SECTION 4. QM — Internal Revenue Bulletin 2024-46

AND WRITTEN AGREEMENT

.01 Registration, Application, and Agreement with the IRS .

(1) General Overview . To become a QM as defined in § 25C(h)(3), a manufacturer of specified property must enter into an agreement with the IRS. Except as provided in section 4.02 of this revenue procedure, manufacturers are not QMs until they have entered into and attested to an agreement as described in section 4.01(2) and (3) of this revenue procedure that has been validated by the IRS.

(2) Manufacturer Registration and QM Written Agreement through IRS Energy Credits Online Portal . An individual representative of the manufacturer who is authorized to bind the manufacturer in matters involving agreements with the IRS (authorized representative) must register through the IRS Energy Credits Online Portal and provide the required information to complete the manufacturer’s application and enter into an agreement (QM Registration Application and Agreement) on the manufacturer’s behalf. The authorized representative will need an account on https://www.irs.gov to verify the manufacturer’s business tax information and to register the manufacturer. Help related to the IRS identity verification process can be found on the sign-in page or at www. irs.gov/registerhelp. The authorized representative must execute the manufacturer’s QM Registration Application and Agreement on the IRS Energy Credits Online

Portal. Specifically, the representative must provide the following information and make the following certifications:

(a) The manufacturer’s name and business address;

(b) The authorized representative’s telephone number and email address;

(d) A listing of the categories of specified property that the manufacturer produces or intends to produce. (The application will provide a menu of property categories from which the manufacturer must select one or more categories.);

(e) A certification that the manufacturer produces specified property as defined in § 25C(h)(4);

(f) A certification that the manufacturer agrees to assign a PIN to each item of specified property produced by such manufacturer using the methodology described in section 5 of this revenue procedure (or any successor guidance), that the manufacturer agrees to label each item of specified property with a PIN in the manner described in section 6 of this revenue procedure (or any successor guidance), and that the manufacturer agrees to submit required periodic written reports to the IRS of the PINs assigned in the manner described in section 7 of this revenue procedure (or any successor guidance);

(g) If the manufacturer is filing as part of a consolidated group, the name and EIN of the corporation filing the consolidated income tax return; and

(h) Such other information and certifications that the IRS Energy Credits Online Portal may require. The IRS may update the required information and certifications in guidance, on https://www.irs.gov, or via the IRS Energy Credits Online Portal.

(3) Penalties of Perjury . The authorized representative must sign the QM Registration Application and Agreement, and also must include the following statement, signed under penalties of perjury: “Under penalties of perjury, I declare that I have examined this QM Registration Application and Agreement, including any and all accompanying documents, and to the best of my knowledge, the facts pre

sented in this application are true, correct, and complete.” The authorized representative must execute this signature electronically within the IRS Energy Credits Online Portal.

(4) Requirement for Multiple Manufac- turers .

(a) In general . If more than one manufacturer participates in the production of the same product that is specified property, only one manufacturer may be the QM with respect to such product. Only the manufacturer whose production results in the product becoming specified property must register with the IRS to become a QM with respect to such property, absent an agreement otherwise among such manufacturers providing that a different one of the manufacturers is required to register with the IRS to become a QM with respect to the property. Any manufacturer that agrees to become a QM with respect to the property must retain a copy of the agreement in the manufacturer’s books and records.

(b) Example . Manufacturers A and B are in involved in the production of a glass window. In the chain of production, A cuts the glass to the desired dimensions, and cleans and seals the panes of glass. B cuts and welds the frames. A then assembles the frames and glass into an exterior window that meets the requirements of specified property. Because A’s process of assembling the frames and glass results in the window becoming specified property, absent an agreement between A and B under which B is required to register with the IRS to become a QM with respect to the window, A must enter into an agreement with the IRS to become the QM with respect to the window.

(5) Special Requirement for Manu- facturers of Enabling Property . A manufacturer that produces enabling property ² must follow the registration, application, and written agreement process described in this section 4, even if the manufacturer produces no other type of specified property, despite modified requirements with respect to enabling property elsewhere in this revenue procedure.

