Bulletin No. 2025–46

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–46

November 10, 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.

INCOME TAX

Notice 2025-63, page 709.

This explains that proposed regulations will be issued to

provide a rule for determining the source of certain borrow

fees paid with respect to securities lending transactions and

sale-repurchase transactions. These fees would be sourced

based on the residence of the recipient.

Finding Lists begin on page ii.

REG-109742-25, page 712.

These proposed regulations would modify the determination of whether a qualified investment entity (QIE) is

domestically controlled by removing a rule in previously

promulgated final regulations that looks to the shareholders of certain domestic corporations in determining

whether foreign persons hold directly or indirectly stock

in a QIE.

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

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and for publishing Treasury Decisions, Executive Orders, Tax

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of the tax laws, including all rulings that supersede, revoke,

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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

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identifying details and information of a confidential nature are

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Rulings and procedures reported in the Bulletin do not have the

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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

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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.

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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 10, 2025 

Bulletin No. 2025–46

Part III

Source of Certain Borrow

Fees

Notice 2025-63

SECTION 1. PURPOSE

Neither the Internal Revenue Code (the

“Code”) nor Treasury regulations directly

specify how to determine the source of

payments referred to as borrow fees or

negative rebate (collectively, “borrow

fees”) with respect to securities lending

transactions or sale-repurchase transactions. As a result, the appropriate source

rule for those payments is uncertain. See,

e.g., TD 9579, 77 FR 9846, 9846 (Feb.

21, 2012) (“The Treasury Department

and the IRS are considering whether separate guidance is needed on the source

of income attributable to certain payments . . . that arise in securities lending

transactions or repurchase transactions”).

This notice announces that the Treasury

Department (“Treasury”) and the Internal

Revenue Service (“IRS”) intend to issue

proposed regulations (the “forthcoming

proposed regulations”) providing that certain borrow fees (as circumscribed in section 3) are sourced based on the residence

of the recipient.

SECTION 2. BACKGROUND

.01 Sourcing Items of Income

The general rules for determining

whether items of income are from sources

within or without the United States are

found in sections 861 through 865 of the

Code. The Code provides specific sourcing rules for, among other items, interest,

dividends, compensation for personal

services, rents and royalties, and income

from sales of personal property. Section

863(a) grants authority to the Secretary

to prescribe regulations allocating or

apportioning items of gross income not

otherwise specified in sections 861(a) and

862(a) to sources within or without the

United States.

.02 Securities Lending and Sale-Repurchase Transactions1

(1) Transactional Documentation

Securities lending transactions and

sale-repurchase transactions are typically

entered into under a standardized form of

agreement2 that includes industry-standard

legal and commercial terms and definitions, and attached annexes or schedules,

which provide other standardized terms

applicable to specific types of transactions

and may include procedures for making

elections permitted by the standardized

agreement (together, a “master agreement”). A related short-form confirmation

memorializes the specific business terms

of a particular securities lending transaction or sale-repurchase transaction.

(2) Securities Lending Transactions

In a securities lending transaction, one

party (the “securities lender”) lends securities (the “loaned securities”) to another

party (the “securities borrower”), subject

to an obligation by the securities borrower

to return equivalent securities to the securities lender, and the securities borrower

typically transfers collateral in the form of

cash, securities, or other financial instruments to the securities lender as security

for the securities borrower’s obligation

under the agreement.

Under the standard master agreement

used in the U.S. financial markets, the

fee arrangement in a securities lending

transaction depends on the type of collateral posted. When the securities borrower

posts non-cash collateral with the securities lender, the securities borrower pays

the securities lender an explicit fee, often

referred to as a borrow fee.

By contrast, when cash collateral is

posted, the master agreement provides for

the securities lender to pay the securities

borrower an amount frequently described

as a fee or “rebate” with respect to the cash

collateral, which is computed daily based

on the amount of cash held by the securities lender as collateral at a rate agreed

to by the parties. The securities lender

retains the excess of the return it generates on the cash collateral over the amount

paid to the securities borrower. This differential retained by the securities lender

provides it with the economic equivalent

of a borrow fee. In most such cases, no

explicit fee is paid by the securities borrower to the securities lender.

However, in certain circumstances

where the securities borrower has posted

cash collateral, the securities borrower

may pay an explicit fee (sometimes

referred to as a “negative rebate”) to the

securities lender. This may happen, for

example, when the prevailing interest

rates are low or the demand for the loaned

securities is high. More specifically, if the

borrow fee, on a standalone basis, exceeds

the return the securities lender could earn

on the cash collateral, the securities borrower would pay the securities lender a

negative rebate equal to the excess of the

borrow fee over the return on the cash collateral.

The terms of master agreements used

in international financial markets or with

respect to non-U.S. securities differ in

some respects. Some master agreements

require the securities borrower to pay an

explicit fee to the securities lender without regard to the type of collateral posted

by the borrower. In such cases, the securities borrower is always required to pay

a borrow fee, although the payment may

be set off against the return on the cash

collateral.

(3) Sale-Repurchase Transactions

In a sale-repurchase transaction (sometimes referred to as a “repo”), one party

(the “cash lender”) purchases securities

from another (the “cash borrower”) sub-

1

The description of securities lending transactions and sale-repurchase transactions in this Section 2.02 is intended as a description of market practice and does not represent a conclusion by

Treasury or the IRS as to the tax characterization of the transactions.

