Bulletin No. 2025–50

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–50

December 8, 2025

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

Announcement 2025-29, page 785.

The Office of Professional Responsibility (OPR) announces

recent disciplinary sanctions imposed on attorneys, certified public accountants, enrolled agents, enrolled actuaries,

enrolled retirement plan agents, and appraisers. The OPR

also announces when certain unenrolled, unlicensed tax

return preparers (individuals who are not enrolled to practice before the Internal Revenue Service (IRS) and are not

licensed as attorneys or certified public accountants) have

been disciplined. Licensed or enrolled practitioners are subject to the regulations governing practice before the IRS,

which are set out in Title 31, Code of Federal Regulations,

Subtitle A, Part 10, and which are released as Treasury

Department Circular No. 230. The regulations prescribe

the duties and restrictions relating to such practice and

prescribe the disciplinary sanctions for violating the regulations. Unenrolled/unlicensed return preparers who choose

to participate in the IRS’s voluntary Annual Filing Season

Program (AFSP) are subject to the guidance in Revenue

Procedure 2014-42, which governs a preparer’s eligibility

to represent taxpayers before the IRS in examinations of

tax returns the preparer both prepared for the taxpayer and

signed as the preparer. Additionally, unenrolled/unlicensed

return preparers who participate in the AFSP agree to be

subject to the duties and restrictions in Circular 230, including the restrictions on incompetence or disreputable conduct.

EMPLOYMENT TAX

Notice 2025-69, page 766.

Notice 2025-69 provides guidance to individual taxpayers

who are eligible for the federal income tax deductions for

qualified tips or qualified overtime compensation for tax year

2025. These new deductions were added by Public Law 119-

Finding Lists begin on page ii.

21, 139 Stat. 72 (July 4, 2025), commonly known as the

One, Big, Beautiful Bill Act (OBBBA). As part of the phased

implementation of the OBBBA, there will be no changes to

the 2025 Form W-2, Form 1099-NEC, Form 1099-MISC, or

Form 1099-K to account for the new reporting requirements

in the OBBBA. As a result, employers and other payors will

not be required to separately account for cash tips or qualified overtime compensation on those forms furnished to individuals for 2025. In the absence of this information reporting, this Notice provides guidance for individual taxpayers on

how to satisfy the requirements for the deductions, including

how to determine the amount of the qualified tips or qualified

overtime compensation, for tax year 2025. This Notice also

provides transition relief for taxpayers regarding the requirement that qualified tips must not be received in the course

of a trade or business that is a specified service trade or

business. This Notice does not affect any rights or responsibilities regarding tips or overtime compensation under the

Fair Labor Standards Act of 1938, as amended.

INCOME TAX

Announcement 2025-22, page 783.

Section 48C(e)(1) directs the Secretary to establish the §

48C(e) program to consider and award certifications for

qualified investments eligible for § 48C credits to qualifying

advanced energy project sponsors. Section 48C(e)(7) provides that upon making a certification under § 48C(e), the

Secretary is required to disclose publicly the identity of the

applicant and the amount of the § 48C credit certified with

respect to such applicant. Notice 2023-18 established the

program under § 48C(e)(1). The Treasury Department and

the IRS provided two allocation rounds. For Round 1, the IRS

allocated approximately $4 billion. Round 1 allocation notification letters were issued on March 29, 2024. Announcement 2025-22 provides the identity of each taxpayer and

the amount of the § 48C credits allocated to each taxpayer

with respect to projects that have been allocated a § 48C

credit and for which a certification was issued during the

period beginning on March 29, 2024, and September 30,

2025. The announcement also provides that the IRS will publish additional such announcements annually for certifications

issued during each successive 12-month period beginning

on October 1, 2025.

Announcement 2025-23, page 784.

Section 48C(e)(1) directs the Secretary to establish the §

48C(e) program to consider and award certifications for

qualified investments eligible for § 48C credits to qualifying

advanced energy project sponsors. Section 48C(e)(7) provides that upon making a certification under § 48C(e), the

Secretary is required to disclose publicly the identity of the

applicant and the amount of the § 48C credit certified with

respect to such applicant. Notice 2023-18 established the

program under § 48C(e)(1). The Treasury Department and

the IRS provided two allocation rounds. For Round 2, the IRS

allocated approximately $6 billion. Round 2 allocation notification letters were issued on January 10, 2025. Announcement 2025-23 provides the identity of each taxpayer and

the amount of the § 48C credits allocated to each taxpayer

with respect to projects that have been allocated a § 48C

credit and for which a certification was issued during the

period beginning on January 10, 2025, and September 30,

2025. The announcement also provides that the IRS will publish additional such announcements annually for certifications

issued during each successive 12-month period beginning

on October 1, 2025.

