Bulletin No. 2025–26

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–26

June 23, 2025

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.

EXEMPT ORGANIZATIONS

Announcement 2025-17, page 1620.

The Internal Revenue Service has revoked its determination

that Little Kings and Queens Inc. qualifies as an organization

described in sections 501(c)(3) and 170(c)(2) of the Internal

Revenue Code of 1986. The revocation is effective January

1, 2020

Announcement 2025-18, page 1621.

Revocation of IRC 501(c)(3) Organizations for failure to meet

the code section requirements. Contributions made to the

organizations by individual donors are no longer deductible

under IRC 170(b)(1)(A).

TAX CONVENTIONS

Notice 2025-27, page 1611.

This notice provides interim guidance regarding the application of the corporate alternative minimum tax, as added to

Finding Lists begin on page ii.

title 26 of the United States Code (Internal Revenue Code) by

the Inflation Reduction Act of 2022. Specifically, this notice

provides an optional simplified method for determining applicable corporation status under § 59(k) of the Internal Revenue Code. This notice also waives certain additions to tax

under § 6655 with respect to a corporation’s CAMT liability

under § 55.

Notice 2025-30, page 1615.

This notice publishes the inflation adjustment factor and

reference price for calendar year 2025 for the renewable

electricity production credit under section 45 of the Internal

Revenue Code. The 2025 inflation adjustment factor and

reference price are used in determining the availability of

the credit and apply to calendar year 2025 sales of kilowatt hours of electricity produced in the United States or a

possession thereof from qualified energy resources. This

notice also provides the credit amounts for calendar year

2025 under section 45.

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 official 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 substantive 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 otherwise indicated. Procedures relating solely to matters of internal 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 rulings 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, disbarment 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.

June 23, 2025 

Bulletin No. 2025–26

Part III

Interim Simplified Method

for Determining Applicable

Corporation Status; Waiver

of Certain Additions to Tax

under Section 6655

Notice 2025-27

SECTION 1. OVERVIEW

This notice provides interim guidance

regarding the application of the corporate

alternative minimum tax (CAMT) and

relief from certain additions to tax for an

applicable corporation’s underpayment of

estimated tax under § 6655 of the Internal Revenue Code (Code).1 Section 3 of

this notice provides an optional simplified

method for determining applicable corporation status (interim simplified method).

Section 4 of this notice waives certain

additions to tax under § 6655 with respect

to a corporation’s CAMT liability under

§ 55.

Prior to the publication of any final

regulations relating to the CAMT, the

Department of the Treasury (Treasury

Department) and the Internal Revenue

Service (IRS) intend to issue a notice

of proposed rulemaking that revises the

CAMT proposed regulations described

in section 2.02(2) of this notice to

include a method for determining applicable corporation status similar to the

interim simplified method as well as

other revisions.

SECTION 2. BACKGROUND

.01 Overview of the CAMT. Section

10101 of Public Law 117-169, 136 Stat.

1818, 1818-1828 (August 16, 2022),

commonly referred to as the Inflation

Reduction Act of 2022, amended § 55 to

impose the CAMT based on the “adjusted

financial statement income” (AFSI) of an

“applicable corporation” for taxable years

beginning after December 31, 2022. The

definition of “applicable corporation” is

1

provided in § 59(k)(1) and described in

section 2.03 of this notice. Section 55(a)

provides that, for the taxable year of an

applicable corporation, the amount of

CAMT imposed by § 55 equals the excess

(if any) of (i) the tentative minimum tax

for the taxable year, over (ii) the sum of the

regular tax, as defined in § 55(c), for the

taxable year plus the tax imposed under

§ 59A. Section 55(b)(2)(A) provides that,

in the case of an applicable corporation,

the tentative minimum tax for the taxable

year is the excess of (i) 15 percent of AFSI

for the taxable year (as determined under

§ 56A), over (ii) the CAMT foreign tax

credit for the taxable year (as determined

under § 59(l)). In the case of any corporation that is not an applicable corporation,

§ 55(b)(2)(B) provides that the tentative

minimum tax for the taxable year is zero.

.02 Prior guidance relating to the

CAMT.

(1) Prior notices. Notice 2023-7,

2023-3 I.R.B. 390 (January 17, 2023),

announced that the Treasury Department

and the IRS intended to issue proposed

regulations addressing the application

of the CAMT. Notice 2023-7 provided

interim guidance on certain issues relating to the CAMT, including the treatment of certain Federal income tax credits under the CAMT and a safe harbor

method for determining whether a corporation is an applicable corporation subject to the CAMT. Notice 2023-20, 202310 I.R.B. 523 (March 6, 2023), Notice

2023-64, 2023-40 I.R.B. 974 (October

2, 2023), and Notice 2024-10, 2024-3

I.R.B. 406 (January 16, 2024), provided

additional interim guidance to further

clarify the application of the CAMT. Taxpayers may generally rely on the interim

guidance provided in Notice 2023-7,

Notice 2023-20, and Notice 2023-64 for

taxable years ending on or before September 13, 2024. Taxpayers may rely on

Notice 2024-10 for “Covered CFC Distributions” (as defined therein) received

on or before September 13, 2024, and

the rules for determining the applicable

financial statement (AFS) of a tax con-

solidated group for taxable years ending

before September 13, 2024.

(2) CAMT Proposed Regulations. On

September 13, 2024, the Treasury Department and the IRS published a notice of

proposed rulemaking (REG-112129-23)

in the Federal Register (89 F.R. 75062)

containing proposed regulations addressing the application of the CAMT (CAMT

Proposed Regulations). Proposed § 1.592(g) of the CAMT Proposed Regulations

would provide a simplified method for

determining applicable corporation status. The CAMT Proposed Regulations

also provide reliance rules, which are

described in section 2.06 of this notice.

On December 26, 2024, the Treasury

Department and the IRS published in the

Federal Register (89 F.R. 104909) technical corrections to the CAMT Proposed

Regulations. Numerous comments were

submitted in response to the CAMT Proposed Regulations, which the Treasury

Department and the IRS continue to consider and study.

.03 Definition of applicable corporation.

(1) Applicable corporation. Section

59(k)(1)(A) provides that, for purposes

of §§ 55 through 59, the term “applicable corporation” means, with respect to

any taxable year, any corporation (other

than an S corporation, a regulated investment company, or a real estate investment

trust) that meets either of the two average

annual AFSI tests provided in § 59(k)(1)

(B), for one or more taxable years that

(1) are prior to that taxable year and (2)

end after December 31, 2021.

(2) Average annual AFSI tests. The

“general AFSI test” of § 59(k)(1)(B)(i)

(described in section 2.03(2)(a) of this

notice) and the “FPMG AFSI test” of

§ 59(k)(1)(B)(ii) (described in section

2.03(2)(b) of this notice) are collectively

referred to as “the average annual AFSI

tests” in this notice.

