Bulletin No. 2025–36

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–36

September 2, 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.

ADMINISTRATIVE, INCOME TAX

REG-108822-25, page 361.

The proposed regulations modify information reporting obligations with respect to sales or exchanges of certain interests in partnerships owning inventory or unrealized receivables. Specifically, the proposed regulations would eliminate

a regulatory requirement that partnerships furnish partners

that bought or sold interests in the partnership certain computational information by January 31 of the year following the

calendar year in which the sale or exchange occurred. As a

result, the proposed regulations would result in partnerships

having additional time (generally, until the due date of the

partnership’s return) to compute and furnish such information.

EMPLOYMENT TAX

Notice 2025-43, page 356.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment

rates for July 2025 used under § 417(e)(3)(D), the

24-month average segment rates applicable for August

2025, and the 30-year Treasury rates, as reflected by

the application of § 430(h)(2)(C)(iv).

EXEMPT ORGANIZATIONS

Announcement 2025-24, page 359.

The Internal Revenue Service has revoked its determination that Foundation for Those With Special Needs 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, 2026.

Finding Lists begin on page ii.

Announcement 2025-25, page 360.

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).

INCOME TAX

Notice 2025-42, page 351.

This notice provides guidance regarding beginning of construction for qualified wind and solar facilities under §§ 45Y

and 48E, as amended by Public Law 119-21, 139 Stat. 72

(July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). Sections 70512(a) and 70513(a) of the

OBBBA add new §§ 45Y(d)(4) and 48E(e)(4), respectively, to

the Code which terminate the § 45Y credit and § 48E credit,

respectively, for applicable wind and solar facilities placed

in service after December 31, 2027. Sections 70512(l)(4)

and 70513(g)(5) of the OBBBA provide that the amendments

made by §§ 70512(a) and 70513(a) of the OBBBA, respectively, apply to facilities the construction of which begins

after the date which is 12 months after the date of enactment of the OBBBA (July 4, 2026). This notice provides new

“beginning of construction” guidance, consistent with Executive Order 14315, 90 FR 30821 (July 7, 2025), to strictly

enforce when construction of an “applicable wind facility” or

“applicable solar facility” (each as defined in section 2.02(1)

of the notice) has begun solely for purposes of determining

whether such facility is subject to credit termination provisions added to §§ 45Y and 48E of the Code by §§ 70512

and 70513 of the OBBBA.

Rev. Rul. 2025-17, page 349.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes

of sections 382, 1274, 1288, 7872 and other sections of

the Code, tables set forth the rates for September 2025.

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.

September 2, 2025 

Bulletin No. 2025–36

Part I

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also, Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2025-17

This revenue ruling provides various prescribed rates for federal income

AFR

110% AFR

120% AFR

130% AFR

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

AFR

110% AFR

120% AFR

130% AFR

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

Bulletin No. 2025–36

tax purposes for September 2025 (the

current month). Table 1 contains the

short-term, mid-term, and long-term

applicable federal rates (AFR) for the

current month for purposes of section

1274(d) of the Internal Revenue Code.

Table 2 contains the short-term, midterm, and long-term adjusted applicable federal rates (adjusted AFR) for the

current month for purposes of section

1288(b). Table 3 sets forth the adjusted

federal long-term rate and the longterm tax-exempt rate described in section 382(f). Table 4 contains the appro-

priate percentages for determining the

low-income housing credit described in

section 42(b)(1) for buildings placed in

service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service

after July 30, 2008, shall not be less

than 9%. Finally, Table 5 contains the

federal rate for determining the present

value of an annuity, an interest for life

or for a term of years, or a remainder or

a reversionary interest for purposes of

section 7520.

REV. RUL. 2025-17 TABLE 1

Applicable Federal Rates (AFR) for September 2025

Period for Compounding

Annual

Semiannual

Quarterly

Short-term

4.00%

3.96%

3.94%

4.41%

4.36%

4.34%

4.81%

4.75%

4.72%

5.22%

5.15%

5.12%

Mid-term

4.04%

4.00%

3.98%

4.45%

4.40%

4.38%

4.86%

4.80%

4.77%

5.27%

5.20%

5.17%

6.09%

6.00%

5.96%

7.12%

7.00%

6.94%

Long-term

4.83%

4.77%

4.74%

5.32%

5.25%

5.22%

5.80%

5.72%

5.68%

6.30%

6.20%

6.15%

Annual

3.03%

3.06%

3.65%

REV. RUL. 2025-17 TABLE 2

Adjusted AFR for September 2025

Period for Compounding

Semiannual

3.01%

3.04%

3.62%

349

Quarterly

3.00%

3.03%

3.60%

Monthly

3.93%

4.32%

4.70%

5.10%

3.97%

4.36%

4.75%

5.14%

5.93%

6.90%

4.72%

5.19%

5.65%

6.12%

Monthly

2.99%

3.02%

3.59%

September 2, 2025

REV. RUL. 2025-17 TABLE 3

Rates Under Section 382 for September 2025

Adjusted federal long-term rate for the current month

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal

long-term rates for the current month and the prior two months.)

3.65%

3.71%

REV. RUL. 2025-17 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for September 2025

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after

July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit

8.03%

Appropriate percentage for the 30% present value low-income housing credit

3.44%

REV. RUL. 2025-17 TABLE 5

Rate Under Section 7520 for September 2025

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,

or a remainder or reversionary interest

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

Section 382.—Limitation

on Net Operating Loss

Carryforwards and

Certain Built-In Losses

Following Ownership

Change

The adjusted applicable federal long-term rate

is set forth for the month of September 2025. See

Rev. Rul. 2025-17, page 349.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of September 2025. See Rev.

Rul. 2025-17, page 349.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

4.80%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

Section 1288.—Treatment

of Original Issue Discount

on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of September 2025. See Rev. Rul. 2025-17, page 349.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of September 2025. See Rev.

Rul. 2025-17, page 349.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

September 2025. See Rev. Rul. 2025-17, page 349.

September 2, 2025

350

Bulletin No. 2025–36

Part III

Beginning of Construction

Requirements for Purposes

of the Termination of Clean

Electricity Production

Credits and Clean

Electricity Investment

Credits for Applicable Wind

and Solar Facilities

Notice 2025-42

SECTION 1. PURPOSE

This notice provides guidance, consistent with Executive Order 14315 of July

7, 2025, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled

Energy Sources, 90 F.R. 30821 (Executive Order 14315), regarding when construction of an applicable wind facility or

applicable solar facility (each as defined

in section 2.02 of this notice) has begun

for purposes of determining whether

such facility is subject to credit termination provisions added to §§ 45Y and 48E

of the Internal Revenue Code (Code)1

by §§ 70512 and 70513 of Public Law

119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful

Bill Act (OBBBA). Section 70512(a)

and (l)(4) of the OBBBA terminates the

clean electricity production credit determined under § 45Y (§ 45Y credit), and

§ 70513(a) and (g)(5) of the OBBBA terminates the clean electricity investment

credit determined under § 48E (§ 48E

credit), in the case of an applicable wind

facility or applicable solar facility that

is placed in service after December 31,

2027 (credit termination date). The credit

termination date applies to applicable

wind and solar facilities the construction of which begins after July 4, 2026

(beginning of construction deadline), the

date that is 12 months after the date of

enactment of the OBBBA.

SECTION 2. BACKGROUND

.01 Overview of pre-OBBBA §§ 45Y

and 48E.

Sections 45Y and 48E were added to

the Code by §§ 13701(a) and 13702(a),

respectively, of Public Law 117-169, 136

Stat. 1818, 1982 (August 16, 2022), commonly known as the Inflation Reduction

Act of 2022. The § 45Y credit is determined with respect to electricity produced

by a taxpayer at a “qualified facility” and

either sold by the taxpayer to an unrelated

party during the taxable year or, if the

facility is equipped with a metering device

which is owned or operated by an unrelated person, sold, consumed, or stored by

the taxpayer during the taxable year. The

§ 48E credit is determined with respect

to a taxpayer’s “qualified investment” in

a qualified facility. A taxpayer’s qualified

investment in a qualified facility is determined with respect to the taxpayer’s basis

in “qualified property” placed in service

by the taxpayer that is part of the qualified facility as well as expenditures paid

or incurred for certain qualified interconnection property.