Notice 2025-70, page 773.

In anticipation of issuing proposed regulations to implement new § 25F of the Internal Revenue Code, as added

by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4,

2025), commonly known as the One, Big, Beautiful Bill Act

(OBBBA), this notice requests comments regarding issues

arising under § 25F that should be addressed in guidance.

This notice emphasizes issues on which guidance is most

quickly needed, including issues relating to the annual certification by a State, as well as scholarship granting organization requirements.

Notice 2025-71, page 779.

This notice provides interim rules under section 139L, which

was added to the Code by Public Law 119-21, 139 Stat. 72

(July 4, 2025), commonly known as the One, Big, Beautiful

Bill Act (OBBBA). This notice clarifies the partial exclusion

from gross income of interest received by qualified lenders

on loans secured by rural or agricultural property. The interim

guidance defines key terms from section 139L, establishes

standards for determining whether a loan is secured by rural

or agricultural property, and provides rules regarding refinancings.

Rev. Rul. 2025-24, page 764.

Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax exempt rate. For purposes

of sections 382, 1274, 1288, 7872 and other sections of

the Code, tables set forth the rates for December 2025.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

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

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

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

December 8, 2025 

Bulletin No. 2025–50

Part I

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2025-24

This revenue ruling provides various prescribed rates for federal income

AFR

110% AFR

120% AFR

130% AFR

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

AFR

110% AFR

120% AFR

130% AFR

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

December 8, 2025

tax purposes for December 2025 (the

current month). Table 1 contains the

short-term, mid-term, and long-term

applicable federal rates (AFR) for the

current month for purposes of section

1274(d) of the Internal Revenue Code.

Table 2 contains the short-term, midterm, and long-term adjusted applicable federal rates (adjusted AFR) for the

current month for purposes of section

1288(b). Table 3 sets forth the adjusted

federal long-term rate and the longterm tax-exempt rate described in section 382(f). Table 4 contains the appro-

priate percentages for determining the

low-income housing credit described in

section 42(b)(1) for buildings placed in

service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service

after July 30, 2008, shall not be less

than 9%. Finally, Table 5 contains the

federal rate for determining the present

value of an annuity, an interest for life

or for a term of years, or a remainder or

a reversionary interest for purposes of

section 7520.

REV. RUL. 2025-24 TABLE 1

Applicable Federal Rates (AFR) for December 2025

Period for Compounding

Annual

Semiannual

Quarterly

Short-term

3.66%

3.63%

3.61%

4.03%

3.99%

3.97%

4.41%

4.36%

4.34%

4.78%

4.72%

4.69%

Mid-term

3.79%

3.75%

3.73%

4.17%

4.13%

4.11%

4.55%

4.50%

4.47%

4.94%

4.88%

4.85%

5.71%

5.63%

5.59%

6.67%

6.56%

6.51%

Long-term

4.55%

4.50%

4.47%

5.01%

4.95%

4.92%

5.47%

5.40%

5.36%

5.94%

5.85%

5.81%

REV. RUL. 2025-24 TABLE 2

Adjusted AFR for December 2025

Period for Compounding

Annual

Semiannual

2.78%

2.76%

2.87%

2.85%

3.45%

3.42%

764

Monthly

3.60%

3.96%

4.32%

4.67%

3.72%

4.09%

4.46%

4.83%

5.57%

6.47%

4.46%

4.90%

5.34%

5.78%

Quarterly

2.75%

2.84%

3.41%

Monthly

2.74%

2.83%

3.40%

Bulletin No. 2025–50

REV. RUL. 2025-24 TABLE 3

Rates Under Section 382 for December 2025

Adjusted federal long-term rate for the current month

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal

long-term rates for the current month and the prior two months.)

3.45%

3.58%

REV. RUL. 2025-24 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for December 2025

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after

July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit

7.97%

Appropriate percentage for the 30% present value low-income housing credit

3.41%

REV. RUL. 2025-24 TABLE 5

Rate Under Section 7520 for December 2025

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,

or a remainder or reversionary interest

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24, page 764.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24 page 764.

Section 382.—Limitation

on Net Operating Loss

Carryforwards and

Certain Built-In Losses

Following Ownership

Change

The adjusted applicable federal long-term rate

is set forth for the month of December 2025. See

Rev. Rul. 2025-24, page 764.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24, page 764.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of December 2025. See Rev.

Rul. 2025-24, page 764.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24, page 764.

4.60%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24, page 764.