(a) General AFSI test. Under the general AFSI test of § 59(k)(1)(B)(i), if a corporation is not a member of a foreign-parented multinational group (FPMG) (as

Unless otherwise specified, all "section" or "§" references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

Bulletin No. 2025–26

1611

June 23, 2025

defined in § 59(k)(2)(B)) for any taxable

year, the corporation meets the average

annual AFSI test for a taxable year if its

average annual AFSI (determined without

regard to the adjustment under § 56A(d)

for financial statement net operating losses

(FSNOLs)) for the 3-taxable-year period

ending with such taxable year exceeds

$1 billion.

(b) FPMG AFSI test. Under the FPMG

AFSI test of § 59(k)(1)(B)(ii), if a corporation is a member of an FPMG for any

taxable year, the corporation meets the

average annual AFSI test if—

(i) the corporation meets the general

AFSI test for the taxable year (determined

after applying the FPMG rule in § 59(k)

(2)), and

(ii) the average annual AFSI of the corporation (determined without regard to

the FPMG rule in § 59(k)(2) and without

regard to the adjustment under § 56(d) for

FSNOLs) for the 3-taxable-year period

ending with such taxable year is $100 million or more.

(3) Proposed § 1.59-2. Proposed

§ 1.59-2 would provide rules under

§ 59(k) for determining whether a corporation is an applicable corporation for

purposes of §§ 55 through 59. Proposed

§ 1.59-2(c) would provide general rules

regarding the average annual AFSI tests

under § 59(k)(1)(B) and for determining

AFSI for purposes of these tests.

.04 Definition of AFSI and adjustments

relevant to interim simplified method.

(1) Definition of AFSI. For purposes

of §§ 55 through 59, the term “AFSI”

means, with respect to any corporation

for any taxable year, the net income

or loss of the taxpayer set forth on the

taxpayer’s AFS for that taxable year,

adjusted as provided in § 56A. Section

56A(c) provides general adjustments to

be made to AFSI. Section 56A(c)(15)

authorizes the Secretary of the Treasury

or the Secretary’s delegate (Secretary)

to issue regulations or other guidance

to provide for such adjustments to AFSI

as the Secretary determines necessary to

carry out the purposes of § 56A.

(2) AFSI adjustments for certain Federal and foreign income taxes. Section

56A(c)(5) provides the general rule that

AFSI is appropriately adjusted to disregard any Federal income taxes, or income,

June 23, 2025

war profits, or excess profits taxes (within

the meaning of § 901) with respect to a foreign country or possession of the United

States, which are taken into account on the

taxpayer’s AFS. Proposed § 1.56A-8(b)

would provide general rules for adjusting AFSI for certain income taxes under

§ 56A(c)(5).

(3) AFSI adjustments with respect

to certain tax credits. Section 56A(c)

(9) requires AFSI to be appropriately

adjusted to disregard any amount treated

as a payment against the Federal income

tax pursuant to an election under § 48D(d)

or § 6417 and included in the net income

or loss set forth on the taxpayer’s AFS.

However, if such amount is otherwise

disregarded under the adjustment rule in

§ 56A(c)(5), the adjustment in § 56A(c)

(9) does not apply. Consistent with

§ 56A(c)(9), and pursuant to the authority

granted by § 56A(c)(15) and (e), proposed

§ 1.56A-12 would provide that AFSI is

adjusted to disregard any amount treated

as a payment against the tax imposed by

subtitle A of the Code pursuant to an election under § 48D(d) or § 6417 and any

amount received from the transfer of an

eligible credit that is not included in the

gross income of the CAMT entity under

§ 6418(b) or that is treated as tax-exempt

income under § 6418(c)(1)(A), to the

extent the amount is not otherwise disregarded under proposed § 1.56A-8, among

other AFSI adjustments.

(4) AFSI adjustments for tax-exempt

entities. Section 56A(c)(12) requires AFSI

to be appropriately adjusted, in the case of

an organization subject to tax under § 511,

to take into account only AFSI (i) of an

unrelated trade or business of such organization, as defined in § 513, or (ii) derived

from debt-financed property, as defined

in § 514, to the extent that income from

such property is treated as unrelated business taxable income. Proposed § 1.56A14 would provide rules implementing

§ 56A(c)(12).

.05 Simplified method for determining

applicable corporation status.

(1) Section 59(k)(3)(A) authorizes the

Secretary to issue regulations or other

guidance providing a simplified method

for determining whether a corporation is

an applicable corporation subject to the

CAMT.

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(2) Under that authority, proposed

§ 1.59-2(g) would provide a simplified

method for determining applicable corporation status, which is generally consistent with section 5 of Notice 2023-7. Proposed § 1.59-2(g)(2) would provide that,

under the simplified method, the average

annual AFSI tests are applied with specified modifications. First, the simplified

method thresholds used for the average

annual AFSI tests in § 59(k)(1)(B) would

be reduced from $1 billion to $500 million and from $100 million to $50 million,

respectively. In addition, proposed § 1.592(g)(2)(iii)(B), as corrected, would provide that, in determining AFSI under the

simplified method, the only adjustments

made are those in proposed § 1.56A-8(b)

(concerning taxes) and proposed § 1.56A14 (concerning tax-exempt entities) and,

solely for purposes of the $100 million

second prong of the FPMG AFSI test,

proposed § 1.56A-7 (regarding adjustment for income effectively connected to

a United States trade or business). Further, in determining the AFSI of a person

whose financial results are reflected on a

consolidated AFS, those members of a test

group whose financial results are reflected

on the consolidated AFS would be treated

as a single CAMT entity for purposes of

proposed § 1.56A-1(c)(3) and (4) so that

consolidation entries would be taken into

account, except for those consolidation

entries that eliminate transactions between

persons that are treated as neither a single

employer under § 52(a) or (b) nor members of an FPMG. See proposed § 1.592(g)(2)(iii)(A). Finally, the simplified

method would permit a corporation that

has an AFS year that differs from its taxable year to determine its AFSI by using

its AFS year. See proposed § 1.59-2(g)(2)

(iv).

(3) Comments submitted in response

to the simplified method provided under

proposed § 1.59-2(g) have generally recommended raising the thresholds for the

simplified method under proposed § 1.592(g) in order to reduce potential compliance burdens for corporations that exceed

the thresholds but are not expected to be

applicable corporations. The comments

indicated that such corporations are currently required to determine applicable

corporation status by applying the average

Bulletin No. 2025–26

annual AFSI tests under § 59(k)(1)(B) or

proposed § 1.59-2(c), and to comply with

applicable reporting requirements, as they

do not satisfy the simplified method in

proposed § 1.59-2(g).

(4) In addition, comments submitted in

response to the simplified method provided

under proposed § 1.59-2(g) requested that

the adjustments to AFSI for certain tax

credits under proposed § 1.56A-12, which

apply for purposes of calculating AFSI for

determining applicable corporation status

under proposed § 1.59-2(c), should also

apply when calculating AFSI under the

simplified method in proposed § 1.59-2(g)

(2). The comments noted that the exclusion

of the AFSI adjustments under proposed

§ 1.56A-12 from the calculation of AFSI

under the simplified method in proposed

§ 1.59-2(g)(2) could cause certain corporations that are not expected to be applicable corporations to exceed the thresholds

in the proposed simplified method and,

accordingly, to bear increased compliance

burdens and higher compliance costs to

calculate AFSI under the average annual

AFSI tests in § 59(k)(1)(B) or proposed

§ 1.59-2(c) and to comply with applicable

reporting requirements.

