Bulletin No. 2025–49
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HIGHLIGHTS
OF THIS ISSUE
Bulletin No. 2025–49
December 1, 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.
EMPLOYEE PLANS
Notice 2025-67, page 761.
Section 415 of the Internal Revenue Code provides for dollar limitations on benefits and contributions under qualified
retirement plans. Section 415(d) requires that the Secretary of the Treasury annually adjust these limits for cost
of living increases. Other limitations applicable to deferred
compensation plans are also affected by these adjustments
under § 415. Under § 415(d), the adjustments are to be
Finding Lists begin on page ii.
made under adjustment procedures similar to those used
to adjust benefit amounts under § 215(i)(2)(A) of the Social
Security Act.
INCOME TAX
Rev. Rul. 2025-23, page 749.
2025 Base Period T-Bill Rate. The “base period T-bill rate”
for the period ending September 30, 2025 is published as
required by section 995(f) of the Internal Revenue Code.
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.
December 1, 2025
Bulletin No. 2025–49
Part I
Section 995.—Taxation
of DISC Income to
Shareholders
2025 Base Period T-Bill Rate. The “base period
T-bill rate” for the period ending September 30,
2025, is published as required by section 995(f) of
the Internal Revenue Code.
Rev. Rul. 2025-23
Section 995(f)(1) of the Internal Revenue Code provides that a shareholder of
a domestic international sales corporation
(“DISC”) shall pay interest for each taxable year in an amount equal to the product of the “shareholder’s DISC-related
deferred tax liability” for the year (as
defined in section 995(f)(2)) and the “base
period T-bill rate.” Under section 995(f)
(4), the base period T-bill rate is “the
annual rate of interest determined by the
Secretary to be equivalent to the average
of the 1-year constant maturity Treasury
yields, as published by the Board of Governors of the Federal Reserve System, for
the 1-year period ending on September 30
of the calendar year ending with (or of the
most recent calendar year ending before)
the close of the taxable year of the shareholder.”
The base period T-bill rate for the
period ending September 30, 2025, is 4.08
percent.
Pursuant to section 6622 of the Internal Revenue Code, interest must be compounded daily. The table below provides
factors for compounding the 2025 base
period T-bill rate daily for any number
of days in the shareholder’s taxable year
(including for a 52-53 week taxable year).
To compute the amount of the interest
charge for the shareholder’s taxable year,
multiply the amount of the shareholder’s
DISC-related deferred tax liability for that
year by the base period T-bill rate factor
corresponding to the number of days in the
shareholder’s taxable year for which the
interest charge is being computed. Gener-
ally, one would use the factor for 365 days.
One would use a different factor only if
the shareholder’s taxable year for which
the interest charge is being determined is
a short taxable year, if the shareholder uses
a 52-53 week taxable year, or if the shareholder’s taxable year is a leap year.
For the base period T-bill rates for periods ending in prior years, see Rev. Rul.
2024-27, 2024-51 I.R.B. 1240; Rev. Rul.
2023-23, 2023-51 I.R.B. 1472; Rev. Rul.
2022-21, 2022-47 I.R.B. 468; Rev. Rul.
2021-22, 2021-47 I.R.B. 726; Rev. Rul.
2020-25, 2020-48 I.R.B. 1109; and Rev.
Rul. 2019-27, 2019-51 I.R.B. 1378.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Stefan A. Pruessmann of the
Office of Associate Chief Counsel (International). For further information regarding the revenue ruling, contact Mr. Pruessmann at (202) 317-3800 (not a toll-free
number).