Section 1288.—Treatment

of Original Issue Discount

on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month

of December 2025. See Rev. Rul. 2025-24, page 764.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of December 2025. See Rev.

Rul. 2025-24, page 764.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

December 2025. See Rev. Rul. 2025-24, page 764.

Bulletin No. 2025–50

765

December 8, 2025

Part III

Guidance for Individual

Taxpayers who received

Qualified Tips or Qualified

Overtime Compensation in

2025

Notice 2025-69

I. PURPOSE

This Notice provides guidance to individual taxpayers who are eligible for the

federal income tax deductions for qualified tips or qualified overtime compensation for tax year 2025. These new deductions were added by Public Law 119-21,

139 Stat. 72 (July 4, 2025), commonly

known as the One, Big, Beautiful Bill Act

(OBBBA). As previously announced, and

as part of the phased implementation of the

OBBBA, there will be no changes to the

2025 Form W-2, Form 1099-NEC, Form

1099-MISC, or Form 1099-K to account

for the new reporting requirements in

the OBBBA.1 As a result, employers and

other payors will not be required to separately account for cash tips or qualified

overtime compensation on those forms

or the written statements (copies of the

forms) furnished to individuals for 2025.2

In the absence of this information reporting, this Notice provides guidance for

individual taxpayers on how to satisfy the

requirements for the deductions, including

how to determine the amount of the qualified tips or qualified overtime compensation, for tax year 2025. This Notice also

provides transition relief for taxpayers

regarding the requirement that qualified

tips must not be received in the course of a

trade or business that is a specified service

trade or business. This Notice does not

affect any rights or responsibilities regarding tips or overtime compensation under

the Fair Labor Standards Act of 1938, as

amended (FLSA).

II. BACKGROUND

Section 70201(a) of the OBBBA

added new section 224 to the Internal

Revenue Code (Code). In general, section 224 provides an income tax deduction for “qualified tips” that are received

during the taxable year by individuals in

an occupation that customarily and regularly received tips on or before December 31, 2024. Section 70201(b) of the

OBBBA added the deduction provided

by section 224 of the Code to the list

of deductions used to determine taxable

income in section 63(b).

Section 70202(a) of the OBBBA added

new section 225 to the Code. In general,

section 225 provides an income tax deduction for “qualified overtime compensation”, defined in section 225(c) as overtime compensation paid to an individual

required under section 7 of the FLSA that

is in excess of the regular rate at which the

individual is employed.3 Section 70202(b)

of the OBBBA added the deduction provided by section 225 of the Code to the list

of deductions used to determine taxable

income in section 63(b). Both deductions

are available for tax years beginning after

December 31, 2024, and ending before

January 1, 2029.

A. No Tax on Tips under Section 224

Section 224(a) provides a deduction

in an amount equal to the qualified tips

received by an individual in a taxable

year that are included on statements4 furnished to the individual pursuant to sec-

tion 6041(d)(3), section 6041A(e)(3), section 6050W(f)(2), or section 6051(a)(18),

or are reported by the taxpayer on Form

4137 (or successor). Section 224(b)(1)

limits the amount of the deduction to an

amount not to exceed $25,000 in a taxable

year. Section 224(b)(2) further limits the

amount based on a taxpayer’s modified

adjusted gross income (MAGI), which is

a taxpayer’s adjusted gross income for

the tax year increased by any amount

excluded from gross income under section 911, section 931, or section 933. The

deduction phases out for taxpayers with

MAGI over $150,000 ($300,000 for joint

filers).

Section 224(c) provides that, in the case

of qualified tips received by an individual

during any taxable year in the course of

a trade or business (other than the trade

or business of performing services as an

employee) of such individual, such qualified tips are taken into account under

section 224(a) only to the extent that the

gross income for the taxpayer from such

trade or business for such taxable year

(including such qualified tips) exceeds

the sum of the deductions allocable to the

trade or business in which such qualified

tips are received by the individual for such

taxable year.

Section 224(d)(1) defines “qualified

tips” as cash tips received by an individual in an occupation that customarily

and regularly received tips on or before

December 31, 2024, as provided by the

Secretary.5 Section 224(d)(2) further

requires that qualified tips not include any

amount received by an individual unless

the amount:

• Is paid voluntarily without any consequence in the event of nonpayment, is

not the subject of negotiation, and is

determined by the payor;

See IRS News Release IR-2025-82 (Aug. 7, 2025). Forms W-2, 1099-NEC, 1099-MISC, and 1099-K will be updated for tax year 2026 to provide separate reporting of the employee’s

qualified tips and qualified overtime compensation.

