Bulletin No. 2025–48

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2025–48

November 24, 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

Notice 2025-62, page 740.

Notice 2025-62 provides penalty relief for taxable year 2025

in connection with the implementation of the new information

reporting requirements related to the deductions for qualified

tips and qualified overtime compensation that were added to

the Internal Revenue Code (Code) by Public Law 119-21, 139

Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). Specifically, this notice provides relief from

the penalty under section 6721 for failure to file correct information returns and the penalty under section 6722 for failure

to furnish correct payee statements. This relief applies only for

taxable year 2025.

Rev. Rul. 2025-22, page 719.

Interest rates: underpayments and overpayments. The rates

for interest determined under Section 6621 of the code for

Finding Lists begin on page ii.

the calendar quarter beginning January 1, 2026, will be 7

percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for

large corporate underpayments. The rate of interest paid on

the portion of a corporate overpayment exceeding $10,000

will be 4.5 percent.

ADMINISTRATIVE, INCOME TAX

Rev. Proc. 2025-31, page 743.

This revenue procedure describes a safe harbor for trusts

that otherwise qualify as investment trusts under § 301.77014(c) and as grantor trusts to stake their digital assets without

jeopardizing their tax status as investment trusts and grantor

trusts for Federal income tax purposes. This revenue procedure also provides a limited time period for an existing trust

to amend its governing instrument to adopt the requirements

of the safe harbor.

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.

November 24, 2025

Bulletin No. 2025–48

Part I

Section 6621.—

Determination of Rate of

Interest

26 CFR 301.6621-1: Interest rate.

Rev. Rul. 2025-22

Section 6621 of the Internal Revenue Code establishes the interest rates

on overpayments and underpayments of

tax. Under section 6621(a)(1), the overpayment rate is the sum of the federal

short-term rate plus 3 percentage points (2

percentage points in the case of a corporation), except the rate for the portion of

a corporate overpayment of tax exceeding

$10,000 for a taxable period is the sum

of the federal short-term rate plus 0.5 of

a percentage point. Under section 6621(a)

(2), the underpayment rate is the sum of

the federal short-term rate plus 3 percentage points.

Section 6621(c) provides that for purposes of interest payable under section

6601 on any large corporate underpayment, the underpayment rate under section 6621(a)(2) is determined by substituting “5 percentage points” for “3

percentage points.” See section 6621(c)

and section 301.6621-3 of the Regulations on Procedure and Administration for the definition of a large corporate underpayment and for the rules for

determining the applicable date. Section

6621(c) and section 301.6621-3 are generally effective for periods after December 31, 1990.

Section 6621(b)(1) provides that the

Secretary will determine the federal shortterm rate for the first month in each cal-

Bulletin No. 2025–48

endar quarter. Section 6621(b)(2)(A)

provides that the federal short-term rate

determined under section 6621(b)(1) for

any month applies during the first calendar quarter beginning after that month.

Section 6621(b)(3) provides that the federal short-term rate for any month is the

federal short-term rate determined during

that month by the Secretary in accordance

with section 1274(d), rounded to the nearest full percent (or, if a multiple of 1/2 of

1 percent, the rate is increased to the next

highest full percent).

Notice 88-59, 1988-1 C.B. 546,

announced that in determining the quarterly interest rates to be used for overpayments and underpayments of tax under

section 6621, the Internal Revenue Service will use the federal short-term rate

based on daily compounding because that

rate is most consistent with section 6621

which, pursuant to section 6622, is subject

to daily compounding.

The federal short-term rate determined

in accordance with section 1274(d) during

October 2025 is the rate published in

Revenue Ruling 2025-21, 2025-45 IRB

690, to take effect beginning November 1, 2025. The federal short-term rate,

rounded to the nearest full percent, based

on daily compounding determined during

the month of October 2025 is 4 percent.

Accordingly, an overpayment rate of 7

percent (6 percent in the case of a corporation) and an underpayment rate of 7

percent are established for the calendar

quarter beginning January 1, 2026. The

overpayment rate for the portion of a corporate overpayment exceeding $10,000

for the calendar quarter beginning January

1, 2026, is 4.5 percent. The underpayment

rate for large corporate underpayments for

the calendar quarter beginning January 1,

719

2026, is 9 percent. These rates apply to

amounts bearing interest during that calendar quarter.

Sections 6654(a)(1) and 6655(a)

(1) provide that the underpayment rate

established under section 6621 applies

in determining the addition to tax under

sections 6654 and 6655 for failure to pay

estimated tax for any taxable year. Thus,

the 7 percent rate also applies to estimated

tax underpayments for the first calendar

quarter beginning January 1, 2026. Pursuant to section 6621(b)(2)(B), in determining the addition to tax under section 6654

for any taxable year for an individual, the

federal short-term rate that applies during

the third month following the taxable year

also applies during the first 15 days of the

fourth month following the taxable year.

In addition, pursuant to section 6603(d)

(4), the rate of interest on section 6603

deposits is 4 percent for the first calendar

quarter in 2026.

Interest factors for daily compound

interest for annual rates of 4.5 percent, 6

percent, 7 percent and 9 percent are published in Tables 14, 17, 19 and 23 of Rev.

Proc. 95-17, 1995-1 C.B. 568, 571, 573,

and 577.

Annual interest rates to be compounded

daily pursuant to section 6622 that apply

for prior periods are set forth in the tables

accompanying this revenue ruling.

DRAFTING INFORMATION

The principal author of this revenue

ruling is Casey R. Conrad of the Office of

the Associate Chief Counsel (Procedure

and Administration). For further information regarding this revenue ruling, contact

Mr. Conrad at (202) 317-6844 (not a tollfree call).

