Internal Revenue Bulletin 2023-48 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 2023–48
November 27, 2023
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2023-34, page 1287.
This revenue procedure sets forth inflation-adjusted
items for 2024 for various Code provisions as in effect
on November 9, 2023. The inflation adjusted items for
the Code sections set forth in section 3 of this revenue
procedure are generally determined by reference to § 1(f)
of the Code. To the extent amendments to the Code are
enacted for 2024 after November 9, 2023 taxpayers
should consult additional guidance to determine whether
these adjustments remain applicable for 2024.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
November 27, 2023 Bulletin No. 2023–48

Part III
26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also: Part I, §§ 6011, 6662, 6662A,
6707A; 1-6011-4.)
Rev. Proc. 2023-34
Table of Contents
SECTION 1. PURPOSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1287
SECTION 2. CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1287
SECTION 3. 2024 ADJUSTED ITEMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1287
Code Section
1
.01 Tax Rate Tables ........................................................................1(j)(2) (A)-(D)
.02 Unearned Income of Minor Children Subject to the “Kiddie Tax” ........................................1(g)
.03 Maximum Capital Gains Rate ....................................................................1(h)
.04 Adoption Credit .................................................................................23
.05 Child Tax Credit .................................................................................24
.06 Earned Income Credit .............................................................................32
.07 Refundable Credit for Coverage Under a Qualified Health Plan ...................................36B(f)(2)(B)
.08 Rehabilitation Expenditures Treated as Separate New Building .........................................42(e)
.09 Low-Income Housing Credit ....................................................................42(h)
.10 Employee Health Insurance Expense of Small Employers ..............................................45R
.11 Exemption Amounts for Alternative Minimum Tax ......................................................55
.12 Alternative Minimum Tax Exemption for a Child Subject to the “Kiddie Tax” ..............................59(j)
.13 Certain Expenses of Elementary and Secondary School Teachers ...................................62(a)(2)(D)
.14 Transportation Mainline Pipeline Construction Industry Optional Expense Substantiation Rules for
Payments to Employees Under Accountable Plans ...................................................62(c)
.15 Standard Deduction ..............................................................................63
.16 Cafeteria Plans .................................................................................125
.17 Qualified Transportation Fringe Benefit ............................................................132(f)
.18 Income from United States Savings Bonds for Taxpayers Who Pay Qualified Higher Education Expenses .........135
.19 Adoption Assistance Programs .....................................................................137
.20 Private Activity Bonds Volume Cap ..............................................................146(d)
.21 Loan Limits on Agricultural Bonds ............................................................147(c)(2)
.22 General Arbitrage Rebate Rules ..................................................................148(f)
.23 Safe Harbor Rules for Broker Commissions on Guaranteed Investment Contracts or Investments
Purchased for a Yield Restricted Defeasance Escrow ...................................................148
.24 Gross Income Limitation for a Qualifying Relative .............................................152(d)(1)(B)
.25 Election to Expense Certain Depreciable Assets .......................................................179
.26 Energy Efficient Commercial Buildings Deduction ...................................................179D
.27 Qualified Business Income ......................................................................199A
.28 Eligible Long-Term Care Premiums ...........................................................213(d)(10)
.29 Medical Savings Accounts ........................................................................220
.30 Interest on Education Loans .......................................................................221
.31 Limitation on Use of Cash Method of Accounting .....................................................448
.32 Threshold for Excess Business Loss ..............................................................461(l)
.33 Treatment of Dues Paid to Agricultural or Horticultural Organizations ..................................512(d)
.34 Insubstantial Benefit Limitations for Contributions Associated With Charitable Fund-Raising Campaigns. . . . . . . 513(h)
.35 Special Rules for Credits and Deductions ............................................................642
.36 Tax on Insurance Companies Other than Life Insurance Companies .......................................831
1
Unless otherwise specified, all references to “section” or “§” references are to provisions of the Internal Revenue Code (Code).
Bulletin No. 2023–48 1287 November 27, 2023

.37 Expatriation to Avoid Tax .........................................................................877
.38 Tax Responsibilities of Expatriation ...............................................................877A
.39 Foreign Earned Income Exclusion ..................................................................911
.40 Debt Instruments Arising Out of Sales or Exchanges ................................................1274A
.41 Unified Credit Against Estate Tax .................................................................2010
.42 Valuation of Qualified Real Property in Decedent’s Gross Estate .......................................2032A
.43 Annual Exclusion for Gifts ..................................................................2503; 2523
.44 Tax on Arrow Shafts ............................................................................4161
.45 Passenger Air Transportation Excise Tax ............................................................4261
.46 Tax on Certain Uses of Crude Oil and Petroleum Products ..............................................4611
.47 Reporting Exception for Certain Exempt Organizations with Nondeductible Lobbying Expenditures .......6033(e)(3)
.48 Notice of Large Gifts Received from Foreign Persons ................................................6039F
.49 Persons Against Whom a Federal Tax Lien Is Not Valid ................................................6323
.50 Property Exempt from Levy ...................................................................6334(a)
.51 Exempt Amount of Wages, Salary, or Other Income ................................................6334(d)
.52 Interest on a Certain Portion of the Estate Tax Payable in Installments ...................................6601(j)
.53 Failure to File Tax Return ........................................................................6651
.54 Failure to File Certain Information Returns, Registration Statements, etc. ..................................6652
.55 Other Assessable Penalties With Respect to the Preparation of Tax Returns for Other Persons ..................6695
.56 Failure
to File Partnership Return .................................................................6698
.57 Failure to File S Corporation Return ...............................................................6699
.58 Failure to File Correct Information Returns ..........................................................6721
.59 Failure to Furnish Correct Payee Statements .........................................................6722
.60 Revocation or Denial of Passport in Case of Certain Tax Delinquencies ...................................7345
.61 Attorney Fee Awards ...........................................................................7430
.62 Periodic Payments Received Under Qualified Long-Term Care Insurance Contracts or Under Certain
Life Insurance Contracts .....................................................................7702B(d)
.63 Qualified Small Employer Health Reimbursement Arrangement .........................................9831
SECTION 4. EFFECTIVE DATE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1298
SECTION 5. DRAFTING INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1298
SECTION 1. PURPOSE
This revenue procedure sets forth
inflation-adjusted items for 2024 for
various Code provisions as in effect
on November 9, 2023. The inflation
adjusted items for the Code sections set
forth in section 3 of this revenue proce-
dure are generally determined by refer-
ence to § 1(f). To the extent amendments
to the Code are enacted for 2024 after
November 9, 2023, taxpayers should
consult additional guidance to determine
whether these adjustments remain appli-
cable for 2024.
SECTION 2. CHANGES
.01 For calendar years beginning on
or after January 1, 2023, § 13601(a)(2) of
Public Law 117-169, 136 Stat. 1818 (August
16, 2022), commonly known as the Inflation
Reduction Act of 2022 (IRA), reinstates the
Hazardous Substance Superfund financing
rate for crude oil received at a United States
refinery and petroleum products entered
into the United States for consumption, use,
or warehousing under § 4611. The rate of
tax imposed by § 4611 is the sum of the
Hazardous Substance Superfund rate and
the Oil Spill Liability Trust Fund financing
rate. In the case of crude oil or petroleum
products entered after December 31, 2016,
for calendar years beginning in 2023, the
rate of tax imposed by § 4611(a) is $0.254
cents a barrel.
.02 The Hazardous Substance Superfund
financing rate described in section 2.01 of
this revenue procedure is adjusted for infla-
tion for calendar years beginning in 2024.
SECTION 3. 2024 ADJUSTED ITEMS
.01 Tax Rate Tables. For taxable years
beginning in 2024, the tax rate tables
under § 1 are as follows:
November 27, 2023 1288 Bulletin No. 2023–48

