# Bulletin No. 2025–49 > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A34cec3153a2767d5 ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text 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 The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A34cec3153a2767d5. Public record. Not legal advice.