November 24, 2025

Days

Factor

0.000013699

0.000027397

0.000041096

0.000054796

0.000068495

0.000082195

0.000095894

0.000109594

0.000123294

0.000136995

0.000150695

0.000164396

0.000178097

0.000191798

0.000205499

0.000219201

0.000232902

0.000246604

0.000260306

0.000274008

0.000287711

365 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000863380

0.000877091

0.000890801

0.000904512

0.000918223

0.000931934

0.000945646

0.000959357

0.000973069

0.000986781

0.001000493

0.001014206

0.001027918

0.001041631

0.001055344

0.001069057

0.001082770

0.001096484

0.001110197

0.001123911

0.001137625

0.000301413

0.000315116

0.000328819

0.000342522

0.000356225

0.000369929

0.000383633

0.000397336

0.000411041

0.000424745

0.000438449

0.000452154

0.000465859

0.000479564

0.000493269

0.000506974

0.000520680

0.000534386

0.000548092

0.000561798

0.000575504

100

101

102

103

104

November 24, 2025

0.001151339

0.001165054

0.001178768

0.001192483

0.001206198

0.001219913

0.001233629

0.001247344

0.001261060

0.001274776

0.001288492

0.001302208

0.001315925

0.001329641

0.001343358

0.001357075

0.001370792

0.001384510

0.001398227

0.001411945

0.001425663

720

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

Factor

0.001713784

0.001727506

0.001741228

0.001754951

0.001768673

0.001782396

0.001796119

0.001809843

0.001823566

0.001837290

0.001851013

0.001864737

0.001878462

0.001892186

0.001905910

0.001919635

0.001933360

0.001947085

0.001960811

0.001974536

0.001988262

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

0.002001988

0.002015714

0.002029440

0.002043166

0.002056893

0.002070620

0.002084347

0.002098074

0.002111801

0.002125529

0.002139257

0.002152985

0.002166713

0.002180441

0.002194169

0.002207898

0.002221627

0.002235356

0.002249085

0.002262815

0.002276544

Bulletin No. 2025–48

0.000589211

0.000602917

0.000616624

0.000630331

0.000644039

0.000657746

0.000671454

0.000685161

0.000698869

0.000712578

0.000726286

0.000739995

0.000753703

0.000767412

0.000781121

0.000794831

0.000808540

0.000822250

0.000835960

0.000849670

Bulletin No. 2025–48

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001439381

0.001453100

0.001466818

0.001480537

0.001494256

0.001507975

0.001521694

0.001535414

0.001549133

0.001562853

0.001576573

0.001590293

0.001604014

0.001617734

0.001631455

0.001645176

0.001658897

0.001672619

0.001686340

0.001700062

721

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002290274

0.002304004

0.002317734

0.002331465

0.002345195

0.002358926

0.002372657

0.002386388

0.002400120

0.002413851

0.002427583

0.002441315

0.002455047

0.002468779

0.002482511

0.002496244

0.002509977

0.002523710

November 24, 2025

Days

Factor

0.000013661

0.000027323

0.000040984

0.000054646

0.000068308

0.000081970

0.000095632

0.000109295

0.000122958

0.000136620

0.000150283

0.000163947

0.000177610

0.000191274

0.000204938

0.000218602

0.000232266

0.000245930

0.000259595

0.000273260

0.000286924

0.000300590

0.000314255

0.000327920

0.000341586

0.000355252

0.000368918

0.000382584

0.000396251

0.000409917

0.000423584

0.000437251

0.000450918

0.000464586

0.000478253

0.000491921

0.000505589

0.000519257

0.000532925

0.000546594

0.000560262

0.000573931

November 24, 2025

366 Day Year

0.5% Compound Rate 184 Days

Days

Factor

0.000861020

0.000874693

0.000888366

0.000902040

0.000915713

0.000929387

0.000943061

0.000956735

0.000970409

0.000984084

0.000997758

0.001011433

0.001025108

0.001038783

0.001052459

0.001066134

0.001079810

0.001093486

0.001107162

0.001120839

0.001134515

0.001148192

0.001161869

0.001175546

0.001189223

0.001202900

0.001216578

0.001230256

0.001243934

0.001257612

0.001271291

0.001284969

0.001298648

0.001312327

0.001326006

0.001339685

0.001353365

100

0.001367044

101

0.001380724

102

0.001394404

103

0.001408085

104

0.001421765

722

Days

125

126

127

128

129

130

131

132

133

134

135

136

137

138

139

140

141

142

143

144

145

146

147

148

149

150

151

152

153

154

155

156

157

158

159

160

161

162

163

164

165

166

Factor

0.001709097

0.001722782

0.001736467

0.001750152

0.001763837

0.001777522

0.001791208

0.001804893

0.001818579

0.001832265

0.001845951

0.001859638

0.001873324

0.001887011

0.001900698

0.001914385

0.001928073

0.001941760

0.001955448

0.001969136

0.001982824

0.001996512

0.002010201

0.002023889

0.002037578

0.002051267

0.002064957

0.002078646

0.002092336

0.002106025

0.002119715

0.002133405

0.002147096

0.002160786

0.002174477

0.002188168

0.002201859

0.002215550

0.002229242

0.002242933

0.002256625

0.002270317

Bulletin No. 2025–48

0.000587600

0.000601269

0.000614939

0.000628608

0.000642278

0.000655948

0.000669618

0.000683289

0.000696959

0.000710630

0.000724301

0.000737972

0.000751643

0.000765315

0.000778986

0.000792658

0.000806330

0.000820003

0.000833675

0.000847348

Bulletin No. 2025–48

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119

120

121

122

123

124

0.001435446

0.001449127

0.001462808

0.001476489

0.001490170

0.001503852

0.001517533

0.001531215

0.001544897

0.001558580

0.001572262

0.001585945

0.001599628

0.001613311

0.001626994

0.001640678

0.001654361

0.001668045

0.001681729

0.001695413

723

167

168

169

170

171

172

173

174

175

176

177

178

179

180

181

182

183

184

0.002284010

0.002297702

0.002311395

0.002325087

0.002338780

0.002352473

0.002366167

0.002379860

0.002393554

0.002407248

0.002420942

0.002434636

0.002448331

0.002462025

0.002475720

0.002489415

0.002503110

0.002516806

November 24, 2025

TABLE OF INTEREST RATES

PERIODS BEFORE JUL. 1, 1975 - PERIODS ENDING DEC. 31, 1986

OVERPAYMENTS AND UNDERPAYMENTS

PERIOD

RATE

Before Jul. 1, 1975

Jul. 1, 1975–Jan. 31, 1976

Feb. 1, 1976–Jan. 31, 1978

Feb. 1, 1978–Jan. 31, 1980

Feb. 1, 1980–Jan. 31, 1982

Feb. 1, 1982–Dec. 31, 1982

Jan. 1, 1983–Jun. 30, 1983

Jul. 1, 1983–Dec. 31, 1983

Jan. 1, 1984–Jun. 30, 1984

Jul. 1, 1984–Dec. 31, 1984

Jan. 1, 1985–Dec. 31, 1985

Jul. 1, 1985–Dec. 31, 1985

Jan. 1, 1986–Jun. 30, 1986

Jul. 1, 1986–Dec. 31, 1986

12%

20%

16%

11%

13%

11%

10%

Table

In 1995-1 C.B.

DAILY RATE TABLE

pg.

37,

pg.

27,

pg.

75,

pg.

75,

pg.

31,

pg.

27,

pg.

25,

pg.

23,

pg.

557

559

558

557

560

591

581

629

585

581

579

577

TABLE OF INTEREST RATES

FROM JAN. 1, 1987 - Dec. 31, 1998

Jan. 1, 1987–Mar. 31, 1987

Apr. 1, 1987–Jun. 30, 1987

Jul. 1, 1987–Sep. 30, 1987

Oct. 1, 1987–Dec. 31, 1987

Jan. 1, 1988–Mar. 31, 1988

Apr. 1, 1988–Jun. 30, 1988

Jul. 1, 1988–Sep. 30, 1988

Oct. 1, 1988–Dec. 31, 1988

Jan. 1, 1989–Mar. 31, 1989

Apr. 1, 1989–Jun. 30, 1989

Jul. 1, 1989–Sep. 30, 1989

Oct. 1, 1989–Dec. 31, 1989

Jan. 1, 1990–Mar. 31, 1990

Apr. 1, 1990–Jun. 30, 1990

Jul. 1, 1990–Sep. 30, 1990

Oct. 1, 1990–Dec. 31, 1990

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

November 24, 2025

RATE

10%

11%

10%

OVERPAYMENTS

1995-1 C.B.

TABLE

575

577

627

625

627

579

581

579

577

623

724

UNDERPAYMENTS

1995-1 C.B. RATE

RATE

TABLE

577

10%

579

11%

629

10%

627

10%

627

11%

629

11%

581

12%

583

12%

583

11%

581

11%

581

11%

581

11%

581

11%

581

11%

581

10%

579

10%

579

10%

579

625

Bulletin No. 2025–48

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Mar. 31, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

Bulletin No. 2025–48

725

621

619

571

573

575

577

575

623

621

623

575

573

10%

623

621

573

575

577

579

577

625

623

625

577

575

November 24, 2025

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS

1995-1 C.B.

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Jan. 1, 2009–Mar. 31, 2009

November 24, 2025

RATE

726

TABLE

PAGE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

619

569

Bulletin No. 2025–48

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

Bulletin No. 2025–48

727

567

565

567

565

613

565

613

615

567

569

571

569

617

November 24, 2025

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023–Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

November 24, 2025

728

613

565

567

569

571

573

575

623

573

Bulletin No. 2025–48

TABLE OF INTEREST RATES

FROM JANUARY 1, 1999 - PRESENT

CORPORATE OVERPAYMENTS AND UNDERPAYMENTS

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 30, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Jun. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Jun. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Bulletin No. 2025–48

OVERPAYMENTS

1995-1 C.B.

RATE

TABLE

729

571

573

621

623

575

573

571

569

567

565

613

615

613

615

567

569

571

573

619

617

615

617

UNDERPAYMENTS

1995-1 C.B.

RATE

TABLE

573

575

623

625

577

575

573

571

569

567

615

617

615

617

569

571

573

575

621

619

617

619

November 24, 2025

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011–Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012–Jun. 30, 2012

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

November 24, 2025

730

567

565

563

565

563

611

563

611

613

565

567

569

567

615

569

567

565

567

565

613

565

613

615

567

569

571

569

617

Bulletin No. 2025–48

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023–Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

Bulletin No. 2025–48

731

615

611

563

565

567

569

571

573

621

571

617

613

565

567

569

571

573

575

623

573

November 24, 2025

TABLE OF INTEREST RATES

FOR LARGE CORPORATE UNDERPAYMENTS

FROM JANUARY 1, 1991 – PRESENT

PERIOD

Jan. 1, 1991–Mar. 31, 1991

Apr. 1, 1991–Jun. 30, 1991

Jul. 1, 1991–Sep. 30, 1991

Oct. 1, 1991–Dec. 31, 1991

Jan. 1, 1992–Mar. 31, 1992

Apr. 1, 1992–Jun. 30, 1992

Jul. 1, 1992–Sep. 30, 1992

Oct. 1, 1992–Dec. 31, 1992

Jan. 1, 1993–Mar. 31, 1993

Apr. 1, 1993–Jun. 30, 1993

Jul. 1, 1993–Sep. 30, 1993

Oct. 1, 1993–Dec. 31, 1993

Jan. 1, 1994–Mar. 31, 1994

Apr. 1, 1994–Jun. 30, 1994

Jul. 1, 1994–Sep. 30, 1994

Oct. 1, 1994–Dec. 31, 1994

Jan. 1, 1995–Jun. 30, 1995

Apr. 1, 1995–Jun. 30, 1995

Jul. 1, 1995–Sep. 30, 1995

Oct. 1, 1995–Dec. 31, 1995

Jan. 1, 1996–Mar. 31, 1996

Apr. 1, 1996–Jun. 30, 1996

Jul. 1, 1996–Sep. 30, 1996

Oct. 1, 1996–Dec. 31, 1996

Jan. 1, 1997–Mar. 31, 1997

Apr. 1, 1997–Jun. 30, 1997

Jul. 1, 1997–Sep. 30, 1997

Oct. 1, 1997–Dec. 31, 1997

Jan. 1, 1998–Mar. 31, 1998

Apr. 1, 1998–Jun. 30, 1998

Jul. 1, 1998–Sep. 30, 1998

Oct. 1, 1998–Dec. 31, 1998

Jan. 1, 1999–Mar. 31, 1999

Apr. 1, 1999–Jun. 30, 1999

Jul. 1, 1999–Sep. 30, 1999

Oct. 1, 1999–Dec. 31, 1999

Jan. 1, 2000–Mar. 31, 2000

Apr. 1, 2000–Jun. 30, 2000

Jul. 1, 2000–Sep. 30, 2000

Oct. 1, 2000–Dec. 31, 2000

Jan. 1, 2001–Mar. 31, 2001

November 24, 2025

RATE

13%

12%

11%

10%

11%

12%

11%

10%

11%

10%

11%

732

1995-1 C.B.