2

For examples of standardized master agreements for securities lending transactions, see, e.g., Securities Industry and Financial Markets Association (SIFMA), Master Securities Loan

Agreement (2017) (referring to a borrow fee as a “Loan Fee”); International Securities Lending Association, Global Master Securities Lending Agreement (2010). For examples of standardized agreements for sale-repurchase agreements, see, e.g., SIFMA, Master Repurchase Agreement (1996); SIFMA and International Capital Market Association, Global Master Repurchase

Agreement (2011); The Bond Market Association and International Securities Market Association, Global Master Repurchase Agreement (2000).

Bulletin No. 2025–46

709

November 10, 2025

ject to an agreement for the cash borrower

to repurchase equivalent securities in the

future at a prearranged price. A sale-repurchase transaction may function economically as a secured loan of money, a securities lending transaction, or both.

If the transaction is initiated because

the initiating party wants to borrow

money or earn a rate of return on excess

funds, then the transaction economically

resembles a loan of money. The securities sold function as collateral for the

loan, with the amount of that collateral

determined based on the loan “principal.” Where a sale-repurchase transaction is intended primarily as a secured

loan of money, the parties will often

agree to a general collateral sale-repurchase agreement. Under a general collateral sale-repurchase agreement, the

parties agree in advance on the types of

securities and related haircuts that the

cash lender is willing to accept, which

generally includes U.S. Treasuries, and

the cash borrower can choose which of

those securities to provide. The cash borrower will pay a “general collateral” rate

of return on the loan “principal.”

A sale-repurchase agreement may

also function as a securities lending

transaction. If the cash lender requires

the cash borrower to sell and repurchase

a specific security, then the sale-repurchase agreement is described as a “special sale-repurchase agreement.” Generally, the effective interest rate on a

special sale-repurchase agreement is less

than the interest rate on a general collateral sale-repurchase agreement (of equal

tenure). The difference between those

rates economically functions as a borrow

fee to the cash borrower. The greater the

demand for a security, the greater the

implicit borrow fee. In a manner similar to a securities lending transaction, a

special sale-repurchase agreement may

result in the cash lender paying a neg-

November 10, 2025

ative rebate when the interest rate for a

general collateral sale-repurchase agreement is low or the demand for the specific security is high.

SECTION 3. PROPOSED

REGULATIONS TO BE ISSUED

Pursuant to the Secretary’s rulemaking authority under section 863(a),

the forthcoming proposed regulations

would provide that the source of borrow fees (as defined in this section)

paid with respect to a securities lending

transaction or a sale-repurchase transaction (also as defined in this section) is

determined based on the residence of the

recipient, subject to the following definitions and rules applicable solely for

this purpose.

A securities lending transaction and

a sale-repurchase transaction have the

meanings provided under §§1.861-2(a)(7)

(transactions with respect to debt securities) and 1.861-3(a)(6) (transactions with

respect to equity securities).

A borrow fee (including negative

rebate) is a fee that is (1) paid pursuant to

a securities lending transaction or sale-repurchase transaction that is (i) documented

on an industry-standard master agreement

and confirmation (or electronic equivalent

thereof) with standard market terms and

(ii) entered into in the ordinary course of

the taxpayer’s and counterparty’s trades

or businesses or pursuant to their normal

investment activities or objectives, and

(2) paid in substance to compensate the

lender of the securities (including a cash

borrower in a sale-repurchase transaction)

for making its securities available to the

borrower of the securities (including a

cash lender in a sale-repurchase transaction).

The residence of the recipient is determined in the same manner as under section 988(a)(3)(B).

710

SECTION 4. APPLICABILITY DATE

AND RELIANCE

The forthcoming proposed regulations would provide that the regulations

will apply prospectively to taxable years

ending after the forthcoming proposed

regulations are published in the Federal

Register. The forthcoming proposed regulations would also provide that taxpayers

may choose to apply the regulations, once

finalized, before the applicability date. In

addition, taxpayers may rely on the rules

described in section 3 of this notice with

respect to securities lending transactions

and sale-repurchase transactions entered

into before the forthcoming proposed regulations are published in the Federal Register.

This notice does not address the source

of any other payments with respect to

securities lending transactions, sale-repurchase transactions, or substantially

similar transactions, including a payment

described as a borrow fee that is not within

the scope of this notice, such as an amount

paid with respect to a one-off or structured

transaction or a transaction that does not

have standard market business terms. The

label given to a payment does not govern

the determination of source; whether a fee

labeled as a borrow fee is treated as such

for Federal income tax purposes is determined based on the substance of the fee.

SECTION 5. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice

is D. Peter Merkel of the Office of Associate Chief Counsel (International). However, other personnel from the Treasury

Department and the IRS participated in

its development. For further information

regarding this notice, contact D. Peter

Merkel on (202) 317-6938 (not a toll-free

number).

Bulletin No. 2025–46

Cross-References in Notice 2025-63

Internal Revenue Code (IRC) Section

861, Income from sources within the

United States: Section 861 provides rules

for determining when certain items of

gross income are from sources within the

United States.

IRC Section 862, Income from sources

without the United States: Section 862

provides rules for determining when

certain items of gross income are from

sources without the United States.

IRC section 863, Special Rules Determining Source: Section 863(a) provides

that the Secretary shall prescribe regulations related to the source of items of gross

income, expenses, losses, and deduction

for which sections 861(a) and 862(a) do

not provide specific sourcing rules.