Bulletin No. 2023–48 1289 November 27, 2023
TABLE 1 - Section 1(j)(2)(A) – Married Individuals Filing Joint Returns and Surviving Spouses
If Taxable Income Is:The Tax Is:
Not over $23,20010% of the taxable income
Over $23,200 but
not over $94,300
$2,320 plus 12% of
the excess over $23,200
Over $94,300 but
not over $201,050
$10,852 plus 22% of
the excess over $94,300
Over $201,050 but
not over $383,900
$34,337 plus 24% of
the excess over $201,050
Over $383,900 but
not over $487,450
$78,221 plus 32% of
the excess over $383,900
Over $487,450 but
not over $731,200
$111,357 plus 35% of
the excess over $487,450
Over $731,200$196,669.50 plus 37% of
the excess over $731,200
TABLE 2 - Section 1(j)(2)(B) – Heads of Households
If Taxable Income Is:The Tax Is:
Not over $16,55010% of the taxable income
Over $16,550 but
not over $63,100
$1,655 plus 12% of
the excess over $16,550
Over $63,100 but
not over $100,500
$7,241 plus 22% of
the excess over $63,100
Over $100,500 but
not over $191,950
$15,469 plus 24% of
the excess over $100,500
Over $191,950 but
not over $243,700
$37,417 plus 32% of
the excess over $191,950
Over $243,700 but
not over $609,350
$53,977 plus 35% of
the excess over $243,700
Over $609,350$181,954.50 plus 37% of
the excess over $609,350
TABLE 3 - Section 1(j)(2)(C) – Unmarried Individuals (other than Surviving Spouses and Heads of Households)
If Taxable Income Is:The Tax Is:
Not over $11,60010% of the taxable income
Over $11,600 but
not over $47,150
$1,160 plus 12% of
the excess over $11,600
Over $47,150 but
not over $100,525
$5,426 plus 22% of
the excess over $47,150
Over $100,525 but
not over $191,950
$17,168.50 plus 24% of
the excess over $100,525
Over $191,950 but
not over $243,725
$39,110.50 plus 32% of
the excess over $191,950
Over $243,725 but
not over $609,350
$55,678.50 plus 35% of
the excess over $243,725
Over $609,350$183,647.25 plus 37% of
the excess over $609,350

November 27, 2023 1290 Bulletin No. 2023–48
TABLE 4 - Section 1(j)(2)(D) – Married Individuals Filing Separate Returns
If Taxable Income Is:The Tax Is:
Not over $11,60010% of the taxable income
Over $11,600 but
not over $47,150
$1,160 plus 12% of
the excess over $11,600
Over $47,150 but
not over $100,525
$5,426 plus 22% of
the excess over $47,150
Over $100,525 but
not over $191,950
$17,168.50 plus 24% of
the excess over $100,525
Over $191,950 but
not over $243,725
$39,110.50 plus 32% of
the excess over $191,950
Over $243,725 but
not over $365,600
$55,678.50 plus 35% of
the excess over $243,725
Over $365,600$98,334.75 plus 37% of
the excess over $365,600
TABLE 5 - Section 1(j)(2)(E) – Estates and Trusts
If Taxable Income Is:The Tax Is:
Not over $3,10010% of the taxable income
Over $3,100 but
not over $11,150
$310 plus 24% of
the excess over $3,100
Over $11,150 but
not over $15,200
$2,242 plus 35% of
the excess over $11,150
Over $15,200$3,659.50 plus 37% of
the excess over $15,200
.02 Unearned Income of Minor
Children Subject to the “Kiddie Tax”.
For taxable years beginning in 2024, the
amount in § 1(g)(4)(A)(ii)(I), which is
used to reduce the net unearned income
reported on the child’s return that is sub-
ject to the “kiddie tax,” is $1,300. This
$1,300 amount is the same as the amount
provided in § 63(c)(5)(A), as adjusted for
inflation. The same $1,300 amount is used
for purposes of § 1(g)(7) to determine
whether a parent may elect to include a
child’s gross income in the parent’s gross
income and to calculate the “kiddie tax.”
For example, one of the requirements
for the parental election is that a child’s
gross income is more than the amount
referenced in § 1(g)(4)(A)(ii)(I) but less
than 10 times that amount; thus, a child’s
gross income for 2024 must be more than
$1,300 but less than $13,000.
.03 Maximum Capital Gains Rate
(§1(h), §1(j)(5)). For taxable years begin-
ning in 2024, the maximum zero rate
amounts and maximum 15 percent rate
amounts under § 1(j)(5)(B), as adjusted
for inflation, are as follows:
Filing StatusMaximum Zero Rate
Amount
Maximum 15% Rate
Amount
Married Individuals Filing Joint Returns and Surviving Spouse$94,050$583,750
Married Individuals Filing Separate Returns$47,025$291,850
Heads of Household$63,000$551,350
All Other Individuals$47,025$518,900
Estates and Trusts$3,150$15,450
.04 Adoption Credit. For taxable years
beginning in 2024, under § 23(a)(3) the
credit allowed for an adoption of a child
with special needs is $16,810. For taxable
years beginning in 2024, under § 23(b)
(1) the maximum credit allowed for other
adoptions is the amount of qualified adop-
tion expenses up to $16,810. The available
adoption credit begins to phase out under
§ 23(b)(2)(A) for taxpayers with modi-
fied adjusted gross income in excess of
$252,150 and is completely phased out for