TABLE

585

583

629

627

625

577

579

581

583

581

629

627

629

581

579

577

579

627

629

581

Bulletin No. 2025–48

Apr. 1, 2001–Jun. 30, 2001

Jul. 1, 2001–Sep. 30, 2001

Oct. 1, 2001–Dec. 31, 2001

Jan. 1, 2002–Mar. 31, 2002

Apr. 1, 2002–Sep. 30, 2002

Jul. 1, 2002–Sep. 30, 2002

Oct. 1, 2002–Dec. 31, 2002

Jan. 1, 2003–Mar. 31, 2003

Apr. 1, 2003–Jun. 30, 2003

Jul. 1, 2003–Sep. 30, 2003

Oct. 1, 2003–Dec. 31, 2003

Jan. 1, 2004–Mar. 31, 2004

Apr. 1, 2004–Jun. 30, 2004

Jul. 1, 2004–Sep. 30, 2004

Oct. 1, 2004–Dec. 31, 2004

Jan. 1, 2005–Mar. 31, 2005

Apr. 1, 2005–Jun. 30, 2005

Jul. 1, 2005–Sep. 30, 2005

Oct. 1, 2005–Dec. 31, 2005

Jan. 1, 2006–Mar. 31, 2006

Apr. 1, 2006–Jun. 30, 2006

Jul. 1, 2006–Sep. 30, 2006

Oct. 1, 2006–Dec. 31, 2006

Jan. 1, 2007–Mar. 31, 2007

Apr. 1, 2007–Jun. 30, 2007

Jul. 1, 2007–Sep. 30, 2007

Oct. 1, 2007–Dec. 31, 2007

Jan. 1, 2008–Mar. 31, 2008

Apr. 1, 2008–Sep. 30, 2008

Jul. 1, 2008–Sep. 30, 2008

Oct. 1, 2008–Dec. 31, 2008

Jan. 1, 2009–Mar. 31, 2009

Apr. 1, 2009–Jun. 30, 2009

Jul. 1, 2009–Sep. 30, 2009

Oct. 1, 2009–Dec. 31, 2009

Jan. 1, 2010–Mar. 31, 2010

Apr. 1, 2010–Jun. 30, 2010

Jul. 1, 2010–Sep. 30, 2010

Oct. 1, 2010–Dec. 31, 2010

Jan. 1, 2011-Mar. 31, 2011

Apr. 1, 2011–Jun. 30, 2011

Jul. 1, 2011–Sep. 30, 2011

Oct. 1, 2011–Dec. 31, 2011

Jan. 1, 2012–Mar. 31, 2012

Apr. 1, 2012-Jun. 30, 2012

Bulletin No. 2025–48

10%

733

579

577

575

573

571

619

621

619

621

573

575

577

579

625

623

621

623

573

571

569

571

569

617

November 24, 2025

Jul. 1, 2012–Sep. 30, 2012

Oct. 1, 2012–Dec. 31, 2012

Jan. 1, 2013–Mar. 31, 2013

Apr. 1, 2013–Jun. 30, 2013

Jul. 1, 2013–Sep. 30, 2013

Oct. 1, 2013–Dec. 31, 2013

Jan. 1, 2014–Mar. 31, 2014

Apr. 1, 2014–Jun. 30, 2014

Jul. 1, 2014–Sep. 30, 2014

Oct. 1, 2014–Dec. 31, 2014

Jan. 1, 2015–Mar. 31, 2015

Apr. 1, 2015–Jun. 30, 2015

Jul. 1, 2015–Sep. 30, 2015

Oct. 1, 2015–Dec. 31, 2015

Jan. 1, 2016–Mar. 31, 2016

Apr. 1, 2016–Jun. 30, 2016

Jul. 1, 2016–Sep. 30, 2016

Oct. 1, 2016–Dec. 31, 2016

Jan. 1, 2017–Mar. 31, 2017

Apr. 1, 2017–Jun. 30, 2017

Jul. 1, 2017–Sep. 30, 2017

Oct. 1, 2017–Dec. 31, 2017

Jan. 1, 2018–Mar. 31, 2018

Apr. 1, 2018–Jun. 30, 2018

Jul. 1, 2018–Sep. 30, 2018

Oct. 1, 2018–Dec. 31, 2018

Jan. 1, 2019–Mar. 31, 2019

Apr. 1, 2019–Jun. 30, 2019

Jul. 1, 2019–Sep. 30, 2019

Oct. 1, 2019–Dec. 31, 2019

Jan. 1, 2020–Mar. 31, 2020

Apr. 1, 2020–Jun. 30, 2020

Jul. 1, 2020–Sep. 30, 2020

Oct. 1, 2020–Dec. 31, 2020

Jan. 1, 2021–Mar. 31, 2021

Apr. 1, 2021–Jun. 30, 2021

Jul. 1, 2021–Sep. 30, 2021

Oct. 1, 2021–Dec. 31, 2021

Jan. 1, 2022–Mar. 31, 2022

Apr. 1, 2022–Jun. 30, 2022

Jul. 1, 2022–Sep. 30, 2022

Oct. 1, 2022–Dec. 31, 2022

Jan. 1, 2023–Mar. 31, 2023

Apr. 1, 2023-Jun. 30, 2023

Jul. 1, 2023–Sep. 30, 2023

November 24, 2025

734

617

569

617

619

571

573

575

573

621

617

569

571

573

575

577

Bulletin No. 2025–48

Oct. 1, 2023–Dec. 31, 2023

Jan. 1, 2024–Mar. 31, 2024

Apr. 1, 2024–Jun. 30, 2024

Jul. 1, 2024–Sep. 30, 2024

Oct. 1, 2024–Dec. 31, 2024

Jan. 1, 2025–Mar. 31, 2025

Apr. 1, 2025–Jun. 30, 2025

Jul. 1, 2025–Sep. 30, 2025

Oct. 1, 2025–Dec. 31, 2025

Jan. 1, 2026–Mar. 31, 2026

Bulletin No. 2025–48

10%

735

579

627

577

November 24, 2025

TABLE OF INTEREST RATES FOR CORPORATE

OVERPAYMENTS EXCEEDING $10,000

FROM JANUARY 1, 1995 – PRESENT

1995-1 C.B.