IRC section 864, Definitions and

Special Rules. Section 864 provides

Bulletin No. 2025–46

definitions for terms such as “trade or

business within the United States” and

“effectively connected income.” Section

864 also provides rules for the treatment

of related person factoring income,

allocating certain interest, and allocating certain research and experimental

expenditures.

IRC section 865, Source Rules for Personal Property Sales: Section 865 provides source rules relating to the sale of

personal property, including inventory,

intangible property, and sales through an

office or fixed place of business.

IRC section 988, Treatment of Certain

Foreign Currency Transactions: Section 988(a)(3)(B) provides rules for determining the residence of a taxpayer for

purposes of determining the source of foreign currency gain or loss attributable to a

section 988 transaction. Section 988 gain

or loss is sourced based on the residence

of the taxpayer.

711

Treas. Reg. § 1.861-2(a)(7), Interest:

Treas. Reg. §1.861-2(a)(7) provides a

rule for determining the source of substitute interest payments made pursuant to a

securities lending transaction or a sale-repurchase transaction.

Treas. Reg. § 1.861-3(a)(6), Dividends

and income inclusions under sections

951, 951A, and 1293 and associated section 78 dividends: Treas. Reg. §1.8613(a)(6) provides a rule for determining the

source of substitute dividend payments

made pursuant to a securities lending

transaction or a sale-repurchase transaction.

TD 9579, 77 FR 9846 (Feb. 21, 2012),

Source of Income from Qualified Fails

Charges: This Treasury Decision provides a final regulation relating to the

source of income from a qualified fails

charge. A qualified fails charge is sourced

based on the residence of a taxpayer who

receives the income.

November 10, 2025

Part IV

Notice of Proposed

Rulemaking

109742-25), Room 5503, Internal Revenue Service, P.O. Box 7604, Ben Franklin

Station, Washington, DC 20044.

Domestically Controlled

Qualified Investment

Entities

FOR FURTHER INFORMATION

CONTACT: Concerning the proposed

regulations, Andrew F. Gordon (or any

other staff member in the Office of the

Associate Chief Counsel (International))

at (202) 317-3800 (not a toll-free number); concerning submissions of comments, requests for a public hearing, and

access to a public hearing, Publications

and Regulations Section at (202) 3176901 (not toll-free numbers) or by e-mail

to publichearings@irs.gov (preferred).

REG-109742-25

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Notice of proposed rulemaking.

SUMMARY: This document contains

proposed regulations that would modify

existing regulations on the determination

of whether a qualified investment entity

is domestically controlled by removing a

rule that looks to the shareholders of certain domestic corporations in determining

whether foreign persons hold directly or

indirectly stock in a qualified investment

entity. The proposed regulations would

primarily affect foreign persons that own

stock in a qualified investment entity that

would be a United States real property

interest if the qualified investment entity

were not domestically controlled.

DATES: Written or electronic comments

and requests for a public hearing must be

received by December 22, 2025.

ADDRESSES: Commenters are strongly

encouraged to submit public comments

electronically via the Federal eRulemaking Portal at https://www.regulations.gov

(indicate IRS and REG-109742-25) by

following the online instructions for submitting comments. Requests for a public

hearing must be submitted as prescribed

in the “Comments and Requests for a

Public Hearing” section. Once submitted

to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The

Department of the Treasury (Treasury

Department) and the IRS will publish for

public availability any comments submitted to the IRS’s public docket. Send paper

submissions to: CC:PA:01:PR (REG-

November 10, 2025

SUPPLEMENTARY INFORMATION:

Background

Section 897(a)(1) of the Internal Revenue Code (Code) provides that gain or

loss of a nonresident alien individual or

foreign corporation from the disposition

of a United States real property interest (USRPI) is taken into account under

section 871(b)(1) or section 882(a)(1),

as applicable, as if the nonresident alien

individual or foreign corporation were

engaged in a trade or business within the

United States during the taxable year and

such gain or loss were effectively connected with that trade or business.

Subject to certain exceptions, section

897(c)(1)(A) defines a USRPI as an interest in real property (including an interest

in a mine, well, or other natural deposit)

located in the United States or the Virgin

Islands, and any interest (other than solely

as a creditor) in any domestic corporation

unless the taxpayer establishes that such

corporation was at no time a United States

real property holding corporation (USRPHC) during the period set forth in section

897(c)(1)(A)(ii) (generally, the five-year

period ending on the date of the disposition of the interest). Under section 897(c)

(2), a USRPHC is generally any corporation if the fair market value of its USRPIs

equals or exceeds 50 percent of the total

fair market value of its USRPIs, its interests in real property located outside the

United States, plus any other of its assets

712

that are used or held for use in a trade or

business.

Section 897(h)(1) provides that any

distribution by a qualified investment

entity (QIE) to a nonresident alien individual, a foreign corporation, or other QIE, to

the extent attributable to gain from sales

or exchanges by the QIE of USRPIs, is

treated as gain recognized by such nonresident alien individual, foreign corporation,

or other QIE from the sale or exchange of

a USRPI, subject to certain exceptions.

Section 897(h)(4)(A) defines a QIE as

any (i) real estate investment trust (REIT),

and (ii) any regulated investment company (RIC) which is a USRPHC or which

would be a USRPHC if the exceptions in

section 897(c)(3) and (h)(2) did not apply

to interests in any REIT or RIC.