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
1
0.000111781
2
0.000223574
3
0.000335380
4
0.000447198
5
0.000559029
Bulletin No. 2025–49
6
7
8
9
10
0.000670872
0.000782728
0.000894597
0.001006477
0.001118371
11
12
13
14
15
0.001230276
0.001342195
0.001454126
0.001566069
0.001678025
749
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
16
17
18
19
20
0.001789993
0.001901974
0.002013968
0.002125974
0.002237992
21
22
23
24
25
0.002350023
0.002462067
0.002574123
0.002686191
0.002798272
26
27
28
29
30
0.002910366
0.003022472
0.003134591
0.003246722
0.003358866
31
32
33
34
35
0.003471022
0.003583191
0.003695372
0.003807566
0.003919772
36
37
38
39
40
0.004031991
0.004144223
0.004256467
0.004368724
0.004480993
41
42
43
44
45
0.004593274
0.004705569
0.004817876
0.004930195
0.005042527
46
47
48
49
50
0.005154871
0.005267228
0.005379598
0.005491980
0.005604375
750
Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
Bulletin No. 2025–49
51
52
53
54
55
0.005716782
0.005829202
0.005941634
0.006054079
0.006166537
56
57
58
59
60
0.006279007
0.006391490
0.006503985
0.006616493
0.006729013
61
62
63
64
65
0.006841546
0.006954092
0.007066650
0.007179221
0.007291804
66
67
68
69
70
0.007404400
0.007517008
0.007629630
0.007742263
0.007854909
71
72
73
74
75
0.007967568
0.008080240
0.008192924
0.008305620
0.008418330
76
77
78
79
80
0.008531051
0.008643786
0.008756533
0.008869293
0.008982065
81
82
83
84
85
0.009094850
0.009207647
0.009320457
0.009433280
0.009546115
751
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
86
87
88
89
90
0.009658963
0.009771824
0.009884697
0.009997582
0.010110481
91
92
93
94
95
0.010223392
0.010336315
0.010449252
0.010562200
0.010675162
96
97
98
99
100
0.010788136
0.010901123
0.011014122
0.011127134
0.011240159
101
102
103
104
105
0.011353196
0.011466246
0.011579308
0.011692384
0.011805471
106
107
108
109
110
0.011918572
0.012031685
0.012144811
0.012257949
0.012371100
111
112
113
114
115
0.012484264
0.012597440
0.012710629
0.012823831
0.012937045
116
117
118
119
120
0.013050272
0.013163511
0.013276764
0.013390029
0.013503306
752
Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
Bulletin No. 2025–49
121
122
123
124
125
0.013616596
0.013729899
0.013843215
0.013956543
0.014069884
126
127
128
129
130
0.014183238
0.014296604
0.014409983
0.014523374
0.014636778
131
132
133
134
135
0.014750195
0.014863625
0.014977067
0.015090522
0.015203990
136
137
138
139
140
0.015317470
0.015430963
0.015544469
0.015657987
0.015771518
141
142
143
144
145
0.015885062
0.015998619
0.016112188
0.016225770
0.016339364
146
147
148
149
150
0.016452972
0.016566591
0.016680224
0.016793869
0.016907528
151
152
153
154
155
0.017021198
0.017134882
0.017248578
0.017362287
0.017476008
753
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
156
157
158
159
160
0.017589743
0.017703490
0.017817249
0.017931022
0.018044807
161
162
163
164
165
0.018158605
0.018272416
0.018386239
0.018500075
0.018613924
166
167
168
169
170
0.018727785
0.018841659
0.018955546
0.019069446
0.019183359
171
172
173
174
175
0.019297284
0.019411222
0.019525172
0.019639136
0.019753112
176
177
178
179
180
0.019867101
0.019981102
0.020095116
0.020209143
0.020323183
181
182
183
184
185
0.020437236
0.020551301
0.020665379
0.020779470
0.020893574
186
187
188
189
190
0.021007690
0.021121819
0.021235961
0.021350115
0.021464283
754
Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
Bulletin No. 2025–49
191
192
193
194
195
0.021578463
0.021692656
0.021806861
0.021921080
0.022035311
196
197
198
199
200
0.022149555
0.022263812
0.022378081
0.022492363
0.022606658
201
202
203
204
205
0.022720966
0.022835287
0.022949620
0.023063966
0.023178325
206
207
208
209
210
0.023292697
0.023407082
0.023521479
0.023635889
0.023750312
211
212
213
214
215
0.023864747
0.023979196
0.024093657
0.024208131
0.024322618
216
217
218
219
220
0.024437118
0.024551630
0.024666155
0.024780693
0.024895244
221
222
223
224
225
0.025009808
0.025124384
0.025238973
0.025353575
0.025468190
755
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
