IRS Bulletin 2024-51 includes updates on Form 1099-K reporting thresholds for 2024-2026, CHIPS Act tax treatment, manufacturing credits, and partnership liability regulations for a smoother tax process.
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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
Notice 2024-85, page 1349.
Notice 2024-85 provides that calendar years 2024 and 2025 will be regarded as the final transition period for purposes of IRS enforcement and administration of the minimum reporting threshold for Form 1099-K, Payment Card and Third Party Network Transactions. Under Notice 2024-85, a third party settlement organization (TPSO) will be required to report payments in settlement of third party network transactions with respect to a participating payee when the amount of total payments for those transactions is more than $5,000 during calendar year 2024; more than $2,500 during calendar year 2025; and more than $600 during calendar year 2026 and after. Notice 2024-85 also provides that for calendar year 2024, the IRS will not assert penalties under section 6651 or 6656 for a TPSO’s failure to withhold and pay backup withholding tax during the calendar year.
INCOME TAX
Announcement 2024-40, page 1352.
This announcement addresses the Federal income tax treatment of certain amounts paid or incurred pursuant to agreements with the Department of Commerce required under the CHIPS Act of 2022.
Rev. Rul. 2024-27, page 1240.
2024 Base Period T-Bill Rate. The “base period T-bill rate” for the period ending September 30, 2024, is published as required by section 995(f) of the Internal Revenue Code.
T.D. 10009, page 1251.
These final regulations provide guidance regarding the advanced manufacturing investment credit under section 48D of the Internal Revenue Code (Code) and the special rules for the investment credit in section 50(a) of the Code. The final regulations reflect changes made by the CHIPS Act of 2022. The section 48D credit may be claimed for qualified investments in an advanced manufacturing facility that engages in the manufacturing of semiconductors or semiconductor manufacturing equipment.
T.D. 10010, page 1286. T
The final regulations provide the rules for claiming the Advanced Manufacturing Production Credit under section 45X of the Internal Revenue Code. The final regulations describe the requirements for the production of eligible components, including the domestic production requirement. The final regulations also provide rules regarding the sale of eligible components to unrelated persons, as well as special rules that apply to sales between related persons. Finally, the final regulations provide definitions of eligible components, rules related to calculating the credit, and specific recordkeeping and reporting requirements.
T.D. 10014, page 1340.
These final regulations provide guidance under § 752 of the Internal Revenue Code relating to a partner’s share of a recourse partnership liability. A partner’s share of a recourse partnership liability is the amount of a liability for which the partner or a related person bears the economic risk of loss. These final regulations clarify when a person is related to a partner, address how a liability is allocated when multiple partners bear the economic risk of loss for the same liability, and provide guidance regarding tiered partnerships when a partner that bears economic risk of loss is a partner in both an upper-tier and lower-tier partnership.