PERIOD

RATE

TABLE

Jan. 1, 1995–Mar. 31, 1995

6.5%

572

Apr. 1, 1995–Jun. 30, 1995

7.5%

574

Jul. 1, 1995–Sep. 30, 1995

6.5%

572

Oct. 1, 1995–Dec. 31, 1995

6.5%

572

Jan. 1, 1996–Mar. 31, 1996

6.5%

620

Apr. 1, 1996–Jun. 30, 1996

5.5%

618

Jul. 1, 1996–Sep. 30, 1996

6.5%

620

Oct. 1, 1996–Dec. 31, 1996

6.5%

620

Jan. 1, 1997–Mar. 31, 1997

6.5%

572

Apr. 1, 1997–Jun. 30, 1997

6.5%

572

Jul. 1, 1997–Sep. 30, 1997

6.5%

572

Oct. 1, 1997–Dec. 31, 1997

6.5%

572

Jan. 1, 1998–Mar. 31, 1998

6.5%

572

Apr. 1, 1998–Jun. 30, 1998

5.5%

570

Jul. 1, 1998–Sep. 30, 1998

5.5%

570

Oct. 1, 1998–Dec. 31, 1998

5.5%

570

Jan. 1, 1999–Mar. 31, 1999

4.5%

568

Apr. 1, 1999–Sep. 30, 1999

5.5%

570

Jul. 1, 1999–Sep. 30, 1999

5.5%

570

Oct. 1, 1999–Dec. 31, 1999

5.5%

570

Jan. 1, 2000–Mar. 31, 2000

5.5%

618

Apr. 1, 2000–Jun. 30, 2000

6.5%

620

Jul. 1, 2000–Sep. 30, 2000

6.5%

620

Oct. 1, 2000–Dec. 31, 2000

6.5%

620

Jan. 1, 2001–Mar. 31, 2001

6.5%

572

Apr. 1, 2001–Jun. 30, 2001

5.5%

570

Jul. 1, 2001–Sep. 30, 2001

4.5%

568

Oct. 1, 2001–Dec. 31, 2001

4.5%

568

Jan. 1, 2002–Mar. 31, 2002

3.5%

566

Apr. 1, 2002–Jun. 30, 2002

3.5%

566

Jul. 1, 2002–Sep. 30, 2002

3.5%

566

Oct. 1, 2002–Dec. 31, 2002

3.5%

566

Jan. 1, 2003–Mar. 31, 2003

2.5%

564

Apr. 1, 2003–Jun. 30, 2003

2.5%

564

Jul. 1, 2003–Sep. 30, 2003

2.5%

564

Oct. 1, 2003–Dec. 31, 2003

1.5%

562

Jan. 1, 2004–Mar. 31, 2004

1.5%

610

Apr. 1, 2004–Jun. 30, 2004

2.5%

612

November 24, 2025

736

Bulletin No. 2025–48

Jul. 1, 2004–Sep. 30, 2004

1.5%

610

Oct. 1, 2004–Dec. 31, 2004

2.5%

612

Jan. 1, 2005–Mar. 31, 2005

2.5%

564

Apr. 1, 2005–Jun. 30, 2005

3.5%

566

Jul. 1, 2005–Sep. 30, 2005

3.5%

566

Oct. 1, 2005–Dec. 31, 2005

4.5%

568

Jan. 1, 2006–Mar. 31, 2006

4.5%

568

Apr. 1, 2006–Jun. 30, 2006

4.5%

568

Jul. 1, 2006–Sep. 30, 2006

5.5%

570

Oct. 1, 2006–Dec. 31, 2006

5.5%

570

Jan. 1, 2007–Mar. 31, 2007

5.5%

570

Apr. 1, 2007–Jun. 30, 2007

5.5%

570

Jul. 1, 2007–Sep. 30, 2007

5.5%

570

Oct. 1, 2007–Dec. 31, 2007

5.5%

570

Jan. 1, 2008–Mar. 31, 2008

4.5%

616

Apr. 1, 2008–Jun. 30, 2008

3.5%

614

Jul. 1, 2008–Sep. 30, 2008

2.5%

612

Oct. 1, 2008–Dec. 31, 2008

3.5%

614

Jan. 1, 2009–Mar. 31, 2009

2.5%

564

Apr. 1, 2009–Jun. 30, 2009

1.5%

562

Jul. 1, 2009–Sep. 30, 2009

1.5%

562

Oct. 1, 2009–Dec. 31, 2009

1.5%

562

Jan. 1, 2010–Mar. 31, 2010

1.5%

562

Apr. 1, 2010–Jun. 30, 2010

1.5%

562

Jul. 1, 2010–Sep. 30, 2010

1.5%

562

Oct. 1, 2010–Dec. 31, 2010

1.5%

562

Jan. 1, 2011–Mar. 31, 2011

0.5%*

Apr. 1, 2011–Jun. 30, 2011

1.5%

562

Jul. 1, 2011–Sep. 30, 2011

1.5%

562

Oct. 1, 2011–Dec. 31, 2011

0.5%*

Jan. 1, 2012–Mar. 31, 2012

0.5%*

Apr. 1, 2012–Jun. 30, 2012

0.5%*

Jul. 1, 2012–Sep. 30, 2012

0.5%*

Oct. 1, 2012–Dec. 31, 2012

0.5%*

Jan. 1, 2013–Mar. 31, 2013

0.5%*

Apr. 1, 2013–Jun. 30, 2013

0.5%*

Jul. 1, 2013–Sep. 30, 2013

0.5%*

Oct. 1, 2013–Dec. 31, 2013

0.5%*

Jan. 1, 2014–Mar. 31, 2014

0.5%*

Apr. 1, 2014–Jun. 30, 2014

0.5%*

Jul. 1, 2014–Sep. 30, 2014

0.5%*

Oct. 1, 2014–Dec. 31, 2014

0.5%*

Bulletin No. 2025–48

737

November 24, 2025

Jan. 1, 2015–Mar. 31, 2015

0.5%*

Apr. 1, 2015–Jun. 30, 2015

0.5%*

Jul. 1, 2015–Sep. 30, 2015

0.5%*

Oct. 1, 2015–Dec. 31, 2015

0.5%*

Jan. 1, 2016–Mar. 31, 2016

0.5%*

Apr. 1, 2016–Jun. 30, 2016

1.5%

610

Jul. 1, 2016–Sep. 30, 2016

1.5%

610

Oct. 1, 2016–Dec. 31, 2016

1.5%

610

Jan. 1, 2017–Mar. 31, 2017

1.5%

562

Apr. 1, 2017–Jun. 30, 2017

1.5%

562

Jul. 1, 2017–Sep. 30, 2017

1.5%

562

Oct. 1, 2017–Dec. 31, 2017

1.5%

562

Jan. 1, 2018–Mar. 31, 2018

1.5%

562

Apr. 1, 2018–Jun. 30, 2018

2.5%

564

Jul. 1, 2018–Sep. 30, 2018

2.5%

564

Oct. 1, 2018–Dec. 31, 2018

2.5%

564

Jan. 1, 2019–Mar. 31, 2019

3.5%

566

Apr. 1, 2019–Jun. 30, 2019

3.5%

566

Jul. 1, 2019–Sep. 30, 2019

2.5%

564

Oct. 1, 2019–Dec. 31, 2019

2.5%

564

Jan. 1, 2020–Mar. 31, 2020

2.5%

612

Apr. 1, 2020–Jun. 30, 2020

2.5%

612

Jul. 1, 2020–Sep. 30, 2020

0.5%*

Oct. 1, 2020–Dec. 31, 2020

0.5%*

Jan. 1, 2021–Mar. 31, 2021

0.5%*

Apr. 1, 2021–Jun. 30, 2021

0.5%*

Jul. 1, 2021–Sep. 30, 2021

0.5%*

Oct. 1, 2021–Dec. 31, 2021

0.5%*

Jan. 1, 2022–Mar. 31, 2022

0.5%*

Apr. 1, 2022–Jun. 30, 2022

1.5%

562

Jul. 1, 2022–Sep. 30, 2022

2.5%

564

Oct. 1, 2022–Dec. 31, 2022

3.5%

566

Jan. 1, 2023–Mar. 31, 2023

4.5%

568

Apr. 1, 2023–Jun. 30, 2023

4.5%

568

Jul. 1, 2023–Sep. 30, 2023

4.5%

568

Oct. 1, 2023–Dec. 31, 2023

5.5%

570

Jan. 1, 2024–Mar. 31, 2024

5.5%

618

Apr. 1, 2024–Jun. 30, 2024

5.5%

618

Jul. 1, 2024–Sep. 30, 2024

5.5%

618

Oct. 1, 2024–Dec. 31, 2024

5.5%

618

Jan. 1, 2025–Mar. 31, 2025

4.5%

568

Apr. 1, 2025–Jun. 30, 2025

4.5%

568

November 24, 2025

738

Bulletin No. 2025–48

Jul. 1, 2025–Sep. 30, 2025

4.5%

568

Oct. 1, 2025–Dec. 31, 2025

4.5%

568

Jan. 1, 2026–Mar. 31, 2026

4.5%

568

* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of

this Revenue Ruling.

Bulletin No. 2025–48

739

November 24, 2025

Part III

Relief from Certain

Penalties Related to

Information Reporting

Required in Connection

with No Tax on Tips and

Overtime

Notice 2025-62

SECTION 1. PURPOSE

This notice provides penalty relief

for taxable year 2025 in connection with

the implementation of the new information reporting requirements related to the

deductions for qualified tips and qualified

overtime compensation that were added

to the Internal Revenue Code (Code)1 by

Public Law 119-21, 139 Stat. 72 (July 4,

2025), commonly known as the One, Big,

Beautiful Bill Act (OBBBA). Specifically,

this notice provides relief from the penalty under section 6721 for failure to file

correct information returns and the penalty under section 6722 for failure to furnish correct payee statements. This relief

applies only for taxable year 2025.

Additional guidance for individual

taxpayers that addresses how they can

claim the deductions for qualified tips and

qualified overtime compensation when

they file their taxable year 2025 returns is

forthcoming.

SECTION 2. BACKGROUND

.01 Filing and Information Reporting

Requirements Generally

Section 6041(a) requires a person

engaged in a trade or business generally

to file an information return with the Secretary of the Treasury or the Secretary’s

delegate (Secretary) if the person made

payments in the course of such trade or

business to another person of fixed or

determinable income such as rent, salaries, wages, premiums, annuities, or compensation in amounts above the applicable

reporting threshold in any taxable year.

The information return must include the

amount of the gains, profits, and income

and the name and address of the recipient of the payment. A person who files a

return pursuant to section 6041(a) must

also, pursuant to section 6041(d), furnish

to the payee a written statement showing

the name, address, and phone number of

the person required to make the return,

and the aggregate amount of payments to

the payee.

Section 6041A imposes similar filing

and furnishing requirements as section

6041(a) with respect to persons engaged

in a trade or business and who pay in the

course of such trade or business remuneration to any person for services performed

in amounts aggregating above the applicable reporting threshold during the calendar year. The information return required

under section 6041A(a) must include the

aggregate amount of the payments and

the name and address of the recipient. A

person who files a return under section

6041A(a) is required by section 6041A(e)

to furnish to the payee a written statement

showing the name, address, and phone

number of the person required to make

such return, and the aggregate amount of

payments to the payee.

Information returns are also required

to be filed pursuant to section 6050W(a)

by certain payment settlement entities

with respect to payments made in settlement of reportable payment transactions.

Returns required by section 6050W(a)

must include the name, address, and taxpayer identification number of the payee,

and the gross amount of the reportable

payment transactions to the payee. Under

section 6050W(f), a payment settlement

entity required to file a return must also

furnish to each payee a written statement

showing the name, address, and phone

number of the information contact of the

person required to make such return, and

the gross amount paid to the payee.

Section 6050W applies to two types

of transactions: (1) payment card transactions and (2) third party network transactions. All payments made in settlement

of payment card transactions must be

reported in the manner described above.

Section 6050W(e) provides that payments

made by a third party settlement organization (TPSO) in settlement of third party

network transactions must be reported

only if the gross amount of payments to

a payee exceeds the de minimis reporting

threshold rules.

For wages paid to an employee,

an employer is required under section

6051(a) to furnish a written statement to

the employee if it is required to deduct and

withhold from the employee a tax under

section 3101 or 3402, or would have been

required to deduct and withhold a tax

under section 3402 if the employee had

claimed no more than one withholding

exemption, or if it pays remuneration for

services performed by the employee. The

written statement must show, among other

things, the total amount of wages paid,

including tips received by an employee in

the course of his employment, but only if

such tips are included in statements furnished to the employer pursuant to section

6053(a), and the amount of income and

employment taxes deducted and withheld.

An employer required to furnish a written statement to an employee under section 6051(a) must also file a copy of each

written statement with the Social Security

Administration (SSA) pursuant to section

6051(d).

.02 OBBBA Amendments to Sections

6041, 6041A, and 6050W

Before amendment by section 70433

of the OBBBA, the applicable reporting

threshold in each of section 6041 and

6041A was $600. Section 70433(a) of the

OBBBA increased the reporting threshold

under section 6041(a) from $600 to $2,000

with respect to payments made after

December 31, 2025, and before January

1, 2027. For payments made after December 31, 2026, section 6041(h), as added by

section 70433(b) of the OBBBA, provides

for an annual inflation adjustment to the

reporting threshold under section 6041(a).

Section 70433(c) of the OBBBA amended

the reporting threshold under section

Unless otherwise specified, all “section” or “§” references are to sections of the Code.

November 24, 2025

740

Bulletin No. 2025–48

6041A from $600 or more to an amount

that equals or exceeds the dollar amount in

effect for such taxable year under section

6041(a).

Before amendment by section 70432

of the OBBBA, the de minimis reporting

threshold in section 6050W(e) was $600

as enacted by section 9674(a) of the American Rescue Plan Act of 2021, Public Law

117-2, 135 Stat. 4 (March 11, 2021). Section 70432(a) of the OBBBA retroactively

amended the de minimis reporting threshold rules of section 6050W(e) by specifying that the amendment “take effect as if

included in section 9674 of the American

Rescue Plan Act.” After amendment by

the OBBBA, section 6050W(e) provides

that payments made by a TPSO in settlement of third party network transactions

must be reported only if the gross amount

of payments to a payee exceeds $20,000

and the number of transactions exceed

200 with respect to the payee.

.03 New Filing and Information Reporting Requirements Under the OBBBA

(a) Deduction for Qualified Tips

Section 70201(a) of the OBBBA added

new section 224 to the Code, providing

an income tax deduction for “qualified

tips” that are received during the taxable

year. Qualified tips are cash tips received

by individuals in an occupation that customarily and regularly received tips on or

before December 31, 2024, subject to certain exclusions. Specifically, individuals

are allowed a deduction, subject to limitations, in an amount equal to the qualified

tips received during the taxable year that

are included on statements furnished to

the individual pursuant to section 6041(d)

(3), 6041A(e)(3), 6050W(f)(2), or 6051(a)

(18), or reported by the individual on

Form 4137 (or successor). An individual

is not eligible to claim the tip deduction

under section 224 if the individual is not

furnished such a statement.