Bulletin No. 2023–48 1291 November 27, 2023
taxpayers with modified adjusted gross
income of $292,150 or more. See section
3.19 of this revenue procedure for the
adjusted items relating to adoption assis-
tance programs.
.05 Child Tax Credit. For taxable years
beginning in 2024, the amount used in
§ 24(d)(1)(A) to determine the amount of
credit under § 24 that may be refundable
is $1,700.
.06 Earned Income Credit.
(1) In general. For taxable years begin-
ning in 2024, the following amounts are
used to determine the earned income
credit under § 32(b). The “earned income
amount” is the amount of earned income
at or above which the maximum amount
of the earned income credit is allowed.
The “threshold phaseout amount” is the
amount of adjusted gross income (or, if
greater, earned income) above which the
maximum amount of the credit begins
to phase out. The “completed phaseout
amount” is the amount of adjusted gross
income (or, if greater, earned income) at
or above which no credit is allowed. The
threshold phaseout amounts and the com-
pleted phaseout amounts shown in the
table below for married taxpayers filing a
joint return include the increase provided
in § 32(b)(2)(B), as adjusted for inflation
for taxable years beginning in 2024. The
threshold phaseout amounts and the com-
pleted phaseout amounts shown in the
table below for taxpayers with all other
filing statuses also apply to married tax-
payers who are not filing a joint return
and satisfy the special rules for separated
spouses in § 32(d).
Number of Qualifying Children
ItemOneTwoThree or MoreNone
Earned Income Amount$12,390$17,400$17,400$8,260
Maximum Amount of Credit$4,213$6,960$7,830$632
Threshold Phaseout Amount (Married Filing Jointly)$29,640$29,640$29,640$17,250
Completed Phaseout Amount (Married Filing Jointly)$56,004$62,688$66,819$25,511
Threshold Phaseout Amount (All other filing statuses)$22,720$22,720$22,720$10,330
Completed Phaseout Amount (All other filing statuses)$49,084$55,768$59,899$18,591
The instructions for the Form 1040
series provide tables showing the amount
of the earned income credit for each type
of taxpayer.
(2) Excessive Investment Income.
For taxable years beginning in 2024, the
earned income tax credit is not allowed
under § 32(i) if the aggregate amount
of certain investment income exceeds
$11,600.
.07 Refundable Credit for Coverage
Under a Qualified Health Plan. For
taxable years beginning in 2024, the lim-
itation on tax imposed under § 36B(f)(2)
(B) for excess advance credit payments is
determined using the following table:
If the household income
(expressed as a percent of
poverty line) is:
The limitation amount for
unmarried individuals
(other than surviving spouses
and heads of household) is:
The limitation amount for
all other taxpayers is:
Less than 200%$375$750
At least 200% but less than 300%$950$1,900
At least 300% but less than 400%$1,575$3,150
.08 Rehabilitation Expenditures
Treated as Separate New Building. For
calendar year 2024, the per low-income
unit qualified basis amount under § 42(e)
(3)(A)(ii)(II) is $8,300.
.09 Low-Income Housing Credit. For
calendar year 2024, the amount used under
§ 42(h)(3)(C)(ii) to calculate the State
housing credit ceiling for the low-income
housing credit is the greater of (1) $2.90
multiplied by the State population, or
(2) $3,360,000.
.10 Employee Health Insurance
Expense of Small Employers. For tax-
able years beginning in 2024, the dollar
amount in effect under § 45R(d)(3)(B)
is $32,400. This amount is used under
§ 45R(c) for limiting the small employer
health insurance credit and under § 45R(d)
(1)(B) for determining who is an eligible
small employer for purposes of the credit.
.11 Exemption Amounts for Alternative
Minimum Tax. For taxable years begin-
ning in 2024, the exemption amounts
under § 55(d)(1) are:
Joint Returns or Surviving Spouses$133,300
Unmarried Individuals (other than Surviving Spouses)$85,700
Married Individuals Filing Separate Returns$66,650
Estates and Trusts$29,900