226
227
228
229
230
0.025582818
0.025697458
0.025812112
0.025926778
0.026041457
231
232
233
234
235
0.026156149
0.026270853
0.026385571
0.026500301
0.026615044
236
237
238
239
240
0.026729800
0.026844568
0.026959350
0.027074144
0.027188952
241
242
243
244
245
0.027303772
0.027418604
0.027533450
0.027648309
0.027763180
246
247
248
249
250
0.027878064
0.027992961
0.028107871
0.028222794
0.028337730
251
252
253
254
255
0.028452678
0.028567639
0.028682613
0.028797600
0.028912600
256
257
258
259
260
0.029027613
0.029142638
0.029257677
0.029372728
0.029487792
756
Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
Bulletin No. 2025–49
261
262
263
264
265
0.029602869
0.029717959
0.029833062
0.029948177
0.030063306
266
267
268
269
270
0.030178447
0.030293601
0.030408768
0.030523948
0.030639141
271
272
273
274
275
0.030754347
0.030869565
0.030984797
0.031100041
0.031215298
276
277
278
279
280
0.031330569
0.031445852
0.031561147
0.031676456
0.031791778
281
282
283
284
285
0.031907112
0.032022460
0.032137820
0.032253193
0.032368579
286
287
288
289
290
0.032483978
0.032599390
0.032714815
0.032830253
0.032945703
291
292
293
294
295
0.033061167
0.033176643
0.033292133
0.033407635
0.033523150
757
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
296
297
298
299
300
0.033638678
0.033754219
0.033869773
0.033985340
0.034100920
301
302
303
304
305
0.034216512
0.034332118
0.034447736
0.034563368
0.034679012
306
307
308
309
310
0.034794669
0.034910340
0.035026023
0.035141719
0.035257428
311
312
313
314
315
0.035373150
0.035488885
0.035604632
0.035720393
0.035836167
316
317
318
319
320
0.035951953
0.036067753
0.036183565
0.036299391
0.036415229
321
322
323
324
325
0.036531081
0.036646945
0.036762822
0.036878712
0.036994615
326
327
328
329
330
0.037110532
0.037226461
0.037342403
0.037458358
0.037574326
758
Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
Bulletin No. 2025–49
331
332
333
334
335
0.037690307
0.037806300
0.037922307
0.038038327
0.038154360
336
337
338
339
340
0.038270406
0.038386464
0.038502536
0.038618621
0.038734718
341
342
343
344
345
0.038850829
0.038966953
0.039083089
0.039199239
0.039315401
346
347
348
349
350
0.039431577
0.039547765
0.039663967
0.039780181
0.039896409
351
352
353
354
355
0.040012649
0.040128903
0.040245169
0.040361449
0.040477741
356
357
358
359
360
0.040594047
0.040710365
0.040826696
0.040943041
0.041059398
361
362
363
364
365
0.041175769
0.041292152
0.041408549
0.041524958
0.041641381
759
December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
FACTOR
December 1, 2025
366
367
368
369
370
0.041757816
0.041874265
0.041990726
0.042107201
0.042223689
371
0.042340189
760
Bulletin No. 2025–49
Part III
2026 Amounts Relating to
Retirement Plans and IRAs,
as Adjusted for Changes in
Cost-of-Living
Notice 2025-67
Section 415 of the Internal Revenue
Code (“Code”) provides for limitations on
benefits and contributions under qualified
retirement plans. Section 415(d) requires
that the Secretary of the Treasury annually adjust these limitations for cost-ofliving increases. Under section 415(d),
the adjustments are to be made under
adjustment procedures similar to those
used to adjust benefit amounts under section 215(i)(2)(A) of the Social Security
Act. Other amounts applicable to deferred
compensation plans are also adjusted for
cost-of-living increases using a variation
of the methodology used for the adjustments under section 415(d).
Cost-of-Living Adjusted Limitations
for 2026
Effective January 1, 2026, the limitation on the annual benefit under a defined
benefit plan under section 415(b)(1)(A)
of the Code is increased from $280,000
to $290,000.
For a participant who separated from
service before January 1, 2026, the participant’s limitation under a defined benefit plan under section 415(b)(1)(B) is
computed by multiplying the participant’s
compensation limitation, as adjusted
through 2025, by 1.0288.
The limitation for defined contribution plans under section 415(c)(1)(A)
is increased in 2026 from $70,000 to
$72,000.
