig Horn County30003940700Directly adjoining
MontanaCuster County30017961300Directly adjoining
MontanaFergus County30027030100Directly adjoining

June 10, 2024 1556 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
MontanaGolden Valley County30037000100Directly adjoining
MontanaMusselshell County30065000100Mine closure
MontanaMusselshell County30065000200Directly adjoining
MontanaPetroleum County30069000100Directly adjoining
MontanaPowder River County30075000100Directly adjoining
MontanaRichland County30083070100Directly adjoining
MontanaRichland County30083070200Directly adjoining
MontanaRichland County30083070301Directly adjoining
MontanaRichland County30083070302Directly adjoining
MontanaRichland County30083070400Generating unit retirement
MontanaRosebud County30087000100Directly adjoining
MontanaRosebud County30087000200Mine closure, Generating unit retirement
MontanaRosebud County30087000300Directly adjoining
MontanaRosebud County30087940400Directly adjoining
MontanaTreasure County30103963500Directly adjoining
MontanaYellowstone County30111000200Directly adjoining
MontanaYellowstone County30111000300Generating unit retirement
MontanaYellowstone County30111000401Directly adjoining
MontanaYellowstone County30111000402Directly adjoining
MontanaYellowstone County30111000800Directly adjoining
MontanaYellowstone County30111000901Directly adjoining
MontanaYellowstone County30111000902Directly adjoining
MontanaYellowstone County30111001000Directly adjoining
MontanaYellowstone County30111001402Directly adjoining
MontanaYellowstone County30111001502Directly adjoining
MontanaYellowstone County30111940001Directly adjoining
NebraskaDakota County31043010400Directly adjoining
NebraskaDouglas County31055000200Generating unit retirement
NebraskaDouglas County31055000300Directly adjoining
NebraskaDouglas County31055000400Directly adjoining
NebraskaDouglas County31055006202Directly adjoining
NebraskaDouglas County31055007303Directly adjoining
NebraskaDouglas County31055007304Directly adjoining
NebraskaSarpy County31153010103Directly adjoining
NebraskaThurston County31173940200Directly adjoining
NevadaClark County32003003314Directly adjoining
NevadaClark County32003003316Directly adjoining
NevadaClark County32003003649Directly adjoining
NevadaClark County32003003657Directly adjoining
NevadaClark County32003005613Directly adjoining
NevadaClark County32003005702Generating unit retirement
NevadaClark County32003005704Directly adjoining
NevadaClark County32003005705Directly adjoining

Bulletin No. 2024–24 1557 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
NevadaClark County32003005818Directly adjoining
NevadaClark County32003005902Generating unit retirement
NevadaClark County32003005904Directly adjoining
NevadaClark County32003007500Directly adjoining
NevadaClark County32003007600Directly adjoining
NevadaClark County32003007802Directly adjoining
NevadaLincoln County32017950200Directly adjoining
NevadaNye County32023960411Directly adjoining
NevadaNye County32023980500Directly adjoining
New JerseyAtlantic County34001011600Directly adjoining
New JerseyAtlantic County34001011804Directly adjoining
New JerseyAtlantic County34001012702Directly adjoining
New JerseyAtlantic County34001012802Directly adjoining
New JerseyBurlington County34005701502Directly adjoining
New JerseyBurlington County34005701700Directly adjoining
New JerseyBurlington County34005704202Directly adjoining
New JerseyCape May County34009020203Directly adjoining
New JerseyCape May County34009020205Directly adjoining
New JerseyCape May County34009020206Directly adjoining
New JerseyCape May County34009020301Generating unit retirement
New JerseyCape May County34009020302Directly adjoining
New JerseyCape May County34009020400Directly adjoining
New JerseyGloucester County34015500500Directly adjoining
New JerseyGloucester County34015500602Directly adjoining
New JerseyGloucester County34015502201Directly adjoining
New JerseyGloucester County34015502202Directly adjoining
New JerseyGloucester County34015502204Directly adjoining
New JerseyGloucester County34015502400Generating unit retirement
New JerseyMercer County34021000100Directly adjoining
New JerseyMercer County34021000200Directly adjoining
New JerseyMercer County34021000300Directly adjoining
New JerseyMercer County34021002500Generating unit retirement
New JerseyMercer County34021002601Directly adjoining
New JerseyMercer County34021002602Directly adjoining
New JerseyMercer County34021003003Directly adjoining
New JerseyMercer County34021003004Directly adjoining
New JerseySalem County34033020100Directly adjoining
New JerseySalem County34033020300Directly adjoining
New JerseySalem County34033020400Directly adjoining
New JerseySalem County34033020500Directly adjoining
New JerseySalem County34033020600Generating unit retirement
New JerseySalem County34033020700Directly adjoining
New JerseySalem County34033021300Directly adjoining

June 10, 2024 1558 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
New JerseySalem County34033021400Directly adjoining
New JerseySalem County34033021500Directly adjoining
New JerseyWarren County34041031200Directly adjoining
New JerseyWarren County34041031601Directly adjoining
New JerseyWarren County34041031700Directly adjoining
New MexicoCatron County35003976401Directly adjoining
New MexicoCatron County35003976402Mine closure
New MexicoCibola County35006974701Directly adjoining
New MexicoCibola County35006974702Directly adjoining
New MexicoColfax County35007950500Directly adjoining
New MexicoColfax County35007950600Mine closure, Generating unit retirement,
Directly adjoining
New MexicoColfax County35007950700Directly adjoining
New MexicoGrant County35017964100Directly adjoining
New MexicoMcKinley County35031943500Directly adjoining
New MexicoMcKinley County35031943602Directly adjoining
New MexicoMcKinley County35031944000Directly adjoining
New MexicoMcKinley County35031946001Directly adjoining
New MexicoMcKinley County35031946002Directly adjoining
New MexicoMcKinley County35031946003Generating unit retirement
New MexicoSan Juan County35045000202Directly adjoining
New MexicoSan Juan County35045000401Directly adjoining
New MexicoSan Juan County35045000402Directly adjoining
New MexicoSan Juan County35045000503Directly adjoining
New MexicoSan Juan County35045000504Mine closure, Generating unit retirement,
Directly adjoining
New MexicoSan Juan County35045000506Directly adjoining
New MexicoSan Juan County35045000507Directly adjoining
New MexicoSan Juan County35045000611Directly adjoining
New MexicoSan Juan County35045000613Directly adjoining
New MexicoSan Juan County35045942801Directly adjoining
New MexicoSan Juan County35045942802Directly adjoining
New MexicoSan Juan County35045942900Directly adjoining
New MexicoSan Juan County35045943000Generating unit retirement, Directly adjoining
New MexicoSan Juan County35045943100Directly adjoining
New MexicoSan Juan County35045943201Directly adjoining
New MexicoSan Juan County35045943300Mine closure, Directly adjoining
New MexicoSierra County35051962402Directly adjoining
New MexicoSocorro County35053940000Directly adjoining
New MexicoSocorro County35053978200Directly adjoining
New YorkBroome County36007012900Directly adjoining
New YorkBroome County36007013000Generating unit retirement
New YorkBroome County36007013100Directly adjoining
New YorkBroome County36007013201Directly adjoining

Bulletin No. 2024–24 1559 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
New YorkBroome County36007013202Directly adjoining
New YorkBroome County36007013304Directly adjoining
New YorkBroome County36007013900Directly adjoining
New YorkBroome County36007014100Directly adjoining
New YorkBroome County36007014200Directly adjoining
New YorkBroome County36007014301Directly adjoining
New YorkCayuga County36011040900Directly adjoining
New YorkCayuga County36011041001Directly adjoining
New YorkChautauqua County36013035500Directly adjoining
New YorkChautauqua County36013035600Generating unit retirement
New YorkChautauqua County36013035700Directly adjoining
New YorkChautauqua County36013036000Directly adjoining
New YorkChautauqua County36013990000Directly adjoining
New YorkErie County36029005600Directly adjoining
New YorkErie County36029005801Directly adjoining
New YorkErie County36029005802Directly adjoining
New YorkErie County36029005900Directly adjoining
New YorkErie County36029007304Directly adjoining
New YorkErie County36029007306Directly adjoining
New YorkErie County36029008202Directly adjoining
New YorkErie County36029008300Directly adjoining
New YorkErie County36029008400Generating unit retirement
New YorkErie County36029008800Directly adjoining
New YorkNiagara County36063024101Directly adjoining
New YorkNiagara County36063024102Generating unit retirement
New YorkNiagara County36063024201Directly adjoining
New YorkNiagara County36063024202Directly adjoining
New YorkNiagara County36063990000Directly adjoining
New YorkOnondaga County36067000100Directly adjoining
New YorkOnondaga County36067002000Directly adjoining
New YorkOnondaga County36067011500Directly adjoining
New YorkOnondaga County36067011800Directly adjoining
New YorkOnondaga County36067011900Directly adjoining
New YorkOnondaga County36067012100Directly adjoining
New YorkOnondaga County36067012700Directly adjoining
New YorkOnondaga County36067012800Generating unit retirement
New YorkOnondaga County36067012900Directly adjoining
New YorkOnondaga County36067013400Directly adjoining
New YorkOnondaga County36067013701Directly adjoining
New YorkOrleans County36073040200Directly adjoining
New YorkOrleans County36073401200Directly adjoining
New YorkOrleans County36073990000Directly adjoining
New YorkSeneca County36099951000Directly adjoining

June 10, 2024 1560 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
New YorkTompkins County36109001500Directly adjoining
New YorkTompkins County36109001600Directly adjoining
New YorkTompkins County36109002100Directly adjoining
New YorkTompkins County36109002200Directly adjoining
New YorkTompkins County36109002300Generating unit retirement
North CarolinaBladen County37017950200Directly adjoining
North CarolinaBladen County37017950301Directly adjoining
North CarolinaBladen County37017950401Generating unit retirement
North CarolinaBladen County37017950402Directly adjoining
North CarolinaBrunswick County37019020101Directly adjoining
North CarolinaBrunswick County37019020108Directly adjoining
North CarolinaBrunswick County37019020205Directly adjoining
North CarolinaBuncombe County37021002203Generating unit retirement
North CarolinaBuncombe County37021002204Directly adjoining
North CarolinaBuncombe County37021002205Directly adjoining
North CarolinaBuncombe County37021002303Directly adjoining
North CarolinaChatham County37037020104Directly adjoining
North CarolinaChatham County37037020600Directly adjoining
North CarolinaChatham County37037020702Generating unit retirement
North CarolinaChatham County37037020703Directly adjoining
North CarolinaChatham County37037020704Directly adjoining
North CarolinaChatham County37037020803Directly adjoining
North CarolinaCleveland County37045951501Directly adjoining
North CarolinaCleveland County37045951502Generating unit retirement
North CarolinaCleveland County37045951503Directly adjoining
North CarolinaCleveland County37045951601Directly adjoining
North CarolinaDavidson County37057061704Directly adjoining
North CarolinaDavidson County37057061807Directly adjoining
North CarolinaDavidson County37057062001Directly adjoining
North CarolinaEdgecombe County37065020400Directly adjoining
North CarolinaEdgecombe County37065020600Generating unit retirement
North CarolinaEdgecombe County37065020700Directly adjoining
North CarolinaEdgecombe County37065021100Directly adjoining
North CarolinaEdgecombe County37065021300Directly adjoining
North CarolinaGaston County37071030103Directly adjoining
North CarolinaGaston County37071030104Generating unit retirement
North CarolinaGaston County37071030106Directly adjoining
North CarolinaGaston County37071032405Directly adjoining
North CarolinaGaston County37071032406Generating unit retirement
North CarolinaGaston County37071032510Directly adjoining
North CarolinaGranville County37077970101Directly adjoining
North CarolinaHalifax County37083930100Generating unit retirement
North CarolinaHalifax County37083930200Directly adjoining

Bulletin No. 2024–24 1561 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
North CarolinaHalifax County37083930400Directly adjoining
North CarolinaHalifax County37083930600Directly adjoining
North CarolinaHalifax County37083931000Directly adjoining
North CarolinaHarnett County37085071002Directly adjoining
North CarolinaHenderson County37089930600Directly adjoining
North CarolinaHenderson County37089930701Directly adjoining
North CarolinaLee County37105030702Directly adjoining
North CarolinaLee County37105030703Directly adjoining
North CarolinaLee County37105030704Directly adjoining
North CarolinaLincoln County37109071102Directly adjoining
North CarolinaMecklenburg County37119005908Directly adjoining
North CarolinaMecklenburg County37119005919Directly adjoining
North CarolinaMecklenburg County37119005920Directly adjoining
North CarolinaMecklenburg County37119005922Directly adjoining
North CarolinaMecklenburg County37119006014Directly adjoining
North CarolinaMecklenburg County37119006103Directly adjoining
North CarolinaMecklenburg County37119006222Directly adjoining
North CarolinaNash County37127010400Directly adjoining
North CarolinaNash County37127010603Directly adjoining
North CarolinaNash County37127010604Directly adjoining
North CarolinaNash County37127010700Directly adjoining
North CarolinaNew Hanover County37129010900Directly adjoining
North CarolinaNew Hanover County37129011300Directly adjoining
North CarolinaNew Hanover County37129011400Directly adjoining
North CarolinaNew Hanover County37129011503Generating unit retirement
North CarolinaNew Hanover County37129011504Directly adjoining
North CarolinaNorthampton County37131920301Directly adjoining
North CarolinaNorthampton County37131920401Directly adjoining
North CarolinaPender County37141920502Directly adjoining
North CarolinaPender County37141920602Directly adjoining
North CarolinaRobeson County37155960802Directly adjoining
North CarolinaRobeson County37155961000Directly adjoining
North CarolinaRobeson County37155961100Generating unit retirement
North CarolinaRobeson County37155961200Directly adjoining
North CarolinaRobeson County37155961302Directly adjoining
North CarolinaRobeson County37155961500Directly adjoining
North CarolinaRockingham County37157040101Directly adjoining
North CarolinaRockingham County37157040200Generating unit retirement
North CarolinaRockingham County37157040300Directly adjoining
North CarolinaRockingham County37157040400Directly adjoining
North CarolinaRockingham County37157041100Directly adjoining
North CarolinaRowan County37159050800Directly adjoining
North CarolinaRowan County37159050901Generating unit retirement

June 10, 2024 1562 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
North CarolinaRowan County37159050903Directly adjoining
North CarolinaRowan County37159050904Directly adjoining
North CarolinaRutherford County37161961102Directly adjoining
North CarolinaRutherford County37161961103Directly adjoining
North CarolinaVance County37181960100Directly adjoining
North CarolinaVance County37181960200Directly adjoining
North CarolinaWake County37183053209Directly adjoining
North CarolinaWake County37183053410Directly adjoining
North CarolinaWake County37183053411Directly adjoining
North CarolinaWake County37183053426Directly adjoining
North CarolinaWake County37183053427Directly adjoining
North CarolinaWake County37183053428Directly adjoining
North CarolinaWarren County37185950101Directly adjoining
North CarolinaWarren County37185950201Directly adjoining
North CarolinaWarren County37185950202Directly adjoining
North CarolinaWayne County37191000601Directly adjoining
North CarolinaWayne County37191000901Generating unit retirement
North CarolinaWayne County37191000902Directly adjoining
North CarolinaWayne County37191001000Directly adjoining
North CarolinaWayne County37191001103Directly adjoining
North CarolinaWayne County37191001500Directly adjoining
North CarolinaWayne County37191002000Directly adjoining
North DakotaBurleigh County38015011103Directly adjoining
North DakotaBurleigh County38015011105Directly adjoining
North DakotaCavalier County38019951100Directly adjoining
North DakotaDunn County38025962200Directly adjoining
North DakotaMcKenzie County38053962500Directly adjoining
North DakotaMcLean County38055940100Directly adjoining
North DakotaMcLean County38055960800Directly adjoining
North DakotaMcLean County38055961001Directly adjoining
North DakotaMercer County38057961600Directly adjoining
North DakotaMercer County38057961700Directly adjoining
North DakotaMercer County38057961800Generating unit retirement
North DakotaMorton County38059020100Directly adjoining
North DakotaMorton County38059020200Generating unit retirement
North DakotaMorton County38059020301Directly adjoining
North DakotaMorton County38059020303Directly adjoining
North DakotaMorton County38059020400Directly adjoining
North DakotaMorton County38059020500Directly adjoining
North DakotaOliver County38065961200Directly adjoining
North DakotaPembina County38067950100Directly adjoining
North DakotaPembina County38067950200Generating unit retirement
North DakotaPembina County38067950600Directly adjoining

Bulletin No. 2024–24 1563 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
North DakotaStark County38089963300Directly adjoining
OhioAdams County39001770302Directly adjoining
OhioAdams County39001770400Directly adjoining
OhioAdams County39001770500Directly adjoining
OhioAdams County39001770600Generating unit retirement
OhioAshtabula County39007000200Directly adjoining
OhioAshtabula County39007000300Generating unit retirement
OhioAshtabula County39007000400Directly adjoining
OhioAshtabula County39007000500Directly adjoining
OhioAshtabula County39007000704Directly adjoining
OhioAshtabula County39007001201Directly adjoining
OhioAshtabula County39007990000Directly adjoining
OhioAthens County39009972600Mine closure, Directly adjoining
OhioAthens County39009972700Directly adjoining
OhioAthens County39009973400Directly adjoining
OhioAthens County39009973500Mine closure, Directly adjoining
OhioAthens County39009973600Directly adjoining
OhioAthens County39009973700Directly adjoining
OhioBelmont County39013010100Directly adjoining
OhioBelmont County39013010300Directly adjoining
OhioBelmont County39013010600Mine closure, Directly adjoining
OhioBelmont County39013010700Mine closure, Directly adjoining
OhioBelmont County39013010802Directly adjoining
OhioBelmont County39013010901Directly adjoining
OhioBelmont County39013010902Mine closure, Directly adjoining
OhioBelmont County39013011000Mine closure, Directly adjoining
OhioBelmont County39013011200Generating unit retirement, Directly adjoining
OhioBelmont County39013011300Directly adjoining
OhioBelmont County39013011400Directly adjoining
OhioBelmont County39013012201Mine closure, Directly adjoining
OhioBelmont County39013012202Mine closure, Directly adjoining
OhioBelmont County39013012300Mine closure, Directly adjoining
OhioBelmont County39013012400Directly adjoining
OhioBrown County39015951600Directly adjoining
OhioButler County39017001001Directly adjoining
OhioButler County39017001002Directly adjoining
OhioButler County39017001100Directly adjoining
OhioButler County39017010301Directly adjoining
OhioButler County39017010302Directly adjoining
OhioButler County39017010500Directly adjoining
OhioButler County39017010600Generating unit retirement
OhioButler County39017011005Directly adjoining
OhioButler County39017011006Directly adjoining

June 10, 2024 1564 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioButler County39017012100Directly adjoining
OhioButler County39017012200Generating unit retirement
OhioButler County39017012300Directly adjoining
OhioButler County39017012400Directly adjoining
OhioButler County39017012700Directly adjoining
OhioButler County39017013000Directly adjoining
OhioButler County39017014300Directly adjoining
OhioButler County39017014400Directly adjoining
OhioButler County39017014600Directly adjoining
OhioButler County39017014700Generating unit retirement
OhioButler County39017015000Directly adjoining
OhioButler County39017015100Directly adjoining
OhioCarroll County39019720100Directly adjoining
OhioCarroll County39019720200Directly adjoining
OhioCarroll County39019720300Mine closure, Directly adjoining
OhioCarroll County39019720400Mine closure, Directly adjoining
OhioCarroll County39019720500Mine closure, Directly adjoining
OhioCarroll County39019720600Mine closure, Directly adjoining
OhioCarroll County39019720700Directly adjoining
OhioClermont County39025041201Directly adjoining
OhioClermont County39025041503Directly adjoining
OhioClermont County39025041504Directly adjoining
OhioClermont County39025041505Directly adjoining
OhioClermont County39025041506Generating unit retirement
OhioClermont County39025041600Directly adjoining
OhioClermont County39025041702Directly adjoining
OhioClermont County39025041900Directly adjoining
OhioClermont County39025042001Directly adjoining
OhioClermont County39025042002Generating unit retirement
OhioColumbiana County39029950100Mine closure, Directly adjoining
OhioColumbiana County39029950200Directly adjoining
OhioColumbiana County39029950300Directly adjoining
OhioColumbiana County39029950400Directly adjoining
OhioColumbiana County39029950900Directly adjoining
OhioColumbiana County39029951000Directly adjoining
OhioColumbiana County39029951100Mine closure, Directly adjoining
OhioColumbiana County39029951200Mine closure, Directly adjoining
OhioColumbiana County39029951300Mine closure, Directly adjoining
OhioColumbiana County39029951401Directly adjoining
OhioColumbiana County39029951402Mine closure, Directly adjoining
OhioColumbiana County39029951500Mine closure, Directly adjoining
OhioColumbiana County39029951600Mine closure, Directly adjoining
OhioColumbiana County39029951700Mine closure, Directly adjoining

Bulletin No. 2024–24 1565 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioColumbiana County39029951800Directly adjoining
OhioColumbiana County39029951900Directly adjoining
OhioColumbiana County39029952000Directly adjoining
OhioColumbiana County39029952400Directly adjoining
OhioCoshocton County39031960900Mine closure, Directly adjoining
OhioCoshocton County39031961000Directly adjoining
OhioCoshocton County39031961100Directly adjoining
OhioCoshocton County39031961200Mine closure, Generating unit retirement,
Directly adjoining
OhioCoshocton County39031961300Mine closure, Directly adjoining
OhioCoshocton County39031961400Directly adjoining
OhioCoshocton County39031961500Directly adjoining
OhioCoshocton County39031961600Directly adjoining
OhioCoshocton County39031961700Directly adjoining
OhioCoshocton County39031961800Directly adjoining
OhioCuyahoga County39035108301Directly adjoining
OhioCuyahoga County39035111202Generating unit retirement
OhioCuyahoga County39035111401Directly adjoining
OhioCuyahoga County39035111700Directly adjoining
OhioCuyahoga County39035112100Directly adjoining
OhioCuyahoga County39035192800Directly adjoining
OhioCuyahoga County39035198900Directly adjoining
OhioCuyahoga County39035199000Directly adjoining
OhioCuyahoga County39035990000Directly adjoining
OhioFranklin County39049009590Directly adjoining
OhioFranklin County39049009753Directly adjoining
OhioFranklin County39049010300Directly adjoining
OhioGallia County39053953500Directly adjoining
OhioGallia County39053953600Mine closure
OhioGallia County39053953700Directly adjoining
OhioGallia County39053953901Directly adjoining
OhioGallia County39053954100Directly adjoining
OhioGuernsey County39059977100Mine closure, Directly adjoining
OhioGuernsey County39059977200Directly adjoining
OhioGuernsey County39059977300Directly adjoining
OhioGuernsey County39059977600Directly adjoining
OhioGuernsey County39059977700Directly adjoining
OhioGuernsey County39059977800Directly adjoining
OhioGuernsey County39059977900Mine closure, Directly adjoining
OhioGuernsey County39059978000Mine closure, Directly adjoining
OhioHamilton County39061020401Directly adjoining
OhioHamilton County39061020403Generating unit retirement
OhioHamilton County39061020404Directly adjoining
OhioHamilton County39061020501Directly adjoining

June 10, 2024 1566 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioHamilton County39061020603Directly adjoining
OhioHamilton County39061021101Directly adjoining
OhioHamilton County39061021102Directly adjoining
OhioHamilton County39061026002Directly adjoining
OhioHamilton County39061026200Directly adjoining
OhioHamilton County39061027500Directly adjoining
OhioHarrison County39067975600Mine closure, Directly adjoining
OhioHarrison County39067975700Directly adjoining
OhioHarrison County39067975800Mine closure, Directly adjoining
OhioHarrison County39067975900Mine closure, Directly adjoining
OhioHarrison County39067976000Mine closure, Directly adjoining
OhioHocking County39073965500Directly adjoining
OhioHolmes County39075976301Directly adjoining
OhioHolmes County39075976302Mine closure, Directly adjoining
OhioHolmes County39075976403Directly adjoining
OhioHolmes County39075976600Directly adjoining
OhioHolmes County39075976700Directly adjoining
OhioHolmes County39075976801Directly adjoining
OhioHolmes County39075976802Mine closure
OhioJackson County39079957700Directly adjoining
OhioJackson County39079957800Directly adjoining
OhioJefferson County39081000200Directly adjoining
OhioJefferson County39081001200Directly adjoining
OhioJefferson County39081001300Directly adjoining
OhioJefferson County39081001400Directly adjoining
OhioJefferson County39081011000Generating unit retirement, Directly adjoining
OhioJefferson County39081011100Mine closure, Directly adjoining
OhioJefferson County39081011401Directly adjoining
OhioJefferson County39081011402Mine closure, Directly adjoining
OhioJefferson County39081011500Mine closure, Directly adjoining
OhioJefferson County39081011700Directly adjoining
OhioJefferson County39081011800Mine closure, Directly adjoining
OhioJefferson County39081011900Mine closure, Directly adjoining
OhioJefferson County39081012000Directly adjoining
OhioJefferson County39081012100Mine closure, Directly adjoining
OhioJefferson County39081012200Mine closure, Directly adjoining
OhioJefferson County39081012300Directly adjoining
OhioJefferson County39081012400Directly adjoining
OhioLake County39085201500Directly adjoining
OhioLake County39085201600Directly adjoining
OhioLake County39085201900Directly adjoining
OhioLake County39085202000Generating unit retirement
OhioLake County39085202100Directly adjoining

Bulletin No. 2024–24 1567 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioLake County39085206600Directly adjoining
OhioLake County39085990000Directly adjoining
OhioLawrence County39087050400Directly adjoining
OhioLawrence County39087050501Directly adjoining
OhioLawrence County39087050502Directly adjoining
OhioLawrence County39087050600Mine closure, Directly adjoining
OhioLawrence County39087050700Mine closure, Directly adjoining
OhioLawrence County39087050800Directly adjoining
OhioLorain County39093010200Directly adjoining
OhioLorain County39093010300Directly adjoining
OhioLorain County39093010400Generating unit retirement
OhioLorain County39093013101Directly adjoining
OhioLorain County39093013202Directly adjoining
OhioLorain County39093021100Directly adjoining
OhioLorain County39093028100Directly adjoining
OhioLorain County39093097401Directly adjoining
OhioLorain County39093990200Directly adjoining
OhioLucas County39095001201Directly adjoining
OhioLucas County39095004600Directly adjoining
OhioLucas County39095005501Directly adjoining
OhioLucas County39095005502Directly adjoining
OhioLucas County39095005601Directly adjoining
OhioLucas County39095005602Directly adjoining
OhioLucas County39095009800Directly adjoining
OhioLucas County39095009901Directly adjoining
OhioLucas County39095009902Generating unit retirement
OhioLucas County39095010001Directly adjoining
OhioLucas County39095010002Directly adjoining
OhioMahoning County39099810900Directly adjoining
OhioMahoning County39099811001Directly adjoining
OhioMahoning County39099811002Directly adjoining
OhioMahoning County39099811902Directly adjoining
OhioMahoning County39099812001Directly adjoining
OhioMahoning County39099812002Directly adjoining
OhioMahoning County39099812101Directly adjoining
OhioMahoning County39099812102Directly adjoining
OhioMahoning County39099812400Directly adjoining
OhioMahoning County39099812500Directly adjoining
OhioMahoning County39099813501Mine closure
OhioMahoning County39099813502Directly adjoining
OhioMahoning County39099813601Directly adjoining
OhioMahoning County39099813602Directly adjoining
OhioMahoning County39099814100Directly adjoining

June 10, 2024 1568 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioMedina County39103417300Directly adjoining
OhioMeigs County39105964100Directly adjoining
OhioMeigs County39105964300Directly adjoining
OhioMeigs County39105964500Directly adjoining
OhioMeigs County39105964600Mine closure, Directly adjoining
OhioMonroe County39111966600Mine closure, Directly adjoining
OhioMonroe County39111966700Directly adjoining
OhioMonroe County39111966800Directly adjoining
OhioMonroe County39111966900Directly adjoining
OhioMontgomery County39113050301Directly adjoining
OhioMontgomery County39113050302Directly adjoining
OhioMontgomery County39113050402Directly adjoining
OhioMontgomery County39113050502Directly adjoining
OhioMontgomery County39113050600Generating unit retirement
OhioMontgomery County39113060100Directly adjoining
OhioMontgomery County39113060200Directly adjoining
OhioMontgomery County39113070101Directly adjoining
OhioMontgomery County39113070201Directly adjoining
OhioMontgomery County39113140100Directly adjoining
OhioMontgomery County39113150100Directly adjoining
OhioMontgomery County39113165000Directly adjoining
OhioMorgan County39115968800Generating unit retirement
OhioMorgan County39115968900Directly adjoining
OhioMorgan County39115969000Directly adjoining
OhioMorgan County39115969100Directly adjoining
OhioMuskingum County39119911000Mine closure, Directly adjoining
OhioMuskingum County39119911100Directly adjoining
OhioMuskingum County39119911601Directly adjoining
OhioMuskingum County39119911900Directly adjoining
OhioMuskingum County39119912600Directly adjoining
OhioMuskingum County39119912700Directly adjoining
OhioMuskingum County39119912800Directly adjoining
OhioNoble County39121968300Mine closure, Directly adjoining
OhioNoble County39121968401Directly adjoining
OhioNoble County39121968500Directly adjoining
OhioPerry County39127965902Directly adjoining
OhioPerry County39127966000Directly adjoining
OhioPerry County39127966100Mine closure, Directly adjoining
OhioPerry County39127966200Directly adjoining
OhioPerry County39127966301Directly adjoining
OhioPerry County39127966302Mine closure, Directly adjoining
OhioPickaway County39129021101Directly adjoining
OhioPickaway County39129021201Directly adjoining

Bulletin No. 2024–24 1569 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioPickaway County39129021202Generating unit retirement
OhioPickaway County39129021403Directly adjoining
OhioPickaway County39129021404Directly adjoining
OhioPickaway County39129021500Directly adjoining
OhioRichland County39139002500Directly adjoining
OhioRichland County39139002600Generating unit retirement
OhioRichland County39139002700Directly adjoining
OhioRichland County39139002800Directly adjoining
OhioScioto County39145002600Directly adjoining
OhioScioto County39145002700Directly adjoining
OhioScioto County39145002800Directly adjoining
OhioStark County39151700200Directly adjoining
OhioStark County39151700400Directly adjoining
OhioStark County39151700701Directly adjoining
OhioStark County39151700702Directly adjoining
OhioStark County39151711700Directly adjoining
OhioStark County39151712102Directly adjoining
OhioStark County39151712201Directly adjoining
OhioStark County39151712202Directly adjoining
OhioStark County39151712300Mine closure
OhioStark County39151712400Directly adjoining
OhioStark County39151712700Directly adjoining
OhioStark County39151712800Directly adjoining
OhioStark County39151712900Mine closure, Directly adjoining
OhioStark County39151713000Directly adjoining
OhioStark County39151713201Directly adjoining
OhioStark County39151714801Directly adjoining
OhioStark County39151714802Directly adjoining
OhioStark County39151714901Directly adjoining
OhioStark County39151714902Mine closure, Directly adjoining
OhioTrumbull County39155932500Directly adjoining
OhioTrumbull County39155932600Directly adjoining
OhioTrumbull County39155932802Directly adjoining
OhioTrumbull County39155933301Directly adjoining
OhioTrumbull County39155933302Generating unit retirement
OhioTrumbull County39155933900Directly adjoining
OhioTuscarawas County39157020100Mine closure, Directly adjoining
OhioTuscarawas County39157020200Directly adjoining
OhioTuscarawas County39157020300Directly adjoining
OhioTuscarawas County39157020400Mine closure, Directly adjoining
OhioTuscarawas County39157020500Mine closure, Directly adjoining
OhioTuscarawas County39157020600Directly adjoining
OhioTuscarawas County39157020700Mine closure, Directly adjoining

June 10, 2024 1570 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OhioTuscarawas County39157020900Directly adjoining
OhioTuscarawas County39157021000Directly adjoining
OhioTuscarawas County39157021100Directly adjoining
OhioTuscarawas County39157021200Directly adjoining
OhioTuscarawas County39157021300Mine closure, Directly adjoining
OhioTuscarawas County39157021400Directly adjoining
OhioTuscarawas County39157021501Directly adjoining
OhioTuscarawas County39157021502Mine closure, Directly adjoining
OhioTuscarawas County39157021503Mine closure, Directly adjoining
OhioTuscarawas County39157021600Mine closure, Directly adjoining
OhioTuscarawas County39157021700Directly adjoining
OhioTuscarawas County39157021800Mine closure, Directly adjoining
OhioTuscarawas County39157021900Directly adjoining
OhioTuscarawas County39157022001Directly adjoining
OhioTuscarawas County39157022002Mine closure, Directly adjoining
OhioVinton County39163953200Directly adjoining
OhioWarren County39165030101Directly adjoining
OhioWarren County39165030102Directly adjoining
OhioWarren County39165030501Directly adjoining
OhioWashington County39167020201Directly adjoining
OhioWashington County39167020300Generating unit retirement
OhioWashington County39167020400Directly adjoining
OhioWashington County39167020500Directly adjoining
OhioWashington County39167021100Directly adjoining
OhioWashington County39167021201Directly adjoining
OhioWashington County39167021202Directly adjoining
OhioWashington County39167021300Directly adjoining
OhioWashington County39167021500Directly adjoining
OhioWashington County39167021600Directly adjoining
OhioWashington County39167021700Directly adjoining
OhioWayne County39169001700Directly adjoining
OhioWayne County39169002500Directly adjoining
OhioWayne County39169002902Directly adjoining
OhioWayne County39169003000Directly adjoining
OhioWayne County39169003400Generating unit retirement
OhioWayne County39169003500Directly adjoining
OklahomaCraig County40035373100Mine closure, Directly adjoining
OklahomaCraig County40035373200Mine closure, Directly adjoining
OklahomaCraig County40035373300Directly adjoining
OklahomaCraig County40035373400Directly adjoining
OklahomaCraig County40035373500Directly adjoining
OklahomaHaskell County40061279100Directly adjoining
OklahomaHaskell County40061279300Directly adjoining

Bulletin No. 2024–24 1571 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OklahomaHaskell County40061279400Directly adjoining
OklahomaJackson County40065968100Directly adjoining
OklahomaJackson County40065968300Directly adjoining
OklahomaLatimer County40077087100Mine closure, Directly adjoining
OklahomaLatimer County40077087200Directly adjoining
OklahomaLatimer County40077087300Directly adjoining
OklahomaLe Flore County40079040299Directly adjoining
OklahomaLe Flore County40079040301Mine closure, Directly adjoining
OklahomaLe Flore County40079040302Directly adjoining
OklahomaLe Flore County40079040303Directly adjoining
OklahomaLe Flore County40079040401Directly adjoining
OklahomaLe Flore County40079040402Directly adjoining
OklahomaLe Flore County40079040500Mine closure, Directly adjoining
OklahomaLe Flore County40079040601Directly adjoining
OklahomaLe Flore County40079040602Mine closure, Directly adjoining
OklahomaLe Flore County40079040700Directly adjoining
OklahomaMayes County40097040300Directly adjoining
OklahomaMayes County40097040400Generating unit retirement
OklahomaMayes County40097040501Directly adjoining
OklahomaMayes County40097040502Directly adjoining
OklahomaMayes County40097040700Directly adjoining
OklahomaMayes County40097040801Directly adjoining
OklahomaNowata County40105172100Directly adjoining
OklahomaNowata County40105172200Directly adjoining
OklahomaNowata County40105172300Mine closure, Directly adjoining
OklahomaNowata County40105172400Directly adjoining
OklahomaOttawa County40115574100Directly adjoining
OklahomaOttawa County40115574700Directly adjoining
OklahomaOttawa County40115574800Directly adjoining
OklahomaRogers County40131050301Directly adjoining
OklahomaRogers County40131050304Directly adjoining
OklahomaRogers County40131050403Directly adjoining
OklahomaRogers County40131050501Directly adjoining
OklahomaRogers County40131050702Directly adjoining
OklahomaRogers County40131050801Generating unit retirement
OklahomaRogers County40131050802Directly adjoining
OklahomaTillman County40141070100Directly adjoining
OklahomaTulsa County40143005404Directly adjoining
OklahomaWagoner County40145030201Directly adjoining
OklahomaWagoner County40145030300Directly adjoining
OklahomaWashington County40147001000Directly adjoining
OklahomaWashington County40147001100Directly adjoining
OklahomaWashington County40147001200Directly adjoining

June 10, 2024 1572 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
OklahomaWashington County40147001300Directly adjoining
OregonGilliam County41021960100Directly adjoining
OregonMorrow County41049970101Generating unit retirement
OregonMorrow County41049970102Directly adjoining
OregonMorrow County41049970200Directly adjoining
PennsylvaniaAllegheny County42003010302Directly adjoining
PennsylvaniaAllegheny County42003020100Directly adjoining
PennsylvaniaAllegheny County42003020300Directly adjoining
PennsylvaniaAllegheny County42003030500Mine closure
PennsylvaniaAllegheny County42003040200Directly adjoining
PennsylvaniaAllegheny County42003050100Directly adjoining
PennsylvaniaAllegheny County42003050900Directly adjoining
PennsylvaniaAllegheny County42003051100Directly adjoining
PennsylvaniaAllegheny County42003405000Directly adjoining
PennsylvaniaAllegheny County42003415001Directly adjoining
PennsylvaniaAllegheny County42003415002Directly adjoining
PennsylvaniaAllegheny County42003416000Directly adjoining
PennsylvaniaAllegheny County42003417100Directly adjoining
PennsylvaniaAllegheny County42003417200Generating unit retirement
PennsylvaniaAllegheny County42003418000Directly adjoining
PennsylvaniaAllegheny County42003419000Mine closure
PennsylvaniaAllegheny County42003421100Directly adjoining
PennsylvaniaAllegheny County42003422000Directly adjoining
PennsylvaniaAllegheny County42003451300Directly adjoining
PennsylvaniaAllegheny County42003452000Directly adjoining
PennsylvaniaAllegheny County42003453003Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003453004Directly adjoining
PennsylvaniaAllegheny County42003455000Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003456001Directly adjoining
PennsylvaniaAllegheny County42003456003Directly adjoining
PennsylvaniaAllegheny County42003457100Directly adjoining
PennsylvaniaAllegheny County42003457200Directly adjoining
PennsylvaniaAllegheny County42003458001Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003458002Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003459101Directly adjoining
PennsylvaniaAllegheny County42003459102Mine closure
PennsylvaniaAllegheny County42003459201Directly adjoining
PennsylvaniaAllegheny County42003460001Directly adjoining
PennsylvaniaAllegheny County42003460002Directly adjoining
PennsylvaniaAllegheny County42003468800Directly adjoining
PennsylvaniaAllegheny County42003470300Directly adjoining
PennsylvaniaAllegheny County42003470400Directly adjoining
PennsylvaniaAllegheny County42003470600Directly adjoining

Bulletin No. 2024–24 1573 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaAllegheny County42003471000Directly adjoining
PennsylvaniaAllegheny County42003475304Directly adjoining
PennsylvaniaAllegheny County42003475401Directly adjoining
PennsylvaniaAllegheny County42003475402Directly adjoining
PennsylvaniaAllegheny County42003480101Directly adjoining
PennsylvaniaAllegheny County42003480102Directly adjoining
PennsylvaniaAllegheny County42003489001Directly adjoining
PennsylvaniaAllegheny County42003489002Directly adjoining
PennsylvaniaAllegheny County42003490002Directly adjoining
PennsylvaniaAllegheny County42003490003Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003490004Directly adjoining
PennsylvaniaAllegheny County42003491101Mine closure, Directly adjoining
PennsylvaniaAllegheny County42003491200Directly adjoining
PennsylvaniaAllegheny County42003494000Directly adjoining
PennsylvaniaAllegheny County42003496101Directly adjoining
PennsylvaniaAllegheny County42003496102Directly adjoining
PennsylvaniaAllegheny County42003496200Directly adjoining
PennsylvaniaAllegheny County42003525200Directly adjoining
PennsylvaniaAllegheny County42003525300Directly adjoining
PennsylvaniaAllegheny County42003526101Directly adjoining
PennsylvaniaAllegheny County42003526102Mine closure
PennsylvaniaAllegheny County42003526201Directly adjoining
PennsylvaniaAllegheny County42003526202Directly adjoining
PennsylvaniaAllegheny County42003526301Directly adjoining
PennsylvaniaAllegheny County42003564000Directly adjoining
PennsylvaniaAllegheny County42003564500Directly adjoining
PennsylvaniaArmstrong County42005950100Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950200Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaArmstrong County42005950300Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950400Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950500Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950600Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950700Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950800Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005950900Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005951000Directly adjoining
PennsylvaniaArmstrong County42005951100Directly adjoining
PennsylvaniaArmstrong County42005951200Directly adjoining
PennsylvaniaArmstrong County42005951300Directly adjoining
PennsylvaniaArmstrong County42005951400Directly adjoining
PennsylvaniaArmstrong County42005951500Directly adjoining
PennsylvaniaArmstrong County42005951600Mine closure, Directly adjoining
PennsylvaniaArmstrong County42005951700Mine closure, Directly adjoining

June 10, 2024 1574 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaBeaver County42007600601Directly adjoining
PennsylvaniaBeaver County42007600602Directly adjoining
PennsylvaniaBeaver County42007602300Directly adjoining
PennsylvaniaBeaver County42007602400Directly adjoining
PennsylvaniaBeaver County42007602500Directly adjoining
PennsylvaniaBeaver County42007602701Directly adjoining
PennsylvaniaBeaver County42007602702Directly adjoining
PennsylvaniaBeaver County42007602800Directly adjoining
PennsylvaniaBeaver County42007602900Generating unit retirement, Directly adjoining
PennsylvaniaBeaver County42007603000Directly adjoining
PennsylvaniaBeaver County42007603202Directly adjoining
PennsylvaniaBeaver County42007603300Directly adjoining
PennsylvaniaBeaver County42007603400Directly adjoining
PennsylvaniaBeaver County42007605002Directly adjoining
PennsylvaniaBeaver County42007605300Directly adjoining
PennsylvaniaBeaver County42007605500Generating unit retirement, Directly adjoining
PennsylvaniaBedford County42009960100Directly adjoining
PennsylvaniaBedford County42009960200Directly adjoining
PennsylvaniaBedford County42009960300Directly adjoining
PennsylvaniaBedford County42009960400Directly adjoining
PennsylvaniaBedford County42009960500Mine closure, Directly adjoining
PennsylvaniaBedford County42009960600Directly adjoining
PennsylvaniaBedford County42009960900Directly adjoining
PennsylvaniaBedford County42009961001Directly adjoining
PennsylvaniaBedford County42009961100Directly adjoining
PennsylvaniaBerks County42011002002Directly adjoining
PennsylvaniaBerks County42011002100Directly adjoining
PennsylvaniaBerks County42011002200Directly adjoining
PennsylvaniaBerks County42011002900Directly adjoining
PennsylvaniaBerks County42011010100Directly adjoining
PennsylvaniaBerks County42011011300Directly adjoining
PennsylvaniaBerks County42011011601Directly adjoining
PennsylvaniaBerks County42011011602Directly adjoining
PennsylvaniaBerks County42011011603Generating unit retirement
PennsylvaniaBerks County42011011702Directly adjoining
PennsylvaniaBerks County42011011704Directly adjoining
PennsylvaniaBerks County42011011705Directly adjoining
PennsylvaniaBerks County42011012003Directly adjoining
PennsylvaniaBerks County42011012200Directly adjoining
PennsylvaniaBlair County42013010101Generating unit retirement, Directly adjoining
PennsylvaniaBlair County42013010102Directly adjoining
PennsylvaniaBlair County42013010103Directly adjoining
PennsylvaniaBlair County42013010403Directly adjoining

Bulletin No. 2024–24 1575 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaBlair County42013010404Directly adjoining
PennsylvaniaBlair County42013010500Directly adjoining
PennsylvaniaBlair County42013010701Generating unit retirement
PennsylvaniaBlair County42013010702Directly adjoining
PennsylvaniaBlair County42013010800Directly adjoining
PennsylvaniaBlair County42013011001Directly adjoining
PennsylvaniaBlair County42013011300Directly adjoining
PennsylvaniaBlair County42013011600Directly adjoining
PennsylvaniaBlair County42013100700Directly adjoining
PennsylvaniaBlair County42013100800Directly adjoining
PennsylvaniaBlair County42013100900Directly adjoining
PennsylvaniaBlair County42013101700Directly adjoining
PennsylvaniaBlair County42013101800Directly adjoining
PennsylvaniaBradford County42015951200Directly adjoining
PennsylvaniaBradford County42015951300Directly adjoining
PennsylvaniaBucks County42017980000Directly adjoining
PennsylvaniaButler County42019902600Directly adjoining
PennsylvaniaButler County42019902900Directly adjoining
PennsylvaniaButler County42019903100Directly adjoining
PennsylvaniaButler County42019910100Mine closure, Directly adjoining
PennsylvaniaButler County42019910200Mine closure, Directly adjoining
PennsylvaniaButler County42019910301Directly adjoining
PennsylvaniaButler County42019910302Directly adjoining
PennsylvaniaButler County42019910600Mine closure, Directly adjoining
PennsylvaniaButler County42019910700Directly adjoining
PennsylvaniaButler County42019910800Directly adjoining
PennsylvaniaButler County42019911000Directly adjoining
PennsylvaniaButler County42019911200Mine closure
PennsylvaniaButler County42019911300Directly adjoining
PennsylvaniaButler County42019911400Directly adjoining
PennsylvaniaButler County42019911501Directly adjoining
PennsylvaniaButler County42019911600Directly adjoining
PennsylvaniaCambria County42021000100Directly adjoining
PennsylvaniaCambria County42021000300Directly adjoining
PennsylvaniaCambria County42021000500Directly adjoining
PennsylvaniaCambria County42021010100Mine closure, Directly adjoining
PennsylvaniaCambria County42021010200Directly adjoining
PennsylvaniaCambria County42021010300Mine closure, Directly adjoining
PennsylvaniaCambria County42021010500Directly adjoining
PennsylvaniaCambria County42021010700Directly adjoining
PennsylvaniaCambria County42021010801Directly adjoining
PennsylvaniaCambria County42021011100Directly adjoining
PennsylvaniaCambria County42021011400Directly adjoining

June 10, 2024 1576 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaCambria County42021011500Mine closure, Directly adjoining
PennsylvaniaCambria County42021011600Directly adjoining
PennsylvaniaCambria County42021011700Mine closure, Directly adjoining
PennsylvaniaCambria County42021011800Mine closure, Directly adjoining
PennsylvaniaCambria County42021011900Directly adjoining
PennsylvaniaCambria County42021012000Mine closure, Directly adjoining
PennsylvaniaCambria County42021012100Mine closure, Directly adjoining
PennsylvaniaCambria County42021012200Directly adjoining
PennsylvaniaCambria County42021012300Directly adjoining
PennsylvaniaCambria County42021012400Directly adjoining
PennsylvaniaCambria County42021012600Directly adjoining
PennsylvaniaCambria County42021012700Mine closure, Directly adjoining
PennsylvaniaCambria County42021012800Directly adjoining
PennsylvaniaCambria County42021012900Mine closure, Directly adjoining
PennsylvaniaCambria County42021013000Directly adjoining
PennsylvaniaCambria County42021013100Mine closure, Directly adjoining
PennsylvaniaCambria County42021013200Directly adjoining
PennsylvaniaCambria County42021013300Mine closure, Directly adjoining
PennsylvaniaCambria County42021013400Directly adjoining
PennsylvaniaCambria County42021013500Mine closure, Directly adjoining
PennsylvaniaCambria County42021013600Directly adjoining
PennsylvaniaCambria County42021013700Directly adjoining
PennsylvaniaCameron County42023960100Directly adjoining
PennsylvaniaCameron County42023960200Mine closure, Directly adjoining
PennsylvaniaCarbon County42025020102Directly adjoining
PennsylvaniaCarbon County42025020106Directly adjoining
PennsylvaniaCarbon County42025020201Directly adjoining
PennsylvaniaCarbon County42025020202Directly adjoining
PennsylvaniaCarbon County42025020301Directly adjoining
PennsylvaniaCarbon County42025020302Mine closure, Directly adjoining
PennsylvaniaCarbon County42025020400Mine closure, Directly adjoining
PennsylvaniaCarbon County42025020501Directly adjoining
PennsylvaniaCentre County42027010100Directly adjoining
PennsylvaniaCentre County42027010200Mine closure, Directly adjoining
PennsylvaniaCentre County42027010300Directly adjoining
PennsylvaniaCentre County42027010400Mine closure, Directly adjoining
PennsylvaniaCentre County42027010500Directly adjoining
PennsylvaniaCentre County42027010600Directly adjoining
PennsylvaniaCentre County42027011504Directly adjoining
PennsylvaniaCentre County42027011600Directly adjoining
PennsylvaniaCentre County42027012100Directly adjoining
PennsylvaniaCentre County42027012200Generating unit retirement
PennsylvaniaCentre County42027012300Directly adjoining

Bulletin No. 2024–24 1577 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaCentre County42027012400Directly adjoining
PennsylvaniaCentre County42027012500Directly adjoining
PennsylvaniaChester County42029300502Directly adjoining
PennsylvaniaChester County42029300600Directly adjoining
PennsylvaniaChester County42029300800Directly adjoining
PennsylvaniaChester County42029301001Directly adjoining
PennsylvaniaChester County42029301002Generating unit retirement
PennsylvaniaChester County42029301100Directly adjoining
PennsylvaniaChester County42029311000Directly adjoining
PennsylvaniaClarion County42031160101Directly adjoining
PennsylvaniaClarion County42031160103Directly adjoining
PennsylvaniaClarion County42031160104Directly adjoining
PennsylvaniaClarion County42031160201Directly adjoining
PennsylvaniaClarion County42031160202Mine closure, Directly adjoining
PennsylvaniaClarion County42031160300Mine closure, Directly adjoining
PennsylvaniaClarion County42031160400Directly adjoining
PennsylvaniaClarion County42031160500Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaClarion County42031160600Directly adjoining
PennsylvaniaClarion County42031160701Directly adjoining
PennsylvaniaClarion County42031160702Mine closure, Directly adjoining
PennsylvaniaClarion County42031160800Mine closure, Directly adjoining
PennsylvaniaClarion County42031160900Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330100Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330200Directly adjoining
PennsylvaniaClearfield County42033330300Directly adjoining
PennsylvaniaClearfield County42033330400Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330500Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330600Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330700Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330800Mine closure, Directly adjoining
PennsylvaniaClearfield County42033330900Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331000Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331100Directly adjoining
PennsylvaniaClearfield County42033331200Directly adjoining
PennsylvaniaClearfield County42033331300Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331401Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331402Directly adjoining
PennsylvaniaClearfield County42033331500Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331600Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331700Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331800Mine closure, Directly adjoining
PennsylvaniaClearfield County42033331900Mine closure, Directly adjoining
PennsylvaniaClinton County42035030100Directly adjoining

June 10, 2024 1578 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaClinton County42035030200Mine closure, Directly adjoining
PennsylvaniaClinton County42035030300Directly adjoining
PennsylvaniaClinton County42035030500Directly adjoining
PennsylvaniaClinton County42035030800Directly adjoining
PennsylvaniaColumbia County42037050200Directly adjoining
PennsylvaniaColumbia County42037050300Directly adjoining
PennsylvaniaColumbia County42037051300Directly adjoining
PennsylvaniaColumbia County42037051400Directly adjoining
PennsylvaniaColumbia County42037051500Mine closure, Directly adjoining
PennsylvaniaDauphin County42043024700Directly adjoining
PennsylvaniaDauphin County42043024801Directly adjoining
PennsylvaniaDauphin County42043024900Mine closure, Directly adjoining
PennsylvaniaDauphin County42043025000Mine closure, Directly adjoining
PennsylvaniaDauphin County42043025100Mine closure, Directly adjoining
PennsylvaniaDauphin County42043025200Directly adjoining
PennsylvaniaDauphin County42043025300Directly adjoining
PennsylvaniaDelaware County42045404102Directly adjoining
PennsylvaniaDelaware County42045404103Directly adjoining
PennsylvaniaDelaware County42045404300Generating unit retirement
PennsylvaniaDelaware County42045404800Directly adjoining
PennsylvaniaDelaware County42045406500Directly adjoining
PennsylvaniaDelaware County42045406600Directly adjoining
PennsylvaniaDelaware County42045410700Directly adjoining
PennsylvaniaElk County42047950100Directly adjoining
PennsylvaniaElk County42047950200Directly adjoining
PennsylvaniaElk County42047950900Mine closure, Directly adjoining
PennsylvaniaElk County42047951000Mine closure, Directly adjoining
PennsylvaniaElk County42047951100Directly adjoining
PennsylvaniaElk County42047951200Directly adjoining
PennsylvaniaElk County42047951300Directly adjoining
PennsylvaniaFayette County42051260100Directly adjoining
PennsylvaniaFayette County42051260200Mine closure, Directly adjoining
PennsylvaniaFayette County42051260300Directly adjoining
PennsylvaniaFayette County42051260402Directly adjoining
PennsylvaniaFayette County42051260500Mine closure, Directly adjoining
PennsylvaniaFayette County42051260600Directly adjoining
PennsylvaniaFayette County42051260900Directly adjoining
PennsylvaniaFayette County42051261000Mine closure, Directly adjoining
PennsylvaniaFayette County42051261100Directly adjoining
PennsylvaniaFayette County42051261300Directly adjoining
PennsylvaniaFayette County42051261401Directly adjoining
PennsylvaniaFayette County42051261402Directly adjoining
PennsylvaniaFayette County42051261500Directly adjoining

Bulletin No. 2024–24 1579 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaFayette County42051261600Directly adjoining
PennsylvaniaFayette County42051261700Directly adjoining
PennsylvaniaFayette County42051261900Directly adjoining
PennsylvaniaFayette County42051262000Mine closure, Directly adjoining
PennsylvaniaFayette County42051262100Directly adjoining
PennsylvaniaFayette County42051262200Mine closure, Directly adjoining
PennsylvaniaFayette County42051262300Directly adjoining
PennsylvaniaFayette County42051262400Directly adjoining
PennsylvaniaFayette County42051262500Directly adjoining
PennsylvaniaFayette County42051262600Directly adjoining
PennsylvaniaFayette County42051262701Mine closure, Directly adjoining
PennsylvaniaFayette County42051262702Mine closure, Directly adjoining
PennsylvaniaFayette County42051262800Mine closure, Directly adjoining
PennsylvaniaFayette County42051262900Mine closure, Directly adjoining
PennsylvaniaFayette County42051263000Directly adjoining
PennsylvaniaFayette County42051263100Mine closure, Directly adjoining
PennsylvaniaFayette County42051263200Mine closure, Directly adjoining
PennsylvaniaFayette County42051263300Directly adjoining
PennsylvaniaForest County42053530100Directly adjoining
PennsylvaniaFulton County42057960200Directly adjoining
PennsylvaniaGreene County42059970101Directly adjoining
PennsylvaniaGreene County42059970102Directly adjoining
PennsylvaniaGreene County42059970200Mine closure, Directly adjoining
PennsylvaniaGreene County42059970300Mine closure, Directly adjoining
PennsylvaniaGreene County42059970400Directly adjoining
PennsylvaniaGreene County42059970501Directly adjoining
PennsylvaniaGreene County42059970502Mine closure, Directly adjoining
PennsylvaniaGreene County42059970600Directly adjoining
PennsylvaniaGreene County42059970700Mine closure, Directly adjoining
PennsylvaniaGreene County42059970800Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaHuntingdon County42061950200Directly adjoining
PennsylvaniaHuntingdon County42061950600Directly adjoining
PennsylvaniaHuntingdon County42061950800Directly adjoining
PennsylvaniaHuntingdon County42061951200Directly adjoining
PennsylvaniaHuntingdon County42061951300Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960100Directly adjoining
PennsylvaniaIndiana County42063960200Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960300Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960400Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960500Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960600Mine closure, Directly adjoining
PennsylvaniaIndiana County42063960700Directly adjoining
PennsylvaniaIndiana County42063960800Mine closure, Directly adjoining

June 10, 2024 1580 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaIndiana County42063960900Directly adjoining
PennsylvaniaIndiana County42063961000Mine closure
PennsylvaniaIndiana County42063961102Directly adjoining
PennsylvaniaIndiana County42063961103Directly adjoining
PennsylvaniaIndiana County42063961104Directly adjoining
PennsylvaniaIndiana County42063961200Directly adjoining
PennsylvaniaIndiana County42063961300Mine closure, Directly adjoining
PennsylvaniaIndiana County42063961400Mine closure, Directly adjoining
PennsylvaniaIndiana County42063961500Mine closure, Directly adjoining
PennsylvaniaIndiana County42063961600Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaIndiana County42063961700Directly adjoining
PennsylvaniaIndiana County42063961800Mine closure, Directly adjoining
PennsylvaniaIndiana County42063961900Mine closure, Directly adjoining
PennsylvaniaIndiana County42063962000Mine closure, Directly adjoining
PennsylvaniaIndiana County42063962100Directly adjoining
PennsylvaniaIndiana County42063962200Directly adjoining
PennsylvaniaJefferson County42065950100Directly adjoining
PennsylvaniaJefferson County42065950200Mine closure, Directly adjoining
PennsylvaniaJefferson County42065950300Mine closure, Directly adjoining
PennsylvaniaJefferson County42065950400Directly adjoining
PennsylvaniaJefferson County42065950500Directly adjoining
PennsylvaniaJefferson County42065950600Mine closure, Directly adjoining
PennsylvaniaJefferson County42065950700Mine closure
PennsylvaniaJefferson County42065950800Directly adjoining
PennsylvaniaJefferson County42065950900Mine closure, Directly adjoining
PennsylvaniaJefferson County42065951000Mine closure, Directly adjoining
PennsylvaniaJefferson County42065951100Directly adjoining
PennsylvaniaJuniata County42067070400Directly adjoining
PennsylvaniaLackawanna County42069101800Directly adjoining
PennsylvaniaLackawanna County42069101900Directly adjoining
PennsylvaniaLackawanna County42069102100Directly adjoining
PennsylvaniaLackawanna County42069102200Directly adjoining
PennsylvaniaLackawanna County42069102300Directly adjoining
PennsylvaniaLackawanna County42069103000Directly adjoining
PennsylvaniaLackawanna County42069103100Directly adjoining
PennsylvaniaLackawanna County42069111200Directly adjoining
PennsylvaniaLackawanna County42069111300Directly adjoining
PennsylvaniaLackawanna County42069111400Mine closure
PennsylvaniaLackawanna County42069111500Directly adjoining
PennsylvaniaLackawanna County42069111700Directly adjoining
PennsylvaniaLackawanna County42069111801Directly adjoining
PennsylvaniaLackawanna County42069111802Directly adjoining
PennsylvaniaLackawanna County42069112400Directly adjoining

Bulletin No. 2024–24 1581 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaLackawanna County42069112500Mine closure
PennsylvaniaLackawanna County42069112600Directly adjoining
PennsylvaniaLackawanna County42069112700Directly adjoining
PennsylvaniaLackawanna County42069112800Directly adjoining
PennsylvaniaLackawanna County42069112901Directly adjoining
PennsylvaniaLawrence County42073001000Directly adjoining
PennsylvaniaLawrence County42073010201Directly adjoining
PennsylvaniaLawrence County42073010400Directly adjoining
PennsylvaniaLawrence County42073010500Mine closure, Directly adjoining
PennsylvaniaLawrence County42073010600Directly adjoining
PennsylvaniaLawrence County42073011100Directly adjoining
PennsylvaniaLawrence County42073011200Directly adjoining
PennsylvaniaLawrence County42073011300Mine closure, Directly adjoining
PennsylvaniaLawrence County42073011400Directly adjoining
PennsylvaniaLawrence County42073011500Directly adjoining
PennsylvaniaLebanon County42075002000Directly adjoining
PennsylvaniaLebanon County42075002100Directly adjoining
PennsylvaniaLuzerne County42079210100Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079210200Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079210300Directly adjoining
PennsylvaniaLuzerne County42079210400Directly adjoining
PennsylvaniaLuzerne County42079210500Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079210600Directly adjoining
PennsylvaniaLuzerne County42079210700Directly adjoining
PennsylvaniaLuzerne County42079210800Directly adjoining
PennsylvaniaLuzerne County42079211101Directly adjoining
PennsylvaniaLuzerne County42079211102Directly adjoining
PennsylvaniaLuzerne County42079211302Directly adjoining
PennsylvaniaLuzerne County42079211701Directly adjoining
PennsylvaniaLuzerne County42079211702Mine closure
PennsylvaniaLuzerne County42079211900Directly adjoining
PennsylvaniaLuzerne County42079213900Directly adjoining
PennsylvaniaLuzerne County42079215400Directly adjoining
PennsylvaniaLuzerne County42079215600Directly adjoining
PennsylvaniaLuzerne County42079215701Generating unit retirement
PennsylvaniaLuzerne County42079215702Directly adjoining
PennsylvaniaLuzerne County42079215800Directly adjoining
PennsylvaniaLuzerne County42079216200Directly adjoining
PennsylvaniaLuzerne County42079216400Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079216501Directly adjoining
PennsylvaniaLuzerne County42079216502Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079216601Directly adjoining
PennsylvaniaLuzerne County42079216602Directly adjoining

June 10, 2024 1582 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaLuzerne County42079216700Directly adjoining
PennsylvaniaLuzerne County42079216800Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079216900Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079217001Directly adjoining
PennsylvaniaLuzerne County42079217002Mine closure, Directly adjoining
PennsylvaniaLuzerne County42079217100Directly adjoining
PennsylvaniaLuzerne County42079217200Directly adjoining
PennsylvaniaLuzerne County42079217300Directly adjoining
PennsylvaniaLuzerne County42079217700Directly adjoining
PennsylvaniaLuzerne County42079217800Directly adjoining
PennsylvaniaLuzerne County42079217900Directly adjoining
PennsylvaniaLycoming County42081010600Directly adjoining
PennsylvaniaLycoming County42081010800Directly adjoining
PennsylvaniaMcKean County42083420700Directly adjoining
PennsylvaniaMcKean County42083420800Directly adjoining
PennsylvaniaMcKean County42083420900Directly adjoining
PennsylvaniaMercer County42085031200Directly adjoining
PennsylvaniaMercer County42085031300Directly adjoining
PennsylvaniaMercer County42085032300Directly adjoining
PennsylvaniaMercer County42085032401Directly adjoining
PennsylvaniaMercer County42085032403Directly adjoining
PennsylvaniaMercer County42085032502Directly adjoining
PennsylvaniaMercer County42085032503Directly adjoining
PennsylvaniaMercer County42085032504Mine closure
PennsylvaniaMercer County42085032505Directly adjoining
PennsylvaniaMercer County42085032601Mine closure
PennsylvaniaMercer County42085032602Directly adjoining
PennsylvaniaMercer County42085032702Directly adjoining
PennsylvaniaMercer County42085033100Directly adjoining
PennsylvaniaMontgomery County42091206105Directly adjoining
PennsylvaniaMontgomery County42091206106Directly adjoining
PennsylvaniaMontour County42093050100Generating unit retirement
PennsylvaniaMontour County42093050400Directly adjoining
PennsylvaniaNorthampton County42095015300Directly adjoining
PennsylvaniaNorthampton County42095015400Directly adjoining
PennsylvaniaNorthampton County42095018200Generating unit retirement
PennsylvaniaNorthampton County42095018300Directly adjoining
PennsylvaniaNorthumberland County42097080100Directly adjoining
PennsylvaniaNorthumberland County42097080400Directly adjoining
PennsylvaniaNorthumberland County42097080500Directly adjoining
PennsylvaniaNorthumberland County42097080700Directly adjoining
PennsylvaniaNorthumberland County42097080800Directly adjoining
PennsylvaniaNorthumberland County42097080900Mine closure, Directly adjoining