.06 Proposed applicability dates and

reliance on the CAMT Proposed Regulations. Proposed § 1.59-2 and other

“specified regulations” (as defined in

the Proposed Applicability Dates and

Reliance on the Proposed Regulations

section of the preamble to the CAMT

Proposed Regulations) are proposed to

apply to taxable years ending after September 13, 2024. In addition, the CAMT

Proposed Regulations provide that a taxpayer may rely on proposed § 1.59-2 and

other specified regulations for any taxable year ending on or before September

13, 2024, provided that the taxpayer, and

each member of its test group determined

under proposed § 1.59-2 for that taxable

year, consistently follow all of the specified regulations (and other enumerated

proposed rules) in their entirety for that

taxable year and each subsequent taxable

year until the first taxable year to which

the final regulations are applicable. In

addition, taxpayers may rely on one or

more other sections of the CAMT Proposed Regulations for any taxable years

ending on or before the date the CAMT

Bulletin No. 2025–26

Proposed Regulations are published as

final in the Federal Register, provided

that the taxpayer and each member of

its test group for the taxable year consistently follow that section in its entirety

and also follow all of the specified regulations (and other enumerated proposed

rules) in their entirety in that taxable year

and each subsequent taxable year until

the first taxable year that final regulations

are applicable.

.07 Estimated taxes.

(1) Section 6655(a) imposes an addition to tax for failure by a corporation

to make a sufficient and timely payment of estimated income tax. Section

6655(c) and (d)(1)(A) generally provide that, in the case of a corporation,

estimated income tax is required to be

paid in four installments and the amount

of any required installment is 25 percent of the required annual payment.

Generally, under § 6655(d)(1)(B), the

required annual payment is the lesser of

two amounts described in § 6655(d)(1)

(B)(i) and (ii). The amount described in

§ 6655(d)(1)(B)(i) is 100 percent of the

tax shown on the return for the taxable

year. The amount described in § 6655(d)

(1)(B)(ii) is 100 percent of the tax shown

on the taxpayer’s return for the preceding taxable year, so long as the preceding

taxable year was a full twelve months

long and the return for such year showed

a liability for tax. However, pursuant to

§ 6655(d)(2), in the case of a large corporation (as defined under § 6655(g)(2)),

the amount described in § 6655(d)(1)(B)

(ii) may not be used to reduce the amount

of an installment payment other than the

first installment payment for the taxable

year. In special circumstances, other

rules specified in § 6655 or elsewhere

may also apply.

(2) On June 7, 2023, the Treasury

Department and the IRS issued Notice

2023-42, 2023-26 I.R.B. 1085, which provided a waiver of the addition to tax under

§ 6655 with respect to a corporation’s

CAMT liability under § 55 for any taxable

year that begins after December 31, 2022,

and before January 1, 2024.

(3) On April 15, 2024, the Treasury

Department and the IRS issued Notice

2024-33, 2024-18 I.R.B. 959, which provided a limited waiver of the addition to

1613

tax under § 6655 to the extent the amount

of any underpayment is attributable to a

portion of a corporation’s CAMT liability. The relief provided in Notice 2024-33

applied only for the purpose of calculating

the installment of estimated tax by a corporate taxpayer that was due on or before

April 15, 2024, or May 15, 2024 (in the

case of a fiscal year taxpayer with a taxable year beginning in February 2024),

with respect to a taxable year that began

in 2024.

(4) On June 13, 2024, the Treasury

Department and the IRS issued Notice

2024-47, 2024-27 I.R.B. 1, which

extended the relief provided in Notice

2024-33. Under Notice 2024-47, the limited waiver of the addition to tax under

§ 6655 provided by Notice 2024-33 was

extended to apply for the purpose of calculating any installment of estimated tax

by a corporate taxpayer that was due on or

before August 15, 2024, with respect to a

taxable year that began in 2024.

(5) Finally, on September 12, 2024,

the Treasury Department and the IRS

issued Notice 2024-66, 2024-40 I.R.B.

682, which provided a waiver of the addition to tax under § 6655 with respect to

a corporation’s CAMT liability under

§ 55 for any taxable year that begins after

December 31, 2023, and before January 1,

2025. Notice 2024-66 also incorporated

the relief provided in Notice 2024-33

and Notice 2024-47 and obsoleted those

notices.

SECTION 3. INTERIM SIMPLIFIED

METHOD

.01 Purpose of the interim guidance.

To reduce compliance burdens and costs

for certain corporations, this section 3

provides an interim simplified method to

determine applicable corporation status

using thresholds of $800 million and $80

million and calculating AFSI by using the

AFSI adjustments described in proposed

§ 1.56A-12 as well as other AFSI adjustments.

.02 Definition of AFS Consolidation

Entries. For purposes of this section 3, the

term “AFS Consolidation Entries” means

the financial accounting journal entries

that are made in preparing a consolidated

financial statement for a financial state-

June 23, 2025

ment group in order to present the financial results of that group as if all members of the group were a single economic

entity, including journal entries:

(1) To eliminate the effect of transactions between members of the financial

statement group;

(2) To report amounts that are not

recorded in the separate books and records

of one or more members of the financial

statement group; and

(3) To correct or otherwise adjust

amounts that are reported in the separate

books and records of one or more members of the financial statement group.

.03 Interim simplified method for determining applicable corporation status.

(1) Interim simplified method. A corporation may apply the interim simplified

method described in this section 3.03 for

purposes of determining whether it is an

applicable corporation under § 59(k)(1).

Under the interim simplified method, a

corporation determines whether it is an

applicable corporation by applying the

rules in § 59(k)(1) and (2) with the following modifications:

(a) The general AFSI test in § 59(k)(1)

(B)(i) (including for purposes of § 59(k)

(1)(B)(ii)(I)) is applied by substituting

“$800,000,000” for “$1,000,000,000.”

(b) The second prong of the FPMG

AFSI test in § 59(k)(1)(B)(ii)(II) is

applied by substituting “$80,000,000” for

“$100,000,000.”

