SubscribeCheck out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15, 2024 – April 19, 2024.
April 15, 2024: The IRS released Internal Revenue Bulletin 2024-16, which includes the following:
- Announcement 2024-16, which describes the experience, structure and activities of the Advance Pricing and Mutual Agreement Program during calendar year 2023.
- Proposed regulations, which would revise regulations pertaining to the advance notice provided to taxpayers before the IRS contacts third parties. These proposed regulations are intended to conform to the new statutory language of Section 7602(c) of the Internal Revenue Code (Code), enacted as part of the Taxpayer First Act of 2019, and provide exceptions to the 45-day advance notice requirement where delaying contact with third parties for 45 days after providing notice to the taxpayer would impair tax administration.
- Announcement 2024-17, which contains corrections to proposed regulations under Code Sections 761 and 6417 that address certain electricity production credits.
- Notice 2024-30, which expands the Nameplate Capacity Attribution Rule under Section 4.02(1)(b) of Notice 2023-29 to include additional attribution property. The notice also adds two 2017 North American Industry Classification System industry codes to the table in Section 3.03(2) of Notice 2023-29, which are relevant for purposes of determining the Fossil Fuel Employment rate (as defined in Section 3.03(2) of Notice 2023-29).
- Notice 2024-32, which addresses the eligibility of loan borrowers through State Supplemental Loan programs and the loan size limitation for State Supplemental Loans. The notice also provides guidance on whether an issue of state or local bonds, the proceeds of which are used to finance or refinance qualified student loans or to finance qualified mortgage loans, is a refunding issue.
- Proposed regulations, which would identify certain charitable remainder annuity trust transactions and substantially similar transactions as listed transactions. Material advisors and certain participants in these listed transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
- Revenue Procedure 2024-19, which provides the process under Code Section 48(e) to apply for an allocation of environmental justice solar and wind capacity limitation as part of the low-income communities bonus credit program for 2024. The revenue procedure also describes how the capacity limitation for the 2024 program year will be divided across the facility categories described in Sections 48(e)(2)(A)(iii) and 1.48(e)-1(b)(2), the Category 1 sub-reservation described in Section 1.48(e)-1(i)(1) and the additional selection criteria application options described in Section 1.48(e)-1(h).
- Revenue Ruling 2024-8, which provides the terminal charge and Standard Industry Faire Level mileage rates used for valuing noncommercial flights on employer-provided aircraft.
April 15, 2024: The IRS announced it has answered over one million more taxpayer phone calls this tax season, helped over 170,000 more people in person and saw 75 million more IRS.gov visits [...]
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