Bulletin No. 2024–24 1583 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaNorthumberland County42097081000Directly adjoining
PennsylvaniaNorthumberland County42097081100Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097081200Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097081300Directly adjoining
PennsylvaniaNorthumberland County42097081400Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097081500Directly adjoining
PennsylvaniaNorthumberland County42097081600Directly adjoining
PennsylvaniaNorthumberland County42097081700Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097081800Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097081900Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097082000Directly adjoining
PennsylvaniaNorthumberland County42097082100Directly adjoining
PennsylvaniaNorthumberland County42097082200Directly adjoining
PennsylvaniaNorthumberland County42097082300Mine closure, Directly adjoining
PennsylvaniaNorthumberland County42097082400Directly adjoining
PennsylvaniaPerry County42099030100Directly adjoining
PennsylvaniaPotter County42105950402Directly adjoining
PennsylvaniaSchuylkill County42107000100Directly adjoining
PennsylvaniaSchuylkill County42107000200Directly adjoining
PennsylvaniaSchuylkill County42107000300Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaSchuylkill County42107000400Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaSchuylkill County42107000500Directly adjoining
PennsylvaniaSchuylkill County42107000601Directly adjoining
PennsylvaniaSchuylkill County42107000602Directly adjoining
PennsylvaniaSchuylkill County42107000700Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107000800Directly adjoining
PennsylvaniaSchuylkill County42107000901Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107000902Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001000Directly adjoining
PennsylvaniaSchuylkill County42107001100Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001200Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001300Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001400Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001500Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001600Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107001700Directly adjoining
PennsylvaniaSchuylkill County42107001800Directly adjoining
PennsylvaniaSchuylkill County42107001902Directly adjoining
PennsylvaniaSchuylkill County42107002000Directly adjoining
PennsylvaniaSchuylkill County42107002100Directly adjoining
PennsylvaniaSchuylkill County42107002200Directly adjoining
PennsylvaniaSchuylkill County42107002300Directly adjoining

June 10, 2024 1584 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaSchuylkill County42107002400Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107002500Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107002600Directly adjoining
PennsylvaniaSchuylkill County42107002700Directly adjoining
PennsylvaniaSchuylkill County42107002800Directly adjoining
PennsylvaniaSchuylkill County42107002900Directly adjoining
PennsylvaniaSchuylkill County42107003000Directly adjoining
PennsylvaniaSchuylkill County42107003200Directly adjoining
PennsylvaniaSchuylkill County42107003400Directly adjoining
PennsylvaniaSchuylkill County42107003500Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107003600Directly adjoining
PennsylvaniaSchuylkill County42107003700Mine closure, Directly adjoining
PennsylvaniaSchuylkill County42107003800Directly adjoining
PennsylvaniaSchuylkill County42107003900Mine closure, Directly adjoining
PennsylvaniaSnyder County42109070100Generating unit retirement, Directly adjoining
PennsylvaniaSnyder County42109070200Directly adjoining
PennsylvaniaSnyder County42109070600Directly adjoining
PennsylvaniaSnyder County42109070701Directly adjoining
PennsylvaniaSomerset County42111020101Directly adjoining
PennsylvaniaSomerset County42111020102Directly adjoining
PennsylvaniaSomerset County42111020200Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020300Directly adjoining
PennsylvaniaSomerset County42111020400Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020500Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020601Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020602Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020700Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020801Directly adjoining
PennsylvaniaSomerset County42111020802Mine closure, Directly adjoining
PennsylvaniaSomerset County42111020900Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021000Directly adjoining
PennsylvaniaSomerset County42111021100Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021200Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021300Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021400Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021500Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021600Directly adjoining
PennsylvaniaSomerset County42111021700Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021800Mine closure, Directly adjoining
PennsylvaniaSomerset County42111021902Directly adjoining
PennsylvaniaSomerset County42111021903Directly adjoining
PennsylvaniaSomerset County42111021904Directly adjoining
PennsylvaniaSullivan County42113960101Directly adjoining

Bulletin No. 2024–24 1585 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaSullivan County42113960102Mine closure
PennsylvaniaSullivan County42113960201Directly adjoining
PennsylvaniaUnion County42119090400Directly adjoining
PennsylvaniaVenango County42121200201Directly adjoining
PennsylvaniaVenango County42121200202Directly adjoining
PennsylvaniaVenango County42121201100Directly adjoining
PennsylvaniaVenango County42121201200Directly adjoining
PennsylvaniaVenango County42121201300Directly adjoining
PennsylvaniaVenango County42121201400Directly adjoining
PennsylvaniaVenango County42121201500Mine closure, Directly adjoining
PennsylvaniaWashington County42125711000Mine closure, Directly adjoining
PennsylvaniaWashington County42125712700Directly adjoining
PennsylvaniaWashington County42125713700Mine closure, Directly adjoining
PennsylvaniaWashington County42125714000Mine closure, Directly adjoining
PennsylvaniaWashington County42125715700Directly adjoining
PennsylvaniaWashington County42125721000Mine closure, Directly adjoining
PennsylvaniaWashington County42125722700Directly adjoining
PennsylvaniaWashington County42125731000Directly adjoining
PennsylvaniaWashington County42125741100Directly adjoining
PennsylvaniaWashington County42125745200Directly adjoining
PennsylvaniaWashington County42125746301Directly adjoining
PennsylvaniaWashington County42125746302Directly adjoining
PennsylvaniaWashington County42125751100Directly adjoining
PennsylvaniaWashington County42125755200Directly adjoining
PennsylvaniaWashington County42125755700Directly adjoining
PennsylvaniaWashington County42125761000Mine closure, Directly adjoining
PennsylvaniaWashington County42125762000Directly adjoining
PennsylvaniaWashington County42125763700Directly adjoining
PennsylvaniaWashington County42125764000Directly adjoining
PennsylvaniaWashington County42125771100Mine closure, Generating unit retirement,
Directly adjoining
PennsylvaniaWashington County42125771200Mine closure, Directly adjoining
PennsylvaniaWashington County42125772700Mine closure, Directly adjoining
PennsylvaniaWashington County42125773100Directly adjoining
PennsylvaniaWashington County42125773200Directly adjoining
PennsylvaniaWashington County42125774700Directly adjoining
PennsylvaniaWashington County42125781700Directly adjoining
PennsylvaniaWashington County42125795700Mine closure, Directly adjoining
PennsylvaniaWashington County42125795900Directly adjoining
PennsylvaniaWashington County42125796000Directly adjoining
PennsylvaniaWestmoreland County42129801200Directly adjoining
PennsylvaniaWestmoreland County42129801600Directly adjoining
PennsylvaniaWestmoreland County42129801701Directly adjoining
PennsylvaniaWestmoreland County42129801702Directly adjoining

June 10, 2024 1586 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaWestmoreland County42129801703Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129801801Directly adjoining
PennsylvaniaWestmoreland County42129801802Directly adjoining
PennsylvaniaWestmoreland County42129801901Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129801902Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129802001Directly adjoining
PennsylvaniaWestmoreland County42129802003Directly adjoining
PennsylvaniaWestmoreland County42129802004Directly adjoining
PennsylvaniaWestmoreland County42129802101Directly adjoining
PennsylvaniaWestmoreland County42129802400Directly adjoining
PennsylvaniaWestmoreland County42129803302Directly adjoining
PennsylvaniaWestmoreland County42129803400Directly adjoining
PennsylvaniaWestmoreland County42129803501Directly adjoining
PennsylvaniaWestmoreland County42129803800Directly adjoining
PennsylvaniaWestmoreland County42129804400Directly adjoining
PennsylvaniaWestmoreland County42129804501Mine closure
PennsylvaniaWestmoreland County42129804503Directly adjoining
PennsylvaniaWestmoreland County42129804504Directly adjoining
PennsylvaniaWestmoreland County42129804600Directly adjoining
PennsylvaniaWestmoreland County42129804701Directly adjoining
PennsylvaniaWestmoreland County42129804705Directly adjoining
PennsylvaniaWestmoreland County42129804706Directly adjoining
PennsylvaniaWestmoreland County42129804901Directly adjoining
PennsylvaniaWestmoreland County42129804902Directly adjoining
PennsylvaniaWestmoreland County42129805000Directly adjoining
PennsylvaniaWestmoreland County42129805100Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129805800Directly adjoining
PennsylvaniaWestmoreland County42129805901Directly adjoining
PennsylvaniaWestmoreland County42129805903Directly adjoining
PennsylvaniaWestmoreland County42129805904Directly adjoining
PennsylvaniaWestmoreland County42129806000Directly adjoining
PennsylvaniaWestmoreland County42129806100Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129806200Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129806500Directly adjoining
PennsylvaniaWestmoreland County42129806600Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129806700Directly adjoining
PennsylvaniaWestmoreland County42129806900Directly adjoining
PennsylvaniaWestmoreland County42129807000Directly adjoining
PennsylvaniaWestmoreland County42129807100Directly adjoining
PennsylvaniaWestmoreland County42129807201Directly adjoining
PennsylvaniaWestmoreland County42129807202Directly adjoining
PennsylvaniaWestmoreland County42129807300Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129807401Mine closure, Directly adjoining

Bulletin No. 2024–24 1587 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
PennsylvaniaWestmoreland County42129807403Directly adjoining
PennsylvaniaWestmoreland County42129807404Directly adjoining
PennsylvaniaWestmoreland County42129807500Directly adjoining
PennsylvaniaWestmoreland County42129807600Directly adjoining
PennsylvaniaWestmoreland County42129807700Directly adjoining
PennsylvaniaWestmoreland County42129807800Directly adjoining
PennsylvaniaWestmoreland County42129807901Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129807902Directly adjoining
PennsylvaniaWestmoreland County42129808100Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129808200Directly adjoining
PennsylvaniaWestmoreland County42129808300Mine closure, Directly adjoining
PennsylvaniaWestmoreland County42129808401Directly adjoining
PennsylvaniaWestmoreland County42129808402Directly adjoining
PennsylvaniaWestmoreland County42129808600Directly adjoining
PennsylvaniaYork County42133020522Directly adjoining
PennsylvaniaYork County42133020523Generating unit retirement
PennsylvaniaYork County42133020524Directly adjoining
PennsylvaniaYork County42133021712Directly adjoining
Rhode IslandNewport County44005990000Directly adjoining
South CarolinaAiken County45003021902Directly adjoining
South CarolinaAiken County45003022001Directly adjoining
South CarolinaAiken County45003022004Directly adjoining
South CarolinaAiken County45003022100Directly adjoining
South CarolinaAiken County45003980100Generating unit retirement
South CarolinaAnderson County45007010403Directly adjoining
South CarolinaAnderson County45007010405Directly adjoining
South CarolinaAnderson County45007010406Generating unit retirement
South CarolinaAnderson County45007011203Directly adjoining
South CarolinaAnderson County45007011204Directly adjoining
South CarolinaAnderson County45007011302Directly adjoining
South CarolinaAnderson County45007011401Directly adjoining
South CarolinaAnderson County45007011402Directly adjoining
South CarolinaBarnwell County45011970102Directly adjoining
South CarolinaBarnwell County45011980100Directly adjoining
South CarolinaBerkeley County45015020101Directly adjoining
South CarolinaBerkeley County45015020201Directly adjoining
South CarolinaBerkeley County45015020202Directly adjoining
South CarolinaBerkeley County45015020301Directly adjoining
South CarolinaBerkeley County45015020303Directly adjoining
South CarolinaBerkeley County45015020304Generating unit retirement
South CarolinaBerkeley County45015020401Directly adjoining
South CarolinaBerkeley County45015020503Directly adjoining
South CarolinaBerkeley County45015020504Directly adjoining

June 10, 2024 1588 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
South CarolinaBerkeley County45015020506Directly adjoining
South CarolinaCherokee County45021970101Directly adjoining
South CarolinaCherokee County45021970203Directly adjoining
South CarolinaCherokee County45021970204Directly adjoining
South CarolinaCherokee County45021970401Directly adjoining
South CarolinaChesterfield County45025950701Directly adjoining
South CarolinaChesterfield County45025950800Directly adjoining
South CarolinaColleton County45029970100Directly adjoining
South CarolinaColleton County45029970200Directly adjoining
South CarolinaColleton County45029970301Directly adjoining
South CarolinaColleton County45029970401Generating unit retirement
South CarolinaColleton County45029970402Directly adjoining
South CarolinaColleton County45029970502Directly adjoining
South CarolinaColleton County45029970601Directly adjoining
South CarolinaColleton County45029970702Directly adjoining
South CarolinaDarlington County45031010100Directly adjoining
South CarolinaDarlington County45031010200Generating unit retirement
South CarolinaDarlington County45031010300Directly adjoining
South CarolinaDarlington County45031010400Directly adjoining
South CarolinaDarlington County45031010600Directly adjoining
South CarolinaDarlington County45031010902Directly adjoining
South CarolinaDorchester County45035010100Directly adjoining
South CarolinaGreenville County45045003202Directly adjoining
South CarolinaGreenville County45045003301Directly adjoining
South CarolinaHorry County45051060101Directly adjoining
South CarolinaHorry County45051060403Directly adjoining
South CarolinaHorry County45051070200Directly adjoining
South CarolinaHorry County45051070300Generating unit retirement
South CarolinaHorry County45051070400Directly adjoining
South CarolinaHorry County45051070500Directly adjoining
South CarolinaHorry County45051070701Directly adjoining
South CarolinaHorry County45051070702Directly adjoining
South CarolinaJasper County45053950100Directly adjoining
South CarolinaJasper County45053950301Directly adjoining
South CarolinaJasper County45053950302Directly adjoining
South DakotaCuster County46033965100Directly adjoining
South DakotaLawrence County46081966601Directly adjoining
South DakotaMeade County46093020200Directly adjoining
South DakotaMeade County46093020302Directly adjoining
South DakotaMeade County46093020303Directly adjoining
South DakotaMeade County46093020500Directly adjoining
South DakotaPennington County46103010202Directly adjoining
South DakotaPennington County46103010300Directly adjoining

Bulletin No. 2024–24 1589 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
South DakotaPennington County46103010400Directly adjoining
South DakotaPennington County46103010906Directly adjoining
South DakotaPennington County46103010908Directly adjoining
South DakotaPennington County46103011200Directly adjoining
South DakotaPennington County46103011300Directly adjoining
South DakotaPennington County46103011400Generating unit retirement
South DakotaPennington County46103011700Directly adjoining
South DakotaPennington County46103011800Directly adjoining
TennesseeAnderson County47001020201Directly adjoining
TennesseeAnderson County47001020400Directly adjoining
TennesseeAnderson County47001020700Mine closure, Directly adjoining
TennesseeAnderson County47001020800Directly adjoining
TennesseeAnderson County47001020901Directly adjoining
TennesseeAnderson County47001021001Mine closure, Directly adjoining
TennesseeAnderson County47001021002Directly adjoining
TennesseeAnderson County47001021100Directly adjoining
TennesseeAnderson County47001021201Directly adjoining
TennesseeAnderson County47001021303Directly adjoining
TennesseeAnderson County47001021304Generating unit retirement
TennesseeBenton County47005963100Directly adjoining
TennesseeBenton County47005963200Directly adjoining
TennesseeBenton County47005963400Directly adjoining
TennesseeBledsoe County47007953000Directly adjoining
TennesseeBledsoe County47007953101Directly adjoining
TennesseeBledsoe County47007953102Directly adjoining
TennesseeBledsoe County47007953200Mine closure, Directly adjoining
TennesseeCampbell County47013950100Mine closure, Directly adjoining
TennesseeCampbell County47013950200Mine closure, Directly adjoining
TennesseeCampbell County47013950300Mine closure, Directly adjoining
TennesseeCampbell County47013950400Mine closure, Directly adjoining
TennesseeCampbell County47013950500Directly adjoining
TennesseeCampbell County47013950601Directly adjoining
TennesseeCampbell County47013950701Directly adjoining
TennesseeCampbell County47013950800Directly adjoining
TennesseeCampbell County47013951100Directly adjoining
TennesseeClaiborne County47025970200Directly adjoining
TennesseeClaiborne County47025970300Directly adjoining
TennesseeClaiborne County47025970400Mine closure, Directly adjoining
TennesseeClaiborne County47025970500Mine closure, Directly adjoining
TennesseeClaiborne County47025970600Directly adjoining
TennesseeCumberland County47035970101Directly adjoining
TennesseeCumberland County47035970104Directly adjoining
TennesseeCumberland County47035970201Directly adjoining

June 10, 2024 1590 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
TennesseeCumberland County47035970603Directly adjoining
TennesseeCumberland County47035970702Directly adjoining
TennesseeCumberland County47035970800Mine closure
TennesseeDavidson County47037014400Directly adjoining
TennesseeDavidson County47037016400Directly adjoining
TennesseeDavidson County47037016500Generating unit retirement
TennesseeDavidson County47037016600Directly adjoining
TennesseeDavidson County47037016800Directly adjoining
TennesseeDavidson County47037019501Directly adjoining
TennesseeFentress County47049965000Directly adjoining
TennesseeFentress County47049965100Directly adjoining
TennesseeFentress County47049965201Mine closure
TennesseeFentress County47049965202Directly adjoining
TennesseeFentress County47049965300Directly adjoining
TennesseeFranklin County47051960600Directly adjoining
TennesseeFranklin County47051960700Directly adjoining
TennesseeGreene County47059091200Directly adjoining
TennesseeGreene County47059091300Directly adjoining
TennesseeGreene County47059091400Directly adjoining
TennesseeGrundy County47061955000Directly adjoining
TennesseeGrundy County47061955200Mine closure, Directly adjoining
TennesseeGrundy County47061955300Directly adjoining
TennesseeHamblen County47063101000Directly adjoining
TennesseeHawkins County47073050100Directly adjoining
TennesseeHawkins County47073050200Directly adjoining
TennesseeHawkins County47073050301Directly adjoining
TennesseeHawkins County47073050302Directly adjoining
TennesseeHawkins County47073050400Directly adjoining
TennesseeHawkins County47073050700Directly adjoining
TennesseeHawkins County47073050800Generating unit retirement
TennesseeHawkins County47073050900Directly adjoining
TennesseeHumphreys County47085130200Directly adjoining
TennesseeHumphreys County47085130300Directly adjoining
TennesseeHumphreys County47085130400Directly adjoining
TennesseeHumphreys County47085130500Generating unit retirement
TennesseeKnox County47093005908Directly adjoining
TennesseeKnox County47093006003Directly adjoining
TennesseeKnox County47093006103Directly adjoining
TennesseeMarion County47115050102Directly adjoining
TennesseeMarion County47115050203Directly adjoining
TennesseeMarion County47115050302Directly adjoining
TennesseeMeigs County47121960100Directly adjoining
TennesseeMeigs County47121960200Directly adjoining

Bulletin No. 2024–24 1591 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
TennesseeMorgan County47129110100Directly adjoining
TennesseeMorgan County47129110200Directly adjoining
TennesseeMorgan County47129110300Directly adjoining
TennesseeMorgan County47129110400Mine closure, Directly adjoining
TennesseeMorgan County47129110500Directly adjoining
TennesseeRhea County47143975000Directly adjoining
TennesseeRhea County47143975100Generating unit retirement
TennesseeRhea County47143975200Directly adjoining
TennesseeRoane County47145030500Directly adjoining
TennesseeRoane County47145030802Directly adjoining
TennesseeRoane County47145030900Directly adjoining
TennesseeScott County47151975000Directly adjoining
TennesseeScott County47151975101Directly adjoining
TennesseeScott County47151975102Directly adjoining
TennesseeScott County47151975200Directly adjoining
TennesseeScott County47151975300Mine closure, Directly adjoining
TennesseeScott County47151975400Directly adjoining
TennesseeSequatchie County47153060102Mine closure, Directly adjoining
TennesseeSequatchie County47153060103Directly adjoining
TennesseeSequatchie County47153060104Directly adjoining
TennesseeShelby County47157004300Directly adjoining
TennesseeShelby County47157005300Directly adjoining
TennesseeShelby County47157011700Directly adjoining
TennesseeShelby County47157022210Directly adjoining
TennesseeShelby County47157022220Directly adjoining
TennesseeShelby County47157980200Generating unit retirement, Directly adjoining
TennesseeShelby County47157980300Generating unit retirement, Directly adjoining
TennesseeUnion County47173040300Directly adjoining
TennesseeVan Buren County47175925000Directly adjoining
TennesseeWarren County47177930900Directly adjoining
TexasAnderson County48001950402Directly adjoining
TexasAnderson County48001951100Directly adjoining
TexasArcher County48009020200Directly adjoining
TexasBastrop County48021950102Directly adjoining
TexasBaylor County48023950302Directly adjoining
TexasBexar County48029131401Directly adjoining
TexasBexar County48029131402Directly adjoining
TexasBexar County48029131801Directly adjoining
TexasBexar County48029131802Directly adjoining
TexasBexar County48029141700Directly adjoining
TexasBexar County48029141800Directly adjoining
TexasBexar County48029141900Generating unit retirement
TexasBrazos County48041000106Directly adjoining

June 10, 2024 1592 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
TexasBrazos County48041002010Directly adjoining
TexasBrazos County48041002016Directly adjoining
TexasBurleson County48051970202Directly adjoining
TexasCamp County48063950101Directly adjoining
TexasCamp County48063950102Directly adjoining
TexasDimmit County48127950202Directly adjoining
TexasDimmit County48127950400Directly adjoining
TexasDuval County48131950200Directly adjoining
TexasDuval County48131950500Directly adjoining
TexasFalls County48145000800Directly adjoining
TexasFoard County48155950100Directly adjoining
TexasFranklin County48159950101Directly adjoining
TexasFranklin County48159950102Directly adjoining
TexasFranklin County48159950300Directly adjoining
TexasFreestone County48161000101Directly adjoining
TexasFreestone County48161000102Mine closure, Generating unit retirement
TexasFreestone County48161000200Directly adjoining
TexasFreestone County48161000300Directly adjoining
TexasFreestone County48161000600Directly adjoining
TexasFreestone County48161000900Directly adjoining
TexasGregg County48183000201Directly adjoining
TexasGregg County48183001100Directly adjoining
TexasGregg County48183001400Directly adjoining
TexasGregg County48183001500Directly adjoining
TexasGregg County48183010501Directly adjoining
TexasGregg County48183010502Directly adjoining
TexasGrimes County48185180202Directly adjoining
TexasGrimes County48185180302Directly adjoining
TexasGrimes County48185180303Mine closure, Directly adjoining
TexasGrimes County48185180304Generating unit retirement, Directly adjoining
TexasHardeman County48197950100Directly adjoining
TexasHarrison County48203020103Mine closure, Directly adjoining
TexasHarrison County48203020104Directly adjoining
TexasHarrison County48203020106Directly adjoining
TexasHarrison County48203020301Directly adjoining
TexasHarrison County48203020401Directly adjoining
TexasHarrison County48203020402Generating unit retirement, Directly adjoining
TexasHarrison County48203020501Directly adjoining
TexasHarrison County48203020502Directly adjoining
TexasHarrison County48203020603Directly adjoining
TexasHarrison County48203020604Mine closure, Generating unit retirement,
Directly adjoining
TexasHarrison County48203020605Directly adjoining
TexasHarrison County48203020606Directly adjoining

Bulletin No. 2024–24 1593 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
TexasHenderson County48213950902Directly adjoining
TexasHopkins County48223950200Directly adjoining
TexasHopkins County48223950301Directly adjoining
TexasHopkins County48223950302Mine closure
TexasHopkins County48223950401Directly adjoining
TexasHopkins County48223950402Directly adjoining
TexasHopkins County48223950500Directly adjoining
TexasHopkins County48223950600Directly adjoining
TexasHopkins County48223950700Directly adjoining
TexasHopkins County48223950800Directly adjoining
TexasKinney County48271950100Directly adjoining
TexasLa Salle County48283950302Directly adjoining
TexasLee County48287000100Mine closure, Directly adjoining
TexasLee County48287000200Directly adjoining
TexasLimestone County48293970800Directly adjoining
TexasMcMullen County48311950100Directly adjoining
TexasMadison County48313000200Directly adjoining
TexasMadison County48313000300Directly adjoining
TexasMaverick County48323950207Directly adjoining
TexasMaverick County48323950500Directly adjoining
TexasMaverick County48323950701Directly adjoining
TexasMaverick County48323950702Mine closure
TexasMilam County48331950100Directly adjoining
TexasMilam County48331950300Directly adjoining
TexasMilam County48331950800Mine closure, Generating unit retirement,
Directly adjoining
TexasMorris County48343950100Directly adjoining
TexasMorris County48343950200Directly adjoining
TexasNavarro County48349970600Directly adjoining
TexasPanola County48365950100Directly adjoining
TexasPanola County48365950200Mine closure, Directly adjoining
TexasPanola County48365950300Directly adjoining
TexasPanola County48365950500Directly adjoining
TexasRobertson County48395960100Mine closure
TexasRobertson County48395960200Directly adjoining
TexasRobertson County48395960300Directly adjoining
TexasRusk County48401950101Directly adjoining
TexasRusk County48401950102Mine closure, Directly adjoining
TexasRusk County48401950200Directly adjoining
TexasRusk County48401950501Mine closure, Directly adjoining
TexasRusk County48401950502Directly adjoining
TexasRusk County48401950600Directly adjoining
TexasRusk County48401950700Directly adjoining
TexasRusk County48401950800Directly adjoining

June 10, 2024 1594 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
TexasRusk County48401950900Directly adjoining
TexasRusk County48401951000Directly adjoining
TexasRusk County48401951100Directly adjoining
TexasTitus County48449950100Directly adjoining
TexasTitus County48449950200Mine closure, Generating unit retirement
TexasTitus County48449950301Directly adjoining
TexasTitus County48449950302Directly adjoining
TexasTitus County48449950400Generating unit retirement
TexasTitus County48449950500Directly adjoining
TexasTitus County48449950800Directly adjoining
TexasWebb County48479001710Mine closure
TexasWebb County48479001711Directly adjoining
TexasWebb County48479001714Directly adjoining
TexasWebb County48479001726Directly adjoining
TexasWebb County48479001727Directly adjoining
TexasWebb County48479001815Directly adjoining
TexasWebb County48479001816Directly adjoining
TexasWichita County48485013700Directly adjoining
TexasWichita County48485013800Directly adjoining
TexasWilbarger County48487950300Generating unit retirement
TexasWilbarger County48487950500Directly adjoining
TexasWilbarger County48487950600Directly adjoining
TexasWilbarger County48487950700Directly adjoining
TexasWilliamson County48491020900Directly adjoining
TexasWilliamson County48491021300Directly adjoining
TexasWilson County48493000103Directly adjoining
TexasWilson County48493000201Directly adjoining
TexasWilson County48493000405Directly adjoining
TexasWilson County48493000406Directly adjoining
UtahCarbon County49007000100Directly adjoining
UtahCarbon County49007000200Directly adjoining
UtahCarbon County49007000300Mine closure, Directly adjoining
UtahCarbon County49007000500Mine closure, Directly adjoining
UtahCarbon County49007000600Mine closure, Generating unit retirement,
Directly adjoining
UtahDaggett County49009960100Directly adjoining
UtahDuchesne County49013940300Directly adjoining
UtahDuchesne County49013940600Directly adjoining
UtahEmery County49015976200Mine closure, Directly adjoining
UtahEmery County49015976300Mine closure, Directly adjoining
UtahEmery County49015976500Mine closure, Directly adjoining
UtahGarfield County49017000300Directly adjoining
UtahGarfield County49017000400Directly adjoining
UtahGrand County49019000302Directly adjoining

Bulletin No. 2024–24 1595 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
UtahIron County49021110100Directly adjoining
UtahIron County49021110602Directly adjoining
UtahKane County49025130100Mine closure
UtahKane County49025130200Directly adjoining
UtahSalt Lake County49035113105Directly adjoining
UtahSalt Lake County49035113526Directly adjoining
UtahSalt Lake County49035113540Directly adjoining
UtahSalt Lake County49035113541Directly adjoining
UtahSalt Lake County49035113542Directly adjoining
UtahSalt Lake County49035113545Directly adjoining
UtahSalt Lake County49035113905Directly adjoining
UtahSalt Lake County49035113906Directly adjoining
UtahSalt Lake County49035113908Directly adjoining
UtahSalt Lake County49035113909Generating unit retirement
UtahSalt Lake County49035114303Directly adjoining
UtahSan Juan County49037942100Directly adjoining
UtahSan Juan County49037978100Directly adjoining
UtahSan Juan County49037978200Directly adjoining
UtahSanpete County49039972101Directly adjoining
UtahSanpete County49039972102Directly adjoining
UtahSanpete County49039972500Directly adjoining
UtahSevier County49041975100Directly adjoining
UtahSevier County49041975200Directly adjoining
UtahTooele County49045130701Directly adjoining
UtahUintah County49047940201Directly adjoining
UtahUintah County49047968201Directly adjoining
UtahUtah County49049010900Directly adjoining
UtahWashington County49053270102Directly adjoining
UtahWayne County49055979100Directly adjoining
VirginiaAlleghany County51005080201Directly adjoining
VirginiaAlleghany County51005080202Directly adjoining
VirginiaAlleghany County51005080301Generating unit retirement
VirginiaAlleghany County51005080302Directly adjoining
VirginiaAugusta County51015070500Directly adjoining
VirginiaAugusta County51015071201Directly adjoining
VirginiaAugusta County51015071202Directly adjoining
VirginiaBath County51017920102Directly adjoining
VirginiaBland County51021040100Directly adjoining
VirginiaBrunswick County51025930302Directly adjoining
VirginiaBuchanan County51027010100Mine closure, Directly adjoining
VirginiaBuchanan County51027010200Mine closure, Directly adjoining
VirginiaBuchanan County51027010300Mine closure, Directly adjoining
VirginiaBuchanan County51027010400Mine closure, Directly adjoining

June 10, 2024 1596 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
VirginiaBuchanan County51027010500Mine closure, Directly adjoining
VirginiaBuchanan County51027010600Mine closure, Directly adjoining
VirginiaBuchanan County51027010700Mine closure, Directly adjoining
VirginiaCharles City County51036600100Directly adjoining
VirginiaChesterfield County51041100300Directly adjoining
VirginiaChesterfield County51041100403Generating unit retirement
VirginiaChesterfield County51041100404Directly adjoining
VirginiaChesterfield County51041100407Directly adjoining
VirginiaChesterfield County51041100409Directly adjoining
VirginiaChesterfield County51041100505Directly adjoining
VirginiaChesterfield County51041100509Directly adjoining
VirginiaChesterfield County51041100510Directly adjoining
VirginiaDickenson County51051040100Mine closure, Directly adjoining
VirginiaDickenson County51051040200Mine closure, Directly adjoining
VirginiaDickenson County51051040300Mine closure, Directly adjoining
VirginiaDickenson County51051040400Mine closure, Directly adjoining
VirginiaGiles County51071930200Directly adjoining
VirginiaGiles County51071930300Generating unit retirement
VirginiaGiles County51071930400Directly adjoining
VirginiaGloucester County51073100500Directly adjoining
VirginiaHenrico County51087201601Directly adjoining
VirginiaHenrico County51087201602Directly adjoining
VirginiaHenry County51089010500Directly adjoining
VirginiaKing George County51099040301Directly adjoining
VirginiaKing George County51099040302Generating unit retirement
VirginiaKing George County51099040400Directly adjoining
VirginiaLee County51105950100Mine closure, Directly adjoining
VirginiaLee County51105950200Directly adjoining
VirginiaLee County51105950301Directly adjoining
VirginiaLee County51105950500Directly adjoining
VirginiaLee County51105950600Directly adjoining
VirginiaLoudoun County51107610300Directly adjoining
VirginiaLoudoun County51107610503Directly adjoining
VirginiaLoudoun County51107610507Directly adjoining
VirginiaLoudoun County51107611002Directly adjoining
VirginiaLoudoun County51107611009Directly adjoining
VirginiaLoudoun County51107611010Directly adjoining
VirginiaLoudoun County51107611101Directly adjoining
VirginiaLoudoun County51107611102Directly adjoining
VirginiaLoudoun County51107611202Directly adjoining
VirginiaLoudoun County51107611206Directly adjoining
VirginiaLoudoun County51107611208Directly adjoining
VirginiaMecklenburg County51117930103Directly adjoining

Bulletin No. 2024–24 1597 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
VirginiaMecklenburg County51117930104Directly adjoining
VirginiaMecklenburg County51117930300Directly adjoining
VirginiaMecklenburg County51117930600Directly adjoining
VirginiaMecklenburg County51117930700Generating unit retirement
VirginiaMecklenburg County51117930800Directly adjoining
VirginiaPittsylvania County51143011100Directly adjoining
VirginiaPrince George County51149850302Directly adjoining
VirginiaRussell County51167030100Mine closure, Directly adjoining
VirginiaRussell County51167030201Mine closure, Directly adjoining
VirginiaRussell County51167030202Directly adjoining
VirginiaRussell County51167030300Directly adjoining
VirginiaRussell County51167030402Directly adjoining
VirginiaRussell County51167030403Directly adjoining
VirginiaRussell County51167030404Directly adjoining
VirginiaRussell County51167030500Directly adjoining
VirginiaRussell County51167030600Mine closure, Generating unit retirement,
Directly adjoining
VirginiaScott County51169030200Directly adjoining
VirginiaScott County51169030300Mine closure, Directly adjoining
VirginiaScott County51169030400Directly adjoining
VirginiaStafford County51179010106Directly adjoining
VirginiaStafford County51179010503Directly adjoining
VirginiaStafford County51179010504Directly adjoining
VirginiaTazewell County51185020100Directly adjoining
VirginiaTazewell County51185020301Mine closure, Directly adjoining
VirginiaTazewell County51185020302Mine closure, Directly adjoining
VirginiaTazewell County51185020400Mine closure, Directly adjoining
VirginiaTazewell County51185020500Mine closure, Directly adjoining
VirginiaTazewell County51185020600Directly adjoining
VirginiaTazewell County51185020800Directly adjoining
VirginiaTazewell County51185020900Mine closure, Directly adjoining
VirginiaTazewell County51185021000Directly adjoining
VirginiaTazewell County51185021101Directly adjoining
VirginiaWise County51195930700Mine closure, Directly adjoining
VirginiaWise County51195930800Mine closure, Directly adjoining
VirginiaWise County51195930900Mine closure, Directly adjoining
VirginiaWise County51195931000Mine closure, Directly adjoining
VirginiaWise County51195931100Mine closure, Directly adjoining
VirginiaWise County51195931200Directly adjoining
VirginiaWise County51195931300Directly adjoining
VirginiaWise County51195931400Mine closure, Directly adjoining
VirginiaWise County51195931500Mine closure, Directly adjoining
VirginiaWise County51195931600Mine closure, Directly adjoining
VirginiaWise County51195931700Mine closure, Directly adjoining

June 10, 2024 1598 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
VirginiaYork County51199050303Directly adjoining
VirginiaYork County51199050306Directly adjoining
VirginiaYork County51199050401Generating unit retirement
VirginiaYork County51199050402Directly adjoining
VirginiaYork County51199050500Directly adjoining
VirginiaYork County51199990100Directly adjoining
VirginiaAlexandria city51510201601Directly adjoining
VirginiaAlexandria city51510201602Directly adjoining
VirginiaAlexandria city51510201802Directly adjoining
VirginiaAlexandria city51510201803Directly adjoining
VirginiaAlexandria city51510201805Generating unit retirement
VirginiaAlexandria city51510980000Directly adjoining
VirginiaChesapeake city51550020200Directly adjoining
VirginiaChesapeake city51550020300Directly adjoining
VirginiaChesapeake city51550020400Generating unit retirement
VirginiaChesapeake city51550020500Directly adjoining
VirginiaChesapeake city51550020600Directly adjoining
VirginiaChesapeake city51550020903Directly adjoining
VirginiaChesapeake city51550020910Directly adjoining
VirginiaChesapeake city51550021301Directly adjoining
VirginiaChesapeake city51550021304Directly adjoining
VirginiaChesapeake city51550021401Directly adjoining
VirginiaChesapeake city51550021402Generating unit retirement
VirginiaChesapeake city51550021403Directly adjoining
VirginiaChesapeake city51550021405Directly adjoining
VirginiaCovington city51580060100Directly adjoining
VirginiaCovington city51580060200Directly adjoining
VirginiaHampton city51650011100Directly adjoining
VirginiaHopewell city51670820100Directly adjoining
VirginiaHopewell city51670820300Directly adjoining
VirginiaHopewell city51670820700Directly adjoining
VirginiaHopewell city51670980100Generating unit retirement
VirginiaNewport News city51700030100Directly adjoining
VirginiaNorfolk city51710000902Directly adjoining
VirginiaNorfolk city51710002400Directly adjoining
VirginiaNorfolk city51710980100Directly adjoining
VirginiaNorton city51720960100Directly adjoining
VirginiaPortsmouth city51740210200Directly adjoining
VirginiaPortsmouth city51740210300Directly adjoining
VirginiaPortsmouth city51740210400Directly adjoining
VirginiaPortsmouth city51740213001Generating unit retirement
VirginiaPortsmouth city51740213002Directly adjoining
VirginiaPortsmouth city51740213103Directly adjoining

Bulletin No. 2024–24 1599 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
VirginiaPortsmouth city51740213104Directly adjoining
VirginiaRichmond city51760060800Directly adjoining
VirginiaRichmond city51760060900Generating unit retirement
VirginiaRichmond city51760070901Directly adjoining
VirginiaSuffolk city51800075106Directly adjoining
VirginiaWaynesboro city51820003100Directly adjoining
VirginiaWaynesboro city51820003200Generating unit retirement
VirginiaWaynesboro city51820003300Directly adjoining
VirginiaWaynesboro city51820003400Directly adjoining
VirginiaWaynesboro city51820003500Directly adjoining
WashingtonBenton County53005011600Directly adjoining
WashingtonKing County53033031202Directly adjoining
WashingtonKing County53033031204Directly adjoining
WashingtonKing County53033031501Directly adjoining
WashingtonKing County53033031603Mine closure
WashingtonKing County53033031604Directly adjoining
WashingtonKing County53033031605Directly adjoining
WashingtonKing County53033032003Directly adjoining
WashingtonKing County53033032010Directly adjoining
WashingtonKing County53033032011Directly adjoining
WashingtonKlickitat County53039950101Directly adjoining
WashingtonLewis County53041970400Directly adjoining
WashingtonLewis County53041970700Directly adjoining
WashingtonLewis County53041970800Directly adjoining
WashingtonLewis County53041971000Directly adjoining
WashingtonLewis County53041971100Generating unit retirement
WashingtonLewis County53041971200Directly adjoining
WashingtonLewis County53041971300Directly adjoining
WashingtonLewis County53041971400Directly adjoining
WashingtonLewis County53041971800Directly adjoining
WashingtonThurston County53067012531Directly adjoining
WashingtonThurston County53067012620Directly adjoining
West VirginiaBarbour County54001965500Mine closure, Directly adjoining
West VirginiaBarbour County54001965600Mine closure, Directly adjoining
West VirginiaBarbour County54001965700Directly adjoining
West VirginiaBarbour County54001965800Mine closure, Directly adjoining
West VirginiaBerkeley County54003971101Directly adjoining
West VirginiaBerkeley County54003971103Directly adjoining
West VirginiaBoone County54005958200Mine closure, Directly adjoining
West VirginiaBoone County54005958300Mine closure, Directly adjoining
West VirginiaBoone County54005958400Directly adjoining
West VirginiaBoone County54005958501Mine closure, Directly adjoining
West VirginiaBoone County54005958502Mine closure, Directly adjoining

June 10, 2024 1600 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaBoone County54005958600Mine closure, Directly adjoining
West VirginiaBoone County54005958700Mine closure, Directly adjoining
West VirginiaBoone County54005958800Mine closure, Directly adjoining
West VirginiaBraxton County54007967900Directly adjoining
West VirginiaBraxton County54007968000Directly adjoining
West VirginiaBraxton County54007968100Mine closure, Directly adjoining
West VirginiaBrooke County54009031102Mine closure, Directly adjoining
West VirginiaBrooke County54009031103Directly adjoining
West VirginiaBrooke County54009031104Mine closure, Directly adjoining
West VirginiaBrooke County54009031200Directly adjoining
West VirginiaBrooke County54009031401Directly adjoining
West VirginiaBrooke County54009031402Directly adjoining
West VirginiaBrooke County54009031600Mine closure, Directly adjoining
West VirginiaBrooke County54009031700Mine closure, Directly adjoining
West VirginiaCabell County54011010500Directly adjoining
West VirginiaCalhoun County54013962600Directly adjoining
West VirginiaCalhoun County54013962700Directly adjoining
West VirginiaClay County54015957900Directly adjoining
West VirginiaClay County54015958000Mine closure, Directly adjoining
West VirginiaClay County54015958100Mine closure, Directly adjoining
West VirginiaDoddridge County54017965000Directly adjoining
West VirginiaFayette County54019020101Mine closure, Directly adjoining
West VirginiaFayette County54019020102Directly adjoining
West VirginiaFayette County54019020201Directly adjoining
West VirginiaFayette County54019020202Directly adjoining
West VirginiaFayette County54019020400Directly adjoining
West VirginiaFayette County54019020500Directly adjoining
West VirginiaFayette County54019020600Mine closure, Directly adjoining
West VirginiaFayette County54019020700Mine closure, Directly adjoining
West VirginiaFayette County54019020800Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaFayette County54019020900Mine closure, Directly adjoining
West VirginiaFayette County54019021000Mine closure, Directly adjoining
West VirginiaFayette County54019021100Mine closure, Directly adjoining
West VirginiaGilmer County54021967701Mine closure, Directly adjoining
West VirginiaGilmer County54021967800Directly adjoining
West VirginiaGilmer County54021980000Directly adjoining
West VirginiaGrant County54023969400Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaGrant County54023969500Directly adjoining
West VirginiaGreenbrier County54025950102Directly adjoining
West VirginiaGreenbrier County54025950200Mine closure, Directly adjoining
West VirginiaGreenbrier County54025950300Mine closure, Directly adjoining
West VirginiaGreenbrier County54025950401Directly adjoining

Bulletin No. 2024–24 1601 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaGreenbrier County54025950402Directly adjoining
West VirginiaGreenbrier County54025950500Directly adjoining
West VirginiaGreenbrier County54025950600Mine closure
West VirginiaGreenbrier County54025950701Directly adjoining
West VirginiaGreenbrier County54025950702Directly adjoining
West VirginiaHampshire County54027968401Directly adjoining
West VirginiaHancock County54029020600Directly adjoining
West VirginiaHancock County54029020700Directly adjoining
West VirginiaHancock County54029020900Directly adjoining
West VirginiaHancock County54029021100Directly adjoining
West VirginiaHancock County54029021200Directly adjoining
West VirginiaHancock County54029021300Directly adjoining
West VirginiaHancock County54029021400Directly adjoining
West VirginiaHancock County54029021500Directly adjoining
West VirginiaHardy County54031970102Directly adjoining
West VirginiaHardy County54031970300Directly adjoining
West VirginiaHarrison County54033030300Directly adjoining
West VirginiaHarrison County54033030501Mine closure, Directly adjoining
West VirginiaHarrison County54033030502Directly adjoining
West VirginiaHarrison County54033030601Directly adjoining
West VirginiaHarrison County54033030603Directly adjoining
West VirginiaHarrison County54033030604Directly adjoining
West VirginiaHarrison County54033030700Mine closure, Directly adjoining
West VirginiaHarrison County54033030801Directly adjoining
West VirginiaHarrison County54033030802Directly adjoining
West VirginiaHarrison County54033031000Directly adjoining
West VirginiaHarrison County54033031100Mine closure, Directly adjoining
West VirginiaHarrison County54033031200Mine closure, Directly adjoining
West VirginiaHarrison County54033031300Mine closure, Directly adjoining
West VirginiaHarrison County54033031400Mine closure, Directly adjoining
West VirginiaHarrison County54033031500Mine closure, Directly adjoining
West VirginiaHarrison County54033031600Mine closure, Directly adjoining
West VirginiaHarrison County54033031700Mine closure, Directly adjoining
West VirginiaHarrison County54033031800Mine closure, Directly adjoining
West VirginiaHarrison County54033031900Directly adjoining
West VirginiaHarrison County54033032000Mine closure, Directly adjoining
West VirginiaHarrison County54033032103Directly adjoining
West VirginiaHarrison County54033032104Directly adjoining
West VirginiaJackson County54035963200Directly adjoining
West VirginiaJackson County54035963300Directly adjoining
West VirginiaJackson County54035963400Directly adjoining
West VirginiaKanawha County54039001100Directly adjoining
West VirginiaKanawha County54039001700Directly adjoining

June 10, 2024 1602 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaKanawha County54039001800Directly adjoining
West VirginiaKanawha County54039010100Directly adjoining
West VirginiaKanawha County54039010200Directly adjoining
West VirginiaKanawha County54039010300Directly adjoining
West VirginiaKanawha County54039010400Generating unit retirement
West VirginiaKanawha County54039010500Directly adjoining
West VirginiaKanawha County54039010602Directly adjoining
West VirginiaKanawha County54039011000Directly adjoining
West VirginiaKanawha County54039011200Directly adjoining
West VirginiaKanawha County54039011301Mine closure, Directly adjoining
West VirginiaKanawha County54039011302Directly adjoining
West VirginiaKanawha County54039011401Directly adjoining
West VirginiaKanawha County54039011402Mine closure, Directly adjoining
West VirginiaKanawha County54039011500Directly adjoining
West VirginiaKanawha County54039011800Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaKanawha County54039012100Mine closure, Directly adjoining
West VirginiaKanawha County54039012200Mine closure, Directly adjoining
West VirginiaKanawha County54039012301Directly adjoining
West VirginiaKanawha County54039012302Mine closure, Directly adjoining
West VirginiaKanawha County54039013200Directly adjoining
West VirginiaKanawha County54039013400Directly adjoining
West VirginiaKanawha County54039013500Directly adjoining
West VirginiaKanawha County54039013701Directly adjoining
West VirginiaLewis County54041967200Directly adjoining
West VirginiaLewis County54041967300Mine closure, Directly adjoining
West VirginiaLewis County54041967400Directly adjoining
West VirginiaLewis County54041967500Directly adjoining
West VirginiaLewis County54041967600Mine closure, Directly adjoining
West VirginiaLincoln County54043955401Mine closure, Directly adjoining
West VirginiaLincoln County54043955402Directly adjoining
West VirginiaLincoln County54043955500Directly adjoining
West VirginiaLincoln County54043955600Directly adjoining
West VirginiaLincoln County54043955700Directly adjoining
West VirginiaLincoln County54043955800Mine closure, Directly adjoining
West VirginiaLogan County54045956102Directly adjoining
West VirginiaLogan County54045956103Directly adjoining
West VirginiaLogan County54045956104Directly adjoining
West VirginiaLogan County54045956200Mine closure, Directly adjoining
West VirginiaLogan County54045956400Mine closure, Directly adjoining
West VirginiaLogan County54045956500Mine closure, Directly adjoining
West VirginiaLogan County54045956600Mine closure, Directly adjoining
West VirginiaLogan County54045956700Mine closure, Directly adjoining
West VirginiaLogan County54045956800Mine closure, Directly adjoining

Bulletin No. 2024–24 1603 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaLogan County54045956900Directly adjoining
West VirginiaMcDowell County54047953600Mine closure, Directly adjoining
West VirginiaMcDowell County54047953800Mine closure, Directly adjoining
West VirginiaMcDowell County54047953900Mine closure, Directly adjoining
West VirginiaMcDowell County54047954000Mine closure, Directly adjoining
West VirginiaMcDowell County54047954200Mine closure, Directly adjoining
West VirginiaMcDowell County54047954501Mine closure, Directly adjoining
West VirginiaMcDowell County54047954503Mine closure, Directly adjoining
West VirginiaMcDowell County54047954504Mine closure, Directly adjoining
West VirginiaMarion County54049020100Mine closure
West VirginiaMarion County54049020200Directly adjoining
West VirginiaMarion County54049020300Directly adjoining
West VirginiaMarion County54049020400Mine closure, Directly adjoining
West VirginiaMarion County54049020500Directly adjoining
West VirginiaMarion County54049020600Directly adjoining
West VirginiaMarion County54049020700Directly adjoining
West VirginiaMarion County54049020800Directly adjoining
West VirginiaMarion County54049020900Directly adjoining
West VirginiaMarion County54049021001Directly adjoining
West VirginiaMarion County54049021002Mine closure
West VirginiaMarion County54049021201Directly adjoining
West VirginiaMarion County54049021202Directly adjoining
West VirginiaMarion County54049021300Mine closure, Directly adjoining
West VirginiaMarion County54049021400Directly adjoining
West VirginiaMarion County54049021500Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaMarion County54049021601Directly adjoining
West VirginiaMarion County54049021602Mine closure, Directly adjoining
West VirginiaMarion County54049021700Directly adjoining
West VirginiaMarion County54049021800Mine closure, Directly adjoining
West VirginiaMarshall County54051020200Directly adjoining
West VirginiaMarshall County54051020702Directly adjoining
West VirginiaMarshall County54051020800Directly adjoining
West VirginiaMarshall County54051020900Generating unit retirement, Directly adjoining
West VirginiaMarshall County54051021001Directly adjoining
West VirginiaMarshall County54051021002Directly adjoining
West VirginiaMason County54053954801Directly adjoining
West VirginiaMason County54053954802Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaMason County54053954901Directly adjoining
West VirginiaMason County54053954902Directly adjoining
West VirginiaMercer County54055000900Directly adjoining
West VirginiaMercer County54055001000Directly adjoining
West VirginiaMercer County54055001100Directly adjoining

June 10, 2024 1604 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaMercer County54055001500Directly adjoining
West VirginiaMercer County54055001600Mine closure, Directly adjoining
West VirginiaMercer County54055001700Directly adjoining
West VirginiaMercer County54055001800Directly adjoining
West VirginiaMercer County54055002400Directly adjoining
West VirginiaMineral County54057010400Directly adjoining
West VirginiaMineral County54057010500Directly adjoining
West VirginiaMineral County54057010600Directly adjoining
West VirginiaMineral County54057010700Mine closure, Directly adjoining
West VirginiaMingo County54059957100Mine closure, Directly adjoining
West VirginiaMingo County54059957200Mine closure, Directly adjoining
West VirginiaMingo County54059957300Mine closure, Directly adjoining
West VirginiaMingo County54059957400Mine closure, Directly adjoining
West VirginiaMingo County54059957500Mine closure, Directly adjoining
West VirginiaMingo County54059957600Mine closure, Directly adjoining
West VirginiaMingo County54059957700Mine closure, Directly adjoining
West VirginiaMonongalia County54061010101Directly adjoining
West VirginiaMonongalia County54061010103Directly adjoining
West VirginiaMonongalia County54061010104Generating unit retirement
West VirginiaMonongalia County54061010202Directly adjoining
West VirginiaMonongalia County54061010203Directly adjoining
West VirginiaMonongalia County54061010204Directly adjoining
West VirginiaMonongalia County54061010400Directly adjoining
West VirginiaMonongalia County54061010601Directly adjoining
West VirginiaMonongalia County54061010602Directly adjoining
West VirginiaMonongalia County54061010700Directly adjoining
West VirginiaMonongalia County54061010901Directly adjoining
West VirginiaMonongalia County54061011000Directly adjoining
West VirginiaMonongalia County54061011100Directly adjoining
West VirginiaMonongalia County54061011200Mine closure, Directly adjoining
West VirginiaMonongalia County54061011300Mine closure, Directly adjoining
West VirginiaMonongalia County54061011400Mine closure, Directly adjoining
West VirginiaMonongalia County54061011500Mine closure, Directly adjoining
West VirginiaMonongalia County54061011601Directly adjoining
West VirginiaMonongalia County54061011602Directly adjoining
West VirginiaMonongalia County54061011700Directly adjoining
West VirginiaMonongalia County54061011803Directly adjoining
West VirginiaMonongalia County54061011804Directly adjoining
West VirginiaMonongalia County54061011805Directly adjoining
West VirginiaMonongalia County54061011806Directly adjoining
West VirginiaMonongalia County54061011900Mine closure, Directly adjoining
West VirginiaMonongalia County54061012000Mine closure
West VirginiaMonroe County54063950300Directly adjoining

Bulletin No. 2024–24 1605 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaNicholas County54067950100Mine closure, Directly adjoining
West VirginiaNicholas County54067950201Mine closure, Directly adjoining
West VirginiaNicholas County54067950202Mine closure, Directly adjoining
West VirginiaNicholas County54067950300Mine closure, Directly adjoining
West VirginiaNicholas County54067950400Mine closure, Directly adjoining
West VirginiaNicholas County54067950500Directly adjoining
West VirginiaNicholas County54067950600Mine closure, Directly adjoining
West VirginiaNicholas County54067950700Mine closure, Directly adjoining
West VirginiaOhio County54069000200Directly adjoining
West VirginiaOhio County54069000300Directly adjoining
West VirginiaOhio County54069000400Directly adjoining
West VirginiaOhio County54069000500Directly adjoining
West VirginiaOhio County54069000600Directly adjoining
West VirginiaOhio County54069000700Directly adjoining
West VirginiaOhio County54069001400Directly adjoining
West VirginiaOhio County54069001500Directly adjoining
West VirginiaOhio County54069001600Directly adjoining
West VirginiaOhio County54069001700Directly adjoining
West VirginiaOhio County54069001800Directly adjoining
West VirginiaOhio County54069002000Mine closure, Directly adjoining
West VirginiaOhio County54069002100Directly adjoining
West VirginiaOhio County54069002600Directly adjoining
West VirginiaOhio County54069002700Mine closure
West VirginiaPendleton County54071970400Directly adjoining
West VirginiaPleasants County54073962100Directly adjoining
West VirginiaPleasants County54073962200Generating unit retirement
West VirginiaPocahontas County54075960102Directly adjoining
West VirginiaPocahontas County54075960201Directly adjoining
West VirginiaPocahontas County54075960300Directly adjoining
West VirginiaPreston County54077963801Directly adjoining
West VirginiaPreston County54077963802Mine closure, Directly adjoining
West VirginiaPreston County54077963900Mine closure, Directly adjoining
West VirginiaPreston County54077964000Mine closure, Generating unit retirement,
Directly adjoining
West VirginiaPreston County54077964101Mine closure, Directly adjoining
West VirginiaPreston County54077964102Directly adjoining
West VirginiaPreston County54077964103Mine closure, Directly adjoining
West VirginiaPreston County54077964200Mine closure, Directly adjoining
West VirginiaPreston County54077964300Mine closure, Directly adjoining
West VirginiaPreston County54077964400Mine closure, Directly adjoining
West VirginiaPreston County54077964500Mine closure, Directly adjoining
West VirginiaPutnam County54079020700Directly adjoining
West VirginiaRaleigh County54081000300Directly adjoining
West VirginiaRaleigh County54081000500Directly adjoining

June 10, 2024 1606 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaRaleigh County54081000600Directly adjoining
West VirginiaRaleigh County54081000700Directly adjoining
West VirginiaRaleigh County54081000802Directly adjoining
West VirginiaRaleigh County54081000804Directly adjoining
West VirginiaRaleigh County54081000900Mine closure, Directly adjoining
West VirginiaRaleigh County54081001001Directly adjoining
West VirginiaRaleigh County54081001002Mine closure, Directly adjoining
West VirginiaRaleigh County54081001100Mine closure, Directly adjoining
West VirginiaRaleigh County54081001200Mine closure, Directly adjoining
West VirginiaRaleigh County54081001300Mine closure, Directly adjoining
West VirginiaRaleigh County54081001400Directly adjoining
West VirginiaRaleigh County54081001500Directly adjoining
West VirginiaRandolph County54083965900Mine closure, Directly adjoining
West VirginiaRandolph County54083966000Directly adjoining
West VirginiaRandolph County54083966200Directly adjoining
West VirginiaRandolph County54083966300Mine closure, Directly adjoining
West VirginiaRandolph County54083966400Directly adjoining
West VirginiaRandolph County54083966500Mine closure, Directly adjoining
West VirginiaRitchie County54085962300Directly adjoining
West VirginiaRitchie County54085962400Directly adjoining
West VirginiaRitchie County54085962500Directly adjoining
West VirginiaSummers County54089000500Directly adjoining
West VirginiaSummers County54089000600Directly adjoining
West VirginiaSummers County54089000800Directly adjoining
West VirginiaTaylor County54091964600Directly adjoining
West VirginiaTaylor County54091964700Directly adjoining
West VirginiaTaylor County54091964800Mine closure, Directly adjoining
West VirginiaTaylor County54091964900Mine closure, Directly adjoining
West VirginiaTucker County54093965200Directly adjoining
West VirginiaTucker County54093965300Mine closure, Directly adjoining
West VirginiaTucker County54093965400Directly adjoining
West VirginiaUpshur County54097966600Mine closure, Directly adjoining
West VirginiaUpshur County54097966700Directly adjoining
West VirginiaUpshur County54097966800Directly adjoining
West VirginiaUpshur County54097966900Mine closure, Directly adjoining
West VirginiaUpshur County54097967000Mine closure, Directly adjoining
West VirginiaUpshur County54097967100Mine closure, Directly adjoining
West VirginiaWayne County54099020500Directly adjoining
West VirginiaWayne County54099020600Directly adjoining
West VirginiaWayne County54099020700Directly adjoining
West VirginiaWayne County54099020800Directly adjoining
West VirginiaWayne County54099020900Mine closure, Directly adjoining
West VirginiaWayne County54099021000Mine closure, Directly adjoining

Bulletin No. 2024–24 1607 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
West VirginiaWebster County54101970101Mine closure, Directly adjoining
West VirginiaWebster County54101970102Directly adjoining
West VirginiaWebster County54101970200Mine closure, Directly adjoining
West VirginiaWebster County54101970300Directly adjoining
West VirginiaWetzel County54103004900Directly adjoining
West VirginiaWetzel County54103030400Directly adjoining
West VirginiaWetzel County54103030500Directly adjoining
West VirginiaWetzel County54103030700Directly adjoining
West VirginiaWood County54107010101Directly adjoining
West VirginiaWood County54107010200Directly adjoining
West VirginiaWood County54107010400Directly adjoining
West VirginiaWood County54107010601Directly adjoining
West VirginiaWood County54107010602Directly adjoining
West VirginiaWyoming County54109002800Mine closure, Directly adjoining
West VirginiaWyoming County54109002901Mine closure, Directly adjoining
West VirginiaWyoming County54109002902Mine closure, Directly adjoining
West VirginiaWyoming County54109003000Mine closure, Directly adjoining
West VirginiaWyoming County54109003100Mine closure, Directly adjoining
West VirginiaWyoming County54109003200Mine closure, Directly adjoining
WisconsinBrown County55009000100Generating unit retirement, Directly adjoining
WisconsinBrown County55009000200Directly adjoining
WisconsinBrown County55009000500Directly adjoining
WisconsinBrown County55009000700Directly adjoining
WisconsinBrown County55009000800Generating unit retirement, Directly adjoining
WisconsinBrown County55009000900Directly adjoining
WisconsinBrown County55009001000Directly adjoining
WisconsinBrown County55009001802Directly adjoining
WisconsinBrown County55009020502Directly adjoining
WisconsinBrown County55009020800Directly adjoining
WisconsinBrown County55009020900Directly adjoining
WisconsinBrown County55009021303Directly adjoining
WisconsinBuffalo County55011960100Directly adjoining
WisconsinBuffalo County55011960300Generating unit retirement
WisconsinBuffalo County55011960400Directly adjoining
WisconsinCalumet County55015020308Directly adjoining
WisconsinCrawford County55023960200Directly adjoining
WisconsinDane County55025001706Directly adjoining
WisconsinDane County55025001707Directly adjoining
WisconsinDane County55025001802Directly adjoining
WisconsinDane County55025001804Directly adjoining
WisconsinDane County55025001901Generating unit retirement
WisconsinDane County55025001902Directly adjoining
WisconsinDane County55025002100Directly adjoining

June 10, 2024 1608 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
WisconsinDane County55025991703Directly adjoining
WisconsinGrant County55043960300Directly adjoining
WisconsinGrant County55043960400Directly adjoining
WisconsinGrant County55043960500Generating unit retirement
WisconsinGrant County55043960600Directly adjoining
WisconsinGrant County55043960700Directly adjoining
WisconsinGrant County55043960800Directly adjoining
WisconsinGrant County55043961100Directly adjoining
WisconsinGrant County55043961200Directly adjoining
WisconsinKenosha County55059001402Directly adjoining
WisconsinKenosha County55059002500Directly adjoining
WisconsinKenosha County55059002603Directly adjoining
WisconsinKenosha County55059002604Directly adjoining
WisconsinKenosha County55059002605Generating unit retirement
WisconsinKenosha County55059002606Directly adjoining
WisconsinKenosha County55059002700Directly adjoining
WisconsinLa Crosse County55063010700Directly adjoining
WisconsinMarathon County55073001000Directly adjoining
WisconsinMarathon County55073001103Directly adjoining
WisconsinMarathon County55073001104Directly adjoining
WisconsinMarathon County55073001105Directly adjoining
WisconsinMarathon County55073001106Generating unit retirement
WisconsinMarathon County55073001203Directly adjoining
WisconsinMarathon County55073001204Directly adjoining
WisconsinMarathon County55073001300Directly adjoining
WisconsinMarathon County55073001600Directly adjoining
WisconsinMarathon County55073001700Directly adjoining
WisconsinMarinette County55075961300Directly adjoining
WisconsinMarinette County55075961400Directly adjoining
WisconsinMarinette County55075961500Directly adjoining
WisconsinMilwaukee County55079012800Directly adjoining
WisconsinMilwaukee County55079090300Directly adjoining
WisconsinMilwaukee County55079090600Directly adjoining
WisconsinMilwaukee County55079090700Directly adjoining
WisconsinMilwaukee County55079091200Directly adjoining
WisconsinMilwaukee County55079091300Directly adjoining
WisconsinMilwaukee County55079185300Generating unit retirement
WisconsinPepin County55091950100Directly adjoining
WisconsinPepin County55091950200Directly adjoining
WisconsinPortage County55097960200Directly adjoining
WisconsinPortage County55097960701Directly adjoining
WisconsinPortage County55097960702Directly adjoining
WisconsinPortage County55097960800Directly adjoining

Bulletin No. 2024–24 1609 June 10, 2024
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
WisconsinPortage County55097960900Directly adjoining
WisconsinPortage County55097961000Directly adjoining
WisconsinPortage County55097961101Directly adjoining
WisconsinPortage County55097961102Generating unit retirement
WisconsinSheboygan County55117000800Directly adjoining
WisconsinSheboygan County55117001000Directly adjoining
WisconsinSheboygan County55117001100Generating unit retirement
WisconsinSheboygan County55117010800Directly adjoining
WisconsinSheboygan County55117990000Directly adjoining
WisconsinVernon County55123960500Directly adjoining
WisconsinVernon County55123960600Directly adjoining
WisconsinVernon County55123960700Generating unit retirement, Directly adjoining
WisconsinWaukesha County55133200901Directly adjoining
WisconsinWaukesha County55133201002Directly adjoining
WisconsinWinnebago County55139002401Directly adjoining
WisconsinWinnebago County55139002800Directly adjoining
WisconsinWinnebago County55139002900Directly adjoining
WisconsinWinnebago County55139003000Generating unit retirement
WisconsinWinnebago County55139003100Directly adjoining
WisconsinWinnebago County55139003400Directly adjoining
WyomingAlbany County56001963900Directly adjoining
WyomingBig Horn County56003962600Directly adjoining
WyomingBig Horn County56003962700Directly adjoining
WyomingBig Horn County56003962800Directly adjoining
WyomingCampbell County56005000101Mine closure, Directly adjoining
WyomingCampbell County56005000102Directly adjoining
WyomingCampbell County56005000103Directly adjoining
WyomingCampbell County56005000200Directly adjoining
WyomingCampbell County56005000300Generating unit retirement, Directly adjoining
WyomingCampbell County56005000400Directly adjoining
WyomingCampbell County56005000500Directly adjoining
WyomingCampbell County56005000600Directly adjoining
WyomingCampbell County56005000701Directly adjoining
WyomingCampbell County56005000702Mine closure, Directly adjoining
WyomingCarbon County56007967600Directly adjoining
WyomingCarbon County56007968000Directly adjoining
WyomingCarbon County56007968100Mine closure, Directly adjoining
WyomingConverse County56009956400Directly adjoining
WyomingConverse County56009956500Directly adjoining
WyomingConverse County56009956600Mine closure, Directly adjoining
WyomingConverse County56009956700Directly adjoining
WyomingCrook County56011950200Directly adjoining
WyomingCrook County56011950300Directly adjoining

June 10, 2024 1610 Bulletin No. 2024–24
State NameCounty or County-Equivalent
Entity Name
2020 Census Tract
Number FIPS code
Tract Type
WyomingFremont County56013000302Directly adjoining
WyomingFremont County56013000400Directly adjoining
WyomingFremont County56013940100Directly adjoining
WyomingFremont County56013940201Directly adjoining
WyomingHot Springs County56017967800Directly adjoining
WyomingHot Springs County56017967900Mine closure
WyomingJohnson County56019955100Directly adjoining
WyomingNatrona County56025001401Directly adjoining
WyomingNatrona County56025001801Directly adjoining
WyomingNatrona County56025001802Directly adjoining
WyomingNiobrara County56027957200Directly adjoining
WyomingPark County56029965302Directly adjoining
WyomingPlatte County56031959100Directly adjoining
WyomingSheridan County56033000100Directly adjoining
WyomingSheridan County56033000200Directly adjoining
WyomingSheridan County56033000300Directly adjoining
WyomingSheridan County56033000400Directly adjoining
WyomingSheridan County56033000501Directly adjoining
WyomingSheridan County56033000502Directly adjoining
WyomingSheridan County56033000600Mine closure
WyomingSweetwater County56037970800Mine closure
WyomingSweetwater County56037970902Directly adjoining
WyomingSweetwater County56037970903Directly adjoining
WyomingSweetwater County56037970904Directly adjoining
WyomingSweetwater County56037971000Directly adjoining
WyomingSweetwater County56037971100Directly adjoining
WyomingSweetwater County56037971200Directly adjoining
WyomingSweetwater County56037971600Directly adjoining
WyomingWashakie County56043000200Directly adjoining
WyomingWeston County56045951100Generating unit retirement, Directly adjoining
WyomingWeston County56045951300Directly adjoining

Bulletin No. 2024–24 1611 June 10, 2024
Credit for Carbon Oxide
Sequestration 2024
Section 45Q Inflation
Adjustment Factor
Notice 2024-39
SECTION 1. PURPOSE
This notice publishes the inflation
adjustment factor for the credit for car-
bon oxide sequestration under § 45Q of
the Internal Revenue Code (§ 45Q credit)
for calendar year 2024. The inflation
adjustment factor is used to determine
the amount of the credit allowable under
§ 45Q for taxpayers that make an elec-
tion under § 45Q(b)(3) to have the dollar
amounts applicable under § 45Q(a)(1) or
(2) apply.
SECTION 2. BACKGROUND
Section 45Q was added to the Code
by § 115 of the Energy Improvement
and Extension Act of 2008, enacted as
Division B of Pub. L. 110-343, 122 Stat.
3765, 3829 (October 3, 2008), to provide
a credit for the sequestration of carbon
dioxide. Section 45Q was amended by
§ 1131 of the American Recovery and
Reinvestment Tax Act of 2009, enacted
as Division B of Pub. L. 111-5, 123
Stat 115 (February 17, 2009), § 41119
of the Bipartisan Budget Act of 2018
(BBA), Pub. L. No. 115-123 (February 9,
2018), § 121 of the Taxpayer Certainty
and Disaster Tax Relief Act of 2020,
enacted as Division EE of the Consoli-
dated Appropriations Act, 2021, Pub. L.
116-260, 134 Stat. 3051 (December 27,
2020), and § 13104 of Pub. L. 117-169,
136 Stat. 1818 (August 16, 2022), com-
monly known as the Inflation Reduction
Act (IRA).
Section 45Q(a)(1) allows a credit of
$20 per metric ton of qualified carbon
oxide (i) captured by the taxpayer using
carbon capture equipment which is origi-
nally placed in service at a qualified facil-
ity before the date of the enactment of the
BBA, (ii) disposed of by the taxpayer in
secure geological storage, and (iii) not
used by the taxpayer as a tertiary injectant
in a qualified enhanced oil or natural gas
recovery project.
Section 45Q(a)(2) allows a credit of
$10 per metric ton of qualified carbon
oxide (i) captured by the taxpayer using
carbon capture equipment which is orig-
inally placed in service at a qualified
facility before the date of the enactment
of the BBA, and (ii) either (I) used by the
taxpayer as a tertiary injectant in a quali-
fied enhanced oil or natural gas recovery
project and disposed of by the taxpayer in
secure geological storage or (II) utilized
by the taxpayer in a manner described in
§ 45Q(f)(5).
Section 45Q(b)(3) provides that, for
purposes of determining the carbon oxide
sequestration credit under this section, a tax-
payer may elect to have the dollar amounts
applicable under § 45Q(a)(1) or (2) apply in
lieu of the dollar amounts applicable under
§ 45Q(a)(3) or (4) for each metric ton of
qualified carbon oxide which is captured
by the taxpayer using carbon capture equip-
ment which is originally placed in service at
a qualified facility on or after the date of the
enactment of the BBA.
Under § 45Q(f)(7), for taxable years
beginning in a calendar year after 2009,
the dollar amounts contained in § 45Q(a)
(1) and (2) must be adjusted for inflation
by multiplying such dollar amount by the
inflation adjustment factor for such calen-
dar year determined under § 43(b)(3)(B),
determined by substituting “2008” for
“1990.”
Section 43(b)(3)(B) defines the term
“inflation adjustment factor” as, with
respect to any calendar year, a fraction the
numerator of which is the GNP implicit
price deflator for the preceding calendar
year and the denominator of which is the
GNP implicit price deflator for 1990. For
purposes of § 45Q(f)(7), for the 2023 cal-
endar year, the inflation adjustment factor
is a fraction the numerator of which is
the GNP implicit price deflator for 2023
(122.179) and the denominator of which
is the GNP implicit price deflator for 2008
(88.046).
Section 45Q(g), as amended by
§ 13104(f) of the IRA, provides that in
the case of any carbon capture equip-
ment placed in service before the date
of the enactment of the BBA, the credit
under § 45Q shall apply with respect to
qualified carbon oxide captured using
such equipment before the earlier of
January 1, 2023, and the end of the cal-
endar year in which the Secretary of the
Treasury or her delegate, in consultation
with the Administrator of the Environ-
mental Protection Agency, certifies that,
during the period beginning after Octo-
ber 3, 2008, a total of 75,000,000 metric
tons of qualified carbon oxide have been
taken into account in accordance with (i)
§ 45Q(a), as in effect on the day before
the date of the enactment of BBA, and
(ii) § 45Q(a)(1) and (2). Notice 2022-
38 provided that 2022 was the final cal-
endar year for which a taxpayer may
claim a § 45Q credit under § 45Q(a)(1)
and (2) for qualified carbon oxide that is
captured by carbon capture equipment
originally placed in service at a quali-
fied facility before the date of enactment
of the BBA. Therefore, the inflation
adjustment amounts in section 3 of this
notice only apply if a taxpayer elects
under § 45Q(b)(3) to apply the dollar
amounts applicable under § 45Q(a)(1)
or (2) in lieu of the dollar amounts appli-
cable under § 45Q(a)(3) or (4). Because
amendments to § 45Q(g) made by sec-
tion 13104(f) of the IRA eliminated the
75,000,000 metric ton threshold begin-
ning January 1, 2023, this notice obso-
letes Notice 2009-83, 2009-2 C.B. 588.
Sections 1 through 5 of Notice 2009-83
were previously obsoleted by the final
regulations for § 45Q, T.D. 9944, 86 FR
4728 (January 15, 2021). This notice
also obsoletes Notice 2011-25, 2011-1
C.B. 604, which modified section 4 of
Notice 2009-83.
SECTION 3. INFLATION
ADJUSTMENT FACTOR
The inflation adjustment factor for
calendar year 2024 is 1.3877. The § 45Q
credit for calendar year 2024 is $27.75 per
metric ton of qualified carbon oxide under
§ 45Q(a)(1) and $13.88 per metric ton of
qualified carbon oxide under § 45Q(a)(2).
SECTION 4. EFFECT ON OTHER
DOCUMENTS
Notice 2009-83 and Notice 2011-25
are obsoleted beginning January 1, 2023.