Sections 45Y(b)(1)(A) and 48E(b)(3)

(A) define a “qualified facility” for purposes of §§ 45Y and 48E, respectively,

as a facility which is used for the generation of electricity, which is placed in

service after December 31, 2024, and for

which the greenhouse gas emissions rate

(for § 45Y) or anticipated greenhouse gas

emissions rate (for § 48E) is not greater

than zero. The Department of the Treasury

(Treasury Department) and the Internal

Revenue Service (IRS) published final

regulations under §§ 45Y and 48E on

January 15, 2025 (90 FR 4006). Sections

1.45Y-2 and 1.48E-2 clarify the definition

of a “qualified facility” for purposes of

§§ 45Y and 48E, respectively.

Section 45Y(b)(2)(C)(i) requires that

the Secretary of the Treasury or the Secretary’s delegate annually publish a table that

sets forth the greenhouse gas emissions

rates for types or categories of facilities,

which a taxpayer must use for purposes

of § 45Y. The Treasury Department and

the IRS published the initial annual table

required by § 45Y(b)(2)(C)(i) in Revenue

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

That table lists both wind facilities and

solar facilities as having a greenhouse gas

emissions rate of not greater than zero.

As noted in section 2.02 of Notice

2022-61, 87 FR 73580, 2022-52 I.R.B.

560, the IRS has issued several notices,

collectively referred to in this notice as

the “IRS Notices,”2 which provide that

taxpayers may establish the beginning of

construction using the “Physical Work

Test” or the “Five Percent Safe Harbor,”

and may satisfy either the “Continuity

Requirement” or the “Continuity Safe

Harbor,” with respect to the credits determined under §§ 45, 45Q, and 48.

Section 5 of Notice 2022-61 provides

guidance, in part, to determine when construction begins for purposes of the credit

determined under §§ 45Y and 48E. Section 5 of Notice 2022-61 states that principles similar to those under Notice 2013-29

regarding the Physical Work Test and Five

Percent Safe Harbor apply, and taxpayers

satisfying either test will be considered

to have begun construction. Section 5 of

Notice 2022-61 additionally provides, in

part, that principles similar to those provided in the IRS Notices regarding the

Continuity Requirement and the Continuity Safe Harbor apply for purposes of

§§ 45Y and 48E, and that taxpayers may

rely on the Continuity Safe Harbor provided the facility is placed in service no

more than four calendar years after the

calendar year during which construction

began.

.02 Overview of OBBBA Changes to

§§ 45Y and 48E.

Sections 70512(a) and 70513(a) of

the OBBBA added new §§ 45Y(d)(4)

and 48E(e)(4), respectively, to the Code.

These new Code provisions terminate the

§ 45Y credit and the § 48E credit, respec-

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

See Notice 2013-29, 2013-20 I.R.B. 1085; clarified by Notice 2013-60, 2013-44 I.R.B. 431; clarified and modified by Notice 2014-46, 2014-36 I.R.B. 520; updated by Notice 2015-25,

2015-13 I.R.B. 814; clarified and modified by Notice 2016-31, 2016-23 I.R.B. 1025; updated, clarified, and modified by Notice 2017-04, 2017-4 I.R.B. 541; Notice 2018-59, 2018-28 I.R.B.

196; modified by Notice 2019-43, 2019-31 I.R.B. 487; modified by Notice 2020-41, 2020-25 I.R.B. 954; clarified and modified by Notice 2021-5, 2021-3 I.R.B. 479; clarified and modified

by Notice 2021-41, 2021-29 I.R.B. 17; Notice 2020-12, 2020-11 I.R.B. 495.

1

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Bulletin No. 2025–36

351

September 2, 2025

tively, for applicable wind and solar facilities placed in service after December 31,

2027. For purposes of this notice, the term

“applicable wind facility” means an applicable facility as provided in §§ 45Y(d)(4)

(B)(i) and 48E(e)(4)(B)(i) (except as provided in § 48E(e)(4)(C) relating to energy

storage technology) and “applicable solar

facility” means an applicable facility

as provided in §§ 45Y(d)(4)(B)(ii) and

48E(e)(4)(B)(ii) (except as provided in

§ 48E(e)(4)(C)). Sections 70512(l)(4) and

70513(g)(5) of the OBBBA provide that

the amendments made by §§ 70512(a)

and 70513(a) of the OBBBA, respectively, apply to facilities the construction

of which begins after the date which is 12

months after the date of enactment of the

OBBBA (that is, July 4, 2026).

.03 Executive Order 14315.

Section 3(a) of Executive Order 14315

directs the Secretary of the Treasury,

within 45 days following enactment of

the OBBBA, to take action he deems necessary and appropriate to strictly enforce

the termination provisions with respect

to the § 45Y credit and the § 48E credit

for wind and solar facilities. Such action

includes issuing new and revised guidance

for applicable wind and solar facilities to

ensure that policies concerning “beginning of construction” are not circumvented, including guidance to prevent the

artificial acceleration or manipulation of

eligibility and to restrict the use of broad

safe harbors unless a substantial portion

of an applicable wind or solar facility has

been built.3

The Treasury Department and the

IRS have determined that the guidance

contained in this notice is necessary and

appropriate to properly enforce the credit

termination date for applicable wind

and solar facilities. Congress provided a

beginning of construction deadline after

which the new credit termination date

for applicable wind and solar facilities

applies. This notice provides beginning

of construction guidance to prevent taxpayers from circumventing the statutory

credit termination date, prevent the artificial manipulation of eligibility for the

§ 45Y credit and § 48E credit for applicable wind and solar facilities, and ensure

that a substantial portion of any applicable wind or solar facility not subject

to the credit termination date is built by

the beginning of construction deadline.

Accordingly, except as provided in section 6 of this notice, the Five Percent Safe

Harbor provided under the IRS notices is

not available for purposes of determining

whether an applicable wind or solar facility has met the beginning of construction

deadline and, thus, is not subject to the

credit termination date.

SECTION 3. METHOD FOR

ESTABLISHING BEGINNING OF

CONSTRUCTION

.01 In general. For purposes of the

beginning of construction deadline in

§§ 70512(l)(4) and 70513(g)(5) of the

OBBBA, a taxpayer may establish that

construction has begun before July 5,

2026, by satisfying the Physical Work Test

as described in section 3.02 of this notice.

Except as provided in section 6 of this

notice, the Physical Work Test described

in section 3.02 of this notice is the sole

method that a taxpayer may use for these

purposes. The Physical Work Test also

requires that a taxpayer maintain a continuous program of construction (Continuity

Requirement). Section 4 of this notice

discusses the Continuity Requirement

and section 4.04 of this notice provides a

safe harbor for satisfying this requirement

(Continuity Safe Harbor).

.02 Physical Work Test. Construction of

an applicable wind or solar facility begins

when physical work of a significant nature

begins. Work performed by the taxpayer

and work performed for the taxpayer by

other persons under a binding written contract that is entered into prior to the manufacture, construction, or production of the

applicable wind or solar facility for use

by the taxpayer in the taxpayer’s trade or

business (or for the taxpayer’s production

of income) is taken into account in determining whether construction has begun.

See section 5.01 of this notice. Whether

physical work of a significant nature has

begun with respect to an applicable wind

or solar facility before July 5, 2026, will

depend on the relevant facts and circumstances.

.03 Physical work of a significant

nature. The Physical Work Test requires

that physical work of a significant nature

be performed. This test focuses on the

nature of the work performed, not the

amount or the cost. Provided that physical

work performed is of a significant nature,

there is no fixed minimum amount of

work or monetary or percentage threshold

required to satisfy the Physical Work Test.

Both off-site and on-site work (performed

either by the taxpayer or by another person

under a binding written contract) may be

taken into account for purposes of demonstrating that physical work of a significant

nature has begun.

(1) Off-site physical work of a significant nature. Generally, off-site physical

work of a significant nature may include

the manufacture of components, mounting equipment, support structures such as

racks and rails, inverters, and transformers

and other power conditioning equipment.

