SECTION 2. WHAT

CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2024-4?

.05 As part of the implementation of the Taxpayer First Act, Pub. L. 116-25, 133 Stat. 981 (2019), the Service and the Internal Revenue Service Independent Office of Appeals (Independent Office of Appeals) continue to review current policies and procedures and prior administrative pronouncements. As a result of this review, there may be additional updates to this revenue procedure or other forms of guidance.

In general .01 This revenue procedure is a general update of Rev. Proc. 2024-4, 2024-1 IRB 160, which sets forth general information about the types of advice provided by Employee Plans Rulings and Agreements; general procedures for letter ruling and determination letter requests; specific procedures for determination letter requests; and the user fees associated with advice requested from Employee Plans Rulings and Agreements. Procedures and user fees applicable to advice provided by the Commissioner, Tax Exempt and Government Entities, Exempt Organizations Office, are set forth in Rev. Proc. 2025-5, this Bulletin.

Changes made to Revenue Procedure 2024-4

.02 In addition to minor non-substantive changes, including changes to dates, cross references, and citations to other revenue procedures, the following changes have been made:

(1) Sections 12 and 30 have been revised to reflect the provisions of Rev. Proc. 2023-37.

(2) New section 12.08 has been added to clarify that the restatement rule in Rev. Proc. 2019-39 and Rev. Proc. 2016-37 continues to apply to all pre-approved plans.

(3) Section 27 has been revised to encourage use of Taxpayer Digital Communications Secure Messaging and the IRS Document Upload Tool for secure messaging and document sharing in relation to letter ruling requests.

(4) Section 30.07 has been revised to reflect that payment of user fees for pre-approved plan submissions must be made through www.pay.gov.

Bulletin No. 2025–1 171 December 30, 2024

(5) References have been removed throughout this revenue procedure relating to the procedures under Rev. Proc. 2013-22, 2013-18 IRB 985, for obtaining opinion and advisory letters for prototype plans and VS plans under § 403(b) with respect to an application submitted for Cycle 1, as these letters will not be issued after 2024 (unless there is an assumption of sponsorship of an approved § 403(b) prototype plan or volume submitter plan, or a change in name and/or address of a sponsor of an approved § 403(b) prototype plan or volume submitter plan, as described in section .05 or section .07 of Appendix A).

(6) Appendix F has been removed as it is no longer applicable (and Appendix G has been redesignated as Appendix F).