June 10, 2024 1612 Bulletin No. 2024–24
SECTION 5. DRAFTING
INFORMATION
The principal author of this notice is
Christopher Vlcek of the Office of Asso-
ciate Chief Counsel (Passthroughs & Spe-
cial Industries). For further information
regarding this notice contact Christopher
Vlcek at (202) 317-4743 (not a toll-free
number).
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2024-40
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 deter-
mined using three 24-month average inter-
est rates (“segment rates”), each of which
applies to cash flows during specified peri-
ods. 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 cal-
endar year in which the plan year begins.
1

However, an election may be made under
§ 430(h)(2)(D)(ii) to use the monthly yield
curve in place of the segment rates.
Section 1.430(h)(2)-1(d) provides
rules for determining the monthly 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 April 2024
data is in Table 2024-4 at the end of this
notice. The spot first, second, and third
segment rates for the month of April 2024
are, respectively, 5.24, 5.48, and 5.61.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i) through
(iii) must be adjusted pursuant to § 430(h)
(2)(C)(iv) to be within the applicable mini-
mum and maximum percentages of the cor-
responding 25-year average segment rates.
For this purpose, any 25-year average seg-
ment rate that is less than 5% is deemed to
be 5%. The 25-year average segment rates
for plan years beginning in 2023 and 2024
were published in Notice 2022-40, 2022-
40 I.R.B. 266 and Notice 2023-66, 2023-
40 I.R.B. 992, respectively. The applicable
minimum and maximum percentages are
95% and 105% for plan years beginning in
2023 and 2024.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for May
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
May 2024 4.84 5.24 5.22
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 May
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
2023May 20244.845.245.74
2024May 20244.845.245.59
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. 2024–24 1613 June 10, 2024
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-
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 April 2024 is 4.66 percent. The Service
determined this rate as the average of the
daily determinations of yield on the 30-year
Treasury bond maturing in February 2054.
For plan years beginning in May 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%
May 20243.393.05 to 3.56
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. Notice 2007-81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for April 2024 are
as follows:
Minimum Present Value Segment Rates
Month First Segment Second Segment Third Segment
April 2024 5.24 5.48 5.61
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 number).

June 10, 2024 1614 Bulletin No. 2024–24
Table 2024-4
Monthly Yield Curve for April 2024
Derived from April 2024 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.55.5520.55.6640.55.6160.55.6280.55.63
1.05.4421.05.6641.05.6161.05.6281.05.63
1.55.3521.55.6541.55.6161.55.6281.55.63
2.05.2722.05.6542.05.6162.05.6282.05.63
2.55.2022.55.6542.55.6162.55.6382.55.63
3.05.1523.05.6443.05.6163.05.6383.05.63
3.55.1223.55.6443.55.6163.55.6383.55.63
4.05.1024.05.6344.05.6164.05.6384.05.63
4.55.1024.55.6344.55.6164.55.6384.55.63
5.05.1125.05.6245.05.6165.05.6385.05.63
5.55.1225.55.6145.55.6165.55.6385.55.63
6.05.1426.05.6146.05.6166.05.6386.05.63
6.5
5.1726.55.6046.55.6166.55.6386.55.63
7.05.2027.05.6047.05.6167.05.6387.05.63
7.55.2427.55.6047.55.6167.55.6387.55.63
8.05.2728.05.5948.05.6268.05.6388.05.63
8.55.3128.55.5948.55.6268.55.6388.55.64
9.05.3429.05.5949.05.6269.05.6389.05.64
9.55.3729.55.5949.55.6269.55.6389.55.64
10.05.4030.05.5950.05.6270.05.6390.05.64
10.55.4330.55.5950.55.6270.55.6390.55.64
11.05.4631.05.5951.05.6271.05.6391.05.64
11.55.4831.55.5951.55.6271.55.6391.55.64
12.05.5032.05.5952.05.6272.05.6392.05.64
12.55.5332.55.5952.55.6272.55.6392.55.64
13.05.5533.05.6053.0
5.6273.05.6393.05.64
13.55.5633.55.6053.55.6273.55.6393.55.64
14.05.5834.05.6054.05.6274.05.6394.05.64
14.55.5934.55.6054.55.6274.55.6394.55.64
15.05.6135.05.6055.05.6275.05.6395.05.64
15.55.6235.55.6055.55.6275.55.6395.55.64
16.05.6336.05.6056.05.6276.05.6396.05.64
16.55.6436.55.6056.55.6276.55.6396.55.64
17.05.6437.05.6057.05.6277.05.6397.05.64
17.55.6537.55.6057.55.6277.55.6397.55.64
18.05.6538.05.6058.05.6278.05.6398.05.64
18.55.6638.55.6058.55.6278.55.6398.55.64
19.05.6639.05.6059.05.6279.05.6399.05.64
19.55.6639.55.6159.55.6279.55.6399.5
5.64
20.05.6640.05.6160.05.6280.05.63100.05.64

Bulletin No. 2024–24 1615 June 10, 2024
Domestic Content Bonus
Credit Amounts under
the Inflation Reduction
Act of 2022: Expansion
of Applicable Projects
for Safe Harbor in Notice
2023-38 and New Elective
Safe Harbor to Determine
Cost Percentages for
Adjusted Percentage Rule
Notice 2024-41
SECTION 1. PURPOSE
This notice modifies section 3.04 of
Notice 2023-38, 2023-22 I.R.B. 872, in
three ways. First, this notice expands
the list of Applicable Projects in “Table
2—Categorization of Applicable Project
Components” (Table 2) to include hydro-
power and pumped hydropower storage
facilities. Second, this notice redesignates
the “Utility scale photovoltaic system”
Applicable Project as the “Ground-mount
and rooftop photovoltaic system.” Third,
this notice includes certain Manufactured
Product Components with respect to pre-
viously listed Applicable Projects. This
notice also provides a new safe harbor
that taxpayers may elect to use to classify
Applicable Project Components and to
calculate the Domestic Cost Percentage
in an Applicable Project (New Elective
Safe Harbor) to qualify for the domestic
content bonus credit amounts under §§ 45,
45Y, 48, and 48E of the Internal Revenue
Code (Code).
1
Taxpayers may elect to use
the classifications and cost percentages in
the New Elective Safe Harbor in lieu of
the Domestic Manufactured Products and
Components Cost and Total Manufactured
Products Cost provisions of the Adjusted
Percentage Rule in section 3.03(2)(b) and
(c) of Notice 2023-38, which provisions
require taxpayers to use the manufactur-
er’s direct costs of producing Manufac-
tured Products and Manufactured Product
Components in an Applicable Project. Tax-
payers who elect to use the New Elective
Safe Harbor for any Applicable Project
must use the classifications and cost per-
centages provided under the New Elective
Safe Harbor when applying the Adjusted
Percentage Rule and may not use a differ-
ent method or substitute any cost percent-
ages into the provided table to determine
any classifications and costs. Finally, this
notice requests comments to inform any
potential updates to Table 2 and the New
Elective Safe Harbor. Although this notice
does not address or modify provisions
other than sections 3.03(2)(b) and (c) and
3.04 of Notice 2023-38, the Department
of the Treasury (Treasury Department)
and the Internal Revenue Service (IRS)
intend to consider comments received on
other sections of the notice in the context
of forthcoming proposed regulations or
any further guidance regarding the domes-
tic content bonus requirements. Taxpayers
may rely on Notice 2023-38, as modified
by this notice, for the domestic content
bonus credit requirements for any Appli-
cable Project the construction of which
begins before the date that is 90 days after
the date of publication of the forthcom-
ing proposed regulations on the domestic
content bonus credit requirements in the
Federal Register. Taxpayers may rely on
the New Elective Safe Harbor provided
in Table 1 of this notice for the domes-
tic content bonus credit requirements for
any Applicable Project the construction
of which begins before the date that is 90
days after any future modification, update,
or withdrawal of the New Elective Safe
Harbor.
SECTION 2. BACKGROUND
Public Law 117-169, 136 Stat. 1818
(August 16, 2022), commonly known
as the Inflation Reduction Act of 2022
(IRA), amended §§ 45 and 48 to provide
a domestic content bonus credit amount
for certain qualified facilities or energy
projects placed in service after December
31, 2022, and added new §§ 45Y and 48E,
which include a domestic content bonus
credit amount for certain investments in
qualified facilities or energy storage tech-
nologies placed in service after December
31, 2024.
2

.01 Notice 2023-38. On May 12, 2023,
the Treasury Department and the IRS
released Notice 2023-38, which states
that the Treasury Department and the IRS
intend to propose regulations to address
the application of the rules that taxpayers
must satisfy to qualify for the domestic
content bonus credit amounts under §§ 45,
45Y, 48, and 48E, including related record-
keeping and certification requirements.
Notice 2023-38 also describes certain
rules that the Treasury Department and the
IRS intend to include in the forthcoming
proposed regulations and describes a safe
harbor regarding the classification of cer-
tain components in representative types
of qualified facilities, energy projects, or
energy storage technologies.
Section 2.01 of Notice 2023-38 pro-
vides that an Applicable Project refers to:
(i) a qualified facility under §§ 45 or 45Y;
(ii) an energy project under § 48, which
may include qualified property for which
a valid irrevocable election under § 48(a)
(5) has been made to treat such qualified
property as energy property under § 48; or
(iii) a qualified investment with respect to
a qualified facility or energy storage tech-
nology under § 48E. An Applicable Proj-
ect is eligible for a domestic content bonus
credit amount if the Applicable Project
satisfies the Domestic Content Require-
ment set forth in section 3 of Notice 2023-
38 and the taxpayer timely submits to the
IRS the Domestic Content Certification
Statement described in section 5 of Notice
2023-38. An Applicable Project satisfies
the Domestic Content Requirement if both
the Steel or Iron Requirement described
in section 3.02, and the Manufactured
Products Requirement described in sec-
tion 3.03, of Notice 2023-38 are satisfied.
To determine whether the Steel or Iron
Requirement and the Manufactured Prod-
ucts Requirement are met, a taxpayer must
first determine if each Applicable Project
Component (as defined in section 3.01(2)
(a) of Notice 2023-38) qualifies as steel,
iron, or a Manufactured Product. Section
3.04 of Notice 2023-38 provides a non-ex-
clusive safe harbor in Table 2 that taxpay-
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

Unless otherwise specified, capitalized terms used
throughout this notice are defined in Notice 2023-38.
2
See §§ 13101(g), 13701(a), 13102(l), and 13702(a) of the IRA, respectively, for the domestic content bonus credit amount requirements under §§ 45(b)(9), 45Y(g)(11), 48(a)(12), and 48E(a)
(3)(B).

June 10, 2024 1616 Bulletin No. 2024–24
ers may rely on for the classification of
certain Applicable Project Components as
steel, iron, or Manufactured Products.
.02 Manufactured Products Require-
ment and the Adjusted Percentage Rule.
Section 3.03 of Notice 2023-38 provides
that the Manufactured Products Require-
ment is met if all Applicable Project Com-
ponents that are Manufactured Products
are produced in the United States or are
deemed to be produced in the United
States. Manufactured Products are pro-
duced in the United States if all the man-
ufacturing processes for the Manufactured
Product take place in the United States
and all the Manufactured Product Com-
ponents are of U.S. origin. Manufactured
Products are deemed to be produced in the
United States if the Adjusted Percentage
Rule in section 3.03(2) of Notice 2023-38
is satisfied.
.03 Direct Costs in Adjusted Percent-
age Rule. In determining if the Adjusted
Percentage Rule is satisfied, the percent-
age produced by dividing the Domestic
Manufactured Products and Components
Cost (as described in section 3.03(2)
(b) of Notice 2023-38, and referred to as
the numerator in this notice) by the Total
Manufactured Products Cost (as described
in section 3.03(2)(c) of Notice 2023-38,
and referred to as the denominator in this
notice) is the Domestic Cost Percentage of
an Applicable Project, which must equal
or exceed the adjusted percentage that
applies to the Applicable Project to satisfy
the Adjusted Percentage Rule. To deter-
mine the costs to include in the numerator,
section 3.03(2)(b) of Notice 2023-38 pro-
vides that taxpayers must include direct
costs (direct materials and direct labor
costs as defined in § 1.263A-1(e)(2)(i))
that are paid or incurred within the mean-
ing of section 461 by the manufacturer to
produce U.S. Manufactured Products or
by the manufacturer of Non-U.S. Manu-
factured Products to produce or acquire
U.S. Components. Section 3.03(2)(b) of
Notice 2023-38 defines U.S. Components
as Manufactured Product Components
of Non-U.S. Manufactured Products that
are Applicable Project Components if
the Manufactured Product Components
are mined, produced, or manufactured in
the United States. To determine the costs
to include in the denominator, section
3.03(2)(c) of Notice 2023-38 provides that
taxpayers must include direct costs (direct
materials and direct labor costs as defined
in § 1.263A-1(e)(2)(i)) that are paid or
incurred within the meaning of section
461 by the manufacturer to produce U.S.
Manufactured Products or Non-U.S. Man-
ufactured Products.
SECTION 3. MODIFICATION OF
TABLE 2 IN SECTION 3.04 OF
NOTICE 2023-38
.01 Safe Harbor in Table 2 for Clas-
sifications of Certain Applicable Project
Components. Table 2 in section 3.04 of
Notice 2023-38 identifies certain Applica-
ble Project Components and Manufactured
Product Components that may be found in
the identified Applicable Projects, which
include utility-scale photovoltaic (PV)
systems, land-based wind facilities, off-
shore wind facilities, and battery energy
storage technologies. The categorization
of each item described in Table 2 as sub-
ject to either the Steel or Iron Requirement
or Manufactured Products Requirement is
based on analysis from the Federal Tran-
sit Administration (FTA), Department of
Transportation, with assistance from the
Department of Energy (DOE) and will be
accepted by the IRS for those Applicable
Project Components and Manufactured
Product Components.
.02 Modification of Table 2. Table 2 in
section 3.04 of Notice 2023-38 is modified
to add the following Applicable Project:
Table 2 – Categorization of Applicable Project Components
Applicable ProjectApplicable Project ComponentCategorization
Hydropower Facility, or Steel or iron rebar for the reservoirs, upper and/or lowerSteel/Iron
Pumped Hydropower Stor-
age Facility
Steel or iron rebar, plating, and piping in water conveyance (penstock
piping)
Steel/Iron
Steel or iron rebar in powerhouse and foundation, spiral case, discharge Steel/Iron
ring, and draft tube
Steel or iron rebar in canalsSteel/Iron
Powerhouse structure, gates, stoplogs, screens, and embedded structure Steel/Iron
parts, foundation plates and anchors
Turbine/Pump Runner (which includes the following Manufactured Manufactured Product
Product Components, if applicable: spiral/scroll case, vanes, bottom
ring, wicket gates, runner, draft tube, shaft, head cover, bearings, and
flow control and isolation mechanisms)
Motor/Generator (which includes the following Manufactured Product Manufactured Product
Components, if applicable: stator, rotor, windings, poles, generator
shaft, thrust bearing, brake ring/disc, guide bearings, ventilation and
cooling system, and exciter)
Generator Step-up Transformer (which includes the following Manu-Manufactured Product
factured Product Components, if applicable: containment/main tank,
cooling system, de-energized tap changer (DETC), load tap changer
(LTC), bushings/insulators)

Bulletin No. 2024–24 1617 June 10, 2024
Table 2 of Notice 2023-38 is further
modified by replacing “Utility-scale pho-
tovoltaic system” with “Ground-mount
and rooftop photovoltaic system.” Tax-
payers may treat any Applicable Project
Components or Manufactured Product
Components that are listed in Table 1
of this notice as also listed in Table 2 of
Notice 2023-38. To the extent Table 2 of
Notice 2023-38 and Table 1 of this notice
are inconsistent regarding the classifica-
tion of Applicable Project Components
or Manufactured Product Components,
Table 1 of this notice will control.
SECTION 4. NEW ELECTIVE SAFE
HARBOR
.01 In General. The new safe harbor
provided in this section applies to both
the Steel or Iron Requirement and the
Manufactured Products Requirement of
the Domestic Content Requirement for an
Applicable Project with respect to which
a taxpayer elects to have this safe harbor
apply. As described more fully in sections
2.03 and 2.04 of this notice, for purposes
of the Adjusted Percentage Rule and cal-
culating the Domestic Cost Percentage,
Notice 2023-38 requires that costs that
are included in the numerator and denom-
inator are the direct materials and direct
labor costs that are paid or incurred by
the manufacturer of the Manufactured
Product. Taxpayers are further required
to calculate the direct costs of any U.S.
Components that may have been incorpo-
rated into Non-U.S. Manufactured Prod-
ucts. The Treasury Department and the
IRS are aware that obtaining a manufac-
turer’s direct costs of manufacturing may
require the taxpayer to gather cost data
from multiple suppliers and manufactur-
ers, including foreign manufacturers, and
may present challenges for substantiation
and verification.
.02 New Elective Safe Harbor. The
Treasury Department and the IRS, in
consultation with the DOE, are providing
a new elective safe harbor in Table 1 of
section 4.04(1)-(3) of this notice (New
Elective Safe Harbor) that provides for
the classification of identified Applicable
Project Components, and the associated
cost percentages for each of the identified
Manufactured Products and Manufactured
Product Components (Assigned Cost
Percentages). Although the New Elec-
tive Safe Harbor is consistent with Table
2 of Notice 2023-38, as modified by this
notice, which provides classifications of
Applicable Project Components, the New
Elective Safe Harbor also provides cost
percentage information obtained from
the DOE for purposes of calculating the
Domestic Cost Percentage and satisfying
the Adjusted Percentage Rule. To gener-
ate the cost percentage information, the
DOE utilized cost data from a variety
of sources, including datasets of system
characteristics, price indices, U.S. sur-
vey data from the government (for exam-
ple, the U.S. Bureau of Labor Statistics,
Department of Labor) and private sector,
public filings from corporations, and com-
prehensive interviews of manufacturers,
installers, developers, and owners of the
representative technologies.
The classifications and cost percentages
provided in Table 1 of section 4.04(1)-(3)
of this notice will be accepted by the IRS
for the identified Manufactured Products
and Manufactured Product Components
for purposes of determining compliance
with the Steel or Iron Requirement and
calculating the Domestic Cost Percentage,
provided all other requirements in Notice
2023-38 are met. A taxpayer electing to
use the New Elective Safe Harbor with
respect to an Applicable Project of the
taxpayer must use the Applicable Project
Components and Manufactured Product
Components and the cost percentages
listed in Table 1 of section 4.04(1)-(3) of
this notice as the exclusive and exhaustive
set of Applicable Project Components and
Manufactured Product Components for
purposes of determining compliance with
the Domestic Content Requirement for the
Applicable Project with respect to which
the taxpayer makes this election.
To be eligible for the safe harbor,
Applicable Projects are not required to be
constituted of the full list of Applicable
Project Components provided in Table 1
of this notice, and each Applicable Proj-
ect Component listed is not required to be
constituted of the full list of Manufactured
Product Components provided in Table 1
of this notice. Taxpayers may still elect to
use the New Elective Safe Harbor even
if entries in Table 1 of this notice are not
used as inputs to their Applicable Projects
or Manufactured Products, or if the Appli-
cable Project contains additional inputs
not listed in Table 1 of this notice.
Any Applicable Project Component or
Manufactured Product Component listed
in Table 1 of this notice that is not uti-
lized as an input to the Applicable Project
must be treated by the electing taxpayer
as having a zero value in calculating the
Domestic Cost Percentage. An Applica-
ble Project Component or Manufactured
Product Component contained in a tax-
payer’s Applicable Project but not listed
in Table 1 of this notice will not disqualify
the taxpayer from using the New Elec-
tive Safe Harbor. However, such unlisted
items may not count toward satisfying the
Adjusted Percentage Rule. The absence of
a Manufactured Product or Manufactured
Product Component that is listed in Table
1 of this notice, or the presence of a Manu-
factured Product or Manufactured Product
Component that is not listed in Table 1 of
this notice, in an Applicable Project does
not affect the Assigned Cost Percentages
listed in Table 1 for purposes of the New
Elective Safe Harbor.
.03 New Elective Safe Harbor Require-
ments.

(1) In general. Unless otherwise pro-
vided in this notice, if a taxpayer elects to
use the New Elective Safe Harbor, all other
provisions of Notice 2023-38 apply in
determining whether an Applicable Proj-
ect meets the Domestic Content Require-
ment. For example, the Applicable Proj-
ects and Applicable Project Components
described in Table 1 of section 4.04(1)-(3)
of this notice must satisfy the Steel or Iron
Requirement described in section 3.02 of
Notice 2023-38 with respect to the Appli-
cable Project Components that are speci-
fied as subject to the Steel or Iron Require-
ment in Table 1 of this notice. See section
4.08 for the New Elective Safe Harbor’s
election and certification requirements.
(2) No Partial Safe Harbor Reliance.
Taxpayers that elect to use the New Elec-
tive Safe Harbor must apply in its entirety
the section of Table 1 of this notice that is
specific to the Applicable Project for which
the taxpayer makes such election. For
example, if a taxpayer’s Applicable Project
is a land-based wind facility, the taxpayer
must use the classifications for Applicable
Project Components and Manufactured
Product Components in Table 1 of this
notice with respect to land-based wind

June 10, 2024 1618 Bulletin No. 2024–24
and must use the Assigned Cost Percent-
ages for all the Manufactured Products and
Manufactured Product Components (for
example, Blades, Rotor Hub, Nacelle, and
Power Converter) provided in Table 1 of
this notice that are utilized in the taxpayer’s
Applicable Project without substitution.
(3) Determining Domestic Cost Per-
centage. To determine the Domestic Cost
Percentage using the New Elective Safe
Harbor, a taxpayer must refer to the sec-
tion of Table 1 of this notice that describes
their Applicable Project and add up the
Assigned Cost Percentages for each listed
U.S. Manufactured Product (as defined in
section 3.03(1) of Notice 2023-38) and
U.S. Component (as described in section
3.03(2)(b) of Notice 2023-38) of their
Applicable Project. This total value is the
Domestic Cost Percentage for purposes of
the New Elective Safe Harbor. Any Manu-
factured Product or Manufactured Product
Component listed in Table 1 of this notice
that is not a part of the taxpayer’s Appli-
cable Project must take a zero value for
the Assigned Cost Percentage under the
New Elective Safe Harbor for such Manu-
factured Product or Manufactured Product
Component, with all Assigned Cost Per-
centages shown in Table 1 of this notice
remaining unchanged. Any Manufactured
Product or Manufactured Product Com-
ponent not listed in Table 1 of this notice
must be disregarded for purposes of deter-
mining the Domestic Cost Percentage
using the New Elective Safe Harbor.
(4) Foreign- and Domestic-Sourced
Manufactured Products and/or Manufac-
tured Product Components. Taxpayers
who source the same type of Manufac-
tured Product or Manufactured Product
Component (that is, they are listed in the
same row of Table 1 of this notice) from
both foreign and domestic sources (Mixed
Source Item or MSI) in a particular Appli-
cable Project described in Table 1 of this
notice may use the New Elective Safe
Harbor to determine a single Assigned
Cost Percentage for each separate type
of Mixed Source Item in the Applica-
ble Project. For Mixed Source Items that
have a nameplate capacity, the following
weighted average formula may be used to
determine the Assigned Cost Percentage
attributable to each type of Mixed Source
Item:
DCP
Domestic MSI
× Nameplate Capacity
Domestic MSI
Nameplate Capacity
MSI
For purposes of this formula:
(a) DCP
Domestic MSI
means the Assigned
Cost Percentage derived from Table 1 of
this notice of the Mixed Source Item.
(b) Nameplate Capacity
DomesticMSI
means
the nameplate capacity of the Mixed
Source Item of the same type in the
Applicable Project that is produced in the
United States.
(c) Nameplate Capacity
MSI
means the
total nameplate capacity of the Mixed
Source Items of the same type in the
Applicable Project.
For Mixed Source Items without name-
plate capacities, the portion of cost per-
centage provided in Table 1 of this notice
that may count toward the Domestic Cost
Percentage must be calculated by using
the weighted average formula described
above, modified by replacing the name-
plate capacity of the Mixed Source Item
with the nameplate capacities of the
associated Applicable Project Compo-
nents with which the Mixed Source Item
is directly integrated. For this purpose,
Mixed Source Items without nameplate
capacities must apply: the total nameplate
capacity of the associated PV module(s)
for the Solar PV Table; the total name-
plate capacity of the associated wind
turbine for land-based wind; or the total
nameplate capacity of the battery pack(s)
for Battery Electric Storage Systems.
If a type of Mixed Source Item without
nameplate capacity has multiple units that
are both foreign- and domestic-sourced
associated and directly integrated with
the same Applicable Project Component
with nameplate capacity, then all such
Mixed Source Items must be treated as
foreign-sourced.
(5) Production Costs. Table 1 of this
notice contains a line item for “Produc-
tion,” which, although listed under the
column for Manufactured Product Com-
ponents, is not a Manufactured Product
Component. “Production” refers to the
production cost of the relevant Manufac-
tured Product and can be included in the
total Domestic Cost Percentage only if all
the Manufactured Product Components of
a Manufactured Product are domestically
produced. See Notice 2023-38, section
3.03(2). The Assigned Cost Percentage
attributable to production costs for a par-
ticular Manufactured Product may be used
if such Manufactured Product contains
Manufactured Product Components not
listed in Table 1 of this notice or if entries
in Table 1 of this notice are not a part of
such Manufactured Product, so long as the
remainder of the Manufactured Product
Components in Table 1 that are a part of
such Manufactured Product are mined,
produced, or manufactured in the United
States.
(6) Solar Energy Property and Energy
Storage Technology as Part of a Single
Energy Project. Taxpayers who wish to
claim the energy credit determined under
§ 48 with respect to an energy project that
is comprised of a solar photovoltaic sys-
tem (solar PV) and battery energy stor-
age system (BESS) described in Table 1
of this notice may use the New Elective
Safe Harbor and the BESS Multiplier as
described below and in section 4.05 of
this notice to determine a single Domestic
Cost Percentage, for a single energy proj-
ect, using a weighted average formula as
follows:
Domestic Cost Percentage =
(DCP
PV
x Nameplate Capacity
PVkW
) + (DCP
BESS
× Nameplate Capacity
BESSkWh
× BESS Multiplier)
Nameplate Capacity
PVkW
+ (Nameplate Capacity
BESSkWh
× BESS Multiplier)

Bulletin No. 2024–24 1619 June 10, 2024
This formula may be applied only to
Applicable Projects that are § 48 energy
projects that are comprised of solar PV and
BESS. The portion of an Applicable Proj-
ect that relates to solar PV, for example,
refers to the solar PV assets in such energy
project. For purposes of this formula:
(a) DCP
PV
means the total Assigned
Cost Percentage derived from Table 1 of
this notice associated with the U.S. Man-
ufactured Products and U.S. Components
of the solar PV portion of the Applicable
Project.
(b) Nameplate Capacity
PVkW
means the
nameplate capacity of the solar PV por-
tion of the Applicable Project, measured
in kilowatts of direct current.
(c) DCP
BESS
means the total Assigned
Cost Percentage derived from Table 1 of
this notice associated with the U.S. Manu-
factured Products and U.S. Components of
the BESS portion of the Applicable Project.
(d) Nameplate Capacity
BESSkWh
means
the nameplate capacity of the BESS por-
tion of the Applicable Project, measured
in kilowatt-hours of stored energy.
(e) BESS Multiplier means the value used
to convert BESS nameplate capacity into
proportional equivalency to the nameplate
capacity of solar PV for weighting costs.
(7) Exclusive Safe Harbor. A taxpayer
that elects to use the New Elective Safe
Harbor with respect to an Applicable Proj-
ect must consider the steel or iron products,
Manufactured Products, and Manufactured
Product Components that are identified in
Table 1 of this notice as an exclusive and
exhaustive set of steel or iron products,
Manufactured Products, and Manufac-
tured Product Components for purposes of
determining compliance with the Domestic
Content Requirement for that Applicable
Project. The New Elective Safe Harbor
may still be used in instances in which a
taxpayer’s Applicable Project does not con-
tain every item identified in Table 1 of this
notice, or in which a taxpayer’s Applicable
Project contains additional items not iden-
tified in Table 1 of this notice, provided the
taxpayer applies the rules for determining
Domestic Cost Percentage described in
section 4.03(3) of this notice.
(8) Certification. Taxpayers must affir-
matively elect to rely on the New Elective
Safe Harbor in Table 1 of this notice and
must notify the IRS of this election by pro-
viding information on the Domestic Con-
tent Certification Statement as described
in section 4.08 of this notice.
.04 Table 1—New Elective Safe Harbor.

June 10, 2024 1620 Bulletin No. 2024–24
Table 1
(1) SOLAR PV TABLE
APCMPCGround-mount
(Tracking)
Ground-mount
(Fixed)
Rooftop
(MLPE)
Rooftop
(String)
PV module
Cells36.949.221.530.8
Frame/Backrail5.37.03.14.4
Front Glass3.74.92.23.1
Encapsulant2.23.01.31.8
Backsheet/Backglass3.74.92.13.1
Junction Box1.62.21.01.4
Edge Seals0.20.20.10.2
Pottants0.20.20.10.2
Adhesives0.20.20.10.2
Bus Ribbons0.40.50.20.3
Bypass Diodes0.40.50.20.3
Production
3
11.5
4
15.3
4
6.7
4
9.6
4
Inverter
Printed Circuit Board Assemblies3.04.016.0
5
2.5
Electrical Parts
6
1.01.31.61.1
Climate Control0.70.9-0.3
Enclosure1.01.31.60.8
Production3.3
4
4.4
4
16.4
4
2.9
4
PV Tracker or
Non-Steel Roof
Racking
Torque tube9.7---
Fasteners0.4-11.116.0
Slew Drive2.0---
Dampers0.4---
Motor3.1---
Controller0.9---
Rails2.0-8.612.3
Production6.2
4
-6.1
4
8.7
4
Steel photo-
voltaic module
racking
--Steel/Iron
Product
--
Pile or ground
screw
-Steel/Iron
Product
Steel/Iron
Product
--
Steel or iron
rebar in foun-
dation
-Steel/Iron
Product
Steel/Iron
Product
--
Total-100100100100
3
Although “Production” is listed under the column for Manufactured Product Components (MPCs), it is not an MPC.

“Production” refers to the production cost of the Manufactured Product
and can only be included in the Domestic Cost Percentage if all of the MPCs of a Manufactured Product are domestically produced.

See section 3.03(2) of Notice 2023-38.

4
Consistent with Notice 2023-38, the direct cost of producing a Manufactured Product counts toward the Domestic Cost Percentage only if all its Manufactured Product Components are
domestically produced.
5
For purposes of this table, module-level power electronics inverter systems, including either microinverters or direct current (DC) optimizers, are considered an inverter product.
6
Includes transformers, capacitors, inductors, bus/cables, circuit protection not on printed circuit board (PCB) assemblies.

Bulletin No. 2024–24 1621 June 10, 2024
(2) LAND-BASED WIND TABLE
APCMPCValue
Wind Turbine
Blades31.2
Rotor Hub9.9
Nacelle47.5
Power Converter8.9
Production0.9
7
Wind Tower Flanges
Material
8
0.8
Production0.8
7
Tower
-Steel/Iron Product
Steel or iron rebar in foundation
-Steel/Iron Product
Total-100
(3) BATTERY ELECTRIC STORAGE SYSTEM (BESS) TABLE
APCMPC Grid-scale BESSDistributed BESS
Battery Pack
Cells38.018.1
Packaging3.330.1
Thermal Management
System
4.99.0
Battery Management System5.29.0
Production21.1
7
27.3
7
Inverter
Printed Circuit Board
Assemblies
1.73.8
Electrical Parts
9
0.60.4
Climate Control0.4-
Enclosure0.60.4
Production1.9
7
1.9
7
Battery Container/Housing
Battery Racks and Metal
Enclosure
15.8-
Production6.5
7
-
Steel or iron rebar in foundation
-Steel/Iron Product-
Total
-
100100
.05 Battery Energy Storage System
(BESS) Multiplier. Solar PV and BESS
systems have nameplate capacities
denominated in different units (that is, kW
versus kWh). Because the New Elective
Safe Harbor was produced using name-
plate capacity, the DOE has advised that
a multiplier for BESS nameplate capacity
is appropriate to align the different solar
energy property listed in Table 1 of this
notice. Taxpayers may use the BESS Mul-
tiplier only with respect to energy projects
described in section 4.03(6) of this notice
for which they make a valid election to
use the New Elective Safe Harbor.
PV MarketGround-mount
(tracker)
Ground-mount
(fixed-tilt)
Rooftop
(MLPE)
Rooftop (string
inverter)
Multiplier
0.570.750.690.99
7
Consistent with Notice 2023-38, the direct cost of producing a Manufactured Product counts toward the Domestic Cost Percentage only if all its Manufactured Product Components are
domestically produced.
8
Flanges are typically made from single pieces of steel bar or pre-formed steel ingot; therefore the only component of a flange would be the steel material.
9
Includes transformers, capacitors, inductors, bus/cables, circuit protection not on PCB assemblies.

June 10, 2024 1622 Bulletin No. 2024–24
.06 Definitions.
(1) Land-based wind. The term “land-
based wind” refers to an energy system
using wind turbines to generate electricity
on land.
(2) Ground-mounted PV (tracker).
The term “ground-mounted PV (tracker)”
refers to an energy system using photovol-
taic solar modules to generate electricity,
mounted to a non-pre-existing, non-build-
ing structure, which integrates a solar
tracker to rotate the solar modules.
(3) Ground-mounted PV (fixed-tilt).
The term “ground-mounted PV (fixed-
tilt)” refers to an energy system using solar
modules to generate electricity, mounted
to a non-pre-existing, non-building struc-
ture, where the PV modules are mounted
at a fixed angle and orientation.
(4) Rooftop PV (MLPE). The term
“rooftop PV (MLPE)” refers to an energy
system using PV solar modules to gener-
ate electricity, mounted to a building struc-
ture, which integrates one or more micro-
inverters or uses a DC-optimized inverter
system to convert direct current electricity
into alternating current electricity.
(5) Rooftop PV (string inverter). The
term “rooftop PV (string inverter)” refers
to an energy system using solar mod-
ules to generate electricity, mounted to a
building structure, which integrates one
or more inverters to convert direct current
electricity from a string of solar panels
into alternating current electricity.
(6) Grid-scale BESS. The term “grid-
scale BESS” refers to an energy storage
system for electricity generation using
battery cells and battery modules, which
has a nameplate capacity greater than 1
megawatt-hour.
(7) Distributed BESS. The term “dis-
tributed BESS” refers to an energy stor-
age system for electricity generation using
battery cells and battery modules, which
has a nameplate capacity not greater than
1 megawatt-hour.
.07 Examples. The following examples
illustrate the application of the New Elec-
tive Safe Harbor in Table 1 of this notice:
(1) Example 1.
(a) In taxable year 2024, taxpayer purchases a
5-megawatt alternating current (MWac) land-based
wind facility (Applicable Project A) from Contractor
under an engineering, procurement, and construc-
tion contract (EPC contract) and places Applicable
Project A in service. Taxpayer makes a valid elec-
tion to use the New Elective Safe Harbor to qualify
for the domestic content bonus credit amount under
§ 45. Applicable Project A is comprised of four
Applicable Project Components identified in Table
1 of this notice: wind turbine, wind tower flanges,
tower, and steel rebar in foundation. For taxable year
2024, § 45(b)(9)(C) provides that, for purposes of the
Adjusted Percentage Rule, the adjusted percentage is
40 percent for qualified facilities that are not offshore
wind facilities.
(b) Taxpayer identifies the tower and steel rebar
in foundation as steel or iron products in accordance
with Table 1 of this notice. The tower and steel rebar
in foundation are manufactured in the United States
and meet the Steel or Iron Requirement described in
section 3.02 of Notice 2023-38.
(c) Taxpayer identifies the wind turbine and the
wind tower flanges as Manufactured Products in
accordance with Table 1 of this notice.
(d) The wind turbine is manufactured in the
United States and has four Manufactured Product
Components: blades, rotor hub, nacelle, and power
converter. The blades and nacelles are manufac-
tured in the United States and the rotor hub and
power converter are not manufactured in the United
States. The wind turbine is, therefore, a Non-U.S.
Manufactured Product because some of its Manu-
factured Product Components are not produced in
the United States.
(e) The wind tower flanges are not manufactured
in the United States and therefore are Non-U.S. Man-
ufactured Products.
(f) Two Manufactured Product Components
identified in Table 1 of this notice are U.S. Com-
ponents, namely, the blades and nacelle of the wind
turbine. Table 1 of this notice identifies the blades
as constituting 31.2% and the nacelle as constituting
47.5% of the total cost of the Manufactured Products
of the land-based wind facility. Therefore, Applica-
ble Project A satisfies the Adjusted Percentage Rule
because its Domestic Cost Percentage of 78.7%
(31.2% + 47.5%) exceeds the adjusted percentage
that applies to Applicable Project A (40%).
(2) Example 1.1. Assume the same facts as in
Example 1, except Applicable Project A includes an
interconnection transformer and substation. Because
an interconnection transformer and substation are
not included in Table 1 of this notice, and the tax-
payer elected to use the New Elective Safe Harbor,
the interconnection transformer and substation are
excluded from the Domestic Cost Percentage cal-
culation. Applicable Project A satisfies the Adjusted
Percentage Rule because its Domestic Cost Percent-
age of 78.7% (31.2% + 47.5%) exceeds the adjusted
percentage that applies to Applicable Project A
(40%).
(3) Example 2.
(a) In taxable year 2024, Taxpayer purchases
a 100-megawatt direct current (MWdc) ground-
mounted PV (tracker) (Applicable Project B) from
Contractor under an EPC contract, places the proj-
ect in service, and makes a valid election to use the
New Elective Safe Harbor to qualify for the domes-
tic content bonus credit amount under § 48. Appli-
cable Project B is an energy project for purposes of
§ 48 that is comprised of five categories of Appli-
cable Project Components identified in Table 1 in
this notice for a ground-mounted PV (tracker): PV
modules, inverters, PV trackers, steel piles, and steel
rebar in foundation. For purposes of the Adjusted
Percentage Rule, the adjusted percentage is 40 per-
cent for energy projects that are not offshore wind
facilities. See § 48(a)(12)(B).
(b) In accordance with Table 1 of this notice,
taxpayer identifies the steel piles and steel rebar
in foundation as steel or iron products and the PV
modules, inverters, and PV trackers as Manufactured
Products.
(c) All of the steel piles and steel rebar in founda-
tion are manufactured in the United States and meet
the Steel or Iron Requirement.
(d) Two sets of PV modules are used in the
Applicable Project B. One set has a capacity of 60
MWdc and uses PV modules manufactured in the
United States, all of whose Manufactured Product
Components, as identified in accordance with Table
1 of this notice, are also manufactured in the United
States. The remaining set has a capacity of 40 MWdc
and uses PV modules that are not manufactured in
the United States and that have no U.S. Components.
None of Applicable Project B’s PV inverters are
manufactured in the United States or have any U.S.
Components.
(e) The PV trackers used in Applicable Project
B are manufactured in the United States and have
seven categories of Manufactured Product Compo-
nents (torque tubes, fasteners, slew drives, dampers,
motor, controllers, and rails) of which a portion of
the torque tubes are manufactured in the United
States. The PV trackers are associated and directly
integrated with all the PV modules used in Applica-
ble Project B. The torque tubes manufactured in the
United States are the only torque tubes associated
and directly integrated with 80 MWdc of Applicable
Project B’s PV modules. The remainder of torque
tubes and other PV tracker components are not man-
ufactured in the United States. The PV trackers are
Non-U.S. Manufactured Products because some of
their Manufactured Product Components are not pro-
duced in the United States.
(f) Applicable Project B’s steel or iron products
identified in Table 1 of this notice meet the Steel
or Iron Requirement. Table 1 of this notice iden-
tifies the torque tube Manufactured Product Com-
ponent of a PV tracker as constituting 9.7% of the
total cost of manufactured products for this type
of Applicable Project. Table 1 of this notice iden-
tifies the Manufactured Product Components of a
PV module as constituting 54.8% (36.9% + 5.3%
+ 3.7% + 2.2% + 3.7% + 1.6% + 0.2% + 0.2% +
0.2% + 0.4% + 0.4%) of the total cost of Manufac-
tured Products for an Applicable Project that is a
ground-mounted PV (tracker). In addition to these
costs, Table 1 of this notice provides that the cost to
produce PV modules for such an Applicable Project
constitutes 11.5% of the total cost of Manufactured
Products for such an Applicable Project. Based on a
nameplate capacity weighted average of Applicable
Project Component categories and Manufactured
Product Component categories identified in Table
1 of this notice, the total Assigned Cost Percentage
attributable to the PV modules of Applicable Proj-
ect B would be calculated as: (54.8% + 11.5%) x
60 / 100 = 39.8%. Based on a nameplate capacity
weighted average of Applicable Project Compo-
nents associated with torque tubes, the Assigned
Cost Percentage attributable to the torque tubes of
Applicable Project B would be calculated as: 9.7%
x 80 / 100 = 7.8%. Applicable Project B’s over-
all Domestic Cost Percentage is: 39.8% + 7.8% =

Bulletin No. 2024–24 1623 June 10, 2024
47.6%. Applicable Project B satisfies the Adjusted
Percentage Rule because its Domestic Cost Per-
centage of 47.6% exceeds the adjusted percentage
that applies to Applicable Project B (40%).
(4) Example 3.
(a) Assume the same facts as in Example 2,
except that the PV modules used in Applicable Proj-
ect B do not include backrails, but instead include
another Manufactured Product Component not men-
tioned in Table 1 of this notice. In this case, the total
Assigned Content Percentage associated with PV
modules would be lowered by 5.3 percentage points.
However, because all of the other components listed
in Table 1 of this notice are in the PV modules and
are manufactured in the United States, the PV mod-
ules are still considered to have been manufactured
in the United States. Any component not mentioned
in Table 1 of this notice may not count toward satis-
fying the Adjusted Percentage Rule.
(b) The calculation of the new Assigned Cost Per-
centage attributable to the PV modules of Applicable
Project B is as follows: (54.8% - 5.3% + 11.5%) x
60 / 100 = 36.6%. The Assigned Cost Percentage
attributable to the torque tubes of Applicable Project
B is 7.8%. Applicable Project B’s overall Domestic
Cost Percentage is 36.6% + 7.8% = 44.4%. The proj-
ect satisfies the Adjusted Percentage Rule because
its Domestic Cost Percentage of 44.4% exceeds the
adjusted percentage that applies to Applicable Proj-
ect B (40%).
(5) Example 4.
(a) Assume the same facts as in Example 2,
except that the § 48 energy project (Applicable Proj-
ect C) also includes a 240 MWh grid-scale BESS.
The grid-scale BESS is comprised of four categories
of Applicable Project Components identified in Table
1 of this notice: battery packs, battery inverters, bat-
tery container/housing, and steel rebar in foundation.
(b) In accordance with Table 1 of this notice,
Taxpayer identifies the steel rebar in foundation as
steel or iron products and the battery pack, battery
inverters, and battery container/housing as Manufac-
tured Products.
(c) All of the steel rebar in foundation is man-
ufactured in the United States and meets the Steel
or Iron Requirement. The battery packs and battery
container/housing are manufactured in the United
States and all their Manufactured Product Compo-
nents, as identified in accordance with Table 1 of this
notice, are manufactured in the United States, except
for the battery packs’ cells. The battery container/
housing is a U.S. Manufactured Product and the bat-
tery packs are Non-U.S. Manufactured Products with
U.S. Components.
(d) None of the battery inverters or their compo-
nents were manufactured in the United States. All of
the inverters are therefore Non-U.S. Manufactured
Products and the components of the inverters are not
U.S. Components.
(e) Taxpayer elects to use the New Elective Safe
Harbor to qualify for the domestic content bonus
credit amounts under § 48. All of Applicable Proj-
ect C’s steel or iron products identified in Table 1
of this notice meet the Steel or Iron Requirement.
The solar PV portion of Applicable Project C has an
Assigned Cost Percentage of 47.6%, as calculated in
Example 2. Table 1 of this notice identifies the non-
cell Manufactured Product Components of a battery
pack as constituting 13.4% of the total cost of Man-
ufactured Products within a grid-scale BESS. Table
1 of this notice identifies the Manufactured Product
Component of a battery container/housing as con-
stituting 15.8% of the total cost of Manufactured
Products within a grid-scale BESS. Table 1 of this
notice also identifies the cost to produce battery con-
tainers/housings for a grid-scale BESS (Production)
as constituting 6.5% of the total cost of Manufac-
tured Products within a grid-scale BESS. The BESS
portion of Applicable Project C has a total Assigned
Cost Percentage of 35.7% (13.4% + 15.8% + 6.5%).
(f) The overall Domestic Cost Percentage of
Applicable Project C, comprising the 100

MWdc PV
system and 240 megawatt-hours BESS, is calculated
based on application of the relative capacities of each
portion of the Applicable Project and the appropriate
BESS Multiplier from section 4.05 of this notice,
as follows: (47.6% x 100 + 35.7% x 240 x 0.57) /
(100 + 240 x 0.57) = 40.7%. Applicable Project C
satisfies the Adjusted Percentage Rule because its
overall Domestic Cost Percentage of 40.7% exceeds
the adjusted percentage that applies to Applicable
Project C (40%).
(6) Example 5.
(a) In taxable year 2024, Taxpayer purchases a
10-kilowatt direct current (kWdc) rooftop PV solar
system with a DC optimized inverter system (Appli-
cable Project D) from Contractor under an EPC con-
tract and places the project in service. Applicable
Project D is an energy project for purposes of section
48 that is comprised of three categories of Applicable
Project Components identified in Table 1 of this notice
for a rooftop PV (MLPE): PV modules, DC optimized
inverter system, and non-steel roof racking.
(b) The non-steel roof racking used in Applicable
Project D is manufactured in the United States and
has two categories of Manufactured Product Com-
ponents (fasteners and rails) of which only the rails
are manufactured in the United States. The non-steel
roof racking is a Non-U.S. Manufactured Product
because some of its Manufactured Product Compo-
nents are not produced in the United States.
(c) Applicable Project D uses PV modules man-
ufactured in the United States, of which only the
PV cells are manufactured in the United States. The
PV modules are Non-U.S. Manufactured Products
because some of their Manufactured Product Com-
ponents are not produced in the United States.
(d) Applicable Project D uses a DC optimized
inverter system. The inverter and the DC optimizers
are manufactured in the United States. The inverter
uses printed circuit board assemblies produced in the
United States; the DC optimizers use printed circuit
board assemblies not produced in the United States.
(e) Taxpayer makes a valid election to use
the New Elective Safe Harbor to qualify for the
domestic content bonus credit amount under § 48.
The PV cells in Applicable Project D are U.S.
Components of the PV module. Table 1 of this
notice identifies the PV cell Manufactured Product
Component of a PV module as constituting 21.5%
of the total cost of manufactured products for this
type of Applicable Project. The rails in Applicable
Project D are U.S. Components of the non-steel
roof racking. Table 1 of this notice identifies the
rails as constituting 8.6% of the total cost of manu-
factured products for this type of Applicable Proj-
ect. The printed circuit board assemblies in Project
D are both U.S. Components and Manufactured
Product Components that are not produced in the
United States of a DC optimized inverter system.
Table 1 of this notice identifies the printed circuit
board assemblies of an inverter as constituting
16.0% of the total cost of manufactured products
for this type of Applicable Project. However, the
individual printed circuit board assemblies do not
have nameplate capacities and cannot be separated
into exclusively foreign and exclusively domes-
tic portions using the nameplate capacity of the
associated Applicable Project Components with
nameplate capacities with which they are directly
integrated. Therefore, Applicable Project D cannot
receive any credit for the domestically produced
printed circuit board assemblies under the New
Elective Safe Harbor.
(f) Applicable Project D’s overall Domestic Cost
Percentage is: 21.5% + 8.6%= 30.1%. Applicable
Project D does not satisfy the Adjusted Percentage
Rule because its Domestic Cost Percentage of 30.1%
is below the adjusted percentage that applies to
Applicable Project D (40%).
.08 Certification. An Applicable Proj-
ect is eligible for a domestic content bonus
credit amount if the Applicable Project sat-
isfies the Domestic Content Requirement
and the taxpayer timely submits to the IRS
the certification described in section 5 of
Notice 2023-38. To affirmatively elect to
rely on the New Elective Safe Harbor, a
taxpayer must provide on the Domestic
Content Certification Statement described
in section 5.01(2)(c) of Notice 2023-38
a statement that the taxpayer is relying
on the New Elective Safe Harbor. As
provided in section 5.01(2)(b) of Notice
2023-38, the Domestic Content Certifica-
tion Statement must be attached to Form
8835, Renewable Electricity Product
Credit; Form 3468, Investment Credit;
or other applicable form for reporting
domestic content bonus credit amounts
under §§ 45, 45Y, 48, or 48E filed with the
taxpayer’s annual return submitted to the
IRS for the first taxable year in which the
taxpayer reports a domestic content bonus
credit amount for such Applicable Project.
SECTION 5. SUBSTANTIATION
A taxpayer reporting a domestic
content bonus credit amount for meet-
ing the Domestic Content Requirement
must meet the general recordkeeping
requirements under § 6001 in order to
substantiate that the Domestic Content
Requirement has been met. Section 6001
provides that every person liable for any
tax imposed by the Code, or for the col-
lection thereof, must keep such records
as the Secretary of the Treasury or her

June 10, 2024 1624 Bulletin No. 2024–24
delegate may from time to time pre-
scribe. Section 1.6001-1(a) provides that
any person subject to income tax must
keep such permanent books of account
or records as are sufficient to establish
the amount of gross income, deductions,
credits, or other matters required to be
shown by such person in any return of
such tax. Section 1.6001-1(e) provides
that the books and records required by
§ 1.6001-1 must be retained so long as
the contents thereof may become mate-
rial in the administration of any internal
revenue law. See also §§ 45(b)(12), 48(a)
(16), 48E(a)(3)(B) (by cross-reference to
§ 48(a)(12)), and 45Y(f).
SECTION 6. REQUEST FOR
COMMENTS
The Treasury Department and the IRS
may consider updates to the New Elec-
tive Safe Harbor and request comments
with respect to the following specific
questions, in addition to general com-
ments regarding the New Elective Safe
Harbor, to inform the development of any
future updates:
(1) Are there any other technologies,
or technology subsets, that should be
addressed by Table 1 of this notice, and
what criteria should be used for new addi-
tions? How often should these tables be
updated?
(2) Are there instances in which the
nameplate capacity allocation approach
in section 4.03 of this notice for calcu-
lating domestic content for a mix of for-
eign and domestic Manufactured Product
Components should be clarified, either for
current technologies or technologies that
may be addressed in the future? In those
instances, how should the Assigned Cost
Percentages be allocated to Applicable
Project Components with a mix of for-
eign and domestic Manufactured Product
Components?
SECTION 7. PROCEDURES FOR
SUBMITTING COMMENTS
.01 Deadline. Written comments should
be submitted by July 15, 2024. However,
consideration will be given to any written
comments submitted after July 15, 2024,
if such consideration will not delay the
issuance of future published guidance.
.02 Form and Manner. The subject line
for the comments should include a refer-
ence to Notice 2024-41. All stakeholders
are strongly encouraged to submit com-
ments electronically. Comments may be
submitted in one of two ways:
(1) Electronically via the Federal
eRulemaking Portal at https://www.reg-
ulations.gov (type IRS-2024-0023 in the
search field on the https://www.regula-
tions.gov homepage to find this notice and
submit comments).
(2) By mail to: Internal Revenue Ser-
vice, CC:PA:LPD:PR (Notice 2024-41),
Room 5203, P.O. Box 7604, Ben Franklin
Station, Washington, DC 20044.
03 Publication of Comments. The Trea-
sury Department and the IRS will publish
for public availability any comment sub-
mitted electronically or on paper to the
IRS’s public docket on https://www.regu-
lations.gov.
SECTION 8. PAPERWORK
REDUCTION ACT
Any collection burden associated with
this notice is accounted for in Office of
Management and Budget (OMB) control
numbers 1545-0123 for businesses and
1545-0047 for non-profit organizations.
The reporting requirements from section
4.08 of this notice and the recordkeep-
ing requirements from section 5 of this
notice are associated with the IRA-re-
lated changes to Form 3468 and Form
8835 that were approved, and will con-
tinue to be approved, under OMB con-
trol numbers 1545-0123 and 1545-0047.
This notice does not alter any previously
approved information collection require-
ments and does not create new collection
requirements not already approved by
OMB.
SECTION 9. EFFECT ON OTHER
DOCUMENTS
Table 2 in section 3.04 of Notice 2023-
38 is modified as provided in section 3.01
of this notice.
SECTION 10. DRAFTING
INFORMATION
The principal author of this notice
is the Office of Associate Chief Coun-
sel (Passthroughs & Special Industries).
However, other personnel from the
Treasury Department and the IRS par-
ticipated in its development. For further
information regarding this notice, call
the energy security guidance contact
number at (202) 317-5254 (not a toll-
free number).
Notice of Proposed
Rulemaking
Transactions with Foreign
Trusts and Information
Reporting on Transactions
with Foreign Trusts and
Large Foreign Gifts
REG-124850-08
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemak-
ing and notice of public hearing.
SUMMARY: This document contains
proposed regulations that provide guid-
ance regarding information reporting
of transactions with foreign trusts and
receipt of large foreign gifts and regarding
loans from, and uses of property of, for-
eign trusts. This document also contains
proposed amendments to the regulations
relating to foreign trusts having one or
more United States beneficiaries. The pro-
posed regulations affect United States per-
sons who engage in transactions with, or
are treated as the owners of, foreign trusts,
and United States persons who receive
large gifts or bequests from foreign per-
sons. This document also provides notice
of a public hearing on the proposed regu-
lations.
DATES: Comments: Electronic or written
public comments must be received by July
8, 2024.
Public Hearing: A public hearing on these
proposed regulations has been scheduled
for August 21, 2024, at 10:00 a.m. ET.