Section 897(h)(2) provides that a

USRPI does not include an interest in a

domestically controlled QIE (DC-QIE

exception). Accordingly, gain or loss on

the disposition of stock in a domestically

controlled QIE is not subject to section

897(a). Section 897(h)(4)(B) provides that

a QIE is domestically controlled if less

than 50 percent of the value of its stock is

held directly or indirectly by foreign persons at all times during the testing period

prescribed in section 897(h)(4)(D) (generally, the five-year period ending on the

date of the disposition).

On December 29, 2022, the Treasury

Department and the IRS published proposed regulations (REG-100442-22) in

the Federal Register (87 FR 80097) that

set forth rules for determining whether

stock of a QIE is considered “held directly

or indirectly” by foreign persons for purposes of defining a domestically controlled QIE under section 897(h)(4)(B)

(2022 proposed regulations). The 2022

proposed regulations defined stock in a

QIE that is held “indirectly” by taking

into account stock of the QIE held through

certain entities under a limited “lookthrough” approach. Under that approach,

only a “non-look-through person” is

treated as holding directly or indirectly

stock of a QIE, and stock of a QIE held by

or through one or more intervening “lookthrough persons” is treated as held proportionately by the look-through person’s

Bulletin No. 2025–46

ultimate owners that are non-look-through

persons.

The 2022 proposed regulations generally treated a “domestic C corporation,”

defined as any domestic corporation other

than a RIC, REIT, or an S corporation, as

a non-look-through person. However, the

2022 proposed regulations treated certain

“non-publicly traded domestic C corporations” as look-through persons if foreign

persons hold a 25 percent or greater interest (by value) in the stock of the corporation (domestic corporation look-through

rule).

On April 24, 2024, the Treasury

Department and the IRS published TD

9992 in the Federal Register (89 FR

31618) (2024 final regulations), which

finalized the 2022 proposed regulations.

The 2024 final regulations retained the

general approach and structure of the

2022 proposed regulations with certain

revisions. In particular, under the 2024

final regulations the domestic corporation

look-through rule applies if foreign persons hold a more than 50 percent interest (by value) in the stock of the corporation. See § 1.897-1(c)(3)(iii)(B) and

(c)(3)(v)(B). The 2024 final regulations

also include a transition rule that exempts

existing QIEs from the application of the

domestic corporation look-through rule

for a 10-year period, provided that there

is not a significant change in the USRPIs

held by the QIE or in the QIE’s ownership.

See § 1.897-1(c)(3)(vi).

Explanation of Provisions

I. Removal of Domestic Corporation

Look-Through Rule

Following the publication of the 2024

final regulations, the Treasury Department

and the IRS received feedback from taxpayers recommending the withdrawal of

the domestic corporation look-through

rule, focusing on the practical difficulty of

tracing upstream ownership, often without

access to reliable data, resulting in legal

uncertainty, operational complexity, and

potentially chilling effects on investment

in U.S. real estate. The Treasury Department and the IRS share these concerns.

In addition, taxpayers argued that the

domestic corporation look-through rule

is inconsistent with the statute and con-

Bulletin No. 2025–46

flicts with congressional intent. They

noted that within the domestically controlled QIE provisions, section 897(h)(4)

(B) does not contain explicit corporate

look-through rules and that Congress

enacted rules in 2015 providing for lookthrough treatment for certain corporate

owners of QIEs, but only in the specific circumstances described in section

897(h)(4)(E). They argued that the presence of the look-through rules in section

897(h)(4)(E) (and in other areas under

section 897) indicates that the absence of

a similar rule in section 897(h)(4)(B) was

intentional, and that interpreting section

897(h)(4)(B) to include corporate lookthrough rules would render the section

897(h)(4)(E) look-through rules surplus.

The recommendations emphasized that

the term “indirectly” can have meanings in the Code other than look-through

treatment of domestic corporations. They

further argued that the interests held by

a domestic corporation are subject to

U.S. corporate income tax and therefore

the objective of section 897 is satisfied

without looking through a domestic corporation.

In response to the feedback received,

the Treasury Department and the IRS have

further considered whether the interpretation of “indirectly” reflected in the domestic corporation look-through rule is consistent with the statutory text and purpose

of the DC‑QIE exception, which Congress

intended to be available for QIEs that are

controlled by United States persons. In

light of this further consideration, the

Treasury Department and the IRS are of

the view that imposing look-through treatment under the domestic corporation lookthrough rule with respect to an entity that

is subject to U.S. taxation based on a strict

50-percent foreign ownership threshold is

not the construction that should be given

to the text of section 897(h)(4)(B), as

informed by the traditional tools of statutory construction, including evaluation of

the provision’s purpose.

Accordingly, the proposed regulations

would remove the domestic corporation

look-through rule and treat all domestic C

corporations as non-look-through persons

in determining whether a QIE is domestically controlled. The proposed regulations

would also provide for various conforming revisions to § 1.897-1(c)(3) that are

713

necessary because of the removal of the

domestic corporation look-through rule.

II. Applicability Date

The proposed regulations, upon finalization, would apply to transactions

occurring on or after October 20, 2025.

However, taxpayers may choose to apply

the final regulations, once published in

the Federal Register, to transactions

occurring on or after April 25, 2024 (and

to transactions occurring before April 25,

2024, resulting from an entity classification election under § 301.7701-3 of this

chapter that was effective on or before

April 25, 2024, but was filed on or after

April 25, 2024). Taxpayers may rely on

the proposed regulations for transactions

occurring before the date the proposed

regulations are finalized.

