# Bulletin No. 2025–46

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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
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

November 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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INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A357b6116a77068d0. Public record. Not legal advice.