Bulletin No. 2024–24 1625 June 10, 2024
Requests to speak and outlines of topics to
be discussed at the public hearing must be
received by July 8, 2024. If no outlines are
received by July 8, 2024, the public hear-
ing will be cancelled. Requests to attend
the public hearing must be received by
5:00 p.m. ET on August 19, 2024.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic submis-
sions via the Federal eRulemaking Por-
tal at www.regulations.gov (indicate IRS
and REG-124850-08) by following the
online instructions for submitting com-
ments. Requests for a public hearing must
be submitted as prescribed in the “Com-
ments and Requests for a Public Hearing”
section. Once submitted to the Federal
eRulemaking Portal, comments cannot be
edited or withdrawn. The Department of
the Treasury (Treasury Department) and
the IRS will publish for public availabil-
ity any comments submitted to the IRS’s
public docket.
Send paper submissions to: CC:PA:01:PR
(REG-124850-08), room 5203, Internal
Revenue Service, P.O. Box 7604, Ben
Franklin Station, Washington, DC 20044.
FOR FURTHER INFORMATION
CONTACT: Concerning the proposed
regulations, Lara A. Banjanin at (202)
317-6933 or S. Eva Wolf at (202) 317-
3893 (not toll-free numbers); concerning
submissions of comments, the hearing, or
to be placed on the building access list to
attend the hearing, Vivian Hayes at (202)
317-6901 (not a toll-free number) or by
email at publichearings@irs.gov (pre-
ferred).
SUPPLEMENTARY INFORMATION:
Background
I. In General
This document contains proposed
amendments to 26 CFR part 1 under sec-
tions 643(i), 679, 6039F, 6048, and 6677
of the Internal Revenue Code (Code) (the
proposed regulations). Section 6048, as
significantly modified by the Small Busi-
ness Job Protection Act of 1996 (1996 Act),
Public Law 104-188 (110 Stat. 1755), and
further amended by the Taxpayer Relief
Act of 1997 (1997 Act), Public Law 105-
34 (111 Stat. 788), and the Hiring Incen-
tives to Restore Employment Act (HIRE
Act), Public Law 111-147 (124 Stat. 71),
generally requires U.S. persons to report
transactions that involve foreign trusts.
Section 6677, as significantly modified
by the 1996 Act and further amended by
the HIRE Act, imposes penalties on U.S.
persons for failing to comply with section
6048. Section 6039F, which was added to
the Code by the 1996 Act, and modified
by the Tax Cuts and Jobs Act, Public Law
115-97 (131 Stat. 2054), requires U.S.
persons to report the receipt of large gifts
or bequests from foreign persons, and in
the event of a failure to provide this infor-
mation, section 6039F(c) imposes penal-
ties and allows the IRS to recharacterize
the purported gift or bequest as income.
Section 643(i), which was added to the
Code by the 1996 Act and amended by the
HIRE Act, and section 679, as amended
by the 1996 Act and the HIRE Act, pro-
vide additional rules intended to prevent
taxpayers from avoiding U.S. income tax
consequences through the use of foreign
trusts.
On June 2, 1997, the Treasury Depart-
ment and the IRS issued Notice 97-34,
1997-1 CB 422, which provides guidance
on sections 643(i), 679, 6039F, 6048 and
6677 (the foreign trust and gift provisions)
as enacted or modified by the 1996 Act.
On August 7, 2000, the Treasury Depart-
ment and the IRS published a notice of
proposed rulemaking and a notice of pub-
lic hearing (REG-209038-89) under sec-
tion 679 in the Federal Register (65 FR
48185). On July 20, 2001, the Treasury
Department and the IRS published final
regulations under section 679. TD 8955
(66 FR 37866).
U.S. persons currently provide infor-
mation required by the foreign trust and
gift provisions on Form 3520, Annual
Return to Report Transactions With For-
eign Trusts and Receipt of Certain Foreign
Gifts, and Form 3520-A, Annual Informa-
tion Return of Foreign Trust With a U.S.
Owner (Under section 6048(b)). In 2015,
section 2006(b)(9) and (10) of the Surface
Transportation and Veterans Health Care
Choice Improvement Act of 2015 (Sur-
face Transportation Act), Public Law 114-
41 (129 Stat. 443), modified the due dates
for Forms 3520 and 3520-A for taxable
years beginning after December 31, 2015.
On March 16, 2020, the Treasury Depart-
ment and the IRS issued Revenue Proce-
dure 2020-17, 2020-12 IRB 539, which
exempts from section 6048 information
reporting requirements certain U.S. indi-
viduals’ transactions with, and ownership
of, certain tax-favored foreign trusts that
are established and operated exclusively
or almost exclusively to provide pension
or retirement benefits, or to provide medi-
cal, disability, or educational benefits.
II. Purpose of Foreign Trust and Gift
Provisions
During the mid- to late-1990s, abusive
tax schemes, including offshore schemes
involving foreign trusts, reemerged in
the United States after last peaking in the
1980s. GAO, Efforts to Identify and Com-
bat Abusive Tax Schemes Have Increased,
But Challenges Remain, GAO-02-733
(Washington D.C.: May 22, 2002). In
these schemes, foreign trusts were used
to transfer large amounts of assets off-
shore, where it was much more difficult
for the IRS to identify whether U.S. per-
sons owned an interest in such trusts, and
whether such persons were reporting and
paying the required taxes on their income
from such trusts. Many of the foreign
trusts were established in tax haven juris-
dictions with bank secrecy laws. Before
the 1996 Act amended sections 6048 and
6677, there was no requirement for U.S.
persons to report distributions from for-
eign trusts, and the penalty for failing to
report transfers to a foreign trust, or an
annual foreign trust information return
(on Form 3520-A), was limited to five
percent of the transfer or trust corpus, as
applicable, not to exceed $1,000. Given
that, it was difficult for the IRS to obtain
information about income earned by U.S.-
owned foreign trusts and distributions to
U.S. beneficiaries of foreign trusts, and
sections 6048 and 6677 were generally
ineffective at ensuring that U.S. persons
provided this information. The result
was “rampant tax avoidance.” 141 Cong.
Rec. S13859 (daily ed. Sept. 19, 1995)
(remarks of Senator Moynihan).
The foreign trust and gift provisions in
the 1996 Act were designed to accommo-
date changes in the use of foreign trusts

June 10, 2024 1626 Bulletin No. 2024–24
and to limit avoidance and evasion of U.S.
tax. The most significant changes were
made to sections 6048 and 6677 to enhance
the IRS’s ability to obtain the information
necessary to enforce the tax laws that
apply to U.S. persons’ transactions with,
and ownership of, foreign trusts. Other
changes included enactment of new sec-
tion 643(i) and amendments to section
679, each of which is designed to prevent
tax avoidance through the use of foreign
trusts. In addition, the legislation included
new section 6039F, which enables the IRS
to obtain information about large foreign
gifts or bequests received by U.S. persons.
III. Overview
A. Section 643(i)
Section 643(i), as originally enacted in
1996, generally provides that, if a foreign
trust makes a loan of cash or marketable
securities directly or indirectly to any
grantor or beneficiary of the foreign trust
who is a U.S. person (other than an entity
that is exempt from tax under Chapter 1
of the Code), or to a U.S. person related
(under sections 267 and 707(b)) to such a
grantor or beneficiary, the amount of the
loan is treated as a distribution by the trust
to the grantor or beneficiary. Section 643(i)
also authorizes the Secretary to issue
regulations providing exceptions, under
which a loan by a foreign trust would not
be treated as a distribution to the grantor
or beneficiary of the trust. The 1996 Act’s
legislative history explains that these reg-
ulations are expected to provide an excep-
tion under section 643(i) for loans with
arm’s-length terms, and in applying this
exception, the regulations should consider
whether there is a reasonable expectation
that the grantor, beneficiary, or related
person would repay the loan. H.R. Conf.
Rep. No. 737, 104
th
Cong., 2d Sess., at
334 (1996).
Section V.A of Notice 97-34 provides
that a loan of cash or marketable securities
by a foreign trust to a U.S. grantor or U.S.
beneficiary of the trust, or to a U.S. person
who is related to a U.S. grantor or U.S.
beneficiary of the trust, is treated as a dis-
tribution under section 643(i) unless the
loan is made in consideration for a qual-
ified obligation that satisfies certain spec-
ified requirements. Notice 97-34 states
that what constitutes a qualified obligation
will be provided in regulations. (Section
III.C of Notice 97-34 provides similar
qualified obligation rules for transfers to
foreign trusts. See section III.B of this
Background.)
In 2010, Congress expanded the scope
of section 643(i) in response to con-
cerns that U.S. persons were avoiding
the application of section 643(i) by using
trust property other than cash or market-
able securities without compensating the
foreign trust for the use of the property.
Section 533 of the HIRE Act amended
section 643(i) to provide that any uncom-
pensated use of trust property by a U.S.
grantor or U.S. beneficiary of the foreign
trust, or any U.S. person related to such
U.S. grantor or U.S. beneficiary, generally
is treated as a distribution of the fair mar-
ket value of the use of such property to the
U.S. grantor or U.S. beneficiary. This rule
does not apply if the foreign trust is paid
fair market value for the use of the trust
property within a reasonable timeframe.
Loans and use of trust property are
reported on Part III of Form 3520. Tax-
payers provide this information based on
guidance in section V.A of Notice 97-34,
as well as the instructions for Form 3520.
This information allows the IRS to deter-
mine whether the loan or use of trust prop-
erty should be treated as a distribution
pursuant to section 643(i).
B. Section 679
1. 1976 Act
Section 679 was enacted by the Tax
Reform Act of 1976 (1976 Act), Public
Law 94-455 (90 Stat. 1520). Section 679
treats a U.S. person who directly or indi-
rectly transfers property to a foreign trust
as the owner of the portion of the foreign
trust attributable to the transferred prop-
erty to the extent that, under the terms of
the trust, the income or corpus of the trust
may be paid to or accumulated for the
benefit of a U.S. person during the taxable
year, including if the trust were to be ter-
minated during the taxable year.
2. 1996 Act Amendments
Section 1903 of the 1996 Act made
several important changes to section 679.
For example, Congress was concerned
that taxpayers were attempting to avoid
the application of section 679(a)(1) by
transferring property to a foreign trust in
exchange for obligations from the foreign
trust that might not be repaid and argu-
ing that such obligations satisfied the fair
market value exception in section 679(a)
(2). H.R. Conf. Rep. No. 737, 104
th
Cong.,
2d Sess., at 334-35 (1996). The fair mar-
ket value exception provides that section
679(a)(1) does not apply to any transfer
of property to a foreign trust in exchange
for consideration of at least the fair market
value of the transferred property. Accord-
ingly, Congress added new section 679(a)
(3), which generally provides that obliga-
tions issued by the foreign trust, by any
grantor or beneficiary of the trust, or by
any person related to any grantor or ben-
eficiary, are not taken into account in
applying the fair market value exception
except as provided in regulations.
Section III.C of Notice 97-34 imple-
mented the fair market value exception of
section 679(a)(2)(B) and (a)(3) by provid-
ing that, if a U.S. person transfers money
or other property to a related foreign trust
in exchange for an obligation issued by
the trust or by a person related to the trust,
the obligation is taken into account for
purposes of determining whether the U.S.
person received fair market value from
the foreign trust only if the obligation is
a qualified obligation that satisfies certain
specified requirements. (Section V.A of
Notice 97-34 provides similar qualified
obligation rules that apply with respect
to loans from foreign trusts under section
643(i). See section III.A of this Back-
ground.) In 2001, the Treasury Depart-
ment and the IRS issued final regulations
under section 679 in TD 8955 (66 FR
37886) that included the section 679 qual-
ified obligation rules described in Notice
97-34. See §1.679-4(d).
A U.S. person’s transfers to a foreign
trust are reported on Part I of Form 3520,
together with information about any qual-
ified obligations received from the trust.
Taxpayers provide this information based
on the final regulations under section 679,
as well as the instructions for Form 3520.
This information allows the IRS to deter-
mine whether the U.S. person should be
treated as an owner of the foreign trust
under section 679.

Bulletin No. 2024–24 1627 June 10, 2024
3. HIRE Act Amendments
In 2010, the HIRE Act made five
amendments to section 679, three of
which are consistent with the final regula-
tions under section 679, and two of which
set forth new rules not reflected in the final
regulations.
First, section 531(a) of the HIRE Act
added new language to section 679(c)
(1) to clarify that an amount is treated
as accumulated for the benefit of a U.S.
person even if the U.S. person’s inter-
est in the foreign trust is contingent on a
future event. This statutory amendment is
consistent with §1.679-2(a)(2)(i), which
states that the determination as to whether
income or corpus may be paid to or accu-
mulated for the benefit of a U.S. person
is made without regard to whether the
income or corpus actually is distributed
to the U.S. person during the year, or
whether the U.S. person’s interest in the
income or corpus of the trust is contingent
on a future event.
Second, section 531(b) of the HIRE
Act added a new paragraph (4) to section
679(c) to clarify that, if any person has the
discretion to make a distribution from the
foreign trust to or for the benefit of any
person, the trust shall be treated as hav-
ing a U.S. beneficiary unless the terms of
the trust specifically identify the class of
persons to whom such distributions may
be made, and none of those persons are
U.S. persons during the taxable year. This
statutory amendment is consistent with
§1.679-2(a)(1), which provides that a for-
eign trust is treated as having a U.S. bene-
ficiary unless no part of the trust’s income
or corpus may be paid or accumulated to
or for the benefit of a U.S. person, and if
the trust is terminated at any time during
the taxable year, no part of the trust’s
income or corpus could be paid to or for
the benefit of a U.S. person.
Third, section 531(c) of the HIRE Act
added a new paragraph (5) to section
679(c) to clarify that, if any U.S. person
who directly or indirectly transfers prop-
erty to a foreign trust is directly or indi-
rectly involved in any agreement or under-
standing that may result in the income or
corpus of the trust being paid to or accu-
mulated for the benefit of a U.S. person,
then such an agreement or understanding
shall be treated as constituting a term of the
trust. This statutory amendment is consis-
tent with §1.679-2(a)(4)(i), which, assum-
ing that a transferor of property to a trust
is generally directly or indirectly involved
with any agreements regarding the accu-
mulation or disposition of the income and
corpus of the trust, allows the IRS to treat
a foreign trust as having a U.S. benefi-
ciary by looking beyond the language of
the trust instrument to all written and oral
agreements and understandings related to
the trust, memoranda or letters of wishes,
all records that relate to the actual distri-
bution of income and corpus, and all other
documents relating to the trust, whether or
not of any purported legal effect.
Fourth, section 532 of the HIRE Act
added a new paragraph (d) to section 679,
which provides a presumption that a for-
eign trust has a U.S. beneficiary in certain
circumstances. If a U.S. person directly or
indirectly transfers property to a foreign
trust (other than certain compensatory
and charitable trusts), the IRS may treat
the trust as having a U.S. beneficiary for
purposes of applying section 679 to the
transfer unless the U.S. person submits
such information to the IRS as the IRS
may require and demonstrates to the sat-
isfaction of the IRS that the trust satisfies
the requirements of section 679(c)(1).
Finally, section 533(c) of the HIRE
Act added a new paragraph (6) to section
679(c), which generally treats a loan of
cash or marketable securities to, or the
use of any other trust property by, any
U.S. person, whether or not a beneficiary
under the terms of the trust, as paid to or
accumulated for the benefit of a U.S. per-
son. Section 679(c)(6) does not apply to
the extent that the U.S. person repays the
loan at a market rate of interest or pays the
fair market value of the use of the prop-
erty within a reasonable period of time.
The effect of section 679(c)(6) is that, if a
foreign trust is not already treated as hav-
ing a U.S. beneficiary, a loan by the trust
of cash or marketable securities to a U.S.
person or the uncompensated use of trust
property by a U.S. person may cause the
foreign trust to be treated as having a U.S.
beneficiary, with the result that a U.S. per-
son who transferred property to the trust
may be treated as the owner of the trust
under section 679(a).
Final regulations were issued under
section 679 in 2001, and although instruc-
tions for Form 3520 and Form 3520-A
have been updated to take into account
the HIRE Act amendments to section 679,
regulations implementing these amend-
ments have not been issued.
C. Section 6039F
Section 1905 of the 1996 Act created
new reporting requirements under section
6039F for U.S. persons (other than certain
exempt organizations) that receive large
gifts (including bequests) from foreign
persons. The new information reporting
provisions require U.S. persons to pro-
vide information concerning the receipt
of large amounts that they treat as for-
eign gifts or bequests, giving the IRS an
opportunity to review the characterization
of these payments and determine whether
they are properly treated as gifts.
Section 6039F(b) generally defines the
term foreign gift as any amount received
from a person other than a U.S. person
that the recipient treats as a gift or bequest.
However, a foreign gift does not include
a qualified transfer (within the meaning
of section 2503(e)(2)) or a distribution
from a foreign trust. A distribution from
a foreign trust must be reported as a dis-
tribution under section 6048(c) (discussed
in section III.E of this Background) rather
than as a gift under section 6039F.
Section 6039F(c) provides that, if a U.S.
person fails, without reasonable cause, to
report a foreign gift as required by section
6039F, then (i) the tax consequences of the
receipt of the gift will be determined by the
Secretary and (ii) the U.S. person will be
subject to a penalty equal to 5 percent of
the amount of the gift for each month the
failure to report the foreign gift continues,
with the total penalty not to exceed 25 per-
cent of the value of the gift. Under sections
6039F(a) and (d), reporting is required
if the value of the aggregate foreign gifts
received by a U.S. person during any tax-
able year exceeds $10,000, as modified by
cost-of-living adjustments. Under section
VI.B.1 of Notice 97-34, however, a U.S.
person is required to report gifts from a
foreign individual or foreign estate only
if the aggregate amount of gifts from that
foreign individual or foreign estate exceeds
$100,000 during the U.S. person’s taxable
year. Section VI.B.3 of Notice 97-34 pro-
vides guidance on when a U.S. person must

June 10, 2024 1628 Bulletin No. 2024–24
aggregate foreign gifts received from for-
eign persons that the U.S. person knows or
has reason to know are related to each other.
Once the $100,000 threshold has been met,
the U.S. person must identify each foreign
gift in excess of $5,000 but is not required
to identify the transferor.
A U.S. person who receives foreign
gifts that exceed the threshold amounts
must report the foreign gifts on Part IV of
Form 3520. Taxpayers provide this infor-
mation based on guidance in section VI of
Notice 97-34, as well as the instructions
for Form 3520.
D. Section 6048
Section 6048(a) through (c) contains
three distinct reporting obligations with
respect to a U.S. person’s transactions
with, and ownership of, foreign trusts.
1. Section 6048(a)
Section 6048(a) generally requires a
responsible party to file information returns
upon the occurrence of certain reportable
events. A responsible party is the U.S.
grantor of an inter vivos foreign trust, the
U.S. transferor, or the executor of a U.S.
decedent’s estate. A reportable event is (a)
the creation of any foreign trust by a U.S.
person; (b) the direct or indirect transfer of
any money or property to a foreign trust by
a U.S. person, including a transfer by reason
of death; or (c) the death of a U.S. citizen or
resident if the decedent was treated as the
owner of any portion of a foreign trust or if
any portion of a foreign trust was included
in the gross estate of the decedent. Section
6048(a)(3)(B)(i) provides an exception for
transfers for fair market value the fair mar-
ket value exception, and section 6048(a)(3)
(B)(ii) provides an exception for transfers
to certain deferred compensation and char-
itable trusts. (These exceptions correspond
to the current substantive exemptions to the
scope of section 679. See section 679(a)(1)
and (2)(B).)
A reportable event is reported on Part I
of Form 3520. Section III of Notice 97-34
and the instructions for Form 3520 pro-
vide information to taxpayers regarding
this reporting. Section 6048(a) enables the
IRS to obtain the information necessary to
enforce sections 679 (discussed in section
III.B of this Background) and 684 (added
by section 1131(b) of the 1997 Act to pro-
vide for recognition of gain on certain
transfers to foreign trusts).
2. Section 6048(b)
Section 6048(b)(1) generally requires a
U.S. person who is treated as the owner
of any portion of a foreign trust under the
grantor trust rules (U.S. owner) to ensure
that the trust (i) files an annual informa-
tion return to provide a full accounting
of all the trust activities for the trust’s
taxable year and (ii) furnishes an annual
information statement to each U.S. owner
and to any other U.S. person who receives
(directly or indirectly) any distribution
from the trust during the year (U.S. bene-
ficiary). In addition, the U.S. owner must
submit such information as the IRS may
prescribe with respect to the foreign trust.
Section 6048(b)(2) provides that,
unless a foreign trust with a U.S. owner
appoints a U.S. agent, the Secretary may
determine the amounts required to be
taken into account with respect to such
trust by the U.S. owner under the grantor
trust rules. The U.S. agent will be required
to act as the foreign trust’s limited agent
solely for purposes of applying sections
7602, 7603, and 7604 with respect to any
request or summons by the Secretary in
connection with the tax treatment of any
items related to the trust. Certain rules
(similar to the rules of section 6038A(e)
(2) and (4)) relating to the enforcement of
requests for certain records with respect
to foreign-owned corporations will apply.
Information about the U.S. agent must be
reported on both the U.S. owner’s Form
3520 and the foreign trust’s Form 3520-A.
The foreign trust’s annual information
return is Form 3520-A, and any additional
information required to be submitted by
the U.S. owner is provided on Part II of
Form 3520. The information statements
that the foreign trust must furnish to each
U.S. owner and to each U.S. beneficiary
who receives a distribution are the For-
eign Grantor Trust Owner Statement and
the Foreign Grantor Trust Beneficiary
Statement, as applicable. Taxpayers pro-
vide this information based on guidance
in section IV of Notice 97-34, as well
as the instructions for Form 3520 and
Form 3520-A. If the foreign trust fails to
file Form 3520-A, section 6677 imposes
a penalty on the U.S. owner. In order to
avoid penalties under section 6677, the
U.S. owner must complete a substitute
Form 3520-A for the foreign trust and
attach it to the U.S. owner’s Form 3520.
See instructions for Part II of Form 3520.
3. Section 6048(c)
Section 6048(c)(1) provides that any
U.S. person who directly or indirectly
receives any distribution from a foreign
trust is required to file an information return
to report the name of the trust, the aggregate
amount of the distributions received, and
any other information that the Secretary
may prescribe. Section 6048(c)(2) gener-
ally provides that, if adequate records are
not provided to the Secretary to determine
the proper treatment of a distribution from
a foreign trust, the distribution is treated
as an accumulation distribution. However,
to the extent provided in regulations, this
rule does not apply if the foreign trust
authorizes a U.S. person to act as its lim-
ited agent under rules similar to the rules
of section 6048(b)(2)(B) (discussed in sec-
tion III.D.2 of this Background). Section
6048(d)(5) (discussed in section III.D.4
of this Background) provides that a U.S.
person’s treatment of a distribution from
a foreign trust must be consistent with the
trust’s treatment of such item or the Secre-
tary must be notified of the inconsistency.
Distributions from a foreign trust are
reported on Part III of Form 3520. Tax-
payers provide this information based on
guidance in section V of Notice 97-34, as
well as the instructions for Form 3520.
Section 6048(c) enables the IRS to obtain
the information it needs to enforce the
rules relating to the taxation of accumu-
lation distributions (sections 665 through
669), as well as sections 672(f), 643(h),
and 643(i). Section 6048(c) requires any
U.S. person, including a U.S. owner and
U.S. beneficiary of a foreign trust, who
receives a distribution from a foreign trust
to report information about the distribu-
tion. See Wilson v. United States, 6 F.4
th

432 (2d Cir. 2021), rev’g, No. 19-CV-5037
(BMC), 2019 WL 6118013 (E.D.N.Y.
Nov. 18, 2019) (holding that when an
individual is both the sole owner and
beneficiary of a foreign trust and fails to
timely report distributions received from
the trust, the IRS may impose a penalty

Bulletin No. 2024–24 1629 June 10, 2024
under section 6677 equal to 35 percent of
the gross reportable amount).
4. Section 6048(d)
Section 6048(d)(1) provides that, for
purposes of section 6048, in determining
whether a U.S. person makes a transfer to,
or receives a distribution from, a foreign
trust, the fact that a portion of the trust is
treated as owned by another person under
the grantor trust rules is disregarded.
Section 6048(d)(2) provides that, to the
extent provided in regulations, a domestic
trust will be treated as a foreign trust for
purposes of sections 6048 and 6677 if the
trust has substantial activities, or holds
substantial property, outside the United
States. The legislative history includes the
statement “that in exercising its regulatory
authority to treat a U.S. trust as a foreign
trust for purposes of information reporting
purposes, the Secretary of the Treasury
will take into account the information that
such a trust reported under the domestic
trust reporting rules.” H.R. Conf. Rep. 737,
104
th
Cong., 2d Sess. at 338 (1996). Section
VIII.C of Notice 97-34 states that the Trea-
sury Department and the IRS are studying
the appropriate scope of section 6048(d)(2)
and that, until further guidance is issued,
a domestic trust is not treated as a foreign
trust pursuant to section 6048(d)(2).
Section 6048(d)(3) provides that any
notice or return required under section
6048 is to be made at such time and in
such manner as the Secretary prescribes.
Section 6048(d)(4) authorizes the IRS
to suspend or modify any requirement of
section 6048 if the IRS determines that the
United States has no significant tax inter-
est in obtaining the required information.
The Treasury Department and the IRS
previously have issued guidance provid-
ing that information reporting under sec-
tion 6048(c) is not required with respect
to distributions from certain foreign
compensatory trusts, provided that the
U.S. person who receives the distribution
reports the distribution as compensation
income on an applicable Federal income
tax return, and that information reporting
under section 6048(a) through (c) is not
required with respect to certain Canadian
retirement plans. See Section V of Notice
97-34; Rev. Proc. 2014-55, 2014-44 I.R.B.
753. In addition, on March 16, 2020, the
Treasury Department and the IRS issued
Revenue Procedure 2020-17, which
exempts from section 6048 information
reporting requirements certain U.S. indi-
viduals’ transactions with, and ownership
of, certain tax-favored foreign trusts that
are established and operated exclusively
or almost exclusively to provide pension
or retirement benefits or to provide medi-
cal, disability, or educational benefits.
Section 6048(d)(5) (added by section
1027(b) of the 1997 Act) provides that
a U.S. person who either is treated as an
owner of any portion of a foreign trust or
receives (directly or indirectly) any distri-
bution from a foreign trust must treat any
portion owned or any item distributed in
a manner that is consistent with the trust’s
treatment of such ownership or item; oth-
erwise, the U.S. person must notify the
Secretary of the inconsistency. A similar
rule in section 6034A(c) (added by sec-
tion 1027(a) of the 1997 Act) generally
provides that a beneficiary of an estate or
trust is required to file a return in a man-
ner that is consistent with the information
received from the estate or trust, unless the
beneficiary files with the return a notifica-
tion of inconsistent treatment identifying
the inconsistency. The Treasury Depart-
ment and the IRS are of the view that the
rules in sections 6034A(c) and 6048(d)(5)
are to be interpreted as comparable to the
consistency rules that already apply to S
corporation shareholders and partners in
partnerships. H.R. Conf. Rep. 220, 105
th

Cong., 1st Sess. at 551 (1997). Taxpayers
may use Form 8082, Notice of Inconsistent
Treatment or Administrative Adjustment
Request (AAR), to report an inconsistency.
Although regulations were issued under
section 6048, these regulations now are
obsolete because they were issued under
an earlier version of section 6048. These
regulations were removed as a result of
regulations issued pursuant to Executive
Order 13789. See TD 9849 (84 FR 9231).
E. Section 6677
Under section 6677, as amended by
section 1901(b) of the 1996 Act, a U.S.
person who fails to file a required infor-
mation return under section 6048(a) or
(c) is subject to an initial penalty of 35
percent of the gross reportable amount
(generally, the value of the property trans-
ferred or received). If an information
return required under section 6048(b) is
not filed, the U.S. person who is treated
as the owner of the foreign trust is subject
to an initial penalty of five percent of the
gross reportable amount (the trust corpus
at the end of the year). See also Wilson v.
United States, 6 F.4th 432 (2d Cir. 2021)
(holding that gross reportable amount has
multiple meanings under section 6677(c)
that differ depending on the part of sec-
tion 6048 that is violated), rev’g, No.
19-CV-5037 (BMC), 2019 WL 6118013
(E.D.N.Y. 2019). In all cases, if the failure
to file an information return continues for
more than 90 days after the day on which
the IRS mails notification of the failure, an
additional $10,000 penalty is imposed for
each 30-day period (or fraction thereof)
during which the failure continues. The
total amount of the penalties with respect
to any failure cannot exceed the gross
reportable amount with respect to that
failure. If the gross reportable amount is
partially reported, then the penalties are
applied based on the amount that is unre-
ported. Section VII of Notice 97-34.
Section 535 of the HIRE Act strength-
ened the penalty structure by further
amending section 6677 to allow the IRS
to impose penalties when it does not have
enough information to determine the
gross reportable amount. Section 6677,
as amended, provides that the initial pen-
alty is the greater of $10,000 or 35 per-
cent (five percent in the case of a failure
to comply with section 6048(b)) of the
gross reportable amount. Thus, the IRS
may impose an initial penalty of $10,000
on a U.S. person who fails to report infor-
mation without having any information
about the foreign trust’s gross reportable
amount. The amendment did not change
the rules for the additional penalties of
$10,000 for each 30-day period (or frac-
tion thereof) during which the failure to
report continues.
Section 6677, as amended, also pro-
vides that, if the IRS, after having assessed
penalties, obtains sufficient information to
determine the gross reportable amount,
any subsequent penalty imposed will be
reduced as necessary to ensure that the
aggregate amount of the penalties does
not exceed the gross reportable amount.
To the extent that the amount already paid
exceeds the gross reportable amount, the

June 10, 2024 1630 Bulletin No. 2024–24
IRS will refund the excess to the U.S. per-
son pursuant to section 6402.
Section 6677(d) provides that no pen-
alty will be imposed on any failure that
is shown to be due to reasonable cause
and not due to willful neglect. It further
provides that the fact that a foreign juris-
diction would impose a civil or criminal
penalty on the U.S. person (or any other
person) for disclosing the required infor-
mation is not reasonable cause.
Section 6677(e) provides that subchap-
ter B of chapter 63 (relating to deficiency
procedures for income, estate, gift, and
certain excise taxes) does not apply in
respect of the assessment or collection of
any penalty imposed under section 6677.
F. Section 643(a)(7)
Section 643(a)(7), which was added to
the Code by section 1906(b) of the 1996
Act, provides that the Secretary shall pre-
scribe such regulations as may be neces-
sary or appropriate to carry out the pur-
poses of part I of subchapter J of chapter
1 of the Code (sections 641 through 685),
including regulations to prevent avoid-
ance of such purposes.
G. Information return due dates
Section 2006(b) of the Surface Trans-
portation Act provides that, in the case of
returns for taxable years beginning after
December 31, 2015, the Secretary, or the
Secretary’s designee, shall modify the
appropriate regulations addressing certain
due dates. Section 2006(b)(9) provides
that the due date of Form 3520-A shall be
the 15th day of the third month after the
close of the trust’s taxable year, and the
maximum extension shall be a 6-month
period beginning on such day. Section
2006(b)(10) states that the due date of
Form 3520 for calendar year filers shall be
April 15 with a maximum extension for a
6-month period ending on October 15.
Explanation of Provisions
I. Section 643(i) – Loans to and Uses of
Foreign Trust Property by U.S. Persons
These proposed regulations provide
rules relating to loans from foreign trusts
to U.S. persons and uses of foreign trust
property by U.S. persons. They gener-
ally incorporate the section 643(i) guid-
ance that was provided in Notice 97-34
(discussed in section III.A of the Back-
ground), with certain modifications to
provide procedural rules, such as how to
determine a loan’s yield to maturity and
how to extend the period of assessment for
any income tax associated with the loan,
and anti-abuse rules, such as requiring
payments and information reporting to be
timely. In addition, the proposed regula-
tions provide guidance implementing the
HIRE Act amendments to section 643(i).
A. Application of section 643(i) to loans
by or uses of property of a foreign trust
Proposed §1.643(i)-1 provides rules
for determining when a loan of cash or
marketable securities from a foreign non-
grantor trust, made to a U.S. person who
is either a grantor or beneficiary of the
foreign trust or is related to a U.S. person
who is a grantor or beneficiary of the for-
eign trust, will be treated as a distribution
under subchapter J of chapter 1 of the
Code (a section 643(i) distribution) to the
U.S. grantor or beneficiary of the foreign
trust. These rules also apply to determine
whether a distribution is made when any
such U.S. persons use the property of the
foreign trust.
These rules apply solely for purposes
of subparts B, C, and D (sections 651-
652, 661-664, and 665-668) of part I of
subchapter J of chapter 1 of the Code, and
thus section 643(i) does not apply to a for-
eign trust to the extent that it is a grantor
trust described in subpart E (sections 671
through 679) of part I of subchapter J.
Although section 643(i) applies to loans of
cash or marketable securities from a for-
eign trust to a U.S. grantor or a U.S. person
related to a U.S. grantor, these provisions
of section 643(i) predate the HIRE Act,
which enacted section 679(c)(6). Under
section 679, a U.S. person who trans-
fers property to a foreign trust is treated
as the owner of the portion of the trust
attributable to the property transferred to
the trust if there is a U.S. beneficiary of
any portion of the trust, unless an excep-
tion applies. Section 679(c)(6) provides
that any direct or indirect loan of cash or
marketable securities to a U.S. person, or
direct or indirect use of any other trust
property by a U.S. person, whether or not
the U.S. person is a beneficiary under the
terms of the trust, will be treated as paid
to or accumulated for the benefit of a U.S.
person, unless an exception applies (see
proposed §1.679-2(a)(5)(iii)). That is, the
U.S. person will be treated as a beneficiary
of the foreign trust for purposes of section
679. In most circumstances, this causes
the foreign trust to be a grantor trust under
section 679, removing it from the purview
of section 643(i). Section 643(i), there-
fore, will rarely apply to a U.S. grantor or
a U.S. person related to a U.S. grantor. It
might apply, however, if the U.S. grantor
created but did not make a transfer to the
foreign trust.
Proposed §1.643(i)-1(b)(1) provides
that, unless an exception applies, any loan
of cash or marketable securities made from
a foreign trust (whether from trust corpus
or income) directly or indirectly to a U.S.
grantor or beneficiary of the trust or to any
U.S. person related to a U.S. grantor or
beneficiary of the trust is treated as a sec-
tion 643(i) distribution to such U.S. grantor
or beneficiary as of the date on which the
loan is made. For these purposes, a loan to
a grantor trust or to a disregarded entity is
treated as a loan to the owner of the grantor
trust or of the disregarded entity. For exam-
ple, a loan to a single member LLC treated
as a disregarded entity is treated as a loan to
the owner of the LLC.
Proposed §1.643(i)-1(b)(2)(i) describes
indirect loans for purposes of section
643(i) to include loans made through an
intermediary, agent, or nominee. Pro-
posed §1.643(i)-1(b)(2)(i) also provides
three examples of indirect loans: (1) a
loan made by any person to a U.S. grantor
or beneficiary of a foreign trust or any
U.S. person related to a U.S. grantor or
beneficiary if the foreign trust guarantees
(within the meaning of §1.679-3(e)(4))
the loan; (2) a loan made by any person
related (within the meaning of proposed
§1.643(i)-1(d)(9)) to the foreign trust to a
U.S. grantor or beneficiary of the foreign
trust or to a U.S. person related to a U.S.
grantor or beneficiary; and (3) a loan made
by a foreign trust to a foreign person, other
than to a nonresident alien individual who
is a grantor or beneficiary of the trust, if
the foreign person is related (within the
meaning of proposed §1.643(i)-1(d)(9)) to
a U.S. grantor or beneficiary of the trust.

Bulletin No. 2024–24 1631 June 10, 2024
See proposed §1.643(i)-1(b)(2)(i)(A)
through (C). However, the loans described
in examples (2) and (3) above are excepted
from section 643(i) treatment if the U.S.
grantor or beneficiary of the foreign trust
satisfies the information reporting require-
ments of proposed §1.6048-4 with respect
to the loan and attaches to a Federal
income tax return an explanatory state-
ment that demonstrates to the satisfaction
of the IRS that the loan would have been
made without regard to the U.S. grantor’s
or beneficiary’s relationship to the for-
eign trust. See proposed §1.643(i)-1(b)(2)
(ii). There is no such exception for a loan
made by any person that is guaranteed
(within the meaning of §1.679-3(e)(4)) by
a foreign trust because a foreign trust is
unlikely to guarantee such a loan absent
its relationship with the U.S. grantor or
beneficiary.
Proposed §1.643(i)-1(b)(2)(iii) pro-
vides that loans from a foreign trust to a
U.S. grantor or beneficiary or U.S. person
related to a U.S. grantor or beneficiary
through an intermediary are treated as
made directly from the foreign trust to the
U.S. grantor or beneficiary or U.S. person
related to a U.S. grantor or beneficiary.
In order to discourage grantors and ben-
eficiaries of a foreign trust from changing
their U.S. residence in a particular year
to avoid the application of section 643(i),
proposed §1.643(i)-1(b)(3) provides an
anti-abuse rule. If a nonresident alien who
is a grantor or beneficiary of a foreign trust
receives a loan from the foreign trust and
becomes a U.S. person within two years,
that grantor or beneficiary will be subject
to section 643(i) with respect to the out-
standing amount of the loan as of the date
the grantor or beneficiary acquires U.S.
residence or citizenship if the loan was not
a qualified obligation as of the date that it
was made.
Proposed §1.643(i)-1(c) provides that
any direct or indirect use of other prop-
erty of a foreign trust by a U.S. grantor
or beneficiary or any U.S. person related
to a U.S. grantor or beneficiary is treated
as a section 643(i) distribution to the U.S.
grantor or beneficiary in the taxable year
in which the use occurs. Use of property
of a foreign trust by a grantor trust or a
disregarded entity is treated as use by the
owner of the grantor trust or of the dis-
regarded entity. For example, use of trust
property by a single member LLC treated
as a disregarded entity would be treated as
use by the owner of the LLC.
Proposed §1.643(i)-1(c)(2)(i) describes
indirect use of trust property to include
use by an agent or nominee. Indirect use
of trust property also includes use by a
foreign person, other than a nonresident
alien individual who is a beneficiary of
the foreign trust, if the foreign person is
related to a U.S. grantor or beneficiary of
the trust, unless the U.S. grantor or ben-
eficiary reports the use of trust property
on Part III of Form 3520, as required by
proposed §1.6048-4, and attaches to the
U.S. grantor’s or beneficiary’s Federal
income tax return an explanatory state-
ment that demonstrates to the satisfaction
of the IRS that the use of trust property
would have been made without regard to
the U.S. grantor’s or beneficiary’s rela-
tionship to the foreign trust. See proposed
§1.643(i)-1(c)(2).
B. Exceptions
Proposed §1.643(i)-2(a) provides four
exceptions to the general rule of proposed
§1.643(i)-1(b)(1):
First, the general rule will not apply
to any loan of cash in exchange for a
qualified obligation within the meaning
of proposed §1.643(i)-2(b)(2)(iii). The
proposed regulations do not provide an
exception from the general rule for loans
of marketable securities as such a rule
would be more difficult to apply, and it
is less likely that a foreign trust would
make a loan of marketable securities. The
Treasury Department and the IRS request
comments on whether qualified obligation
rules are needed for loans of marketable
securities.
Second, in the case of a use of trust
property other than a loan of cash or mar-
ketable securities, the general rule will not
apply to the extent that the foreign trust
receives the fair market value of such use
within a reasonable period (described in
proposed §1.643(i)-2(a)(2)(ii) as 60 days
or less) from the start of the use of the trust
property. The fair market value of the use
will be based on all the facts and circum-
stances, including the type of property
used and the period of use.
Third, the general rule will not apply
to any de minimis use of trust property
(described in proposed §1.643(i)-2(a)(3)
as aggregate use by members of a group
consisting of the U.S. grantors and ben-
eficiaries and the U.S. persons related to
them for a total of 14 days or less during
the taxable year), other than a loan of cash
or marketable securities, by a U.S. grantor
or beneficiary or a U.S. person related to a
U.S. grantor or beneficiary.
Fourth, the general rule will not apply
to a loan of cash that is made by a foreign
corporation to a U.S. beneficiary of the
foreign trust to the extent the aggregate
amount of all such loans to the benefi-
ciary does not exceed undistributed earn-
ings and profits of the foreign corporation
attributable to amounts that are, or have
been, included in the beneficiary’s gross
income under section 951, 951A, or 1293.
This exception is intended to prevent dou-
ble taxation that could result by reason
of the application of section 643(i) to an
amount that has already been included
in the U.S. beneficiary’s gross income as
a subpart F income inclusion, a global
intangible low-taxed income inclusion,
an inclusion by reason of a controlled
foreign corporation’s investment of earn-
ings in United States property, or a quali-
fied electing fund inclusion. The Treasury
Department and the IRS request com-
ments on whether the scope of the excep-
tion is appropriate, and whether ordering
rules to determine the sourcing of loan
amounts, for example, rules based on the
principles of section 959 or similar to the
provisions of §1.672(f)-4(c)(3), or other
clarifications on the exception’s applica-
tion, are necessary.
C. Qualified obligations
Proposed §1.643(i)-2(b) provides
rules for determining whether a loan of
cash is made in exchange for a quali-
fied obligation. Proposed §1.643(i)-2(b)
(2) defines the terms obligor, obligation,
and qualified obligation. The definitions
of obligation and qualified obligation are
consistent with the amended definitions
of obligation and qualified obligation in
proposed §1.679-1(c)(6) and §1.679-4(d),
respectively. The term obligor means a
person who issues an obligation (within
the meaning of proposed §1.643(i)-2(b)
(2)(i)) to a foreign trust in exchange for a
loan of cash. The term obligation means

June 10, 2024 1632 Bulletin No. 2024–24
any instrument or contractual arrange-
ment that constitutes indebtedness under
general principles of Federal income tax
law (for example, a bond, note, deben-
ture, certificate, bill receivable, account
receivable, note receivable, open account,
or other evidence of indebtedness), and
an annuity contract that would not other-
wise be classified as indebtedness under
general principles of Federal income tax
law. Under proposed §1.643(i)-2(b)(2)(iii)
(A), the term qualified obligation means
an obligation that satisfies all of the fol-
lowing requirements:
First, the obligation must be in writing.
Second, the term of the obligation must
not exceed five years.
Third, all payments on the obligation
must be made in cash in U.S. dollars. The
Treasury Department and the IRS stress
this requirement to make all payments in
cash in U.S. dollars, in light of abusive
transactions in which taxpayers have used
an inflated valuation of in-kind property to
purportedly repay an obligation.
Fourth, the obligation must be issued
at par and must provide for stated interest
at a fixed rate or a qualified floating rate
within the meaning of §1.1275-5(b).
Fifth, the yield to maturity must be not
less than 100 percent and not greater than
130 percent of the applicable Federal rate
in effect under section 1274(d) on the day
on which the obligation is issued. The
yield to maturity and the applicable Fed-
eral rate must be based on the same com-
pounding period. If an obligation is a vari-
able rate debt instrument that provides for
stated interest at a qualified floating rate,
the rules in §§1.1274-2(f)(1) and 1.1275-
5(e) apply to determine the obligation’s
yield to maturity.
Sixth, all stated interest on the obli-
gation must be qualified stated interest
within the meaning of §1.1273-1(c).
In addition to these six initial require-
ments, for both the first year and each
succeeding year in which the obligation
remains outstanding, the three require-
ments of proposed §1.643(i)-2(b)(2)(iii)
(B) must be satisfied in order for the obli-
gation to remain a qualified obligation.
First, the U.S. grantor or beneficiary (as
the person who would be subject to income
tax if an obligation either is not a qualified
obligation or ceases to be a qualified obli-
gation) must extend the period for assess-
ment on Part III of Form 3520 (under rules
described in proposed §1.643(i)-2(b)(2)
(iii)(B)(1)) of any income tax attributable
to the loan and any consequent income tax
changes for each year that the obligation
is outstanding to a date not earlier than
three years after the maturity date of the
obligation issued in consideration for the
loan. Second, the U.S. grantor or bene-
ficiary must report the status of the obli-
gation, including any payments made, on
Part III of Form 3520. Third, the obligor
must make all payments of principal and
interest on the obligation according to the
terms of the obligation.
Proposed §1.643(i)-2(b)(3) provides
that, if the terms of the obligation are
modified and the modification is treated
as an exchange under §1.1001-3, the new
obligation that is deemed issued in the
exchange under §1.1001-3 must satisfy the
requirements in proposed §1.643(i)-2(b)
(2)(iii) to be a qualified obligation using
the original obligation’s issue date. If the
modification is not treated as an exchange
under §1.1001-3, then the obligation is
retested as of the date of the modification
to determine whether the obligation, as
modified, continues to satisfy the require-
ments to be a qualified obligation.
Proposed §1.643(i)-2(b)(4) provides
that if, while the obligation is outstand-
ing, the U.S. obligor directly or indirectly
issues another obligation to the foreign
trust in exchange for cash, the outstanding
obligation is deemed to have the matu-
rity date of the new obligation for pur-
poses of determining whether the term of
the outstanding obligation exceeds five
years. The outstanding obligation must
be retested as of the issue date of the
new obligation to determine whether the
outstanding obligation continues to be a
qualified obligation. The new obligation
also must be separately tested to see if it
satisfies the requirements to be a qualified
obligation.
Proposed §1.643(i)-2(b)(5) provides
that the IRS may treat two or more obliga-
tions issued by a U.S. obligor as a single
obligation that is not a qualified obligation
if they are structured with a principal pur-
pose to avoid the application of section
643(i).
Proposed §1.643(i)-2(b)(6) provides
that, if a qualified obligation ceases to be a
qualified obligation (for example, because
a modification causes the term of the
obligation to exceed five years), the U.S.
grantor or beneficiary is treated as receiv-
ing a section 643(i) distribution from
the foreign trust. In general, the amount
of the section 643(i) distribution is the
obligation’s outstanding stated principal
amount plus any accrued but unpaid qual-
ified stated interest (within the meaning of
§1.1273-1(c)) as of the date of the event
that causes the obligation to no longer be
a qualified obligation. If the IRS treats two
or more obligations as a single obligation
that is not a qualified obligation under pro-
posed §1.643(i)-2(b)(5), then the amount
of the section 643(i) distribution will not
exceed the sum of the outstanding stated
principal amounts of the obligations plus
any accrued but unpaid qualified stated
interest as of the date determined by the
IRS.
D. Trust property attributable to
nongrantor trust portion
Proposed §1.643(i)-2(c) provides rules
for determining the extent to which a
loan or use of trust property from a par-
tial nongrantor trust will be attributable to
the nongrantor trust portion. Generally, a
loan or use of trust property from a partial
nongrantor trust must be apportioned in
a manner that is reasonable based on all
the facts and circumstances, including the
terms of the governing instrument, local
law, and the practice of the trustee, if it is
reasonable and consistent. However, if a
loan or use of trust property can be made
from only one portion of the foreign trust
because the type of property loaned or
used is held only by that portion, then the
loan or use of property is attributable to
that portion.
E. Reporting
The Treasury Department and the
IRS are of the view that it is appropri-
ate to require reporting, pursuant to the
authority granted to the Treasury Depart-
ment and the IRS by section 643(a)(7),
of all loans and uses of trust property
that are potentially subject to section
643(i), in order to ensure that the IRS
has the information necessary to enforce
taxpayer compliance with these rules.
Thus, proposed §1.643(i)-2(d) provides

Bulletin No. 2024–24 1633 June 10, 2024
that any loan of cash or marketable secu-
rities by a foreign trust to a U.S. person
and any use by a U.S. person of prop-
erty belonging to a foreign trust, with-
out regard to whether such loan or use
of property is treated as a section 643(i)
distribution, also is a distribution within
the meaning of proposed §1.6048-4(b)
and subject to the information reporting
described under proposed §1.6048-4(a).
See proposed §1.6048-4(b)(3)(ii) and
(iii) and (b)(4)(ii) and (iii).
F. Amount treated as section 643(i)
distribution
Proposed §1.643(i)-3(a) provides
rules for determining the amount that is
treated as a section 643(i) distribution if
an exception does not apply. In the case of
a loan of cash, the amount of the section
643(i) distribution is the issue price of
the loan as of the date the loan is treated
as a distribution from the foreign trust.
In the case of a loan of marketable secu-
rities, the amount of the section 643(i)
distribution is the fair market value of the
securities as of the date the loan is treated
as a distribution from the foreign trust. In
the case of the use of trust property with-
out fair market value compensation, the
amount of the section 643(i) distribution
is the fair market value of the use of the
property less any payments made for the
use of the property within a reasonable
period of time.
G. Allocation of section 643(i)
distribution among multiple U.S. grantors
and beneficiaries
Proposed §1.643(i)-3(b) provides a
rule for allocating a section 643(i) distri-
bution among multiple U.S. grantors and
beneficiaries. If a U.S. person who is not
a U.S. grantor or beneficiary of a foreign
trust but who is related to more than one
U.S. grantor or beneficiary of the foreign
trust receives a loan of cash or market-
able securities from the trust, or uses trust
property, and the loan or use is treated as a
section 643(i) distribution, then each U.S.
grantor or beneficiary who is related to the
U.S. person receiving the loan or using
trust property is treated as receiving an
equal share of the section 643(i) distribu-
tion.
H. Tax consequences of a section 643(i)
distribution
Proposed §1.643(i)-3(c) provides rules
to determine the tax consequences of a
section 643(i) distribution to a foreign trust
treated as making a section 643(i) distri-
bution and to a U.S. grantor or beneficiary
treated as receiving the distribution. Pro-
posed §1.643(i)-3(c)(2) provides that a for-
eign trust generally must treat the section
643(i) distribution as an amount properly
paid, credited, or required to be distributed
by the trust as described in section 661(a)
(2) for which the trust may be allowed a
distribution deduction in computing its tax-
able income. In addition, a section 643(i)
distribution of marketable securities would
cause a foreign trust to be deemed to have
elected to have section 643(e)(3) apply to
such distribution, which would cause the
trust to recognize gain or loss as if the mar-
ketable securities had been sold at fair mar-
ket value. Any capital gain recognized by
the foreign trust would be included in the
trust’s distributable net income (DNI) pur-
suant to section 643(a)(6)(C). As a result
of the deemed election, a U.S. grantor or
beneficiary would be treated as including
in gross income under section 662(a)(2) the
fair market value of the marketable securi-
ties, and in computing its taxable income,
the foreign trust would be allowed to
deduct the fair market value of the market-
able securities to the extent allowed under
section 661(a)(2).
Proposed 1.643(i)-3(c)(2)(iii) provides
that the foreign trust may issue a Foreign
Nongrantor Trust Beneficiary Statement
(described in proposed §1.6048-4(c)(2))
to each U.S. grantor or beneficiary who
receives any loan of cash or marketable
securities or uses other trust property during
the taxable year of the trust or is related to
a U.S. person who receives any loan of
cash or marketable securities or uses other
trust property during the taxable year of the
trust, whether or not such U.S. grantor or
beneficiary would be required to take the
amount into account as a section 643(i)
distribution. A U.S. grantor or beneficiary
who does not receive a Foreign Nongrantor
Trust Beneficiary Statement with respect
to a section 643(i) distribution is required
to determine the tax consequences of the
distribution under the default calculation
method in proposed §1.643(i)-3(c)(3)(ii).
Proposed §1.643(i)-3(c)(3) provides
that a U.S. grantor or beneficiary who is
treated as receiving a section 643(i) dis-
tribution must determine the tax conse-
quences of the distribution using either the
actual calculation method or the default
calculation method. Under the actual cal-
culation method, set out under proposed
§1.643(i)-3(c)(3)(i), a U.S. grantor or ben-
eficiary must treat a section 643(i) distri-
bution as an amount properly paid, cred-
ited, or required to be distributed by the
foreign trust as described in section 662(a)
(2) (relating to inclusions in gross income
by beneficiaries of trusts accumulating
income or distributing corpus). The tax
consequences of the section 643(i) distri-
bution to a U.S. grantor or beneficiary are
determined by using information provided
in the Foreign Nongrantor Trust Benefi-
ciary Statement and applying the rules of
subparts C and D of part I of subchapter J
of chapter 1 of the Code.
Under the default calculation method,
as provided in proposed §1.643(i)-3(c)
(3)(ii), a U.S. grantor or beneficiary must
determine the tax consequences of the
section 643(i) distribution under the rules
provided in proposed §1.6048-4(d)(3).
For an explanation of the default calcu-
lation method, see section IV.C of this
Explanation of Provisions.
A U.S. grantor or beneficiary may not
use the actual calculation method unless
the U.S. grantor or beneficiary has received
a Foreign Nongrantor Trust Beneficiary
Statement (described in proposed §1.6048-
4(c)(2)) from the foreign trust. A U.S.
grantor or beneficiary who previously has
used the default calculation method must
consistently use the default calculation
method to determine the tax consequences
of all subsequent distributions from the
same foreign trust (including distributions
other than section 643(i) distributions),
except in the year in which the foreign trust
terminates. See proposed §1.6048-4(b) for
the definition of the term distribution, and
see proposed §1.6048-4(d)(3)(iii) for rules
relating to the tax consequences to a U.S.
grantor or beneficiary in the year in which
a foreign trust terminates.
I. Subsequent transactions
Proposed §1.643(i)-3(d)(1) provides
rules regarding the treatment of any sub-

June 10, 2024 1634 Bulletin No. 2024–24
sequent transaction between a foreign
trust and an obligor regarding the prin-
cipal of any loan of cash or marketable
securities (or use of trust property) that
is treated as a section 643(i) distribution,
including complete or partial repayment,
satisfaction, cancellation, discharge,
return of trust property, or otherwise, but
not including payments of interest. Pro-
posed §1.643(i)-3(d)(2) provides that any
subsequent transaction with respect to the
principal of any loan of cash or market-
able securities or return of trust property
treated as a section 643(i) distribution has
no tax consequences to a foreign trust.
However, payment to a foreign trust other
than the repayment of principal of any
loan treated as a section 643(i) distribu-
tion, such as the payment of interest, is
treated as income to the trust.
Proposed §1.643(i)-3(d)(3) provides
the consequences to an obligor of sub-
sequent transactions between a foreign
trust and the obligor related to a section
643(i) distribution. Generally, any subse-
quent transaction regarding the principal
of any loan of cash or marketable securi-
ties or return of trust property treated as a
section 643(i) distribution is treated as a
transfer that is not a gratuitous transfer by
a U.S. person for purposes of §1.671-2(e)
(2)(i) and chapter 1 of the Code. Thus, the
repayment of principal would not cause
an obligor to be treated as the owner of
the foreign trust. However, if an obligor
satisfies the principal of any loan of cash
or marketable securities treated as a sec-
tion 643(i) distribution through a transfer
of property to the foreign trust, the obligor
will recognize as gain or loss the differ-
ence between the fair market value of the
property transferred and its adjusted basis
in the hands of the obligor under the rules
of section 1001 and the regulations issued
under section 1001.
II. Section 679 – Foreign Trusts Treated
as Having a U.S. Beneficiary
The proposed regulations amend the
definition of U.S. person in §1.679-1(c)
(2), the definition of obligation in §1.679-
1(c)(6), and the definition of qualified obli-
gation in §1.679-4(d). The amended defi-
nitions generally are consistent with the
definitions of the same terms in proposed
§§1.643(i)-1(d)(12) and 1.643(i)-2(b)(2),
except that the definition of a U.S. per-
son in proposed §1.679-1(c)(2) does not
exclude tax-exempt entities.
The proposed regulations also make
two additions to §1.679-2 that provide
guidance on two statutory provisions
added to section 679 by the HIRE Act.
First, proposed §1.679-2(a)(5) and pro-
posed §1.679-2(b)(3) provide guidance
to determine when a loan from a foreign
trust to a U.S. person or the use of foreign
trust property by a U.S. person causes the
foreign trust to be treated as having a U.S.
beneficiary. Second, proposed §1.679-
2(d) implements section 679(d), which
generally provides that, if a U.S. person
directly or indirectly transfers property
to a foreign trust, the trust is presumed to
have a U.S. beneficiary in certain circum-
stances.
A. Definition of U.S. person
Proposed §1.679-1(c)(2) amends the
current definition of U.S. person for pur-
poses of §§1.679-1 through 1.679-6 to
remove the explicit statement that a non-
resident alien individual who elects under
section 6013(g) to be treated as a resident
of the United States is a U.S. person for
purposes of section 679 without intend-
ing a substantive change from the exist-
ing regulation regarding the treatment of
persons who make an election under sec-
tion 6013(g). Additionally, a U.S. person
for purposes of section 679 will include
a nonresident alien individual who elects
under section 6013(h) to be treated as
a resident of the United States. An elec-
tion under either section 6013(g) or (h) is
effective for all purposes of chapter 1 of
the Code, including section 679, and thus,
no specific reference to either rule should
be required.
Under the definition of U.S. person in
the proposed regulations, however, a dual
resident taxpayer (within the meaning of
§301.7701(b)-7(a)(1)) is not treated as a
U.S. person with respect to any taxable
year (or portion of a taxable year) for
which such person computes U.S. tax
liability as a nonresident alien pursuant
to §301.7701(b)-7. The Treasury Depart-
ment and the IRS are of the view that it
is not necessary to treat a dual resident
taxpayer who has elected to compute such
person’s income tax liability as a nonres-
ident alien as a U.S. person for purposes
of §§1.679-1 through 1.679-6 in order
to carry out the purposes of section 679.
However, see §1.679-5 for rules that may
apply if a dual resident taxpayer who has
been computing U.S. tax liability as a non-
resident alien begins to compute tax liabil-
ity as a U.S. resident.
B. Definition of obligation
Proposed §1.679-1(c)(6) amends the
current definition of obligation for pur-
poses of §§1.679-1 through 1.679-6 to
conform to the definition of obligation in
proposed §1.643(i)-2(b)(2)(i).
C. Loans from foreign trusts and uses of
trust property
Proposed §1.679-2(a)(5)(i) provides
guidance under section 679(c)(6), which
was added to the Code by the HIRE Act.
As a general rule, any direct or indirect
loan of cash or marketable securities
(whether from trust income or corpus)
by a foreign trust to, or the direct or indi-
rect use of any other property of a foreign
trust by, any U.S. person (whether or not
a beneficiary under the terms of the trust)
will be treated as causing trust income or
corpus to be paid to or accumulated for
the benefit of a U.S. person for purposes
of §1.679-2(a)(1). For these purposes, a
loan to, or use of any other property of a
foreign trust by, a grantor trust or a dis-
regarded entity is treated as a loan to, or
use of trust property by, the owner of the
grantor trust or of the disregarded entity.
(For example, a loan to a single member
LLC treated as a disregarded entity would
be treated as a loan to the owner of the
LLC.) Consequently, a foreign trust that is
not already treated as having a U.S. bene-
ficiary under §1.679-2 is treated as having
a U.S. beneficiary for purposes of §1.679-
1, with the result that a U.S. grantor who
has made a transfer to the foreign trust is
treated as the owner of the trust (or a por-
tion of the trust). See proposed §1.6048-4
for rules relating to information reporting
with respect to loans from foreign trusts
and the use of property of a foreign trust.
Proposed §1.679-2(a)(5)(ii) provides
that an indirect loan from a foreign trust
to a U.S. person includes a loan made by
any person, whether U.S. or foreign, if the

Bulletin No. 2024–24 1635 June 10, 2024
foreign trust provides a guarantee (within
the meaning of §1.679-3(e)(4)) for the
loan. An indirect loan from a foreign trust
to a U.S. person also includes a loan made
through an intermediary, such as an agent
or nominee of the foreign trust or of the
U.S. beneficiary, and a loan from a person
related (within the meaning of proposed
§1.643(i)-1(d)(9)) to the foreign trust.
Proposed §1.679-2(a)(5)(iii) provides
three exceptions to the general rule of pro-
posed §1.679-2(a)(5)(i).
First, the general rule does not apply
if the U.S. person who receives the loan
of cash or marketable securities, or who
uses trust property, is described in section
501(c)(3).
Second, the general rule does not apply
to any loan of cash received by a U.S.
person in exchange for a qualified obli-
gation within the meaning of proposed
§1.643(i)-2(b)(2)(iii)(A), provided the
obligor timely makes all payments within
the meaning of proposed §1.643(i)-2(b)
(2)(iii)(B)(3).
Third, the general rule does not apply
if the U.S. person who uses trust property
(other than a loan of cash or marketable
securities) pays the foreign trust the fair
market value of the use of such property
within a reasonable period from the date
of the start of the use of the property. The
fair market value is based on all the facts
and circumstances, including the type of
property used and the period of use. Pro-
posed §1.679-2(a)(5)(iv) provides two
safe harbors in which this fair market
value exception applies.
Proposed §1.679-2(a)(5)(v) addresses
the interaction of proposed §1.679-2(a)(5)
with section 643(i) and confirms that sec-
tion 643(i) does not apply to the extent a
foreign trust is treated as having acquired
a U.S. beneficiary and is treated as owned
by a U.S. person under section 679 (dis-
cussed in section I.A of this Explanation
of Provisions).
Proposed §1.679-2(b)(3) provides that
a loan of cash or marketable securities
or the use of trust property that does not
qualify for the exceptions described in
proposed §1.679-2(a)(5)(iii) is treated as
paid to or accumulated for the benefit of
a U.S. person if the loan is made to, or
the property is used by, a foreign entity
described in §1.679-2(b)(1), or if the loan
is made through, or the property is used
by, an intermediary or is made by any
other means where a U.S. person may
obtain an actual or constructive benefit, as
described in §1.679-2(b)(2).
D. Presumption that foreign trust has
U.S. beneficiary
Proposed §1.679-2(d)(1) provides
guidance under section 679(d) regarding
whether a foreign trust is deemed to have
a U.S. beneficiary. As a general rule, if a
U.S. person directly or indirectly transfers
property to a foreign trust (other than a
compensatory or charitable trust described
in §1.679-4(a)(2) or (3)), the IRS may treat
the trust as having a U.S. beneficiary for
purposes of applying §1.679-1 unless the
U.S. person, for the tax year in which the
transfer is made, (i) satisfies the informa-
tion reporting requirements of proposed
§1.6048-2 with respect to the transfer,
and (ii) attaches an explanatory statement
to the U.S. person’s Federal income tax
return demonstrating to the satisfaction of
the IRS that the trust satisfies the require-
ments of §1.679-2(a)(1) immediately
after the transfer. Section 1.679-2(a)(1)
provides that a foreign trust is treated as
having a U.S. beneficiary unless, during
the taxable year in which the U.S. per-
son made the transfer, (i) no part of the
income or corpus of the foreign trust may
be paid to or accumulated for the benefit
of, directly or indirectly, a U.S. person,
and (ii) if the foreign trust is terminated at
any time during the taxable year, no part
of the income or corpus of the trust could
be paid to or for the benefit of, directly or
indirectly, a U.S. person.
Proposed §1.679-2(d)(2) provides that
the IRS may request additional infor-
mation related to the foreign trust and
its potential beneficiaries to determine
whether the trust satisfies the require-
ments of §1.679-2(a)(1). Unless the U.S.
person provides such additional informa-
tion within 60 days (90 days if the U.S.
person is outside the United States) after
the IRS’s written notice and request, the
trust will be presumed to have a U.S. ben-
eficiary.
E. Definition of qualified obligation
Proposed §1.679-4(d) amends the cur-
rent definition of qualified obligation for
purposes of §1.679-4 to conform to the
definition of qualified obligation in pro-
posed §1.643(i)-2(b)(2)(iii) and the addi-
tional rules in proposed §§1.643(i)-2(b)
(3) through (6) (discussed in section I.C of
this Explanation of Provisions).
III. Section 6039F – Information
Reporting Rules for U.S. Recipients of
Foreign Gifts
The proposed regulations provide
information reporting rules for U.S. recip-
ients of foreign gifts by generally incor-
porating the section 6039F guidance that
was provided in Notice 97-34 (discussed
in section III.C of the Background). They
also provide additional guidance that is
needed to implement all of section 6039F
and to address certain abuses of which the
IRS has become aware and relevant statu-
tory developments since 1997, including
the enactment of section 2801 dealing
with gifts and bequests from certain expa-
triates.
A. In general
Proposed §1.6039F-1(a)(1) provides
that any U.S. person who treats an amount
received from a foreign person as a for-
eign gift during a taxable year must report
that amount on Part IV of Form 3520 by
the fifteenth day of the fourth month after
the close of the U.S. person’s taxable
year. Proposed §1.6039F-1(a)(2) pro-
vides that, if the U.S. person qualifies for
an automatic extension of time to file an
income tax return under section 6081 and
§1.6081-5(a)(5) because the U.S. person
resides outside of the United States and
Puerto Rico, and the U.S. person’s main
place of business or post of duty is out-
side of the United States or Puerto Rico,
Form 3520 must be filed by the fifteenth
day of the sixth month after the close of
the U.S. person’s taxable year. In either
case, if the U.S. person has been granted
an extension of time to file an income
tax return pursuant to section 6081, an
extension of time for filing Form 3520 is
automatically granted to the fifteenth day
of the tenth month following the close of
the U.S. person’s taxable year. See pro-
posed §1.6039F-1(a)(1) and (2). Proposed
§1.6039F-1(a)(3) provides that, if the U.S.
person dies, the executor of the U.S. per-

June 10, 2024 1636 Bulletin No. 2024–24
son’s estate must report the foreign gift on
Part IV of Form 3520 by the fifteenth day
of the fourth month following the close of
the 12-month period which began with the
first day of the U.S. person’s final taxable
year or, if the executor has been granted
an extension of time to file the U.S. per-
son’s final income tax return pursuant to
section 6081, by the fifteenth day of the
tenth month following the close of the
12-month period which began with the
first day of the U.S. person’s final taxable
year. No additional extension of time to
file Form 3520 is allowed.
For purposes of proposed §1.6039F-
1, the term U.S. person means a United
States person as defined under section
7701(a)(30). However, under proposed
§1.6039F-1(f), consistent with the
approach in proposed §§ 1.643(i)-1(d)
(12)(ii) and 1.679-1(c)(2)(ii), neither a
dual resident taxpayer nor a dual status
taxpayer is treated as a U.S. person for
purposes of proposed §1.6039F-1 for a
taxable year or any portion of a taxable
year that the taxpayer is treated as a non-
resident alien for purposes of computing
U.S. tax liability. See section III.F of this
Explanation of Provisions.
B. Definition of “foreign gift” and
coordination with section 6048(c)
For purposes of proposed §1.6039F-1,
the term foreign gift is defined to include
any amount received from a person other
than a U.S. person that the recipient treats
as a gift, bequest, devise, or inheritance
for Federal income tax purposes. The
term, however, does not include any quali-
fied transfer within the meaning of section
2503(e)(2) (relating to certain transfers for
educational or medical expenses) or any
transfer from a foreign trust that is treated
as a distribution (within the meaning of
proposed §1.6048-4(b)) and reported on
a return under proposed §1.6048-4. Pro-
posed §1.6039F-1(b)(1) also provides that
a U.S. person who receives a transfer from
a foreign trust must treat the transfer as a
distribution from the trust that is report-
able under proposed §1.6048-4, rather
than reportable as a foreign gift under pro-
posed §1.6039F-1(a), even if the U.S. per-
son treats the transfer as a gift for another
purpose, such as computing the U.S. per-
son’s Federal income tax liability.
Proposed §1.6039F-1(b)(2) includes
an anti-avoidance rule that provides that
the term foreign gift includes transfers
from a person other than a U.S. person
that the recipient does not treat as a gift,
bequest, devise, or inheritance for Fed-
eral income tax purposes, such as a pur-
ported loan, if based on all the facts and
circumstances the IRS determines that
the transfer is in substance a gift. The
IRS has become aware of U.S. persons
who are seeking to circumvent the sec-
tion 6039F information reporting rules
by claiming that the amounts they receive
from foreign persons are not foreign gifts
because they do not treat them as gifts
but that they are otherwise not taxable
(claiming instead that the transfers are
loans). These amounts, however, objec-
tively have all the indicia of being a gift.
Under the existing principles of Federal
tax law, the IRS therefore will recharac-
terize these amounts as foreign gifts that
should have been reported under section
6039F.
C. Exceptions
Proposed §1.6039F-1(c) provides a
number of exceptions to the general rule
in proposed §1.6039F-1(a). Proposed
§1.6039F-1(c)(1) provides that the gen-
eral rule does not apply if the recipient
of the foreign gift is described in section
501(c) and is exempt from tax under sec-
tion 501(a). Proposed §1.6039F-1(c)(2)
(i) through (iii) provides exceptions from
information reporting under proposed
§1.6039F-1(a) for amounts below the
reporting thresholds.
Under proposed §1.6039F-1(c)(2)
(i)(A), a U.S. person is not required to
report foreign gifts from foreign indi-
viduals or foreign estates if, during the
U.S. person’s taxable year, the aggregate
amount of foreign gifts received, directly
or indirectly, from any one individual or
estate (the transferor) does not exceed
$100,000, as modified by cost of living
adjustments under proposed §1.6039F-
1(c)(2)(v). For purposes of determining
whether the $100,000 reporting threshold
is met, all foreign gifts (including covered
gifts and bequests) from the transferor and
from any foreign persons related to the
transferor are aggregated. See proposed
§1.6039F-1(c)(2)(i)(B).
If the aggregate amount of foreign
gifts from a transferor exceeds the
$100,000 reporting threshold, the pro-
posed regulations require the U.S. per-
son to separately identify each foreign
gift in excess of $5,000 received from
the transferor and from each foreign
person related to the transferor, and to
provide identifying information about
the transferor and related foreign per-
sons, including foreign individuals or
foreign estates (for example, name and
address). Specific identifying informa-
tion about the transferor is not currently
required to be provided on Form 3520.
The Treasury Department and the IRS are
of the view that the additional identifying
information would assist the IRS in its
determination of whether these amounts
are properly treated as foreign gifts, and
the burden imposed on the U.S. person
should be minimal because the U.S. per-
son would need to know the transferor’s
identity in order to know whether the
transferor is foreign and in order to apply
the aggregation rule.
Under proposed §1.6039F-1(c)(2)(ii),
notwithstanding the reporting threshold
described above, beginning on the date
on which final regulations under section
2801 (tax on gifts and bequests from expa-
triates) apply, a U.S. person who receives
foreign gifts that are covered gifts or
bequests will be required to report the
covered gifts or bequests under proposed
§1.6039F-1(a) if the aggregate amount of
all covered gifts and bequests received by
the U.S. person during the calendar year
exceeds the exclusion amount under sec-
tion 2801(c). See proposed §1.6039F-1(h)
(2). This exclusion amount is the dollar
amount of the per-donee gift tax exclusion
in effect under section 2503(b) for the cal-
endar year ($18,000 for 2024).
Under proposed §1.6039F-1(c)(2)(iii),
a U.S. person is not required to report for-
eign gifts from a foreign corporation or
partnership if, during the U.S. person’s
taxable year, the aggregate amount of
transfers received from any particular cor-
poration or partnership does not exceed
$10,000, as modified by cost-of-living
adjustments under proposed §1.6039F-
1(c)(2)(v). The proposed regulations pro-
vide rules for aggregating and reporting
foreign gifts from persons related to the
transferor.