(2) Rules for determining AFSI. For

purposes of this section 3.03, AFSI is

determined—

(a) Except as provided in section

3.03(2)(c) of this notice,

(i) with regard to the adjustments set

forth in § 56A(c)(2)(A), (c)(2)(B), (c)

(5), (c)(9), and (c)(12) and, solely for purposes of applying § 59(k)(1)(B)(ii)(II), the

adjustment set forth in § 56A(c)(4), and

(ii) without regard to any other adjustments set forth in § 56A(c) and (d),

(b) By adjusting AFSI to disregard (to

the extent not already disregarded under

§ 56A(c)(9)):

(i) Any amount received from the

transfer of an eligible credit, as defined in

§ 6418(f)(1)(A), that is not includible in the

gross income of the taxpayer by application of § 6418(b) or is treated as tax exempt

under § 6418(c)(1)(A), provided that such

June 23, 2025

amount (or portion thereof) is not otherwise disregarded under § 56A(c)(5),

(ii) Any amount received pursuant to

an election under §§ 48D(d)(2) or 6417(c)

that is treated as tax exempt income under

§ 48D(d)(2)(A)(i)(III) or 6417(c)(1)(C),

provided that such amount is not otherwise disregarded under § 56A(c)(5),

(iii) Any amount paid by the transferee

taxpayer, as defined in § 6418(a), to the

eligible taxpayer, as defined in § 6418(f)

(2), as consideration for the transfer of the

eligible tax credit, as defined in § 6418(f)

(1)(A), provided that the amount is not

otherwise disregarded under § 56A(c)(5),

and

(iv) Any increase in the transferee taxpayer’s net income or loss set forth on the

taxpayer’s AFS resulting from the utilization of the eligible tax credit, provided

that the increase is not otherwise disregarded under § 56A(c)(5), and

(c) After taking into account AFS Consolidation Entries, except those that eliminate transactions between persons not

treated as a single employer under § 52(a)

or between entities not included in an

FPMG, as applicable.

(3) AFS year different than taxable year.

For purposes of this section 3.03, if a corporation has an AFS that covers a period (AFS

year) that differs from its taxable year—

(a) Section 59(k)(1)(B)(i) and (ii)(II)

are applied by substituting “3-AFS-year

period ending during such taxable year”

for “3-taxable-year-period ending with

such taxable year” in each place those

phrases appear, and

(b) Section 59(k)(1)(E) is applied by

substituting “AFS year” for “taxable year”

and “3-AFS years” for “3-taxable years”

in each place those phrases appear.

.04 Effect of exceeding the thresholds

under the interim simplified method. If a

corporation applies the interim simplified

method described in section 3.03 of this

notice for a taxable year and determines

that its AFSI (as determined under section

3.03 of this notice) exceeds the relevant

interim simplified method thresholds, then

the corporation will be an applicable corporation for such taxable year only if it is

determined to be an applicable corporation under § 59(k)(1) or, if the corporation

follows the CAMT Proposed Regulations,

proposed § 1.59-2(c).

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.05 Applicability dates and reliance.

A corporation may use the interim simplified method provided in section 3.03

of this notice for determining applicable corporation status for any taxable

year ending on or before the date that a

Treasury Decision adopting a simplified

method pursuant to § 59(k)(3)(A) is published in the Federal Register and for

which the original Federal income tax

return has not been filed as of June 23,

2025. A corporation’s use of the interim

simplified method to determine that it is

not an applicable corporation for a taxable year will not cause the corporation

to become subject to, or to violate, the

reliance rules, including the consistency

requirements, provided in the preamble

of the CAMT Proposed Regulations for

such taxable year.

.06 Instructions to be modified. The

instructions to Form 4626, Alternative

Minimum Tax – Corporations and Schedule K of Form 1120, U.S. Corporation

Income Tax Return (or other appropriate

instructions in the Form 1120 series),

will be modified, as necessary, to reflect

the availability of the interim simplified

method provided in section 3.03 of this

notice. The modified instructions will be

posted on https://www.irs.gov.

SECTION 4. LIMITED WAIVER OF

ADDITION TO TAX

.01 Waiver. In light of the continued

uncertainty with respect to tax positions

determined by applicable corporations

following the publication of the CAMT

Proposed Regulations, and in the interest

of sound tax administration, the IRS will

waive the addition to tax under § 6655

with respect to a corporation’s CAMT

liability under § 55 for any taxable year

that begins after December 31, 2024, and

before January 1, 2026 (Covered CAMT

Year). Accordingly, for a Covered CAMT

Year, a corporation’s required installments of estimated tax need not include

amounts attributable to its CAMT liability under § 55 to prevent the imposition

of an addition to tax under § 6655. If a

corporation fails to timely pay its CAMT

liability under § 55 when due, other sections of the Code may apply; for example, additions to tax could be imposed

Bulletin No. 2025–26

under § 6651 if payment of the CAMT

liability is not made by the due date

(without regard to any extension) of the

corporation’s return.

.02 Instructions to be modified. The

instructions to Form 2220, Underpayment of Estimated Tax by Corporations,

will be modified, as necessary, to clarify

that no addition to tax will be imposed

under § 6655 based on a corporation’s

failure to make an estimated tax payment

of its CAMT liability under § 55 for any

Covered CAMT Year, and that a taxpayer

may exclude such amounts when calculating the amount of its required annual

payment on Form 2220. The modified

instructions will be posted on https://

www.irs.gov.

.03 Instructions to avoid penalty

notice. Taxpayers seeking the relief provided in this notice (affected taxpayers)

must file Form 2220 with their Federal

income tax return, even if they owe no

estimated tax penalty. The Form 2220

must be completed without including

the CAMT liability from Schedule J of

Form 1120, U.S. Corporation Income

Tax Return (or other appropriate line of

the corporation’s income tax return in the

Form 1120 series). Affected taxpayers

must also include an amount of estimated

tax penalty on Line 34 of their Form 1120

(or other appropriate line of the corporation’s income tax return in the Form

1120 series), even if that amount is zero.

Failure to follow these instructions could

result in affected taxpayers receiving a

penalty notice that will require an abatement request to apply the relief provided

by this notice.

.04 Applicability. The waiver of

the addition to tax imposed by § 6655

described in section 4.01 of this notice

applies for any Covered CAMT Year.

SECTION 5. ADDITIONAL

INTERIM GUIDANCE AND

REGULATIONS

.01 The Treasury Department and the

IRS intend to issue additional interim

guidance regarding application of the

CAMT to respond to other comments submitted in response to the CAMT Proposed

Bulletin No. 2025–26

Regulations. The Treasury Department

and the IRS anticipate that the additional

interim guidance will address several

issues, including among others:

(1) the interaction of the CAMT and

the tonnage tax regime enacted by the

American Jobs Creation Act of 2004, Public Law 108-357, 118 Stat. 1418 (October

22, 2004),

(2) how unrealized gains and losses

on certain investment assets reported for

financial statement purposes are taken

into account for purposes of determining

AFSI,

(3) alternative rules for determining a

partner’s distributive share of partnership

AFSI,

(4) AFSI adjustments resulting from

certain transactions between a partner and

partnership,

(5) AFSI adjustments resulting from

certain corporate transactions, and

(6) alternative rules for early reliance

on the CAMT Proposed Regulations.

.02 The Treasury Department and the

IRS anticipate that new proposed regulations issued to revise the CAMT Proposed

Regulations will incorporate rules similar

to the interim simplified method described

in section 3 of this notice, the additional

interim guidance addressing the issues

described in section 5.01(1) through (6) of

this notice, and other issues described in

interim guidance.

