In this release of IRS Internal Revenue Bulletin 2024-52, explore essential updates on tax reform, employee plans, and energy credit regulations. Learn more about these changes and their implications.
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The Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.
ADMINISTRATIVE
AOD 2024-1, page 1354.
Acquiescence to the holding that notices that identify certain arrangements as reportable transactions, issued without following notice-and-comment rulemaking procedures after the American Jobs Creation Act of 2004, are invalid under the Administrative Procedure Act.
ADMINISTRATIVE, INCOME
TAX Rev. Proc. 2024-44, page 1438.
This proposed revenue procedure specifies when information shown on a return in accordance with the applicable forms and instructions will be an adequate disclosure for purposes of reducing an understatement of income tax under section 6662(d) and for purposes of avoiding the section 6694(a) preparer penalty. This revenue procedure updates Rev. Proc. 2023-40, 2023-51 I.R.B. 1553, and applies to any income tax return filed on 2024 tax forms for a taxable year beginning in 2024, and to any income tax return filed in 2025 on 2024 tax forms for short taxable years beginning in 2025.
EMPLOYEE PLANS
Notice 2024-82, page 1425.
This notice sets forth the 2024 Required Amendments List (2024 RA List). The 2024 RA List applies to individually designed plans qualified under section 401(a) of the Internal Revenue Code and individually designed plans that satisfy the requirements of section 403(b). The 2024 RA List also applies to pre-approved plans with respect to interim amendments.
Notice 2024-86, page 1429.
In order to ensure that plans, participants, beneficiaries, qualified beneficiaries, and claimants in disaster areas are not fur ther adversely affected by Hurricane Helene, Tropical Storm Helene, and Hurricane Milton with respect to their employee benefit plans, certain timeframes are extended during the Relief Period established by this document. This document is jointly issued by the Departments of Labor and the Treasury, through the Employee Benefits Security Administration and the Internal Revenue Service, respectively, under section 518 of ERISA and section 7508A(b) of the Code.
EMPLOYMENT TAX
REG-106595-22, page 1444.
These proposed regulations relate to the definition of qualified nonpersonal use vehicles. Qualified nonpersonal use vehicles are excepted from the substantiation requirements that apply to certain listed property. These proposed regulations add unmarked vehicles used by firefighters or members of a rescue squad or ambulance crew as a new type of qualified nonpersonal use vehicle. These regulations affect governmental units that provide firefighter or rescue squad or ambulance crew member employees with unmarked qualified nonpersonal use vehicles and the employees who use those vehicles.
INCOME TAX
T.D. 10015, page 1355.
Section 48 provides an investment tax credit for energy property (energy credit). These final regulations update the regulations under section 48 to reflect changes to that section since 1987, mostly notably changes made by the Inflation Reduction Act of 2022 (IRA). Generally, in connection with the IRA, the final regulations update the types of energy property eligible for the energy credit, including additional types of energy property added by the IRA; clarify the application of new credit transfer rules to recapture due to failure to satisfy the prevailing wage requirements, including notification requirements for eligible taxpayers; and include qualified interconnection costs in the basis of certain lower-output energy properties. The final regulations also provide rules generally applicable to energy property, such as rules regarding: functionally interdependent components; property that is an integral part of an energy property; application of the “80/20 Rule” to retrofitted energy property; dual use property; ownership of components of an energy property; energy property that may be eligible for multiple Federal income tax credits; and the election to treat qualified facilities eligible for the renewable electricity production credit under section 45 instead as property eligible for the energy credit.
INCOME TAX, TAX CONVENTIONS
Rev. Proc. 2024-42, page 1433.
This revenue procedure updates and supersedes the lists of countries in Rev. Proc. 2023-36. Armenia and Uruguay are added to the list of jurisdictions with which the United States has in effect a relevant information exchange agreement. Costa Rica and Thailand are added to the list of countries with which Treasury and the IRS have determined it is appropriate to have an automatic exchange relationship with respect to the information collected under Treas. Reg. §§ 1.6049-4(b)(5) and 1.6049-8(a).
TAX CONVENTIONS
Announcement 2024-42, page 1443.
The competent authorities of the United States and the Kingdom of Norway have entered a Competent Authority Arrangement under paragraph 2 of Article 27 (Mutual Agreement Procedure) of the Convention between the United States of America and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Property in which the competent authorities confirm that Article 20 (Investment or Holding Companies) is not applicable to a U.S. investment company that qualifies as a Regulated Investment Company pursuant to sections 851 (Definition of regulated investment company) and 852 (Taxation of regulated investment companies and their shareholders) of the Internal Revenue Code.