Bulletin No. 2024–24 1637 June 10, 2024
Proposed §1.6039F-1(c)(2)(iv) pro-
vides that, with respect to spouses who
file joint income tax returns under section
6013, the reporting threshold amounts
apply separately to each spouse.
D. Valuation principles
Proposed §1.6039F-1(d) provides that
the amount of a foreign gift is the value of
the property at the time of the transfer. The
value of the property is the price at which
the property would change hands between
a willing buyer and a willing seller, nei-
ther being under any compulsion to buy
or sell, and both having reasonable knowl-
edge of relevant facts. The value is to be
determined in accordance with the Fed-
eral gift tax valuation principles of sec-
tion 2512 and sections 2701 through 2704
(chapter 14 of the Code) and the related
regulations.
E. Penalty for failure to file information
Proposed §1.6039F-1(e)(1) describes
penalties for failure to furnish the informa-
tion required by proposed §1.6039F-1(a)
by the due date (including extensions) of
Form 3520. The tax consequences of the
receipt of the foreign gift will be deter-
mined by the IRS based on all the facts
and circumstances. A U.S. person who
fails to furnish the required information
is subject to a penalty equal to five per-
cent of the amount of the foreign gift for
each month (or portion thereof) for which
the failure continues, but not to exceed 25
percent of the amount of the foreign gift.
For purposes of determining the tax
consequences of the receipt of the foreign
gift, the IRS may take into account the
purported gift rules in §1.672(f)-4 (which
address the treatment of a purported gift,
as defined in §1.672(f)-4(d), from a part-
nership or foreign corporation). Unless
an exception described in §1.672(f)-4(b),
(e) or (f) applies, §1.672(f)-4 generally
requires a U.S. person who receives a
purported gift or bequest, directly or
indirectly, from a partnership or foreign
corporation to include the purported gift
or bequest in gross income as ordinary
income.
Proposed §1.6039F-1(e)(2)(i) explains
that no penalty is imposed if the U.S. per-
son shows that the failure to comply is due
to reasonable cause and not due to will-
ful neglect. The determination of whether
a failure is due to reasonable cause and
not due to willful neglect will be made
under the principles set out in §1.6664-4
and §301.6651-1(c) and will be made on a
case-by-case basis, taking into account all
pertinent facts and circumstances.
F. Special rules for dual resident and
dual status taxpayers
Proposed §1.6039F-1(f)(1) provides
a special rule for dual resident taxpayers
(within the meaning of §301.7701(b)-7(a)
(1)). A dual resident taxpayer who, pursu-
ant to a provision of an income tax treaty
that provides for resolution of conflicting
claims of residence by the United States
and the treaty partner, claims to be treated
as a resident of the treaty partner as pro-
vided in §301.7701(b)–7 is taxed as a non-
resident for U.S. tax purposes for the por-
tion of the taxable year that the individual
is treated as a nonresident. The Treasury
Department and the IRS are of the view
that, because the dual resident taxpay-
er’s filing of relevant forms pursuant to
§301.7701(b)–7 provides adequate infor-
mation for the IRS to identify residents in
this category in order to ensure their tax
compliance, reporting on Form 3520 by
such a taxpayer is not essential to effec-
tive IRS tax enforcement efforts relating
to this category of residents.
Similarly, proposed §1.6039F-1(f)(2)
provides a special rule for dual status tax-
payers. As provided in §1.6012-1(b)(2)
(ii), a dual status taxpayer who, during the
taxable year, abandons U.S. citizenship or
U.S. residence or acquires U.S. citizen-
ship or U.S. residence is not treated as a
U.S. person for the part of the year that the
taxpayer is treated as a nonresident alien
for purposes of computing the taxpayer’s
income tax liability as reflected on the
Form 1040NR or other similar schedule
attached to such Form 1040NR.
These rules are relevant both for pur-
poses of determining whether a dual resi-
dent taxpayer or dual status taxpayer who
receives a foreign gift is a U.S. person
required to report the foreign gift on Form
3520 and for purposes of determining
whether a gift or bequest from a dual res-
ident taxpayer or dual status taxpayer is a
gift from a foreign person.
IV. Section 6048 – Information with
Respect to Certain Foreign Trusts
The proposed regulations provide
information reporting rules with respect
to a U.S. person’s transfers to, creation
of, ownership of, and receipt of distri-
butions from foreign trusts. These pro-
posed regulations generally implement
the rules set forth in Notice 97-34, Rev-
enue Procedure 2014-55, and Revenue
Procedure 2020-17 (discussed in sec-
tion III.D of the Background) but also
provide additional exceptions to section
6048 reporting and include certain other
modifications.
A. Section 6048(a) – Notice of certain
events
The proposed regulations under section
6048(a) require a responsible party to pro-
vide notice of reportable events that occur
during the taxable year on Part I of Form
3520. See proposed §1.6048-2(a)(1).
Proposed §1.6048-2(c) defines respon-
sible party as the grantor in the case of the
creation of an inter vivos foreign trust,
the transferor in the case of a transfer of
property to a foreign trust by a U.S. person
other than a transfer by reason of death,
or the executor of the estate of a deceased
grantor or transferor in any other case,
even if the executor is not a U.S. person.
Proposed §1.6048-2(b) defines a
reportable event as: (i) the creation of a
foreign trust by a U.S. person, (ii) any
direct, indirect, or constructive transfer,
within the meaning of §1.679-3 or §1.684-
2, of property (including cash) to a foreign
trust by a U.S. person, including a transfer
by reason of death, and (iii) the death of
a citizen or resident of the United States
if the decedent was treated as the owner
of any portion of a foreign trust under the
grantor trust rules or if any portion of a
foreign trust was included in the gross
estate of the decedent. A reportable event
also includes a U.S. person’s transfer of
property to a domestic trust that becomes
a foreign trust, as described in §1.684-4
(outbound migrations of domestic trusts),
and a U.S. person’s transfer of property in
exchange for any obligation of the foreign
trust or of a related person, as described
in §1.679-4, without regard to whether
the obligation is a qualified obligation. A

June 10, 2024 1638 Bulletin No. 2024–24
reportable event does not include transfers
to certain foreign charitable trusts, foreign
compensatory trusts, and tax-favored for-
eign retirement and non-retirement sav-
ings trusts, as discussed in section IV.D.2.i
of this Explanation of Provisions. See pro-
posed §1.6048-5.
Form 3520 generally must be filed by
the fifteenth day of the fourth month after
the close of the responsible party’s taxable
year, but no later than the fifteenth day of
the tenth month if the responsible party
receives an extension of time to file the
responsible party’s income tax return under
section 6081. See proposed §1.6048-2(a)
(2)(i). However, if the responsible party
who is a grantor or transferor qualifies
for an automatic extension of time to file
an income tax return under section 6081
and §1.6081-5(a)(5) because the respon-
sible party resides outside of the United
States and Puerto Rico, and the responsi-
ble party’s main place of business or post
of duty is outside of the United States or
Puerto Rico, Form 3520 must be filed by
the fifteenth day of the sixth month after
the close of the responsible party’s taxable
year. See proposed §1.6048-2(a)(2)(ii). If
the responsible party who is a grantor or
transferor dies, the executor of the respon-
sible party’s estate must file Form 3520 by
the fifteenth day of the fourth month after
the close of the 12-month period which
began on the first day of the responsible
party’s final taxable year. See proposed
§1.6048-2(a)(2)(iii).
B. Section 6048(b) – U.S. owners of
foreign trusts
The proposed regulations under section
6048(b) generally require any U.S. person
who is treated as the owner (U.S. owner)
of any portion of a foreign trust under
the grantor trust rules to ensure that the
foreign trust: (i) files Form 3520-A with
the IRS by the fifteenth day of the third
month after the end of the trust’s taxable
year (March 15 if the trust’s taxable year
is a calendar year) with a maximum exten-
sion of a 6-month period beginning on
such day, (ii) furnishes a Foreign Grantor
Trust Owner Statement (described in pro-
posed §1.6048-4(c)(1)(i)) to each U.S.
owner of the foreign trust, and (iii) fur-
nishes a Foreign Grantor Trust Benefi-
ciary Statement (described in proposed
§1.6048-4(c)(1)(ii)) to each U.S. person
to whom the trust made distributions
during the trust’s taxable year. The foreign
trust must attach copies of each Foreign
Grantor Trust Owner Statement and each
Foreign Grantor Trust Beneficiary State-
ment to the Form 3520-A. See proposed
§1.6048-3(a)(1). If the foreign trust does
not comply with all these requirements,
the U.S. owner is required to: (i) com-
plete and file Part II of Form 3520 by the
U.S. owner’s Form 3520 due date, and (ii)
complete the foreign trust’s Form 3520-A
and related statements and file them with
Part II of the U.S. owner’s Form 3520.
Further, the U.S. owner must furnish the
Foreign Grantor Trust Beneficiary State-
ment to each U.S. beneficiary by the due
date of the U.S. owner’s Form 3520. See
proposed §1.6048-3(a)(2). If neither the
foreign trust nor the U.S. owner com-
plies with these requirements, the penalty
for failure to comply is imposed on the
U.S. owner. See proposed §1.6677-1(b).
As discussed in section IV.D.2.i of this
Explanation of Provisions, the proposed
regulations under section 6048(b) do not
apply to tax-favored foreign retirement
and non-retirement savings trusts. See
proposed §1.6048-5.
The proposed regulations require
a U.S. person who receives a Foreign
Grantor Trust Owner Statement or Foreign
Grantor Trust Beneficiary Statement from
a foreign trust to treat any item reported by
the trust consistently with the trust’s treat-
ment of such item unless the U.S. person
notifies the IRS about any inconsistency
on Form 8082. See proposed §1.6048-
3(b). If the U.S. person fails to notify the
IRS about the inconsistency, or if the U.S.
person receives information believed to
be incorrect from the foreign trust, then,
similar to the rules of section 6034A(c)
(addressing reporting in respect of income
tax returns), any adjustment relating to an
unreported item is treated as a mathemati-
cal or clerical error under section 6213(b),
with the result that the adjustment would
not be subject to the usual restrictions on
assessment and the U.S. grantor or U.S.
beneficiary would have no right to file a
Tax Court petition based on the adjust-
ment.
Proposed §1.6048-3(c) provides that,
unless a foreign trust with a U.S. owner
appoints a limited U.S. agent, the deter-
mination of amounts required to be taken
into account with respect to the trust by the
U.S. owner under the grantor trust rules
will be determined by the IRS based on
all the facts and circumstances. Proposed
§1.6048-3(d) provides rules relating to the
appointment and duties of the limited U.S.
agent. Proposed §1.6048-3(d) also pro-
vides rules concerning the issuance of a
summons to a U.S. person (either directly
or as the limited agent of the foreign trust)
or to the foreign trust to produce records
or testimony to determine the amounts
required to be taken into account under the
grantor trust rules.
C. Section 6048(c) – Reporting by U.S.
persons receiving distributions from
foreign trusts
1. In General
Unless an exception described in pro-
posed §1.6048-5 applies, proposed reg-
ulations under section 6048(c) generally
require a U.S. person to complete and file
Part III of Form 3520 for each taxable year
in which the U.S. person receives (directly
or indirectly) any distribution from a for-
eign trust (including a foreign trust that
the U.S. person is treated as owning under
the grantor trust rules). Part III of Form
3520 must be filed by the due date of the
U.S. person’s Form 3520 for that taxable
year. See proposed §1.6048-4(a). The
Treasury Department and the IRS inter-
pret section 6048(c) as requiring any U.S.
person, including a U.S. owner, to report
the receipt of foreign trust distributions.
This interpretation is consistent with both
the plain language of section 6048(c) and
its purpose - to address Congress’s con-
cerns that U.S. taxpayers were avoiding
their U.S. tax obligations through the use
of foreign trusts that are less visible to the
IRS - and empowers the IRS to obtain
information that would allow it to enforce
U.S. tax laws.
2. Distributions
Proposed §1.6048-4(b)(1) provides
that, as a general rule, the term distribu-
tion for purposes of proposed §1.6048-4
means any transfer of property from a
foreign trust received directly or indi-
rectly by a U.S. person to the extent such

Bulletin No. 2024–24 1639 June 10, 2024
property exceeds the fair market value
of any property or services received by
the foreign trust in exchange, without
regard to whether any portion of the
trust is treated as owned by the grantor
or another person under the grantor trust
rules, whether the recipient is designated
as a beneficiary under the terms of the
trust, or whether the distribution has
any income tax consequences. A distri-
bution includes any amount actually or
constructively received and includes the
receipt of a gift or bequest described in
section 663(a). For purposes of proposed
§1.6048-4(b)(1), a transfer of property
from a foreign trust to a grantor trust or to
a disregarded entity is treated as a trans-
fer to the U.S. owner of the grantor trust
or of the disregarded entity.
Proposed §1.6048-4(b)(2)(i) provides
that the term distribution also includes
any transfer of property from a foreign
trust received by a U.S. person through
an intermediary, nominee, or agent. In
such a case, the intermediary, nominee,
or agent generally is treated as an agent
of the foreign trust, and the property is
treated as distributed to the U.S. person
in the year the property is transferred
or made available to the U.S. person.
However, proposed §1.6048-4(b)(2)(ii)
provides that, if the IRS determines that
the intermediary, nominee, or agent is an
agent of the U.S. person, then the prop-
erty is treated as being transferred from
the foreign trust to the U.S. person on
the date of the transfer from the foreign
trust to the intermediary, nominee, or
agent. Regardless of the income tax con-
sequences of such a transfer, pursuant to
proposed §1.6048-4(b)(2)(iii), the U.S.
person receiving an indirect transfer of
property from a foreign trust must report
it on Part III of Form 3520.
Proposed §1.6048-4(b)(3) provides
that a distribution includes any transfer of
property from an entity owned by a for-
eign trust to a U.S. person who is related
(within the meaning of §1.679-1(c)(5)) to
the foreign trust. It also explains that the
transfer is treated as a distribution from
the entity to the foreign trust followed
by a distribution from the foreign trust to
the U.S. person, unless the U.S. person
demonstrates to the satisfaction of the
IRS that the distribution from the entity is
attributable to the U.S. person’s ownership
interest in the entity. This rule is the con-
verse of the rule of §1.679-3(f)(1), which
provides that a transfer by a U.S. person
to an entity owned by a foreign trust is
treated as a transfer to the foreign trust
followed by a transfer from the foreign
trust to the entity, unless the U.S. person
demonstrates to the satisfaction of the IRS
that the transfer to the entity is attributable
to the U.S. person’s ownership interest in
the entity.
Proposed §1.6048-4(b)(4) provides
that a distribution includes the migration
of a foreign trust to a domestic trust. In
such a case, the income and corpus of
the foreign trust is treated as distributed
to the domestic trust on the date the for-
eign trust becomes a domestic trust. See
§301.7701-7 for the rules that apply to
determine whether a trust is a foreign trust
or domestic trust.
Proposed §1.6048-4(b)(5)(i) provides
that a distribution includes any loan of
cash or marketable securities made from
a foreign trust (whether from corpus or
income) directly or indirectly to a U.S.
person. It also clarifies that a loan to a
grantor trust or to an entity disregarded
as an entity separate from its owner will
be treated as a loan to the owner of the
grantor trust or of the disregarded entity.
Loans from a foreign trust also include a
loan made by any foreign or U.S. person
if the foreign trust guarantees the loan,
as well as a loan made to a U.S. person
through any intermediary, nominee or
agent.
Proposed §1.6048-4(b)(5)(ii) further
provides that a distribution includes any
loan of cash or marketable securities made
directly or indirectly to a U.S. grantor
or beneficiary (as defined in proposed
§1.643(i)-1(d)(1)) of a foreign nongrantor
trust or to a U.S. person related (as defined
in proposed §1.643(i)-1(d)(9)) to a U.S.
grantor or beneficiary of such foreign non-
grantor trust without regard to whether the
foreign trust receives an obligation (within
the meaning of proposed §1.643(i)-2(b)
(2)(i)) in exchange for the loan.
Proposed §1.6048-4(b)(5)(iii) provides
that a loan of cash or marketable securi-
ties from a foreign trust must be reported
by the U.S. person who receives the loan
without regard to whether the loan would
have any U.S. income tax consequences to
a U.S. grantor or beneficiary of the foreign
trust. If the U.S. person who receives the
loan is related to a U.S. grantor or bene-
ficiary of a foreign nongrantor trust, then
the U.S. grantor or beneficiary also must
report the distribution.
Proposed §1.6048-4(b)(6)(i) provides
that a distribution includes the fair mar-
ket value of the direct or indirect use of
trust property by a U.S. person without
regard to whether the use of trust prop-
erty would be treated as having any U.S.
income tax consequences to a U.S. grantor
or beneficiary of the foreign trust. For
these purposes, the use of trust property
by a grantor trust or a disregarded entity is
treated as used by the owner of the grantor
trust or of the disregarded entity, respec-
tively. Proposed §1.6048-4(b)(6)(ii) fur-
ther provides that a distribution includes
the fair market value of the direct or indi-
rect use of trust property by a U.S. grantor
or beneficiary of a foreign nongrantor
trust or by a U.S. person related to such
U.S. grantor or beneficiary whether or not
the foreign trust is paid the fair market
value for such use. Proposed §1.6048-4(b)
(6)(iii) provides that the use of trust prop-
erty must be reported on Part III of Form
3520 by the U.S. person that uses the trust
property without regard to whether the
use of trust property would have any U.S.
income tax consequences to a U.S. grantor
or beneficiary of the foreign trust. If the
U.S. person who uses the trust property is
related to a U.S. grantor or beneficiary of
a foreign nongrantor trust, then the U.S.
grantor or beneficiary also must report the
distribution.
The Treasury Department and the IRS
are of the view that because, under sec-
tion 643(i), a distribution to a U.S. person
related to a U.S. grantor or beneficiary
affects the U.S. grantor’s or beneficiary’s
income tax liability, it is appropriate to
require reporting by both the U.S. person
receiving a distribution from a foreign
trust and the U.S. grantor or beneficiary of
the foreign trust who is related to that U.S.
person. Requiring both parties to report
the distribution ensures that the IRS has
the information it needs for tax compli-
ance efforts.
Proposed §1.6048-4(b)(7) confirms
that the term distribution also includes any
covered gift or bequest (within the mean-
ing of section 2801(e)) that is received
from a foreign trust.

June 10, 2024 1640 Bulletin No. 2024–24
3. Information Statements
Proposed §1.6048-4(c) lists four types
of information statements that may be
provided by a foreign trust if a U.S. per-
son receives a distribution (including
a loan of cash or marketable securities
or the use of other trust property) from
the foreign trust – Foreign Grantor Trust
Owner Statement, Foreign Grantor Trust
Beneficiary Statement, Foreign Non-
grantor Trust Beneficiary Statement,
and Foreign-Owned Grantor Trust Ben-
eficiary Statement. The instructions for
Form 3520 will be modified after these
regulations are finalized to include a list
of items that must be included on a For-
eign-Owned Grantor Trust Beneficiary
Statement. The list will be similar to the
lists of items that must be included on
the Foreign Grantor Trust Beneficiary
Statement and the Foreign Nongrantor
Trust Beneficiary Statement. A U.S. per-
son who receives one of these statements
may use the statement to determine the
tax consequences of the distribution.
4. Tax Consequences of Distributions
Proposed §1.6048-4(d) describes the
rules that a U.S. person (other than a U.S.
owner of the distributing trust) must use
to determine the tax consequences of a
distribution from a foreign trust other
than a distribution that is a loan of cash or
marketable securities or the use of other
trust property that is not treated as a sec-
tion 643(i) distribution under proposed
§1.643(i)-1. Two methods to determine
the tax consequences are provided: (i)
the actual calculation method and (ii) the
default calculation method. If the U.S. per-
son who receives the distribution does not
receive a copy of the relevant statement
(see proposed §1.6048-4(c)), the U.S. per-
son must determine the tax consequences
of the distribution under the default calcu-
lation method. A U.S. person who receives
the relevant statement generally may com-
pute the tax consequences of the distribu-
tion under either the actual calculation
method or the default calculation method.
However, a U.S. person may not use the
actual calculation method if the U.S. per-
son knows or has reason to know that the
information in the relevant statement is
incorrect. Additionally, if the U.S. person
has previously used the default calculation
method with respect to distributions from
the foreign trust, the U.S. person must
consistently use the default calculation
method to determine the tax consequences
of any subsequent distributions from the
trust for all future years, except for the
year in which the trust terminates.
Under the actual calculation method
provided in proposed §1.6048-4(d)(2),
a U.S. person who receives a Foreign
Grantor Trust Beneficiary Statement or
a Foreign-Owned Grantor Trust Bene-
ficiary Statement from the foreign trust
determines the income tax consequences
of the distribution as a distribution being
made from a grantor trust. Thus, if the
distribution is a gift under section 102,
the U.S. person does not include the
distribution in gross income, but the
distribution remains subject to the pro-
posed §1.6048-4 reporting requirements.
A U.S. person who receives a Foreign
Nongrantor Trust Beneficiary Statement
determines the tax consequences of the
distribution by applying the rules of sub-
parts C and D of Part 1 of subchapter J of
chapter 1 of the Code.
Under the default calculation method
provided in proposed §1.6048-4(d)(3)
(i)(A), the U.S. person treats a portion
of the distribution as a distribution of
current income based on the average
amount of the distributions that the U.S.
person received from the foreign trust
during the prior three taxable years, with
only the excess amount of the distribu-
tion (that is, the amount that exceeds
125 percent of that average) treated as
an accumulation distribution within the
meaning of section 665(b) consisting of
undistributed net income (UNI) of the
foreign trust. In applying the default cal-
culation method, in the absence of actual
information provided on a statement
described in proposed §1.6048-4(c), the
U.S. person must presume that the appli-
cable number of years the foreign trust
has been in existence is ten years and
that no taxes described in section 665(d)
have been imposed on the trust in any
applicable previous year (even if a dis-
tribution has been made and tax under
section 665(d) has previously been
imposed). These rules are consistent
with the default calculation method that
is currently prescribed in the instruc-
tions for Part III of Form 3520. The U.S.
person’s use of the default calculation
method does not affect any calculations
made by the foreign trust for purposes of
trust accounting. See proposed §1.6048-
4(d)(3)(ii).
5. Accumulation distributions and U.S.
Agents
Proposed §1.6048-4(e) provides that,
if a U.S. person fails to provide adequate
records to the IRS for purposes of deter-
mining the income tax consequences of a
distribution from a foreign trust (within the
meaning of proposed §1.6048-4(b)) other
than a loan or use of trust property that is
not treated as a section 643(i) distribution
under proposed §1.643(i)-1, then the entire
distribution is treated as an accumulation
distribution includible in the U.S. person’s
income. However, if the trustee of the
foreign trust authorizes a U.S. person to
act as the trust’s limited agent under the
rules prescribed in proposed §1.6048-3(e),
then the IRS can summons and examine
trust records through the U.S. agent and
thus may determine the tax consequences
of the distribution under the general rules
provided in proposed §1.6048-4(d)(1)
rather than treating the entire distribution
as an accumulation distribution.
6. Coordination with the Rule for
Reporting Large Foreign Gifts
Proposed §1.6048-4(f) addresses the
interaction of proposed §1.6048-4 and
proposed §1.6039F-1. If a U.S. person
receives a distribution from a foreign trust,
the U.S. person must report the distribu-
tion under proposed §1.6048-4(a) and not
under proposed §1.6039F-1, regardless of
whether the distribution is taxable to the
U.S. person.
D. Exceptions
1. Exceptions to Reporting Transfers of
Property to Foreign Trusts
Proposed §1.6048-5(a) provides an
exception from section 6048(a) reporting
based on section 6048(a)(3)(B). The pro-
posed regulations provide that, for pur-
poses of proposed §1.6048-2, a reportable
event does not include any of the follow-

Bulletin No. 2024–24 1641 June 10, 2024
ing: (1) a transfer of property to a foreign
trust that is a transfer for fair market value
within the meaning of §1.679-4(b) (other
than a transfer described in the following
sentence); (2) any transfer of property to
certain compensatory foreign trusts, as
described in section 402(b), 404(a)(4),
or 404A; and (3) any transfer of prop-
erty to a foreign trust provided that the
trust has received a determination letter
from the IRS that has not been revoked
that recognizes the trust as an organiza-
tion described in section 501(c)(3) that is
exempt from Federal income tax under
section 501(a). However, a reportable
event does include a transfer for fair
market value if the transfer is made by a
U.S. transferor that is a related person (as
defined in §1.679-1(c)(5)) with respect to
the foreign trust in exchange for any obli-
gation of the trust or of a related person,
without regard to whether such obliga-
tion is a qualified obligation described in
proposed §1.679-4(d).
2. Additional Exceptions to Reporting
Transactions with Foreign Trusts
Proposed §1.6048-5(b) through (e)
provides additional exceptions from sec-
tion 6048 reporting based on the authority
granted to the IRS by section 6048(d)(4)
to suspend or modify the requirements of
section 6048.
i. Tax-favored foreign retirement trusts,
non-retirement savings trusts, and de
minimis savings trusts
Proposed §1.6048-5(b) provides an
exception from section 6048(a) through
(c) and proposed §§1.6048-2 through
1.6048-4 for certain eligible U.S. indi-
viduals’ transactions with, or ownership
of, certain tax-favored foreign retirement
trusts, non-retirement savings trusts, and
de minimis savings trusts. These excep-
tions to section 6048 reporting generally
follow the exceptions provided under
Rev. Proc. 2020-17, but are modified to
address comments received, including
comments requesting that future guid-
ance include an increase to the applicable
contribution limitation thresholds, rules
for tax-favored foreign retirement trusts
that may allow limited contributions of
unearned income, and relief with respect
to certain trusts that do not fall within
the listed categories but that have values
below a certain threshold.
A tax-favored foreign retirement trust
means a foreign trust that is established
under the laws of a foreign jurisdiction to
operate exclusively or almost exclusively
to provide, or to earn income for the pro-
vision of, pension or retirement benefits
and ancillary or incidental benefits, and
that meets certain additional require-
ments, such as contribution limitations
or value thresholds, conditions for with-
drawal, and information reporting. See
proposed §1.6048-5(b)(2). A tax-favored
foreign non-retirement savings trust
means a foreign trust that is established
under the laws of a foreign jurisdiction
to operate exclusively or almost exclu-
sively to provide, or to earn income for
the provision of, medical, disability, or
educational benefits, and that also meets
certain additional requirements, such as
contribution limitations, conditions for
withdrawal, and information reporting.
See proposed §1.6048-5(b)(3). A tax-fa-
vored foreign de minimis savings trust
means a foreign trust that is established
under the laws of a foreign jurisdiction
to operate as a savings vehicle, that
is not treated as a tax-favored foreign
retirement trust or a tax-favored foreign
non-retirement savings trust, and that
meets certain additional requirements,
such as information reporting, and whose
value is under a de minimis threshold.
See proposed §1.6048-5(b)(4).
The Treasury Department and the IRS
are of the view that it would be appropri-
ate to exempt U.S. individuals from the
requirement to provide information about
these foreign trusts for several reasons.
First, these foreign trusts generally are
subject to written restrictions, such as con-
tribution limitations, conditions for with-
drawal, and information reporting, under
the laws of the country in which they are
established that are broadly consistent
with the eligibility requirements under the
Code for U.S. trusts serving similar pol-
icy goals. Second, U.S. individuals with
an interest in these trusts may be required
under section 6038D to separately report
information about their interests in
accounts held by, or through, these trusts.
Additionally, with respect to tax-favored
foreign de minimis savings trusts and
tax-favored foreign retirement trusts, the
Treasury Department and the IRS are of
the view that exempting U.S. individuals
from the section 6048 requirements based
on the value of the trust is appropriate and
consistent with the reporting thresholds
under section 6038D.
ii. Distributions from certain foreign
compensatory trusts
The proposed regulations imple-
ment the exception from section 6048(c)
reporting provided in section V of Notice
97-34 for distributions from certain
foreign compensatory trusts described
in §1.672(f)-3(c)(1) (section 402(b)
employee trusts and foreign rabbi trusts).
Proposed §1.6048-5(c). The exception
applies only if the U.S. individual who
receives the distribution reports the distri-
bution as compensation income on a Fed-
eral income tax return.
iii. Distributions received by certain
domestic charitable organizations
Proposed §1.6048-5(d) implements
the exception from section 6048(c)
reporting provided in section V of Notice
97-34 for distributions received by a
domestic organization described in sec-
tion 501(c)(3). The exception applies
only if the domestic organization has
received a determination letter from the
IRS that has not been revoked recogniz-
ing the domestic organization’s exemp-
tion from Federal income tax under sec-
tion 501(a) as an organization described
in section 501(c)(3).
iv. Certain trusts located in a mirror code
possession
Proposed §1.6048-5(e) provides an
exemption from sections 6048(a) through
(c) for a trust located in a mirror code pos-
session to the extent the responsible party
(within the meaning of section 6048(a)
(4)), U.S. owner, or U.S. recipient is a
bona fide resident (within the meaning
of §1.937-1(b)) of the mirror code pos-
session. For this purpose, a mirror code
possession is a possession of the United
States where, under the income tax system
of the possession, the income tax liability
of the residents of the possession is deter-

June 10, 2024 1642 Bulletin No. 2024–24
mined by reference to the income tax laws
of the United States as if the possession
were the United States. A trust is located
in a mirror code possession if a court
within such mirror code possession is able
to exercise primary supervision over the
administration of the trust and one or more
bona fide residents of the mirror code pos-
session have the authority to control all
substantial decisions of the trust.
E. Special rules
1. Dual Resident and Dual Status
Taxpayers
Proposed §1.6048-6(a)(1) provides
that a dual resident taxpayer (within the
meaning of §301.7701(b)-7(a)(1)) who
computes U.S. income tax liability as a
nonresident alien and complies with the
filing requirements of §301.7701(b)-7(b)
and (c) is not treated as a U.S. person
for purposes of the proposed regulations
for the portion of the year that the dual
resident taxpayer is treated as a nonres-
ident alien. Similarly, under proposed
§1.6048-6(a)(2), a dual status taxpayer
who abandons U.S. citizenship or res-
idence during the tax year or acquires
U.S. citizenship or residence during the
taxable year, as provided in §1.6012-
1(b)(2)(ii), is not treated as a U.S. person
for purposes of the proposed regulations
for the portion of the year that the dual
status taxpayer is treated as a nonresi-
dent alien. As a result, these taxpayers
are not subject to section 6048 reporting
for the portion of the year during which
they are treated as nonresident aliens for
purposes of computing their U.S. income
tax liability.
2. Reporting by all U.S. Transferors and
Recipients
Section 6048(d)(1) provides that, “For
purposes of [section 6048], in determining
whether a United States person makes a
transfer to, or receives a distribution from,
a foreign trust, the fact that a portion of
such trust is treated as owned by another
person under the rules of subpart E of Part
I of subchapter J of chapter 1 shall be disre-
garded.” The Treasury Department and the
IRS are of the view that it is necessary to
receive information about transfers to, and
distributions from, foreign grantor trusts
with regard to all U.S. transferors and U.S.
recipients, including the U.S. owner, in
order to administer the foreign trust pro-
visions and to determine a taxpayer’s U.S.
tax liability with respect to foreign trusts.
For example, the IRS uses this information
to determine whether the transferor should
be treated as the owner of the foreign trust,
the value of the foreign trust’s corpus at the
end of the year for purposes of assessing
penalties under section 6677, and the tax
consequences of distributions in later years,
such as distributions of corpus or UNI, if
the foreign trust becomes a nongrantor trust
(because, for example, the grantor dies).
Therefore, proposed §1.6048-6(b) clari-
fies that, pursuant to section 6048(d)(1), a
transfer to, or a distribution from, a foreign
trust is reportable under section 6048(a)
and (c) and the proposed regulations with-
out regard to whether the trust is a grantor
trust or a nongrantor trust, and whether or
not there are any U.S. income tax conse-
quences associated with the transfer or dis-
tribution.
3. Domestic Trust with Substantial
Foreign Activities or Assets
Proposed §1.6048-6(c) is reserved for
rules under section 6048(d)(2). Section
6048(d)(2) provides that, to the extent
provided in regulations, a domestic trust
is treated as a foreign trust for purposes
of sections 6048 and 6677 if the trust has
substantial activities, or holds substantial
property, outside the United States. See
section III.D.4 of the Background.
4. Joint Filers
Proposed §1.6048-6(d) provides that
married U.S. persons, each of whom
is subject to the information reporting
requirements under proposed §1.6048-
2(a) (as a grantor or transferor required
to file Part I of Form 3520), proposed
§1.6048-3(a)(2) (as a U.S. owner of a for-
eign trust required to file a substitute Form
3520-A), or proposed §1.6048-4(a) (as a
U.S. recipient of a distribution from a for-
eign trust required to file Part III of Form
3520) for the same foreign trust, may file
one Form 3520 for purposes of proposed
§§1.6048-2 through 1.6048-4, but only if
they file a joint income tax return under
section 6013 for the tax year for which
reporting is required.
V. Section 6677 – Civil Penalties for
Failure to File Information with Respect
to Certain Foreign Trusts
Proposed §1.6677-1 provides rules for
civil penalties that may be assessed if any
notice or return required to be filed under
proposed §§1.6048-2 through 1.6048-4 is
not timely filed or contains incomplete or
incorrect information. The proposed reg-
ulations provide for three separate civil
penalties that correspond to each separate
reporting requirement under proposed
§1.6048-2, §1.6048-3, and §1.6048-4. The
Treasury Department and the IRS inter-
pret section 6677 as assessing a penalty
based on a percentage of a gross report-
able amount, a term that is defined sep-
arately under section 6677(c) and in the
proposed regulations with respect to each
corresponding section 6048 reporting
requirement. This interpretation is consis-
tent with the plain text of sections 6048
and 6677 and the purpose of the 1996
Act’s modifications to these sections,
which is to discourage U.S. persons from
using foreign trusts to avoid their U.S. tax
obligations.
A. General rules
Proposed §1.6677-1(a)(1) provides
that, as a general rule, a person who fails
to timely file a required notice or return,
or fails to provide complete and correct
information, is subject to a penalty equal
to the greater of $10,000 or 35 percent of
the applicable gross reportable amount
(defined in proposed §1.6677-1(c)) for
each such failure (or for each year, in the
case of a failure under proposed §1.6048-3
relating to information reporting about
U.S. owners of foreign trusts). If a per-
son reports an amount that is less than
the gross reportable amount, the penalty
is based on the amount that is unreported.
Proposed §1.6677-1(a)(2) provides
that, if the failure to comply with the
applicable reporting requirement contin-
ues for more than 90 days after the day on
which the IRS mails notice of the failure
to the U.S. person required to pay the pen-
alty, the person is required to pay an addi-
tional penalty of $10,000 for each 30-day

Bulletin No. 2024–24 1643 June 10, 2024
period (or fraction thereof) during which
the failure continues.
Proposed §1.6677-1(a)(3)(i) addresses
maximum penalties. Proposed §1.6677-
1(a)(3)(i) provides that the aggregate
amount of the penalties imposed by pro-
posed §1.6677-1(a)(1) and (2) (as modi-
fied by proposed §1.6677-1(b), if applica-
ble) with respect to any single failure may
not exceed the gross reportable amount
with respect to that failure (provided that
the IRS receives enough information to
accurately determine the gross reportable
amount). In some cases, the IRS can begin
to assess penalties before it has received
enough information to determine the
gross reportable amount. If the aggregate
amount of the penalty collected exceeds
the applicable gross reportable amount
(because the penalty was assessed and
collected before the IRS was able to deter-
mine the gross reportable amount), the
IRS will refund the excess amount pursu-
ant to section 6402.
Proposed §1.6677-1(a)(3)(ii) provides
that the limitations period for claims for
refund under section 6511(a) and (b)
applies to the refund of any excess amount.
B. Failures to comply with proposed
§1.6048-3
Proposed §1.6677-1(b) makes two
modifications to the rules of proposed
§1.6677-1(a) in the case of a notice or
return required to be filed under proposed
§1.6048-3 (relating to information report-
ing about U.S. owners of foreign trusts).
First, in the case of a notice or return
required to be filed by a foreign trust
under proposed §1.6048-3(a), the U.S.
owner, rather than the foreign trust, must
pay the penalty. Second, the amount of
any penalty that initially is imposed under
proposed §1.6677-1(a)(1) is the greater
of $10,000 or five percent (rather than 35
percent) of the gross reportable amount.
C. Gross reportable amount
Proposed §1.6677-1(c)(1) provides
that the term gross reportable amount
means (i) the gross value of the property
involved in the reportable event (deter-
mined as of the date of the event) in the
case of a failure relating to proposed
§1.6048-2, (ii) the gross value of the por-
tion of the foreign trust’s assets (at the
close of the trust’s taxable year) treated as
owned by the U.S. person in the case of
a failure relating to proposed §1.6048-3,
and (iii) the gross amount of the distribu-
tion or deemed distribution in the case of
a failure relating to proposed §1.6048-4.
Proposed §1.6677-1(c)(2) provides guid-
ance on how to determine the gross value
or gross amount of property for purposes
of proposed §1.6677-1(c)(1).
D. Reasonable cause
Proposed §1.6677-1(d) provides that
the penalty does not apply if the per-
son required to file the notice or return
(including a U.S. person who is treated
as an owner of a foreign trust that fails
to comply with proposed §1.6048-3(b))
shows that the failure to file is due to
reasonable cause and not due to willful
neglect. The determination of whether
a failure is due to reasonable cause and
not due to willful neglect will be made
under the principles set out in §1.6664-4
and §301.6651-1(c) and will be made on
a case-by-case basis, taking into account
all pertinent facts and circumstances.
The fact that a foreign jurisdiction would
impose a civil or criminal penalty on any
person for disclosing the required infor-
mation will not satisfy the reasonable
cause exception. In addition, refusal on
the part of a foreign trustee to provide
information for any reason, including
difficulty in producing the required infor-
mation or the existence of provisions in
the trust instrument that prevent the dis-
closure of required information, does not
constitute reasonable cause.
E. Inapplicability of deficiency
procedures
Proposed §1.6677-1(e) provides that
deficiency procedures do not apply in the
case of the assessment or collection of a
penalty imposed under section 6677.
F. Joint filers
Proposed §1.6677-1(f)(1) provides
that married U.S. persons who jointly
file Form 3520 for purposes of proposed
§§1.6048-2 through 1.6048-4 and jointly
file an income tax return under section
6013 (as described section IV.E of this
Explanation of Provisions) are treated as a
single U.S. person for purposes of assess-
ing section 6677 penalties.
In addition, proposed §1.6677-1(f)(2)
provides that the IRS may treat married
U.S. persons who file a joint income tax
return under section 6013, but who did
not file an information return as required
under §§1.6048-2 through 1.6048-4,
as a single U.S. person for purposes of
assessing section 6677 penalties, unless
the IRS determines that, based on all
the facts and circumstances, only one
of the spouses was subject to the infor-
mation reporting requirement (for exam-
ple, because only one spouse had an
interest in the property constituting the
transfer to, or receipt from, a foreign
trust). In these cases, it can be difficult
for the IRS to determine who, between
spouses, should be treated as the trans-
feror, grantor, or owner of, or the recip-
ient of a distribution from, a foreign
trust (because, for example, a transfer
of property to, or the receipt of property
from, a foreign trust was made from (or
to) a joint bank account). By enabling
the IRS to assess section 6677 penalties
on a joint and several basis against mar-
ried U.S persons who do not file infor-
mation returns required under section
6048, proposed §1.6677-1(f)(2) allows
the IRS to properly enforce section
6048, while still allowing each spouse
to demonstrate that they should not be
jointly and severally liable for the sec-
tion 6677 penalties assessed (for exam-
ple, because one spouse did not have an
interest in the underlying property giv-
ing rise to a reporting requirement under
proposed §§1.6048-2 through 1.6048-4).
The liability of married U.S. persons
treated as a single person is joint and sev-
eral pursuant to proposed §1.6677-1(f)(3).
VI. Proposed Applicability Dates
These regulations are proposed to apply
to transactions with foreign trusts and the
receipt of foreign gifts in taxable years
beginning after the date on which the final
regulations are published in the Federal
Register. However, a taxpayer may rely
on these proposed regulations for any tax-
able year ending after May 8, 2024 and
beginning on or before the date that final

June 10, 2024 1644 Bulletin No. 2024–24
regulations are published in the Federal
Register, provided that the taxpayer and
all related persons (within the meaning
of sections 267(b) and 707(b)(1)) apply
the proposed regulations in their entirety
and in a consistent manner for all taxable
years beginning with the first taxable year
of reliance until the applicability date of
the final regulations.
Special Analyses
I. Regulatory Planning and Review —
Economic Analysis
Pursuant to the Memorandum of
Agreement, Review of Treasury Regula-
tions under Executive Order 12866 (June
9, 2023), tax regulatory actions issued by
the IRS are not subject to the requirements
of section 6 of Executive Order 12866, as
amended. Therefore, a regulatory impact
assessment is not required.
II. Paperwork Reduction Act
The Paperwork Reduction Act of 1995
(44 U.S.C. 3501–3520) (PRA) generally
requires that a Federal agency obtain the
approval of the Office of Management
and Budget (OMB) before collecting
information from the public, whether such
collection of information is mandatory,
voluntary, or required to obtain or retain
a benefit.
The estimated number of taxpayers
impacted by these proposed regulations
is 58,000. This is the number of taxpayers
who currently file Form 3520 and Form
3520-A to report information required by
sections 643(i), 679, 6039F, and 6048 as
reflected under OMB control numbers
1545-0074 (for individual filers), 1545-
0123 (for business filers), and 1545-0159
(for trust and estate filers). However, the
Treasury Department and the IRS estimate
that 58,000 is the upper bound because the
proposed regulations exempt certain tax-
payers from information reporting under
sections 6039F and 6048. See, e.g., pro-
posed §§1.6039F-1(c) and 1.6048-5.
The collections of information in the
proposed regulations are in proposed §§
1.643(i)-1(b)(2)(ii), 1.643(i)-1(c)(2)(ii),
1.679-2(d)(1), 1.679-4(d)(1)(ii), 1.6039F-
1(a), 1.6039F-1(e), 1.6048-2(a), 1.6048-
3(a), 1.6048-4(c), and 1.6677-1(d). In
general, the collections of information
contained in these proposed regulations
are currently reflected in the collection
of information for Form 3520 and Form
3520-A, which have been reviewed and
approved by the OMB in accordance with
the PRA under control numbers 1545-
0074 (for individual filers), 1545-0123
(for business filers), and 1545-0159 (for
trust and estate filers). Thus, the burden
estimates for OMB control numbers 1545-
0074, 1545-0123, and 1545-0159 will be
updated to reflect the collections of infor-
mation associated with the proposed reg-
ulations.
An agency may not conduct or sponsor
and a person is not required to respond to
a collection of information unless it dis-
plays a valid OMB control number.
III. Regulatory Flexibility Act
When an agency issues a rulemaking
proposal, the Regulatory Flexibility Act
(5 U.S.C. chapter 6) (RFA) requires the
agency “to prepare and make available
for public comment an initial regulatory
flexibility analysis” that will “describe
the impact of the proposed rule on small
entities.” See 5 U.S.C. 603(a). Section 605
of the RFA provides an exception to this
requirement if the agency certifies that the
proposed rulemaking will not have a sig-
nificant economic impact on a substantial
number of small entities. A small entity
is defined as a small business, small non-
profit organization, or small governmental
jurisdiction. See 5 U.S.C. 601(3) through
(6).
The Treasury Department and the IRS
do not expect the proposed regulations to
have a significant economic impact on a
substantial number of small entities within
the meaning of sections 601(3) through
601(6) of the RFA. The proposed regu-
lations generally reflect the existing col-
lection of information requirements for
Form 3520 and Form 3520-A. However,
because the proposed regulations gen-
erally apply to any U.S. person, includ-
ing small entities, that engage in certain
transactions with foreign trusts or receive
large foreign gifts, an initial regulatory
flexibility analysis has been prepared for
this notice of proposed rulemaking under
5 U.S.C. chapter 6 and is provided below.
The Treasury Department and the IRS
request comments on the number of small
entities that may be impacted and whether
that impact will be economically signifi-
cant.
A. Statement of the need for, and
objectives of, the proposed regulations
As discussed in the Background and
Explanation of Provisions, the proposed
regulations implement sections 643(i), 679,
6039F, 6048 and 6677 (the foreign trust
and gift provisions), which were added
to the Code or significantly modified to
address the use of foreign trusts and simi-
lar offshore arrangements by United States
persons to avoid U.S. tax. These provisions
also enhance the IRS’s ability to obtain
information regarding these offshore
arrangements, including the receipt of large
foreign gifts by United States persons. The
proposed regulations address potential
uncertainty under current law, including
the necessary requirements for complying
with the foreign trust and gift provisions,
and the relevant tax consequences and
potential penalties for compliance failures.
B. Small entities to which the proposed
regulations will apply
The proposed regulations gener-
ally define a United States person
using the definition in section 7701(a)
(30), which includes domestic partner-
ships and domestic corporations, sub-
ject to exceptions for certain entities
that are exempt from taxation under
chapter 1 of the Code. See, e.g., pro-
posed §§ 1.643(i)-1(d)(12), 1.679-1(c)
(2), 1.6039F-1(a), and 1.6048-1(b)(7).
Because the number of small businesses
that file Form 3520 and Form 3520-A is
reflected in the taxpayer compliance bur-
den provided for U.S. business income
tax returns under OMB 1545-0123, an
estimate of the number of small busi-
nesses affected by the proposed regula-
tions is not currently feasible, and there-
fore, this initial regulatory flexibility
analysis assumes that a substantial num-
ber of small businesses will be affected.
The Treasury Department and the IRS do
not expect that the proposed regulations
will affect a substantial number of small
nonprofit organizations or small govern-
mental jurisdictions.

Bulletin No. 2024–24 1645 June 10, 2024
C. Projected reporting, recordkeeping,
and other compliance requirements
The proposed regulations generally
do not impose additional reporting,
recordkeeping, or other compliance
obligations. The proposed regulations
are substantially similar to the existing
guidance in Notice 97-34, Revenue Pro-
cedure 2014-55, and Revenue Procedure
2020-17 and the existing instructions
to Form 3520 and Form 3520-A. The
proposed regulations include certain
limited clarifications to the existing
guidance and also provide additional
taxpayer relief, including with respect
to small entities. Moreover, even with-
out the proposed regulations, small enti-
ties would continue to be required to file
Form 3520 or Form 3520-A to comply
with the statutory requirements. There-
fore, these regulations generally are not
expected to impose new compliance
burdens, other than the time necessary
for small entities to read the proposed
regulations.
D. Duplicate, overlapping, or relevant
Federal rules
The Treasury Department and the IRS
are not aware of any Federal rules that
duplicate, overlap, or conflict with the
proposed regulations.
E. Alternatives considered
The foreign trust and gift provisions
apply to any United States person, and
the statutes do not establish different rules
for small entities. Because the foreign
trust and gift provisions are intended to
address the use of foreign trusts and simi-
lar arrangements to avoid U.S. tax, which
can be structured using large and small
business entities, the Treasury Department
and the IRS are of the view that the pro-
posed regulations should apply uniformly
to all business entities. The Treasury
Department and the IRS did not consider
any significant alternatives. The proposed
regulations address potential uncertainty
under current law without imposing addi-
tional economic burdens on these entities.
Therefore, the proposed regulations adopt
the approach with the least economic
impact.
IV. Section 7805(f)
Pursuant to section 7805(f) of the Inter-
nal Revenue Code, this regulation will be
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administration
for comment on its impact on small busi-
ness.
V. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates
Reform Act of 1995 requires that agencies
assess anticipated costs and benefits and
take certain other actions before issuing a
final rule that includes any Federal man-
date that may result in expenditures in any
one year by a State, local, or Tribal gov-
ernment, in the aggregate, or by the pri-
vate sector, of $100 million in 1995 dol-
lars, updated annually for inflation. The
proposed regulations do not include any
Federal mandate that may result in expen-
ditures by State, local, or Tribal govern-
ments, or by the private sector in excess of
that threshold.
VI. Executive Order 13132: Federalism
Executive Order 13132 (entitled Fed-
eralism) prohibits an agency from publish-
ing any rule that has federalism implica-
tions if the rule either imposes substantial,
direct compliance costs on State and local
governments, and is not required by stat-
ute, or preempts State law, unless the
agency meets the consultation and fund-
ing requirements of section 6 of the Exec-
utive Order. The proposed regulations
do not have federalism implications, do
not impose substantial direct compliance
costs on State and local governments, and
do not preempt State law within the mean-
ing of the Executive order.
Comments and Requests for a Public
Hearing
Before these proposed amendments
to the regulations are adopted as final
regulations, consideration will be given
to any comments regarding the notice of
proposed rulemaking that are submitted
timely to the IRS, as prescribed in this
preamble under the “Addresses” head-
ing. The Treasury Department and the
IRS request comments on all aspects of
the proposed rules. Comments are spe-
cifically requested in Section I.B. of the
Explanation of Provisions, regarding
whether qualified obligation rules are
needed for loans of marketable securities
and regarding the scope and application of
the exception from section 643(i) distribu-
tion treatment for certain loans made by a
foreign corporation. All comments will be
made available at www.regulations.gov.
Once submitted to the Federal eRulemak-
ing Portal, comments cannot be edited or
withdrawn.
A public hearing has been scheduled
for August 21, 2024, at 10:00 a.m. ET, in
the Auditorium at the Internal Revenue
Building, 1111 Constitution Avenue, NW.,
Washington DC. Due to building security
procedures, visitors must enter at the Con-
stitution Avenue entrance. In addition, all
visitors must present photo identification
to enter the building. Because of access
restrictions, visitors will not be admitted
beyond the immediate entrance area more
than 30 minutes before the hearing starts.
Participants may alternatively attend the
public hearing by telephone.
The rules of 26 CFR 601.601(a)(3)
apply to the hearing. Persons who wish to
present oral comments at the hearing must
submit an outline of the topics to be dis-
cussed and the time to be devoted to each
topic by July 8, 2024. Outlines must be
submitted electronically via the Federal
eRulemaking Portal at www.regulations.
gov (indicate IRS and REG-124850-08).
A period of 10 minutes will be allotted
to each person for making comments.
An agenda showing the scheduling of the
speakers will be prepared after the dead-
line for receiving outlines has passed.
Copies of the agenda will be available free
of charge at the hearing. If no outline of
the topics to be discussed at the hearing is
received by July 8, 2024, the public hear-
ing will be cancelled. If the public hearing
is cancelled, a notice of cancellation of
the public hearing will be published in the
Federal Register.
Individuals who want to testify in per-
son at the public hearing must send an
email to publichearings@irs.gov to have
your name added to the building access
list. The subject line of the email must
contain the regulation number REG-
124850-08 and the language TESTIFY
in Person. For example, the subject line

June 10, 2024 1646 Bulletin No. 2024–24
may say: Request to TESTIFY in Person
at Hearing for REG-124850-08.
Individuals who want to testify by tele-
phone at the public hearing must send an
email to publichearings@irs.gov to receive
the telephone number and access code for
the hearing. The subject line of the email
must contain the regulation number REG-
124850-08 and the language TESTIFY
Telephonically. For example, the subject
line may say: Request to TESTIFY Tele-
phonically at Hearing for REG-124850-08.
Individuals who want to attend the pub-
lic hearing in person without testifying must
also send an email to publichearings@irs.
gov to have your name added to the build-
ing access list. The subject line of the email
must contain the regulation number REG-
124850-08 and the language ATTEND In
Person. For example, the subject line may
say: Request to ATTEND Hearing in Per-
son for REG-124850-08. Requests to attend
the public hearing must be received by 5:00
p.m. ET on August 19, 2024.
Hearings will be made accessible to
people with disabilities. To request special
assistance during a hearing please contact
the Publications and Regulations Branch
of the Office of Associate Chief Counsel
(Procedure and Administration) by send-
ing an email to publichearings@irs.gov
(preferred) or by telephone at (202) 317-
6901 (not a toll-free number) by at least
August 16, 2024.
Statement of Availability of IRS
Documents
IRS Revenue Procedures, Revenue
Rulings, Notices and other guidance cited
in this document are published in the
Internal Revenue Bulletin or Cumulative
Bulletin and are available from the Super-
intendent of Documents, U.S. Govern-
ment Publishing Office, Washington, DC
20402, or by visiting the IRS website at
https://www.irs.gov.
Drafting Information
The principal authors of these proposed
regulations are Lara A. Banjanin, Tracy M.
Villecco, and S. Eva Wolf of the Office of
Associate Chief Counsel (International),
and M. Grace Fleeman, formerly of the
Office of Associate Chief Counsel (Inter-
national). However, other personnel from
the Treasury Department and the IRS par-
ticipated in their development.
List of Subjects
26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Proposed Amendments to the
Regulations
Accordingly, the Treasury Department
and IRS propose to amend 26 CFR part 1
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 is amended by adding entries in
numerical order and revising entries for
§§1.679-1, 1.679-2, and 1.679-4 to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
Section 1.643(i)-1 also issued under 26
U.S.C. 643.
Sections 1.643(i)-2 through 1.643(i)-4
also issued under 26 U.S.C. 643 and 6048.
Section 1.643(i)-5 also issued under 26
U.S.C. 643.
* * * * *
Section 1.679-1 also issued under 26
U.S.C. 643 and 679.
Section 1.679-2 also issued under 26
U.S.C. 643 and 679.
Section 1.679-4 also issued under 26
U.S.C. 643 and 679.
* * * * *
Section 1.6039F-1 also issued under 26
U.S.C. 6039F.
* * * * *
Sections 1.6048-1 through 1.6048-6
also issued under 26 U.S.C. 643 and 6048.
* * * * *
Section 1.6677-1 also issued under 26
U.S.C. 643 and 6048.
* * * * *
Par. 2. Sections 1.643(i)-1, 1.643(i)-2,
1.643(i)-3, 1.643(i)-4, and 1.643(i)-5 are
added to read as follows:
§1.643(i)-1 Loans from and use of trust
property of foreign nongrantor trusts.
(a) Loans and use of trust property—
(1) In general. For purposes of subparts B,
C, and D of part I of subchapter J of chap-
ter 1 of the Internal Revenue Code, a loan
or use of trust property described in para-
graph (b) or (c) of this section is treated as
a section 643(i) distribution from a foreign
trust to a U.S. grantor or beneficiary of the
foreign trust under subchapter J of chapter
1 of the Internal Revenue Code, as pro-
vided in such paragraphs. Paragraph (d)
of this section provides definitions for this
section and §§1.643(i)-2 through 1.643(i)-
5. Section 1.643(i)-2 provides exceptions
to the general rules of this section. Section
1.643(i)-3 provides rules relating to the
determination of the amount treated as a
section 643(i) distribution and the tax con-
sequences of a section 643(i) distribution.
Section 1.643(i)-4 provides examples,
and §1.643(i)-5 provides the applicabil-
ity date for the rules in this section and
§§1.643(i)-2 through 1.643(i)-4.
(2) Interaction with section 6048(c).
For rules relating to information reporting
of loans from foreign trusts and the use of
property of a foreign trust, see §1.6048-
4. That provision applies without regard
to whether the loan or use of property is
treated as a section 643(i) distribution or
has any other tax consequences, and with-
out regard to whether the foreign trust is a
nongrantor or grantor trust.
(b) Loan of cash or marketable secu-
rities from foreign nongrantor trust gen-
erally treated as a distribution—(1) In
general. Except as provided in §1.643(i)-
2, any direct or indirect loan of cash or
marketable securities from a foreign non-
grantor trust (whether from trust corpus or
income) to any U.S. grantor or beneficiary
of that trust or any U.S. person related
to such a U.S. grantor or beneficiary is
treated as a section 643(i) distribution to
the U.S. grantor or beneficiary on the date
such loan is made. For these purposes, a
loan from a nongrantor trust to a grantor
trust or to a disregarded entity is treated as
a loan to the owner of the grantor trust or
of the disregarded entity, respectively. For
example, a loan to a single member LLC
treated as a disregarded entity is treated as
a loan to the owner of the LLC.
(2) Indirect loans—(i) In general.
Except as provided in paragraph (b)(2)
(ii) of this section, an indirect loan of cash
or marketable securities from a foreign
nongrantor trust includes a loan of cash
or marketable securities made by an inter-