November 27, 2023 1292 Bulletin No. 2023–48
For taxable years beginning in 2024,
under § 55(b)(1), the excess taxable
income above which the 28 percent tax
rate applies is:
Married Individuals Filing Separate Returns$116,300
All Other Taxpayers$232,600
For taxable years beginning in 2024,
the amounts used under § 55(d)(2) to
determine the phaseout of the exemption
amounts are:
Threshold Phaseout AmountComplete Phaseout Amount
Joint Returns or Surviving Spouses$1,218,700$1,751,900
Unmarried Individuals (other than Surviving Spouses)$609,350$952,150
Married Individuals Filing Separate Returns$609,350$875,950
Estates and Trusts$99,700$219,300
.12 Alternative Minimum Tax
Exemption for a Child Subject to the
“Kiddie Tax.” For taxable years begin-
ning in 2024, for a child to whom the
§ 1(g) “kiddie tax” applies, the exemp-
tion amount under §§ 55(d) and 59(j) for
purposes of the alternative minimum tax
under § 55 may not exceed the sum of (1)
the child’s earned income for the taxable
year, plus (2) $9,250.
.13 Certain Expenses of Elementary
and Secondary School Teachers. For
taxable years beginning in 2024, under
§ 62(a)(2)(D) the amount of the deduc-
tion allowed under § 162 that consists of
expenses paid or incurred by an eligible
educator in connection with books, sup-
plies (other than nonathletic supplies for
courses of instruction in health or phys-
ical education), computer equipment
(including related software and services)
and other equipment, and supplementary
materials used by the eligible educator in
the classroom is $300.
.14 Transportation Mainline Pipeline
Construction Industry Optional Expense
Substantiation Rules for Payments to
Employees Under Accountable Plans. For
calendar year 2024, an eligible employer
may pay certain welders and heavy
equipment mechanics an amount up to $22
per hour for rig-related expenses that are
deemed substantiated under an account-
able plan if paid in accordance with Rev.
Proc. 2002-41, 2002-1 C.B. 1098. If the
employer provides fuel or otherwise reim-
burses fuel expenses, an amount up to $13
per hour is deemed substantiated if paid
under Rev. Proc. 2002-41.
.15 Standard Deduction.
(1) In general. For taxable years begin-
ning in 2024, the standard deduction
amounts under § 63(c)(2) are as follows:
Filing StatusStandard Deduction
Married Individuals Filing Joint Returns and Surviving Spouses (§ 1(j)(2)(A))$29,200
Heads of Households (§ 1(j)(2)(B))$21,900
Unmarried Individuals (other than Surviving Spouses and Heads of Households) (§ 1(j)(2)(C))$14,600
Married Individuals Filing Separate Returns (§ 1(j)(2)(D))$14,600
(2) Dependent. For taxable years
beginning in 2024, the standard deduction
amount under § 63(c)(5) for an individ-
ual who may be claimed as a dependent
by another taxpayer cannot exceed the
greater of (1) $1,300, or (2) the sum of
$450 and the individual’s earned income.
(3) Aged or blind. For taxable years
beginning in 2024, the additional standard
deduction amount under § 63(f) for the
aged or the blind is $1,550. The additional
standard deduction amount is increased to
$1,950 if the individual is also unmarried
and not a surviving spouse.
.16 Cafeteria Plans. For taxable years
beginning in 2024, the dollar limitation
under § 125(i) on voluntary employee sal-
ary reductions for contributions to health
flexible spending arrangements is $3,200.
If the cafeteria plan permits the carryover
of unused amounts, the maximum carry-
over amount is $640.
.17 Qualified Transportation Fringe
Benefit. For taxable years beginning
in 2024, the monthly limitation under
§ 132(f)(2)(A) regarding the aggregate
fringe benefit exclusion amount for trans-
portation in a commuter highway vehicle
and any transit pass is $315. The monthly
limitation under § 132(f)(2)(B) regarding
the fringe benefit exclusion amount for
qualified parking is $315.
.18 Income from United States Savings
Bonds for Taxpayers Who Pay Qualified
Higher Education Expenses. For tax-
able years beginning in 2024, the exclu-
sion under § 135, regarding income from
United States savings bonds for taxpay-
ers who pay qualified higher education
expenses, begins to phase out for modified
adjusted gross income above $145,200
for joint returns and $96,800 for all other

Bulletin No. 2023–48 1293 November 27, 2023
returns. The exclusion is completely
phased out for modified adjusted gross
income of $175,200 or more for joint
returns and $111,800 or more for all other
returns.
.19 Adoption Assistance Programs.
For taxable years beginning in 2024,
under § 137(a)(2), the amount that can
be excluded from an employee’s gross
income for the adoption of a child with
special needs is $16,810. For taxable years
beginning in 2024, under § 137(b)(1) the
maximum amount that can be excluded
from an employee’s gross income for the
amounts paid or expenses incurred by an
employer for qualified adoption expenses
furnished pursuant to an adoption assis-
tance program for adoptions by the
employee is $16,810. The amount exclud-
able from an employee’s gross income
begins to phase out under § 137(b)(2)
(A) for taxpayers with modified adjusted
gross income in excess of $252,150 and
is completely phased out for taxpayers
with modified adjusted gross income of
$292,150 or more. (See section 3.04 of
this revenue procedure for the adjusted
items relating to the adoption credit.)
.20 Private Activity Bonds Volume
Cap. For calendar year 2024, the amounts
used under § 146(d) to calculate the State
ceiling for the volume cap for private
activity bonds is the greater of (1) $125
multiplied by the State population, or (2)
$378,230,000.
.21 Loan Limits on Agricultural
Bonds. For calendar year 2024, the loan

limit amount on agricultural bonds under
§ 147(c)(2)(A) for first-time farmers is
$649,400.
.22 General Arbitrage Rebate Rules.
For bond years ending in 2024, the amount
of the computation credit determined
under § 1.148-3(d)(4) of the Income Tax
Regulations is $2,070.
.23 Safe Harbor Rules for Broker
Commissions on Guaranteed Investment
Contracts or Investments Purchased for a
Yield Restricted Defeasance Escrow. For
calendar year 2024, under § 1.148-5(e)(2)
(iii)(B)(1) of the Income Tax Regulations,
a broker’s commission or similar fee for
the acquisition of a guaranteed investment
contract or investments purchased for a
yield restricted defeasance escrow is rea-
sonable if (1) the amount of the fee that
the issuer treats as a qualified adminis-
trative cost does not exceed the lesser of
(A) $49,000, and (B) 0.2 percent of the
computational base (as defined in § 1.148-
5(e)(2)(iii)(B)(2)) or, if more, $5,000; and
(2) for any issue, the issuer does not treat
more than $138,000 in brokers’ commis-
sions or similar fees as qualified adminis-
trative costs for all guaranteed investment
contracts and investments for yield
restricted defeasance escrows purchased
with gross proceeds of the issue.
.24 Gross Income Limitation for a
Qualifying Relative. For taxable years
beginning in 2024, the exemption amount
referenced in § 152(d)(1)(B) is $5,050.
.25 Election to Expense Certain
Depreciable Assets. For taxable years

beginning in 2024, under § 179(b)(1), the
aggregate cost of any § 179 property that
a taxpayer elects to treat as an expense
cannot exceed $1,220,000 and under
§ 179(b)(5)(A), the cost of any sport util-
ity vehicle that may be taken into account
under § 179 cannot exceed $30,500.
Under § 179(b)(2), the $1,220,000 lim-
itation under § 179(b)(1) is reduced (but
not below zero) by the amount by which
the cost of § 179 property placed in ser-
vice during the 2024 taxable year exceeds
$3,050,000.
.26 Energy Efficient Commercial
Building Deduction. For taxable years
beginning in 2024, the applicable dol-
lar value used to determine the maxi-
mum allowance of the deduction under
§ 179D(b)(2) is $0.57 increased (but not
above $1.13) by $0.02 for each percentage
point by which the total annual energy and
power costs for the buildings are certified
to be reduced by a percentage greater than
25 percent. For taxable years beginning in
2024, the applicable dollar value used to
determine the increased deduction amount
for certain property under § 179D(b)(3) is
$2.83 increased (but not above $5.65) by
$0.11 for each percentage point by which
the total annual energy and power costs
for the building are certified to be reduced
by a percentage greater than 25 percent.
.27 Qualified Business Income. For tax-
able years beginning in 2024, the threshold
amounts under § 199A(e)(2) and phase-in
range amounts under § 199A(b)(3)(B) and
§ 199A(d)(3)(A) are:
Filing StatusThreshold amountPhase-in range amount
Married Individuals Filing Joint Returns$383,900$483,900
Married Individuals Filing Separate Returns$191,950$241,950
All Other Returns$191,950$241,950
.28 Eligible Long-Term Care Premiums.
For taxable years beginning in 2024, the
limitations under § 213(d)(10), regard-
ing eligible long-term care premiums
includible in the term “medical care”, as
adjusted for inflation, are as follows:
Attained Age Before the Close of the Taxable YearLimitation on Premiums
40 or less$470
More than 40 but not more than 50$880
More than 50 but not more than 60$1,760
More than 60 but not more than 70$4,710
More than 70$5,880