The Code provides that various other
amounts are to be adjusted at the same
time and in the same manner as the limitation of section 415(b)(1)(A). After taking into account the applicable rounding
rules, the amounts for 2026 are as follows:
The limitation under section 402(g)(1)
on the exclusion for elective deferrals
Bulletin No. 2025–49
described in section 402(g)(3), which
includes elective deferrals made to the
Thrift Savings Plan, is increased from
$23,500 to $24,500.
The limitation on deferrals under section 457(e)(15) concerning deferred
compensation plans of state and local
governments and tax-exempt organizations is increased from $23,500 to
$24,500.
The limitation under section 414(v)
(2)(B)(i) for catch-up contributions
to an applicable employer plan other
than a plan described in section 401(k)
(11) or section 408(p) that generally
applies for individuals aged 50 or over
is increased from $7,500 to $8,000.
The limitation under section 414(v)(2)
(E)(i) for catch-up contributions to an
applicable employer plan other than a
plan described in section 401(k)(11)
or section 408(p) that applies for individuals who attain age 60, 61, 62, or
63 in 2026 remains $11,250. The Roth
catch-up wage threshold for 2025,
which under section 414(v)(7)(A) is
used to determine whether an individu
al’s catch-up contributions to an appli
cable employer plan (other than a plan
described in section 408(k) or (p)) for
2026 must be designated as Roth con
tributions, is increased from $145,000
to $150,000.
The limitation under section 408(p)
(2)(E)(i)(III) that generally applies to
salary reduction contributions under a
SIMPLE retirement account or elective contributions under a SIMPLE
401(k) plan is increased from $16,500
to $17,000. The limitation for certain of those accounts or plans under
section 408(p)(2)(E)(i)(I) or (II) is
increased from $17,600 to $18,100.
The limitation under section 414(v)(2)
(B)(ii) for catch-up contributions to an
applicable employer plan described in
section 401(k)(11) or section 408(p)
that generally applies for individuals aged 50 or over is increased from
$3,500 to $4,000. The limitation under
761
section 414(v)(2)(E)(ii) for catch-up
contributions to an applicable employer
plan described in section 401(k)(11) or
section 408(p) that applies for individuals who attain age 60, 61, 62, or
63 in 2026 remains $5,250. The limitation under section 414(v)(2)(B)(iii)
for catch-up contributions to certain
accounts or plans described in section 401(k)(11) or section 408(p) that
generally applies for individuals aged
50 or over remains $3,850.
The limitation under section 401(k)
(16)(D)(i)(II) and 403(b)(16)(D)(i)
(II) that generally applies for elective
contributions made to a starter 401(k)
deferral-only arrangement described in
section 401(k)(16)(B) or a safe harbor
deferral-only plan described in section
403(b)(16)(B), respectively, remains
$6,000. This limitation is increased for
individuals who attain age 50 before
the end of the taxable year by $1,100.
The threshold used in the definition
of “highly compensated employee”
under section 414(q)(1)(B) remains
$160,000.
The threshold under section 416(i)
(1)(A)(i) concerning the definition of
“key employee” for top-heavy plan
purposes is increased from $230,000 to
$235,000.
The annual compensation limitation
under
sections
401(a)
(17), 404(l), 408(k)(3)(C), and 408(k)
(6)(D)(ii) is increased from $350,000
to $360,000. The annual compensation
limitation under section 401(a)(17) for
eligible participants in certain governmental plans that, under the plan as in
effect on July 1, 1993, allowed cost-ofliving adjustments to the compensation
limitation under the plan under section
401(a)(17) to be taken into account, is
increased from $520,000 to $535,000.
The limitation under section 402A(e)
(3)(A)(i) concerning pension-linked
emergency savings accounts that may
be included in certain types of defined
December 1, 2025
contribution plans is increased from
$2,500 to $2,600.
The compensation threshold under section 408(k)(2)(C) regarding simplified
employee pensions is increased from
$750 to $800.
The amount under section 409(o)(1)
(C)(ii) for determining the maximum
account balance in an employee stock
ownership plan subject to a 5‑year
distribution period is increased from
$1,415,000 to $1,455,000, while the
dollar amount used to determine the
lengthening of the 5-year distribution
period is increased from $280,000 to
$290,000.
The limitation on the aggregate amount
of length of service awards accruing
with respect to any year of service
for any bona fide volunteer under
section 457(e)(11)(B)(ii) concerning
deferred compensation plans of state
and local governments and tax-exempt
organizations is increased from $7,500
to $8,000.