Bulletin No. 2024–24 1647 June 10, 2024
mediary, agent, or nominee of the trust,
as well as a loan made to an intermedi-
ary, agent, or nominee of a U.S. grantor or
beneficiary or of a U.S. person related to a
U.S. grantor or beneficiary. For example,
such indirect loans include:
(A) Loans made by any person other
than the trust to either a U.S. grantor or
beneficiary of a foreign trust or any U.S.
person related to a U.S. grantor or benefi-
ciary if the foreign trust provides a guar-
antee (within the meaning of §1.679-3(e)
(4)) for the loan;
(B) Loans made by any person related
to a foreign trust, to either a U.S. grantor
or beneficiary of the trust, or a U.S. person
related to a U.S. grantor or beneficiary;
and
(C) Loans made by a foreign trust to a
foreign person, other than to a nonresident
alien individual grantor or beneficiary of
the trust, if the foreign person is related to
a U.S. grantor or beneficiary of the trust.
(ii) Limitation. The loans described in
paragraphs (b)(2)(i)(B) and (b)(2)(i)(C) of
this section will not be treated as a section
643(i) distribution if the U.S. grantor or
beneficiary:
(A) Satisfies the information reporting
requirements of §1.6048-4 with respect to
the loan, and
(B) Includes an explanatory statement
attached to the U.S. grantor or benefi-
ciary’s Federal income tax return that
demonstrates to the satisfaction of the
Commissioner that the loan would have
been made without regard to the fact that
the U.S. grantor or beneficiary is a grantor
or beneficiary of the foreign trust.
(iii) Effect of indirect loans—(A) In
general. In the case of a loan described in
paragraph (b)(2)(i)(A) or (B) of this sec-
tion, the person making the loan is treated
as an agent of the foreign trust.
(B) Loans to a foreign person related
to a U.S. grantor or beneficiary. In the
case of a loan described in paragraph (b)
(2)(i)(C) of this section, the foreign person
related to the U.S. grantor or beneficiary is
treated as an agent of the U.S. grantor or
beneficiary, and the date the loan is made
to the foreign person is treated as the date
the loan is made to the U.S. grantor or
beneficiary.
(3) Rule for nonresident alien indi-
vidual grantors or beneficiaries of a for-
eign trust who become U.S. persons. If
a nonresident alien individual who is a
grantor or beneficiary of a foreign trust
receives a loan from the trust and, while
the loan is outstanding, becomes a U.S.
resident (within the meaning of section
7701(b)) or a U.S. citizen within two
years after the date the loan was made,
the loan will be treated as a section 643(i)
distribution with respect to the outstand-
ing amount of the loan as of the date the
individual acquires U.S. residence or cit-
izenship unless an exception described in
§1.643(i)-2 applies.
(c) Use of trust property generally
treated as a distribution—(1) In gen-
eral. Except as provided in §1.643(i)-2,
any direct or indirect use of property of
a foreign trust, other than a loan of cash
or marketable securities, by any U.S.
grantor or beneficiary of the trust or any
U.S. person related to a U.S. grantor or
beneficiary is treated as a section 643(i)
distribution to the U.S. grantor or benefi-
ciary in the taxable year in which the use
occurs. For these purposes, use of prop-
erty of a nongrantor trust by a grantor
trust or by a disregarded entity is treated
as use by the owner of the grantor trust
or of the disregarded entity, respectively.
For example, use of trust property by a
single member LLC treated as a disre-
garded entity would be treated as use by
the owner of the LLC.
(2) Indirect use of trust property—(i)
In general. Indirect use of property of a
foreign trust includes use by an agent or
nominee of a U.S. grantor or beneficiary
of the trust or an agent or nominee of a
U.S. person related to a U.S. grantor or
beneficiary. Indirect use of trust property
also includes use by a foreign person,
other than a nonresident alien individual
beneficiary of the trust, if the foreign per-
son is related to a U.S. grantor or benefi-
ciary of the trust, unless paragraph (c)(2)
(ii) of this section applies.
(ii) Limitation. The use of trust prop-
erty described in the second sentence of
paragraph (c)(2)(i) of this section is not
treated as a section 643(i) distribution to
the U.S. grantor or beneficiary if the U.S.
grantor or beneficiary:
(A) Satisfies the information reporting
requirements of §1.6048-4 with respect to
the use; and
(B) Includes an explanatory statement
attached to the U.S. grantor’s or bene-
ficiary’s Federal income tax return that
demonstrates to the satisfaction of the
Commissioner that the use of trust prop-
erty would have been allowed without
regard to the fact that the U.S. grantor or
beneficiary is a grantor or beneficiary of
the foreign trust.
(iii) Effect of indirect use of trust prop-
erty. In the case of the use of trust prop-
erty by a foreign person related to the U.S.
grantor or beneficiary described in para-
graph (c)(2)(i) of this section, such foreign
person is treated as an agent of the U.S.
grantor or beneficiary.
(d) Definitions. The following defini-
tions apply for purposes of this section
and §§1.643(i)-2 through 1.643(i)-5:
(1) Beneficiary. The term beneficiary
means a person to whom or for whose
benefit, under the terms of the trust instru-
ment or applicable local law, at any time
during the term of the trust or upon termi-
nation, trust income or corpus may be paid
(including pursuant to a power of appoint-
ment that has been exercised in favor of
that person) or accumulated, directly or
indirectly. All references to a U.S. bene-
ficiary mean a beneficiary who is a U.S.
person.
(2) Cash. The term cash includes for-
eign currencies and cash equivalents.
(3) Disregarded entity. The term disre-
garded entity means an entity that, under
§§301.7701–1 through 301.7701–3 of this
chapter, is disregarded as an entity sepa-
rate from its owner.
(4) Foreign person. The term foreign
person means any person who is not a
U.S. person within the meaning of section
7701(a)(30).
(5) Grantor trust. The term grantor
trust means a trust or any portion of a trust
that is treated as owned by any person
under subpart E of part I of subchapter J
of chapter 1 of the Internal Revenue Code.
(6) Loan of cash. Except as provided
in §1.643(i)-2(a)(1), the term loan of cash
includes an extension of credit.
(7) Marketable securities. The term
marketable securities means marketable
securities within the meaning of section
731(c)(2)(A), but not including foreign
currencies.
(8) Nongrantor trust. The term non-
grantor trust means a trust or any portion
of a trust that is not treated as owned by
any person under subpart E of part I of

June 10, 2024 1648 Bulletin No. 2024–24
subchapter J of chapter 1 of the Internal
Revenue Code.
(9) Related. A person will be consid-
ered to be related to another person if the
relationship between such persons would
result in a disallowance of losses under
section 267 or 707(b). In applying section
267 for purposes of the previous sentence,
section 267(c)(4) is applied as if the fam-
ily of an individual includes the spouses
of the members of the individual’s family.
(10) Section 643(i) distribution. The
term section 643(i) distribution means a
transaction described in paragraph (b) or
(c) of this section.
(11) U.S. grantor. The term U.S.
grantor means a U.S. person described in
§1.671-2(e).
(12) U.S. person—(i) In general. Sub-
ject to paragraph (d)(12)(ii) of this sec-
tion, the term U.S. person means a United
States person as defined in section 7701(a)
(30) but does not include an entity that is
exempt from tax under chapter 1 of the
Internal Revenue Code.
(ii) Special rules—(A) Dual resident
taxpayers. If a dual resident taxpayer
(within the meaning of §301.7701(b)-7(a)
(1) of this chapter) computes U.S. income
tax liability as a nonresident alien on the
last day of the taxable year and com-
plies with the filing requirements of
§301.7701(b)-7(b) and (c) of this chapter,
the dual resident taxpayer is not treated
as a U.S. person for purposes of section
643(i) with respect to the portion of the
taxable year the dual resident taxpayer
was treated as a nonresident alien for pur-
poses of computing U.S. income tax lia-
bility.
(B) Dual status taxpayers. Except as
provided in paragraph (b)(3) of this sec-
tion, if a taxpayer abandons U.S. citi-
zenship or residence during the tax year
or acquires U.S. citizenship or residence
during the taxable year as provided in
§1.6012-1(b)(2)(ii), the taxpayer is not
treated as a U.S. person with respect to the
portion of the taxable year the taxpayer
was treated as a nonresident alien for pur-
poses of computing U.S. income tax lia-
bility.
§1.643(i)-2 Exceptions
(a) In general. A loan of cash or use
of trust property will not be treated as a
section 643(i) distribution if the loan of
cash or use of trust property is one of the
following:
(1) Loan of cash in exchange for a
qualified obligation. A loan of cash that
is in exchange for a qualified obligation
(within the meaning of paragraph (b)(2)
(iii) of this section).
(2) Compensated use of trust prop-
erty—(i) In general. Use of trust prop-
erty, other than a loan of cash or market-
able securities, to the extent that the trust
is paid the fair market value of such use
within a reasonable period from the start
of the use of the property. A determina-
tion as to the fair market value of the use
of such property and as to whether a fair
market value payment is made within a
reasonable period must be based on all
the facts and circumstances, including
the type of property used and the period
of use. In appropriate cases, such as
rental of real property, payments may be
made on a periodic basis consistent with
arm’s length dealings between unrelated
parties.
(ii) Safe harbor. For purposes of para-
graph (a)(2)(i) of this section, a payment
is made within a reasonable period if the
payment is made or periodic payments
commence within 60 days of the start of
the use of trust property.
(3) De minimis use of trust property.
Use of trust property, other than a loan of
cash or marketable securities, if such use
is de minimis. Use of trust property will
be considered de minimis if aggregate use
by members of the group consisting of the
U.S. grantors, U.S. beneficiaries, and the
U.S. persons related to any U.S. grantor
or beneficiary does not exceed 14 days
during the calendar year.
(4) Certain loans made by a foreign
corporation. A loan of cash that is made
by a foreign corporation to a U.S. benefi-
ciary of the foreign trust to the extent the
aggregate amount of all such loans to the
beneficiary does not exceed undistributed
earnings and profits of the foreign corpo-
ration attributable to amounts that are, or
have been, included in the beneficiary’s
gross income under section 951, 951A, or
1293.
(b) Qualified obligations—(1) In gen-
eral. The rules in this paragraph (b) apply
to determine whether a loan of cash is in
exchange for a qualified obligation.
(2) Definitions. The following defini-
tions apply for purposes of this section
and §§1.643(i)-1 and 1.643(i)-3 through
1.643(i)-5:
(i) Obligation. The term obligation
means any instrument or contractual
arrangement that constitutes indebtedness
under general principles of Federal income
tax law (for example, a bond, note, deben-
ture, certificate, bill receivable, account
receivable, note receivable, open account,
or other evidence of indebtedness), and
any annuity contract that would not oth-
erwise be classified as indebtedness under
general principles of Federal income tax
law.
(ii) Obligor. The term obligor means
the person who issues an obligation to
a foreign trust in exchange for a loan of
cash.
(iii) Qualified obligation—(A) General
requirements. The term qualified obliga-
tion means an obligation that at all times
satisfies all of the following requirements:
(1) The obligation is reduced to writing
in an express written agreement.
(2) The term of the obligation does not
exceed five years. For purposes of deter-
mining the term of an obligation, the obli-
gation’s maturity date is the last possible
date that the obligation can be outstanding
under the terms of the obligation.
(3) All payments on the obligation
must be made in cash in U.S. dollars.
(4) The obligation is issued at par
and provides for stated interest at a fixed
rate or a qualified floating rate within the
meaning of §1.1275-5(b).
(5) The yield to maturity of the obli-
gation is not less than 100 percent of the
applicable Federal rate and not greater
than 130 percent of the applicable Fed-
eral rate. The applicable Federal rate for
an obligation is the applicable Federal
rate in effect under section 1274(d) for the
day on which the obligation is issued, as
published in the Internal Revenue Bulletin
(see §601.601(d)(2) of this chapter). The
yield to maturity and the applicable Fed-
eral rate must be based on the same com-
pounding period. If an obligation is a vari-
able rate debt instrument that provides for
stated interest at a qualified floating rate,
the equivalent fixed rate debt instrument
rules in §1.1274-2(f)(1) or §1.1275-5(e),
whichever is applicable, apply to deter-
mine the obligation’s yield to maturity.

Bulletin No. 2024–24 1649 June 10, 2024
(6) All stated interest on the obliga-
tion is qualified stated interest within the
meaning of §1.1273-1(c).
(B) Additional requirements to remain
a qualified obligation. An obligation will
remain a qualified obligation only if, for
the first year and each succeeding year
that the obligation remains outstanding,
the following requirements are satisfied:
(1) The U.S. grantor or beneficiary
timely extends the period for assessment
of any income tax attributable to the
obligation and any consequent income
tax changes for each year that the obli-
gation is outstanding to a date not earlier
than three years after the maturity date
of the obligation. This extension of the
period for assessment is not necessary
with respect to the taxable year of the
U.S. grantor or beneficiary in which the
maturity date of the obligation falls, pro-
vided that the obligation is paid in cash in
U.S. dollars within that year. The period
of assessment is extended by completing
and filing Part III of Form 3520, Annual
Return to Report Transactions with For-
eign Trusts and Receipt of Certain For-
eign Gifts, for every year that the obli-
gation is outstanding. The waiver in Part
III of Form 3520 shall also contain such
other terms with respect to assessment
as may be considered necessary by the
Commissioner to ensure the assessment
and collection of the correct tax liabil-
ity for each year for which the waiver is
required. When Part III of Form 3520 is
properly executed and filed, the consent
to extend the period for assessment of tax
will be deemed to be agreed upon and
executed by the Commissioner for pur-
poses of §301.6501(c)-1(d).
(2) The U.S. grantor or beneficiary
timely reports the status of the obligation,
including principal and interest payments,
on Part III of Form 3520 for each year that
the obligation is outstanding.
(3) The obligor timely makes all pay-
ments of principal and interest on the obli-
gation according to the terms of the obli-
gation (which may include a reasonable
grace period of no more than thirty days
for a late payment).
(3) Modification of a qualified obli-
gation. If the terms of a qualified obliga-
tion are modified and the modification is
treated as an exchange under §1.1001-3,
the new obligation that is deemed issued
in the exchange under §1.1001-3 must
satisfy all the requirements in paragraph
(b)(2)(iii) of this section to be a qualified
obligation using the original obligation’s
issue date. If the modification is not treated
as an exchange under §1.1001-3, then the
obligation must be retested as of the date
of the modification to determine whether
the obligation, as modified, continues to
satisfy the requirements in paragraph (b)
(2)(iii) of this section to be a qualified
obligation.
(4) Additional loans. If a qualified
obligation is outstanding and the obli-
gor directly or indirectly issues an addi-
tional obligation to the foreign trust in
exchange for cash, the outstanding obliga-
tion is deemed to have the maturity date
of the additional obligation in determin-
ing whether the outstanding obligation
exceeds the specified five-year term. The
outstanding obligation must be retested as
of the issue date of the additional obliga-
tion to determine whether it would have
satisfied, as of the outstanding obliga-
tion’s issue date, all the requirements in
paragraph (b)(2)(iii) of this section to be a
qualified obligation. If there is more than
one qualified obligation outstanding, the
determination is made based on the out-
standing obligation with the earliest issue
date. The additional obligation also must
be separately tested to see if it satisfies the
requirements in paragraph (b)(2)(iii) of
this section to be a qualified obligation.
(5) Anti-abuse rule. Notwithstanding
paragraphs (b)(3) and (4) of this section,
if the Commissioner determines, based on
all of the facts and circumstances, that two
or more obligations issued by a U.S. obli-
gor are structured with a principal purpose
to avoid the application of section 643(i),
the Commissioner may treat the obliga-
tions as a single obligation that is not a
qualified obligation.
(6) Obligations that cease to be quali-
fied—(i) In general. If an obligation ceases
to be a qualified obligation (for exam-
ple, because an obligation is modified so
that the term of the obligation exceeds 5
years), the U.S. grantor or beneficiary is
treated as receiving a section 643(i) distri-
bution from the trust.
(ii) Amount of section 643(i) distri-
bution. Except as otherwise provided in
this paragraph (b)(6)(ii), the amount of
the section 643(i) distribution treated as
received pursuant to paragraph (b)(6)(i)
of this section is equal to the obligation’s
outstanding stated principal amount plus
any accrued but unpaid qualified stated
interest (within the meaning of §1.1273-
1(c)) as of the date of the event that causes
the obligation to no longer be a qualified
obligation. In the case of an obligation
that ceases to be a qualified obligation
because the Commissioner treats two or
more obligations as a single obligation
pursuant to paragraph (b)(5) of this sec-
tion, the amount of the section 643(i) dis-
tribution will not exceed the sum of the
outstanding stated principal amount plus
any accrued but unpaid qualified stated
interest on each of the obligations as of
the date determined by the Commissioner
under paragraph (b)(6)(iii) of this section.
(iii) Date of section 643(i) distribution.
In general, the U.S. grantor or beneficiary
is treated as receiving a section 643(i)
distribution on the date of the event that
causes an obligation to no longer be a qual-
ified obligation. However, based on all of
the facts and circumstances, if an obliga-
tion (or obligations) is structured with a
principal purpose to avoid the application
of section 643(i), the Commissioner may
deem a section 643(i) distribution to have
occurred on any date on or after the issue
date of the obligation(s).
(c) Trust property attributable to non-
grantor trust portion—(1) In general. A
loan or use of trust property from a par-
tial nongrantor trust must be apportioned
between the nongrantor and grantor por-
tions of the trust in a manner that is rea-
sonable in light of all the facts and cir-
cumstances, including the terms of the
governing instrument, local law, and the
practice of the trustee if it is reasonable
and consistent.
(2) Specific property. If a loan of cash
or marketable securities, or a use of trust
property, can be made from only one por-
tion of the foreign trust because the type
of property loaned or used is held only by
that portion, then the loan or use of prop-
erty is deemed to be attributable to that
portion.
(d) Reporting. A loan of cash or mar-
ketable securities from, or the use of any
property of, a foreign grantor or non-
grantor trust to or by a U.S. person is a dis-
tribution for purposes of §1.6048-4(b)(3)
or (4), as applicable, and must be reported

June 10, 2024 1650 Bulletin No. 2024–24
by the U.S. person, and if the trust is a for-
eign nongrantor trust, by the U.S. grantor
or beneficiary, under §1.6048-4(a), irre-
spective of whether the loan or use of trust
property is a section 643(i) distribution.
(e) Examples. The following exam-
ples illustrate the rules of paragraphs (b)
through (d) of this section:
(1) Example 1: Loan of cash not in exchange for
qualified obligation. Y, a nonresident alien, created
and funded a foreign nongrantor trust, FT, for the
benefit of X, a U.S. person. X is the sole beneficiary
of FT. In Year 1, FT makes a loan of cash to X in
exchange for a demand note that permits FT to require
repayment by X at any time. The demand note issued
by X is not a qualified obligation within the meaning
of paragraph (b)(2)(iii) of this section because X’s
obligation to FT could remain outstanding for more
than five years. Accordingly, the qualified obligation
exception in paragraph (a)(1) of this section does not
apply. Under §1.643(i)-1(b) and §1.643(i)-3(a), X is
treated as receiving a section 643(i) distribution from
FT. X must determine the tax consequences of the
distribution under §1.643(i)-3(c). Under §1.6048-
4(a), X is required to report the section 643(i) dis-
tribution on Part III of Form 3520 for Year 1, as a
distribution from a foreign trust.
(2) Example 2: Beneficiary fails to extend period
of assessment and fails to report loan on Form 3520.
Y, a nonresident alien, created and funded a foreign
nongrantor trust for the benefit of X, a U.S. person.
On June 30, Year 1, FT makes a loan of cash to X in
exchange for an obligation that satisfies the require-
ments of paragraph (b)(2)(iii)(A) of this section.
However, X fails to timely file Form 3520 and did
not request an extension to file. As a result, X has
failed to extend the period for assessment of any
income tax attributable to the loan through the fil-
ing of Form 3520 by its due date as required under
paragraph (b)(2)(iii)(B)(1) of this section. X also has
failed to report the status of the loan on Form 3520
as required under paragraph (b)(2)(iii)(B)(2) of this
section. Either one of X’s failures is sufficient to
cause the loan to be treated as a section 643(i) dis-
tribution under §1.643(i)-1(b). Because the loan fails
to continue to be treated as a qualified obligation, the
loan is treated as a section 643(i) distribution from
FT as of April 15, Year 2, the date that X’s Form
3520 was due.
(3) Example 3: Effect of subsequent obligation
on original obligation. Y, a nonresident alien, created
and funded a foreign nongrantor trust for the ben-
efit of X, a U.S. person. On January 1, Year 1, FT
makes a loan of cash to X in exchange for Note 1,
an obligation with a maturity date of January 1, Year
6, that satisfies the requirements of paragraph (b)(2)
(iii) of this section. On June 30, Year 1, FT makes an
additional loan of cash to X in exchange for Note 2,
an obligation with a maturity date of June 30, Year 6.
Under paragraph (b)(4) of this section, Note 1 will
be deemed to have a maturity date of June 30, Year 6
(i.e., a greater than five-year term) and will cease to
be a qualified obligation. Under paragraph (b)(6)(ii)
of this section, X will be treated as receiving a sec-
tion 643(i) distribution equal to Note 1’s outstand-
ing stated principal amount plus any accrued but
unpaid qualified stated interest (within the meaning
of §1.1273-1(c)) as of June 30, Year 1. Note 2 will be
separately tested to determine whether it satisfies the
requirements of paragraph (b)(2)(iii) of this section.
(4) Example 4: Anti-abuse rule. Y, a nonresident
alien, created and funded a foreign nongrantor trust
for the benefit of X, a U.S. person. On January 1,
Year 1, FT makes a loan of cash to X in exchange for
Note 1, an obligation with a maturity date of January
1, Year 4 that satisfies the requirements of paragraph
(b)(2)(iii) of this section. On January 1, Year 4, FT
makes another loan of cash to X in exchange for
Note 2, an obligation with a maturity date of Janu-
ary 1, Year 7, but otherwise has the same terms as
Note 1. Based on all of the facts and circumstances,
the Commissioner determines under paragraph (b)
(5) of this section that Notes 1 and 2 are structured
with a principal purpose to avoid the application of
section 643(i). Therefore, under paragraph (b)(5)
and paragraph (b)(6)(ii) and (iii) of this section, the
Commissioner may treat Notes 1 and 2 as a single
obligation (with a six-year term) that is not a quali-
fied obligation and may treat X as receiving a section
643(i) distribution equal to the combined outstand-
ing stated principal amounts of Note 1 and Note 2
plus any accrued but unpaid qualified stated interest
as of any date determined by the Commissioner.
(5) Example 5: Allocation of trust property
attributable to partial grantor trust. In Year 1, Y, a
nonresident alien, creates and settles a foreign trust,
FT, for the benefit of X, a U.S. beneficiary. Y funds
the trust with a vacation home valued at $500,000
and $500,000 cash. Under the trust document, Y has
the power to revoke the trust as to the vacation home
and any income earned by the vacation home at any
time without the consent of any person. This power
to revoke results in Y being treated as the owner of
the portion of the trust comprising the vacation home
(the grantor trust portion) under section 676 (after
application of §1.672(f)-3(a)). Y has no powers that
would cause Y to be treated as the owner of the por-
tion of the trust comprising the cash Y contributed or
any income earned by that cash. X uses the vacation
home for 2 months in Year 2 and does not compen-
sate the trust for the use of the vacation home. Under
paragraph (c)(2) of this section, the use of the vaca-
tion home will be deemed to be attributable to the
grantor trust portion and thus will not be treated as
a section 643(i) distribution to X. Under paragraph
(d) of this section, X must comply with the report-
ing requirements of §1.6048-4 with respect to the
use of the vacation home. Under §1.6048-4(b)(4),
X is required to report the use of the vacation home
on Part III of Form 3520 for Year 2 as a distribution
from FT.
§1.643(i)-3 Consequences of section
643(i) distribution.
(a) Amount treated as section 643(i)
distribution—(1) Loan of cash. Except
as provided otherwise, in the case of a
loan of cash treated as a section 643(i)
distribution, the amount of the section
643(i) distribution is the issue price of
the loan, as determined under §1.446-2(d)
(1), §1.1273-2 or §1.1274-2 (whichever
is applicable), as of the date (described in
§1.643(i)-2(b)(6)) the loan is treated as a
section 643(i) distribution.
(2) Loan of marketable securities. In
the case of a loan of marketable securities
treated as a section 643(i) distribution, the
amount of the section 643(i) distribution
is the fair market value of the securities as
of the date the loan is treated as a section
643(i) distribution.
(3) Uncompensated use of trust prop-
erty. In the case of the use of trust prop-
erty treated as a section 643(i) distribu-
tion, the amount of the section 643(i)
distribution is the fair market value of
the use of the property less the amount of
any payments made within a reasonable
period (described in §1.643(i)-2(a)(2)) for
the use of such property. The fair market
value of the use of the property is based on
all the facts and circumstances, including
the type of property used and the period
of use.
(b) Allocation of section 643(i) distri-
bution among multiple U.S. grantors and
beneficiaries. If a U.S. person who is not
a U.S. grantor or beneficiary of a foreign
trust but who is related to more than one
U.S. grantor or beneficiary of the trust
receives a loan of cash or marketable secu-
rities, or uses trust property, that is treated
as a section 643(i) distribution, then each
U.S. grantor and beneficiary who is related
to the U.S. person receiving the loan or
using trust property is treated as receiving
an equal share of the section 643(i) distri-
bution. For purposes of this allocation, the
term U.S. beneficiary includes only those
beneficiaries who must or may receive a
current distribution from the foreign trust.
(c) Tax consequences of a section
643(i) distribution—(1) In general. A
U.S. grantor or beneficiary who is treated
as receiving a section 643(i) distribution
must determine the tax consequences of
the distribution under either the actual cal-
culation method (as defined in §1.6048-
4(d)(2)) or the default calculation method
(as defined in §1.6048-4(d)(3)). A U.S.
grantor or beneficiary may not use the
actual calculation method to determine
the tax consequences of a section 643(i)
distribution in a tax year in which the U.S.
grantor or beneficiary has not received
a Foreign Nongrantor Trust Beneficiary
Statement (see §1.6048-4(d)(2)) from the
foreign trust before completing the U.S.

Bulletin No. 2024–24 1651 June 10, 2024
grantor’s or beneficiary’s return, knows or
has reason to know that the information in
the Foreign Nongrantor Trust Beneficiary
Statement is incorrect, or previously has
used the default calculation method for
the same trust. A U.S. grantor or benefi-
ciary who previously has used the default
calculation method must consistently use
the default calculation method to deter-
mine the tax consequences of any subse-
quent distribution (within the meaning of
§1.6048-4(b)) from the same trust in all
future years, except in the year in which
the trust terminates. See §1.6048-4(d)(3)
(iii).
(2) Consequences to foreign trust—(i)
Treatment of amount under section 661(a)
(2). In the case of a section 643(i) distribu-
tion, regardless of whether a U.S. grantor
or beneficiary uses the default calculation
method or the actual calculation method of
computing the tax consequences of a dis-
tribution, the foreign trust must treat the
section 643(i) distribution as an amount
properly paid, credited, or required to be
distributed by the trust as described in sec-
tion 661(a)(2).
(ii) Distribution of marketable secu-
rities. If the section 643(i) distribution is
of marketable securities, the trust will be
deemed to have made an election to have
section 643(e)(3) apply with respect to all
section 643(i) distributions of marketable
securities made by the trust during the tax-
able year, and any resulting capital gain
is included in the trust’s distributable net
income pursuant to section 643(a)(6)(C).
(iii) Foreign Nongrantor Trust Bene-
ficiary Statement. The foreign trust may
issue a Foreign Nongrantor Trust Benefi-
ciary Statement (as described in §1.6048-
4(c)(2)) to each U.S. person who receives
a loan of cash or marketable securities,
or uses trust property other than a loan of
cash or marketable securities, during the
taxable year of the trust, without regard to
whether a U.S. person would be required
to take the amount of the loan or use of
trust property into account as a section
643(i) distribution. If a U.S. person to
whom a statement is issued is not a U.S.
grantor or beneficiary but is related to a
U.S. grantor or beneficiary, the foreign
trust may issue a duplicate statement to
the U.S. grantor or beneficiary.
(3) Consequences to U.S. grantor
or beneficiary—(i) Actual calculation
method. If a U.S. grantor or beneficiary is
eligible to use, and uses, the actual calcu-
lation method, the U.S. grantor or benefi-
ciary must treat a section 643(i) distribu-
tion as an amount properly paid, credited,
or required to be distributed by the trust as
described in section 662(a)(2) using infor-
mation about the foreign trust as provided
in the Foreign Nongrantor Trust Benefi-
ciary Statement and applying the rules of
subparts C and D of part I of subchapter J
of chapter 1 of the Internal Revenue Code.
(ii) Default calculation method. Under
the default calculation method, a U.S.
grantor or beneficiary must apply the rules
provided in §1.6048-4(d)(3).
(d) Subsequent transactions for loans
or use of trust property—(1) In general.
Any subsequent transaction regarding the
principal of any loan of cash or market-
able securities treated as a section 643(i)
distribution (including complete or partial
repayment, satisfaction, cancellation, dis-
charge, or otherwise, but not including the
payment of interest) or the return of trust
property the use of which was treated as
a section 643(i) distribution has the con-
sequences described in paragraphs (d)(2)
and (3) of this section.
(2) Consequences to foreign trust. Any
subsequent transaction regarding the prin-
cipal of any loan of cash or marketable
securities or the return of trust property
treated as a section 643(i) distribution has
no tax consequences to the trust. However,
any payment to the trust other than the
repayment of principal of any loan treated
as a section 643(i) distribution, includ-
ing the payment of interest, is treated as
income to the trust.
(3) Consequences to obligor—(i) In
general. Any subsequent transaction
regarding the principal of any loan of cash
or marketable securities or the return of
trust property treated as a section 643(i)
distribution is treated as a transfer that is
not a gratuitous transfer by a U.S. per-
son for purposes of §1.671-2(e)(2)(i) and
chapter 1 of the Internal Revenue Code.
(ii) Satisfaction of loan with property.
Any transfer of property to a foreign trust
in satisfaction of any amount due under
a loan of cash or marketable securities
treated as a section 643(i) distribution
causes the obligor to recognize as gain or
loss the difference between the fair mar-
ket value of the property transferred and
the adjusted basis of such property in the
hands of the obligor in accordance with
the rules of section 1001 and the regula-
tions under section 1001 in this part.
§1.643(i)-4 Examples.
(a) Scope. The examples in this section
illustrate the rules of §§1.643(i)-1 through
1.643(i)-3.
(b) Example 1: Loan to contingent remainder
beneficiary treated as loan to U.S. beneficiary. Y,
a nonresident alien, created and funded a foreign
nongrantor trust, FT, for the benefit of Y’s two chil-
dren from Y’s first marriage, A and B, who are both
nonresident aliens. FT’s governing trust instrument
provides that, upon the death of the second to die
of A and B, the trust may make a distribution to
any of Y’s surviving children, in the discretion of
the trustee. In Year 1, X, a U.S. person who is Y’s
daughter from Y’s second marriage, receives a loan
of $100,000 from FT in exchange for an obligation
that is not a qualified obligation within the meaning
of §1.643(i)-2(b)(2)(iii). Under §1.643(i)-1(d)(1), X
is a U.S. beneficiary of FT because X is a U.S. per-
son to whom, at some point before the termination of
the trust, the trust income or corpus may be paid at
the discretion of the trustee. Under §§1.643(i)-1(b)
(1) and 1.643(i)-3(a)(1), X is treated as receiving a
section 643(i) distribution from FT in the amount of
$100,000. X must determine the tax consequences
of the distribution under §1.643(i)-3(c). Under
§1.6048-4(a), X is required to report the section
643(i) distribution on Part III of Form 3520 for Year
1 as a distribution from a foreign trust.
(c) Example 2: Loan from foreign nongrantor
trust to a foreign grantor trust treated as section
643(i) distribution to U.S. owner. The facts are the
same as in paragraph (b) of this section (Example
1), except that instead of a loan to X, in Year 1, FT
makes a loan of $100,000 to GT, a foreign grantor
trust treated as wholly owned by X, in exchange
for an obligation that is not a qualified obligation
within the meaning of §1.643(i)-2(b)(2)(iii). Under
§1.643(i)-1(d)(1), X is a U.S. beneficiary of FT as
explained in paragraph (b) of this section (Example
1). Under §§1.643(i)-1(b)(1) and 1.643(i)-3(a)(1),
X, who is treated as the owner of GT, is treated as
receiving a section 643(i) distribution from FT in the
amount of $100,000. X must determine the tax con-
sequences of the distribution under §1.643(i)-3(c).
Under §1.6048-4(a), X is required to report the sec-
tion 643(i) distribution on Part III of Form 3520 for
Year 1 as a distribution from a foreign trust.
(d) Example 3: Loan by a person related to a for-
eign nongrantor trust treated as a section 643(i) dis-
tribution. X, a U.S. person, is a beneficiary of FT, a
foreign nongrantor trust. FT owns 55% of the stock of
FC, a foreign corporation that is not a controlled for-
eign corporation within the meaning of section 957
or a passive foreign investment company within the
meaning of section 1297. FC is related to FT within
the meaning of §1.643(i)-1(d)(9). On January 2, Year
1, FC lends cash to X in exchange for an obligation
that is not a qualified obligation within the meaning
of §1.643(i)-2(b)(2)(iii). Under §1.643(i)-1(b)(2)

June 10, 2024 1652 Bulletin No. 2024–24
(iii), FC is treated as the agent of FT with respect to
the loan, and under §1.643(i)-1(b)(1) and (2)(i), X is
treated as receiving the loan from FT on January 2,
Year 1. Nevertheless, under §1.643(i)-1(b)(2)(ii), the
loan is not treated as a section 643(i) distribution if
X satisfies the reporting requirements of §1.6048-4
and attaches a statement to X’s income tax return
that demonstrates to the satisfaction of the Commis-
sioner that the loan would have been made without
regard to X’s relationship with FT. Otherwise, X is
treated as receiving a section 643(i) distribution and
must determine the tax consequences of the distribu-
tion under §1.643(i)-3(c). Regardless of whether X
claims the exception described in §1.643(i)-1(b)(2)
(ii), under §1.6048-4(a), X is required to report the
loan on Part III of Form 3520 for Year 1 as a distri-
bution from a foreign trust.
(e) Example 4: Guaranteed loan by an unrelated
person treated as a section 643(i) distribution. X is a
U.S. beneficiary of FT, a foreign nongrantor trust. On
January 2, Year 1, X borrows $100,000 from Bank in
exchange for an obligation that is not a qualified obli-
gation within the meaning of §1.643(i)-2(b)(2)(iii),
and FT provides a guarantee (within the meaning of
§1.679-3(e)(4)) for the loan. Under §1.643(i)-1(b)
(1) and (2)(i), X is treated as receiving a loan from
FT on January 2, Year 1, in the amount of $100,000
because FT guaranteed the loan from Bank to X. On
January 2, Year 1, X is treated as receiving a section
643(i) distribution. X must determine the tax con-
sequences of the distribution under §1.643(i)-3(c).
Under §1.6048-4(a), X is required to report the sec-
tion 643(i) distribution on Part III of Form 3520 as a
distribution from a foreign trust.
(f) Example 5: Loan to a foreign person related
to a U.S. beneficiary. X is a U.S. beneficiary of FT,
a foreign nongrantor trust. X is also the sole share-
holder of CFC, a foreign corporation, treated as a
controlled foreign corporation under section 957.
On January 2, Year 1, FT lends $100,000 to CFC
in exchange for an obligation that is not a qualified
obligation within the meaning of §1.643(i)-2(b)
(2)(iii). CFC is related to X within the meaning of
§1.643(i)-1(d)(9). Under §1.643(i)-1(b)(1) and (2)
(i), X is treated as receiving a loan from FT on Janu-
ary 2, Year 1, in the amount of $100,000 because FT
made the loan to CFC, a foreign person related to X
. Under §1.643(i)-1(b)(2)(ii), the loan is not treated
as a section 643(i) distribution if X reports the loan
consistent with the requirements of §1.6048-4 and
attaches a statement to X’s income tax return that
demonstrates to the satisfaction of the Commissioner
that the loan from FT to CFC would have been made
without regard to X’s relationship with FT. Other-
wise, X is treated as receiving a section 643(i) dis-
tribution and must determine the tax consequences
of the distribution under §1.643(i)-3(c). Regard-
less of whether X claims the limitation described
in §1.643(i)-1(b)(2)(ii), under §1.6048-4(a), X is
required to report the loan on Part III of Form 3520
for Year 1 as a distribution from a foreign trust.
(g) Example 6: Loan to wholly owned corpora-
tion of U.S. beneficiary. Y, a nonresident alien, cre-
ated and funded a foreign nongrantor trust, FT, for
the benefit of Y’s child, X, a U.S. person. X is a U.S.
beneficiary within the meaning of §1.643(i)-1(d)(1).
X wholly owns XYZ Corp, a domestic corporation.
On July 1, Year 1, FT lends $100,000 to XYZ Corp
in exchange for an obligation that is not a qualified
obligation within the meaning of §1.643(i)-2(b)(2)
(iii). Under §1.643(i)-1(d)(9) and (12), XYZ Corp
is a U.S. person related to X. Under §1.643(i)-1(b)
(1) and (2)(i) and §1.643(i)-3(a)(1), X is treated as
receiving a section 643(i) distribution from FT in the
amount of $100,000. X must determine the tax con-
sequences of the distribution under §1.643(i)-3(c).
Under §§1.6048-4(a), X and XYZ Corp are required
to report the loan on Part III of Form 3520 for Year 1
as a distribution from a foreign trust.
(h) Example 7: Subsequent transactions with
respect to loan treated as a section 643(i) distri-
bution. The facts are the same as in paragraph (g)
of this section (Example 6). In Year 1, XYZ Corp
makes a payment to FT that it characterizes in part as
a partial repayment of principal and in part as interest
on its obligation to FT. Under §1.643(i)-3(d)(3)(i),
the portion of the payment that is characterized as a
repayment of principal will be treated as a transfer
that is not a gratuitous transfer by a U.S. person for
purposes of §1.671-2(e)(2)(i) and chapter 1 of the
Internal Revenue Code. Under §1.643(i)-3(d)(2), the
transfer of principal will have no tax consequences
to FT. Furthermore, under §1.643(i)-3(d)(2), the por-
tion of the payment that is characterized as interest
by XYZ Corp will be treated as income to FT.
(i) Example 8: Uncompensated use of trust
property. Y, a nonresident alien, created and funded
a foreign nongrantor trust, FT, for the benefit of Y’s
daughter, A, a U.S. person. A is a U.S. beneficiary
of FT within the meaning of §1.643(i)-1(d)(1).
FT owns real property that could be rented to an
unrelated person at fair market value for $10,000 a
month. During all of Year 1, A lives in the property
rent-free. Under §§1.643(i)-1(c) and §1.643(i)-3(a)
(3), A is treated as receiving a section 643(i) distri-
bution from FT in Year 1 in the amount of $120,000
(12 x $10,000). A must determine the tax conse-
quences of the distribution under §1.643(i)-3(c).
Under §1.6048-4(a), A must report the section
643(i) distribution on Part III of Form 3520 for Year
1 as a distribution from FT.
(j) Example 9: Partially compensated use of
trust property. The facts are the same as in para-
graph (i) of this section (Example 8) except that A
pays FT $2,000 on the first of each month for the
use of the property even though the fair market value
is $10,000. Under §§1.643(i)-1(c), 1.643(i)-2(a)
(2), and 1.643(i)-3(a)(3), A is treated as receiving a
section 643(i) distribution in Year 1 from FT in the
amount of $96,000 (12 x ($10,000 - $2,000)). A must
determine the tax consequences of the distribution
under §1.643(i)-3(c). Under §§1.6048-4(a), A must
report the entire fair market value of $120,000 on
Part III of Form 3520 for Year 1 as a distribution
from FT even through only a portion of the fair mar-
ket value is treated as a section 643(i) distribution
due to partial compensation.
(k) Example 10: Uncompensated use of trust
property treated as distribution from accumulated
income. On January 1, Year 1, Y, a nonresident
alien, creates and funds a foreign nongrantor trust,
FT, for the benefit of Y’s son, X, a U.S. person. X
is a U.S. beneficiary of FT within the meaning of
§1.643(i)-1(d)(1). FT has $60,000 of distributable
net income (DNI), as defined under section 643(a),
in Year 1, $80,000 of DNI in Year 2, and $90,000
of DNI in Year 3. FT has never made any distribu-
tions. FT owns real property that could be rented to
an unrelated person for $10,000 a month. During all
of Year 3, X occupies the property rent free. Under
§1.643(i)-1(c) and §1.643(i)-3(a)(3), X is treated as
receiving a section 643(i) distribution from FT in
Year 3 in the amount of $120,000, the fair market
value use of the trust property (12 x $10,000). Under
§1.6048-4(a), X must report the section 643(i) distri-
bution on Part III of Form 3520 for Year 3 as a dis-
tribution from FT. X receives a Foreign Nongrantor
Trust Beneficiary Statement from FT and uses the
actual calculation method under §1.643(i)-3(c)(3)
(i) to determine the tax consequences of the sec-
tion 643(i) distribution. The $120,000 is treated as
an amount properly paid, credited, or required to be
distributed by the trust as described in section 662(a)
(2). As a result of X’s uncompensated use of FT’s
property, X’s section 643(i) distribution consists of a
distribution of DNI of $90,000 (FT’s DNI in Year 3)
and an accumulation distribution of $30,000 under
subpart D of subchapter J of chapter 1 of the Internal
Revenue Code.
(l) Example 11: Use of property of partial
grantor trust not treated as section 643(i) distribu-
tion. X and Y are married. X is a U.S. person and Y
is a nonresident alien. X and Y have three children,
A, B, and C. A and B are both nonresident aliens. C
is a U.S. person. In Year 1, X and Y created a for-
eign trust, FT, for the benefit of A and B to which X
contributed a vacation home and Y contributed cash
and securities. Neither X nor Y retained any powers
described in sections 673 through 677. In Year 2, C
lived in the vacation home rent free. Although C is
not a beneficiary of FT under the terms of the trust,
under §1.679-2(a)(5), C’s uncompensated use of the
vacation home causes FT to be treated as having a
U.S. beneficiary. Thus, under §1.679-1(a), X will be
treated as the owner of the portion of FT attributable
to the vacation home. Under §1.643(i)-2(c)(2), C’s
use of the vacation home will be treated as the use of
property from the grantor trust portion of FT. C will
not be treated as receiving a section 643(i) distribu-
tion. Under §§1.6048-4(a), C must report the use of
the vacation home on Part III of Form 3520 for Year
2 as a distribution from FT.
(m) Example 12: Use of trust property by exempt
entity not treated as section 643(i) distribution. In
Year 1, X, a nonresident alien, creates a foreign non-
grantor trust, FT, and funds the trust with cash and
a valuable painting. In Year 1, pursuant to the terms
of the trust instrument, FT lends the painting to E, a
U.S. organization described in section 501(c)(3) with
a valid determination letter from the Commissioner.
E exhibits the painting and does not reimburse FT
for the use of the painting. E is not a U.S. person
within the meaning of §1.643(i)-1(d)(12) because E
is an entity that is exempt from tax under chapter 1 of
the Internal Revenue Code. Accordingly, E’s use of
the painting is not a section 643(i) distribution under
§1.643(i)-1(c). E’s use of the painting, however, is
a distribution within the meaning of §1.6048-4(b).
Nevertheless, under §1.6048-5(d), E is not required
to report the use of the painting on Part III of Form
3520 because E is a section 501(c)(3) entity that has
received a determination letter from the Commis-
sioner that recognizes that E is exempt from Federal
income tax under section 501(a) as an organization

Bulletin No. 2024–24 1653 June 10, 2024
described in section 501(c)(3), and the determination
letter has not been revoked.
§1.643(i)-5 Applicability date.
The rules of §§1.643(i)-1 through
1.643(i)-4 apply to loans of cash or mar-
ketable securities made from, and to the
use of any other property of, a foreign
trust after the [date of publication of the
final regulations in the Federal Register].
Par. 3. Section 1.679-0 is amended by:
a. Revising entry for §1.679-1(c)(2).
b. Adding new entry for §1.679-2(a)
(5).
c. Redesignating the entry for §1.679-
2(b)(3) as the entry for §1.679-2(b)(4).
d. Adding new entry for §1.679-2(b)
(3).
e. Adding new entries for §1.679-2(b)
(4)(i) through (vi).
f. Adding new entry for §1.679-2(d).
g. Revising the entries for §1.679-4(d)
(1) through (6).
h. Removing the entry for §1.679-4(d)
(7).
i. Revising the entry for §1.679-7.
The revisions and additions read as fol-
lows:
§1.679-0 Outline of major topics.
* * * * *
§1.679-1 U.S. transferor treated as owner
of foreign trust.
(c) * * *
(2) U.S. person.
(i) In general.
(ii) Special rules.
(A) Dual resident taxpayers.
(B) Dual status taxpayers.
* * * * *
(6) Obligation.
§1.679-2 Trusts treated as having a U.S.
beneficiary.
(a) * * *
(5) Loan or uncompensated use of trust
property treated as paid or accumulated
for the benefit of a U.S. person.
(i) In general.
(ii) Indirect loans.
(iii) Exceptions.
(iv) Safe harbors.
(A) Reasonable period.
(B) De minimis use.
(v) Interaction with section 643(i).
(vi) Examples.
(A) Example 1: Loan of cash to U.S.
person.
(B) Example 2: Use of trust property
by U.S. person.
(C) Example 3: Use of trust property
by church.
(D) Example 4: Indirect loan of cash to
a U.S. person.
(E) Example 5: Interaction with section
643(i) and with section 6048(c) informa-
tion reporting.
* * * * *
(b) * * *
(3) Loans to, or uncompensated use of
trust property by, indirect beneficiaries.
(4) * * *
(i) Example 1. Trust benefiting foreign
corporation.
(ii) Example 2. Trust benefiting another
trust.
(iii) Example 3. Trust benefiting
another trust after transferor’s death.
(iv) Example 4. Indirect benefit through
use of debit card.
(v) Example 5. Other indirect benefit.
(vi) Example 6. Indirect benefit through
an indirect loan.
* * * * *
(d) Presumption that foreign trust has
U.S. beneficiary.
(1) In general.
(2) Authority of Commissioner to
request information.
§1.679-4 Exceptions to general rule.
* * * * *
(d) * * *
(1) In general.
(i) Requirements of the obligation.
(ii) Additional requirements to remain
a qualified obligation.
(2) Modification of a qualified obliga-
tion.
(3) Additional loans.
(4) Anti-abuse rule.
(5) Obligations that cease to be qual-
ified.
(i) In general.
(ii) Amount transferred to the trust.
(iii) Timing of transfers resulting from
failed qualified obligations.
(6) Examples.
(i) Example 1: Demand loan.
(ii) Example 2: Private annuity.
(iii) Example 3: Transfer to unrelated
foreign trust in exchange for an obligation.
(iv) Example 4: Transfer for an obliga-
tion with term in excess of 5 years.
(v) Example 5: Transfer for a qualified
obligation.
(vi) Example 6: Effect of modification
treated as an exchange.
(vii) Example 7: Effect of subsequent
obligation on original obligation.
* * * * *
§1.679-7 Applicability dates.
* * * * *
Par. 4. Section 1.679-1 is amended by
revising paragraphs (c)(2) and (c)(6) to
read as follows:
§1.679-1 U.S. transferor treated as
owner of foreign trust.
* * * * *
(c) * * *
(2) U.S. person—(i) In general. Subject
to paragraph (c)(2)(ii) of this section, the
term U.S. person means a United States
person as defined in section 7701(a)(30).
(ii) Special rules—(A) Dual resident
taxpayers. If a dual resident taxpayer
(within the meaning of §301.7701(b)-7(a)
(1) of this chapter) computes U.S. income
tax liability as a nonresident alien on the
last day of the taxable year and com-
plies with the filing requirements of
§301.7701(b)-7(b) and (c) of this chap-
ter, the dual resident taxpayer will not be
treated as a U.S. person for purposes of
section 679 with respect to the portion of
the taxable year the dual resident taxpayer
was treated as a nonresident alien for pur-
poses of computing U.S. income tax lia-
bility.
(B) Dual status taxpayers. If a taxpayer
abandons U.S. citizenship or residence
during the tax year or acquires U.S. cit-
izenship or residence during the taxable
year as provided in §1.6012-1(b)(2)(ii),
the taxpayer will not be treated as a U.S.
person with respect to the portion of the
taxable year the taxpayer was treated as a
nonresident alien for purposes of comput-
ing U.S. income tax liability.
* * * * *

June 10, 2024 1654 Bulletin No. 2024–24
(6) Obligation. The term obligation
means any instrument or contractual
arrangement that constitutes indebtedness
under general principles of Federal income
tax law (for example, a bond, note, deben-
ture, certificate, bill receivable, account
receivable, note receivable, open account,
or other evidence of indebtedness), and an
annuity contract that would not otherwise
be classified as indebtedness under gen-
eral principles of Federal income tax law.
* * * * *
Par. 5. Section 1.679-2 is amended by:
a. Adding paragraph (a)(5).
b. Redesignating paragraph (b)(3) as
paragraph (b)(4).
c. Adding new paragraph (b)(3).
d. In newly redesignated paragraph (b)
(4), designating Examples 1 through
5 as paragraphs (b)(4)(i) through (v).
e. Adding paragraph (b)(4)(vi).
f. Adding paragraph (d).
The revisions and additions read as fol-
lows:
§1.679-2 Trusts treated as having a
U.S. beneficiary.
(a) * * *
(5) Loan or uncompensated use of trust
property treated as paid or accumulated
for the benefit of a U.S. person—(i) In
general. Except as provided in paragraph
(a)(5)(iii) of this section, any direct or
indirect loan of cash or marketable secu-
rities from a foreign trust or portion of a
foreign trust (whether from trust corpus
or income) as described in paragraph (a)
(5)(ii) to, or the direct or indirect use of
any other property of a foreign trust or
portion of a foreign trust by, any U.S. per-
son (whether or not a beneficiary under
the terms of the trust) is treated as causing
trust income or corpus to be paid or accu-
mulated for the benefit of a U.S. person
for purposes of paragraph (a)(1) of this
section. For these purposes, a loan from a
foreign trust to, or the use of property of a
foreign trust by, a grantor trust (as defined
in §1.643(i)-1(d)(5)) or a disregarded
entity (as defined in §1.643(i)-1(d)(3)) is
treated as a loan to or use by the owner
of the grantor trust or of the disregarded
entity, respectively. For example, a loan
to a single member LLC treated as a dis-
regarded entity is treated as a loan to the
owner of the LLC.
(ii) Indirect loans. For purposes of
paragraph (a)(5)(i) of this section, an indi-
rect loan of cash or marketable securities
from a foreign trust or portion of a foreign
trust includes:
(A) Loans of cash or marketable secu-
rities made by any person to a U.S. person,
if the foreign trust provides a guarantee
(within the meaning of §1.679-3(e)(4)) for
the loan; and
(B) Loans of cash or marketable secu-
rities made from a foreign trust to a U.S.
person through an intermediary, such as
an agent or nominee of the foreign trust, or
from a person related (within the meaning
of §1.643(i)-1(d)(9)) to the foreign trust.
(iii) Exceptions. Paragraph (a)(5)(i) of
this section does not apply if—
(A) The U.S. person who receives the
loan of cash or marketable securities,
or who uses trust property, is an entity
described in section 501(c)(3),
(B) The loan of cash received by the
U.S. person is in exchange for a qual-
ified obligation within the meaning of
§1.643(i)-2(b)(2)(iii) (but without regard
to §1.643(i)-2(b)(2)(iii)(B)(1) and (2)), or
(C) The U.S. person who uses trust
property, other than a loan of cash or mar-
ketable securities, pays the trust the fair
market value of the use of such property
within a reasonable period from the date
of the start of the use of the property. A
determination as to the fair market value
of the use of such property and as to
whether a fair market value payment is
made within a reasonable period will be
based on all the facts and circumstances,
including the type of property used and
the period of use. In appropriate cases,
such as rental of real property, payments
may be made on a periodic basis, if doing
so would be consistent with arm’s-length
dealings between unrelated parties.
(iv) Safe harbors. The following safe
harbors apply for purposes of paragraph
(a)(5)(iii)(C) of this section.
(A) Reasonable period. A payment is
made within a reasonable period if the
payment is made or periodic payments
commence within 60 days of the start of
the use of trust property.
(B) De minimis use. Use of trust prop-
erty will be disregarded if the aggregate
use by all U.S. persons (within the mean-
ing of §1.679-1(c)(2)) does not exceed 14
days during the calendar year.
(v) Interaction with section 643(i). If a
foreign trust or a portion of a foreign trust
is treated as having a U.S. beneficiary pur-
suant to the rules of this paragraph (a)(5)
and a U.S. transferor is thus treated as the
owner of the foreign trust or a portion of
the foreign trust under section 679, section
643(i) does not apply to the trust or por-
tion of the trust of which the U.S. trans-
feror is treated as the owner.
(vi) Examples. The following examples
illustrate the rules of paragraph (a)(5) of
this section. In these examples, X, Y, and
E are U.S. persons (within the meaning of
§1.679-1(c)(2)), and FT is a foreign trust.
In addition, FT’s trust instrument provides
that no U.S. person can benefit either as to
income or corpus of FT.
(A) Example 1: Loan of cash to U.S. person. In
Year 1, X transfers cash and real property to FT. X is
not treated as the owner of any portion of FT under
sections 673 through 679. In Year 2, Y receives a loan
of cash from FT that is not in exchange for a quali-
fied obligation within the meaning of §1.643(i)-2(b)
(2)(iii) and thus does not qualify for the exception
under paragraph (a)(5)(iii)(B) of this section. Y is not
an entity described in section 501(c)(3) and thus does
not qualify for the exception under paragraph (a)(5)
(iii)(A) of this section. Under paragraph (a)(5) of this
section, the loan is treated as paid or accumulated
for the benefit of a U.S. person for purposes of para-
graph (a)(1) of this section, and under §1.679-1(a),
X is treated as the owner of FT. Under paragraph (c)
(1) of this section, FT is treated as acquiring a U.S.
beneficiary in Year 2.
(B) Example 2: Use of trust property by U.S. per-
son. The facts are the same as in paragraph (a)(5)(vi)
(A) of this section (Example 1) except that, instead
of receiving a loan of cash in Year 2, Y occupies
real property owned by FT in exchange for monthly
payments of $2,000. FT could rent the property to
an unrelated party at fair market value for $10,000
a month. Under paragraph (a)(5) of this section, Y’s
use of FT’s property is treated as paid or accumu-
lated for the benefit of a U.S. person for purposes
of paragraph (a)(1) of this section because Y has not
paid fair market value for the use of the real property.
Under §1.679-1(a), X is treated as the owner of FT.
Under paragraph (c)(1) of this section, FT is treated
as acquiring a U.S. beneficiary in Year 2.
(C) Example 3: Use of trust property by church.
In Year 1, X transfers cash and a valuable painting
to FT. X is not treated as the owner of any portion
of FT under sections 673 through 679. In Year 2,
FT lends the painting to E, a U.S. church described
in section 501(c)(3). E’s use of the painting is not
treated as paid or accumulated for the benefit of a
U.S. person for purposes of paragraph (a)(1) of this
section because the exception in paragraph (a)(5)(iii)
(A) of this section applies, and thus FT is not treated
as having a U.S. beneficiary in Year 2.
(D) Example 4: Indirect loan of cash to a U.S.
person. In Year 1, X transfers property to FT. In Year
2, Y borrows $100,000 from Bank in exchange for an
obligation that is not a qualified obligation within the

Bulletin No. 2024–24 1655 June 10, 2024
meaning of §1.643(i)-2(b)(2)(iii) and thus does not
qualify for the exception under paragraph (a)(5)(iii)
(B) of this section. FT provides a guarantee (within
the meaning of §1.679-3(e)(4)) for the loan. Under
paragraph (a)(5)(ii)(A) of this section, Y is treated
as receiving a loan from FT because FT guaranteed
the loan from Bank to Y. Under paragraph (a)(5) of
this section, the loan is treated as paid or accumu-
lated for the benefit of a U.S. person for purposes of
paragraph (a)(1) of this section. Under §1.679-1(a),
X is treated as the owner of FT. Under paragraph (c)
(1) of this section, FT is treated as acquiring a U.S.
beneficiary in Year 2.
(E) Example 5: Interaction of grantor trust rules
with section 643(i) and with section 6048(c) informa-
tion reporting. In Year 1, X created and funded a for-
eign nongrantor trust, FT. During Year 1 and Year 2,
FT accumulates income in the amount of $110,000.
Before Year 3, neither X nor any other person is
treated as owning FT under the rules of sections 673
through 679. In Year 3, Y receives a loan of $100,000
cash from FT that is not in exchange for a qualified
obligation within the meaning of §1.643(i)-2(b)(2)
(iii) and thus does not qualify for the exception under
paragraph (a)(5)(iii)(B) of this section. Under para-
graph (a)(5) of this section, the loan to Y is treated as
paid for the benefit of a U.S. person for purposes of
paragraph (a)(1) of this section. Under §1.679-1(a),
X is now treated as the owner of FT. Under para-
graph (a)(5)(v) of this section, section 643(i) does
not apply to the loan from FT to Y. Under paragraph
(c)(1) of this section, FT is treated as acquiring a
U.S. beneficiary in Year 3. Pursuant to §1.6048-4(b)
(3), Y is treated as receiving a distribution from FT
and must comply with the reporting requirements in
§1.6048-4 with respect to the loan.
(b) * * *
(3) Loans to, or uncompensated use of
trust property by, indirect beneficiaries.
For purposes of paragraphs (a)(1) and (a)
(5) of this section, a loan of cash or market-
able securities or the use of trust property
shall be treated as paid or accumulated for
the benefit of a U.S. person if—
(i) The loan is made to, or the trust prop-
erty is used by, a foreign entity described
in paragraph (b)(1) of this section; or
(ii) The loan is made through, or the
use of trust property is made available to,
an intermediary described in paragraph (b)
(2) of this section, or such loan or use of
trust property is made by any other means
where a U.S. person may obtain an actual
or constructive benefit.
(4) * * *
(vi) Example 6. Indirect benefit through an indi-
rect loan. A, a U.S. person, transfers property to FT.
The trust instrument provides that no U.S. person
can benefit either as to income or corpus. However,
FT maintains an account with FB, a foreign bank,
and FB issues a loan to B, a U.S. person, against the
account maintained by FT. Under paragraphs (a)(1),
(a)(5), and (b)(3) of this section, FT is treated as hav-
ing a U.S. beneficiary.
* * * * *
(d) Presumption that foreign trust has
U.S. beneficiary—(1) In general. If a
U.S. person directly or indirectly trans-
fers property to a foreign trust other than
a trust described in §1.679-4(a)(2) or (3),
the Commissioner may treat the trust as
having a U.S. beneficiary for purposes of
§1.679-1(a), unless the U.S. person—
(i) Satisfies the reporting requirements of
§1.6048-2 with respect to the transfer; and
(ii) Includes an explanatory statement
attached to the U.S. person’s Federal
income tax return that demonstrates to the
satisfaction of the Commissioner that the
trust satisfies the requirements of para-
graph (a)(1) of this section immediately
after the transfer.
(2) Authority of Commissioner to
request information. The Commissioner
may request information related to the
trust described in paragraph (d)(1) of this
section and its potential beneficiaries to
determine whether the trust satisfies the
requirements of paragraph (a)(1) of this
section. Unless such additional informa-
tion is provided upon the Commissioner’s
written notice and request to the U.S. per-
son, the trust will be deemed to have a U.S.
beneficiary. The U.S. person will have 60
days (90 days if the notice is addressed
to a person outside the United States) to
respond to the notice and request.
Par. 6. Section 1.679-4 is amended by
revising paragraph (d) to read as follows:
§1.679-4 Exceptions to general rule.
* * * * *
(d) Qualified obligations—(1) In gen-
eral—(i) Requirements of the obligation.
For purposes of this section, an obligation
is treated as a qualified obligation only if
the obligation at all times satisfies all of
the following requirements—
(A) The obligation is reduced to writ-
ing in an express written agreement;
(B) The term of the obligation does not
exceed five years. For purposes of deter-
mining the term of an obligation, the obli-
gation’s maturity date is the last possible
date that the obligation can be outstanding
under the terms of the obligation;
(C) All payments on the obligation
must be made in cash in U.S. dollars;
(D) The obligation is issued at par
and provides for stated interest at a fixed
rate or a qualified floating rate within the
meaning of §1.1275-5(b);
(E) The yield to maturity of the obli-
gation is not less than 100 percent of the
applicable Federal rate and not greater
than 130 percent of the applicable Fed-
eral rate. The applicable Federal rate for
an obligation is the applicable Federal
rate in effect under section 1274(d) for the
day on which the obligation is issued, as
published in the Internal Revenue Bulletin
(see §601.601(d)(2) of this chapter). The
yield to maturity and the applicable Fed-
eral rate must be based on the same com-
pounding period. If an obligation is a vari-
able rate debt instrument that provides for
stated interest at a qualified floating rate,
the equivalent fixed rate debt instrument
rules in §1.1274-2(f)(1) or §1.1275-5(e),
whichever is applicable, apply to deter-
mine the obligation’s yield to maturity;
and
(F) All stated interest on the obliga-
tion is qualified stated interest within the
meaning of §1.1273-1(c).
(ii) Additional requirements to remain
a qualified obligation. An obligation will
remain a qualified obligation only if, for
the first year and each succeeding year
that the obligation remains outstanding,
the trust timely makes all payments of
principal and interest on the obligation
according to the terms of the obligation
(which may include a reasonable grace
period of no more than thirty days for a
late payment) and the U.S. transferor ful-
fills the requirements of this paragraph (d)
(1)(ii):
(A) The U.S. transferor timely extends
the period for assessment of any income
tax attributable to the obligation and any
consequent income tax changes for each
year that the obligation is outstanding to
a date not earlier than three years after
the maturity date of the obligation. This
extension of the period for assessment
is not necessary with respect to the tax-
able year of the U.S. transferor in which
the maturity date of the obligation falls,
provided that the obligation is paid in
cash in U.S. dollars within that year.
The period of assessment is extended
by completing and filing Part I of Form
3520, Annual Return to Report Trans-
actions with Foreign Trusts and Receipt
of Certain Foreign Gifts, for every year
that the obligation is outstanding. Part