(6) Special Requirements for Certain Manufacturers of Heat Pumps . A manu

2 Defined in § 1.25C-1(b)(6) of the proposed regulations.

Bulletin No. 2024–46 1115 November 12, 2024

facturer that produces only the indoor unit of a heat pump, but does not manufacture outdoor units of a heat pump, must follow the registration, application, and written agreement process described in this section 4, even if the manufacturer produces no other type of specified property, despite modified requirements with respect to heat pumps elsewhere in this revenue procedure.

(7) Validation . After the manufacturer submits a complete QM Registration Application and Agreement through the IRS Energy Credits Online Portal, the IRS will validate the QM Registration Application and Agreement, taking into account the manufacturer’s North American Industry Classification System (NAICS) Code. In the event the manufacturer fails the validation process, or the IRS requires missing or supplemental information or certifications, the IRS will contact the manufacturer’s authorized representative.

(8) Acceptance, QM Code and List of QMs . After reviewing a manufacturer’s QM Registration Application and Agreement, the IRS will notify the manufacturer if the manufacturer’s registration is accepted or rejected. If the IRS accepts the QM Registration Application and Agreement, the IRS will send a certification to the manufacturer’s authorized representative through the IRS Energy Credits Online Portal. The IRS also will assign and issue a unique 4-character QM Code to the manufacturer through the IRS Energy Credits Online Portal. The IRS will publish a list of QMs and the date that their application was accepted on https://www. irs.gov. Except as provided in section 4.02 of this revenue procedure, no § 25C credit is allowed for any specified property produced by a manufacturer prior to the date that the IRS accepts a manufacturer as a QM, as such property is not considered produced by a QM under § 25C(h)(1)(A). Any manufacturer entering into a QM Registration Application and Agreement agrees to have its name listed as a QM on https://www.irs.gov.

.02 Special Registration Procedure for 2025 . Any manufacturer that submits its QM Registration Application and Agreement by April 30, 2025, will be deemed to have been a QM as of December 31,

2024, provided such QM Registration Application and Agreement is validated by the IRS. Accordingly, for a manufacturer that meets the requirements of the Special Registration Procedure for 2025, any specified property produced by such manufacturer on or after January 1, 2025, and on or before April 30, 2025, will be deemed to have been produced by a QM.

.03 Suspension or Revocation of Reg- istration . The IRS may suspend or revoke a QM registration in the IRS’s sole discretion if the IRS concludes that the manufacturer is not in compliance with the PIN assignment requirement in section 5 of this revenue procedure, the PIN labeling requirement in section 6 of this revenue procedure, or the periodic written report requirement in section 7 of this revenue procedure, or other QM requirements published in the Internal Revenue Bulletin, on https://www.irs.gov, or via the IRS Energy Credits Online Portal. The IRS will notify the manufacturer’s authorized representative that the QM registration has been suspended or revoked. The list of QMs published by the IRS will be updated to reflect suspensions and revocations.

.04 Administrative Review of a Rejec- tion, Suspension or Revocation of QM sta- tus . If the IRS rejects a QM Registration Application and Agreement or if the IRS revokes or suspends a manufacturer’s QM registration status, then the manufacturer may request administrative review of the IRS’s determination by the IRS. During the period that such review is pending, the manufacturer will not be a QM. Any IRS determination relating to the rejection of a QM Registration Application and Agreement, or the revocation or suspension of a manufacturer’s QM registration status is not subject to administrative appeal to the IRS Independent Office of Appeals.

.05 Voluntary Discontinuance of QM status . A QM may discontinue its QM status by sending a secure message to the IRS through the IRS Energy Credits Online Portal and filing a final QM Report, as provided in section 7.12 of this revenue procedure. The secure message must state that the QM is terminating its QM status and provide the date that the final QM Report will be filed. The IRS will process such requests, and

the QM’s status will be discontinued as of the date the final QM report is filed through the IRS Energy Credits Online Portal. A QM that discontinues its QM status will no longer be included on the list of QMs published by the IRS. The IRS will publicize discontinued QM status information on https://www.irs.gov. All PINs reported in the final QM Report, or in QM Reports filed previously by the QM, will continue to be valid PINs for purposes of the § 25C credit despite the discontinued QM status.