This notice addresses the availability of administrative exemptions from and waivers of the requirements to file returns and other documents in electronic form. This notice provides information about publications pertaining to failed attempts to electronically file Forms 1120, 1120-S, and 1120-F using Internal Revenue Service (IRS) filing systems. In addition, this notice obsoletes Notice 2010-13, 2010-4 I.R.B. 327 (January 25, 2010), Form 1120, Form 1120-F, Form 1120S, Form 990, and Form 990-PF Electronic Filing Waiver Request Procedures. This notice also modifies Notice 2023-60 as released on August 11, 2023, but not published in the Internal Revenue Bulletin.

This notice provides relief from certain penalties imposed solely for failure of a partnership with unrealized receivables or inventory items to furnish Part IV of Form 8308, Report of a Sale or Exchange of Certain Partnership Interests, by January 31, 2024, to the transferor and transferee in certain transfers of partnership interests that occurred in calendar year 2023.

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 deductible under IRC 170(b)(1)(A).

These regulations specify the methodology for constructing the corporate bond yield curve that is used to derive the interest rates used in calculating present value and making other calculations under a defined benefit plan, as well as for discounting unpaid losses and estimated salvage recoverable of insurance companies.

26 CFR 1.430(h)(2)-1

This document finalizes rules related to the fees established by the No Surprises Act for the Federal independent dispute resolution (IDR) process, as established by the Consolidated Appropriations Act, 2021 (CAA). These final rules amend existing regulations to provide that the administrative fee amount charged by the Department of the Treasury, the Department of Labor, and the Department of Health and Human Services (the Departments) to participate in the Federal IDR process, and the ranges for certified IDR entity fees for single and batched determinations, will be set by the Departments through notice and comment rulemaking. The preamble to these final rules also sets forth the methodology used to calculate the administrative fee and the considerations used to develop the certified IDR entity fee ranges. This document also finalizes the amount of the administrative fee for disputes initiated on or after the effective date of these rules. Finally, this document finalizes the certified IDR entity fee ranges for disputes initiated on or after the effective date of these rules.

(26 CFR 54.9816-8 Independent dispute resolution process; 26 CFR 54.9816-8T Independent dispute resolution process (temporary))

This notice announces that Treasury and the IRS intend to issue proposed regulations that will address certain basis consequences of internal restructuring transactions in which a U.S. corporation acquires stock of a controlled foreign corporation (“CFC”) from another CFC. In particular, the notice announces rules under which basis provided under section 961(c) in stock of a second-tier CFC held by a first-tier CFC will be transferred to a U.S. corporation that acquires the second-tier CFC from the first-tier CFC in a liquidation described in section 332 or an asset reorganization described in section 368(a)(1).

Notice 2024-12 clarifies and modifies Notice 2023-63, which provided interim guidance to address issues regarding specified research or experimental expenditures under § 174. Specifically, Notice 2024-12 clarifies and modifies Notice 2023-63 regarding (1) the treatment of costs paid or incurred by a research provider for research performed under contract, (2) the requirement that a taxpayer that chooses to rely on any of the rules described in Notice 2023-63 must rely on all the rules described in sections 3 through 9 of the notice, and (3) the obsoletion of section 5 of Revenue Procedure 2000-50.

This notice announces that the Department of the Treasury and the Internal Revenue Service intend to propose regulations to implement the product identification number (PIN) requirement with respect to the energy efficient home improvement credit under § 25C of the Internal Revenue Code, as amended by § 13301 of Public Law 117-169, 136. Stat. 1818 (August 16, 2022), commonly known as the Inflation Reduction Act of 2022. This notice requests comments on this PIN requirement.

This document contains proposed regulations that would provide guidance under section 166 regarding whether a debt instrument is worthless for Federal income tax purposes. The proposed regulations update the standard for determining when a debt instrument held by a regulated financial company or a member of a regulated financial group will be conclusively presumed to be worthless.

Revenue Procedure 2024-9 provides procedures for obtaining automatic consent to change methods of accounting for specified research or experimental expenditures under § 174 paid or incurred in taxable years beginning after December 31, 2021. Revenue Procedure 2024-9 also clarifies section 9 of Revenue Procedure 2023-24 to provide that section 5 of Revenue Procedure 2000-50 is obsoleted for costs of developing computer software paid or incurred in any taxable year beginning after December 31, 2021, and continues to apply to costs of developing computer software paid or incurred in any taxable year beginning on or before December 31, 2021.

26 CFR 601.204: Changes in accounting periods and in methods of accounting.

(Also, Part 1, §§ 174, 446, 460, 1.446-1.)

The United States provided a diplomatic notification, dated July 8, 2022, to the Government of the Republic of Hungary of its termination of the United States-Hungary Tax Treaty. In respect of tax withheld at source, the United States-Hungary Tax Treaty ceases to have effect with respect to amounts paid or credited on or after January 1, 2024. In respect of other taxes, the United States-Hungary Tax Treaty ceases to have effect with respect to taxable periods beginning on or after January 1, 2024.