SECTION 6. DRAFTING AND

CONTACT INFORMATION

The principal authors of this notice

are Madeline Padner of the Office of the

Associate Chief Counsel (Income Tax

and Accounting) and Alexander Wu of

the Office of the Associate Chief Counsel

(Procedure and Administration). Other

personnel from the Treasury Department

and the IRS participated in its development. For further information regarding

section 3 of this notice, please contact

Madeline Padner at (202) 317-7006 (not a

toll-free number). For further information

regarding section 4 of this notice, please

contact Alexander Wu at (202) 317-6845

(not a toll-free number).

1615

Credit for Renewable

Electricity Production and

Publication of Inflation

Adjustment Factor and

Reference Price for

Calendar Year 2025

Notice 2025-30

This notice publishes the inflation

adjustment factor and reference price for

calendar year 2025 for the renewable electricity production credit under section 45

of the Internal Revenue Code (section 45

credit). The 2025 inflation adjustment factor and reference price are used in determining the availability of the credit and

apply to calendar year 2025 sales of kilowatt hours of electricity produced in the

United States or a possession thereof from

qualified energy resources.

BACKGROUND

Section 45 was amended by section

13101 of Public Law 117-169, 136 Stat.

1818 (August 16, 2022), commonly

known as the Inflation Reduction Act of

2022 (IRA). The IRA changed the manner

in which the section 45 credit amounts are

calculated for any qualified facility placed

in service after December 31, 2021.

As amended by the IRA, section 45(b)

(6)(A) provides that, in the case of any

qualified facility that satisfies the requirements of section 45(b)(6)(B), the credit

amount determined under section 45(a)

(determined after the application of section 45(b)(1) through (5) and without

regard to section 45(b)(6)) is equal to

such amount multiplied by 5. A qualified

facility satisfies the requirements of section 45(b)(6)(B) if it is placed in service

after December 31, 2021, and it is one of

the following: (i) a facility with a maximum net output of less than 1 megawatt

(as measured in alternating current); (ii)

a facility the construction of which began

prior to January 29, 2023, which is the

date that is 60 days after the publication of

the guidance with respect to the require-

June 23, 2025

ments of section 45(b)(7)(A) (prevailing

wage requirements) and section 45(b)(8)

(apprenticeship requirements);1 or (iii) a

facility that satisfies the requirements of

section 45(b)(7)(A) and (8). The IRA also

added bonus credit amounts with respect

to qualified facilities placed in service after

December 31, 2022, that meet domestic

content requirements under section 45(b)

(9)2 or energy community requirements

under section 45(b)(11).3

The IRA amended the phaseout of the

section 45 credit for wind facilities under

section 45(b)(5) such that it does not apply

to facilities placed in service after December 31, 2021. The IRA also added a new

phaseout of the section 45 credit under

section 45(b)(10) in the case of qualified

facilities placed in service after December

31, 2022, for taxpayers making an elective payment election under section 6417.

The IRA also amended the credit amount

reduction under section 45(b)(3) in the

case of qualified facilities the construction

of which began after August 16, 2022.

The IRA amended section 45(d)(4) to

restore the section 45 credit for electricity produced in solar energy facilities in

the case of qualified facilities placed in

service after December 31, 2021, and the

construction of which began before January 1, 2025. Effective for facilities placed

in service after December 31, 2022, the

IRA (1) removed the one-half reduction

of the credit amount under section 45(b)

(4)(A) for qualified hydropower facilities

and marine and hydrokinetic renewable

energy facilities and (2) amended the definition of marine and hydrokinetic renewable energy under section 45(c)(10) and

the definition of a marine and hydrokinetic

renewable energy facility under section

45(d)(11). The IRA also extended certain

deadlines in the definitions under section

45(d) for wind facilities, closed-loop biomass facilities, open-loop biomass facilities, geothermal facilities, landfill gas

facilities, trash facilities, qualified hydropower facilities, and marine and hydrokinetic renewable energy facilities.

Section 45(a) provides that the renewable electricity production credit for any

tax year is an amount equal to the product

of the kilowatt hours of specified electricity produced by the taxpayer and sold to

an unrelated person during the tax year

multiplied by 1.5 cents (in the case of a

qualified facility placed in service before

January 1, 2022) or 0.3 cents (in the case

of a qualified facility placed in service

after December 31, 2021). This electricity

must be produced from qualified energy

resources and at a qualified facility during

the 10-year period beginning on the date

the facility was originally placed in service.

Section 45(b)(1) provides that the

amount of the credit determined under

section 45(a) is reduced by an amount

which bears the same ratio to the amount

of the credit as the amount by which the

reference price for the calendar year in

which the sale occurs exceeds 8 cents,

bears to 3 cents. Under section 45(b)(2),

the 1.5 cent (or 0.3 cent) amount in section 45(a) and the 8 cent amount in section

45(b)(1) are each adjusted by multiplying

such amount by the inflation adjustment

factor for the calendar year in which the

sale occurs. In the case of any qualified

facility placed in service before January

1, 2022, if any amount as increased under

section 45(b)(2) is not a multiple of 0.1

cent, such amount is rounded to the nearest multiple of 0.1 cent. In the case of any

qualified facility placed in service after

December 31, 2021, if the 0.3 cent amount

as increased under section 45(b)(2) is not

a multiple of 0.05 cent, such amount is

rounded to the nearest multiple of 0.05

cent.

In the case of electricity produced in

open-loop biomass facilities, landfill gas

facilities, trash facilities, qualified hydropower facilities, and, if placed in service before January 1, 2023, marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount in

effect under section 45(a)(1) for such calendar year (determined before rounding as

required by section 45(b)(2)) to be reduced

by one-half. As amended by the IRA, the

one-half reduction under section 45(b)(4)

(A) no longer applies to qualified hydro-

power facilities and marine and hydrokinetic renewable energy facilities placed in

service after December 31, 2022.

Section 45(b)(5) provides that in the

case of any qualified wind facility placed

in service before January 1, 2022, the

amount of the credit determined under

section 45(a) (determined after the application of section 45(b)(1), (2), and (3) and

without regard to section 45(b)(5)) shall

be reduced by (A) in the case of any facility the construction of which began after

December 31, 2016, and before January 1,

2018, 20 percent, (B) in the case of any

facility the construction of which began

after December 31, 2017, and before January 1, 2019, 40 percent, (C) in the case

of any facility the construction of which

began after December 31, 2018, and

before January 1, 2020, 60 percent, and

(D) in the case of any facility the construction of which began after December

31, 2019, and before January 1, 2022, 40

percent.

Section 45(c)(1) defines qualified

energy resources as wind, closed-loop

biomass, open-loop biomass, geothermal energy, solar energy, municipal solid

waste, qualified hydropower production,

and marine and hydrokinetic renewable

energy.

Section 45(d)(1) defines a qualified

facility using wind to produce electricity as any facility owned by the taxpayer

that was originally placed in service after

December 31, 1993, and the construction

of which began before January 1, 2025.