2

On November 5, 2025, the Internal Revenue Service (IRS) published Notice 2025-62, IRB 2025-48, which provides penalty relief from the new information reporting requirements for cash

tips and qualified overtime compensation under the OBBBA to employers and other payors for not filing correct information returns and not providing correct payee statements to employees

and other payees. Specifically, this notice provides relief from the penalty under section 6721 for failure to file correct information returns and the penalty under section 6722 for failure to

furnish correct payee statements. This relief applies only for taxable year 2025. See IRS News Release IR-2025-110 (Nov. 5, 2025).

3

The FLSA is codified at 29 USC §§ 201-219. Section 7 is found at 29 USC § 207.

4

The House Budget Committee report on the OBBBA, H. Rept. 119-106, at 1503 (2025), specifies that the tip amounts included on reporting statements (for example, Form 1099) must

be separately accounted for on the statements in order to take the deduction. The OBBBA revisions to sections 6041, 6041A, and 6050W further require the statements to provide either a

separate accounting or the portion of the amount designated as tips. The OBBBA revision to section 6051 follows the existing statutory structure of enumerating each separate category of

amounts to be listed on the Form W-2.

5

Under section 7701(a)(11)(B), Secretary means the Secretary of the Treasury or his delegate.

1

December 8, 2025

766

Bulletin No. 2025–50

•

Is not received in the course of a trade

or business that is a specified service

trade or business as defined in section

199A(d)(2); and

• Satisfies such other requirements as

may be established by the Secretary

in regulations or other guidance.

Section 224(d)(2) further provides that

an individual receiving tips in the trade

or business of performing services as an

employee is treated as receiving tips in

the course of a trade or business that is

a specified service trade or business as

defined in section 199A(d)(2) if the trade

or business of the employer in which they

are employed is a specified service trade

or business.

Section 224(d)(3) provides that for purposes of section 224(d)(1), the term “cash

tips” includes tips received from customers that are paid in cash or charged and,

in the case of an employee, tips received

under any tip-sharing arrangement.

Section 224(e) provides that no deduction is allowed under section 224 unless

the taxpayer includes on the tax return for

the taxable year such individual’s social

security number as defined in section

24(h)(7) of the Code.

Section 224(f) provides that if the taxpayer is a married individual (within the

meaning of section 7703), section 224

applies only if the taxpayer and the taxpayer’s spouse file a joint return for the

taxable year. That is, the deduction is not

available for a taxpayer who is married

and files separately.

Section 70201(h) of the OBBBA

instructs the Secretary to publish a list of

occupations that customarily and regularly received tips on or before December

31, 2024, for purposes of section 224(d)

(1) of the Code no later than 90 days after

the date the OBBBA was enacted (July 4,

2025). On September 19, 2025, a notice

of proposed rulemaking (NPRM) (REG110032-25) was published in the Federal

Register (90 FR 45340) that includes a proposed list of occupations that customarily

and regularly received tips on or before

December 31, 2024, and a proposed definition of qualified tips for purposes of the

income tax deduction for qualified tips.

The NPRM states that taxpayers may rely

on the proposed regulations, including the

proposed list of eligible occupations, for

taxable years beginning after December

31, 2024, and on or before the date the

regulations are published as final regulations in the Federal Register, provided that

taxpayers follow the proposed regulations

in their entirety and in a consistent manner.

Section 70201(f) of the OBBBA added

to the information reporting requirements

of the Code for employers and other payors making payments of cash tips by:

(1) amending section 6041(a) of the

Code to require a payor to include on the

information return filed with the IRS a

separate accounting of any such amounts

reasonably designated as cash tips and the

occupation described in section 224(d)(1)

of the person receiving such tips;

(2) adding new paragraph (d)(3) to section 6041 to provide that, in the case of

compensation to non-employees, a payor

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

of payments reasonably designated as

cash tips and the occupation described in

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

such tips;

(3) amending section 6041A(a) to

require a payor to include on the information return filed with the IRS a separate

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

the person receiving such tips;

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

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

include on the written statement furnished

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

occupation described in section 224(d)(1)

of the person receiving such tips;

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

of a third party settlement organization

(TPSO), the TPSO must include on the

information return filed with the IRS the

portion of reportable payment transactions

that have been reasonably designated by

payors as cash tips and the occupation

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

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

require a TPSO to include on the written

statement furnished to the payee a separate

accounting of any such amounts that have

been reasonably designated by payors as

cash tips and the occupation described in

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

such tips; and

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

section 6051 to provide that an employer

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

of cash tips reported by the employee

under section 6053(a) and the occupation

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

Section 70201(k) of the OBBBA provides a transition rule for persons required

to file returns or furnish statements under

section 6041(a), 6041(d)(3), 6041A(a),

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

(2) of the Code for cash tips required to

be reported for periods before January 1,

2026. Under this transition rule, those persons may approximate a separate accounting of amounts designated as cash tips by

any reasonable method specified by the

Secretary.