The limitation under section 664(g)
(7) concerning the qualified gratuitous
transfer of qualified employer securities to an employee stock ownership
plan is increased from $60,000 to
$65,000.
The compensation amount under §
1.61-21(f)(5)(i) of the Income Tax
Regulations concerning the definition
of “control employee” for fringe benefit valuation purposes is increased
from $140,000 to $145,000. The compensation amount under § 1.61-21(f)
(5)(iii) is increased from $285,000 to
$290,000.
The limitation on premiums paid for a
qualifying longevity annuity contract
under § 1.401(a)(9)-6(q)(2)(ii) remains
$210,000.
The $1,000,000,000 threshold used
to determine whether a multiemployer
plan is a systemically important plan
under section 432(e)(9)(H)(v)(III)(aa) is
adjusted using the cost-of-living adjustment provided under section 432(e)(9)(H)
December 1, 2025
(v)(III)(bb). After taking the applicable
rounding rule into account, the threshold
used to determine whether a multiemployer plan is a systemically important
plan under section 432(e)(9)(H)(v)(III)
(aa) is increased from $1,441,000,000 to
$1,505,000,000.
The Code also provides that several
retirement-related amounts are to be
adjusted using a variation of the methodology used for the cost-of-living adjustments under section 1(f)(3). After taking
the applicable rounding rules into account,
the amounts for 2026 are as follows:
The adjusted gross income limitation
under section 25B(b)(1)(A) for determining the retirement savings contributions credit for married taxpayers
filing a joint return is increased from
$47,500 to $48,500; the limitation
under section 25B(b)(1)(B) is increased
from $51,000 to $52,500; and the limitation under sections 25B(b)(1)(C)
and 25B(b)(1)(D) is increased from
$79,000 to $80,500.
The adjusted gross income limitation
under section 25B(b)(1)(A) for determining the retirement savings contributions credit for taxpayers filing as
head of household is increased from
$35,625 to $36,375; the limitation
under section 25B(b)(1)(B) is increased
from $38,250 to $39,375; and the limitation under sections 25B(b)(1)(C)
and 25B(b)(1)(D) is increased from
$59,250 to $60,375.
The adjusted gross income limitation
under section 25B(b)(1)(A) for determining the retirement savings contributions credit for all other taxpayers
is increased from $23,750 to $24,250;
the limitation under section 25B(b)
(1)(B) is increased from $25,500 to
$26,250; and the limitation under sections 25B(b)(1)(C) and 25B(b)(1)(D) is
increased from $39,500 to $40,250.
The deductible amount under section
219(b)(5)(A), which limits the amount
of an individual’s deductible qualified
retirement contributions for a taxable year is increased from $7,000 to
$7,500. The deductible amount pursuant to section 219(b)(5)(B)(ii) for
762
individuals who have attained age 50
before the close of the taxable year is
increased from $1,000 to $1,100.
The applicable amount under section
219(g)(3)(B)(i) for determining the
deductible amount of an IRA contribution for taxpayers who are active
participants filing a joint return or as
a qualifying widow(er) is increased
from $126,000 to $129,000. The applicable amount under section 219(g)(3)
(B)(ii) for all other taxpayers who are
active participants (other than married
taxpayers filing separate returns) is
increased from $79,000 to $81,000.
If an individual or the individual’s
spouse is an active participant, the
applicable amount under section
219(g)(3)(B)(iii) for a married individual filing a separate return is not
subject to an annual cost-of-living
adjustment and remains $0. The applicable amount under section 219(g)
(7)(A) for a taxpayer who is not an
active participant but whose spouse is
an active participant is increased from
$236,000 to $242,000.
In light of the changes to the applicable amounts, under section 219(g)(2)
(A), the deduction for taxpayers making contributions to a traditional IRA
is phased out for single individuals and
heads of household who are active participants in a qualified plan (or another
retirement plan specified in section
219(g)(5)) and have adjusted gross
incomes (as defined in section 219(g)
(3)(A)) between $81,000 and $91,000,
increased from between $79,000 and
$89,000. For married couples filing
jointly, if the spouse who makes the
IRA contribution is an active participant, the income phase‑out range
is between $129,000 and $149,000,
increased from between $126,000 and
$146,000. For an IRA contributor who
is not an active participant and is married to someone who is an active participant, the deduction is phased out if the
couple’s income is between $242,000
and $252,000, increased from between
$236,000 and $246,000. For a married individual filing a separate return
who is an active participant, the phaseout range is not subject to an annual
Bulletin No. 2025–49
cost‑of‑living adjustment and remains
$0 to $10,000.