Special Analyses

I. Regulatory Planning and Review -Economic Analysis

The proposed regulations are not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memorandum of Agreement (July 4, 2025)

between the Treasury Department and the

Office of Management and Budget (OMB)

regarding review of tax regulations.

II. Paperwork Reduction Act

The Paperwork Reduction Act of 1995

(44 U.S.C. 3501–3520) (PRA) generally

requires that a Federal agency obtain the

approval of the OMB before collecting

information from the public, whether such

collection of information is mandatory,

voluntary, or required to obtain or retain

a benefit. An agency may not conduct or

sponsor, and a person is not required to

respond to, a collection of information

unless it displays a valid control number

assigned by the OMB.

The existing collection of information

requirement in § 1.1445-2(c)(3) is a statement provided by a domestic corporation

that certifies that an interest in such corporation is not a U.S. real property interest. Section 1.1445-2(c)(3) also provides

that the same procedure may be used by

a domestic corporation to certify that it is

November 10, 2025

a domestically controlled QIE (as determined under § 1.897-1(c)(3)), as long as

the certification is voluntarily issued and

otherwise complies with the requirements

in § 1.897-2(h).

The proposed regulations do not modify any existing information collection

requirements or create new or additional

information collection requirements. For

purposes of the PRA, the reporting burden

associated with the collections of information in § 1.1445-2(c)(3) is reflected in

the PRA submissions associated with the

section 1445 regulations (OMB control

number 1545-0902).

III. Regulatory Flexibility Act

When an agency issues a rulemaking

proposal, the Regulatory Flexibility Act

(5 U.S.C. chapter 6) (RFA) requires the

agency to prepare and make available

for public comment an initial regulatory

flexibility analysis that will describe the

impact of the proposed rule on small entities. See 5 U.S.C. 603(a). Section 605 of

the RFA provides an exception to this

requirement if the agency certifies that

the proposed rulemaking will not have

a significant economic impact on a substantial number of small entities. A small

entity is defined as a small business,

small nonprofit organization, or small

governmental jurisdiction. See 5 U.S.C.

601(3) through (6).

The proposed regulations would

remove the domestic corporation lookthrough rule and, therefore, a domestic C corporation would be treated as a

non-look-through person in determining

whether a QIE is domestically controlled.

Data on the number of small entities

potentially affected by the proposed regulations is not readily available. Even if a

substantial number of small entities would

be affected, the economic impact is not

expected to be significant. The Treasury

Department and the IRS are of the view

that the proposed regulations will reduce

the economic impact on small entities by

reducing compliance burdens. Accordingly, a regulatory flexibility analysis is

not required.

Notwithstanding this certification, the

Treasury Department and the IRS welcome comments about the impacts of

these regulations on small entities.

November 10, 2025

IV. Section 7805(f)

Pursuant to section 7805(f) of the

Code, the proposed regulations (REG109742-25) have been submitted to the

Chief Counsel for Advocacy of the Small

Business Administration for comment on

their impact on small businesses.

V. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandates

Reform Act of 1995 requires that agencies

assess anticipated costs and benefits and

take certain other actions before issuing a

final rule that includes any Federal mandate that may result in expenditures in any

one year by a State, local, or Tribal government, in the aggregate, or by the private sector, of $100 million in 1995 dollars, updated annually for inflation. The

proposed regulations do not include any

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

that threshold.

VI. Executive Order 13132: Federalism

Executive Order 13132 (entitled

“Federalism”) prohibits an agency from

publishing any rule that has federalism

implications if the rule either imposes

substantial, direct compliance costs on

State and local governments, and is not

required by statute, or preempts State

law, unless the agency meets the consultation and funding requirements of

section 6 of the Executive order. The

proposed regulations do not have federalism implications, do not impose substantial direct compliance costs on State

and local governments, and do not preempt State law within the meaning of the

Executive order.

Comments and Requests for a Public

Hearing

Before these proposed regulations

are adopted as final regulations, consideration will be given to any comments

that are submitted timely to the IRS as

prescribed in this preamble under the

ADDRESSES heading. The Treasury

Department and the IRS request comments on all aspects of the proposed reg-

714

ulations. Any comments submitted will

be made available at http://www.regulations.gov or upon request.

A public hearing will be scheduled if

requested in writing by any person who

timely submits electronic or written comments. Requests for a public hearing are

also encouraged to be made electronically. If a public hearing is scheduled,

notice of the date and time for the public

hearing will be published in the Federal

Register.

Drafting Information

The principal author of the proposed

regulations is the Office of the Associate

Chief Counsel (International). However,

other personnel from the Treasury Department and the IRS participated in their

development.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the

Regulations

Accordingly, the Treasury Department

and the IRS propose to amend 26 CFR

part 1 as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation

for part 1 continues to read, in part, as follows:

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

Par. 2. Section 1.897-1 is amended by:

1. Revising paragraphs (a)(2) and (c)(3)

(iii)(A);

2. Removing paragraph (c)(3)(iii)(B)

and redesignating paragraph (c)(3)

(iii)(C) as paragraph (c)(3)(iii)(B);

3. Revising the last sentence of newly

redesignated paragraph (c)(3)(iii)(B);

4. Removing the language “see paragraph (c)(3)(vii)(A)” in the second

sentence of paragraph (c)(3)(iv)(A)

and adding “see paragraph (c)(3)(vi)

(A)” in its place;

5. Revising paragraph (c)(3)(v)(B);

6. Removing the last sentence in paragraph (c)(3)(v)(C);

7. Revising paragraph (c)(3)(v)(D);

Bulletin No. 2025–46

8.