Section 70201(f) of the OBBBA added

to the information reporting requirements

of the Code for certain payments of cash

tips by:

(1) amending section 6041(a) to

require a payor to include on the information return filed a separate accounting of

any such amounts reasonably designated

as cash tips and the occupation described

in section 224(d)(1) of the person receiving such tips;

Bulletin No. 2025–48

(2) adding new paragraph (d)(3) to

section 6041 to provide that in the case of

compensation to non-employees, a payor

is required to include on the written statement furnished to the payee the portion of

payments reasonably designated as cash

tips and the occupation described in section

224(d)(1) of the person receiving such tips;

(3) amending section 6041A(a) to

require a payor to include on the information return filed a separate accounting of

any such amounts reasonably designated

as cash tips and the occupation described

in section 224(d)(1) of the person receiving such tips;

(4) adding new paragraph (e)(3) to section 6041A to provide that in the case of

section 6041A(a), a payor is required to

include on the written statement furnished

to the payee the portion of payments reasonably designated as cash tips and the

occupation described in section 224(d)(1)

of the person receiving such tips;

(5) adding new paragraph (a)(3) to section 6050W to provide that in the case of a

TPSO, the TPSO is required to include on

the information return filed the portion of

reportable payment transactions that have

been reasonably designated by payors as

cash tips and the occupation described in

section 224(d)(1) of the person receiving

such tips;

(6) amending section 6050W(f)(2) to

require a TPSO to include on the written

statement furnished to the payee a separate

accounting of any such amounts that have

been reasonably designated by payors as

cash tips and the occupation described in

section 224(d)(1) of the person receiving

such tips; and

(7) adding new paragraph (a)(18) to

section 6051 to provide that an employer

must include on the written statement furnished to the employee the total amount

of cash tips reported by the employee

under section 6053(a) and the occupation

described in section 224(d)(1) such person.

Section 70201(j) of the OBBBA provides that the amendments made by section 70201 of the OBBBA with respect

to qualified tips, including the additional

information reporting requirements, apply

to taxable years beginning after December

31, 2024.

(b) Deduction for Qualified Overtime

Compensation

741

Section 70202(a) of the OBBBA added

new section 225 to the Code, providing an

income tax deduction, subject to limitations, in an amount equal to the qualified

overtime compensation received during

the taxable year and included on statements furnished to the individual pursuant

to section 6041(d)(4) or 6051(a)(19).

Section 70202(c) of the OBBBA added

to the information reporting requirements

of the Code for certain payments of qualified overtime compensation by:

(1) adding new paragraph (a)(19) to

section 6051 to provide that an employer

must include on the written statement furnished to the employee the total amount

of qualified overtime compensation (as

defined in section 225(c));

(2) amending section 6041(a) to require

a payor to include on the information

return filed a separate accounting of any

amount of qualified overtime compensation (as defined in section 225(c)); and

(3) adding new paragraph (d)(4) to

section 6041 to provide that a payor is

required to include on the written statement furnished to the payee the portion of

payments that are qualified overtime compensation (as defined in section 225(c)).

Section 70202(g) of the OBBBA provides that the amendments made by section 70202 of the OBBBA, including the

additional information reporting requirements, apply to taxable years beginning

after December 31, 2024.

.04 Penalties

Penalties under sections 6721 and

6722 are applicable to payors subject to

the requirements of sections 6041, 6041A,

6050W, and 6051.

Section 6721 imposes a penalty for any

failure to file an information return on or

before the required filing date, and for any

failure to include all of the information

required to be shown on the return or the

inclusion of incorrect information.

Section 6722 imposes a penalty for

any failure to furnish a payee statement

on or before the required furnishing date

to the person to whom such statement

is required to be furnished, and for any

failure to include all of the information

required to be shown on a payee statement

or the inclusion of incorrect information.

Section 6724(a) provides an exception

to a penalty for any failure under sections

6721 and 6722 if it is shown that the fail-

November 24, 2025

ure is due to reasonable cause and not due

to willful neglect. Under § 301.6724-1 of

the Procedure and Administration Regulations, a penalty may be waived for reasonable cause if the filer establishes that there

are significant mitigating factors with

respect to the failure or the failure arose

from events beyond the filer’s control. In

addition, the filer generally must establish

that the filer acted in a responsible manner

both before and after the failure occurred.

SECTION 3. TRANSITION

PENALTY RELIEF

.01 Qualified Tips and Occupations

Prior to the enactment of the OBBBA,

payors reporting payments pursuant to

sections 6041, 6041A, and 6050W, were

not required to include a separate accounting of amounts designated as cash tips or

the occupation of recipients. Employers

reporting the payment of wages pursuant

to section 6051 generally were required to

report certain tips but were not required

to report the occupations of employees.

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) are aware that payors

and employers may not currently have

the information required to be reported

under the information reporting changes

made by the OBBBA, or the systems

or procedures in place to be able to correctly file the additional information with

the Secretary (or the SSA in the case of a

Form W-2) and furnish such information

to payees and employees. Moreover, the

IRS has already announced that Forms

W-2 and 1099 for taxable year 2025 will

not be updated to account for the OBBBA-related changes. Therefore, taxable

year 2025 will be regarded as a transition

period for purposes of IRS enforcement

and administration of the new information

reporting requirements for cash tips added

to the Code under section 70201(f) of the

OBBBA.

For taxable year 2025, the IRS will

not impose a penalty under section 6721

or 6722 in any of the following circumstances:

(1) if a payor required to file an information return under section 6041(a)

fails to provide on that return a separate

accounting of any such amounts reasonably designated as cash tips or the occupa-

November 24, 2025

tion described in section 224(d)(1) of the

person receiving such tips;

(2) if a payor required to furnish a written statement under section 6041(d) fails

to provide on that statement the portion

of payments that have been reasonably

designated as cash tips or the occupation

described in section 224(d)(1) of the person receiving such tips;

(3) if a payor required to file an information return under section 6041A(a)

fails to provide on that return a separate

accounting of any such amounts reasonably designated as cash tips or the occupation described in section 224(d)(1) of the

person receiving such tips;

(4) if a payor required to furnish a written statement under section 6041A(e) fails

to provide on that statement the portion

of payments that have been reasonably

designated as cash tips or the occupation

described in section 224(d)(1) of the person receiving such tips;

(5) if a TPSO required to file an information return under section 6050W(a)

fails to provide on that return the portion of

reportable payment transactions that have

been reasonably designated by payors as

cash tips or the occupation described in

section 224(d)(1) of the person receiving

such tips;

(6) if a TPSO required to furnish a written statement under section 6050W(f) fails

to provide on that statement a separate

accounting of any such amounts that have

been reasonably designated by payors as

cash tips or the occupation described in

section 224(d)(1) of the person receiving

such tips;

(7) if an employer required to furnish

a written statement under section 6051(a)

fails to provide on that statement the

total amount of cash tips reported by the

employee under section 6053(a) or the

occupation described in section 224(d)(1)

of such employee; or

(8) if an employer required to file a

copy of the written statement under section 6051(a) with the SSA pursuant to section 6051(d) fails to provide on that statement the total amount of cash tips reported

by the employee under section 6053(a) or

the occupation described in section 224(d)

(1) of such employee.

The penalty relief provided in this

notice is limited to returns and statements

filed and furnished with respect to taxable

742

year 2025. The penalty relief applies only

to the extent that the person required to

make the return or statement otherwise

files and furnishes a complete and correct

return or statement. A complete return or

statement must include the amount of cash

tips that would otherwise be required to

be separately accounted for on the return

or statement in the aggregate amount of

payments required to be reported under

section 6041(a) or (d), section 6041A(a)

or (e), the gross amount of reportable payment transactions required to be reported

under section 6050W(a) or (f), or the

total amount of wages paid required to be

reported under section 6051(a) or (d).

While not a requirement to receive

the penalty relief provided in this notice,

employers and payors are encouraged to

provide employees and payees, particularly those in a tipped occupation, with the

occupation codes and separate accountings of cash tips, such that the employee

or payee has the information the employee

or payee needs to determine whether the

employee or payee can claim the deduction for qualified tips under section 224

for taxable year 2025. Employers are

also encouraged to provide employees

with information regarding whether the

employer’s trade or business is a specified service trade or business as defined in

section 199A(d)(2). Employers and payors can make such information available

to their employees and payees through

an online portal, additional written statements furnished to the employees or payees, or other secure methods.

.02 Qualified Overtime Compensation

Prior to the enactment of the OBBBA,

payors reporting payments pursuant to

section 6041 were not required to file

returns and furnish statements containing

a separate accounting of amounts designated as qualified overtime compensation. Employers reporting the payment of

wages pursuant to section 6051 generally

were also not required to separately report

the total amount of qualified overtime

compensation. The Treasury Department

and the IRS are aware that payors and

employers may not currently have the

information required to be reported by the

OBBBA or the systems or procedures in

place to be able to correctly file the additional information with the Secretary (or

the SSA in the case of a Form W-2) and

Bulletin No. 2025–48

furnish such information to payees and

employees. Therefore, taxable year 2025

will be regarded as a transition period for

purposes of IRS enforcement and administration of the new information reporting

requirements for qualified overtime compensation added to the Code under section

70202(c) of the OBBBA.

The IRS will not impose a penalty

under sections 6721, or 6722 in any of the

following circumstances:

(1) if an employer required to furnish

a written statement under section 6051(a)

fails to separately provide on that statement the total amount of qualified overtime compensation (as defined in section

225(c));

(2) if an employer required to file a

copy of the written statement under section 6051(a) with the SSA pursuant to section 6051(d) fails to separately provide on

that statement the total amount of qualified overtime compensation (as defined in

section 225(c));

(3) if a payor required to file an information return under section 6041(a)

fails to provide on that return a separate

accounting of any amount of qualified

overtime compensation (as defined in section 225(c)); or

(4) if a payor required to furnish a written statement under section 6041(d) fails

to provide on that statement the portion of

payments that are qualified overtime compensation (as defined in section 225(c)).