June 10, 2024 1656 Bulletin No. 2024–24
I of Form 3520 also may contain such
other terms with respect to assessment
as may be considered necessary by the
Commissioner to ensure the assessment
and collection of the correct tax liabil-
ity for each year for which the extension
of the period of assessment is required.
When Part I of Form 3520 is properly
executed and filed, the consent to extend
the period for assessment of tax will be
deemed to be agreed upon and executed
by the Commissioner for purposes of
§301.6501(c)-1(d); and
(B) The U.S. transferor timely reports
the status of the obligation, including prin-
cipal and interest payments, on Part I of
Form 3520 for each year that the obliga-
tion is outstanding.
(2) Modification of a qualified obli-
gation. If the terms of a qualified obliga-
tion are modified and the modification is
treated as an exchange under §1.1001-3,
the new obligation that is deemed issued
in the exchange under §1.1001-3 must sat-
isfy all the requirements in paragraph (d)
(1) of this section to be a qualified obli-
gation using the original obligation’s issue
date. If the modification is not treated as
an exchange under §1.1001-3, then the
obligation must be retested as of the date
of the modification to determine whether
the obligation, as modified, continues to
satisfy the requirements in paragraph (d)
(1) of this section to be a qualified obli-
gation.
(3) Additional loans. If a qualified
obligation is outstanding and the U.S.
transferor directly or indirectly obtains an
additional obligation issued by the foreign
trust in exchange for cash, or if the U.S.
transferor directly or indirectly obtains
an additional obligation issued by a per-
son related to the trust, the outstanding
obligation is deemed to have the maturity
date of the additional obligation in deter-
mining whether the outstanding obligation
exceeds the specified five-year term. The
outstanding obligation must be retested as
of the issue date of the additional obliga-
tion to determine whether it would have
satisfied, as of the outstanding obliga-
tion’s issue date, all the requirements in
paragraph (d)(1) of this section to be a
qualified obligation. If there is more than
one qualified obligation outstanding, the
determination is made based on the out-
standing obligation with the earliest issue
date. The additional obligation also must
be separately tested to see if it satisfies the
requirements of (d)(1) of this section to be
a qualified obligation.
(4) Anti-abuse rule. Notwithstanding
paragraphs (2) and (3) of this section, if
the Commissioner determines, based on
all the facts and circumstances, that two or
more obligations issued by a foreign trust
or a person related to the trust are struc-
tured with a principal purpose to avoid the
application of section 679, the Commis-
sioner may treat the obligations as a single
obligation that is not a qualified obliga-
tion.
(5) Obligations that cease to be quali-
fied—(i) In general. If an obligation ceases
to be a qualified obligation (for example,
because an obligation is modified so that
the term exceeds 5 years), the U.S. trans-
feror is treated as making a transfer to the
foreign trust.
(ii) Amount transferred to the trust. The
amount that the U.S. transferor is treated
as having transferred to the trust will be
equal to the obligation’s outstanding
stated principal amount plus any accrued
but unpaid qualified stated interest (within
the meaning of §1.1273-1(c)) as of the
date of the event that causes the obligation
to no longer be a qualified obligation. In
the case of an obligation that ceases to be a
qualified obligation because the Commis-
sioner treats two or more obligations as
a single obligation pursuant to paragraph
(d)(4) of this section, the U.S. transferor
is treated as making a transfer to the trust
in an amount not to exceed the sum of the
outstanding stated principal amount of the
obligations plus any accrued but unpaid
qualified stated interest for each of the
obligations as of the date determined by
the Commissioner under paragraph (d)(5)
(iii) of this section.
(iii) Timing of transfers resulting from
failed qualified obligations. In general,
a U.S. transferor is treated as making a
transfer to the foreign trust on the date
of the event that causes an obligation to
no longer be a qualified obligation. How-
ever, based on all of the facts and circum-
stances, if an obligation (or obligations)
is structured with a principal purpose to
avoid the application of section 679, the
Commissioner may deem a transfer to
have occurred on any date on or after the
issue date of the obligation(s).
(6) Examples. The following example
illustrates the rules of this paragraph (d).
In these examples, A and B are U.S. resi-
dents and FT is a foreign trust.
(i) Example 1: Demand loan. A is a related per-
son (as defined in §1.679-1(c)(5)) with respect to FT.
A transfers $50,000 to FT in exchange for a demand
note that permits A to require repayment by FT at
any time. Because FT’s obligation to A could remain
outstanding for more than five years, the obligation
is not a qualified obligation within the meaning of
paragraph (d)(1) of this section and, pursuant to para-
graph (c) of this section, it is not taken into account
for purposes of determining whether A’s transfer is
eligible for the fair market value exception of para-
graph (a)(4) of this section. Accordingly, §1.679-1
applies to treat A as the owner of the portion of FT
attributable to the full $50,000 transfer to FT.
(ii) Example 2: Private annuity. A is a related
person (as defined in §1.679-1(c)(5)) with respect
to FT. A transfers $40,000 to FT in exchange for
an annuity from FT that will pay A $100x per year
for the rest of A’s life. Because FT’s obligation to A
could remain outstanding for more than five years,
the obligation is not a qualified obligation within the
meaning of paragraph (d)(1) of this section and, pur-
suant to paragraph (c) of this section, it is not taken
into account for purposes of determining whether A’s
transfer is eligible for the fair market value excep-
tion of paragraph (a)(4) of this section. Accordingly,
§1.679-1 applies to treat A as the owner of the por-
tion of FT attributable to the full $40,000 transfer to
FT.
(iii) Example 3: Transfer to unrelated foreign
trust in exchange for an obligation. B is not a related
person (as defined in §1.679-1(c)(5)) with respect
to FT. B transfers $10,000 to FT in exchange for an
obligation of the trust. The term of the obligation is
fifteen years. Because B is not a related person with
respect to FT, paragraph (c) of this section does
not apply. The fair market value of the obligation
received by B is taken into account for purposes of
the fair market value exception of paragraph (a)(4)
of this section even though the obligation is not a
qualified obligation within the meaning of paragraph
(d)(1) of this section.
(iv) Example 4: Transfer for an obligation with
term in excess of 5 years. A is a related person (as
defined in §1.679-1(c)(5)) with respect to FT. A trans-
fers property that has a fair market value of $50,000
to FT in exchange for an obligation of FT. The term
of the obligation is ten years. Because the term of the
obligation exceeds five years, the obligation is not a
qualified obligation within the meaning of paragraph
(d)(1) of this section, and pursuant to paragraph (c)
of this section, it is not taken into account for pur-
poses of determining whether A’s transfer is eligible
for the fair market value exception of paragraph (a)
(4) of this section. Accordingly, §1.679-1 applies to
treat A as the owner of the portion of FT attributable
to the full $50,000 transfer to FT.
(v) Example 5: Transfer for a qualified obliga-
tion. The facts are the same as in paragraph (d)(6)
(iv) of this section (Example 4), except that the term
of the obligation is three years. Assuming the other
requirements of paragraph (d)(1) of this section are
satisfied, the obligation is a qualified obligation, and
its stated principal amount is taken into account for

Bulletin No. 2024–24 1657 June 10, 2024
purposes of determining whether A’s transfer is eligi-
ble for the fair market value exception of paragraph
(a)(4) of this section.
(vi) Example 6: Effect of modification treated
as an exchange. A is a related person (as defined
in §1.679-1(c)(5)) with respect to FT. A transfers
property that has a fair market value of $10,000 to
FT in exchange for an obligation with a term of four
years that satisfies the requirements of paragraph
(d)(1) of this section. Two years later, a significant
modification of the obligation within the meaning
of §1.1001-3, including an extension of the obli-
gation by an additional term of three years, occurs,
and the modification is treated as an exchange under
§1.1001-3. The new obligation that is deemed issued
in the exchange under §1.1001-3 must satisfy the
requirements of paragraph (d)(1) of this section to
be a qualified obligation as of the original obliga-
tion’s issue date. Because the new obligation would
not satisfy the five-year requirement of paragraph (d)
(1), the obligation ceases to be treated as a qualified
obligation.
(vii) Example 7: Effect of subsequent obliga-
tion on original obligation. A is a related person
(as defined in §1.679-1(c)(5)) with respect to FT.
On January 1, Year 1, A transfers $100,000 to FT
in exchange for Obligation 1 from FT, an obliga-
tion with a maturity date of January 1, Year 6, that
satisfies the requirements of paragraph (d)(1) of this
section. On June 30, Year 1, A transfers an additional
$50,000 to FT in exchange for Obligation 2, an obli-
gation with a maturity date of June 30, Year 6, that
independently satisfies the requirements of paragraph
(d)(1) of this section. Under paragraph (d)(3) of this
section, Obligation 1 will be deemed to have a matu-
rity date of June 30, Year 6 (i.e., a greater than five-
year term) and will cease to be a qualified obligation
under paragraph (d)(1) of this section. Pursuant to
paragraph (c) of this section, because Obligation 1 is
not a qualified obligation, it is not taken into account
for purposes of determining whether A’s transfer of
$100,000 is eligible for the fair market value excep-
tion of paragraph (a)(4) of this section. Accordingly,
§1.679-1 applies to treat A as the owner of the por-
tion of FT attributable to the $100,000 transferred
to FT. Obligation 2 is separately tested to determine
whether it satisfies the qualified obligation rules of
paragraph (d)(1) of this section and to the extent it
does, A is treated as eligible for the fair market value
exception of paragraph (a)(4) of this section and is
not treated as the owner of the portion of FT attribut-
able to the $50,000 transferred to FT.
Par. 7. Section 1.679-7 is amended by:
a. Revising the section heading.
b. Adding paragraphs (b)(4) through
(b)(7).
The revision and additions read as fol-
lows:
§1.679-7 Applicability dates.
* * * * *
(b) * * *
(4) The amendments to §§1.679-1(c)
(2) and 1.679-1(c)(6) apply for taxable
years beginning after the [date of publica-
tion of the final regulations in the Federal
Register].
(5) The rules of §1.679-2(a)(5) apply
to loans and the use of trust property after
the [date of publication of the final regula-
tions in the Federal Register].
(6) The rules of §1.679-2(d) apply to
transfers of property after the [date of
publication of the final regulations in the
Federal Register].
(7) Section 1.679-4(d) applies to obli-
gations issued or modified after the [date
of publication of the final regulations in
the Federal Register]. If an obligation
issued on or before the [date of publica-
tion of the final regulations in the Federal
Register] is modified after that date, and
the modification is a significant modifica-
tion under §1.1001-3, the new obligation
that is deemed issued in the exchange is
treated as issued after the [date of publi-
cation of the final regulations in the Fed-
eral Register]. If the modification is not
a significant modification under §1.1001-
3, then the original obligation must be
retested as of the date of the modification
to determine whether the obligation, as
modified, satisfies the requirements in
paragraph (d)(1), as amended, to be a
qualified obligation.
Par. 8. Section 1.6039F-1 is added to
read as follows:
§1.6039F-1 U.S. recipients of foreign
gifts.
(a) Reporting of foreign gifts—(1) In
general. Except as provided in paragraph
(c) of this section, and subject to para-
graph (a)(2) and (3) of this section, each
U.S. person (within the meaning of sec-
tion 7701(a)(30)) who receives a foreign
gift (within the meaning of paragraph
(b) of this section) during a taxable year
must report such gift (including the addi-
tional information required under para-
graph (c) of this section if, after apply-
ing the aggregation rules, the foreign gift
exceeds certain reporting thresholds) on
Part IV of Form 3520, Annual Return To
Report Transactions With Foreign Trusts
and Receipt of Certain Foreign Gifts, by
the fifteenth day of the fourth month after
the close of the U.S. person’s taxable
year. In the case of a U.S. person who
has been granted an extension of time to
file the U.S. person’s income tax return
pursuant to section 6081, an extension
of time for filing Form 3520 is granted
to the fifteenth day of the tenth month
following the close of the U.S. person’s
taxable year. No further extension of time
to file Form 3520 is allowed. For special
rules concerning the treatment of dual
resident taxpayers (within the meaning
of §301.7701(b)-7(a)(1) of this chapter)
and dual status taxpayers (described in
§1.6012-1(b)(2)(ii)) as U.S. persons for
purposes of this section, see paragraph (f)
of this section.
(2) Reporting by U.S. citizens and
residents residing abroad. In the case of
a U.S. person who is an individual and
who qualifies for an automatic extension
to file their income tax return under sec-
tion 6081 and §1.6081-5(a)(5) because the
U.S. person resides outside of the United
States and Puerto Rico and the U.S. per-
son’s main place of business or post of
duty is outside of the United States and
Puerto Rico, the U.S. person must report
the foreign gifts received by the U.S. per-
son during the taxable year on Part IV of
Form 3520 by the fifteenth day of the sixth
month after the close of the U.S. person’s
taxable year. If the U.S. person has been
granted an extension of time to file the
U.S. person’s income tax return pursuant
to section 6081, an extension of time for
filing Form 3520 is granted to the fifteenth
day of the tenth month following the close
of the U.S. person’s taxable year. No addi-
tional extension of time to file Form 3520
is allowed.
(3) Reporting for deceased U.S. per-
sons. In the case of a deceased U.S. per-
son, the executor (within the meaning of
section 2203) of the U.S. person’s estate
must report the foreign gifts received by
the U.S. person during the U.S. person’s
final taxable year on Part IV of Form 3520
by the fifteenth day of the fourth month
following the close of the 12-month
period which began with the first day of
the U.S. person’s final taxable year. If the
executor of the U.S. person’s estate has
been granted an extension of time to file
the U.S. person’s final income tax return
pursuant to section 6081, an extension of
time for filing Form 3520 is granted to
the fifteenth day of the tenth month fol-
lowing the close of the 12-month period
which began with the first day of the U.S.
person’s final taxable year. No additional

June 10, 2024 1658 Bulletin No. 2024–24
extension of time to file Form 3520 is
allowed.
(b) Definition of foreign gift—(1) In
general. The term foreign gift means any
amount received from a non-U.S. person
that the recipient (including a spouse)
treats as a gift, bequest, devise, or inher-
itance for income tax purposes, but does
not include any qualified transfer within
the meaning of section 2503(e)(2) (relat-
ing to certain transfers for educational or
medical expenses) or any transfer that is
treated as a distribution (within the mean-
ing of §1.6048-4(b)) from a foreign trust
and that is reported on a return under
§1.6048-4. A U.S. person who receives a
transfer from a foreign trust must treat that
transfer as a distribution from the trust that
is reportable under §1.6048-4, rather than
as a foreign gift that is reportable under
paragraph (a) of this section, even if the
U.S. person treats the transfer as a gift
for another purpose (such as computing
the person’s Federal income tax liability).
For example, although a covered gift or
bequest described in section 2801(e) is a
foreign gift, a U.S. person who receives a
covered gift or bequest from a foreign trust
must report the covered gift or bequest
as a distribution (within the meaning of
§1.6048-4(b)) under §1.6048-4.
(2) Anti-avoidance rule. The term for-
eign gift includes any amount received by
a U.S. person from a non-U.S. person that
meets all of the following requirements—
(i) Based on all the facts and circum-
stances, the Commissioner determines
that the amount received is in substance
a gift;
(ii) The recipient does not treat the
amount received as a gift, bequest, devise,
or inheritance; and
(iii) The recipient does not treat the
amount received as taxable income (such
as a purported loan).
(c) Exceptions—(1) Section 501(c)
recipient. Paragraph (a) of this section
does not apply if the recipient of the for-
eign gift is an organization described in
section 501(c) and exempt from tax under
section 501(a).
(2) Reporting threshold rules—(i)
Foreign gifts from foreign individuals or
foreign estates—(A) Reporting threshold.
Except as provided in paragraph (c)(2)(ii)
of this section, paragraph (a) of this section
does not apply to a foreign gift received
by a U.S. person from a non-U.S. person
who is an individual (a foreign individual)
or a foreign estate (within the meaning
of section 7701(a)(31)(A)) if, during the
U.S. person’s taxable year, the aggregate
amount of foreign gifts received, directly
or indirectly, from that foreign individual
or foreign estate (the transferor) does not
exceed $100,000, as modified by cost-of-
living adjustments pursuant to paragraph
(c)(2)(v) of this section.
(B) Aggregation rule. To determine
whether paragraph (c)(2)(i)(A) of this sec-
tion applies to foreign gifts received from
a transferor, each U.S. person must aggre-
gate foreign gifts, including covered gifts
and bequests described in section 2801(e),
received from all foreign individuals, for-
eign estates, and any other foreign person
(such as corporations or partnerships) that
the U.S. person knows or has reason to
know are related to the transferor within
the meaning of §1.643(i)-1(d)(9). If the
aggregate amount of all these foreign gifts
exceeds the $100,000 reporting threshold,
the U.S. person must separately iden-
tify each foreign gift in excess of $5,000
received from the transferor and from
each foreign person related to the trans-
feror and must provide identifying infor-
mation (for example, name and address)
about the transferor and each such foreign
person, including a foreign individual or a
foreign estate.
(ii) Covered gifts and bequests. Subject
to paragraph (h)(2) of this section, para-
graph (a) of this section does not apply
to a foreign gift that is a covered gift or
bequest described in section 2801(e) if
the aggregate amount of covered gifts
and bequests received by the U.S. person
during the calendar year does not exceed
the section 2801(c) amount, which is the
dollar amount of the per-donee exclu-
sion in effect under section 2503(b). For
purposes of this paragraph (c)(2)(ii), the
aggregate amount of covered gifts and
bequests received by the U.S. person
during the calendar year does not include
transfers from a foreign trust (as described
in paragraph (b)(1) of this section), as
such transfers are reportable as distribu-
tions (within the meaning of §1.6048-
4(b)) under §1.6048-4.
(iii) Other foreign gifts—(A) Reporting
threshold. Paragraph (a) of this section
does not apply to a foreign gift received
by a U.S. person from a foreign corpora-
tion or a foreign partnership if, during the
U.S. person’s taxable year, the aggregate
amount of foreign gifts from that corpora-
tion or partnership (the transferor), when
aggregated with foreign gifts received
from other foreign persons that the U.S.
person knows or has reason to know are
related to the transferor as described in
paragraph (c)(2)(iii)(B) of this section,
does not exceed $10,000, as modified by
cost-of-living adjustments pursuant to
paragraph (c)(2)(v) of this section.
(B) Aggregation rule. To determine
whether paragraph (c)(2)(iii)(A) of this
section applies to foreign gifts from a
transferor, the U.S. person must aggregate
foreign gifts received from all foreign cor-
porations, foreign partnerships, and any
other foreign person that the U.S. person
knows or has reason to know are related
to the transferor within the meaning of
§1.643(i)-1(d)(9). If the aggregate amount
of these foreign gifts exceeds the report-
ing threshold, the U.S. person must sep-
arately identify each foreign gift from the
transferor and from each foreign person
related to the transferor and provide iden-
tifying information (for example, name
and address) about the transferor and each
such foreign person, including a foreign
individual or foreign estate.
(iv) Joint returns. In the case of mar-
ried U.S. persons who file joint income tax
returns under section 6013 for a tax year,
the reporting threshold under paragraph
(c)(2)(i)(A) of this section applies sepa-
rately to each spouse. Thus, married U.S.
persons who file a joint income tax return
will not be subject to paragraph (a) of this
section if the aggregate amount of foreign
gifts received by each spouse, directly or
indirectly from any one foreign individual
or foreign estate, taking into account the
aggregation rule of paragraph (c)(2)(i)(B)
of this section, does not exceed $100,000
during the taxable year.
(v) Cost-of-living adjustments. The
reporting thresholds under paragraph
(c)(2)(i)(A) and under paragraph (c)(2)
(iii)(A) of this section are increased by
an amount equal to the product of the
amounts specified in such paragraphs and
the cost-of-living adjustment for the tax-
able year of the gift under section 1(f)(3),
except that paragraph (A)(ii) thereof is
applied by substituting “1995” for “2016.”

Bulletin No. 2024–24 1659 June 10, 2024
(d) Valuation principles. The amount
of a foreign gift is the value of the prop-
erty at the time of its transfer. The value
of the property is the price at which such
property would change hands between a
willing buyer and a willing seller, neither
being under any compulsion to buy or to
sell, and both having reasonable knowl-
edge of relevant facts. Accordingly, the
value of the property is determined in
accordance with the Federal gift tax val-
uation principles of section 2512 and sec-
tions 2701 through 2704 (chapter 14 of
the Internal Revenue Code) and the reg-
ulations under section 2512 and sections
2701 through 2704 in this part.
(e) Penalty for failure to file infor-
mation—(1) In general. If a U.S. person
fails to furnish information required under
paragraph (a) of this section with respect
to any foreign gift by the due date pro-
vided under paragraph (a)—
(i) The tax consequences of the receipt
of such foreign gift may be determined by
the Commissioner based on all the facts
and circumstances, and
(ii) Notwithstanding the tax conse-
quences under paragraph (e)(1)(i) of this
section, such U.S. person must pay (upon
notice and demand by the Commissioner
and in the same manner as tax) an amount
equal to 5 percent of the amount of such
foreign gift for each month (or portion
thereof) for which the failure to report the
foreign gift as a gift on Form 3520 con-
tinues (not to exceed 25 percent of such
amount in the aggregate).
(2) Reasonable cause exception. Para-
graph (e)(1) of this section will not apply
to any failure to report a foreign gift if the
U.S. person submits a reasonable cause
statement to the Commissioner under pen-
alties of perjury and demonstrates to the
satisfaction of the Commissioner that the
failure is due to reasonable cause and not
due to willful neglect. The determination
of whether a taxpayer acted with reason-
able cause and not with willful neglect
is made under the principles set out in
§1.6664-4 and §301.6651-1(c). This deter-
mination is made on a case-by-case basis,
taking into account all pertinent facts and
circumstances.
(f) Special rules—(1) Dual resident
taxpayers. If a dual resident taxpayer
(within the meaning of §301.7701(b)-7(a)
(1) of this chapter) computes U.S. income
tax liability as a nonresident alien on the
last day of the taxable year and com-
plies with the filing requirements of
§301.7701(b)-7(b) and (c) of this chap-
ter, the dual resident taxpayer will not be
treated as a U.S. person for purposes of
section 6039F with respect to the portion
of the taxable year the dual resident tax-
payer was treated as a nonresident alien
for purposes of computing U.S. income
tax liability.
(2) Dual status taxpayers. If a taxpayer
abandons U.S. citizenship or residence
during the taxable year or acquires U.S.
citizenship or residence during the tax-
able year as provided in §1.6012-1(b)(2)
(ii), the taxpayer will not be treated as a
U.S. person with respect to the portion of
the taxable year the taxpayer is treated as a
nonresident alien for purposes of comput-
ing U.S. income tax liability.
(g) Examples. The following examples
illustrate the rules of this section. In these
examples and unless otherwise stated,
assume that the reporting threshold under
paragraph (c)(2)(i)(A) of this section is
$100,000:
(1) Example 1: Qualified transfer exception. X,
a U.S. person, attends Private University, an accred-
ited college in the United States. X’s grandparents,
who are not U.S. persons, pay X’s tuition directly
to Private University. The tuition payment is a qual-
ified transfer within the meaning of section 2503(e)
(2). Under paragraph (b)(1) of this section, X is not
treated as receiving a foreign gift from X’s grand-
parents. Accordingly, X is not required to report the
tuition payment under paragraph (a) of this section.
(2) Example 2: Charitable donee. XYZ, a U.S.
person, is an organization described in section 501(c)
and is exempt from tax under section 501(a). XYZ
receives a bequest of $200,000 from a foreign estate.
Because XYZ meets the exception under paragraph
(c)(1) of this section for organizations described in
section 501(c) and exempt from tax under section
501(a), XYZ is not required to report the bequest
under paragraph (a) of this section.
(3) Example 3: Gift from dual resident taxpayer.
X is a lawful permanent resident of the United
States within the meaning of §301.7701(b)-1(b) of
this chapter and is a resident of Country F under the
domestic law of Country F. X is a resident of Coun-
try F under the residence article of the U.S.-Country
F income tax treaty and notifies the United States by
taking such a position on Form 1040NR and Form
8833 for Year 1. Pursuant to §301.7701(b)-7 of this
chapter, X is treated as a nonresident alien for pur-
poses of computing X’s U.S. income tax liability for
Year 1. During Year 1, X makes a gift of $150,000 to
Y, a U.S. citizen. Under paragraph (f)(1) of this sec-
tion, X is not treated as a U.S. person for purposes of
this section. Because X is not treated as a U.S. person
for Year 1, the gift is a foreign gift within the mean-
ing of paragraph (b) of this section. Y must report the
foreign gift on Part IV of Form 3520 under paragraph
(a) of this section.
(4) Example 4: Gifts from related foreign indi-
viduals. X, a U.S. citizen, is married to Y, a nonres-
ident alien. Y has three brothers, A, B, and C, who
also are nonresident aliens. In Year 1, Y makes a
gift of $90,000 to X, A makes a gift of $40,000 to
X, B makes two gifts to X (one of $4,000 and one
of $3,000), and C makes a gift of $4,000 to X. X
knows or has reason to know that A, B, and C are
related to Y within the meaning of §1.643(i)-1(d)(9).
X treats all five transfers as gifts. Under paragraphs
(c)(2)(i)(A) and (B) of this section, to calculate the
$100,000 reporting threshold, X must aggregate for-
eign gifts from Y, A, B, and C. For Year 1, X must
report the receipt of $141,000 in foreign gifts. In
addition, under paragraphs (a) and (c)(2)(i)(B) of
this section, X must separately identify and report
information regarding the $90,000 foreign gift from
Y, the $40,000 foreign gift from A, and the aggre-
gated $7,000 foreign gifts from B because each per-
son’s foreign gift for Year 1 exceeds $5,000. X is not
required to identify the $4,000 gift from C separately
because it does not exceed $5,000.
(5) Example 5: Covered gift within meaning of
section 2801(e). Z is a resident of Country F and
relinquishes U.S. citizenship on July 1, Year 1,
becoming a covered expatriate within the meaning of
section 877A(g)(1). On December 31, Year 10, a date
after the date final regulations under section 2801 are
published in the Federal Register, Z gives $50,000
to Z’s son, X, who is a U.S. person. The transfer is
a covered gift within the meaning of section 2801(e)
and a foreign gift within the meaning of paragraph
(b) of this section. Because the value of the foreign
gift exceeds the threshold specified in paragraph (c)
(2)(ii) of this section (assuming that for Year 10 this
amount is under $50,000), X must report receipt of
the foreign gift on Part IV of Form 3520 under para-
graph (a) of this section. X also is subject to tax and
separate reporting requirements under section 2801.
(6) Example 6: Gifts from foreign individual and
related corporation. X, a U.S. citizen, is married to
Y, a nonresident alien. Y is the sole shareholder of
FC, a foreign corporation. During Year 1, Y makes a
gift of $11,000 to X, and FC makes a gift of $9,000
to X. Because X knows or has reason to know that Y
and FC are related, X must aggregate the gifts from
Y and FC ($20,000). Although the $20,000 aggregate
amount deemed received from Y does not exceed the
$100,000 reporting threshold with respect to foreign
gifts from foreign individuals, the $20,000 aggregate
amount received from FC exceeds the applicable
reporting threshold for foreign gifts from foreign
corporations under paragraph (c)(2)(iii) of this sec-
tion for Year 1 (assume that for Year 1 this amount is
$18,000). Accordingly, X must report receipt of the
foreign gift on Part IV of Form 3520 under paragraph
(a) of this section. In addition, X must separately
identify each foreign gift from Y and FC and must
provide identifying information about Y and FC.
(7) Example 7: Penalties for failure to report
information. The facts are the same as in paragraph
(g)(6) of this section (Example 6). X fails to report
the amounts received from Y and FC on Form 3520
and does not demonstrate to the satisfaction of the
Commissioner that such failure is due to reasonable
cause and not due to willful neglect. Under para-

June 10, 2024 1660 Bulletin No. 2024–24
graph (e)(1)(i) of this section and §1.672(f)-4(a)(2),
the Commissioner may determine that, based on all
the facts and circumstances, the gift of $9,000 from
FC to X should be treated as a dividend from FC to X
and included in X’s gross income. Under paragraph
(e)(1)(i) of this section, the Commissioner also may
determine that there are no tax consequences to X
upon receiving the gift of $11,000 from Y. Without
regard to the tax consequences determined under
paragraph (e)(1)(i) of this section, under paragraph
(e)(1)(ii) of this section, X must pay (upon notice
and demand by the Commissioner and in the same
manner as tax) $1,000, an amount equal to 5 percent
of the aggregate amount of $20,000 for each month
for which the failure to disclose the foreign gifts
on Form 3520 continues (not to exceed $5,000, an
amount equal to 25 percent of the aggregate amount
of $20,000).
(h) Applicability date—(1) In general.
Except as provided in paragraph (h)(2) of
this section, the rules of this section apply
to amounts received after the [date of pub-
lication of the final regulations in the Fed-
eral Register].
(2) Covered gifts and bequests. Para-
graph (c)(2)(ii) of this section is effective
on the date final regulations under section
2801 are published in the Federal Regis-
ter and applies to covered gifts or bequests
received on or after that date.
Par. 9. Sections 1.6048-1 through
1.6048-7 are added to read as follows:
§1.6048-1 Scope.
(a) In general. Sections 1.6048-1
through 1.6048-7 provide rules concern-
ing information that must be reported
under section 6048 with respect to for-
eign trusts. This section provides general
definitions for purposes of §§1.6048-1
through 1.6048-7. Section 1.6048-2 pro-
vides rules requiring a responsible party
to provide notice of a reportable event
that occurs during the taxable year with
respect to a foreign trust. Section 1.6048-3
provides rules applicable to a U.S. owner
of a foreign trust to ensure that the trust
provides certain information about the
trust’s activities and operations for the
year to the Commissioner and to any U.S.
person (within the meaning of section
7701(a)(30)) who is treated as an owner
of the trust or who receives a distribution
from the trust. Section 1.6048-4 provides
rules requiring a U.S. person to report the
receipt of a distribution from a foreign
trust during the U.S. person’s taxable year.
Section 1.6048-5 provides exceptions to
the rules of §§1.6048-2 through 1.6048-
4. Section 1.6048-6 provides certain spe-
cial rules, including rules concerning dual
resident taxpayers (within the meaning
of §301.7701(b)-7(a)(1) of this chapter)
and dual status taxpayers (described in
§1.6012-1(b)(2)(ii)) who compute their
U.S. income tax liability as nonresident
aliens for part or all of the taxable year.
Section 1.6048-7 provides applicability
dates. For civil penalties that apply for
failure to comply with the requirements
of §§1.6048-2 through 1.6048-4, see
§1.6677-1. For penalties that apply to
understatements of tax that are attributable
to transactions involving undisclosed for-
eign financial assets, including assets with
respect to which information was required
to be provided under section 6048 but was
not provided, see section 6662(b)(7) and
(j). For suspension of the statute of lim-
itations when required information has
not been provided under section 6048, see
section 6501(c)(8).
(b) Definitions. The following defini-
tions apply for purposes of this section
and §§1.6048-2 through 1.6048-7:
(1) Executor. The term executor means
an executor within the meaning of section
2203.
(2) Foreign person. The term foreign
person means any person who is not a
U.S. person within the meaning of para-
graph (b)(4) of this section.
(3) Foreign trust. The term foreign trust
means a foreign trust within the meaning
of §301.7701-7.
(4) Grantor trust. The term grantor
trust means a trust or any portion of a trust
that is treated as owned by any person
under subpart E of part I of subchapter J
of chapter 1 of the Internal Revenue Code.
(5) Grantor trust rules. The term
grantor trust rules means the rules under
subpart E of part I of subchapter J of chap-
ter 1 of the Internal Revenue Code.
(6) Nongrantor trust. The term non-
grantor trust means a trust or any portion
of a trust that is not treated as owned by
any person under subpart E of part I of
subchapter J of chapter 1 of the Internal
Revenue Code.
(7) U.S. person. The term U.S. person
means any person who is a U.S. person
within the meaning of section 7701(a)
(30) but not including certain dual resi-
dent taxpayers and dual status taxpayers
as described in §1.6048-6(a).
§1.6048-2 Notice of reportable events.
(a) In general—(1) Filing requirement.
Unless an exception in §1.6048-5 applies,
a responsible party (as defined in para-
graph (c) of this section) must provide
written notice of any reportable event (as
defined in paragraph (b) of this section)
that occurs during the taxable year of the
U.S. person described in paragraph (b) of
this section on Part I of Form 3520, Annual
Return To Report Transactions With For-
eign Trusts and Receipt of Certain Foreign
Gifts. If a responsible party must report a
reportable event with regard to more than
one foreign trust during the taxable year,
the responsible party must file a separate
Form 3520 for each such foreign trust. See
§§1.679-1 and 1.684-1 for additional rules
regarding transfers to foreign trusts by
U.S. persons. See §1.6048-6(d) for infor-
mation reporting by married U.S. persons
who file a joint income tax return.
(2) Due dates—(i) General rule. Sub-
ject to paragraph (a)(2)(ii) and (iii) of
this section, the responsible party must
file Form 3520 by the fifteenth day of the
fourth month after the close of the respon-
sible party’s taxable year. If the responsi-
ble party has been granted an extension of
time to file the responsible party’s income
tax return pursuant to section 6081, an
extension of time for filing Form 3520 is
granted to the fifteenth day of the tenth
month following the close of the respon-
sible party’s taxable year. No additional
extension of time to file Form 3520 is
allowed beyond the fifteenth day of the
tenth month following the close of the
responsible party’s taxable year.
(ii) Filing by U.S. persons residing
outside the United States. In the case
of a grantor or transferor (described in
paragraph (c)(1) or (c)(2) of this section,
respectively) who qualifies for an auto-
matic extension to file the grantor’s or
transferor’s income tax return under sec-
tion 6081 and §1.6081-5(a)(5) because
the grantor or transferor resides outside
of the United States and Puerto Rico and
the grantor’s or transferor’s main place of
business or post of duty is outside of the
United States and Puerto Rico, the grantor
or transferor must file Form 3520 by the
fifteenth day of the sixth month after the
close of the grantor’s or transferor’s tax-
able year. If the grantor or transferor has

Bulletin No. 2024–24 1661 June 10, 2024
been granted an extension of time to file the
grantor’s or transferor’s income tax return
pursuant to section 6081, an extension of
time for filing Form 3520 is granted to the
fifteenth day of the tenth month following
the close of the grantor’s or transferor’s
taxable year. No additional extension of
time to file Form 3520 is allowed.
(iii) Filing by executor of grantor’s
or transferor’s estate. In the case of a
deceased grantor or transferor, the exec-
utor of the grantor’s or transferor’s estate
(within the meaning of paragraph (c)(3)
of this section) must file Form 3520 by
the fifteenth day of the fourth month fol-
lowing the close of the 12-month period
which began with the first day of the
grantor’s or transferor’s final taxable
year. If the executor of the grantor’s or
transferor’s estate has been granted an
extension of time to file the grantor’s or
transferor’s final income tax return pur-
suant to section 6081, an extension of
time for filing Form 3520 is granted to
the fifteenth day of the tenth month fol-
lowing the close of the 12-month period
which began with the first day of the
grantor’s or transferor’s final taxable
year. No additional extension of time to
file Form 3520 is allowed.
(b) Reportable event. Subject to
§1.6048-5, for purposes of this section,
the term reportable event means any of
the events described in paragraphs (b)(1)
through (3):
(1) The creation of any foreign trust by
any U.S. person.
(2) Any direct, indirect, or constructive
transfer, within the meaning of §1.679-3 or
§1.684-2, of property (including cash) to a
foreign trust by a U.S. person, including
a transfer by reason of death. In addition,
a reportable event includes an outbound
migration of a domestic trust, as described
in §1.684-4, without regard to whether any
gain is taxable under §1.684-1, and a U.S.
person’s transfer of property in exchange
for any obligation of the foreign trust or of
a person related to the trust, as described
in §1.679-4, without regard to whether the
obligation is a qualified obligation.
(3) The death of a citizen or resident of
the United States if—
(i) The decedent was treated as the
owner of any portion of a foreign trust
under subpart E of part I of subchapter J of
chapter 1 of the Internal Revenue Code, or
(ii) Any portion of a foreign trust was
included in the gross estate of the dece-
dent for Federal estate tax purposes.
(c) Responsible party. For purposes of
this section, the term responsible party
means each of the following:
(1) The grantor (within the meaning of
§1.671-2(e)) in the case of the creation of
an inter vivos trust.
(2) The transferor in the case of a
reportable event described in paragraph
(b)(2) of this section other than a transfer
by reason of death.
(3) The executor of the deceased grant-
or’s or transferor’s estate in any other case
(whether or not the executor is a U.S. per-
son).
(d) Examples. The following examples
illustrate the rules of this section.
(1) Example 1: Creation and funding of foreign
trust. A, an attorney, creates a foreign trust, FT, on
behalf of B, A’s client. A and B are both U.S. persons.
Shortly thereafter, B transfers $100x to FT. A and
B are both grantors of FT under §1.671-2(e), even
though only B transferred property to FT. Under
paragraph (b)(1) of this section, the creation of FT
is a reportable event, and under paragraph (c)(1) of
this section, A and B are responsible parties. Under
paragraph (b)(2) of this section, the funding of FT
is a reportable event, and under paragraph (c)(2) of
this section, B is the responsible party. Accordingly,
under paragraph (a) of this section, A must report the
creation of FT and B must report the creation and the
transfer to FT, respectively, on Part I of Form 3520.
(2) Example 2: Transfers to two foreign trusts.
The facts are the same as in paragraph (d)(1) of this
section (Example 1). B also transfers $100x to a sec-
ond foreign trust, FT2, during the same taxable year.
Under paragraph (a)(1) of this section, B must file
two Forms 3520, one for the creation and funding of
FT and one for the funding of FT2.
(3) Example 3: Transfer by domestic trust to for-
eign trust. Under the grantor trust rules, B is treated
as the owner of a domestic trust, DT. B is a U.S.
person and funds DT with $1,000x. Subsequently,
B causes DT to transfer $600x to FT, an existing
foreign trust. Under §1.679-3(b), B is treated as
transferring $600x to FT. Under paragraph (b)(2) of
this section, the transfer is a reportable event. Under
paragraph (c)(2) of this section, B is a responsible
party. Accordingly, under paragraph (a) of this sec-
tion, B is required to report the transfer to FT on Part
I of Form 3520.
(4) Example 4: Transfer by reason of death. C,
a U.S. person who files on a calendar year basis, is
treated as the owner of a domestic trust, DT, under
the grantor trust rules. The trust instrument provides
that, upon C’s death, DT will terminate and the
trustee must distribute the trust corpus to a foreign
trust, FT, for the benefit of C’s children. C dies in
Year 1. The trustee of DT distributes the trust corpus
to FT in Year 1. The transfer to FT is a reportable
event under paragraph (b)(2) of this section as a
transfer by reason of C’s death. Under paragraph (c)
(3) of this section, the executor of C’s estate is the
responsible party. Accordingly, under paragraph (a)
of this section, the executor of C’s estate is required
to report the transfer on Part I of Form 3520 by April
15, Year 2, the fifteenth day of the fourth month after
the close of the 12-month period which began with
the first day of C’s final taxable year, as described in
paragraph (a)(2)(ii) of this section. If C’s executor is
granted an extension of time to file C’s final income
tax return, then C’s Form 3520 will have a 6-month
extension and be due by October 15, Year 2.
(5) Example 5: Death of U.S. citizen who was
the owner of a foreign trust. The facts are the same
as in paragraph (d)(4) of this section (Example 4),
except that C dies in Year 1 while C is treated as the
owner of FT. Under paragraph (b)(3)(i) of this sec-
tion, C’s death is a reportable event. Under paragraph
(c)(3) of this section, the executor of C’s estate is a
responsible party. Accordingly, under paragraph (a)
of this section, the executor of C’s estate is required
to report C’s death on Form 3520 by April 15, Year 2,
the fifteenth day of the fourth month after the close of
the 12-month period which began with the first day
of C’s final taxable year, as described in paragraph
(a)(2)(ii) of this section. If C’s executor is granted an
extension of time to file C’s final income tax return
for the year of decedent’s death, then C’s Form 3520
will also have an extension and be due by October
15, Year 2.
(6) Example 6: Transfer in exchange for less than
fair market value. X, a U.S. person, sells property
worth $1,000x to a foreign trust, FT, in exchange for
$100x in cash. Under §1.671-2(e)(2)(ii), the $900x
excess amount is a gratuitous transfer by X to FT.
Under §1.679-3(a), X is treated as making a transfer
of $900x to FT. Under paragraph (b)(2) of this sec-
tion, the transfer is a reportable event. Under para-
graph (c)(2) of this section, X is a responsible party.
Accordingly, under paragraph (a) of this section, X
is required to report the $900x transfer to FT on Part
I of Form 3520.
(7) Example 7: Creation and funding of trust
in Puerto Rico by U.S. citizen. X is a U.S. citizen
and a bona fide resident of Puerto Rico. X creates
and funds a trust, T, in Puerto Rico. T is subject to
the primary jurisdiction of the Puerto Rican courts.
Because T fails the court test of §301.7701-7(a)(i),
it is classified as a foreign trust under §301.7701-7.
Under paragraph (b)(1) and (2) of this section, the
creation and funding of T are reportable events.
Under paragraph (c)(1) and (2) of this section, X is a
responsible party. Accordingly, under paragraph (a)
of this section, X is required to report the creation
and funding of T on Part I of Form 3520.
(8) Example 8: Indirect transfer. X, a U.S. per-
son, creates FT, a foreign trust, for the benefit of X’s
children, who are U.S. citizens. On July 1, Year 1, X
transfers ABC stock to X’s brother, Y, a nonresident
alien, for no consideration. Y immediately sells the
ABC stock and uses the proceeds to purchase DEF
stock. On January 5, Year 2, Y transfers the DEF
stock to FT. X is related to Y within the meaning of
§1.679-3(c)(4). X cannot demonstrate to the satisfac-
tion of the Commissioner that Y, as the intermediary,
has a relationship with the beneficiaries of the trust
that establishes a reasonable basis for concluding
that the intermediary would make a transfer to FT,
that Y acted independently of X, or that Y is not an
agent of X. Thus, the transfer is deemed to be for

June 10, 2024 1662 Bulletin No. 2024–24
the principal purpose of tax avoidance under §1.679-
3(c)(2). Under §1.679-3(c)(1), X is treated as having
made an indirect transfer of the DEF stock to FT on
January 5, Year 2. Under §1.679-3(c)(3), Y is treated
as an agent of X, and the DEF stock is treated as
transferred to FT by X. Under paragraph (b)(2) of
this section, the transfer is a reportable event. Under
paragraph (c)(2) of this section, X is a responsible
party. Accordingly, under paragraph (a) of this sec-
tion, X is required to report the transfer on Part I of
Form 3520.
(9) Example 9: Constructive transfer. FT, a for-
eign trust, owes $100x to F Corp, an unrelated for-
eign corporation, for the performance of services by
F Corp for the benefit of FT. In satisfaction of FT’s
liability to F Corp, X, a U.S. person, transfers to F
Corp property with a fair market value of $100x. By
satisfying FT’s obligation, under §1.679-3(d)(1), X
is treated as having made a constructive transfer of
property to FT. Under paragraph (b)(2) of this sec-
tion, the transfer is a reportable event. Under para-
graph (c)(2) of this section, X is a responsible party.
Accordingly, under paragraph (a) of this section, X is
required to report the transfer on Part I of Form 3520.
(10) Example 10: Partial guarantee of foreign
trust obligations. F Corp, a foreign corporation,
lends $100x to FT, a foreign trust, in exchange for
FT’s obligation to repay the loan. Knowing that F
Corp would not have made the loan without a guar-
antee, X, a U.S. person related to FT under §1.679-
1(c)(5), gratuitously guarantees the repayment of
$60x of FT’s obligation. Under §1.679-3(e), X is
treated as having transferred $60x to FT. Under para-
graph (b)(2) of this section, the transfer is a report-
able event. Under paragraph (c)(2) of this section, X
is a responsible party. Accordingly, under paragraph
(a) of this section, X is required to report the transfer
on Part I of Form 3520.
(11) Example 11: Dual resident taxpayer. The
facts are the same as in paragraph (d)(10) of this sec-
tion (Example 10) except that X is a dual resident
taxpayer (within the meaning of §301.7701(b)-7(a)
(1)) who computes his U.S. tax liability as a nonres-
ident alien for the taxable year during which he is
treated as making the transfer. Pursuant to §1.6048-
6(a)(1), X is not treated as a U.S. person for that tax-
able year and is not required to report the transfer on
Part I of Form 3520.
(12) Example 12: Outbound migration of domes-
tic nongrantor trust. X, a U.S. person, transfers
property to an irrevocable domestic trust, DT, for
the sole benefit of X’s daughter. DT is not treated as
owned by X or any other person under the grantor
trust rules. DB, a domestic bank, resigns as trustee
when X dies, and FB, a foreign bank, becomes the
replacement trustee under the terms of the trust.
Pursuant to §301.7701-7(d), DT becomes a foreign
trust, FT. Under §1.684-4(a), DT is treated as hav-
ing transferred all of its assets to FT and is required
to recognize gain on the transfer under §1.684-1(a).
Under paragraph (b)(2) of this section, the transfer
is a reportable event. Under paragraph (c)(2) of this
section, DT is the responsible party. Accordingly,
under paragraph (a) of this section, DT is required to
report the transfer on Part I of a Form 3520.
(13) Example 13: Outbound migration of domes-
tic grantor trust. On January 2, Year 1, X, a U.S.
person, transfers property with a fair market value
of $100x and an adjusted basis of $40x to a revo-
cable domestic trust, DT, for the benefit of A, a
U.S. person. X is treated as the owner of DT under
section 676. On January 15, Year 2, when the fair
market value of all property transferred to DT by X
is $150x, DT acquires a foreign trustee who has the
power to determine whether and when distributions
will be made to A. Under sections 7701(a)(30)(E)
and 7701(a)(31)(B) and §301.7701-7(d)(1)(ii)(A)
and (d)(2)(i), DT becomes a foreign trust, FT, on
January 15, Year 2. Under §1.684-2(d), X is treated
as transferring property with a fair market value of
$150x to FT on January 15, Year 2, without regard
to whether FT is a foreign grantor trust. Under para-
graph (b)(2) of this section, the transfer is a report-
able event. Under paragraph (c)(2) of this section, X
is the responsible party. Under paragraph (a) of this
section, X is required to report the transfer on Part I
of Form 3520.
§1.6048-3 U.S. owners of foreign trusts.
(a) U.S. owner requirement to ensure
foreign trust information is provided—
(1) In general. Unless an exception in
§1.6048-5 applies, any U.S. person who
is treated as an owner (U.S. owner) of a
foreign trust or of any portion of a foreign
trust under subpart E of part I of subchap-
ter J of chapter 1 of the Internal Revenue
Code during any taxable year is responsi-
ble for ensuring that, by the fifteenth day
of the third month after the end of the for-
eign trust’s taxable year, with a maximum
extension of a 6-month period pursuant to
section 6081, the foreign trust —
(i) Files Form 3520-A, Annual Infor-
mation Return of Foreign Trust With a U.S.
Owner (under section 6048(b)), under an
identification number assigned to the trust
(or portion of the trust) with the Commis-
sioner in accordance with the instructions
for Form 3520-A, and attaches copies of
the statements required by paragraphs (a)
(1)(ii) and (iii) of this section,
(ii) Furnishes a Foreign Grantor Trust
Owner Statement in accordance with the
instructions for Form 3520-A for the tax-
able year to each U.S. owner; and
(iii) Furnishes a Foreign Grantor Trust
Beneficiary Statement in accordance with
the instructions for Form 3520-A for the
taxable year to each U.S. person, other
than the U.S. owner, to whom the trust has
made a distribution (within the meaning
of §1.6048-4(b)), either directly or indi-
rectly, during the trust’s taxable year (each
a U.S. beneficiary).
(2) Substitute Form 3520-A filed by
the U.S. owner. If the foreign trust does
not comply with the requirements of
paragraph (a)(1) of this section, the U.S.
owner must—
(i) Complete and file Part II of Form
3520, Annual Return To Report Trans-
actions With Foreign Trusts and Receipt
of Certain Foreign Gifts, in accordance
with the instructions for Form 3520 by the
due date of the U.S. owner’s Form 3520,
as described in §1.6048-2(a)(2) but as if
“U.S. owner” replaces “responsible party”
in §1.6048-2(a)(2)(i) and as if “U.S.
owner” replaces “grantor or transferor” in
§1.6048-2(a)(2)(ii) and (iii), as applicable;
and
(ii) Complete Form 3520-A and related
statements for each U.S. owner and U.S.
beneficiary on behalf of the foreign trust
and file them with the U.S. owner’s Part
II of Form 3520 by the due date of the
U.S. owner’s Form 3520 as provided in
paragraph (a)(2)(i) of this section. Further,
unless paragraph (a)(3) of this section
applies, the U.S. owner must furnish the
Foreign Grantor Trust Beneficiary State-
ment in accordance with the instructions
for Form 3520-A to each U.S. beneficiary
by the due date of the U.S. owner’s Form
3520.
(3) Certain fixed investment trusts.
A U.S. owner who is subject to the rules
of this section is not required to provide
information about the other persons who
are treated as owners of the foreign trust if
the foreign trust meets all requirements to
qualify as a widely held fixed investment
trust within the meaning of §1.671-5(b)
(22) other than the requirement that it be a
U.S. person under section 7701(a)(30)(E).
(b) Consistency rule—(1) In general.
Subject to paragraph (b)(2) of this section,
U.S. owners or U.S. beneficiaries who
receive a Foreign Grantor Trust Owner
Statement or Foreign Grantor Trust Bene-
ficiary Statement from a foreign trust must
treat any item reported by the trust to such
U.S. person in a manner that is consistent
with the trust’s treatment of such item on
the Foreign Grantor Trust Owner State-
ment or Foreign Grantor Trust Beneficiary
Statement.
(2) Notification of inconsistent treat-
ment. If a U.S. owner’s or U.S. benefi-
ciary’s treatment on such U.S. owner’s
or U.S. beneficiary’s return is (or may be)
inconsistent with the treatment of the item
reported on a Foreign Grantor Trust Owner

Bulletin No. 2024–24 1663 June 10, 2024
Statement or Foreign Grantor Trust Bene-
ficiary Statement, then the U.S. owner or
U.S. beneficiary must notify the Commis-
sioner about the inconsistent treatment.
The notification of inconsistent treatment
must be made on a Form 8082, Notice of
Inconsistent Treatment or Administrative
Adjustment Request (AAR). Rules similar
to the rules of section 6034A(c) (generally
requiring beneficiaries of estates or trusts
to file their returns in a manner that is con-
sistent with information received from the
estate or trust) will apply, including the
rules for any adjustments required to make
the treatment of reported items consistent
in the case of a U.S. owner’s or U.S. ben-
eficiary’s failure to notify the Commis-
sioner about the inconsistent treatment.
(c) Income tax determinations for for-
eign grantor trusts without U.S. agents.
If a foreign trust with a U.S. owner does
not have a U.S. agent as described in para-
graph (d) of this section, or if otherwise
provided pursuant to paragraph (d)(5) of
this section, then the amounts required to
be taken into account with respect to the
trust by the U.S. owner under the grantor
trust rules are determined by the Commis-
sioner based on all the facts and circum-
stances.
(d) Authorization of a U.S. agent—(1)
In general. Paragraph (c) does not apply
if a U.S. owner of a foreign trust ensures
that the foreign trust authorizes a U.S. per-
son to act as the trust’s limited agent as
described in paragraph (d)(2) of this sec-
tion solely for purposes of applying sec-
tions 7602, 7603, and 7604 with respect
to—
(i) Any request by the Commissioner
to examine records or produce testimony
related to the proper treatment of amounts
required to be taken into account under the
grantor trust rules, or
(ii) Any summons by the Commis-
sioner for such records or testimony.
(2) Requirements. In order to autho-
rize a U.S. person to act as an agent under
paragraph (d)(1) of this section, a U.S.
owner of a foreign trust must ensure that
the trust and the agent enter into a bind-
ing authorization agreement that is exe-
cuted by the foreign trust and the U.S.
agent before the due date of Form 3520-A
or substitute Form 3520-A (as described
in §1.6048-3(a)(1) and (2), respectively)
for the taxable year that the U.S. owner
is considered the owner of the trust. The
authorization must remain in effect for as
long as the statute of limitations remains
open for the U.S. owner’s relevant taxable
year. If the agent resigns or liquidates or
if the agent’s responsibility is terminated,
the U.S. owner of the foreign trust must
ensure that the foreign trust notifies the
Commissioner within 90 days, by filing an
amended Form 3520-A. This notification
must contain the name, address and Tax-
payer Identification Number of the new
U.S. agent.
(3) Limitations. The appearance of per-
sons or production of records by reason
of a U.S. person being an agent described
in paragraph (d)(1) of this section will
not subject such persons or records to
legal process for any purpose other than
determining the correct treatment of the
amounts to be taken into account by the
U.S. owner under paragraph (c) of this
section.
(4) No office, permanent establishment,
or trade or business. A foreign trust that
appoints a U.S. agent described in para-
graph (d)(1) of this section will not be
considered to have an office or a perma-
nent establishment in the United States,
or to be engaged in a trade or business in
the United States, solely because of the
agent’s activities as an agent pursuant to
this section.
(5) Summons issued to a U.S. agent—
(i) In general. Paragraph (c) of this sec-
tion applies if a summons is issued to a
U.S. person (either directly or as a limited
agent of a foreign trust who is appointed
pursuant to paragraph (d)(1) of this sec-
tion) or to a foreign trust (where service
of the summons can be effectuated) to
produce any records or testimony in order
to determine the amounts required to be
taken into account under the grantor trust
rules, and if—
(A) The summons is not quashed in a
proceeding, if any, begun not later than
the 90th day after the summons was issued
and is not determined to be invalid in a
proceeding, if any, begun under section
7604 to enforce the summons; and
(B) The Commissioner has sent by
certified or registered mail a notice to the
U.S. person or foreign trust of its deter-
mination that the U.S. person or foreign
trust has not substantially and timely com-
plied with the summons, and a proceeding
to review the determination is not begun
any later than 90 days after the notice is
mailed. If such a proceeding is not begun
on or before such 90th day, the determina-
tion by the Commissioner will be binding.
(ii) Enforcement proceeding not
required. The Commissioner is not
required to begin an enforcement pro-
ceeding to enforce the summons in order
to apply the rules of paragraph (d)(5) of
this section.
(iii) Suspension of statute of limitations.
If the U.S. person or foreign trust to which
a summons is issued brings a proceeding
to quash the summons not later than the
90th day after the summons was issued,
or begins a proceeding to review a deter-
mination under paragraph (d)(5)(i)(B) of
this section not later than the 90th day after
the day on which the notice referred to in
paragraph (d)(5)(i)(B) of this section was
mailed, the running of any period of limita-
tion under section 6501 (relating to assess-
ment and collection of tax) or under section
6531 (relating to criminal prosecutions) for
the taxable year or years to which the sum-
mons that is the subject of such proceed-
ing relates will be suspended for the period
during which the proceeding, and appeals
therein, are pending. In no event will any
such period expire before the 90th day after
the day on which there is a final determina-
tion in the proceeding.
(e) Examples. The following examples
illustrate the rules of this section.
(1) Example 1: Fixed investment trust. X, a U.S.
person, is treated as an owner of a foreign trust, FT,
that would be a widely held fixed investment trust
within the meaning of §1.671-5(b)(22) if it were a
domestic trust. FT does not file a Form 3520-A for
Year 1. Under paragraph (a)(2) of this section, X is
required to complete and file Part II of Form 3520 by
the due date for X’s Year 1 Form 3520. In addition,
under paragraph (a)(2) of this section, X is required to
complete a substitute Form 3520-A and related state-
ments and file them with X’s Year 1 Form 3520. Under
paragraph (a)(4) of this section, X is not required to
provide information about the other owners of FT.
(2) Example 2: Substitute Form 3520-A. X, a
U.S. person, is treated as the owner of a foreign
trust, FT. FT’s taxable year ends on December 31.
On November 1, Year 1, FT makes a distribution to
Y, a U.S. beneficiary of the trust. FT fails to com-
ply with the requirements of paragraph (a)(1) of
this section for its taxable year ending December
31, Year 1. Under paragraph (a)(2) of this section,
X is required to complete and file Part II of Form
3520 by the due date for X’s Year 1 Form 3520. In
addition, under paragraph (a)(2) of this section, X
is required to complete a substitute Form 3520-A
and related statements and file them with X’s Year 1

June 10, 2024 1664 Bulletin No. 2024–24
Form 3520. X must furnish a Foreign Grantor Trust
Beneficiary Statement to Y by the due date for X’s
Year 1 Form 3520.
(3) Example 3: Failures to appoint U.S. agent and
to respond to summons. X, a U.S. person, is treated as
the owner of a foreign trust, FT. FT does not appoint
a U.S. agent described in paragraph (d)(1) of this sec-
tion. The Commissioner issues a summons to X for
the production of records of FT related to the proper
treatment of amounts required to be taken into account
by X under the grantor trust rules. Neither X nor FT
responds to the summons. Under paragraph (c) of this
section, the Commissioner may determine the amount
that X must take into account under the grantor trust
rules based on all the facts and circumstances.
(4) Example 4: Multiple trusts and multiple trans-
actions. X, a U.S. person, is treated as the owner of two
foreign trusts, FT1 and FT2. During Year 1, X trans-
fers cash to FT1 and receives a distribution from FT2.
FT1 and FT2 fail to comply with the requirements of
paragraph (a)(1) of this section for their taxable years
ending in Year 1. Under §1.6048-2 and paragraph
(a)(2) of this section, X must report X’s transfer to,
and ownership of, FT1 on one Form 3520, and under
§1.6048-4 and paragraph (a)(2) of this section, X must
report X’s ownership of, and distribution from, FT2
on a second Form 3520. In addition, under paragraph
(a)(2)(ii) of this section, X must complete a substitute
Form 3520-A for each trust, FT1 and FT2, and file
them with X’s Year 1 Form 3520 for each trust.
(5) Example 5: Dual resident taxpayer. (i) X
is a lawful permanent resident of the United States
within the meaning of §301.7701(b)-1(b) of this
chapter and a tax resident of Country F under the
domestic tax law of Country F. X is treated as a res-
ident of Country F under the residence article of the
U.S.-Country F income tax treaty (the treaty). Pur-
suant to §301.7701(b)-7 of this chapter, X is treated
as a nonresident alien for purposes of computing X’s
U.S. income tax liability for Year 1. During Year
1, X transfers $100x to a foreign trust, FT, for the
benefit of X’s children, who are U.S. citizens. Under
§1.6048-6(a), X is not treated as a U.S. person and is
not required to report the transfer under §1.6048-2
on a Form 3520 for Year 1.
(ii) In Year 2, X waives any benefits to which X
would have been entitled under the treaty and computes
X’s U.S. income tax liability as a resident alien. Under
§1.679-5(a), X is treated as having made a transfer to
FT on January 1, Year 2, in the amount of the fair mar-
ket value of FT as of that date. Under §1.679-1(a), X
is treated as the owner of FT as of January 1, Year 2.
Under §1.6048-2(a), X is required to file a Form 3520
for Year 2 on which X reports the transfer to FT. If FT
fails to comply with the requirements of paragraph (a)
(1) of this section for FT’s taxable year ending in Year
2, under paragraph (a)(2) of this section, X also must
complete and file Part II of Form 3520, and complete
and file a substitute Form 3520-A with the related state-
ments attached to X’s Year 2 Form 3520.
§1.6048-4 Reporting by U.S. persons
receiving distributions from foreign
trusts.
(a) Reporting of trust distributions.
Unless an exception in §1.6048-5 applies,
any U.S. person who receives directly or
indirectly any distribution from a foreign
trust (without regard to whether any per-
son is treated as the owner of the foreign
trust under the rules of subpart E of part
I of subchapter J of chapter 1) must file
Part III of Form 3520, Annual Return To
Report Transactions With Foreign Trusts
and Receipt of Certain Foreign Gifts, by
the due date of the U.S. person’s Form
3520, as described in §1.6048-2(a)(2)
by replacing “responsible party” with
“U.S. person” in §1.6048-2(a)(2)(i) and
by replacing “grantor or transferor” with
“U.S. person” in §1.6048-2(a)(2)(ii) and
(iii), as applicable. See §1.6048-6(d) for
information reporting by married U.S.
persons who file a joint income tax return.
(b) Distribution—(1) In general.
Except as provided in paragraphs (b)(5)(ii)
and (b)(6)(ii) of this section, a distribution
means any transfer of property (including
cash) from a foreign trust received directly
or indirectly by a U.S. person to the extent
such property exceeds the fair market
value of any property or services received
by the foreign trust in exchange for the
property transferred, without regard to
whether any portion of the foreign trust is
treated as owned by the grantor or another
person under the rules of subpart E of part
I of subchapter J of chapter 1, whether
the recipient is designated as a benefi-
ciary by the terms of the foreign trust, or
whether the distribution has any income
tax consequences. A distribution includes
any amount, including without limita-
tion a gift or bequest described in section
663(a), actually or constructively received
by a U.S. person. For these purposes, a
transfer of property from a foreign trust to
a grantor trust or to a disregarded entity
(as defined in §1.643(i)-1(d)(3) of this
chapter) is treated as a distribution to the
owner of the grantor trust or of the disre-
garded entity, respectively. For example,
a transfer of property from a foreign trust
to a single member LLC treated as a dis-
regarded entity is treated as a distribution
to the owner of the LLC. For distributions
through intermediaries, see paragraph (b)
(2) of this section; for distributions from
entities owned by a foreign trust, see para-
graph (b)(3) of this section; for inbound
migrations of foreign trusts, see paragraph
(b)(4) of this section; for loans of cash or
marketable securities, see paragraph (b)
(5) of this section; for use of trust property,
see paragraph (b)(6) of this section; and
for the receipt of covered gifts or bequests
from a foreign trust, see paragraph (b)(7)
of this section.
(2) Distributions from foreign trusts
through intermediaries—(i) In general.
A distribution includes any transfer of
property from a foreign trust received by
a U.S. person through an intermediary,
nominee, or agent. In such a case, except
as otherwise provided in paragraph (b)
(2)(ii) of this section, the intermediary,
nominee, or agent is treated as an agent
of the foreign trust and the property is
treated as distributed from the foreign
trust to the U.S. person in the year the
property is received by or made available
by the intermediary, nominee, or agent to
the U.S. person.
(ii) Special rule. If the Commissioner
determines that the intermediary, nomi-
nee, or agent is an agent of the U.S. per-
son, the property is treated as distributed
from the foreign trust to the U.S. person
in the year the property is received by the
intermediary, nominee, or agent. In such
case, the intermediary, nominee, or agent
is not treated as distributing the property
to the U.S. person when the property is
subsequently received by or made avail-
able by the intermediary, nominee, or
agent to the U.S. person.
(iii) Reporting indirect transfers of
property. An indirect transfer of prop-
erty from a foreign trust must be reported
on Part III of Form 3520 without regard
to whether the receipt of such property
would be treated as having any income tax
consequences to the U.S. person receiving
such property, to a U.S. grantor or ben-
eficiary of the foreign trust, or to a U.S.
owner of the foreign trust.
(3) Distributions from entities owned
by a foreign trust. A distribution includes
any transfer of property from an entity
in which a foreign trust directly or indi-
rectly holds an ownership interest that is
received by a U.S. person who is a related
person (as defined in §1.679-1(c)(5)) with
respect to the foreign trust. In such case,
the transfer of the property by the entity
owned by the foreign trust to the U.S.
person is treated as a distribution of such
property by the entity to the foreign trust
followed by a distribution of the property
from the foreign trust to the U.S. person,