Removing paragraph (c)(3)(v)(E) and

redesignating paragraph (c)(3)(v)(F)

as paragraph (c)(3)(v)(E);

9. Removing paragraph (c)(3)(v)(G)

and redesignating paragraphs (c)(3)

(v)(H) through (J) as paragraphs (c)

(3)(v)(F) through (H);

10. Revising the last sentence of newly

redesignated paragraphs (c)(3)(v)(G)

and (H);

11. Redesignating paragraphs (c)(3)(v)

(K) through (O) as paragraphs (c)(3)

(v)(I) through (M);

12. Removing paragraph (c)(3)(vi) and

redesignating paragraph (c)(3)(vii) as

paragraph (c)(3)(vi);

13. Revising the newly redesignated

paragraph (c)(3)(vi); and

14. Removing the language “paragraph

(c)(3)(ii) through (vii)” in paragraph

(c)(4) and adding “paragraph (c)(3)

(ii) through (vi)” in its place.

The revisions read as follows:

§1.897-1 Taxation of foreign investment

in United States real property interests,

definition of terms.

(a) * * *

(2) Applicability date. Except as otherwise provided in this paragraph (a)(2), the

regulations set forth in this section and §§

1.897-2 through 1.897-4 apply to transactions occurring after June 18, 1980. Paragraphs (c)(3) and (4) of this section apply

to transactions occurring on or after October 20, 2025. For transactions occurring

before October 20, 2025, see paragraphs

(c)(3) and (4) of this section contained in

26 CFR part 1, as revised April 1, 2025.

With respect to transactions occurring

before October 20, 2025, taxpayers may

apply paragraphs (c)(3) and (4) of this section for transactions occurring on or after

April 25, 2024, and transactions occurring before April 25, 2024, resulting from

an entity classification election under §

301.7701-3 of this chapter that was effective on or before April 25, 2024, but was

filed on or after April 25, 2024. Paragraphs (k) and (l) of this section apply to

transactions occurring on or after April 25,

2024, and transactions occurring before

April 25, 2024, resulting from an entity

classification election under § 301.7701-3

of this chapter that was effective on or

before April 25, 2024, but was filed on

Bulletin No. 2025–46

or after April 25, 2024. For transactions

occurring before April 25, 2024, see paragraphs (c)(2)(i) and (l) of this section and

§ 1.897-9T(c) contained in 26 CFR part 1,

as revised April 1, 2024.

*****

(c) * * *

(3) * * *

(iii) * * *

(A) Certain holders of U.S. publicly

traded QIE stock. Notwithstanding any

other provision of this paragraph (c)(3),

a person holding less than five percent

of U.S. publicly traded stock of a QIE at

all times during the testing period, determined without regard to paragraph (c)(3)

(ii)(A) of this section, is treated as a United

States person that is a non-look-through

person with respect to that stock, unless

the QIE has actual knowledge that such

person is not a United States person or

has actual knowledge that such person is a

look-through person that is a foreign-controlled entity. For an example illustrating

the application of this paragraph (c)(3)(iii)

(A), see paragraph (c)(3)(vi)(B) of this

section (Example 2).

(B) * * * For an example illustrating

the application of this paragraph (c)(3)

(iii)(B), see paragraph (c)(3)(vi)(B) of this

section (Example 2).

*****

(v) * * *

(B) A foreign-controlled entity is any

entity in which foreign persons hold

directly or indirectly more than 50 percent

of the fair market value of the entity’s outstanding interests. For purposes of determining whether an entity is a foreign-controlled entity, the rules of paragraphs (c)

(3)(ii)(A) through (C), (c)(3)(iii)(A) and

(B), and (c)(3)(iv) of this section apply

(treating the entity as if it were a QIE for

this purpose).

*****

(D) A non-look-through person is an

individual, a domestic C corporation, a

nontaxable holder, a foreign corporation

(including a foreign government pursuant

to section 892(a)(3)), a publicly traded

partnership (domestic or foreign), a public

RIC, an estate (domestic or foreign), an

international organization (as defined in

section 7701(a)(18)), a qualified foreign

pension fund (including any part of a qualified foreign pension fund), or a qualified

controlled entity. For special rules that

715

treat certain holders of QIE stock as nonlook-through persons, see paragraphs (c)

(3)(iii)(A) and (B) of this section.

*****

(G) * * * A RIC is not a public RIC,

however, if the QIE whose status as

domestically controlled is being determined under this paragraph (c)(3) has

actual knowledge that the RIC is a foreign-controlled entity.

(H) * * * A domestic partnership is not

a publicly traded partnership, however,

if the QIE whose status as domestically

controlled is being determined under this

paragraph (c)(3) has actual knowledge

that the domestic partnership is a foreign-controlled entity.

*****

(vi) Examples. The rules of this paragraph (c)(3) are illustrated by the following examples. It is assumed that each

entity has a single class of stock or other

ownership interests, that the ownership

described existed throughout the relevant testing period and that, unless otherwise stated, a QIE is not a public QIE

as defined under paragraph (c)(3)(v)(F) of

this section.

(A) Example 1: QIE stock held by domestic C

corporation--(1) Facts. USR is a REIT, 51 percent

of the stock of which is held by X, a domestic C corporation as defined in paragraph (c)(3)(v)(A) of this

section, and 49 percent of the stock of which is held

by nonresident alien individuals, which are foreign

persons as defined in paragraph (k) of this section.