(2) On-site physical work of a significant nature. The following non-exclusive

list of examples is intended to illustrate

what constitutes on-site physical work of

a significant nature for applicable wind

and solar facilities:

(a) Applicable wind facility. On-site

physical work of a significant nature

begins with the beginning of the excavation for the foundation, the setting

of anchor bolts into the ground, or the

pouring of the concrete pads of the foundation. If the applicable wind facility’s

wind turbines and tower units are to be

assembled on-site from components

manufactured off-site by a person other

than the taxpayer and delivered to the

site, physical work of a significant nature

In addition, § 3(b) of Executive Order 14315 directs the Secretary of the Treasury, within 45 days following enactment of the OBBBA, to take prompt action as the Secretary of the Treasury

deems appropriate and consistent with applicable law to implement the enhanced “Foreign Entity of Concern” restrictions in the OBBBA (also known as “Prohibited Foreign Entities”).

Section 70512 of the OBBBA added those new restrictions regarding certain foreign entities in order to qualify for the § 45Y credit and the § 48E credit, among others, and included separate

beginning of construction rules for those new provisions. See § 7701(a)(51) and (52) of the Code. The guidance in this notice is not intended to address the beginning of construction rules

for the purposes of those foreign entity restrictions. The Treasury Department and the IRS are currently drafting additional guidance as is necessary and appropriate to implement those

restrictions, as enacted by the OBBBA.

3

September 2, 2025

352

Bulletin No. 2025–36

begins when the manufacture of the components begins at the off-site location,

but only if: (i) the manufacturer’s work is

done pursuant to a binding written contract (as described in section 5.01(1) of

this notice); and (ii) these components

are not held in the manufacturer’s inventory (as described in section 3.05 of this

notice). If a manufacturer produces components for multiple applicable facilities, a reasonable method must be used

to associate individual components with

particular applicable facilities.

(b) Applicable solar facility. On-site

physical work of a significant nature may

include the installation of racks or other

structures to affix photovoltaic (PV) panels, collectors, or solar cells to a site.

.04 Preliminary activities. Physical

work of a significant nature does not

include preliminary activities, even if

the cost of those preliminary activities is

properly included in the depreciable basis

of the applicable wind or solar facility.

Generally, preliminary activities for applicable wind or solar facilities include, but

are not limited to:

(a) planning or designing;

(b) securing financing;

(c) exploring;

(d) researching;

(e) conducting mapping and modeling

to assess a resource;

(f) obtaining permits and licenses;

(g) conducting geophysical, gravity,

magnetic, seismic and resistivity surveys;

(h) conducting environmental and

engineering studies;

(i) clearing a site;

(j) conducting test drilling to determine soil condition (including to test the

strength of a foundation);

(k) excavating to change the contour of

the land (as distinguished from excavation

for a foundation); and

(l) removing existing foundations, turbines, and towers, solar panels, or any

components that will no longer be part

of the applicable wind or solar facility

(including those on or attached to building

structures).

.05 Inventory. Physical work of a significant nature does not include work

(performed either by the taxpayer or by

another person under a binding written

contract) to produce a component/part of

an applicable wind or solar facility that is

Bulletin No. 2025–36

either in existing inventory or is normally

held in inventory by one selling the component/part to the taxpayer.

SECTION 4. CONTINUITY

REQUIREMENT

.01 Continuous program of construction. A taxpayer will satisfy the Continuity Requirement of this section 4 only if

the taxpayer maintains a continuous program of construction with respect to an

applicable wind or solar facility. A continuous program of construction involves

continuing physical work of a significant

nature (as described in section 3.03 of this

notice). Unless the Continuity Safe Harbor provided in section 4.04 of this notice

applies, whether a taxpayer maintains a

continuous program of construction to

satisfy the Continuity Requirement will

be determined by the relevant facts and

circumstances.

.02 Excusable disruptions to continuous program of construction. Certain

disruptions in a taxpayer’s continuous

construction to advance towards completion of an applicable wind or solar facility

that are beyond the taxpayer’s control will

not be considered as indicating that a taxpayer has failed to satisfy the Continuity

Requirement.

The following is a non-exclusive list

of construction disruptions that will not

be considered as indicating that a taxpayer has failed to satisfy the Continuity

Requirement:

(a) delays due to severe weather conditions;

(b) delays due to natural disasters;

(c) delays in obtaining permits or

licenses from federal, state, local, or

Indian tribal governments, including,

but not limited to, delays in obtaining permits or licenses from the Federal Energy Regulatory Commission

(FERC), the Environmental Protection

Agency (EPA), the Bureau of Land

Management (BLM), and the Federal

Aviation Agency (FAA);

(d) delays at the written request of

a federal, state, local, or Indian tribal

government regarding matters of public

safety, security, or similar concerns;

(e) interconnection-related delays,

such as those relating to the completion

of construction on a new transmission or

353

distribution line or necessary transmission

or distribution upgrades to resolve grid

congestion issues that may be associated

with an applicable wind or solar facility’s

planned interconnection;

(f) delays in the manufacture of custom

components;

(g) delays due to labor stoppages;

(h) delays due to the inability to obtain

specialized equipment of limited availability;

(i) delays due to the presence of endangered species;

(j) financing delays; and

(k) delays due to supply shortages.

.03 Timing of excusable disruption

determination. In the case of a single

project comprised of multiple facilities

(as described in section 5.02(2) of this

notice), whether an excusable disruption

has occurred for purposes of the Continuity Requirement must be determined

in the calendar year during which the last

of multiple facilities is placed in service.

In the case of a single applicable wind or

solar facility, whether an excusable disruption has occurred for purposes of the

Continuity Requirement must be determined in the calendar year during which

the applicable wind or solar facility is

placed in service.

.04 Continuity safe harbor: deemed

satisfaction of continuity requirement.

Except as provided in this section 4.04,

if a taxpayer places an applicable wind

or solar facility in service by the end of

a calendar year that is no more than four

calendar years after the calendar year

during which construction of the applicable wind or solar facility began (Continuity Safe Harbor Deadline), the applicable

wind or solar facility will be considered

to satisfy the Continuity Requirement

(Continuity Safe Harbor). The excusable disruption rules in section 4.02 of

this notice do not apply for purposes of

applying the Continuity Safe Harbor. If

an applicable wind or solar facility is not

placed in service before the end of the

fourth calendar year after the calendar

year during which construction of the

applicable wind or solar facility began,

whether the applicable wind or solar

facility satisfies the Continuity Requirement under the Physical Work Test will

be determined by the relevant facts and

circumstances.

September 2, 2025

For example, if construction begins

on an applicable wind or solar facility

on August 20, 2025, and the applicable

wind or solar facility is placed in service by December 31, 2029, the applicable wind or solar facility will be considered to satisfy the Continuity Safe

Harbor. If the applicable wind or solar

facility is not placed in service before

January 1, 2030, whether the Continuity Requirement was satisfied will be

determined by the relevant facts and

circumstances.

SECTION 5. OTHER RULES

.01 Construction by contract. For

property that is manufactured, constructed, or produced for the taxpayer by

another person under a binding written

contract (as described in section 5.01(1)

of this notice), the work performed

under the contract is taken into account

in determining when physical work of a

significant nature begins, provided the

contract is entered into prior to the work

taking place.

(1) Binding written contract. A contract is binding only if it is enforceable

under local law against the taxpayer or a

predecessor and does not limit damages

to a specified amount (for example, by

use of a liquidated damages provision).

For this purpose, a contractual provision

that limits damages to an amount equal

to at least five percent of the total contract price will not be treated as limiting

damages to a specified amount. For additional guidance regarding the definition

of a binding contract, see § 1.168(k)-1(b)

(4)(ii)(A)-(D).

(2) Master contract. If a taxpayer

enters into a binding written contract for

a specific number of components to be

manufactured, constructed, or produced

for the taxpayer by another person (a

“master contract”), and then through a

new binding written contract (a “project

contract”) the taxpayer assigns its rights

to certain components to an affiliated

special purpose vehicle that will own the

applicable wind or solar facility for which

such property is to be used, work performed with respect to the master contract

may be taken into account in determining

when physical work of a significant nature

September 2, 2025

begins with respect to the applicable wind

or solar facility.