Section 6053(a) requires every

employee who, in the course of the

employee’s employment by an employer,

receives in any calendar month tips that

are wages (as defined in section 3121(a)

for Federal Insurance Contributions Act

(FICA) tax purposes or section 3401(a)

for income tax withholding purposes)6 to

report all those tips in one or more written statements furnished to the employer

on or before the tenth day of the following month. The employee is to furnish the

statements in the form and manner prescribed by the IRS. See § 31.6053-1(b) of

the Employment Tax Regulations.

B. No Tax on Overtime under Section

225

Section 225(a) provides for a deduction in an amount equal to the qualified

overtime compensation received by an

individual in a tax year that is included

on statements furnished to the individual

pursuant to section 6041(d)(4) or 6051(a)

(19). Section 225(b)(1) limits this deduc-

See also sections 3121(a)(12) and 3401(a)(16) of the Code (generally excluding from wages non-cash tips and tips under $20 per month), sections 3121(q) and 3401(f) (specifically including

tips in wages), and the regulations thereunder.

6

Bulletin No. 2025–50

767

December 8, 2025

tion to an amount not to exceed $12,500

per return ($25,000 in the case of a joint

return) in a tax year. Section 225(b)(2)

further limits the amount of the deduction based on a taxpayer’s MAGI, which

is a taxpayer’s adjusted gross income

for the tax year increased by any amount

excluded from gross income under section 911, section 931, or section 933. The

deduction phases out for taxpayers with

MAGI over $150,000 ($300,000 for joint

filers).

Section 225(c)(1) defines “qualified

overtime compensation” as overtime compensation paid to an individual required

under 29 USC § 207 that is in excess of

the regular rate at which the individual is

employed. The FLSA defines the regular

rate as including “all remuneration for

employment paid to, or on behalf of, the

employee”, subject to eight exclusions

established in 29 USC § 207(e). Part 778

of CFR title 29 contains the regulations

addressing the calculation of the regular

rate of pay for overtime compensation

under 29 USC § 207. Individuals covered7

by the FLSA generally must receive overtime pay for hours worked in excess of

40 in a workweek at a rate not less than

one and one-half times their regular rate

of pay. Generally, the amount of overtime

pay due to an individual is based on the

individual’s regular rate of pay8 and the

number of hours worked in a workweek.9

Certain individuals are statutorily exempt

from the FLSA’s overtime requirements.10

The Code and the FLSA use different definitions of “employee.” Therefore, it is

possible (but not common) for a non-employee under the Code to be covered as an

employee under the FLSA.

Under the FLSA, the overtime requirements are different for certain classes of

employers and employees (as defined in

the FLSA) under specific circumstances.

For example, 29 USC § 207(k) allows

overtime for public sector employees in

fire protection and law enforcement to

be based on a work period longer than

a standard 40-hour workweek in certain

circumstances, and subsection 29 USC

§ 207(j) allows hospitals and certain

residential care facilities to adopt agreements with their employees in certain

circumstances to pay one-and-one-half

times overtime rates for all hours worked

over eight in any workday or over 80 in

a 14-day work period, whichever is the

greater number of overtime hours. The

FLSA also permits employers to satisfy the overtime pay requirements with

(1) certain payments creditable under 29

USC § 207(h); (2) paid compensatory

time off in certain circumstances by a

public agency which is a State, a political subdivision of a State or an interstate

governmental agency under 29 USC

§ 207(o); and (3) alternative rate structures under 29 USC § 207(g).

Some employers or other service-recipients, on their own initiative, under a collective bargaining agreement with a labor

union, and/or under State law, may provide overtime pay that is not required by

29 USC § 207. For example, an employer

may choose to pay a higher overtime

amount than the one and one-half times

an individual’s regular rate of pay that is

generally required by the FLSA (e.g., the

employer may choose to pay double time

for hours worked over 40 in a workweek)

or they may choose to pay employees an

extra amount to work on weekends or

holidays.11 In such cases, while the additional one-half times portion required by

the FLSA may be qualified overtime, payments in excess of the FLSA-required premium are not.

Section 225(c)(2) of the Code excludes

from the definition of qualified overtime

compensation any qualified tips as defined

in section 224(d) of the Code.

