SubscribeCheck out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2024.
December 16, 2024: The IRS released Internal Revenue Bulletin 2024-51, which includes the following:
- Treasury Decision 10009, which provides guidance regarding the advanced manufacturing investment credit under § 48D of the Internal Revenue Code (Code). The guidance reflects changes made by the CHIPS Act of 2022. The § 48D credit may be claimed for qualified investments in an advanced manufacturing facility that engages in the manufacturing of semiconductors or semiconductor manufacturing equipment.
- Treasury Decision 10010, which provides the rules for claiming the Advanced Manufacturing Production Credit under Code § 45X. The regulations describe the requirements for the production of eligible components, including the domestic production requirement. The regulations also provide rules regarding the sale of eligible components to unrelated persons, as well as rules that apply to sales between related persons. They include definitions of eligible components, rules related to calculating the credit, and specific recordkeeping and reporting requirements.
- Treasury Decision 10014, which finalizes 2013 proposed regulations under Code § 752, which relates to a partner’s share of a partnership recourse liability. The final regulations adopt a proportionality rule in instances where more than one partner bears the economic risk of loss of the partnership recourse debt. The regulations also provide guidance regarding how partnership recourse debt should be allocated in tiered partnership structures, as well as guidance on the related-party rules. Interestingly, no new notice of proposed rulemaking or opportunity for public comment was provided regarding these regulations in the 11 years since the 2013 proposed regulations were issued.
- Revenue Ruling 2024-27, which publishes the base period T-bill rate for the period ending September 30, 2024, pursuant to Code § 995(f). The rate for this period is 4.93%.
The IRS also released Notice 2025-1, which provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under § 417(e)(3), the 24-month average segment rates used under § 430(h)(2), the interest 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) of the Code.
The IRS also issued Revenue Ruling 2025-1, which provides the January 2025 applicable federal rates for purposes of Code § 1274(d) and relates to the determination of issue price in the case of certain instruments issued for property.
December 17, 2024: The IRS issued Revenue Procedure 2025-8, which modifies the procedures under Code § 446 and Treasury Regulation § 1.446-1(e) for obtaining automatic consent of the Commissioner of Internal Revenue (Commissioner) to change methods of accounting for expenditures paid or incurred in taxable years beginning after December 31, 2021, to comply with § 174 or to rely on interim guidance provided in Notice 2023-63, 2023-39 I.R.B. 919, as modified by Notice 2024-12, 2024-5 I.R.B. 616.
December 18, 2024: In Notice 2025-4 the [...]
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