.02 Qualified facility – (1) In general.

Physical work of a significant nature with

respect to an applicable wind or solar

facility must be performed with respect to

property included in a qualified facility, as

defined in § 1.45Y-2(b) or § 1.48E-2(d), as

applicable.

(2) Single project. Solely for purposes

of determining whether construction of an

applicable wind or solar facility has begun

for purposes of this notice, multiple facilities that are operated as part of a single

project (along with any property, such as a

computer control system, that serves some

or all such facilities) will be treated as a

single applicable wind or solar facility.

Whether multiple facilities are operated as

part of a single project will depend on the

relevant facts and circumstances. Factors

indicating that multiple facilities are operated as part of a single project include, but

are not limited to:

(a) The facilities are owned by a single

legal entity;

(b) The facilities are constructed on

contiguous pieces of land;

(c) The facilities are described in a

common power purchase agreement or

agreements;

(d) The facilities have a common intertie;

(e) The facilities share a common substation;

(f) The facilities are described in one

or more common environmental or other

regulatory permits;

(g) The facilities were constructed pursuant to a single master construction contract; and

(h) The construction of the facilities

was financed pursuant to the same loan

agreement.

(3) Timing of single project determination. The determination of whether

multiple facilities are operated as part of

a single project and are therefore treated

as a single applicable wind or solar facility for purposes of this notice must be

made in the calendar year during which

the last of the multiple facilities is placed

in service.

.03 Property integral to the applicable wind or solar facility. Only physical

work of a significant nature on tangible

354

personal property and other tangible

property used as an integral part of the

activity performed by the applicable

wind or solar facility will be considered

for purposes of determining whether a

taxpayer has begun construction of an

applicable wind or solar facility. This

includes property integral to the production of electricity, but does not include

property used for electrical transmission.

See §§ 1.45Y-2(b)(3) and 1.48E-2(d)(3)

for additional descriptions of property

integral to a qualified facility.

.04 Application of 80/20 rule to retrofitted applicable wind or solar facilities

– (1) In general. A retrofitted applicable

wind or solar facility may qualify as originally placed in service even though it contains some used components of property,

provided the fair market value of the used

components of property is not more than

20 percent of the applicable wind or solar

facility’s total value (the cost of the new

components of property plus the value of

the used components of property) (80/20

Rule). See §§ 1.45Y-4(d) and 1.48E-4(c).

In the case of a single project comprised

of multiple facilities (as described in section 5.02(2) of this notice), the 80/20 Rule

is applied to each facility comprising the

single project. For purposes of the 80/20

Rule, the cost of a new applicable wind or

solar facility includes all properly capitalized costs of the new applicable wind or

solar facility.

(2) Beginning of construction. In situations where the 80/20 Rule applies,

the Physical Work Test applies only with

respect to the work performed on, or

amounts paid or incurred for, new components of property used to retrofit an existing applicable wind or solar facility. The

total cost of the applicable wind or solar

facility does not include the cost of land

(including lease payments) or any property that is not part of the applicable wind

or solar facility, as described in section

5.03 of this notice.

.05 Transfer of an applicable wind or

solar facility – (1) In general. A taxpayer

may claim either the § 45Y credit with

respect to electricity produced by such

taxpayer at an applicable wind or solar

facility or the § 48E credit with respect to

the taxpayer’s qualified investment with

respect to an applicable wind or solar

Bulletin No. 2025–36

facility. Neither § 45Y nor § 48E requires

the taxpayer to own the applicable wind

or solar facility at the time construction

began on the applicable wind or solar

facility. Accordingly, except as provided

in section 5.05(3) of this notice, a fully

or partially developed applicable wind or

solar facility may be transferred without

losing its qualification under the Physical

Work Test for purposes of the § 45Y credit

or the § 48E credit.

(2) Relocation of equipment by a taxpayer. A taxpayer may begin construction

of an applicable wind or solar facility with

the intent to develop the applicable wind

or solar facility at a certain site, and thereafter transfer components of property of

the applicable wind or solar facility to a

different site, complete its development,

and place it in service. The work performed or the amounts paid or incurred

prior to the site transfer by such a taxpayer

may be taken into account for purposes of

determining when the applicable wind or

solar facility satisfies the Physical Work

Test.

(3) Transfers of equipment between

unrelated parties. In the case of a transfer consisting solely of tangible personal

property (including contractual rights to

such property under a binding written

contract) to a transferee not related (within

the meaning of §§ 197(f)(9)(C) and 1.1972(h)(6)) to the transferor, any work performed or amounts paid or incurred by the

transferor with respect to such transferred

property will not be taken into account

with respect to the transferee for purposes

of the Physical Work Test.

For example, a developer, X, intends

to develop and operate Facility A at a

location to be determined. In 2025, X

pays or incurs $60,000 to have tangible

personal property integral to Facility

A manufactured off-site pursuant to a

binding written contract. Thereafter, X

incurs no further development costs and

engages in no further development activity with respect to Facility A. In January

2026, X sells the tangible personal property to another developer, Y, a party unrelated to X. Y is developing and intends to

operate Facility B, located on a parcel of

land owned by Y. Y incorporates the tangible personal property acquired from X

into Facility B. In October 2026, Y places

Bulletin No. 2025–36

Facility B in service on the parcel of land.

The total cost of Facility B is $1,000,000.

Work performed for X in 2025 on the tangible personal property cannot be taken

into account by Y for purposes of satisfying the Physical Work Test with respect

to Facility B, because X and Y are not

related persons (within the meaning

of §§ 197(f)(9)(C) and 1.197-2(h)(6))

as described in section 5.05(3) of this

notice. However, if without regard to the

tangible personal property acquired from

X, Y has otherwise satisfied the Physical

Work Test with respect to Facility B in

2025, Y will be considered to have begun

construction in 2025.

SECTION 6. FIVE PERCENT SAFE

HARBOR FOR LOW OUTPUT

SOLAR FACILITIES

.01 In general. In the case of a low

output solar facility (as defined in section

6.02 of this notice), a taxpayer may establish that construction has begun before

July 5, 2026, by satisfying either the Physical Work Test described in section 3.02 of

this notice, or by applying principles similar to those provided in section 5 of Notice

2013-29 regarding the Five Percent Safe

Harbor (as described in section 2.02(2)(ii)

of Notice 2022-61).

.02 Low output solar facility.

(1) Definition. A low output solar facility is an applicable solar facility that has

maximum net output of not greater than

1.5 megawatt (MW) (as measured in

alternating current) (1.5-Megawatt Maximum). For purposes of the 1.5-Megawatt

Maximum, output is measured at the level

of the qualified facility.

(2) Property included in an applicable solar facility. An applicable solar

facility includes a unit of a qualified

solar facility, which, in turn, includes all

functionally interdependent components

of property owned by the taxpayer that

are operated together and that can operate apart from other property to produce

electricity. Components of property are

functionally interdependent if the placing in service of each of the components

is dependent upon the placing in service

of each of the other components to produce electricity. A qualified solar facility also includes property owned by the

355

taxpayer that is an integral part of the

qualified solar facility. A component of

property owned by the taxpayer is an

integral part of the qualified facility if

it is used directly in the intended function of the facility and is essential to

the completeness of such function. See

§§ 1.45Y-2(b)(3) and 1.48E-2(d)(3) for

additional descriptions of property integral to a qualified facility.

.03 Measurement of output.

(1) In general. The maximum net

output of an applicable solar facility is

measured only by nameplate generating

capacity (in alternating current) of the

unit of qualified facility (as described

in §§ 1.45Y-2(b)(2) and 1.48E-2(d)(2)),

which does not include the nameplate

capacity of any component that is an

integral part (as described in §§ 1.45Y2(b)(3) and 1.48E-2(d)(3)) of the applicable solar facility, at the time the applicable solar facility is placed in service.

The nameplate generating capacity of

the applicable solar facility is measured

independently from any other applicable solar facility that shares an integral

part with the applicable solar facility.