See section 45(e)(7) for rules relating to

the inapplicability of the credit to electricity sold to utilities under certain contracts.

Section 45(d)(2)(A) defines a qualified

facility using closed-loop biomass to produce electricity as any facility owned by

the taxpayer that was originally placed in

service after December 31, 1992, and the

construction of which began before January 1, 2025, or owned by the taxpayer

which before January 1, 2025, was originally placed in service and modified to use

closed-loop biomass to co-fire with coal,

with other biomass, or with both, but only

if the modification is approved under the

See §§ 1.45-6, 1.45-7, 1.45-8, and 1.45-12 of the Income Tax Regulations for additional information regarding the requirements of section 45(b)(6)(B).

See Notice 2023-38, 2023-22 I.R.B. 872 (May 12, 2023), Notice 2024-41, 2024-24 I.R.B. 1615 (May 16, 2024), corrected at IR 2024-147 (May 24, 2024), and Notice 2025-08, 2025-8 I.R.B.

800 (February 18, 2025), for additional information regarding the domestic content bonus credit.

3

See Notice 2024-30, 2024-16 I.R.B. 878 (April 15, 2024), for additional information regarding the energy community bonus credit.

1

2

June 23, 2025

1616

Bulletin No. 2025–26

Biomass Power for Rural Development

Programs or is part of a pilot project of

the Commodity Credit Corporation as

described in 65 FR 63052. For purposes

of section 45(d)(2)(A)(ii), a facility shall

be treated as modified before January 1,

2025, if the construction of such modification began before such date. Section 45(d)

(2)(C) provides that in the case of a qualified facility described in section 45(d)(2)

(A)(ii), the 10-year period referred to in

section 45(a) is treated as beginning no

earlier than the date of the enactment of

section 45(d)(2)(C)(i) (October 22, 2004),

and if the owner of such facility is not the

producer of the electricity, the person eligible for the credit allowable under section

45(a) is the lessee or the operator of such

facility. A qualified facility using closedloop biomass includes a new unit placed

in service after the date of the enactment

of section 45(d)(2)(B) (October 3, 2008)

in connection with a qualified facility

using closed-loop biomass, but only to the

extent of the increased amount of electricity produced at the facility by reason of

such new unit.

Section 45(d)(3)(A) defines a qualified facility using open-loop biomass to

produce electricity as any facility owned

by the taxpayer which in the case of a

facility using agricultural livestock waste

nutrients, was originally placed in service

after the date of the enactment of section

45(d)(3)(A)(i)(I) (October 22, 2004) and

the construction of which began before

January 1, 2025, and the nameplate capacity rating of which is not less than 150

kilowatts, and in the case of any other

facility, the construction of which began

before January 1, 2025. In the case of any

facility described in section 45(d)(3)(A),

if the owner of such facility is not the producer of the electricity, section 45(d)(3)

(C) provides that the person eligible for

the credit allowable under section 45(a) is

the lessee or the operator of such facility.

A qualified facility using open-loop biomass includes a new unit placed in service

after the date of the enactment of section

45(d)(3)(B) (October 3, 2008) in connection with a qualified facility using openloop biomass, but only to the extent of the

increased amount of electricity produced

at the facility by reason of such new unit.

Section 45(d)(4) defines a qualified

facility using geothermal energy to pro-

Bulletin No. 2025–26

duce electricity as any facility owned by

the taxpayer that was originally placed in

service after the date of the enactment of

section 45(d)(4) (October 22, 2004) and

the construction of which began before

January 1, 2025. A qualified facility using

geothermal energy does not include any

property described in section 48(a)(3) the

basis of which is taken into account by the

taxpayer for purposes of determining the

energy credit under section 48.

As amended by the IRA and effective

for solar energy facilities placed in service

after December 31, 2021, section 45(d)(4)

also defines a qualified facility using solar

energy to produce electricity as any facility owned by the taxpayer that was originally placed in service after the date of the

enactment of section 45(d)(4) (October

22, 2004) and the construction of which

began before January 1, 2025. A qualified

facility using solar energy does not include

any property described in section 48(a)(3)

the basis of which is taken into account by

the taxpayer for purposes of determining

the energy credit under section 48.

Section 45(d)(6) defines a qualified

facility using gas derived from the biodegradation of municipal solid waste to

produce electricity as any facility owned

by the taxpayer that was originally placed

in service after the date of the enactment

of section 45(d)(6) (October 22, 2004) and

the construction of which began before

January 1, 2025.

Section 45(d)(7) defines a qualified

facility (other than a facility described in

section 45(d)(6)) that uses municipal solid

waste to produce electricity as any facility owned by the taxpayer that was originally placed in service after the date of the

enactment of section 45(d)(7) (October

22, 2004) and the construction of which

began before January 1, 2025. A qualified facility using municipal solid waste

includes a new unit placed in service in

connection with a facility placed in service on or before the date of the enactment

of section 45(d)(7), but only to the extent

of the increased amount of electricity produced at the facility by reason of such new

unit.

Section 45(d)(9) defines a qualified

facility producing qualified hydroelectric

production (as described in section 45(c)

(8)) as (i) any facility producing incremental hydropower production, but only to the

1617

extent of its incremental hydropower production attributable to efficiency improvements or additions to capacity described in

section 45(c)(8)(B) placed in service after

the date of the enactment of section 45(d)

(9) (August 8, 2005) and before January

1, 2025, and (ii) any other facility placed

in service after the date of the enactment

of section 45(d)(9) (August 8, 2005) and

the construction of which began before

January 1, 2025. Section 45(d)(9)(B) provides that, in the case of a qualified facility described in section 45(d)(9)(A), the

10-year period referred to in section 45(a)

shall be treated as beginning on the date

the efficiency improvements or additions

to capacity are placed in service. Section

45(d)(9)(C) provides that for purposes

of section 45(d)(9)(A)(i), an efficiency

improvement or addition to capacity shall

be treated as placed in service before January 1, 2025, if the construction of such

improvement or addition began before

such date.

As amended by the IRA, section 45(d)

(11) provides that, in the case of a facility producing electricity from marine

and hydrokinetic renewable energy, the

term “qualified facility” means any facility owned by the taxpayer which has a

nameplate capacity rating of at least 150

kilowatts (or at least 25 kilowatts in the

case of a facility placed in service after

December 31, 2022), and was originally

placed in service on or after the date of

the enactment of section 45(d)(11) (October 3, 2008) and the construction of which

began before January 1, 2025.

Section 45(e)(2)(A) requires the Secretary to determine and publish in the Federal Register each calendar year the inflation adjustment factor and the reference

price for such calendar year. The inflation

adjustment factor and the reference price

for the 2025 calendar year were published

in the Federal Register at 90 FR 22438 on

May 27, 2025.

