Welcome to the inaugural edition of the IRS Bulletin Notes, where we break down the latest IRS updates into bite-sized, easy-to-digest summaries. Our goal is to save you time and keep you informed about the most important updates and changes in the tax world. Let's dive into IRS Bulletin No. 2024-22 and highlight the key takeaways for tax professionals.
HIGHLIGHTS OF INTERNAL REVENUE BULLETIN 2024-22
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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
Rev. Proc. 2024-25, IRB page 1333.
This revenue procedure provides the 2025 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under § 223 of the Internal Revenue Code and the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements (HRAs) provided under § 54.9831-1(c)(3)(viii) of the Pension Excise Tax Regulations.
ADMINISTRATIVE, INCOME TAX
T.D. 9995, IRB page 1241
These final regulations provide guidance regarding general provisions and special rules for §§ 25E and 30D, as well as rules related to the Critical Minerals and Battery Components Requirements of section 30D(e). Furthermore, these final regulations provide guidance for elections to transfer clean vehicle credits under §§ 25E(f) and 30D(g). These final regulations provide guidance to qualified manufacturers of new clean vehicles to comply with rules regarding foreign entities of concern (FEOC) and excluded entities. These final regulations provide guidance for qualified manufacturers of new clean vehicles to comply with rules to determine if the battery components and applicable critical minerals contained in a vehicle battery satisfy the requirements of § 30D(d)(7) and are FEOC-compliant. Finally, the final regulations also define the omission of a correct vehicle identification number for purposes of § 6213.
ESTATE TAX, GIFT TAX
T.D. 9996, IRB page 1317.
These final regulations provide guidance under section 2642(g) describing the circumstances and procedures under which an extension of time will be granted by the Internal Revenue Service (IRS) to make certain allocations and elections related to the generation-skipping transfer (GST) tax. Since the enactment of section 2642(g) in 2001, the IRS has granted relief for such allocations and elections under the regulatory authority of section 301.9100-1 through the private letter ruling program. To reduce taxpayers’ compliance burden attendant to requesting relief under section 301.9100-1, the final regulations set forth nonexclusive factors that the IRS will consider in determining whether a transferor, or the executor of a transferor’s estate, has met the standards of reasonableness, good faith, and lack of prejudice to the interests of the Government so that the IRS may grant relief. Henceforward, taxpayers requesting relief for certain allocations and elections related to the GST tax must seek relief under section 2642(g) and cannot obtain relief under section 301.9100-1.
EXEMPT ORGANIZATIONS
Rev. Proc. 2024-22, IRB page 1332.
This revenue procedure obsoletes Rev. Proc. 82-2, 1982-1 C.B. 367, which identified the circumstances in which an organization could satisfy § 1.501(c)(3)-1(b)(4) (requiring that the assets of a section 501(c)(3) organization be dedicated to an exempt purpose) by operation of the law of certain States or the District of Columbia. Due to material changes in the law of many jurisdictions since 1982, the jurisdictional list set forth in Rev. Proc. 82-2 is no longer accurate.
Rev. Rul. 2024-10, IRB page 1240.
This revenue ruling obsoletes Rev. Rul. 75-38, 1975-1 C.B. 161, which identified the District of Columbia and each State with statutory provisions that, in 1975, satisfied the private foundation governing instrument requirements of section 508(e). Due to material changes in the laws of several jurisdictions since 1975, the jurisdictional list set forth in Rev. Rul. 75-38 is no longer accurate.