November 27, 2023 1294 Bulletin No. 2023–48
.29 Medical Savings Accounts.
(1) Self-only coverage. For taxable
years beginning in 2024, the term “high
deductible health plan” as defined in
§ 220(c)(2)(A) means, for self-only cov-
erage, a health plan that has an annual
deductible that is not less than $2,800
and not more than $4,150, and under
which the annual out-of-pocket expenses
required to be paid (other than for premi-
ums) for covered benefits do not exceed
$5,550.
(2) Family coverage. For taxable
years beginning in 2024, the term “high
deductible health plan” means, for family
coverage, a health plan that has an annual
deductible that is not less than $5,550
and not more than $8,350, and under
which the annual out-of-pocket expenses
required to be paid (other than for premi-
ums) for covered benefits do not exceed
$10,200.
.30 Interest on Education Loans. For
taxable years beginning in 2024, the
$2,500 maximum deduction for interest
paid on qualified education loans under
§ 221 begins to phase out under § 221(b)
(2)(B), as adjusted for inflation, for taxpay-
ers with modified adjusted gross income
in excess of $80,000 ($165,000 for joint
returns), and is completely phased out for
taxpayers with modified adjusted gross
income of $95,000 or more ($195,000 or
more for joint returns).
.31 Limitation on Use of Cash Method
of Accounting. For taxable years begin-
ning in 2024, a corporation or partnership
meets the gross receipts test of § 448(c)
for any taxable year if the average annual
gross receipts of such entity for the 3-tax-
able-year period ending with the taxable
year which precedes such taxable year
does not exceed $30,000,000.
.32 Threshold for Excess Business
Loss. For taxable years beginning in 2024,
in determining a taxpayer’s excess busi-
ness loss, the amount under § 461(l)(3)
(A)(ii)(II) is $305,000 ($610,000 for joint
returns).
.33 Treatment of Dues Paid
to Agricultural or Horticultural
Organizations. For taxable years begin-
ning in 2024, the limitation under § 512(d)
(1), regarding the exemption of annual
dues required to be paid by a member to
an agricultural or horticultural organiza-
tion, is $201.
.34 Insubstantial Benefit Limitations for
Contributions Associated with Charitable
Fund-Raising Campaigns.
(1) Low cost article. For taxable years
beginning in 2024, for purposes of defin-
ing the term “unrelated trade or business”
for certain exempt organizations under
§ 513(h)(2), “low cost articles” are articles
costing $13.20 or less.
(2) Other insubstantial benefits. For
taxable years beginning in 2024, under
§ 170, the $5, $25, and $50 guidelines in
section 3 of Rev. Proc. 90-12, 1990-1 C.B.
471 (as amplified by Rev. Proc. 92-49,
1992-1 C.B. 987, and modified by Rev.
Proc. 92-102, 1992-2 C.B. 579), for the
value of insubstantial benefits that may be
received by a donor in return for a con-
tribution, without causing the contribution
to fail to be fully deductible, are $13.20,
$66.00 and $132.00, respectively.
.35 Special Rules for Credits and
Deductions. For taxable years beginning
in 2024, the amount of the deduction
under § 642(b)(2)(C)(i) is $5,000.
.36 Tax on Insurance Companies Other
than Life Insurance Companies. For
taxable years beginning in 2024, under
§ 831(b)(2)(A)(i) the amount of the limit
on net written premiums or direct writ-
ten premiums (whichever is greater) is
$2,800,000 to elect the alternative tax for
certain small companies under § 831(b)
(1) to be taxed only on taxable investment
income.
.37 Expatriation to Avoid Tax. For
calendar year 2024, under § 877A(g)(1)
(A), unless an exception under § 877A(g)
(1)(B) applies, an individual is a covered
expatriate if the individual’s “average
annual net income tax” under § 877(a)
(2)(A) for the five taxable years ending
before the expatriation date is more than
$201,000.
.38 Tax Responsibilities of Expatriation.
For taxable years beginning in 2024, the
amount that would be includible in the
gross income of a covered expatriate by
reason of § 877A(a)(1) is reduced (but
not below zero) by $866,000 pursuant to
§ 877A(a)(3).
.39 Foreign Earned Income Exclusion.
For taxable years beginning in 2024, the
foreign earned income exclusion amount
under § 911(b)(2)(D)(i) is $126,500.
.40 Debt Instruments Arising Out of
Sales or Exchanges. For calendar year