The penalty relief provided in this

notice is limited to returns and statements

filed and furnished with respect to taxable

year 2025. The penalty relief applies only

to the extent that the person required to

make the return or statement otherwise

files and furnishes a complete and correct

return or statement. A complete return

or statement must include the amount

of qualified overtime compensation that

would otherwise be required to be separately accounted for on the return or statement in the aggregate amount of payments

required to be reported under section

6041(a) or (d), or in the total amount of

wages required to be reported under section 6051(a).

While not a requirement to receive

the penalty relief provided in this notice,

employers and payors are encouraged to

provide employees and payees with separate accountings of overtime compensation such that the employee or payee has

the information the employee or payee

needs to determine whether the employee

or payee can claim the deduction for qualified overtime compensation under section

225 for taxable year 2025. Employers and

payors can make such information available to their employees and payees by

including it in box 14 of the employee’s

Form W-2, or through an online portal,

additional written statements furnished to

the employees or payees, or other secure

methods.

SECTION 5. EFFECTIVE DATE

This notice is effective for returns and

statements related to amounts paid during

2025.

SECTION 6. DRAFTING

INFORMATION

The principal author of this notice

is the Office of Associate Chief Counsel (Procedure and Administration). For

further information regarding this notice

contact the office at (202) 317-3400 (not

a toll-free number).

26 CFR 601.105: Examination of returns and claims

for refund, credit or abatement; determination of

correct tax liability.

(Also: Part I, §§ 671, 677; 301.7701-2, 301.7701-4)

Rev. Proc. 2025-31

SECTION 1. PURPOSE

This revenue procedure describes a

safe harbor for trusts that otherwise qualify as investment trusts under § 301.77014(c) and as grantor trusts to stake their

digital assets without jeopardizing their

tax status as investment trusts and grantor

trusts for Federal income tax purposes.

This revenue procedure also provides a

limited time period for an existing trust

to amend its governing instrument (trust

agreement) to adopt the requirements of

the safe harbor.

SECTION 2. BACKGROUND –

DIGITAL ASSETS AND STAKING

.01 Digital assets are digital representations of value recorded on a cryptographically secured distributed ledger

or similar technology within the meaning

of section 6045(g)(3)(D) of the Internal

Revenue Code (Code) (digital assets).1

Digital assets generally are treated as

property for Federal income tax purposes

and Federal income tax principles apply

to digital asset transactions.2 This revenue

procedure addresses only digital assets for

which transactions are carried out on a

permissionless network that uses a proofof-stake consensus mechanism to validate

those transactions.

.02 The operation of each digital asset

blockchain network is governed by software that programmatically enforces certain network rules and technical requirements, as well as distributions of rewards

(protocol). For a digital asset transaction

to be recognized by the blockchain network, the transaction must be added to

the network’s decentralized digital ledger

(blockchain).

.03 Digital assets rely on cryptography and economic mechanisms designed

to reduce reliance on designated trusted

intermediaries to verify transactions and

provide settlement assurances to users.

Each protocol has a consensus mechanism that enables a distributed set of

unrelated computers (commonly referred

to as “nodes”) to agree on the authoritative record of digital asset address ownership balances, transactions, and other

data relating to a digital asset’s blockchain

at any given time (state). The consensus

mechanism is intended to maintain the

integrity of the blockchain by validating

transactions and ensuring transactions

added to the blockchain are valid. This

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

CFR Part 301).

See Notice 2014-21, 2014-16 I.R.B. 938.

Bulletin No. 2025–48

743

November 24, 2025

can be done, for example, by rejecting

transactions that attempt to move the same

units to two different wallet addresses at

the same time (so-called “double spending”). Preventing such transactions from

being recorded on a blockchain is essential to the security and integrity of a digital

asset’s blockchain. Absent such assurance,

users could lose confidence in the digital

asset network and the corresponding digital assets could lose value.

.04 Proof-of-stake is a type of consensus mechanism. In a proof-of-stake consensus mechanism, a validator node is a

type of node that actively participates in

the consensus mechanism (in addition to

the typical duties of a node, which include

maintaining and verifying blockchain

data). Non-validator nodes typically only

store and relay blockchain data, and do

not propose or create new blocks. Validator node operators commit or “stake” digital assets to become eligible to be selected

by the relevant protocol to validate a new

block of data to, and update the state of,

the network’s blockchain. While staked,

digital assets are “locked up” and cannot

be transferred for a period of time under

the terms of the applicable protocol. Some

protocols employ specific criteria for

selecting validators, such as the number of

digital assets staked by the validator node

operator.

.05 For the validation process to be

effective in ensuring the security and

integrity of a digital asset’s blockchain,

there must be enough node operators that

no one validator or group of validators can

control a majority of the total staked digital assets, which would allow that party

or group to manipulate the blockchain by

influencing the validation of transactions

and potentially altering the blockchain’s

transaction history. Consequently, an

increase in the number of digital assets

staked by different validator nodes can

increase the security of blockchains using

proof-of-stake consensus mechanisms. To

incentivize multiple validator node operators to participate, and in exchange for

providing validation and related activities, newly minted digital assets specified

by the protocol and/or fees paid by parties seeking to add their transactions to

the blockchain (collectively, “rewards”)

are credited or transferred to validators.

Rewards generally are received in the

November 24, 2025

form of a blockchain’s native digital asset.

Conversely, if a validator fails to act in

accordance with a blockchain network’s

consensus mechanism, some staked units

may be forfeited as a penalty (slashing).

.06 Digital asset owners can participate

in staking in various forms. One such form

is custodial staking, in which a third party

(custodian) takes custody of the owner’s

digital assets and facilitates the staking

of such digital assets on behalf of the

owner. Generally, a custodian focuses on

securely holding, storing, and safeguarding digital assets on behalf of digital asset

owners. The custodian, acting on behalf

of the owner, selects and enters into contractual arrangements with one or more

validator node operators who engage in

proof-of-stake activities for digital asset

blockchains (staking provider). In some

cases, the legal entity that is the custodian

also may act as the staking provider. The

arrangement between the custodian and

the staking provider generally provides

that an agreed-on portion of the staking

rewards are allocated to the owner of the

digital assets.

.07 Some legal entities formed as trusts

under applicable State law that hold digital assets intend to be treated for Federal

income tax purposes as investment trusts

under § 301.7701-4(c) and as grantor

trusts. Certain actions of the trust may be

directed by the trust’s sponsor.

.08 The Department of the Treasury

and the Internal Revenue Service have

received requests for guidance on: (1)

whether staking prevents a legal entity

formed as a trust under applicable State

law from qualifying for Federal income

tax purposes as a trust classified as an

investment trust under § 301.7701-4(c)

and as a grantor trust; and (2) if not,

whether an existing trust agreement may

be amended to authorize the staking of

some or all of its digital assets without

impairing qualification of the trust as an

investment trust under § 301.7701-4(c)

and as a grantor trust.

SECTION 3. BACKGROUND TRUSTS

.01 Section 301.7701-2(a) defines a

“business entity” as an entity recognized

for Federal tax purposes (including an

entity with a single owner that may be

744

disregarded as an entity separate from

its owner under § 301.7701-3) that is

not properly classified as a trust under

§ 301.7701-4 or otherwise subject to special treatment under the Code.

.02 Section 301.7701-4(a) provides

generally that an arrangement is treated as

a trust if the purpose of the arrangement is

to vest in trustees the responsibility to protect or conserve property for beneficiaries

who cannot share in the discharge of this

responsibility and, therefore, are not associates in a joint enterprise for the conduct

of business for profit.

.03 Section 301.7701-4(b) provides

that there are other arrangements known

as trusts because the legal title to property

is conveyed to trustees for the benefit of

beneficiaries, but that are not classified

as trusts for Federal tax purposes because

they are not simply arrangements to protect or conserve the property for the beneficiaries. These trusts, which are often

known as business or commercial trusts,

generally are created by the beneficiaries

simply as a device to carry on a profit-making business that normally would

have been carried on through a business

organization classified as a corporation or

partnership.

.04 Section 301.7701-4(c) provides

that an “investment” trust is not classified

as a trust if there is a power under the trust

agreement to vary the investment of the

certificate holders. An investment trust

with a single class of ownership interests,

representing undivided beneficial interests

in the assets of the trust, is classified as a

trust if there is no power under the trust

agreement to vary the investments of the

certificate holders.

.05 A power to vary the investment of

the certificate holders exists where there is

a managerial power under the trust instrument that enables a trust to take advantage

of variations in the market to improve the

investments of the certificate holders. See

Comm’r v. North American Bond Trust,

122 F.2d 545 (2d Cir. 1941), cert. denied,

314 U.S. 701 (1942).

.06 Rev. Rul. 75-192, 1975-1 C.B. 384,

discusses the situation where a provision

in the trust agreement requires the trustee

to invest cash on hand between quarterly

distribution dates. The trustee is required

to invest the money in short-term obligations of (or guaranteed by) the United

Bulletin No. 2025–48

States, or any agency or instrumentality

thereof, and in certificates of deposit of any

bank or trust company having a minimum

stated surplus and capital. The trustee is

permitted to invest only in obligations

maturing before the next distribution date

and is required to hold such obligations

until maturity. Rev. Rul. 75-192 concludes

that, because the restrictions on the types

of permitted investments limit the trustee

to a fixed return like that earned on a bank

account and eliminate any opportunity to

profit from market fluctuations, the power

to invest in the specified kinds of shortterm investments is not a power to vary

the trust’s investment.