Section 225(d) provides that no deduction is allowed under section 225 unless

the taxpayer includes on the return of tax

for the tax year such individual’s social

security number as defined in section

24(h)(7) of the Code.

Section 225(e) provides that if the taxpayer is a married individual (within the

meaning of section 7703), section 225

applies only if the taxpayer and the taxpayer’s spouse file a joint return for the tax

year. That is, the deduction is not available

for a taxpayer who is married and files

separately.

Section 70202(c) of the OBBBA added

to the information reporting requirements

of the Code for employers and certain

other payors for certain payments of qualified overtime compensation by:

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

section 6051 of the Code to provide that

an employer must include on the written

statement furnished to the employee the

total amount of qualified overtime compensation (as defined in section 225(c)),

(2) amending section 6041(a) to

require a payor to include on the information return filed with the IRS a separate accounting of any amount of qualified

overtime compensation (as defined in section 225(c)), and

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

section 6041 to provide that a payor is

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

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

Section 70202(h) of the OBBBA provides a transition rule for persons required

to file returns or furnish statements under

See U.S. Department of Labor (DOL), Wage and Hour Division (WHD), Fact Sheet #14: Coverage Under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.

dol.gov/agencies/whd/fact-sheets/14-flsa-coverage (last visited Oct. 28, 2025).

8

Earnings may be determined on a piece-rate, salary, commission, or some other basis, but in all such cases the overtime pay due must be computed on the basis of the average hourly rate

derived from such earnings. This rate is calculated by dividing the total pay for employment (except for the statutory exclusions) in any workweek by the total number of hours actually

worked. See DOL, WHD, Fact Sheet #56A: Overview of the Regular Rate of Pay Under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.dol.gov/agencies/whd/

fact-sheets/56a-regular-rate (last visited Oct. 28, 2025).

9

The FLSA applies on a workweek basis. An employee’s workweek is a fixed and regularly recurring period of 168 hours -- seven consecutive 24-hour periods. It need not coincide with the

calendar week and may begin on any day and at any hour of the day. See DOL, WHD, Fact Sheet #23: Overtime Pay Requirements of the FLSA | U.S. Department of Labor, https://www.dol.

gov/agencies/whd/fact-sheets/23-flsa-overtime-pay (last visited Oct. 28, 2025).

10

See, e.g., 29 USC 207(i), 213. Whether an individual is exempted under the FLSA is a fact-specific determination that depends on the individual’s occupation, work activities, and/or earnings. More information on exemptions from the FLSA is available at WHD Fact Sheets | U.S. Department of Labor, https://www.dol.gov/agencies/whd/fact-sheets (last visited Oct. 28, 2025).

11

Amounts for which the employer can and does claim a credit under 29 USC § 207(h) to satisfy 29 USC § 207(a) may constitute qualified overtime compensation (although the credit effectively offsets other qualified overtime compensation). Individuals may consider requesting information from their employer for purposes of calculating this amount. See also Fact Sheet #21:

Recordkeeping Requirements under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor regarding employer’s recordkeeping requirements, https://www.dol.gov/agencies/whd/

fact-sheets/21-flsa-recordkeeping (last visited Oct. 28, 2025).

7

December 8, 2025

768

Bulletin No. 2025–50

section 6051(a)(19), 6041(a), or 6041(d)

(4) of the Code for qualified overtime

compensation required to be reported for

periods before January 1, 2026. Under this

transition rule, those persons may approximate a separate accounting of amounts

designated as qualified overtime compensation by any reasonable method specified

by the Secretary.

III. GUIDANCE FOR TAX YEAR

2025

A. Qualified Tips

1. Determining the amount of qualified

tips received by employees

Under Section 224(a), an employee

may deduct an amount equal to the qualified tips received during the taxable year

and included on a statement furnished to

the employee (a Form W-2) or reported

by the employee on Form 4137, subject

to certain limitations. Section 6051(a)

(18) requires employers to include the

total amount of cash tips reported by

the employee to the employer and the

employee’s occupation described in section 224(d)(1) on the Form W-2. Only

cash tips separately accounted for on the

Form W-2 or reported on the Form 4137

are included in calculating the deduction.