2024, a qualified debt instrument under
§ 1274A(b) has stated principal that does
not exceed $7,098,600, and a cash method
debt instrument under § 1274A(c)(2)
has stated principal that does not exceed
$5,070,500.
.41 Unified Credit Against Estate Tax.
For an estate of any decedent dying in
calendar year 2024, the basic exclusion
amount is $13,610,000 for determining
the amount of the unified credit against
estate tax under § 2010.
.42 Valuation of Qualified Real
Property in Decedent’s Gross Estate. For
an estate of a decedent dying in calendar
year 2024, if the executor elects to use
the special use valuation method under
§ 2032A for qualified real property, the
aggregate decrease in the value of quali-
fied real property resulting from electing
to use § 2032A for purposes of the estate
tax cannot exceed $1,390,000.
.43 Annual Exclusion for Gifts.
(1) For calendar year 2024, the first
$18,000 of gifts to any person (other than
gifts of future interests in property) are
not included in the total amount of taxable
gifts under § 2503 made during that year.
(2) For calendar year 2024, the first
$185,000 of gifts to a spouse who is not
a citizen of the United States (other than
gifts of future interests in property) are
not included in the total amount of taxable
gifts under §§ 2503 and 2523(i)(2) made
during that year.
.44 Tax on Arrow Shafts. For calen-
dar year 2024, the tax imposed under
§ 4161(b)(2)(A) on the first sale by the
manufacturer, producer, or importer of
any shaft of a type used in the manufac-
ture of certain arrows is $0.62 per shaft.
.45 Passenger Air Transportation
Excise Tax. For calendar year 2024, the
tax under § 4261(b)(1) on the amount paid
for each domestic segment of taxable air
transportation is $5.00. For calendar year
2024, the tax under § 4261(c)(1) on any
amount paid (whether within or without
the United States) for any international air
transportation, if the transportation begins
or ends in the United States, generally is
$22.20. Under § 4261(c)(3), however, a
lower rate of tax applies under § 4261(c)
(1) to a domestic segment beginning or
ending in Alaska or Hawaii, and the tax
applies only to departures. For calendar
year 2024, the rate of tax is $11.10.

Bulletin No. 2023–48 1295 November 27, 2023
.46 Tax on Certain Uses of Crude Oil
and Petroleum Products. For calendar year
2024, the tax imposed under § 4611(a) on
crude oil received at a United States refin-
ery and petroleum products entered into
the United States for consumption, use, or
warehousing is $0.26 cents per barrel.
.47 Reporting Exception for Certain
Exempt Organizations with Nondeductible
Lobbying Expenditures. For taxable years
beginning in 2024, the annual per per-
son, family, or entity dues limitation to
qualify for the reporting exception under
§ 6033(e)(3) (and section 5.05 of Rev.
Proc. 98-19, 1998-1 C.B. 547), regarding
certain exempt organizations with nonde-
ductible lobbying expenditures, is $140 or
less.
.48 Notice of Large Gifts Received
from Foreign Persons. For taxable years
beginning in 2024, § 6039F authorizes the
Secretary of the Treasury or her delegate
to require recipients of gifts from certain
foreign persons to report these gifts if the
aggregate value of gifts received in the
taxable year exceeds $19,570.
.49 Persons Against Whom a Federal
Tax Lien Is Not Valid. For calendar year
2024, a federal tax lien is not valid against
(1) certain purchasers under § 6323(b)
(4) who purchased personal property in
a casual sale for less than $1,900, or (2)
a mechanic’s lienor under § 6323(b)(7)
who repaired or improved certain residen-
tial property if the contract price with the
owner is not more than $9,520.
.50 Property Exempt from Levy. For
calendar year 2024, the value of property
exempt from levy under § 6334(a)(2) (fuel,
provisions, furniture, and other household
personal effects, as well as arms for per-
sonal use, livestock, and poultry) cannot
exceed $11,390. The value of property
exempt from levy under § 6334(a)(3)
(books and tools necessary for the trade,
business, or profession of the taxpayer)
cannot exceed $5,700.
.51 Exempt Amount of Wages, Salary,
or Other Income. For taxable years begin-
ning in 2024, the dollar amount used to
calculate the amount determined under
§ 6334(d)(4)(B) is $5,000.
.52 Interest on a Certain Portion of the
Estate Tax Payable in Installments. For an
estate of a decedent dying in calendar year
2024, the dollar amount used to determine
the “2-percent portion” (for purposes of
calculating interest under § 6601(j)) of the
estate tax extended as provided in § 6166
is $1,850,000.
.53 Failure to File Tax Return. In the
case of any return required to be filed
in 2025, the amount of the addition to
tax under § 6651(a) for failure to file an
income tax return within 60 days of the
due date of such return (determined with
regard to any extensions of time for filing)
will not be less than the lesser of $510 or
100 percent of the amount required to be
shown as tax on such return.
.54 Failure to File Certain Information
Returns, Registration Statements, etc. For
returns required to be filed in 2025, the
penalty amounts under § 6652(c) are:
(1) for failure to file a return required
under § 6033(a)(1) (relating to returns by
exempt organization) or § 6012(a)(6) (relat-
ing to returns by exempt organizations):
ScenarioDaily Penalty Maximum Penalty
Organization (§ 6652(c)(1)(A))$25Lesser of $12,500 or 5%
of gross receipts of the
organization for the year
Organization with gross receipts exceeding $1,274,000 (§ 6652(c)(1)(A))$125$63,500
Managers (§ 6652(c)(1)(B))$10$6,000
Public inspection of annual returns and reports (§ 6652(c)(1)(C))$25$12,500
Public inspection of applications for exemption and notice of status (§ 6652(c)
(1)(D))
$25No Limit
(2) for failure to file a return required
under § 6034 (relating to returns by certain
trusts) or § 6043(b) (relating to termina-
tions, etc., of exempt organizations):
ScenarioDaily Penalty Maximum Penalty
Organization or trust (§ 6652(c)(2)(A))$10$6,000
Managers (§ 6652(c)(2)(B))$10$6,000
Split-Interest Trust (§ 6652(c)(2)(C)(ii))$25$12,500
Any trust with gross income exceeding $318,500 (§ 6652(c)(2)(C)(ii))$125$63,500
(3) for failure to file a disclosure required under § 6033(a)(2):
ScenarioDaily Penalty Maximum Penalty
Tax–exempt entity (§ 6652(c)(3)(A))$125$63,500
Failure to comply with written demand (§ 6652(c)(3)(B)(ii))$125$12,500