Notwithstanding this rule, the nameplate

generating capacity of two or more applicable solar facilities having integrated

operations are measured in the aggregate

for purposes of the 1.5-Megawatt Maximum.

(2) Nameplate capacity. For purposes of section 6.02(1) of this notice,

the determination of whether a qualified

facility has a maximum net output of not

greater than 1.5 MW (as measured in

alternating current) is based on the nameplate capacity. The nameplate capacity

for purposes of the 1.5-Megawatt Maximum is the maximum electrical generating output in megawatts that the unit of

qualified facility is capable of producing

on a steady state basis and during continuous operation under standard conditions, as measured by the manufacturer

and consistent with the definition of

nameplate capacity provided in 40 CFR

96.202. If applicable, taxpayers should

use the International Standard Organization (ISO) conditions to measure the

maximum electrical generating output of

a unit of qualified facility. For applicable

solar facilities that generate electricity

September 2, 2025

in direct current, a taxpayer determines

whether an applicable solar facility has a

maximum net output of not greater than

1.5 MW (in alternating current) by using

the lesser of:

(a) The sum of the nameplate generating capacities within the applicable solar

facility in direct current, which is deemed

the nameplate generating capacity of the

unit of applicable solar facility in alternating current; or

(b) The nameplate capacity of the first

component of the applicable solar facility

that inverts the direct current electricity

into alternating current.

(3) Integrated operations. For the purposes of the 1.5-Megawatt Maximum, an

applicable solar facility is treated as having integrated operations with one or more

other applicable solar facilities of the same

technology type if the facilities are:

(a) Owned by the same or related taxpayers;

(b) Placed in service in the same taxable year; and

(c) Transmit electricity generated by

the facilities through the same point of

interconnection or, if the facilities are not

grid-connected or are delivering electricity directly to an end user behind a utility

meter, are able to support the same end

user.

(4) Related taxpayers. For purposes

of section 6.03(3) of this notice, the term

“related taxpayers” means members of

a group of trades or businesses that are

under common control (as defined in

§ 1.52-1(b)). Related taxpayers are treated

as one taxpayer in determining whether an

applicable facility has integrated operations.

SECTION 7. EFFECTIVE DATE

This notice is effective for applicable

wind and solar facilities the construction

of which did not begin (as determined

under section 5 of Notice 2022-61) prior

to September 2, 2025.

SECTION 8. EFFECT ON OTHER

DOCUMENTS

YIELD CURVE AND SEGMENT

RATES

Except as provided in sections 6 and 7

of this notice, this notice modifies Notice

2022-61 to provide that section 5 of such

notice is not applicable for determining

whether construction of an applicable

wind or solar facility began prior to the

beginning of construction deadline in

§§ 70512(l)(4) and 70513(g)(5) of the

OBBBA.

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC plans

under § 414(y)) pursuant to § 412. Section

430(h)(2) specifies the interest rates that

must be used to determine a plan’s target

normal cost and funding target. Under this

provision, present value is generally determined using three 24-month average interest rates (“segment rates”), each of which

applies to cash flows during specified periods. To the extent provided under § 430(h)

(2)(C)(iv), these segment rates are adjusted

by the applicable percentage of the 25-year

average segment rates for the period ending

September 30 of the year preceding the calendar year in which the plan year begins.1

However, an election may be made under

§ 430(h)(2)(D)(ii) to use the monthly yield

curve in place of the segment rates.

Section 1.430(h)(2)-1(d) provides

rules for determining the monthly corporate bond yield curve,2 and § 1.430(h)

(2)-1(c) provides rules for determining

the 24-month average corporate bond

segment rates used to compute the target normal cost and the funding target.

Consistent with the methodology specified in § 1.430(h)(2)-1(d), the monthly

corporate bond yield curve derived from

July 2025 data is in Table 2025-7 at the

end of this notice. The spot first, second,

and third segment rates for the month of

July 2025 are, respectively, 4.38, 5.41,

and 6.13.

The 24-month average segment rates

determined under § 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant to

§ 430(h)(2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. Those percentages are

95% and 105% for plan years beginning

in 2024 and 2025. For this purpose, any

25-year average segment rate that is less

than 5% is deemed to be 5%. The 25-year

SECTION 9. DRAFTING

INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

(Energy, Credits, and Excise Tax); however, other personnel from the Treasury

Department and the IRS participated in

its development. For further information

regarding this notice contact (202) 3176853 (not a toll-free number).

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

Notice 2025-43

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

under § 417(e)(3), and the 24-month

average segment rates under § 430(h)

(2) of the Internal Revenue Code. In

addition, this notice provides guidance

as to the interest rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)

(II) as in effect for plan years beginning

before 2008 and the 30-year Treasury

weighted average rate under § 431(c)

(6)(E)(ii)(I).

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount

of the full funding limitation under § 433(c)(7)(C)).

2

For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts

the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market.

Those enhancements are described in the preamble to TD 9986 (89 FR 2127).

1

September 2, 2025

356

Bulletin No. 2025–36

average segment rates for plan years

beginning in 2024 and 2025 were published in Notice 2023-66, 2023-40 I.R.B.

992 and Notice 2024-67, 2024-41 I.R.B.

726, respectively.

Applicable Month

August 2025

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate bond segment rates applicable for

August 2025 without adjustment for

the 25-year average segment rate limits

are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment

First Segment

Second Segment

Third Segment

4.86

5.36

5.67

The adjusted 24-month average segment rates set forth in the chart below

reflect § 430(h)(2)(C)(iv) of the Code. The

24-month averages applicable for August

2025, adjusted to be within the applicable

minimum and maximum percentages of

the corresponding 25-year average segment rates in accordance with § 430(h)(2)

(C)(iv) of the Code, are as follows:

Adjusted 24-Month Average Segment Rates

For Plan Years

Beginning In

Applicable Month

First Segment

Second Segment

Third Segment

2024

August 2025

4.86

5.36

5.67

2025

August 2025

4.86

5.31

5.67

Section 431 specifies the minimum

funding requirements that apply to multiemployer plans pursuant to § 412. Section

431(c)(6)(B) specifies a minimum amount

for the full-funding limitation described in

§ 431(c)(6)(A), based on the plan’s current

liability. Section 431(c)(6)(E)(ii)(I) pro-

vides that the interest rate used to calculate

current liability for this purpose must be

no more than 5 percent above and no more

than 10 percent below the weighted average of the rates of interest on 30-year Treasury securities during the four-year period

ending on the last day before the beginning

of the plan year. Notice 88-73, 1988-2 C.B.

383, provides guidelines for determining

the weighted average interest rate. The rate

of interest on 30-year Treasury securities

for July 2025 is 4.92 percent. The Service

determined this rate as the average of the

daily determinations of yield on the 30-year

Treasury bond maturing in May 2055. For

plan years beginning in August 2025, the

weighted average of the rates of interest on

30-year Treasury securities and the permissible range of rates used to calculate current

liability are as follows:

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

August 2025

4.17

3.75 to 4.38

under § 417(e)(3)(D) are segment rates

computed without regard to a 24-month

average. Section 1.417(e)-1(d)(3) provides guidelines for determining the min-

imum present value segment rates. Pursuant to that section, the minimum present

value segment rates determined for July

2025 are as follows:

30-YEAR TREASURY SECURITIES

INTEREST RATES

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

July 2025

Minimum Present Value Segment Rates

First Segment

Second Segment

4.38

5.41

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2025–36

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

357

Third Segment

6.13

of this guidance. For further information

regarding this notice, contact Mr. Morgan

at 202-317-6700 or Tony Montanaro at

626-927-1475 (not toll-free number).