Section 45(e)(2)(B) defines the inflation adjustment factor for a calendar year

as a fraction the numerator of which is the

GDP implicit price deflator for the preceding calendar year and the denominator

of which is the GDP implicit price deflator for the calendar year 1992. The term

“GDP implicit price deflator” means the

most recent revision of the implicit price

deflator for the gross domestic product as

June 23, 2025

computed and published by the Department of Commerce before March 15 of

the calendar year.

Section 45(e)(2)(C) provides that the

reference price with respect to a calendar year is the Secretary’s determination

of the annual average contract price per

kilowatt hour of electricity generated

from the same qualified energy resource

and sold in the previous year in the

United States. Only contracts entered

into after December 31, 1989, are taken

into account.

INFLATION ADJUSTMENT

FACTOR AND REFERENCE PRICE

The inflation adjustment factor for

calendar year 2025 for qualified energy

resources is 1.9971.

The reference price for calendar year

2025 for facilities producing electricity from wind (based upon information

provided by the Department of Energy)

is 3.1 cents per kilowatt hour. The reference prices for facilities producing

electricity from closed-loop biomass,

open-loop biomass, geothermal energy,

solar energy, municipal solid waste,

qualified hydropower production, and

marine and hydrokinetic renewable

energy have not been determined for

calendar year 2025.

PHASEOUT CALCULATION

Because the 2025 reference price for

electricity produced from wind (3.1 cents

per kilowatt hour) does not exceed 8

cents multiplied by the inflation adjustment factor (1.9971), the phaseout of the

credit provided in section 45(b)(1) does

not apply to such electricity sold during

calendar year 2025. However, section

45(b)(5) provides an additional phaseout

of the credit for wind facilities placed

in service before January 1, 2022, and

the construction of which began after

December 31, 2016. For electricity produced from closed-loop biomass, openloop biomass, geothermal energy, solar

energy, municipal solid waste, qualified

hydropower production, and marine

and hydrokinetic renewable energy, the

phaseout of the credit provided in section

45(b)(1) does not apply to such electricity sold during calendar year 2025.

CREDIT AMOUNT FOR A

QUALIFIED FACILITY PLACED

IN SERVICE BEFORE JANUARY 1,

2022

As required by section 45(b)(2), the 1.5

cent amount provided in section 45(a)(1)

is adjusted by multiplying such amount

by the inflation adjustment factor for the

calendar year in which the sale occurs.

If any amount as increased under section

45(b)(2) is not a multiple of 0.1 cent, such

amount is rounded to the nearest multiple of 0.1 cent. In the case of electricity

produced in open-loop biomass facilities,

landfill gas facilities, trash facilities, qualified hydropower facilities, and marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount in

effect under section 45(a)(1) for such calendar year (before rounding to the nearest

0.1 cent as required by section 45(b)(2)) to

be reduced by one-half.4

Under the calculation required by section 45(b)(2), the credit for renewable

electricity production for calendar year

2025 determined under section 45(a) is 3

cents per kilowatt hour on the sale of electricity produced in any qualified facility

placed in service before January 1, 2022,

from the qualified energy resources of

wind, closed-loop biomass, and geothermal energy, and 1.5 cents per kilowatt

hour on the sale of electricity produced

in any qualified facility placed in service

before January 1, 2022, from the qualified

energy resources of open-loop biomass,

landfill gas, trash, qualified hydropower,

and marine and hydrokinetic renewable

energy.

is adjusted by multiplying such amount by

the inflation adjustment factor for the calendar year in which the sale occurs. If the

0.3 cent amount as adjusted for inflation

is not a multiple of 0.05 cent, the amount

is rounded to the nearest multiple of 0.05

cent. In the case of electricity produced

in open-loop biomass facilities, landfill

gas facilities, trash facilities, qualified

hydropower facilities, and marine and

hydrokinetic renewable energy facilities,

section 45(b)(4)(A) requires the amount

in effect under section 45(a)(1) for such

calendar year (determined before rounding as required by section 45(b)(2)) to be

reduced by one-half.

Under the calculation required by

section 45(b)(2), the credit for renewable electricity production for calendar

year 2025 determined under section

45(a) is 0.6 cents per kilowatt hour on

the sale of electricity produced in any

qualified facility placed in service after

December 31, 2021, from the qualified

energy resources of wind, closed-loop

biomass, geothermal energy, and solar

energy, and 0.3 cents per kilowatt hour

on the sale of electricity produced in

any qualified facility placed in service

after December 31, 2021, from the qualified energy resources of open-loop biomass, landfill gas and trash. The credit

for renewable electricity production for

calendar year 2025 determined under

section 45(a) is also 0.3 cents per kilowatt hour on the sale of electricity produced in any qualified facility placed in

service after December 31, 2021, and

before January 1, 2023, from the qualified energy resources of qualified hydropower and marine and hydrokinetic

renewable energy.

CREDIT AMOUNT FOR A

QUALIFIED FACILITY PLACED IN

SERVICE AFTER DECEMBER 31,

2021

CREDIT AMOUNT FOR

QUALIFIED HYDROPOWER

FACILITIES AND MARINE AND

HYDROKINETIC RENEWABLE

ENERGY FACILITIES PLACED IN

SERVICE AFTER DECEMBER 31,

2022

As required by section 45(b)(2), the 0.3

cent amount provided in section 45(a)(1)

The one-half reduction under section

45(b)(4)(A) no longer applies to quali-

As amended by the IRA and discussed later in this notice, the one-half reduction under section 45(b)(4)(A) no longer applies to qualified hydropower facilities and marine and hydrokinetic

renewable energy facilities placed in service after December 31, 2022.

4

June 23, 2025

1618

Bulletin No. 2025–26

fied hydropower facilities and marine

and hydrokinetic renewable energy

facilities placed in service after December 31, 2022. Accordingly, under the

calculation required by section 45(b)

(2), the credit for renewable electricity production for calendar year 2025

determined under section 45(a) is 0.6

Bulletin No. 2025–26

cents per kilowatt hour on the sale of

electricity produced in any qualified

facility placed in service after December 31, 2022, from the qualified energy

resources of qualified hydropower and

marine and hydrokinetic renewable

energy.

1619

DRAFTING AND CONTACT

INFORMATION

The principal author of this notice

is Charles Hyde of the Office of Associate Chief Counsel (Energy, Credits,

and Excise Tax). For further information

regarding this notice contact Mr. Hyde at

(202) 317-6853 (not a toll-free number).

June 23, 2025

Part IV

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-17

The Internal Revenue Service has revoked its determination that the organization listed below qualifies as an organization described

in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.

Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a

deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely

filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or

determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities

or omissions of the organization that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described

in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on

January 1, 2018 and would end on the date the court first determines the organization is not described in section 170(c)(2) as more

particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband

and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the

organization that were the basis for revocation.

The Following organization is no longer qualified as an organization exempt from income tax under Internal Revenue Code (the

“Code”) Section 501(a) as an organization described in Section 501(c)(3) of the Code:

NAME OF ORGANIZATION

LITTLE KINGS AND QUEENS INC.