(2) Analysis. Under paragraph (c)(3)(v)(K) of

this section, USR is a QIE. Because X is a domestic C corporation it is a non-look-through person as

defined under paragraph (c)(3)(v)(D) of this section.

Thus, under paragraph (c)(3)(ii)(A) of this section X

is considered as holding directly or indirectly stock

of USR for purposes of determining whether USR is

a domestically controlled QIE. Under paragraph (c)

(3)(ii)(C) of this section, the USR stock held directly

or indirectly by X is not considered held directly or

indirectly by any other person, including the shareholders of X. Because X is not a foreign person as

defined in paragraph (k) of this section and holds

directly or indirectly 51 percent of the single class

of outstanding stock of USR, foreign persons hold

directly or indirectly less than 50 percent of the fair

market value of the stock of USR, and USR therefore

is a domestically controlled QIE under paragraph (c)

(3)(i) of this section.

(3) Alternative facts: QIE stock held by domestic

partnership. The facts are the same as in paragraph

(c)(3)(vi)(A)(1) of this section (Example 1), except

that, instead of being a domestic C corporation, X is

a domestic partnership that is not a publicly traded

partnership as defined in paragraph (c)(3)(v)(H) of

this section. In addition, FC1, a foreign corporation,

holds a 50 percent interest in X, and the remaining

interests in X are held by U.S. citizens. X is not a

November 10, 2025

non-look-through person as defined in paragraph (c)

(3)(v)(D) of this section and, therefore, is a lookthrough person as defined in paragraph (c)(3)(v)(C)

of this section. Accordingly, under paragraph (c)(3)

(ii)(A) of this section, X is not considered as holding directly or indirectly stock of USR for purposes

of determining whether USR is a domestically controlled QIE. Under paragraph (c)(3)(ii)(B) of this

section, the stock of USR that, but for paragraph (c)

(3)(ii)(A) of this section, is considered held by X,

a look-through person, is instead considered held

proportionately by X’s partners that are non-lookthrough persons. Accordingly, because FC1 and

the U.S. citizen partners in X are non-look-through

persons as defined in paragraph (c)(3)(v)(D) of this

section, 25.5 percent of the stock of USR is considered as held directly or indirectly by FC1 (50% x

51%), a foreign person as defined in paragraph (k)

of this section, and 25.5 percent (in the aggregate)

of the stock of USR is considered as held directly

or indirectly by the U.S. citizen partners in X (50%

x 51%), who are not foreign persons as defined in

paragraph (k) of this section. Foreign persons therefore hold directly or indirectly 74.5 percent of the

stock of USR (49 percent of the stock of USR held

directly or indirectly by nonresident alien individuals, who are non-look-through persons as defined in

paragraph (c)(3)(v)(D) of this section, plus the 25.5

percent held directly or indirectly by FC1), and USR

is not a domestically controlled QIE under paragraph

(c)(3)(i) of this section. The result described in this

paragraph (c)(3)(vi)(A)(3) would be the same if,

instead of being a domestic partnership, X were a

foreign partnership.

(4) Alternative facts: QIE stock held by a qualified foreign pension fund. The facts are the same as

in paragraph (c)(3)(vi)(A)(3) of this section, except

that, instead of being a foreign corporation, FC1 is

a qualified foreign pension fund. The analysis is the

same as in paragraph (c)(3)(vi)(A)(3) of this section

regarding the treatment of X as a look-through person

as defined in paragraph (c)(3)(v)(C) of this section.

In addition, FC1, a foreign person under paragraph

(c)(3)(iv)(A) of this section, is a non-look-through

person as defined in paragraph (c)(3)(v)(D) of this

section. Because FC1 and the U.S. citizen partners in

X are non-look-through persons, 25.5 percent of the

stock of USR is considered as held directly or indirectly by FC1 (50% x 51%), and 25.5 percent (in the

aggregate) of the stock of USR is considered as held

directly or indirectly by the U.S. citizen partners in X

(50% x 51%). Thus, for the same reasons described

in paragraph (c)(3)(vi)(A)(3) of this section, foreign

persons hold directly or indirectly 74.5 percent of the

stock of USR, and USR is not a domestically controlled QIE under paragraph (c)(3)(i) of this section.

(B) Example 2: QIE stock held by public QIE

that is a domestically controlled QIE--(1) Facts.

USR2 is a REIT, 51 percent of the stock of which is

held by USR1, a REIT that is a public QIE as defined

in paragraph (c)(3)(v)(F) of this section. The remaining 49 percent of the stock of USR2 is held by nonresident alien individuals, which are foreign persons

as defined in paragraph (k) of this section. The stock

November 10, 2025

of USR1 is U.S. publicly traded QIE stock as defined

in paragraph (c)(3)(v)(M) of this section. FC1 and

FC2, both foreign corporations, each hold 20 percent of the stock of USR1. The remaining 60 percent

of the stock of USR1 is held by persons that each

hold less than 5 percent of the stock of USR1 (USR1

less than five-percent public shareholders) and with

respect to which USR1 has no actual knowledge that

such person is not a United States person or is a lookthrough person that is a foreign-controlled entity (as

determined under paragraph (c)(3)(v)(B) of this section by treating any entity as if it were a QIE for this

purpose).