September 2, 2025

Table 2025-7

Monthly Yield Curve for July 2025

Derived from July 2025 Data

Maturity

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

7.5

8.0

8.5

9.0

9.5

10.0

10.5

11.0

11.5

12.0

12.5

13.0

13.5

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

18.5

19.0

19.5

20.0

Yield

4.44

4.38

4.33

4.30

4.30

4.32

4.35

4.39

4.45

4.51

4.58

4.65

4.72

4.80

4.88

4.95

5.02

5.09

5.16

5.22

5.28

5.33

5.39

5.44

5.49

5.53

5.57

5.61

5.65

5.68

5.71

5.74

5.77

5.80

5.82

5.84

5.86

5.88

5.90

5.91

September 2, 2025

Maturity

20.5

21.0

21.5

22.0

22.5

23.0

23.5

24.0

24.5

25.0

25.5

26.0

26.5

27.0

27.5

28.0

28.5

29.0

29.5

30.0

30.5

31.0

31.5

32.0

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

38.0

38.5

39.0

39.5

40.0

Yield

5.93

5.94

5.95

5.96

5.97

5.97

5.98

5.98

5.99

5.99

6.00

6.00

6.00

6.01

6.01

6.02

6.02

6.03

6.03

6.04

6.05

6.05

6.06

6.07

6.07

6.08

6.08

6.09

6.10

6.10

6.11

6.11

6.12

6.12

6.13

6.13

6.14

6.14

6.14

6.15

Maturity

40.5

41.0

41.5

42.0

42.5

43.0

43.5

44.0

44.5

45.0

45.5

46.0

46.5

47.0

47.5

48.0

48.5

49.0

49.5

50.0

50.5

51.0

51.5

52.0

52.5

53.0

53.5

54.0

54.5

55.0

55.5

56.0

56.5

57.0

57.5

58.0

58.5

59.0

59.5

60.0

Yield

6.15

6.16

6.16

6.16

6.17

6.17

6.17

6.18

6.18

6.18

6.19

6.19

6.19

6.20

6.20

6.20

6.21

6.21

6.21

6.21

6.22

6.22

6.22

6.22

6.23

6.23

6.23

6.23

6.23

6.24

6.24

6.24

6.24

6.25

6.25

6.25

6.25

6.25

6.25

6.26

358

Maturity

60.5

61.0

61.5

62.0

62.5

63.0

63.5

64.0

64.5

65.0

65.5

66.0

66.5

67.0

67.5

68.0

68.5

69.0

69.5

70.0

70.5

71.0

71.5

72.0

72.5

73.0

73.5

74.0

74.5

75.0

75.5

76.0

76.5

77.0

77.5

78.0

78.5

79.0

79.5

80.0

Yield

6.26

6.26

6.26

6.26

6.27

6.27

6.27

6.27

6.27

6.27

6.27

6.28

6.28

6.28

6.28

6.28

6.28

6.29

6.29

6.29

6.29

6.29

6.29

6.29

6.29

6.30

6.30

6.30

6.30

6.30

6.30

6.30

6.30

6.30

6.31

6.31

6.31

6.31

6.31

6.31

Maturity

80.5

81.0

81.5

82.0

82.5

83.0

83.5

84.0

84.5

85.0

85.5

86.0

86.5

87.0

87.5

88.0

88.5

89.0

89.5

90.0

90.5

91.0

91.5

92.0

92.5

93.0

93.5

94.0

94.5

95.0

95.5

96.0

96.5

97.0

97.5

98.0

98.5

99.0

99.5

100.0

Yield

6.31

6.31

6.31

6.31

6.32

6.32

6.32

6.32

6.32

6.32

6.32

6.32

6.32

6.32

6.32

6.33

6.33

6.33

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Bulletin No. 2025–36

Part IV

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-24

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

EFFECTIVE DATE OF REVOCATION

LOCATION

1/1/2026

Orlando, FL

Foundation for Those With Special Needs

Bulletin No. 2025–36

359

September 2, 2025

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-25

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

August 15, 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.

Effective Date of Revocation

Location

John Derner Foundation

01/01/2021

Milford, IA

Second Paw Dog Rescue

01/01/2022

Abilene, TX

Second Paw Dog Rescue

01/01/2022

Jonesville, LA

Second Paw Dog Rescue

01/01/2022

Newton, MS

Second Paw Dog Rescue

01/01/2022

Knox City, TX

Second Paw Dog Rescue

01/01/2022

McCall Creek, MS

Legacy of Faith Partners

01/01/2022

Rocklin, CA

Name Of Organization

September 2, 2025

360

Bulletin No. 2025–36

Notice of Proposed

Rulemaking

Returns Relating to Sales

or Exchanges of Certain

Partnership Interests

REG-108822-25

Agency: Internal Revenue Service (IRS),

Treasury.

Action: Notice of proposed rulemaking.

Summary: This document contains proposed regulations modifying information

reporting obligations with respect to sales

or exchanges of certain interests in partnerships owning inventory or unrealized

receivables. The proposed regulations

affect partnerships.

DATES: Written or electronic comments

and requests for a public hearing must be

received by September 18, 2025.

ADDRESSES: Commenters are strongly

encouraged to submit public comments

and requests for a public hearing electronically via the Federal eRulemaking Portal

at https://www.regulations.gov (indicate

IRS and REG-108822-25) by following

the online instructions for submitting

comments and requests for a public hearing. Requests for a public hearing must

be submitted as prescribed in the “Comments and Requests for a Public Hearing”

section. Once submitted to the Federal

eRulemaking Portal, comments cannot be

edited or withdrawn. The Department of

the Treasury (Treasury Department) and

the IRS will publish for public availability any comment submitted to the IRS’s

public docket. Send paper submissions to:

CC:PA:01:PR (REG-108822-25), Room

5203, Internal Revenue Service, P.O. Box

7604, Ben Franklin Station, Washington,

DC 20044.

FOR FURTHER INFORMATION

CONTACT: Concerning the proposed

regulations, Jeremy Brown, (202) 3175279 (not a toll-free number); concerning the submission of comments, contact

Bulletin No. 2025–36

the Publications and Regulations Section

of the Office of Associate Chief Counsel

(Procedure and Administration) by email

at publichearings@irs.gov (preferred) or

by telephone at (202) 317-6901 (not a tollfree number).

SUPPLEMENTARY INFORMATION:

Authority

This document contains proposed

amendments to the Income Tax Regulations (26 CFR part 1) under section

6050K of the Internal Revenue Code

(Code). Section 6050K(a) provides that,

except as provided in regulations prescribed by the Secretary of the Treasury

or the Secretary’s delegate (Secretary),

a partnership is required to file a return

if there is an exchange described in section 751(a) of the Code of any interest in

the partnership during any calendar year.

Section 6050K(a) also contains express

delegations of authority for the Secretary

to promulgate regulations prescribing the

information required to be disclosed on

such partnership returns, the manner in

which such returns are made, and the due

date of such returns.

Section 6031(a) of the Code provides

an express grant of authority for the Secretary to prescribe in forms or regulations

partnership reporting information required

“for the purpose of carrying out the provisions of subtitle A.”

Section 7805(a) of the Code authorizes

the Secretary to “prescribe all needful

rules and regulations for the enforcement

of [the Code], including all rules and regulations as may be necessary by reason of

any alteration of law in relation to internal

revenue.”

Background

Section 741 of the Code provides that

gain or loss recognized by a transferor

partner upon sale or exchange of a partnership interest is considered as gain or

loss from the sale or exchange of a capital

asset, except as provided in section 751.

Section 751(a) provides that the amount of

any money, or the fair market value of any

property, received by a transferor partner

in exchange for all or a part of the transferor partner’s interest in the partnership

361

attributable to (1) unrealized receivables

of the partnership, or (2) inventory items

of the partnership, will be considered as an

amount realized from the sale or exchange

of property other than a capital asset. Section 1.6050K-1(a)(4)(i) refers to a sale or

exchange to which section 751(a) applies

as a “section 751(a) exchange.”

Section 6050K(a) requires a partnership to file a return if there is a section

751(a) exchange of any interest in the

partnership during any calendar year. Section 6050K(a) further provides that the

return must state the name and address of

the transferee and transferor in the section

751(a) exchange and such other information as the Secretary may by regulations

prescribe.