June 23, 2025

EFFECTIVE DATE OF REVOCATION

1/1/2020

1620

LOCATION

BUFORD GA

Bulletin No. 2025–26

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-18

The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in

sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.

Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a

deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely

filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or

determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities

or omissions of the organization that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described

in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on

June 6, 2025, and would end on the date the court first determines the organization is not described in section 170(c)(2) as more

particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband

and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the

organization that were the basis for revocation.

Name Of Organization

Global Rescue Welfare League, Inc.

Global Rescue Welfare League, Inc.

Providing Hope VA

Houston Serenity Place Inc.

Preserve Reasonable Shoreline

Bulletin No. 2025–26

Effective Date of Revocation

07/01/2021

07/01/2021

01/01/2020

01/01/2020

07/01/2021

1621

Location

Columbia, SC

Williston, SC

Loris, SC

Spring, TX

Bainbridge Island, WA

June 23, 2025

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 published 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

applied 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

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published 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 published ruling that is not considered determinative 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 substance 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 previously

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 rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings 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.

Bulletin No. 2025–26

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.

i

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.

June 23, 2025

Numerical Finding List1

Bulletin 2025–26

Announcements:

2025-2, 2025-2 I.R.B. 305

2025-3, 2025-2 I.R.B. 306

2025-4, 2025-2 I.R.B. 306

2025-1, 2025-3 I.R.B. 431

2025-5, 2025-3 I.R.B. 433

2025-6, 2025-5 I.R.B. 526

2025-8, 2025-13 I.R.B. 1384

2025-13, 2025-15 I.R.B. 1392

2025-15, 2025-18 I.R.B. 1420

2025-7, 2025-25 I.R.B. 1600

2025-9, 2025-25 I.R.B. 1601

2025-10, 2025-25 I.R.B. 1602

2025-11, 2025-25 I.R.B. 1603

2025-12, 2025-25 I.R.B. 1604

2025-14, 2025-25 I.R.B. 1605

2025-16, 2025-25 I.R.B. 1609

2025-17, 2025-26 I.R.B. 1620

2025-18, 2025-26 I.R.B. 1621

Notices:

2025-1, 2025-3 I.R.B. 415

2025-2, 2025-3 I.R.B. 418

2025-4, 2025-3 I.R.B. 419

2025-5, 2025-3 I.R.B. 426

2025-3, 2025-4 I.R.B. 488

2025-7, 2025-5 I.R.B. 524

2025-9, 2025-6 I.R.B. 681

2025-10, 2025-6 I.R.B. 682

2025-11, 2025-6 I.R.B. 704

2025-13, 2025-6 I.R.B. 710

2025-6, 2025-8 I.R.B. 799

2025-8, 2025-8 I.R.B. 800

2025-12, 2025-8 I.R.B. 813

2025-14, 2025-10 I.R.B. 980

2025-15, 2025-11 I.R.B. 1089

2025-16, 2025-13 I.R.B. 1378

2025-17, 2025-14 I.R.B. 1387

2025-18, 2025-16 I.R.B. 1416

2025-19, 2025-17 I.R.B. 1418

2025-20, 2025-19 I.R.B. 1423

2025-21, 2025-19 I.R.B. 1424

2025-22, 2025-19 I.R.B. 1427

2025-23, 2025-19 I.R.B. 1428

2025-24, 2025-19 I.R.B. 1429

2025-25, 2025-20 I.R.B. 1445

2025-26, 2025-20 I.R.B. 1445

2025-29, 2025-20 I.R.B. 1445

2025-27, 2025-26 I.R.B. 1611

2025-30, 2025-26 I.R.B. 1615

Proposed Regulations:

Treasury Decisions:

REG-117213-24, 2025-3 I.R.B. 433

REG-134420-10, 2025-4 I.R.B. 513

REG-105479-18, 2025-5 I.R.B. 527

REG-116610-20, 2025-5 I.R.B. 638

REG-115560-23, 2025-6 I.R.B. 716

REG-123525-23, 2025-6 I.R.B. 726

REG-124930-21, 2025-7 I.R.B. 772

REG‑100669‑24, 2025-8 I.R.B. 819

REG-101268-24, 2025-8 I.R.B. 836

REG-107420-24, 2025-8 I.R.B. 854

REG-116085-23, 2025-8 I.R.B. 865

REG-118988-22, 2025-8 I.R.B. 869

REG-107895-24, 2025-9 I.R.B. 972

REG-110878-24, 2025-9 I.R.B. 979

REG-112261-24, 2025-10 I.R.B. 983

10016, 2025-3 I.R.B. 313

10020, 2025-3 I.R.B. 408

10018, 2025-4 I.R.B. 446

10019, 2025-4 I.R.B. 482

10017, 2025-5 I.R.B. 517

10028, 2025-6 I.R.B. 660

10022, 2025-8 I.R.B. 773

10026, 2025-9 I.R.B. 878

10027, 2025-9 I.R.B. 897

10029, 2025-9 I.R.B. 936

10030, 2025-11 I.R.B. 1066

10024, 2025-12 I.R.B. 1104

10023, 2025-13 I.R.B. 1259

Revenue Procedures:

2025-1, 2025-1 I.R.B. 1

2025-2, 2025-1 I.R.B. 118

2025-3, 2025-1 I.R.B. 142

2025-4, 2025-1 I.R.B. 158

2025-5, 2025-1 I.R.B. 260

2025-7, 2025-1 I.R.B. 301

2025-8, 2025-3 I.R.B. 427

2025-9, 2025-4 I.R.B. 491

2025-10, 2025-4 I.R.B. 492

2025-11, 2025-4 I.R.B. 501

2025-12, 2025-4 I.R.B. 512

2025-6, 2025-6 I.R.B. 713

2025-14, 2025-7 I.R.B. 770

2025-13, 2025-8 I.R.B. 816

2025-15, 2025-11 I.R.B. 1090

2025-16, 2025-11 I.R.B. 1100

2025-17, 2025-13 I.R.B. 1382

2025-18, 2025-19 I.R.B. 1430

2025-19, 2025-21 I.R.B. 1447

2025-20, 2025-22 I.R.B. 1448

2025-21, 2025-22 I.R.B. 1448

2025-23, 2025-24 I.R.B. 1476

Revenue Rulings:

2025-1, 2025-3 I.R.B. 307

2025-2, 2025-3 I.R.B. 309

2025-3, 2025-4 I.R.B. 443

2025-4, 2025-7 I.R.B. 758

2025-5, 2025-7 I.R.B. 767

2025-6, 2025-11 I.R.B. 1064

2025-7, 2025-13 I.R.B. 1239

2025-8, 2025-15 I.R.B. 1390

2025-9, 2025-16 I.R.B. 1415

2025-10, 2025-19 I.R.B. 1421

2025-11, 2025-23 I.R.B. 1451

2025-12, 2025-23 I.R.B. 1471

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

June 23, 2025

ii

Bulletin No. 2025–26

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–26

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

Bulletin No. 2025–26

iii

June 23, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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