.07 Rev. Rul. 78-371, 1978-2 C.B. 344,

concludes that a trust established by the

heirs of a number of contiguous parcels

of real estate is an association taxable as

a corporation for Federal income tax purposes where the trustees have the power to

purchase and sell contiguous or adjacent

real estate, accept or retain contributions

of contiguous or adjacent real estate, raze

or erect any building or structure, make

any improvements to the land originally

contributed, borrow money, and mortgage

or lease the property.

.08 Rev. Rul. 79-77, 1979-1 C.B. 448,

concludes that a trust formed by three parties to hold a single parcel of real estate

is classified as a trust for Federal income

tax purposes when the trustee was authorized to sign a long-term net lease for the

property, with options to renew the lease

with recomputed rent; to hold title to the

land and building and to proceeds and

income of the property; to distribute all

trust income and otherwise to protect or

conserve the property. See Wyman Building Trust v. Commissioner, 45 B.T.A. 155

(1941), acq., 1941-2 C.B. 14 (trust not

treated as association taxable as a corporation where trust held a single property, the

trustee executed and extended net leases

to the same tenant at the same rental, and

collected and distributed the rents).

.09 Rev. Rul. 81-238, 1981-2 C.B. 248,

establishes that an automatic reinvestment

plan in which trust interest holders elect

to use distributions to purchase interests in

new fixed investment trusts does not constitute a power to vary. The plan does not

involve reinvestment in the original trust

and there is no change in, or addition to,

the assets of the original trust.

.10 Rev. Rul. 90-63, 1990-2 C.B. 270,

holds that the power to consent to changes

in the credit support for debt obligations

held in an investment trust is not a “power

to vary the investment” within the meaning of § 301.7701-4(c) if that power is

exercisable only to the extent that the

trustee reasonably believes the change is

advisable to maintain the value of trust

property by preserving the credit rating of

the bonds.

.11 Rev. Rul. 2004-86, 2004-2 C.B.

191, concludes that a Delaware statutory trust is classified as an investment

trust where the trust holds a single property subject to a mortgage and net lease,

the trustee is permitted to renegotiate the

lease or enter into leases with other tenants

in the event of the tenant’s bankruptcy or

insolvency, and otherwise has very limited

powers.

.12 Section 671 provides that, where

the grantor or another person is treated as

the owner of any portion of a trust (commonly referred to as a “grantor trust”),

there shall be included in computing the

taxable income and credits of the grantor

or the other person those items of income,

deductions, and credits against tax of the

trust which are attributable to that portion

of the trust to the extent that the items

would be taken into account under chapter 1 of the Code in computing taxable

income or credits against the tax of an

individual.

.13 Section 677(a) provides that the

grantor is treated as the owner of any portion of a trust whose income without the

approval or consent of any adverse party

is, or, in the discretion of the grantor or

a nonadverse party, or both, may be distributed, or held or accumulated for future

distribution, to the grantor or the grantor’s

spouse.

.14 A person that is treated as the

owner of an undivided fractional interest

in a trust under subpart E of part I, sub-

chapter J of chapter 1 of the Code (sections 671 and following), is considered

to own the trust assets attributable to that

undivided fractional interest of the trust

for Federal income tax purposes. See Rev.

Rul. 88-103, 1988-2 C.B. 304; and Rev.

Rul. 85-13, 1985-1 C.B. 184; see also

§ 1.1001-2(c), Example 5.

SECTION 4. BACKGROUND –

APPLICABLE REGULATORY

RULES

.01 SEC Rules. The offer and sale of

interests in a trust holding digital assets

to investors in a public offering is subject to regulation by the U.S. Securities

and Exchange Commission (SEC). The

regulations and rules of the SEC address,

among other matters, the public disclosure by the trust of its activities, including with respect to staking. Accordingly,

the SEC reviews and must approve such

disclosure before the trust is permitted to

make a public offering of trust interests.

SEC rules also may require an issuer to

provide additional disclosure to investors

when material facts relating to its offering

change, which disclosure the SEC also

reviews and approves.

.02 SEC Statement and Orders Relating to Staking. On May 29, 2025, the SEC

Division of Corporation Finance issued

a Statement on Certain Protocol Staking Activities.3 The Statement addresses

certain activities known as “staking”

on digital asset networks that use proofof-stake as a consensus mechanism. On

July 29, 2025, the SEC approved In-Kind

Creations and Redemptions for Crypto

ETPs.4 On September 17, 2025, the SEC

approved rule changes proposed by three

national securities exchanges to adopt

generic listing standards for exchangetraded products that hold commodities,

which as defined in the SEC order include

certain digital assets.5

.03 Exchange Rules. Interests in trusts

holding digital assets may be listed and

traded on a national securities exchange

that is a self-regulatory organization. The

rules of the national securities exchange,

SEC, Statement on Certain Protocol Staking Activities (May 29, 2025), https://www.sec.gov/newsroom/speeches-statements/statement-certain-protocol-staking-activities-052925.

SEC Release No. 34-103571, 90 FR 36248 (Aug. 1, 2025); SEC, SEC Permits In-Kind Creations and Redemptions for Crypto ETPs (July 29, 2025), https://www.sec.gov/newsroom/pressreleases/2025-101-sec-permits-kind-creations-redemptions-crypto-etps. An ETP is an exchange-traded product.

SEC Release No. 34-103995, 90 FR 45414 (Sept. 22, 2025).

Bulletin No. 2025–48

745

November 24, 2025

approved by the SEC, prescribe conditions

that must be satisfied in order for shares

(including trust interests) to be listed.

Under those rules, certain trust interest

holders are issued interests in the trust in

a specified aggregate minimum number

in return for a deposit of a quantity of the

underlying digital asset and/or cash; and

when aggregated in the same specified

minimum number, the trust interests may

be redeemed at such holder’s request by

the trust, which will deliver to the redeeming holder the quantity of the underlying

digital asset and/or cash.

.04 Liquidity Policies and Procedures. The generic listing standards of

the national securities exchange where a

trust’s interests are listed and traded that

have been approved by the SEC require

that the trust have in place liquidity risk

policies and procedures to ensure that the

trust can redeem trust interests at a trust

interest holder’s request.6 Pursuant to

these generic listing standards, if a trust

has on a daily basis less than 85 percent

of its assets readily available to meet

redemption requests, the trust must have

and disclose written liquidity risk policies and procedures reasonably designed

to address the risk that it could not meet

requests to redeem interests issued by

the trust without significant dilution of

the remaining holders’ interests in the

trust. For this purpose, an asset is deemed

not readily available to meet redemption requests if it is segregated, pledged,

hypothecated, encumbered, or otherwise

restricted or prevented from being liquidated, sold, transferred, or assigned

within one business day. These policies

and procedures must be periodically

reviewed, no less frequently than annually. The exchange’s disclosure requirements regarding liquidity risk are intended

to cover situations such as staking by the

trust of its digital assets, particularly if the

staked amount exceeds 15 percent of the

trust’s assets on any given day and such

staked assets are not readily available for

redemption requests within one business

day. The generic listing standards require

that the trust’s liquidity risk policies and

procedures be prominently displayed on

the trust’s website.

SECTION 5. SCOPE

This revenue procedure applies to an

arrangement formed as a trust under applicable State law that: (i) would be treated

for Federal income tax purposes as a trust

that qualifies as an investment trust under

§ 301.7701-4(c), and as a grantor trust, if

the trust agreement did not authorize staking and the trust’s digital assets were not

staked; and (ii) with respect to a trust in

existence prior to the date on which its

trust agreement first authorizes staking and

related activities in a manner that satisfies

each of the requirements of section 6.02

hereof, qualified as an investment trust

under § 301.7701-4(c), and as a grantor

trust, immediately before that date.

SECTION 6. SAFE HARBOR

.01 Safe Harbor. Provided all the

requirements in section 6.02 of this revenue procedure are satisfied, a trust’s authorization, pursuant to its trust agreement,

to stake its digital assets and the resulting staking of the trust’s digital assets do

not prevent the trust from qualifying for

Federal income tax purposes as a trust

classified as an investment trust under

§ 301.7701-4(c) and as a grantor trust.

References in section 6 of this revenue

procedure to actions taken by the trust also

include actions directed by the sponsor of

the trust pursuant to the trust agreement.

.02 Requirements.

(1) Interests in the trust are traded on

a national securities exchange. The trust’s

activities comply with the SEC’s regulations and rules. The trust’s disclosure

regarding the staking of its digital assets

has been reviewed and approved by the

SEC. The trust’s assets and activities are

described in the May 29, 2025, Statement

on Certain Protocol Staking Activities

of the SEC’s Division of Corporation

Finance. The trust has written liquidity

risk policies and procedures that comply

with the rules of the national securities

exchange on which the trust interests are

listed and traded.

(2) The trust owns only cash and units

of a single type of digital asset (as defined

by section 6045(g)(3)(D)), transactions

for which are carried out on a permissionless network that uses a proof-of-stake

consensus mechanism to validate those

transactions.

(3) The trust’s digital assets are held by

a custodian, acting on behalf of the trust,

at digital asset addresses controlled by the

custodian. Only the custodian has access

to the private keys associated with those

digital asset addresses; accordingly, only

the custodian can effect a sale, transfer, or

exercise the rights of ownership over the

trust’s digital assets, including while those

assets are staked. For Federal income tax

purposes, the trust retains ownership of

the digital assets at all times, including

while they are staked.

(4) The trust’s staking of its digital

assets protects and conserves trust property by mitigating the risk that another

party or group could control a majority

of the total staked digital assets of that

type and engage in transactions that could

reduce the value of the trust’s digital

assets.

(5) The trust’s activities relating to

digital assets are limited to: (i) accepting deposits of the digital asset or cash

in exchange for newly issued interests

in the trust; (ii) holding the digital assets

and cash; (iii) paying trust expenses and

selling digital assets for cash to pay trust

expenses or to make cash redemptions of

trust interests; (iv) purchasing additional

digital assets with cash contributed to the

trust; (v) distributing digital assets or cash

to trust interest holders in redemption of

their interests in the trust; (vi) selling digital assets for cash in connection with the

trust’s liquidation; and (vii) directing the

staking of its digital assets in a manner

consistent with the applicable requirements of the national securities exchange

on which the trust interests are traded and

this safe harbor, including providing for a

liquidity reserve to the extent provided in

section 6.02(9) of this revenue procedure

and entering into a contingent liquidity

arrangement to the extent provided in section 6.02(12) of this revenue procedure.