Section 1.6050K-1(a)(1) generally

requires a partnership to make a separate

return using Form 8308, Report of a Sale

or Exchange of Certain Partnership Interests, with respect to each section 751(a)

exchange. Section 1.6050K-1(b) requires

the Form 8308 to include the following

information: (1) the names, addresses,

and taxpayer identification numbers of the

transferee and transferor in the exchange

and of the partnership filing the return;

(2) the date of the exchange; and (3) such

other information as may be required

by Form 8308 or its instructions. Section 1.6050K-1(f)(1) requires a partnership to file Form 8308 as an attachment to

its Form 1065, U.S. Return of Partnership

Income, for the partnership’s taxable year

that includes the last day of the calendar

year in which the section 751(a) exchange

took place.

Section 6050K(b) requires a partnership to provide certain information to

transferors and transferees that are parties

to a section 751(a) exchange on or before

January 31 of the year following the calendar year of the section 751(a) exchange.

Among other things, the information provided to each transferor and transferee

must include the information required

to be shown on the partnership’s return

under section 6050K(a) with respect to

such person.

Section 6050K(c)(1) provides that the

transferor of the partnership interest must

notify the partnership of any exchange

described in section 6050K(a). Under

section 6050K(c)(2), a partnership is

not required to make a return under sec-

September 2, 2025

tion 6050K with respect to any exchange

until the partnership is notified of such

exchange.

Section 1.6050K-1(c)(1) clarifies that

each partnership that is required to file a

Form 8308 must furnish a statement to the

transferor and transferee by the later of

(1) January 31 of the year following the

calendar year in which the section 751(a)

exchange occurs, or (2) 30 days after the

partnership receives notice of the exchange

as specified under section 6050K(c) and

§1.6050K-1(e). A partnership generally

must use a copy of the completed Form

8308 as the required statement.

On November 30, 2020, the Treasury

Department and the IRS published in the

Federal Register final regulations (TD

9926, 85 FR 76910) that added §1.6050K1(c)(2) to require a partnership to furnish

to a transferor partner the information

necessary for the transferor to make the

transferor partner’s required statement

in §1.751-1(a)(3). Section 1.751-1(a)(3)

requires a transferor partner in a section

751(a) exchange to submit with the transferor partner’s income tax return for the

taxable year in which the sale or exchange

occurs a statement separately stating the

date of the sale or exchange, the amount of

any gain or loss attributable to section 751

property, and the amount of any gain or

loss attributable to capital gain or loss on

the sale of the partnership interest. After

the promulgation of §1.6050K-1(c)(2), the

IRS revised Form 8308.

Part IV of the revised Form 8308

requires a partnership to report, among

other items, the partnership’s gain or loss

from a deemed sale under section 751

and the transferor partner’s share of such

amount. As a result of the changes to Part

IV of Form 8308, a partnership’s obligation

to report the gain or loss attributable to a

section 751(a) exchange to a transferor is

effectively accelerated to January 31 of the

year following the section 751(a) exchange,

even though §1.751-1(a)(3) generally does

not require the transferor partner to report

such information to the IRS until the transferor partner files the partner’s income tax

return for the taxable year in which the sale

or exchange occurs, the due date of which

can be several months after January 31.

Following the revisions to Form 8308,

the Treasury Department and the IRS

September 2, 2025

received comments from stakeholders

that many partnerships are unable to

furnish the information required in Part

IV of the Form 8308 to transferors and

transferees by the January 31 due date

because, in many cases, partnerships do

not have all the information required by

Part IV of the Form 8308 by January 31

of the year following the calendar year

in which the section 751(a) exchange

occurred.

On January 11, 2024, the IRS published Notice 2024-19, 2024-5 I.R.B. 627,

which provided limited relief from penalties under section 6722 of the Code for

partnerships that failed to furnish a completed Part IV of Form 8308 by January

31, 2024, for section 751(a) exchanges

during calendar year 2023. Penalty relief

in Notice 2024-19 was contingent on the

partnership (1) timely and correctly furnishing to the transferor and transferee a

copy of Parts I, II, and III of Form 8308,

or a statement that includes the same information, by the later of January 31, 2024,

or 30 days after the partnership is notified

of the section 751(a) exchange, and (2)

furnishing to the transferor and transferee

a copy of the complete Form 8308, including Part IV, or a statement that includes

the same information and any additional

information required under §1.6050K1(c), by the later of (a) the due date of the

partnership’s Form 1065 (including extensions), or (b) 30 days after the partnership

is notified of the section 751(a) exchange.

On December 13, 2024, the IRS published

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

extended the relief provided in Notice

2024-19 for partnerships that fail to complete Part IV of Form 8308 by January

31, 2025, with respect to section 751(a)

exchanges occurring during calendar year

2024.

After considering stakeholder feedback

regarding the undue burdens imposed by

§1.6050K-1(c)(2) after the revision of

Form 8308, the Treasury Department and

the IRS are issuing these proposed regulations to propose the removal of §1.6050K1(c)(2).

Explanation of Provisions

The proposed regulations would

remove §1.6050K-1(c)(2) to eliminate

362

the requirement that partnerships furnish

the information required in Part IV of

the Form 8308 by January 31 of the year

following the calendar year in which the

section 751(a) exchange occurred. The

proposed regulations would also modify §1.6050K-1(c)(1) by removing the

reference to a “completed copy of Form

8308” and replacing it with a reference to

“a copy of Form 8308 filled out in accordance with the instructions to the form.”

In addition, the Treasury Department and

the IRS would update the instructions for

Form 8308 to provide that only the information in Parts I, II, and III is required by

the due dates of section 6050K.

As a result of the proposed changes to

§1.6050K-1 and the associated changes

in the instructions to Form 8308, a partnership would be required to furnish

the information reported on only Parts

I, II, and III of Form 8308, or a statement that includes the same information, to the transferor and transferee in

a section 751(a) exchange by the later

of (1) January 31 of the year following

the calendar year in which the section

751(a) exchange occurred, or (2) 30 days

after the partnership has received notice

of the exchange as specified under section 6050K and §1.6050K-1.

Further, the Treasury Department and

the IRS would update the Instructions for

Form 8308 to make clear that a partnership must file a completed Form 8308,

including Part IV, as an attachment to its

Form 1065. Accordingly, and pursuant to

§1.6031(a)-1(a)(2), which provides that a

partnership return must contain the information required by the prescribed form

and the accompanying instructions, a

partnership would be required to file the

completed Form 8308, including Part IV,

as an attachment to its Form 1065, for

the taxable year of the partnership that

includes the last day of the calendar year

in which the section 751(a) exchange took

place. Thus, the current requirement that

a partnership file a completed Form 8308,

including Part IV, as an attachment to its

Form 1065 would remain unchanged by

these proposed regulations.

Pursuant to §1.6031(b)-1T(a)(3),

which provides, in part, that a partnership

generally must furnish a written statement

to each partner containing any additional

Bulletin No. 2025–36

information that may be required by

form or instructions, the partnership will

also continue to be required to report the

information required of the transferor in

§1.751-1(a)(3) to the transferor (including

the information required in Part IV of the

Form 8308), in the Schedule K-1 (Form

1065), Partner’s Share of Income, Deductions, Credits, etc. issued to the transferor

partner as provided by the Form and

Instructions to the Schedule K-1 (Form

1065).

Finally, the proposed regulations would

modify §1.6050K-1(c)(1)(i) to clarify that

the partnership will be providing to the

IRS the information included on a substitute statement furnished in lieu of a Form

8308 under §1.6050K-1(c)(1).

Proposed Applicability Date

Section 1.6050K-1(c)(2) is proposed

to be removed on the date these regulations are published as final regulations

in the Federal Register. The amendment

to §1.6050K-1(c)(1)(i) is proposed to

apply to returns filed for taxable years

ending on or after the date these regulations are published as final regulations

in the Federal Register. However, a

partnership may rely on these proposed

regulations, and the description of the

anticipated changes to the instructions

to Form 8308 contained in this preamble, with respect to section 751(a)

exchanges occurring on or after January

1, 2025, and before the date these regulations are published as final regulations

in the Federal Register.

Special Analyses

I. Regulatory Planning and Review

These proposed regulations are not

subject to review under section 6(b) of

Executive Order 12866 pursuant to the

Memorandum of Agreement (July 4,

2025) between the Treasury Department

and the Office of Management and Budget (OMB) regarding review of tax regulations. Therefore, a regulatory impact

assessment is not required.