November 27, 2023 1296 Bulletin No. 2023–48
.55 Other Assessable Penalties With
Respect to the Preparation of Tax Returns
for Other Persons. In the case of any fail-
ure relating to a return or claim for refund
filed in 2025, the penalty amounts under
§ 6695 are:
ScenarioPer Return or Claim for
Refund
Maximum
Penalty
Failure to furnish copy to taxpayer (§ 6695(a))$60$31,500
Failure to sign return (§ 6695(b))$60$31,500
Failure to furnish identifying number (§ 6695(c))$60$31,500
Failure to retain copy or list (§ 6695(d))$60$31,500
Failure to file correct information returns (§ 6695(e))$60 per return and item
in return
$31,500
Negotiation of check (§ 6695(f))$635 per checkNo limit
Failure to be diligent in determining eligibility for head of household filing status,
child tax credit, American Opportunity tax credit, and earned income credit
(§ 6695(g))
$635 per failureNo limit
.56 Failure to File Partnership Return.
In the case of any return required to be
filed in 2025, the dollar amount used to
determine the amount of the penalty under
§ 6698(b)(1) is $245.
.57 Failure to File S Corporation
Return. In the case of any return required
to be filed in 2025, the dollar amount used
to determine the amount of the penalty
under § 6699(b)(1) is $245.
.58 Failure to File Correct Information
Returns. In the case of any failure relating
to a return required to be filed in 2025, the
penalty amounts under § 6721 are:
(1) for persons with average annual
gross receipts for the most recent three
taxable years of more than $5,000,000, for
failure to file correct information returns:
ScenarioPenalty Per Return Calendar Year Maximum
General Rule (§ 6721(a)(1))$330$3,987,000
Corrected on or before 30 days after required filing date (§ 6721(b)(1))$60$664,500
Corrected after 30
th
day but on or before August 1, 2025 (§ 6721(b)(2))$130$1,993,500
(2) for persons with average annual
gross receipts for the most recent three
taxable years of $5,000,000 or less, for
failure to file correct information returns:
ScenarioPenalty Per Return Calendar Year Maximum
General Rule (§ 6721(d)(1)(A))$330$1,329,000
Corrected on or before 30 days after required filing date (§ 6721(d)(1)(B))$60$232,500
Corrected after 30
th
day but on or before August 1, 2025 (§ 6721(d)(1)(C))$130$664,500
(3) for failure to file correct informa-
tion returns due to intentional disregard
of the filing requirement (or the correct
information reporting requirement):

Bulletin No. 2023–48 1297 November 27, 2023
ScenarioPenalty Per Return Calendar Year
Maximum
Return other than a return required to be filed under
§§ 6045(a), 6041A(b), 6050H, 6050I, 6050J, 6050K, or
6050L (§ 6721(e)(2)(A))
Greater of (i) $660, or (ii) 10% of aggregate
amount of items required to be reported
correctly
No limit
Return required to be filed under §§ 6045(a), 6050K, or
6050L (§ 6721(e)(2)(B))
Greater of (i) $660, or (ii) 5% of aggregate
amount of items required to be reported
correctly
No limit
Return required to be filed under § 6050I(a) (§ 6721(e)(2)(C))Greater of (i) $33,220, or (ii) amount of cash
received up to $132,500
No limit
Return required to be filed under § 6050V (§ 6721(e)(2)(D))Greater of (i) $660, or (ii) 10% of the value
of the benefit of any contract with respect to
which information is required to be included on
the return
No limit
.59 Failure to Furnish Correct Payee
Statements. In the case of any failure
relating to a statement required to be fur-
nished in 2025, the penalty amounts under
§ 6722 are:
(1) for persons with average annual
gross receipts for the most recent three
taxable years of more than $5,000,000, for
failure to furnish correct payee statements:
ScenarioPenalty Per StatementCalendar Year Maximum
General Rule (§ 6722(a)(1))$330$3,987,000
Corrected on or before 30 days after required furnishing date
(§ 6722(b)(1))
$60$664,500
Corrected after 30th day but on or before August 1, 2025 (§ 6722(b)
(2))
$130$1,993,500
(2) for persons with average annual
gross receipts for the most recent 3 taxable
years of $5,000,000 or less, for failure to
furnish correct payee statements:
ScenarioPenalty Per StatementCalendar Year Maximum
General Rule (§ 6722(d)(1)(A))$330$1,329,000
Corrected on or before 30 days after required furnishing date
(§ 6722(d)(1)(B))
$60$232,500
Corrected after 30
th
day but on or before August 1, 2025 (§ 6722(d)
(1)(C))
$130$664,500
(3) for failure to furnish correct payee
statements due to intentional disregard
of the requirement to furnish a payee
statement (or the correct information
reporting requirement):
ScenarioPenalty Per StatementCalendar Year
Maximum
Payee statement other than a statement required under §§ 6045(b),
6041A(e) (in respect of a return required under § 6041A(b)),
6050H(d), 6050J(e), 6050K(b), or 6050L(c) (§ 6722(e)(2)(A))
Greater of (i) $660, or (ii) 10% of
aggregate amount of items required
to be reported correctly
No limit
Payee statement required under §§ 6045(b), 6050K(b), or 6050L(c)
(§ 6722(e)(2)(B))
Greater of (i) $660, or (ii) 5% of
aggregate amount of items required
to be reported correctly
No limit

November 27, 2023 1298 Bulletin No. 2023–48
.60 Revocation or Denial of Passport
in Case of Certain Tax Delinquencies.
For calendar year 2024, the amount of a
serious delinquent tax debt under § 7345
is $62,000.
.61 Attorney Fee Awards. For fees
incurred in calendar year 2024, the attor-
ney fee award limitation under § 7430(c)
(1)(B)(iii) is $240 per hour.
.62 Periodic Payments Received Under
Qualified Long-Term Care Insurance
Contracts or Under Certain Life Insurance
Contracts. For calendar year 2024, the
stated dollar amount of the per diem lim-
itation under § 7702B(d)(4), regarding
periodic payments received under a qual-
ified long-term care insurance contract or
periodic payments received under a life
insurance contract that are treated as paid
by reason of the death of a chronically ill
individual, is $410.
.63 Qualified Small Employer Health
Reimbursement Arrangement. For tax-
able years beginning in 2024, to qualify
as a qualified small employer health reim-
bursement arrangement under § 9831(d),
the arrangement must provide that the total
amount of payments and reimbursements
for any year cannot exceed $6,150
($12,450 for family coverage).
SECTION 4. EFFECTIVE DATE
.01 General Rule. Except as provided
in section 4.02 of this revenue procedure,
this revenue procedure applies to taxable
years beginning in 2024.
.02 Calendar Year Rule. This reve-
nue procedure applies to transactions or
events occurring in calendar year 2024 for
purposes of sections 3.08 (rehabilitation
expenditures treated as separate new build-
ing), 3.09 (low-income housing credit),
3.14 (transportation mainline pipeline con-
struction industry optional expense sub-
stantiation rules for payments to employees
under accountable plans), 3.20 (private
activity bonds volume cap), 3.21 (loan
limits on agricultural bonds), 3.22 (general
arbitrage rebate rules), 3.23 (safe harbor
rules for broker commissions on guaran-
teed investment contracts or investments
purchased for a yield restricted defeasance
escrow), 3.37 (expatriation to avoid taxes),
3.40 (debt instruments arising out of sales
or exchanges), 3.41 (unified credit against
estate tax), 3.42 (valuation of qualified real
property in decedent’s gross estate), 3.43
(annual exclusion for gifts), 3.44 (tax on
arrow shafts), 3.45 (passenger air transpor-
tation excise tax), 3.46 (tax on certain uses
of crude oil and petroleum products), 3.49
(persons against whom a federal tax lien
is not valid), 3.50 (property exempt from
levy), 3.52 (interest on a certain portion of
the estate tax payable in installments), 3.60
(revocation or denial of passport in case
of certain tax delinquencies), 3.61 (attor-
ney fee awards), and 3.62 (periodic pay-
ments received under qualified long-term
care insurance contracts or under certain
life insurance contracts) of this revenue
procedure.
SECTION 5. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Kyle Walker of the Office
of Associate Chief Counsel (Income Tax
& Accounting). For further information
regarding this revenue procedure, contact
Mr. Walker at (202) 317-4718 (not a toll-
free number).

