Revenue Procedure 2024-15 sets forth the Federal income tax treatment that may apply to certain legislatively authorized transactions entered into by a public utility to recover specified costs through a surcharge to customers within the utility’s service area. The transactions in question involve a securitization in which the issuance of debt instruments is by a qualifying State financing entity. The revenue procedure also modifies Rev. Proc. 2005-62, 2005-2 C.B. 507.

Revenue Procedure 2024-15 will be in IRB: 2024-12, dated March 18, 2024.