The Executive Order 14192 designation for this rule is expected to be deregulatory.

Bulletin No. 2025–36

II. Paperwork Reduction Act

The Paperwork Reduction Act of

1995 (44 U.S.C. 3501-3520) generally

requires that a Federal agency obtain the

approval of the OMB before collecting

information from the public, whether

such collection of information is mandatory, voluntary, or required to obtain

or retain a benefit. An agency may not

conduct or sponsor, and a person is not

required to respond to, a collection of

information unless the collection of

information displays a valid control

number. These proposed regulations do

not impose a new or modify an existing

collection of information.

III. Regulatory Flexibility Act

It is hereby certified that the proposed

regulations would not have a significant

economic impact on a substantial number

of small entities pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6).

This rule would affect partnerships for

which there is a section 751(a) exchange

(as defined in §1.6050K-1(a)(4)(i)). These

proposed regulations would likely affect

a substantial number of small entities

organized as partnerships for Federal tax

purposes, but the impact of the proposed

regulations would be limited because the

proposed regulations would delay the date

by which partnerships must provide transferors of interests in the partnership the

information necessary for the transferor to

make the transferor’s required statement

under §1.751-1(a)(3). This delay would

benefit the partnerships by providing

additional time to furnish the information

but would not have a significant economic

impact. Accordingly, a regulatory flexibility analysis under the Regulatory Flexibility Act is not required. The Treasury

Department and the IRS invite comments

on the impact of the proposed regulations

on small entities.

IV. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandate

Reform Act of 1995 (UMRA) requires

that agencies assess anticipated costs and

benefits and take certain other actions

before issuing a final rule that includes any

363

Federal mandate that may result in expenditures in any one year by a State, local,

or Tribal government, in the aggregate,

or by the private sector, of $100 million

(updated annually for inflation). These

proposed regulations do not include any

Federal mandate that may result in expenditures by State, local, or Tribal governments or by the private sector in excess of

that threshold.

V. Executive Order 13132: Federalism

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

compliance costs on State and local governments, and is not required by statute,

or preempts State law, unless the agency

meets the consultation and funding

requirements of section 6 of the Executive order. These proposed regulations do

not have federalism implications and do

not impose substantial, direct compliance

costs on State and local governments or

preempt State law within the meaning of

the Executive order.

VI. Small Business Administration

Pursuant to section 7805(f), this notice

of proposed rulemaking has been submitted to the Chief Counsel for the Office of

Advocacy of the Small Business Administration for comment on its impact on small

business.

Comments and Request for a Public

Hearing

Before these proposed regulations are

adopted as final regulations, consideration

will be given to comments that are submitted timely to the IRS as prescribed in

the preamble under the ADDRESSES

section. The Treasury Department and

the IRS request comments on all aspects

of the proposed regulations. Any comments submitted will be made available

at https://www.regulations.gov or upon

request. Once submitted to the Federal

eRulemaking Portal, comments cannot

be edited or withdrawn. A public hearing

will be scheduled if requested in writing

by any person that timely submits written

September 2, 2025

comments. If a public hearing is scheduled, notice of the date, time, and place for

the public hearing will be published in the

Federal Register.

Statement of Availability of IRS

Documents

IRS notices and other guidance cited in

this preamble are published in the Internal

Revenue Bulletin (or Cumulative Bulletin)

and are available from the Superintendent

of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by

visiting the IRS website at https://www.

irs.gov.

Drafting Information

The principal authors of these proposed

regulations are Jeremy Brown and Benjamin Weaver of the Office of Associate

Chief Counsel (Passthroughs, Trusts and

Estates). However, other personnel from

the Treasury Department and the IRS participated in their development.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the

Regulations

Accordingly, the Treasury Department

and IRS propose to amend 26 CFR part 1

as follows:

September 2, 2025

PART 1--INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

*****

Section 1.6050K-1 also issued under

26 U.S.C. 6050K(a).

*****

Par. 2. Section 1.6050K-1 is amended

by:

1. Adding a heading for paragraph (c);

2. Revising the introductory text of

paragraph (c)(1);

3. Revising paragraph (c)(1)(i);

4. Removing paragraph (c)(2) and

redesignating paragraph (c)(3) as new

paragraph (c)(2); and

5. Revising paragraph (h).

The revisions read as follows:

§1.6050K-1 Returns relating to sales

or exchanges of certain partnership

interests.

*****

(c) Statement to be furnished to transferor and transferee—(1) In general.

Every partnership required to file a return

under paragraph (a) of this section must

furnish to each person whose name is

required to be set forth in such return a

written statement on or before January

31 of the calendar year following the calendar year in which the section 751(a)

exchange occurred to which the return

under paragraph (a) relates (or, if later,

364

30 days after the partnership is notified

of the exchange as defined in paragraph

(e) of this section). The partnership must

use a copy of the Form 8308, filled out in

accordance with the instructions accompanying the form, as a statement unless

the Form 8308 contains information with

respect to more than one section 751(a)

exchange (see paragraph (a)(3) of this

section). If the partnership does not use

a copy of Form 8308 as a statement, the

statement shall include the information

required to be shown on Form 8308 with

respect to the section 751(a) exchange to

which the person to whom the statement

is furnished is a party. In addition, it shall

state that—

(i) The information shown on the statement will be supplied to the Internal Revenue Service.

*****

(h) Applicability date. Paragraphs (c)

(1) introductory text and (c)(1)(i) of this

section apply to returns filed for taxable

years ending on or after [date of publication of final regulations in the Federal

Register]. Paragraph (c)(2) of this section

applies to returns filed on or after November 30, 2020. Paragraph (d)(3) of this section applies to transfers that occur on or

after November 30, 2020.

Edward T. Killen,

Acting Chief Tax Compliance Officer.

(Filed by the Office of the Federal Register August

18, 2025, 8:45 a.m., and published in the issue of the

Federal Register for August 19, 2025, 90 FR 40269)

Bulletin No. 2025–36

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.

ER—Employer.

Bulletin No. 2025–36

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.

i

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.

September 2, 2025

Numerical Finding List1

Bulletin 2025–36

Announcements:

2025-19, 2025-29 I.R.B. 191

2025-20, 2025-31 I.R.B. 271

2025-21, 2025-32 I.R.B. 312

2025-24, 2025-36 I.R.B. 359

2025-25, 2025-36 I.R.B. 360

Notices:

2025-32, 2025-27 I.R.B. 1

2025-33, 2025-27 I.R.B. 4

2025-34, 2025-27 I.R.B. 6

2025-35, 2025-27 I.R.B. 8

2025-31, 2025-28 I.R.B. 14

2025-36, 2025-30 I.R.B. 192

2025-37, 2025-30 I.R.B. 198

2025-40, 2025-31 I.R.B. 266

2025-39, 2025-32 I.R.B. 308

2025-28, 2025-34 I.R.B. 316

2025-41, 2025-34 I.R.B. 325

2025-42, 2025-36 I.R.B. 351

2025-43, 2025-36 I.R.B. 356

Proposed Regulations:

REG-125710-18, 2025-30 I.R.B. 263

REG-107459-24, 2025-32 I.R.B. 313

REG-132805-17, 2025-35 I.R.B. 342

REG-108822-25, 2025-36 I.R.B. 361

Revenue Procedures:

2025-22, 2025-30 I.R.B. 200

2025-24, 2025-31 I.R.B. 273

2025-25, 2025-32 I.R.B. 311

2025-26, 2025-33 I.R.B. 315

Revenue Rulings:

2025-13, 2025-28 I.R.B. 11

2025-14, 2025-32 I.R.B. 300

2025-15, 2025-32 I.R.B. 302

2025-16, 2025-35 I.R.B. 342

2025-17, 2025-36 I.R.B. 349

Treasury Decisions:

10021, 2025-31 I.R.B. 264

10031, 2025-32 I.R.B. 304

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2025–52, dated December 22, 2025.

1

September 2, 2025

ii

Bulletin No. 2025–36

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–36

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2025–52, dated December 22, 2025.

1

Bulletin No. 2025–36

iii

September 2, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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