The adjusted gross income limitation
under section 408A(c)(3)(B)(ii)(I) for
determining the maximum Roth IRA contribution for married taxpayers filing a joint
return or for taxpayers filing as a qualifying widow(er) is increased from $236,000
to $242,000. The adjusted gross income
limitation under section 408A(c)(3)(B)
(ii)(II) for all other taxpayers (other than
married taxpayers filing separate returns)
is increased from $150,000 to $153,000.
The applicable amount under section
408A(c)(3)(B)(ii)(III) for a married individual filing a separate return is not subject to an annual cost-of-living adjustment
and remains $0.
In light of the changes to the adjusted
gross income limitations, under section 408A(c)(3)(A), the adjusted gross
income phase-out range for taxpayers
making contributions to a Roth IRA
is between $242,000 and $252,000
for married couples filing jointly,
increased from between $236,000 and
$246,000. For singles and heads of
household, the income phase-out range
is between $153,000 and $168,000,
increased from between $150,000
and $165,000. For a married individual filing a separate return, the phaseout range is not subject to an annual
cost-of-living adjustment and remains
between $0 and $10,000.
The aggregate amount of qualified
charitable distributions that are not
includible in gross income under section 408(d)(8)(A) is increased from
$108,000 to $111,000. The amount
of qualified charitable distributions
made directly to a split-interest entity
that are not includible in gross income
under section 408(d)(8)(F)(i)(II) pursuant to a one-time election is increased
from $54,000 to $55,000.
The annual compensation limitation
under section 45E(f)(2)(C) for employees excluded from the calculation of
the additional small employer pension plan startup cost credit for certain
employer contributions is increased
from $105,000 to $110,000.1
The limitation under section 72(t)(2)
(K)(ii)(I) for eligible distributions
to victims of domestic abuse from
applicable eligible retirement plans is
increased from $10,300 to $10,500.
The limitation under section 401(a)
(39)(B)(i)(III) on a qualified longterm care distribution from a qualified
defined contribution plan with respect
to certified long-term care insurance
remains $2,600.
The limitation under section 408(p)
(2)(A)(iv) for additional nonelective
contributions for an employee to a
SIMPLE retirement account or a SIMPLE 401(k) plan is increased from
$5,100 to $5,300.
Drafting Information
The principal author of this notice
is Tom Morgan of the Office of Associate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment Taxes). However, other personnel
from the IRS participated in the development of this guidance. For further
information regarding this notice, contact Mr. Morgan at (202) 317‑6700 (not
a toll-free call).
Pursuant to section 45E(f)(2)(C)(iii), for a taxable year beginning in a calendar year after 2023, this limitation is equal to the initial limitation of $100,000, multiplied by the cost-of-living
adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting “calendar year 2007” for “calendar year 2016” in section 1(f)
(3)(A)(ii). Because the specification of a 2007 base period to be used for computing an adjustment that is first made for 2024 appears to be an error that has been identified as the subject of
future legislative correction, the IRS will calculate and apply the limitation in section 45E(f)(2)(C) by substituting “calendar year 2022” for “calendar year 2007” in section 45E(f)(2)(C)(iii).
1
Bulletin No. 2025–49
763
December 1, 2025
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior published position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confusion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously published ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the substance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rulings in the series.
Suspended is used in rare situations
to show that the previous published rulings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
Bulletin No. 2025–49
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
i
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
December 1, 2025
Numerical Finding List1
Bulletin 2025–49
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
2025-67, 2025-49 I.R.B. 761
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
2025-23, 2025-48 I.R.B. 749
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.
1
December 1, 2025
ii
Bulletin No. 2025–49
Finding List of Current Actions on
Previously Published Items1
Bulletin 2025–49
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin
2025–52, dated December 22, 2025.
1
Bulletin No. 2025–49
iii
December 1, 2025
Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
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