As noted above, the 2025 Form W-2

has not been modified to account for the

new tips reporting requirements. As a

result, employers are not required to separately account for cash tips on the written statements furnished to individuals for

2025. Therefore, the Department of the

Treasury (Treasury Department) and the

IRS have determined that, for purposes

of satisfying the requirements of section

224(a) for tax year 2025, an employee

may (1) treat the section 224(a) requirement that qualified tips be included on a

statement furnished to the employee pursuant to section 6051(a)(18) as satisfied

if the employee’s cash tips are properly

reported on the employee’s Form W-2,

without regard to the requirements of sec-

tion 6051(a)(18) (to separately account

for the total amount of cash tips reported

by the employee under section 6053(a)),

and (2) calculate the amount of qualified

tips (subject to the other limitations and

requirements for qualified tips in section

224) for tax year 2025 as follows:

1) Use the total amount of social security tips reported in box 7 of the Form

W-2;

2) Use the total amount of tips reported

by the employee to the employer on

all Forms 4070, Employee’s Report of

Tips to Employer (or any similar substitute form used to monthly report

tips to the employer); or12

3) If an employer voluntarily chooses

to report the amount of an employee’s cash tips in box 14 of Form

W-2 (or on a separate statement), the

employee may use this amount in

determining the amount of qualified

tips for tax year 2025.

4) In addition to these three options,

employees may also include any

amount listed on line 4 of the 2025

Form 4137 filed with the employee’s

2025 income tax return (and included

as income on that return).

Although the occupation of an

employee receiving tips may not appear on

the Form W-2 furnished to the employee

in 2025, the employee is still responsible

for determining whether the tips received

by the employee were received in an

occupation that customarily and regularly received tips on or before December

31, 2024, as provided by the Secretary.13

See 2025 Form 1040 instructions. Some

employers may choose to provide information on an employee’s occupation or

other relevant information to employees

using box 14 of Form W-2, in which case

employees may rely on that information.

The Treasury Department and the IRS

recognize that the deduction for qualified

tips is a newly enacted provision and that

employees receiving tips are determining

their eligibility for the deduction for the

first time. The Treasury Department and

the IRS understand that it may be par-

ticularly difficult for employees to determine whether their tips were received in

the course of a specified service trade or

business, since section 224(d)(2) provides

that this determination turns on whether

the trade or business of their employer

in the course of which they receive tips

is a specified service trade or business.

Reporting by the employer regarding

the employer’s specified service trade or

business status would be helpful both to

assist employees in determining whether

they are eligible for the tips deduction and

to the IRS in administering section 224.

However, in order to implement such

information reporting, employers with

employees who receive tips will have to

make a determination as to whether their

trade or business in the course of which an

employee receives tips is a specified service trade or business, and many of these

employers, a significant number of which

are small businesses, have not previously

had to make such a determination. Given

these circumstances, the Treasury Department and the IRS believe that additional

guidance is needed to assist employees

and employers in determining whether an

employer’s trade or business is a specified

service trade or business. Employees and

employers will also need additional time

once guidance is issued to understand and

implement the guidance. Accordingly, in

the interest of sound tax administration,

there will be a transition period for purposes of IRS enforcement and administration with regard to the specified service

trade or business requirement. Specifically, until January 1 of the first calendar

year following the issuance of final regulations regarding the determination of

whether a trade or business is a specified

service trade or business for purposes

of section 224 and associated employer

information reporting, the IRS will treat

the employee as having received tips in

the course of a trade or business that is

not a specified service trade or business

if the employee is in an occupation that

customarily and regularly received tips on

or before December 31, 2024, as provided

If the combined total of the amounts in boxes 3 and 7 of the employee’s Form W-2 is equal to $176,100, the amount in box 7 may not include all the employee’s cash tips. In this instance,

the employee should consider reviewing the Forms 4070 they used to report tips to their employer.

13

Taxpayers claiming the deduction under section 224 on their tax return must demonstrate they meet the requirements of section 224 and establish that they are entitled to the deduction as

well as determine the appropriate amount of the deduction. Taxpayers must maintain adequate books and records to substantiate both their eligibility for and the amount of any deduction

claimed. See § 6001; Treas. Reg. § 1.6001-1; See generally Publication 17, pp. 17-18.

12

Bulletin No. 2025–50

769

December 8, 2025

by the Secretary. The Treasury Department and the IRS intend to issue proposed

regulations and solicit public comment on

these issues before publishing final regulations.

2. Determining the amount of qualified

tips for non-employees

Under section 224(a) an individual

may deduct an amount equal to the qualified tips received as a non-employee

during the taxable year and included on

a statement furnished to the individual (a

Form 1099-MISC, 1099-NEC, or 1099K), subject to certain limitations. Under

sections 6041(d)(3), 6041A(e)(3), and

6050W(f)(2), payors must include on

the applicable Form 1099 the portion of

(or a separate accounting of) payments

that have been reasonably designated as

cash tips and the occupation described

in section 224(d)(1) of the individual

receiving the tips. Only cash tips separately accounted for on the applicable

Form 1099 are included in calculating

the deduction.