Pursuant to the trust agreement, the trust

is prohibited from seeking to take advantage of variations in the market to improve

the investments of trust interest holders,

See SEC Release No. 34-103972, 90 FR 45075 (Sept. 18, 2025); SEC Release No. 34-103974, 90 FR 45082 (Sept. 18, 2025); SEC Release No. 34-103973, 90 FR 45089 (Sept. 18, 2025).

November 24, 2025

746

Bulletin No. 2025–48

including variations based on the value of

the digital assets or the amount of staking

rewards.

(6) The trust directs the staking of its

digital assets through one or more custodians who facilitate the staking of the

digital assets on the trust’s behalf with

one or more staking providers. The trust

and the sponsor are unrelated to the staking provider. The trustee, sponsor, or custodian performs all appropriate due diligence with regard to the selection of each

staking provider and negotiates, on behalf

of the trust, the provisions of the contract

with the staking provider. The staking

provider regularly enters into arrangements with unrelated persons involving

similar activities, and such other persons are also unrelated to the trust, the

custodian, and the sponsor. The staking

provider bears its own expenses. The

allocation of staking rewards between

the staking provider and the custodian on

behalf of the trust is an arm’s length allocation that is independent of the expenses

of the staking provider or custodian, and

may be stated as a percentage of the staking rewards derived from staking the

trust’s digital assets. The other terms and

conditions of the custodian’s arrangements with the staking provider reflect

arm’s length terms.

(7) The trust, the custodian in its capacity as such, and the sponsor have no legal

right or arrangement to participate in or

direct or control the activities of the staking provider in any way, and do not do so,

except to direct the staking and unstaking

of the trust’s digital assets as provided in

this section 6.02.

(8) All of the digital assets of the trust

must be made available to the staking provider to be staked at all times, except as

provided in sections 6.02(9), (10), (11),

and (12) of this revenue procedure.

(9) When appropriate in the trustee’s or sponsor’s reasonable judgment

to comply with the trust’s liquidity risk

policies and procedures required by the

national securities exchange on which

the interests in the trust are listed and

traded, a trust may stake less than all

its digital assets to create and maintain

a liquidity reserve. The trust’s liquidity risk policies and procedures must

be based solely on factors relating to

the requirement of the national secu-

Bulletin No. 2025–48

rities exchange that assets be readily

available to meet redemption requests

within the required period. The trust

may increase or decrease the liquidity

reserve in compliance with its liquidity

risk policies and procedures, provided

that, to the extent the liquidity reserve

is reduced, the trust shall resume making the digital assets not subject to the

liquidity reserve available for staking

as soon as and to the extent reasonably

possible. On the occurrence of one or

more of the events described in section

6.02(10) and (11) of this revenue procedure, the trust shall direct the staking

or unstaking of a necessary number of

its digital assets to satisfy its liquidity

reserve as soon as and to the extent reasonably possible.

(10) In addition to holding in a liquidity reserve (as described in section 6.02(9)

of this revenue procedure), if any, digital

assets that are not staked, the trust also

may, on a short-term temporary basis and

in connection with one or more of the

following events, hold additional digital

assets that are not staked, provided that

the trust shall make such digital assets

available for staking (subject to section

6.02(9) of this revenue procedure, if applicable) as soon as and to the extent reasonably possible:

(i) the sale of digital assets for cash to

pay trust expenses;

(ii) the contribution of digital assets in

connection with the creation of interests in

the trust or distributions of digital assets

to trust interest holders in redemption of

their interests in the trust;

(iii) the purchase of digital assets in

connection with the creation of trust interests for cash or the sale of digital assets to

make cash redemptions of trust interests;

(iv) the ownership of additional digital

assets received as, or available for receipt,

as staking rewards.

(11) In addition to holding in a liquidity reserve (as described in section 6.02(9)

of this revenue procedure), if any, digital

assets that are not staked, the trust also

may, in connection with one or more of

the following events, hold additional digital assets that are not staked, provided

that the trust shall make such digital assets

available for staking (subject to section

6.02(9) of this revenue procedure, if appli-

747

cable) as soon as and to the extent reasonably possible:

(i) obtaining or disposing of digital

assets through the contingent liquidity

arrangement described in section 6.02(12)

of this revenue procedure pursuant to

applicable law or regulatory rules;

(ii) the sale of digital assets for cash in

connection with the trust’s liquidation;

(iii) the need to take protective measures against potential systemic vulnerabilities in the network’s protocol, the staking smart contracts, or the validator client

software;

(iv) the cessation of the arrangement

between the trust and a custodian, but only

with respect to the digital assets affected

by the cessation;

(v) the cessation of the arrangement

between a custodian and a staking provider, but only with respect to the staked

digital assets affected by the cessation; or

(vi) a change in applicable law or regulation.

(12) When appropriate in the trustee’s or sponsor’s reasonable judgment

to comply with the trust’s liquidity risk

policies and procedures required by the

national securities exchange on which

the interests in the trust are listed and

traded, the trust may enter into a contingent liquidity arrangement intended to

mitigate an adverse liquidity event that

otherwise would prevent the fund from

distributing digital assets or cash to trust

interest holders in redemption of their

interests in the trust, provided that the

digital assets or cash obtained through

the contingent liquidity arrangement are

expected to be distributed, or included

in a pool of assets expected to be distributed, in the near future. For purposes

of the foregoing sentence, a contingent

liquidity arrangement is (a) a lending

facility or other arrangement permitting the trust to borrow cash or (b) an

arrangement to sell or purchase digital

assets for cash or digital assets on a current or deferred basis.

(13) To protect or conserve the trust’s

property, the trust’s digital assets are

indemnified from slashing due to the

activities of staking providers.

(14) The only new assets received by

the trust as a result of staking its digital

assets are additional units, in the same

form, of the single type of digital asset

November 24, 2025

held by the trust. The trust’s staking

rewards, net of trust expenses, are, in proportion to the trust interest holders’ relative interests in the trust, either distributed

in-kind to trust interest holders or sold for

cash and the proceeds distributed to trust

interest holders, in each case on a periodic

basis that is no less frequently than quarterly. The trust treats all staking rewards

consistently.

.03 Amendment. A trust may amend its

trust agreement to authorize staking at any

time during the nine-month period beginning on November 10, 2025 and such an

amendment will not prevent a trust from

being treated as a trust that qualifies as an

investment trust under § 301.7701-4(c) or

as a grantor trust if the requirements set

forth in section 6.02 of this revenue procedure are satisfied.

November 24, 2025

SECTION 7. NO INFERENCES ON

LAW

.01 No inferences should be drawn

about whether similar consequences

would result if actions taken by or on

behalf of a trust fall outside the limited

scope of this revenue procedure.

.02 No inferences should be drawn as

to any Federal income tax consequences

not expressly addressed in this revenue procedure, including with respect to

whether income attributable to staking

would be treated as income effectively

connected with the conduct of a trade or

business within the United States or as

unrelated business taxable income. No

inferences should be drawn regarding

the Federal income tax treatment of other

transactions involving digital assets not

748

expressly addressed in this revenue procedure, including with respect to forks and

airdrops.

SECTION 8. EFFECTIVE DATE

This revenue procedure is effective for

tax years ending on or after November 10,

2025.

SECTION 9. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Andrew B. Christopherson

of the Office of Associate Chief Counsel

(Passthroughs, Trusts, and Estates). For

further information, contact Andrew B.

Christopherson at (202) 317-3889 (not a

toll-free number).

Bulletin No. 2025–48

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. 2025–48

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.

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.

November 24, 2025

Numerical Finding List1

Bulletin 2025–48

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

2025-26, 2025-40 I.R.B. 444

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

2025-44, 2025-37 I.R.B. 386

2025-45, 2025-37 I.R.B. 388

2025-38, 2025-38 I.R.B. 392

2025-47, 2025-40 I.R.B. 441

2025-51, 2025-41 I.R.B. 448

2025-52, 2025-41 I.R.B. 474

2025-54, 2025-41 I.R.B. 479

2025-46, 2025-43 I.R.B. 533

2025-50, 2025-43 I.R.B. 542

2025-53, 2025-43 I.R.B. 624

2025-55, 2025-43 I.R.B. 625

2025-49, 2025-44 I.R.B. 627

2025-57, 2025-45 I.R.B. 692

2025-61, 2025-45 I.R.B. 693

2025-63, 2025-46 I.R.B. 709

2025-65, 2025-47 I.R.B. 717

2025-62, 2025-48 I.R.B. 740

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

2025-28, 2025-38 I.R.B. 393

2025-30, 2025-42 I.R.B. 489

2025-27, 2025-44 I.R.B. 646

2025-32, 2025-45 I.R.B. 695

2025-31, 2025-48 I.R.B. 743

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

2025-18, 2025-37 I.R.B. 365

2025-19, 2025-41 I.R.B. 445

2025-20, 2025-41 I.R.B. 447

2025-21, 2025-45 I.R.B. 690

2025-22, 2025-48 I.R.B. 719

Treasury Decisions:

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

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

10033, 2025-40 I.R.B. 411

10035, 2025-42 I.R.B. 484

10034, 2025-43 I.R.B. 523

10036, 2025-43 I.R.B. 525

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

REG-129260-16, 2025-39 I.R.B. 410

REG-108673-25, 2025-42 I.R.B. 494

REG-110032-25, 2025-42 I.R.B. 495

REG-112261-24; REG-116085-23, 2025-42

I.R.B. 522

REG-109742-25, 2025-46 I.R.B. 712

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.

November 24, 2025

Bulletin No. 2025–48

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–48

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.

Bulletin No. 2025–48

iii

November 24, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

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