(2) Analysis. Under paragraph (c)(3)(v)(K)

of this section, USR2 and USR1 are QIEs. Under

paragraph (c)(3)(iii)(A) of this section, each of the

USR1 less than five-percent public shareholders is

treated as a United States person that is a non-lookthrough person. Consequently, under paragraph (c)

(3)(i) of this section USR1 is a domestically controlled QIE because FC1 and FC2, each a foreign

person as defined in paragraph (k) of this section

that is a non-look-through person under paragraph

(c)(3)(v)(D) of this section, together hold directly

or indirectly only 40 percent of the stock of USR1

and, thus, foreign persons hold directly or indirectly

less than 50 percent of the fair market value of the

stock of USR1. In addition, the USR2 stock held

by USR1 is treated as held directly or indirectly by

a United States person that is a non-look-through

person under paragraph (c)(3)(iii)(B) of this section. Because USR1 holds directly or indirectly 51

percent of the stock of USR2, foreign persons hold

directly or indirectly less than 50 percent of the fair

market value of the stock of USR2, and USR2 is a

domestically controlled QIE under paragraph (c)(3)

(i) of this section.

(3) Alternative facts: QIE stock held by public

QIE that is not a domestically controlled QIE. The

facts are the same as in paragraph (c)(3)(vi)(B)(1)

of this section (Example 2), except that 25 percent

of the stock of USR1 is held by each of FC1 and

FC2, with the remaining 50 percent of the stock of

USR1 held by the USR1 less than five-percent public shareholders. Regardless of the treatment of the

USR1 less than five-percent public shareholders,

USR1 is not a domestically controlled QIE under

paragraph (c)(3)(i) of this section because FC1 and

FC2, each a foreign person as defined in paragraph

(k) of this section that is a non-look-through person under paragraph (c)(3)(v)(D) of this section,

together hold directly or indirectly 50 percent of

the stock of USR1 and, thus, foreign persons do not

hold directly or indirectly less than 50 percent of

the fair market value of the stock of USR1. In addition, the USR2 stock held by USR1 is treated as

held by a foreign person that is a non-look-through

person under paragraph (c)(3)(iii)(B) of this section. Because USR1 holds directly or indirectly 51

percent of the stock of USR2, foreign persons do

not hold directly or indirectly less than 50 percent

of the fair market value of the stock of USR2, and

USR2 is not a domestically controlled QIE under

paragraph (c)(3)(i) of this section.

716

(C) Example 3: QIE stock held by non-public

QIE--(1) Facts. USR2 is a REIT, 49 percent of the

stock of which is held by nonresident alien individuals, and 51 percent of the stock of which is held by

USR1, a REIT. USR1 is not a public QIE as defined

in paragraph (c)(3)(v)(F) of this section. U.S. citizens

hold 50 percent of the stock of USR1. The remaining

50 percent of the stock of USR1 is held by PRS, a

domestic partnership, 50 percent of the interests in

which are held by DC, a domestic C corporation as

defined in paragraph (c)(3)(v)(A) of this section, and

50 percent of the interests in which are held by nonresident alien individuals.

(2) Analysis. Under paragraph (c)(3)(v)(K) of

this section, USR2 and USR1 are QIEs. USR1 is

not treated as a non-look-through person under

paragraph (c)(3)(iii)(B) of this section because

USR1 is not a public QIE as defined in paragraph

(c)(3)(v)(F) of this section. Each of USR1 and

PRS is a look-through person as defined in paragraph (c)(3)(v)(C) of this section that is not treated

as holding directly or indirectly stock in USR2

for purposes of determining whether USR2 is a

domestically controlled QIE under paragraph (c)

(3)(ii)(A) of this section. Because the U.S. citizens who hold USR1 stock are non-look-through

persons as defined in paragraph (c)(3)(v)(D) of

this section, those U.S. citizens are treated under

paragraph (c)(3)(ii)(B) of this section as holding

directly or indirectly 25.5 percent of the stock of

USR2 through their USR1 stock interest (50% x

51%) in accordance with paragraph (c)(3)(ii)(A) of

this section. Similarly, because DC and the nonresident alien partners in PRS are non-look-through

persons as defined in paragraph (c)(3)(v)(D) of

this section, each is treated under paragraph (c)(3)

(ii)(B) of this section as holding directly or indirectly the stock of USR2 through its interest in PRS

and PRS’s interest in USR1. Thus, DC is treated

as holding directly or indirectly 12.75 percent of

the stock of USR2 (50% x 50% x 51%) and the

nonresident alien individual partners, which are

foreign persons as defined in paragraph (k) of this

section, are treated as directly or indirectly holding

a 12.75 percent aggregate interest in the stock of

USR2 (50% x 50% x 51%). Foreign persons therefore hold directly or indirectly 61.75 percent of

the stock of USR2 (the 49 percent stock in USR2

directly held by nonresident alien individuals, who

are foreign persons and non-look-through persons

as defined in paragraph (c)(3)(v)(D) of this section,

plus the 12.75 percent in stock indirectly held by

the nonresident alien individual partners in PRS),

and USR2 is not a domestically controlled QIE

under paragraph (c)(3)(i) of this section.

*****

Jarod J. Koopman,

Acting Chief Tax Compliance Officer.

(Filed by the Office of the Federal Register October

20, 2025, 8:45 a.m., and published in the issue of the

Federal Register for October 21, 2025, 90 FR 48422)

Bulletin No. 2025–46

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. 2025–46

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.

November 10, 2025

Numerical Finding List1

Bulletin 2025–46

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

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

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

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

November 10, 2025

ii

Bulletin No. 2025–46

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–46

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. 2025–46

iii

November 10, 2025

Internal Revenue Service

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