Bulletin No. 2024–24 1665 June 10, 2024
unless the U.S. person demonstrates to
the satisfaction of the Commissioner that
the distribution from the entity is properly
attributable to the U.S. person’s owner-
ship interest in the entity.
(4) Inbound migrations of foreign
trusts. A distribution includes an inbound
migration of a foreign trust. An inbound
migration of a foreign trust occurs when
a foreign trust becomes a domestic trust.
In such case, the foreign trust is treated as
distributing the trust corpus and income to
the domestic trust on the date the foreign
trust becomes a domestic trust.
(5) Loans of cash or marketable securi-
ties—(i) In general. A distribution includes
any loan of cash or marketable securities
made from a foreign trust (whether from
trust corpus or income) directly or indi-
rectly to a U.S. person. For these purposes,
a loan to a grantor trust or to a disregarded
entity (as defined in §1.643(i)-1(d)(3) of
this chapter) will be treated as a loan to the
owner of the grantor trust or of the disre-
garded entity, respectively. For example, a
loan to a single member LLC treated as a
disregarded entity will be treated as a loan
to the owner of the LLC. Loans from a
foreign trust include:
(A) A loan of cash or marketable secu-
rities made by any person to a U.S. person,
if the foreign trust provides a guarantee
(within the meaning of §1.679-3(e)(4)) for
the loan, and
(B) A loan of cash or marketable secu-
rities made by any intermediary, nominee
or agent of a foreign trust to a U.S. person.
(ii) Section 643(i) loans of cash or
marketable securities. A distribution
includes a direct or indirect loan of cash
or marketable securities from a foreign
nongrantor trust to any U.S. grantor
or beneficiary (within the meaning of
§1.643(i)-1(d)(11) or (1), respectively) or
a U.S. person related (within the mean-
ing of §1.643(i)-1(d)(9)) to a U.S. grantor
or beneficiary regardless of whether the
loan was made in exchange for a qual-
ified obligation within the meaning of
§1.643(i)-2(b)(2)(iii). For these purposes,
indirect loans include loans described in
§1.643(i)-1(b)(2).
(iii) Reporting loans of cash or mar-
ketable securities. A loan of cash or
marketable securities made from a for-
eign trust must be reported by the U.S.
person described under paragraph (b)(5)
(i) of this section and by the U.S. grantor
or beneficiary described under para-
graph (b)(5)(ii) of this section on Part III
of Form 3520, Annual Return to Report
Transactions with Foreign Trusts and
Receipt of Certain Foreign Gifts, with-
out regard to whether the loan would be
treated as having any income tax conse-
quences to a U.S. grantor or beneficiary
(within the meaning of §1.643(i)-1(d)
(11) or (1), respectively) of the foreign
trust.
(6) Use of trust property—(i) In gen-
eral. A distribution includes the fair market
value of the direct or indirect use of any
property of a foreign trust by a U.S. person.
For these purposes, use of property of a
foreign trust by a grantor trust or by a disre-
garded entity (as defined in §1.643(i)-1(d)
(3)) will be treated as the use of trust prop-
erty by the owner of the grantor trust or of
the disregarded entity, respectively. For
example, use of trust property by a sin-
gle member LLC treated as a disregarded
entity will be treated as use of trust prop-
erty by the owner of the LLC.
(ii) Section 643(i) use of trust prop-
erty. A distribution includes the fair mar-
ket value of the direct or indirect use of
any property of a foreign nongrantor trust
by a U.S. grantor or beneficiary (within
the meaning of §1.643(i)-1(d)(11) or (1),
respectively) or a U.S. person related
(within the meaning of §1.643(i)-1(d)
(9)) to a U.S. grantor or beneficiary with-
out regard to whether the foreign trust is
paid the fair market value for such use.
For these purposes, indirect use of trust
property includes the use described in
§1.643(i)-1(c)(2).
(iii) Reporting use of trust property.
The use of trust property must be reported
by the U.S. person described under para-
graph (b)(6)(i) of this section and by the
U.S. grantor or beneficiary described
under paragraph (b)(6)(ii) of this section
on Part III of Form 3520, Annual Return
to Report Transactions with Foreign
Trusts and Receipt of Certain Foreign
Gifts, without regard to whether the use
of trust property would be treated as hav-
ing any income tax consequences to a U.S.
grantor or beneficiary (within the meaning
of §1.643(i)-1(d)(11) or (1), respectively)
of the foreign trust.
(7) Certain covered gifts or bequests.
A distribution includes any covered gift or
bequest (described in section 2801(e)) that
is received as a distribution from a foreign
trust.
(c) Statements provided by foreign
trust—(1) Foreign grantor trust with U.S.
owner—(i) Owner statement. Pursuant
to §1.6048-3(a)(1)(ii), a U.S. owner of a
foreign trust (or portion of a foreign trust)
should receive a Foreign Grantor Trust
Owner Statement.
(ii) Statement for U.S. person receiving
a distribution. Pursuant to §1.6048-3(a)
(1)(iii), a U.S. person, other than a U.S.
owner, who receives a distribution from a
foreign grantor trust (or portion of a for-
eign grantor trust) should receive a For-
eign Grantor Trust Beneficiary Statement.
(2) Foreign nongrantor trust. A for-
eign nongrantor trust may issue, by the
fifteenth day of the third month after the
end of the trust’s taxable year, a Foreign
Nongrantor Trust Beneficiary Statement
to each U.S. person who receives a dis-
tribution from the foreign trust during the
trust’s taxable year.
(3) Foreign grantor trust with foreign
owner. A foreign trust that is treated as
owned by a foreign person under the
grantor trust rules may issue, by the fif-
teenth day of the third month after the
end of the trust’s taxable year, a For-
eign-Owned Grantor Trust Beneficiary
Statement to each U.S. person who
receives a distribution.
(d) Tax consequences of distributions—
(1) In general. Subject to paragraph (e) of
this section, a U.S. person (other than a
U.S. person described in §1.6048-4(c)(1)
(i)) who receives a distribution (other than
a distribution described in §1.6048-4(b)(5)
or (6) that is not treated as a section 643(i)
distribution under §1.643(i)-1) from a
foreign trust must determine the tax con-
sequences of the distribution as follows,
unless the distribution is received in a year
that the foreign trust terminates. For rules
determining the tax consequences of a dis-
tribution in the year a foreign trust termi-
nates, see paragraphs (d)(3)(i)(B) and (d)
(3)(iii) of this section.
(i) A U.S. person who receives a For-
eign Grantor Trust Beneficiary Statement
or a Foreign-Owned Grantor Trust Benefi-
ciary Statement before the due date of the
U.S. person’s income tax return (including
extensions) must determine the income
tax consequences of the distribution from

June 10, 2024 1666 Bulletin No. 2024–24
the trust as a distribution being made from
a grantor trust.
(ii) A U.S. person who receives a For-
eign Nongrantor Trust Beneficiary State-
ment before the due date of the U.S.
person’s income tax return (including
extensions) may determine the income
tax consequences of the distribution
under either the actual calculation method
described in paragraph (d)(2) of this sec-
tion or the default calculation method
described in paragraph (d)(3) of this sec-
tion, unless the U.S. person knows or has
reason to know that the information in the
statement is incorrect or the U.S. person
has previously used the default calculation
method with respect to distributions from
the same foreign trust.
(iii) In all other cases, including when
a U.S. person does not receive a statement
described in §1.6048-4(c) before the due
date of the U.S. person’s income tax return
(including extensions), the U.S. person
must use the default calculation method
described in paragraph (d)(3) of this sec-
tion.
(2) Actual calculation method. Under
the actual calculation method, the tax
consequences of the distribution are deter-
mined by using actual information about
the foreign trust as provided in the Foreign
Nongrantor Trust Beneficiary Statement
described in §1.6048-4(c)(2) and applying
the rules of subparts C and D of Part I of
subchapter J of chapter 1 of the Internal
Revenue Code.
(3) Default calculation method—
(i) Consequences to U.S. person who
receives a distribution from a foreign
trust—(A) In general. Under the default
calculation method, the tax consequences
of the distribution are determined by allo-
cating the distribution between a distribu-
tion of current income and a distribution
of accumulated income under the rules of
this paragraph (d)(3). The portion of the
distribution that is treated as a distribution
of current income is 125% of the average
distribution that the U.S. person received
from the foreign trust during the imme-
diately preceding three taxable years (or
the number of years during which the trust
has been a foreign trust, if fewer than three
years). The remainder of the distribution,
if any, is treated as an accumulation dis-
tribution within the meaning of section
665(b) that is subject to an interest charge
under section 668. For purposes of com-
puting the interest charge (in the absence
of actual information provided on a state-
ment described in §1.6048-4(c)), the U.S.
person must assume that the applicable
number of years the trust has been in
existence is ten years and that no taxes
described in section 665(d) have been
imposed on the trust in any applicable
previous year (even if a distribution had
been made and tax under section 665(d)
had been imposed).
(B) Year of trust termination. Unless
paragraph (d)(3)(iii) of this section
applies, the tax consequences of a distribu-
tion in the year a foreign trust terminates
are determined by treating the distribution
as an accumulation distribution within the
meaning of section 665(b) that is subject
to an interest charge under section 668 for
any amount in excess of the portion of the
distribution that is treated as a distribution
of current income described in paragraph
(d)(3)(i)(A) of this section.
(ii) Consequences to trust. A foreign
trust must determine the income tax con-
sequences of distributions to U.S. persons
by applying the applicable rules of part I
of subchapter J of chapter 1 of the Internal
Revenue Code.
(iii) Actual calculation method in year
of foreign trust termination after using the
default calculation method. A U.S. per-
son who has previously used the default
calculation method with respect to distri-
butions from a foreign trust may, for the
year in which the foreign trust terminates,
determine the tax consequences of a dis-
tribution from the same trust by using the
actual calculation method provided that,
before the due date of the U.S. person’s
income tax return (including extensions),
the trust provides to the U.S. person com-
plete and accurate information about all
previous distributions from such foreign
trust. The U.S. person must use this infor-
mation to recalculate the tax effect of all
previous distributions from such foreign
trust under the actual calculation method
in order to determine the portion attrib-
utable to current income, accumulated
income, and principal in the year that the
foreign trust terminates. A U.S. person
described in this paragraph (d)(3)(iii) may
not use the actual calculation method for
the year that the foreign trust terminates
if the U.S. person knows or has reason to
know that the information provided by the
foreign trust is incorrect.
(iv) Example. The following example illustrates
the rules of paragraph (d)(3)(i) of this section. B, a
U.S. person, is a beneficiary of a foreign nongrantor
trust, FT, that was established in Year 1. In Year 2,
Year 3, and Year 4, B received distributions from FT
of $100x, $200x, and $300x respectively. In Year 5,
B receives a $400x distribution from FT. To deter-
mine the tax consequences of the Year 5 distribution,
B applies the default calculation method. Under the
default calculation method, the average distribution
that B received from FT during the preceding three
years is $200x and 125% of such average distribu-
tion is $250x. Therefore, $250x of the Year 5 distri-
bution is treated as a distribution of current income
and the remaining $150x is treated as an accumu-
lation distribution. The $150x that is treated as an
accumulation distribution is subject to an interest
charge under section 668. B must report the distri-
bution and the default calculation on Part III of Form
3520 for Year 5.
(e) Distribution treated as accumula-
tion distribution if records are not pro-
vided. If adequate records are not pro-
vided to the Commissioner to determine
the proper treatment of any distribution
from a foreign trust (within the meaning
of paragraph (b) of this section) other than
a loan or use of trust property that is not
treated as a section 643(i) distribution
under §1.643(i)-1, the entire distribution
will be treated as an accumulation distri-
bution includible in the gross income of
the U.S. person who received the distribu-
tion under chapter 1 of the Internal Rev-
enue Code. However, if the trustee of a
foreign trust authorizes a U.S. person to
act as the trust’s limited agent under rules
prescribed in §1.6048-3(d), then the tax
consequences of the distribution may be
determined under the rules described in
paragraph (d)(1) of this section.
(f) Interaction with §1.6039F-1. If a
U.S. person receives a distribution from a
foreign trust, the U.S. person must report
the distribution under paragraph (a) of
this section and not under §1.6039F-1(a),
regardless of whether the distribution is
taxable to the U.S. person receiving the
distribution. See §1.6039F-1(b).
(g) Examples. The following examples
illustrate the rules of this section. In each
example, X is a U.S. citizen, FT is a for-
eign trust, and FC is a foreign corporation.
(1) Example 1: Payment of liability treated as
distribution. X owes $1,000x to Y for services that Y
performed for X. In satisfaction of X’s liability to Y,
FT transfers to Y property with a fair market value of
$1,000x. Under paragraph (b)(1) of this section, FT’s
transfer of property to Y is constructively received

Bulletin No. 2024–24 1667 June 10, 2024
by X from FT, and is a distribution in the amount
of $1,000x to X for purposes of this section. Under
paragraph (a) of this section, X must report the dis-
tribution on Part III of Form 3520.
(2) Example 2: Assumption of liability treated as
distribution. The facts are the same as in paragraph
(g)(1) of this section (Example 1) except that FT
assumes X’s liability to pay Y. The result is the same
as in paragraph (g)(1) of this section (Example 1).
(3) Example 3: Trust’s partial guarantee of U.S.
person’s obligation treated as distribution from for-
eign trust. Y lends $1,000x of cash to X in exchange
for X’s obligation to repay the loan. X is a U.S. per-
son. FT guarantees the repayment of $600x of X’s
obligation. Under paragraph (b)(5)(i)(A) of this sec-
tion, FT’s guarantee of X’s obligation is a distribu-
tion from FT to X in the amount of $600x. Under
paragraph (a) of this section, X must report the dis-
tribution on Part III of Form 3520.
(4) Example 4: Section 643(i) loan not in
exchange for qualified obligation. X’s sister, A, and
A’s husband, B, are both U.S. citizens. X, A, and B
are U.S. persons within the meaning of §1.643(i)-1(d)
(12), and X is related to B under §1.643(i)-1(d)(9). B
is a beneficiary of FT, a nongrantor trust. In Year 1,
FT lends $100x to X in exchange for a demand note
that permits FT to require repayment by X at any
time. The demand note issued by X is not a qualified
obligation within the meaning of §1.643(i)-2(b)(2)
(iii) because X’s obligation to FT could remain out-
standing for more than five years. Accordingly, the
loan from FT to X is treated as a section 643(i) distri-
bution of $100x to B under §1.643(i)-1(a). The loan
is a distribution from FT to X and B under paragraph
(b)(5)(ii) of this section. Under paragraphs (a) and
(b)(5)(iii) of this section, X and B each must report
the distribution on Part III of Form 3520.
(5) Example 5: Section 643(i) loan in exchange
for qualified obligation. The facts are the same as in
paragraph (g)(4) of this section (Example 4) except
that the loan cannot remain outstanding for more
than five years and it is a qualified obligation within
the meaning of §1.643(i)-2(b)(2)(iii). Although the
loan is not a section 643(i) distribution within the
meaning of §1.643(i)-1(a), the loan nevertheless is a
distribution from FT to X and to B under paragraph
(b)(5)(ii) of this section. Under paragraphs (a) and
(b)(5)(iii) of this section, X and B each must report
the distribution on Part III of Form 3520.
(6) Example 6: Distribution through interme-
diary. Y, a nonresident alien, created FT in 1980
for the benefit of Y’s children and their descen-
dants, all of whom are U.S. persons. FT’s trustee,
T, determines that $100x of accumulated income
should be distributed to X, one of Y’s children.
Pursuant to a plan with a principal purpose of
avoiding the interest charge that would be imposed
on an accumulation distribution from a foreign
trust by section 668, T makes a gratuitous transfer
from FT of $100x to N, a foreign person. N sub-
sequently makes a gratuitous transfer of $100x to
X. Under §1.643(h)-1(a)(1), FT is deemed to have
made an accumulation distribution of $100x to X.
The distribution through N as the intermediary is
treated as a distribution under paragraph (b)(2)(i)
of this section. Under paragraphs (a) and (b)(2)
(iii) of this section, X must report the distribution
on Part III of Form 3520.
(7) Example 7: Excess payment in exchange
for property. X transfers to FT property with a fair
market value of $200x in exchange for a payment
of $500x. Under paragraph (b)(1) of this section, the
excess amount of $300x is treated as a distribution
from FT to X. Under paragraph (a) of this section,
X must report the distribution of $300x on Part III
of Form 3520.
(8) Example 8: Excess payment in exchange for
services. X receives a payment of $100x from FT
purportedly in exchange for X’s performance of ser-
vices as a trustee of FT. The fair market value of the
services performed is $20x. Under paragraph (b)(1)
of this section, X is treated as receiving a distribution
of $80x from FT. Under paragraph (a) of this section,
X must report the distribution of $80x on Part III of
Form 3520.
(9) Example 9: Distribution from entity owned by
foreign trust. FT owns all of the outstanding stock
of FC. FC distributes $100x directly to X, a related
person within the meaning of §1.679-1(c)(5) with
respect to FT. Because FT is the sole shareholder of
FC, X is unable to demonstrate to the satisfaction of
the Commissioner that the distribution is properly
attributable to X’s ownership interest in FC. Accord-
ingly, under paragraph (b)(3) of this section, X is
treated as receiving a distribution of $100x from FT.
Under paragraph (a) of this section, X must report
the distribution of $100x on Part III of Form 3520.
(10) Example 10: Distribution from entity
co-owned by foreign trust. FC has 100 outstanding
shares of stock. FT owns 25 shares of FC stock, X
owns 50 shares, and N, a nonresident alien, owns
the remaining 25 shares. In Year 1, FC distributes a
dividend of $25x to each of FT and N and $50x to
X. Because the distribution was made to FT, X, and
N in proportion to their ownership interests in FC
and X reports $50x as a dividend on X’s timely filed
income tax return for Year 1, X is able to demon-
strate to the satisfaction of the Commissioner that the
distribution is properly attributable to X’s ownership
interest in FC. Accordingly, under paragraph (b)(3)
of this section, X is not treated as receiving a report-
able distribution of $50x from FT.
(11) Example 11: Foreign trust becomes domes-
tic trust. FB, a foreign bank, resigns as trustee of FT,
and DB, a domestic bank, becomes the new trustee of
FT. Pursuant to section 7701(a)(30)(E), FT becomes
a domestic trust, DT. Under paragraph (b)(4) of this
section, DT is treated as receiving a distribution of
the trust corpus and income from FT. Under para-
graph (a) of this section, DT must report the deemed
distribution of the trust corpus and income on Part
III of Form 3520 for the year in which the inbound
migration occurs.
(12) Example 12: Distribution received by
domestic trust. T, as trustee of FT, has the power to
decant. Exercising that power, T distributes the trust
corpus and income of FT to DT, a domestic trust.
Neither FT nor DT is a grantor trust. Under para-
graph (b)(1) and (4) of this section, DT receives
a distribution of the trust corpus and income from
FT. Under paragraph (a) of this section, DT must
report the distribution of the trust corpus and income
on Part III of Form 3520 for the year in which the
decanting occurs.
(13) Example 13: Distribution received by U.S.
owner. X is treated as the owner of FT under section
679. X receives a distribution from FT. Under para-
graph (a) of this section, X must report the distribu-
tion on Part III of Form 3520.
(14) Example 14: Distribution from trust owned
by another person. X receives a distribution from
FT. Y, a nonresident alien, is treated as the owner of
FT under the grantor trust rules. X receives a com-
pleted Foreign-Owned Grantor Trust Beneficiary
Statement. Under paragraph (a) of this section and
§1.6048-6(b), X must file Form 3520 for the year of
the distribution.
(15) Example 15: Use of default calculation
method if statement not provided. The facts are the
same as in paragraph (g)(14) (Example 14) except
that X does not receive a Foreign-Owned Grantor
Trust Beneficiary Statement from FT. Pursuant to
paragraph (d)(3) of this section, X must determine
the tax consequences of the distribution using the
default calculation method. Under the default cal-
culation method, X must include the distribution in
income in accordance with rules prescribed in para-
graph (d)(3) of this section and in the Instructions for
Form 3520 for the applicable taxable year.
(16) Example 16: Distribution attributable to
covered gift. Z relinquishes Z’s U.S. citizenship
on September 15, Year 1. Z is a covered expatri-
ate within the meaning of section 877A(g)(1). On
August 1, Year 2, Z creates and transfers $300x to
a foreign trust, FT, for the benefit of Z’s son, S, a
U.S. citizen. On December 30, Year 3, S receives a
$40x distribution from FT. Whether or not the entire
amount of the distribution is a covered gift within
the meaning of section 2801(e), under paragraph (b)
(7) of this section, the $40x is a distribution. Under
paragraph (a) of this section, S must report the dis-
tribution on Part III of Form 3520. S also may have
additional reporting requirements under section 2801
for the covered gift.
§1.6048-5 Exceptions.
(a) Exceptions under section 6048(a)
(3)(B). For purposes of §1.6048-2, a
reportable event does not include any of
the following:
(1) Any transfer of property to a for-
eign trust to the extent the transfer is a
transfer for fair market value within the
meaning of §1.679-4(b), provided that the
transfer is not one made by a U.S. per-
son that is a related person (as defined in
§1.679-1(c)(5)) with respect to the foreign
trust in exchange for an obligation of the
trust or of a related person (without regard
to whether such obligation is a qualified
obligation described in §1.679-4(d));
(2) Any transfer of property to a for-
eign trust described in section 402(b),
404(a)(4), or 404A; and
(3) Any transfer of property to a foreign
trust, provided that the trust has received
a determination letter from the Commis-
sioner that has not been revoked recogniz-

June 10, 2024 1668 Bulletin No. 2024–24
ing that the foreign trust is exempt from
Federal income tax under section 501(a)
as an organization described in section
501(c)(3).
(b) Exceptions for certain tax-favored
foreign trusts—(1) In general. Sections
6048(a) through 6048(c) and §§1.6048-2
through 1.6048-4 do not apply to any eli-
gible individual’s transactions with, or
ownership of, a tax-favored foreign retire-
ment trust as defined under paragraph (b)
(2) of this section or a tax-favored foreign
non-retirement savings trust as defined
under paragraph (b)(3) of this section. For
purposes of this paragraph (b)(1), an eligi-
ble individual means an individual who is,
or at any time was, a U.S. person and who,
for any period during which an amount of
tax may be assessed under section 6501
(without regard to section 6501(c)(8)),
is compliant (or comes into compliance)
with all requirements for filing a Federal
income tax return (or returns) covering the
period such individual was a U.S. person,
and to the extent required under U.S. tax
law, has reported as income any contribu-
tions to, earnings of, or distributions from
an applicable tax-favored foreign trust
on the applicable return (including on an
amended return).
(2) Tax-favored foreign retirement
trust. For purposes of this section, a
tax-favored foreign retirement trust means
a foreign trust that is created, organized,
or otherwise established under the laws
of a foreign jurisdiction (the trust’s juris-
diction) as a trust, plan, fund, scheme, or
other arrangement (collectively, a trust) to
operate exclusively or almost exclusively
to provide, or to earn income for the pro-
vision of, pension or retirement benefits
and ancillary or incidental benefits, and
that meets the following requirements
established by the laws of the jurisdiction
governing the trust:
(i) The trust generally is exempt from
income tax or otherwise is tax-favored
under the laws of the trust’s jurisdiction.
For purposes of this section, a trust is
tax-favored under the laws of the trust’s
jurisdiction if it meets any one or more of
the following conditions:
(A) Contributions to the trust that oth-
erwise would be subject to tax are deduct-
ible or excluded from income, are taxed
at a reduced rate, give rise to a tax credit,
or otherwise are eligible for another tax
benefit (such as a government subsidy or
contribution); or
(B) Taxation of investment income
earned by the trust is deferred until distri-
bution or the investment income is taxed
at a reduced rate (including exempt from
tax).
(ii) Annual information reporting with
respect to the trust (or of its participants or
beneficiaries) is provided, or otherwise is
available, to the relevant tax authorities in
the trust’s jurisdiction.
(iii) Generally, only contributions with
respect to income earned from the perfor-
mance of personal services are permitted
(with allowances made for limited con-
tributions made by unemployed individ-
uals).
(iv) The trust meets either the value
threshold in paragraph (b)(2)(iv)(1) or any
one of the contribution limitations in para-
graph (b)(2)(iv)(2) of this section:
(1) Value threshold. The aggregate
value of the trust(s) in the trust’s jurisdic-
tion is limited to no more than $600,000
at any point during the taxable year (as
adjusted under paragraph (b)(2)(iv)(3) of
this section) regardless of the number of
trusts established.
(2) Contribution limitations. The con-
tributions to the trust(s) in the trust’s juris-
diction are limited to any one of the fol-
lowing:
(i) A percentage of earned income of
the participant,
(ii) An annual limit of $75,000 (as
adjusted under paragraph (b)(2)(iv)(3) of
this section) or less, or
(iii) A lifetime limit of $1,000,000 (as
adjusted under paragraph (b)(2)(iv)(3) of
this section) or less.
(3) Dollar limitations subject to adjust-
ments—(i) The value threshold in para-
graph (b)(2)(iv)(1) and contribution limits
in paragraph (b)(2)(iv)(2) of this section
are determined using the U.S. Treasury
Bureau of Fiscal Service foreign currency
conversion rate on July 1 of the tax year
(available at https://fiscaldata.treasury.
gov/datasets/treasury-reporting-rates-ex-
change/treasury-reporting-rates-of-ex-
change).
(ii) In the case of calendar years begin-
ning on or after January 1, 2025, the
amounts under paragraph (b)(2)(iv)(1)
and paragraph (b)(2)(iv)(2) of this section
will be adjusted at the same time and in the
same manner as the amounts are adjusted
under section 415(d), except that the base
period will be the calendar quarter begin-
ning July 1, 2024.
(v) Withdrawals, distributions, or
payments from the trust are conditioned
upon reaching a specified retirement age,
disability, or death, or penalties apply to
withdrawals, distributions, or payments
made before such conditions are met. A
trust that otherwise meets the require-
ments of this paragraph (b)(2)(v), but that
allows withdrawals, distributions, or pay-
ments for in-service loans or for reasons
such as hardship, educational purposes, or
the purchase of a primary residence, will
be treated as meeting the requirements of
this paragraph.
(vi) In the case of an employer-main-
tained trust:
(A) The trust is nondiscriminatory
insofar as a wide range of employees,
including rank and file employees, must
be eligible to make or receive contribu-
tions or accrue benefits under the terms
of the trust (alone or in combination with
other comparable plans);
(B) The trust (alone or in combination
with other comparable plans) actually pro-
vides significant benefits for a substantial
majority of eligible employees; and
(C) The benefits actually provided
under the trust to eligible employees are
nondiscriminatory.
(3) Tax-favored foreign non-retirement
savings trust. For purposes of this section,
a tax-favored foreign non-retirement sav-
ings trust means a foreign trust that is cre-
ated, organized, or otherwise established
under the laws of a foreign jurisdiction
(the trust’s jurisdiction) as a trust, plan,
fund, scheme, or other arrangement (col-
lectively, a trust) to operate exclusively or
almost exclusively to provide, or to earn
income for the provision of, medical, dis-
ability, or educational benefits, and that
meets the following requirements estab-
lished by the laws of the trust’s jurisdic-
tion:
(i) The trust generally is exempt from
income tax or otherwise is tax-favored
under the laws of the trust’s jurisdiction
as defined in paragraph (b)(2)(i) of this
section.
(ii) Annual information reporting with
respect to the trust (or of its participants or
beneficiaries) is provided, or otherwise is

Bulletin No. 2024–24 1669 June 10, 2024
available, to the relevant tax authorities in
the trust’s jurisdiction.
(iii) Contributions to the trust are lim-
ited to $10,000 (multiplied by the cost-
of-living adjustment determined under
section 1(f)(3) for the calendar year by
substituting “calendar year 2020” for
“calendar year 2016” in section 1(f)(3)(A)
(ii) and rounding to the nearest multiple
of $1,000) or less annually, or $200,000
(multiplied by the cost-of-living adjust-
ment determined under section 1(f)(3) for
the calendar year by substituting “calen-
dar year 2020” for “calendar year 2016”
in section 1(f)(3)(A)(ii) and rounding to
the nearest multiple of $1,000) or less on
a lifetime basis, determined using the U.S.
Treasury Bureau of Fiscal Service foreign
currency conversion rate on the last day
of the tax year (available at https://fis-
caldata.treasury.gov/datasets/treasury-re-
porting-rates-exchange/treasury-report-
ing-rates-of-exchange).
(iv) Withdrawals, distributions, or
payments from the trust are conditioned
upon the provision of medical, disability,
or educational benefits, or apply penalties
to withdrawals, distributions, or payments
made before such conditions are met.
(4) Tax-favored foreign de minimis sav-
ings trusts. For purposes of this section,
a tax-favored foreign de minimis savings
trust means a foreign trust that is cre-
ated, organized, or otherwise established
under the laws of a foreign jurisdiction
(the trust’s jurisdiction) as a trust, plan,
fund, scheme, or other arrangement (col-
lectively, a trust) to operate as a savings
vehicle, that is not treated as a tax-favored
foreign retirement trust, as described in
paragraph (b)(2) or a tax-favored foreign
non-retirement savings trust, as described
in paragraph (b)(3), and that meets each of
the following requirements:
(i) The trust generally is exempt from
income tax or otherwise is tax-favored
under the laws of the trust’s jurisdiction
as defined in paragraph (b)(2)(i) of this
section;
(ii) Annual information reporting with
respect to the trust (or of its participants or
beneficiaries) is provided, or otherwise is
available, to the relevant tax authorities in
the trust’s jurisdiction pursuant to the laws
of the trust’s jurisdiction; and
(iii) The aggregate value of the trust(s)
in the trust’s jurisdiction is limited to no
more than $50,000 at any point during
the taxable year (multiplied by the cost-
of-living adjustment determined under
section 1(f)(3) for the calendar year by
substituting “[the year of the date of pub-
lication of the final regulations in the Fed-
eral Register]” for “calendar year 2016”
in section 1(f)(3)(A)(ii) and rounding to
the nearest multiple of $1,000) regard-
less of the number of trusts established.
The $50,000 is determined using the U.S.
Treasury Bureau of Fiscal Service foreign
currency conversion rate on the last day
of the tax year (available at https://fis-
caldata.treasury.gov/datasets/treasury-re-
porting-rates-exchange/treasury-report-
ing-rates-of-exchange).
(5) Certain rollovers and transfers.
A trust that otherwise meets the require-
ments of paragraphs (b)(2) or (b)(3) of
this section will not fail to be treated as a
tax-favored foreign retirement or non-re-
tirement savings trust within the meaning
of this paragraph (b) solely because it
may receive a rollover of assets or funds
transferred from another tax-favored for-
eign retirement or non-retirement savings
trust established and operated under the
laws of the same jurisdiction, provided
that the trust transferring assets or funds
also meets the requirements of this para-
graph (b)(2) or (b)(3), as applicable (but
this paragraph does not apply to transfers
between tax-favored retirement trusts and
non-retirement savings trusts).
(c) Exception for distributions from
certain foreign compensatory trusts. Sec-
tion 6048(c) does not apply to a distri-
bution received by a U.S. person from a
foreign trust described in §1.672(f)-3(c)
(1) provided that the U.S. person includes
in income any amounts accumulated on
behalf of, or distributed by the trust, to the
U.S. person to the extent such amounts are
required to be included in income (other
than amounts that are exempt from Fed-
eral income tax under a bilateral income
tax treaty or any other bilateral agreement
to which the United States is a party) of
the U.S. person, including pursuant to sec-
tion 409A(b).
(d) Exception for certain distributions
received by domestic section 501(c)(3)
organizations. Section 6048(c) does not
apply to a distribution from a foreign
trust received by a domestic organiza-
tion, provided that the organization has
received a determination letter from the
Commissioner that has not been revoked
recognizing that the domestic organiza-
tion is exempt from Federal income tax
under section 501(a) as an organization
described in section 501(c)(3).
(e) Exception for certain mirror code
possession trusts. Sections 6048(a)
through 6048(c) do not apply to a trust
located in a mirror code possession to
the extent the responsible party (within
the meaning of section 6048(a)(4)), U.S.
owner, or U.S. recipient is a bona fide
resident (within the meaning of §1.937-
1(b)) of such mirror code possession. For
purposes of this paragraph (e), a mirror
code possession is a possession of the
United States where, under the income
tax system of the possession, the income
tax liability of the residents of the pos-
session is determined by reference to the
income tax laws of the United States as
if the possession were the United States,
and a trust is located in a mirror code
possession if a court within the mirror
code possession is able to exercise pri-
mary supervision over the administration
of the trust and one or more bona fide res-
idents of the mirror code possession have
the authority to control all substantial
decisions of the trust.
§1.6048-6 Special rules.
(a) Special rules—(1) Dual resident
taxpayers. If a dual resident taxpayer
(within the meaning of §301.7701(b)-7(a)
(1) of this chapter) computes U.S. income
tax liability as a nonresident alien on the
last day of the taxable year and com-
plies with the filing requirements of
§301.7701(b)-7(b) and (c) of this chapter,
the dual resident taxpayer is not treated as
a U.S. person for purposes of section 6048
with respect to the portion of the taxable
year the dual resident taxpayer is treated
as a nonresident alien for purposes of
computing U.S. income tax liability.
(2) Dual status taxpayers. If a taxpayer
abandons U.S. citizenship or residence
during the taxable year or acquires U.S.
citizenship or residence during the tax-
able year as provided in §1.6012-1(b)(2)
(ii), the taxpayer will is not treated as a
U.S. person for purposes of §§1.6048-1
through 1.6048-7 with respect to the por-
tion of the taxable year the taxpayer was

June 10, 2024 1670 Bulletin No. 2024–24
treated as a nonresident alien for purposes
of computing U.S. income tax liability.
(b) Effect of ownership under the
grantor trust rules. The fact that a portion
of a foreign trust is treated as owned by the
grantor or another person under subpart E
of part I of subchapter J of chapter 1 of the
Internal Revenue Code is irrelevant for
purposes of determining whether a U.S.
person makes a transfer to, or receives a
distribution from, a foreign trust that must
be reported under §§1.6048-2 through
1.6048-4. See §1.6048-4(g)(13) and (14).
(c) [Reserved]
(d) Married U.S. persons filing a joint
income tax return. Married U.S. persons
who file a joint income tax return under
section 6013 for a tax year, and each of
whom is subject to the information report-
ing requirements under §§1.6048-2(a) (as
a grantor or transferor under §§1.6048-2(c)
(1) and (2) required to file Part I of Form
3520), 1.6048-3(a)(2) (as a U.S. owner of
a foreign trust required to file a substitute
Form 3520-A), or 1.6048-4(a) (as a U.S.
recipient of a distribution from a foreign
trust required to file Part III of Form 3520)
for the same foreign trust, may together
file a single Form 3520, Annual Return to
Report Transactions with Foreign Trusts
and Receipt of Certain Foreign Gifts, for
that year at the time and in the manner
described in §§1.6048-2 through 1.6048-
6. For purposes of filing a substitute Form
3520-A under §1.6048-3(a)(2), a separate
Foreign Grantor Trust Owner statement
must be completed and attached for each
married U.S. person. See §1.6677-1(f)
with respect to liability for penalties.
§1.6048-7 Applicability dates.
(a) In general. The rules of §§1.6048-1
through 1.6048-4 and §1.6048-6 apply as
follows:
(1) Section 1.6048-1 applies after the
[date of publication of the final regula-
tions in the Federal Register].
(2) To the extent related to §1.6048-
2, including the relevant portions of
§1.6048-6, the rules apply to reportable
events occurring after the [date of publica-
tion of the final regulations in the Federal
Register].
(3) To the extent related to §1.6048-
3, including the relevant portions of
§1.6048-6, the rules apply to taxable years
of U.S. persons beginning after the [date
of publication of the final regulations in
the Federal Register].
(4) To the extent related to §1.6048-4,
including the relevant portions of §1.6048-
6, the rules apply to distributions received
after the [date of publication of the final
regulations in the Federal Register].
(b) Special rule for §1.6048-5. Section
1.6048-5 applies as follows—
(1) To the extent related to reportable
events under section 6048(a) and the regu-
lations under section 6048 in this part, the
rules apply to reportable events occurring
after the [date that final regulations are
published in the Federal Register].
(2) To the extent related to ownership
of a foreign trust under section 6048(b)
and the regulations under section 6048 in
this part, the rules apply to taxable years
of U.S. owners beginning after the [date
that final regulations are published in the
Federal Register]; and
(3) To the extent related to distributions
from a foreign trust under section 6048(c)
and the regulations under section 6048 in
this part, the rules apply to distributions
received after the [date that final regula-
tions are published in the Federal Regis-
ter].
Par. 10. Section 1.6677-1 is added to
read as follows:
§1.6677-1 Failure to file information
with respect to certain foreign trusts.
(a) Civil penalty—(1) In general. In
addition to any criminal penalty pro-
vided by law, and subject to the rules of
paragraph (b) of this section (concerning
reporting required under §1.6048-3) and
the rules of paragraph (a)(3) of this sec-
tion (regarding the maximum penalty that
may be assessed), if any notice or return
required to be filed by §§1.6048-2 through
1.6048-4 is not timely filed, or contains
incomplete or incorrect information, then
with respect to each failure to comply with
§§1.6048-2 through 1.6048-4, the per-
son required to file such notice or return
must pay a penalty equal to the greater of
$10,000 or 35 percent of the gross report-
able amount (within the meaning of para-
graph (c) of this section).
(2) Penalty for continuing failure.
Subject to the rules of paragraph (a)(3)
of this section (regarding the maximum
penalty that may be assessed), if any
failure described in paragraph (a)(1) of
this section continues for more than 90
days after the day on which the Commis-
sioner mails notice of such failure to the
person required to pay the penalty, the
person must pay an additional penalty
(in addition to the amount determined
under paragraph (a)(1) of this section)
of $10,000 for each 30-day period (or
fraction thereof) during which the fail-
ure continues after the expiration of the
90-day period.
(3) Maximum penalty—(i) Limited to
gross reportable amount. At such time as
the gross reportable amount with respect
to any failure can be determined by the
Commissioner, the aggregate amount of
the penalties imposed under paragraphs
(a)(1) and (2) of this section will be
reduced as necessary to ensure that the
amount does not exceed the gross report-
able amount with respect to that failure
(and to the extent that the aggregate
amount already collected exceeds the
gross reportable amount, the Commis-
sioner will refund the excess amount pur-
suant to section 6402).
(ii) Period of limitations on refund of
excess amounts. The limitations period
provided for claims for refund under sec-
tion 6511(a) and (b) applies to the refund
of any excess amount.
(b) Special rules for returns under
§1.6048-3. In the case of a Form 3520-A
or a substitute Form 3520-A, including
attached statements, that are required to be
filed and furnished under §1.6048-3(a)—
(1) The U.S. person who is treated as
the owner of the foreign trust (or a por-
tion of the foreign trust) is liable for the
penalty imposed by paragraph (a) of this
section for the failure to comply with
§1.6048-3(a), and
(2) Paragraph (a) of this section is
applied by substituting “5 percent” for “35
percent.”
(c) Gross reportable amount—(1) In
general. For purposes of paragraph (a)
of this section, the term gross reportable
amount means—
(i) The gross value of the property
involved in the reportable event (deter-
mined as of the date of the event) in the
case of a failure relating to §1.6048-2,
(ii) The gross value of the portion of
the trust’s assets at the close of the trust’s

Bulletin No. 2024–24 1671 June 10, 2024
taxable year treated as owned by the U.S.
person in the case of each applicable fail-
ure relating to §1.6048-3, and
(iii) The gross amount of the distri-
bution in the case of a failure relating to
§1.6048-4.
(2) Gross value and gross amount. The
gross value or gross amount of property is
determined in accordance with the valua-
tion principles of sections 2512 and 2031
and the regulations under sections 2512
and 2031 in this part, though, in all events,
without regard to any taxes, expenses, lia-
bilities, or restrictions on the sale or use of
the property.
(d) Reasonable cause exception—(1)
In general. Paragraph (a) of this section
does not apply to any failure to file infor-
mation with respect to a foreign trust if the
person required to file such information
submits a reasonable cause statement to
the Commissioner under penalties of per-
jury and demonstrates to the satisfaction
of the Commissioner that the failure is due
to reasonable cause and not due to willful
neglect. The determination of whether a
taxpayer acted with reasonable cause and
not with willful neglect is made under
the principles set out in §1.6664-4 and
§301.6651-1(c) of this chapter. This deter-
mination is made on a case-by-case basis,
taking into account all pertinent facts and
circumstances.
(2) Examples of situations that do not
satisfy the reasonable cause exception.
Examples of facts that do not constitute
reasonable cause for purposes of this para-
graph (d) include but are not limited to the
following:
(i) The fact that a foreign jurisdiction
would impose a civil or criminal penalty
on such person (or any other person) for
disclosing the required information.
(ii) Refusal on the part of a foreign
trustee to provide information for any
reason, including difficulty in producing
the required information or the existence
of provisions in the trust instrument that
prevent the disclosure of required infor-
mation.
(e) Deficiency procedures do not apply.
Subchapter B of chapter 63 (relating to
deficiency procedures for income, estate,
gift, and certain excise taxes) does not
apply in respect of the assessment or col-
lection of any penalty imposed under this
section.
(f) Married U.S. persons filing a joint
income tax return—(1) In general. For
purposes of this section, married U.S. per-
sons who file one Form 3520 with respect
to the same foreign trust under §1.6048-
6(d) for a tax year are treated as if they are
a single U.S. person for that year.
(2) Anti-abuse rule. For purposes of
this section, the Commissioner may treat
married U.S. persons who file a joint
income tax return under section 6013 for
a tax year as a single U.S. person for that
year, unless the Commissioner determines
that, based on all the facts and circum-
stances, only one of the married individu-
als was subject to the information report-
ing requirement under §§1.6048-2 through
1.6048-4 (for example, because only one
spouse had an interest in the property con-
stituting the transfer to, or receipt from, a
foreign trust).
(3) Joint and several liability. If mar-
ried U.S. persons are treated as a single
U.S. person for a tax year, such married
U.S. persons have joint and several liabil-
ity with respect to any penalties imposed
under this section.
(g) Examples. The following examples
illustrate the rules of this section. In each
example, X is a U.S. person and FT is a
foreign trust.
(1) Example 1: Partial reporting. X transfers
property worth $100,000 to FT but reports only
$40,000 of that amount on Part I of Form 3520 pur-
suant to §1.6048-2. X does not demonstrate to the
satisfaction of the Commissioner that X’s failure
to report the correct amount was due to reasonable
cause and not due to willful neglect. Under para-
graph (a)(1) of this section, penalties will be imposed
only on the unreported $60,000.
(2) Example 2: Maximum penalty limited to
gross reportable amount. X receives a distribution
of $100,000 from FT in Year 1 but fails to report
the distribution as required by §1.6048-4(a). The
Commissioner learns about the distribution but does
not have enough information to determine the gross
reportable amount. On January 2, Year 4, the Com-
missioner mails a notice of the reporting failure to X
and assesses a penalty of $10,000 under paragraph
(a)(1) of this section. X does not comply with X’s
reporting requirement within 90 days after the day
that the Commissioner mails the notice (by April
2, Year 4), so the Commissioner begins to assess
additional penalties of $10,000 under paragraph (a)
(2) of this section for each 30-day period (or frac-
tion thereof), beginning on April 2, Year 4, during
which the failure continues. By the time X complies
with X’s reporting requirement, the aggregate pen-
alties assessed with respect to X’s failure to report
the distribution total $150,000. Under paragraph (a)
(3)(i) of this section, the maximum penalty that the
Commissioner may assess with respect to this failure
is $100,000 (the applicable gross reportable amount
determined under paragraph (c)(1)(iii) of this sec-
tion), and the Commissioner must abate the excess
$50,000 of assessed penalties.
(3) Example 3: Maximum penalty limited to gross
reportable amount below $10,000 minimum. Assume
the same facts as in Example 2 above except that
instead of a $100,000 distribution, X receives a dis-
tribution of $4,000 from FT. By the time X complies
with X’s reporting requirement, the aggregate pen-
alties assessed with respect to X’s failure to report
the distribution total $20,000. Under paragraph (a)
(3)(i) of this section, the maximum penalty that the
Commissioner may assess with respect to this failure
is $4,000 (the applicable gross reportable amount
determined under paragraph (c)(1)(iii) of this sec-
tion), and the Commissioner must abate the excess
$16,000 of assessed penalties.
(4) Example 4: Multiple failures over multiple
years. X created FT in Year 1 and is treated as the
owner of FT under the grantor trust rules. The trustee
of FT fails to file a Form 3520-A with respect to FT
for Year 2 and Year 3 as required by §1.6048-3(a)
(1), and X fails to file a substitute Form 3520-A and
a Form 3520 (as required by §1.6048-3(a)(2)) for
the same period. (In Year 4, X replaces the trustee,
and the new trustee files a Form 3520-A for Year 4.)
Under paragraphs (a)(1) and (b) of this section, X is
subject to one penalty for Year 2 and one penalty for
Year 3 for the failure to comply with §1.6048-3(a)(1)
and (a)(2) for those years.
(5) Example 5: Distribution from foreign-owned
grantor trust through an intermediary. Y, a nonresi-
dent alien, is treated as the owner of FT under sec-
tion 676, after the application of section 672(f). X
receives a distribution from FT through an interme-
diary as described in §1.6048-4(b)(2)(i). X does not
include the distribution in gross income and does not
report the distribution on Part III of Form 3520 as
required by §1.6048-4(a). Even if the Commissioner
determines that X was not required to include the
distribution in gross income, X is liable for penalties
imposed by paragraph (a)(1) of this section based
on the gross reportable amount determined under
paragraph (c)(1)(iii) of this section because X is
required to report indirect transfers of property under
§1.6048-4(b)(2)(iv).
(6) Example 6: Multiple failures in multiple
years. (i) Facts. On December 31, Year 1, X creates
FT and makes a gratuitous transfer of property with
a value of $100,000 to FT. X is treated as the sole
owner of FT under the grantor trust rules. During
Year 2, X makes no transfers to FT and receives no
distributions from FT. At the end of Year 2, the value
of FT’s assets is $110,000. During Year 3, X makes
no transfers to FT, but X receives a distribution of
$30,000. At the end of Year 3, the value of FT’s
assets is $85,000. X does not file any Forms 3520
or substitute Forms 3520-A for Year 1 through Year
3. The Trustee of FT does not file any Forms 3520-A
for Year 1 through Year 3.
(ii) Analysis–(A) Year 1. For Year 1, X is sub-
ject to two penalties under paragraphs (a)(1) and
(b) of this section: a $35,000 penalty (the greater of
$10,000 or $35,000 (35% of $100,000)) for failure
to comply with §1.6048-2(a) and a $10,000 penalty
(the greater of $10,000 or $5,000 (5% of $100,000))
for failure to comply with §1.6048-3(a). If X does

June 10, 2024 1672 Bulletin No. 2024–24
not comply with X’s reporting requirements for Year
1 within 90 days after the day on which the Com-
missioner mails notice of the reporting failures to X,
X will be subject to additional penalties under para-
graph (a)(2) of this section of $10,000 per failure per
30-day period (or fraction thereof) ($20,000 in the
aggregate per 30-day period (or fraction thereof))
during which the failure continues. Under paragraph
(a)(3)(i) of this section, the aggregate amount of the
penalty imposed under paragraphs (a)(1) and (2)
of this section with respect to each failure will not
exceed the gross reportable amount for that failure.
(B) Year 2. For Year 2, X is subject to one pen-
alty under paragraphs (a)(1) and (b) of this sec-
tion: a $10,000 penalty (the greater of $10,000 or
$5,500 (5% of $110,000)) for failure to comply with
§1.6048-3(a). If X does not comply with X’s report-
ing requirements for Year 2 within 90 days after the
day on which the Commissioner mails notice of the
reporting failures to X, X will be subject to addi-
tional penalties under paragraph (a)(2) of this section
of $10,000 per failure per 30-day period (or fraction
thereof) ($10,000 per 30-day period (or fraction
thereof)) during which the failure continues. Under
paragraph (a)(3)(i) of this section, the aggregate
amount of the penalty imposed under paragraphs (a)
(1) and (2) of this section with respect to each failure
will not exceed the gross reportable amount for that
failure.
(C) Year 3. For Year 3, X is subject to two pen-
alties under paragraphs (a)(1) and (b) of this sec-
tion: a $10,000 penalty (the greater of $10,000 or
4,250 (5% of $85,000)) for failure to comply with
§1.6048-3(a), and a penalty of $10,500 (the greater
of $10,000 or $10,500 (35% of $30,000)) for fail-
ure to comply with §1.6048-4. If X does not comply
with X’s reporting requirements for Year 3 within 90
days after the day on which the Commissioner mails
notice of the reporting failures to X, X will be sub-
ject to additional penalties under paragraph (a)(2) of
this section of $10,000 per failure per 30-day period
(or fraction thereof) ($20,000 in the aggregate per
30-day period (or fraction thereof)) during which the
failure continues. Under paragraph (a)(3)(i) of this
section, the aggregate amount of the penalty imposed
under paragraphs (a)(1) and (2) of this section with
respect to each failure will not exceed the gross
reportable amount for that failure.
(iii) Conclusion. X is subject to aggregate pen-
alties of $75,500 under paragraphs (a)(1) and (b) of
this section: $45,000 for Year 1, $10,000 for Year 2,
and $20,500 for Year 3. X may be subject to addi-
tional penalties under paragraph (a)(2) of this section
if X fails to comply with X’s reporting requirements
within 90 days after the day on which the Commis-
sioner mails notice of each failure to X. Under para-
graph (a)(3)(i) of this section, the aggregate amount
of the penalty imposed under paragraphs (a)(1) and
(2) of this section with respect to each failure will not
exceed the gross reportable amount for that failure.
(7) Example 7: Interaction with §1.6039F-1. In
Year 1, X receives $500,000 from FT that X treats as
a gift. Under §1.6048-4(d) and §1.6039F-1(b), X is
required to report the amount as a distribution under
§1.6048-4 and not as a foreign gift under §1.6039F-
1(a). However, based on the advice of X’s tax advi-
sor, X reports the distribution under §1.6039F-1(a)
and not under §1.6048-4. X’s failure to report the
distribution under §1.6048-4 is subject to penalties
under §1.6677-1(a) unless X demonstrates to the sat-
isfaction of the Commissioner that such failure is due
to reasonable cause and not due to willful neglect.
The fact that X reported the distribution under
§1.6039F-1(a) based on the advice of X’s tax advisor
is a factor that may be taken into account in deter-
mining whether X’s failure to report the distribution
under §1.6048-4 was due to reasonable cause. X’s
reliance on X’s tax advisor’s advice can only con-
stitute reasonable cause, however, if, under all the
circumstances, the reliance was reasonable within
the meaning of §1.6664-4(c).
(8) Example 8: Presumption that FT has a
U.S. owner. X created FT in Year 1 and transferred
$100,000 to FT. X reported the transfer to FT on
Part I of Form 3520 for Year 1, but did not com-
plete the other parts of Form 3520. X did not file
any Forms 3520 with respect to FT in Year 2 or sub-
sequent years. FT has not filed any Forms 3520-A
with respect to FT (and X has not filed any substi-
tute Forms 3520-A). Pursuant to §1.679-2(d)(2), the
Commissioner sends a written notice to X requesting
additional information related to the trust and its
potential beneficiaries. X does not respond. Under
§1.679-2(d)(1), FT is treated as having a U.S. benefi-
ciary. Under §1.679-1(a), X is treated as the owner of
FT. Under paragraphs (a) and (b) of this section, X is
subject to penalties for Year 1 and subsequent years
for failure to comply with §1.6048-3(a).
(9) Example 9: Penalty for failure to report loan
that is not treated as a section 643(i) distribution.
FT is not treated as being owned by X or any other
person under the grantor trust rules. X receives a
loan of cash from FT and in exchange issues an
obligation to FT that is a qualified obligation within
the meaning of §1.643(i)-2(b)(2)(iii). Provided the
obligation does not cease to be a qualified obliga-
tion, the loan will not be a section 643(i) distribu-
tion under §1.643(i)-1(a) and therefore will not be
taxable to X. However, the loan is a distribution
within the meaning of §1.6048-4(b)(3) that must be
reported on Part III of Form 3520 under §1.6048-
4(a). X fails to report the loan. X is subject to pen-
alties under §1.6677-1(a) unless X demonstrates
to the satisfaction of the Commissioner that such
failure is due to reasonable cause and not due to
willful neglect.
(10) Example 10: Joint and several penalties.
X and Y are married U.S. persons who file a joint
income tax return under section 6013. In Year 1, X
and Y create FT and fund the trust with $100,000 for
the benefit of their U.S. children. X and Y jointly file
their income tax return for the Year 1 tax year but fail
to file a Form 3520 reporting the transfer of assets
to a foreign trust pursuant to §1.6048-2. In addition,
FT has not filed any Forms 3520-A with respect to
FT (and X and Y have not filed any substitute Forms
3520-A) pursuant to §1.6048-3(a). For the Year 1 tax
year, X and Y are jointly and severally liable for pen-
alties under paragraph (a) of this section pursuant to
paragraph (f)(2) and (3) of this section.
(h) Applicability dates—(1) Reportable
events. To the extent related to §1.6048-2,
this section applies to reportable events
occurring after the [date of publication of
the final regulations in the Federal Reg-
ister].
(2) U.S owners of foreign trusts. To the
extent related to §1.6048-3, this section
applies to taxable years of U.S. persons
beginning after the [date of publication of
the final regulations in the Federal Reg-
ister].
(3) Reporting by U.S. persons receiv-
ing distributions from foreign trusts. To
the extent related to §1.6048-4, this sec-
tion applies to distributions received after
the [date of publication of the final regula-
tions in the Federal Register].
Douglas W. O’Donnell,
Deputy Commissioner
(Filed by the Office of the Federal Register May 7,
2024, 8:45 a.m., and published in the issue of the
Federal Register for May 8, 2024, 89 FR 39440)

Bulletin No. 2024–24 1673 June 10, 2024
Part IV
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2024-22
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 continue
to be deductible. Protection under section
7428(c) would begin on June 10, 2024 and
would end on the date the court first deter-
mines 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 pro-
tected is $1,000, with a husband and wife
treated as one contributor. This benefit is
not extended to any individual, in whole
or in part, for the acts or omissions of the
organization that were the basis for revo-
cation.
Name Of OrganizationEffective Date of RevocationLocation
Love Louder1/1/2021Catawba, VA
Best Florida Beer, Inc.1/1/2018Clearwater, FL

June 10, 2024 1674 Bulletin No. 2024–24
Deletions From Cumulative
List of Organizations,
Contributions to Which are
Deductible Under Section
170 of the Code
Announcement 2024-23
The Internal Revenue Service has
revoked its determination that the organi-
zation listed below qualifies as an organi-
zation 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 January
1, 2018 and would end on the date the
court first determines the organization is
not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a 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.
The Following organization is no lon-
ger qualified as an organization exempt
from income tax under Internal Revenue
Code (the “Code”) Section 501(a) as an
organization described in Section 501(c)
(3) of the Code:
NAME OF ORGANIZATIONEFFECTIVE DATE OF REVOCATIONLOCATION
FUNCTIONAL HEALTH INC.1/1/2018ATLANTA GA

Bulletin No. 2024–24 1675 June 10, 2024
Updated Reference
Standard 90.1 for § 179D
Announcement 2024-24
This announcement notifies taxpayers
of the applicable Reference Standard 90.1
required under § 179D(c)(2) of the Internal
Revenue Code (Code) as part of the defini-
tion of energy efficient commercial build-
ing property (EECBP). This announcement
supplements and supersedes Announce-
ment 2023-1, 2023-3 I.R.B. 422 (2023), by
affirming ASHRAE/IES Reference Stan-
dard 90.1-2022 (Reference Standard 90.1-
2022) as the applicable Reference Standard
90.1 for EECBP placed in service after
December 31, 2028, and the construction
of which did not begin by December 31,
2022. The effective date of this announce-
ment is May 17, 2024.
Section 179D provides a deduction
for the cost of EECBP placed in service
during the taxable year. Section 179D(c)
(1) defines EECBP as property (A) with
respect to which depreciation (or amor-
tization in lieu of depreciation) is allow-
able, (B) which is installed on or in any
building located in the United States and
within the scope of Reference Standard
90.1, (C) which is installed as part of (i)
the interior lighting systems, (ii) the heat-
ing, cooling, ventilation, and hot water
systems, or (iii) the building envelope, and
(D) which is certified in accordance with
§ 179D(d)(5) as being installed as part of
a plan designed to reduce the total annual
energy and power costs with respect to the
interior lighting systems, heating, cooling,
ventilation, and hot water systems of the
building by 25 percent or more in com-
parison to a reference building that meets
the minimum requirements of Reference
Standard 90.1 using methods of calcula-
tion under § 179D(d)(1).
Since § 179D was enacted in 2005,
§ 179D(c)(2) has provided as the applica-
ble reference standard for EECBP a version
of Reference Standard 90.1 as published by
the American Society of Heating, Refrig-
erating, and Air Conditioning Engineers
(ASHRAE) and the Illuminating Engineer-
ing Society of North America (IES). For
EECBP placed in service before January
1, 2015, Reference Standard 90.1-2001
applied. For EECBP placed in service after
December 31, 2014, and before January
1, 2021, Reference Standard 90.1-2007
applied. For EECBP placed in service
after December 31, 2020, § 179D(c)(2),
as amended by the Taxpayer Certainty and
Disaster Relief Act of 2020, defined “Refer-
ence Standard 90.1” to mean, with respect to
any property, the most recent Standard 90.1
published by the ASHRAE and the IES that
has been affirmed by the Secretary of the
Treasury or her delegate (Secretary), after
consultation with the Secretary of Energy,
for purposes of § 179D not later than the
date that is 2 years before the date that
construction of such property begins. This
statutory amendment changed the reference
date for application of Reference Standard
90.1 from the placed in service date to the
beginning of construction date.
Section 13303 of Public Law 117-169,
136 Stat. 1818, 1947 (August 16, 2022),
commonly known as the Inflation Reduc-
tion Act of 2022 (IRA), amended § 179D
for taxable years beginning after Decem-
ber 31, 2022. This amendment returned
the reference date for application of Refer-
ence Standard 90.1 to the date the EECBP
is placed in service. Section 179D(c)(2),
as amended, defines the term “Reference
Standard 90.1” as meaning, with respect
to any property, the more recent of:
(A) Standard 90.1-2007 published by
the ASHRAE and the IES, or
(B) The most recent Standard 90.1 pub-
lished by the ASHRAE and the IES for
which the Department of Energy (DOE)
has issued a final determination and which
has been affirmed by the Secretary, after
consultation with the Secretary of Energy,
for purposes of § 179D not later than the
date that is 4 years before the date such
property is placed in service.
For EECBP placed in service after
December 31, 2026, and for which con-
struction began after December 31, 2022,
Reference Standard 90.1-2019 applies.
1
On March 6, 2024, the DOE deter-
mined that the updated edition Refer-
ence Standard 90.1-2022
2
would improve
energy efficiency in commercial build-
ings. Upon publication of this affirmative
determination, each State is required to
review the provisions of its commercial
building code regarding energy efficiency,
and, as necessary, update its codes to meet
or exceed Reference Standard 90.1-2022
not later than 2 years from March 6, 2024.
The Secretary, after consultation with
the Secretary of Energy, hereby affirms
Reference Standard 90.1-2022 as the appli-
cable Reference Standard 90.1 for purposes
of calculating the annual energy and power
consumption and costs with respect to the
interior lighting systems, heating, cooling,
ventilation, and hot water systems of the
reference building as follows: Reference
Standard 90.1-2022 will be the applicable
standard for EECBP that is placed in ser-
vice after December 31, 2028. Taxpayers
for whose EECBP construction began by
December 31, 2022, or who already placed
EECBP in service or will place EECBP in
service by December 31, 2028, are not sub-
ject to Reference Standard 90.1-2022. The
table below provides the applicable Refer-
ence Standard 90.1 based on the date the
EECBP is placed in service. Taxpayers for
whose EECBP construction began before
January 1, 2023, may apply Reference
Standard 90.1-2007 regardless of when the
EECBP is placed in service.
1
See Announcement 2023-1.
2
Final Determination Regarding Energy Efficiency Improvement in ANSI/ASHRAE/IES Standard 90.1-2022, 89 FR 15983 (March 6, 2024).
Date EECBP Placed in ServiceApplicable Reference Standard 90.1
Before 1/1/2015Reference Standard 90.1-2001
After 12/31/2014 and before 1/1/2027Reference Standard 90.1-2007
After 12/31/2026 and before 1/1/2029Reference Standard 90.1-2019
After 12/31/2028Reference Standard 90.1-2022

June 10, 2024 1676 Bulletin No. 2024–24
The principal author of this announce-
ment is the Office of Associate Chief
Counsel (Passthroughs & Special Indus-
tries). However, other personnel from the
Treasury Department and the IRS par-
ticipated in its development. For further
information regarding this announcement,
call the energy security guidance contact
number at (202) 317-5254 (not a toll-free
number).

Bulletin No. 2024–24 i June 10, 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.

June 10, 2024 ii Bulletin No. 2024–24
Numerical Finding List
1
Bulletin 2024–24
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
2024-15, 2024-15 I.R.B. 876
2024-16, 2024-16 I.R.B. 909
2024-17, 2024-16 I.R.B. 932
2024-19, 2024-17 I.R.B. 950
2024-20, 2024-19 I.R.B. 1069
2024-18, 2024-21 I.R.B. 1234
2024-21, 2024-21 I.R.B. 1236
2024-22, 2024-24 I.R.B. 1673
2024-23, 2024-24 I.R.B. 1674
2024-24, 2024-24 I.R.B. 1675
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
2024-28, 2024-13 I.R.B. 720
2024-29, 2024-14 I.R.B. 751
2024-31, 2024-15 I.R.B. 869
Notices:—Continued
2024-30, 2024-16 I.R.B. 878
2024-32, 2024-16 I.R.B. 897
2024-33, 2024-18 I.R.B. 959
2024-34, 2024-18 I.R.B. 960
2024-35, 2024-19 I.R.B. 1051
2024-37, 2024-21 I.R.B. 1191
2024-38, 2024-21 I.R.B. 1211
2024-36, 2024-24 I.R.B. 1479
2024-39, 2024-24 I.R.B. 1611
2024-40, 2024-24 I.R.B. 1612
2024-41, 2024-24 I.R.B. 1615
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
REG-101552-24, 2024-13 I.R.B. 741
REG-117631-23, 2024-14 I.R.B. 754
REG-108761-22, 2024-16 I.R.B. 933
REG-117542-22, 2024-16 I.R.B. 942
REG-123379-22, 2024-16 I.R.B. 952
REG-115710-22, 2024-20 I.R.B. 1070
REG-118499-23, 2024-20 I.R.B. 1167
REG-117631-23, 2024-21 I.R.B. 1237
REG-124850-08, 2024-24 I.R.B. 1624
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
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
2024-11, 2024-13 I.R.B. 721
2024-17, 2024-15 I.R.B. 873
2024-18, 2024-15 I.R.B. 874
2024-19, 2024-16 I.R.B. 899
2024-20, 2024-19 I.R.B. 1053
2024-21, 2024-19 I.R.B. 1054
2024-24, 2024-21 I.R.B. 1214
2024-22, 2024-22 I.R.B. 1332
2024-25, 2024-22 I.R.B. 1333
2024-23, 2024-23 I.R.B. 1334
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
Revenue Rulings:—Continued
2024-4, 2024-10 I.R.B. 686
2024-6, 2024-10 I.R.B. 688
2024-7, 2024-14 I.R.B. 749
2024-8, 2024-16 I.R.B. 877
2024-9, 2024-19 I.R.B. 964
2024-10, 2024-22 I.R.B. 1240
2024-11, 2024-24 I.R.B. 1459
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
9988, 2024-15 I.R.B. 794
9989, 2024-15 I.R.B. 850
9990, 2024-19 I.R.B. 966
9992, 2024-21 I.R.B. 1175
9995, 2024-22 I.R.B. 1241
9996, 2024-22 I.R.B. 1317
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. 2024–24 iii June 10, 2024
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2024–24
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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