Bulletin No. 2023–48 i November 27, 2023
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion. It
is not used where a position in a prior rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR
—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.
—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

November 27, 2023 ii Bulletin No. 2023–48
Numerical Finding List
1
Bulletin 2023–48
Announcements:
2023-18, 2023-30 I.R.B. 366
2023-19, 2023-30 I.R.B. 367
2023-20, 2023-30 I.R.B. 368
2023-17, 2023-31 I.R.B. 412
2023-21, 2023-31 I.R.B. 413
2023-22, 2023-32 I.R.B. 429
2023-23, 2023-34 I.R.B. 569
2023-24, 2023-35 I.R.B. 661
2023-25, 2023-37 I.R.B. 821
2023-26, 2023-37 I.R.B. 822
2023-28, 2023-37 I.R.B. 823
2023-29, 2023-41 I.R.B. 1064
2023-30, 2023-45 I.R.B. 1236
2023-31, 2023-46 I.R.B. 1251
2023-32, 2023-47 I.R.B. 1258
2023-33, 2023-47 I.R.B. 1261
Notices:
2023-29, 2023-29 I.R.B. 1
2023-45, 2023-29 I.R.B. 317
2023-47, 2023-29 I.R.B. 318
2023-37, 2023-30 I.R.B. 359
2023-50, 2023-30 I.R.B. 361
2023-51, 2023-30 I.R.B. 362
2023-54, 2023-31 I.R.B. 382
2023-53, 2023-32 I.R.B. 424
2023-55, 2023-32 I.R.B. 427
2023-57, 2023-34 I.R.B. 560
2023-58, 2023-34 I.R.B. 563
2023-59, 2023-34 I.R.B. 564
2023-52, 2023-35 I.R.B. 650
2023-61, 2023-35 I.R.B. 651
2023-62, 2023-37 I.R.B. 817
2023-56, 2023-38 I.R.B. 824
2023-63, 2023-39 I.R.B. 919
2023-64, 2023-40 I.R.B. 974
2023-66, 2023-40 I.R.B. 992
2023-68, 2023-41 I.R.B. 1060
2023-65, 2023-42 I.R.B. 1067
2023-67, 2023-42 I.R.B. 1074
2023-69, 2023-42 I.R.B. 1079
2023-71, 2023-44 I.R.B. 1191
2023-70, 2023-45 I.R.B. 1228
2023-72, 2023-45 I.R.B. 1228
2023-73, 2023-45 I.R.B. 1232
2023-75, 2023-47 I.R.B. 1256
Proposed Regulations:
REG-124123-22, 2023-30 I.R.B. 369
REG-124930-21, 2023-31 I.R.B. 431
REG-120730-21, 2023-33 I.R.B. 491
REG-134420-10, 2023-34 I.R.B. 571
Proposed Regulations:—Continued
REG-109348-22, 2023-35 I.R.B. 662
REG-120727-21, 2023-36 I.R.B. 670
REG-122793-19, 2023-38 I.R.B. 829
REG-100908-23, 2023-39 I.R.B. 931
REG-115559-23, 2023-42 I.R.B. 1082
REG-106203-23, 2023-43 I.R.B. 1143
REG-113064-23, 2023-43 I.R.B. 1144
REG-117614-14, 2023-44 I.R.B. 1193
REG-127391-16, 2023-44 I.R.B. 1214
REG-103525-23, 2023-46 I.R.B. 1252
REG-115762-23, 2023-47 I.R.B. 1262
REG-120727-21, 2023-47 I.R.B. 1285
Revenue Procedures:
2023-31, 2023-25 I.R.B. 386
2023-26, 2023-33 I.R.B. 486
2023-27, 2023-35 I.R.B. 655
2023-17, 2023-37 I.R.B. 819
2023-30, 2023-40 I.R.B. 995
2023-31, 2023-40 I.R.B. 1057
2023-32, 2023-41 I.R.B. 1064
2023-35, 2023-42 I.R.B. 1079
2023-28, 2023-43 I.R.B. 1092
2023-33, 2023-43 I.R.B. 1135
2023-34, 2023-48 I.R.B. 1287
Revenue Rulings:
2023-13, 2023-32 I.R.B. 413
2023-14, 2023-33 I.R.B. 484
2023-15, 2023-34 I.R.B. 559
2023-15, 2023-34 I.R.B. 559
2023-16, 2023-37 I.R.B. 796
2023-17, 2023-37 I.R.B. 798
2023-18, 2023-40 I.R.B. 972
2023-19, 2023-41 I.R.B. 1059
2023-20, 2023-45 I.R.B. 1221
Treasury Decisions:
9976, 2023-30 I.R.B. 354
9977, 2023-31 I.R.B. 375
9978, 2023-32 I.R.B. 415
9979, 2023-35 I.R.B. 602
9980, 2023-43 I.R.B. 1087
9981, 2023-44 I.R.B. 1174
9982, 2023-45 I.R.B. 1223
9983, 2023-46 I.R.B. 1237
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 27, 2023.

Bulletin No. 2023–48 iii November 27, 2023
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2023–48
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 27, 2023.

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