However, for tax year 2025, a separate accounting of cash tips received by

a non-employee will not appear on the

Form 1099 furnished to the non-employee. Therefore, the Treasury Department and the IRS have determined that,

for purposes of satisfying the requirements of section 224(a) for tax year

2025, a non-employee may (1) treat the

section 224(a) requirement that qualified

tips be included on a statement furnished

pursuant to the requirements of sections

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

as satisfied if the non-employee’s cash

tips are included in the total amounts

reported as other income on the Form

1099-MISC, nonemployee compensation

on the Form 1099-NEC, or payment card/

third-party network transactions on the

Form 1099-K furnished to the non-employee, and (2) calculate the amount of

qualified tips (subject to the other limitations and requirements for qualified

tips under section 224) using earnings

statements or other documentation such

as receipts, point-of-sale system reports,

daily tip logs, third party settlement

14

organization records, or other documentary evidence that corroborates the calculation of the total amount of tips that

are qualified tips for tax year 2025. For

example, if a payor issues an earnings

statement to contractors who provide

services to the payor, the contractor may

use the amount designated as tips by the

payor on the earnings statement in determining the amount of qualified tips, provided the other limitations and requirements for qualified tips are satisfied, and

provided the contractor maintains a copy

of the earnings statement in accordance

with IRS recordkeeping requirements.14

Non-employee payees may also consult

with the payor regarding any available

information that may assist in determining and documenting the amount of qualified tips.

Although the occupation of a non-employee payee receiving tips will not

appear on a 2025 Form 1099 furnished

to the non-employee payee, the payee is

still responsible for determining whether

the tips received by the payee were

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

before December 31, 2024, as provided

by the Secretary

As with employees receiving tips, the

Treasury Department and the IRS recognize that most non-employees receiving

tips are determining their eligibility for

the deduction for the first time. Similarly, the Treasury Department and the

IRS understand that it may be difficult

for these non-employees to determine

whether their tips were received in connection with a specified service trade or

business and that additional guidance is

needed to assist non-employees in making

that determination. Accordingly, the transition relief described above with regard

to whether employee tips were received in

connection with a specified service trade

or business will also apply to non-employees.

3. Examples

The following examples are intended

to assist taxpayers in determining the

amount of qualified tips under section

224(d) and do not address other limitations on the deduction allowed under

section 224(a), including the overall limit

on deductions in section 224(b)(1), the

MAGI limit in section 224(b)(2), and

the social security number requirement

in section 224(e). See 2025 Form 1040

instructions for more details on how to

apply these limitations. In each example,

unless otherwise indicated, assume that

(1) the individual’s occupation is one that

customarily and regularly received tips

on or before December 31, 2024, and (2)

all other requirements for claiming the

deduction are satisfied.

Example 1. Employee A is a restaurant

server. The amount reported in A’s Form

W-2 box 7 is $18,000 of social security

tips. A did not report any additional tips on

Form 4137. A may use $18,000 in determining the amount of qualified tips for tax

year 2025.

Example 2. Employee B is a bartender.

During tax year 2025, B reports $20,000

in tips to B’s employer on Form 4070.

B’s 2025 Form W-2 reports $200,000 in

box 1, an amount in excess of the social

security wage base, and $15,000 in box

7. Additionally, B reports $4,000 of unreported tips on Form 4137, line 4, and

includes this amount in income on B’s

Form 1040. B may use either the $15,000

in box 7 of the Form W-2, or the $20,000

of tips reported to B’s employer on Forms

4070 in determining the amount of qualified tips for tax year 2025. Regardless

of the option chosen, B may also include

the $4,000 of unreported tips from Form

4137, line 4, in determining the amount of

qualified tips.

Example 3. Individual D is a self-employed travel guide who operates as a

sole proprietor. In 2025, Individual D

receives $7,000 in tips from customers paid through a third-party settlement organization as defined in section

6050W(b)(3). For tax year 2025, Individual D receives a Form 1099-K from an

online booking platform that is a thirdparty settlement organization as defined

in section 6050W(b)(3) showing $55,000

of total payments. The Form 1099-K does

not separately identify the tips. However, Individual D keeps a log of each

See id.

December 8, 2025

770

Bulletin No. 2025–50

tour that shows the date, customer, and

tip amount received. Because Individual

D has daily tip logs substantiating the

$7,000 tip amount, D may use the $7,000

tip amount in determining qualified tips

for tax year 2025.

B. Qualified Overtime Compensation

1. Determining whether an individual is

covered and nonexempt

Section 225(c) of the Code limits qualified overtime compensation to overtime

compensation in excess of the individual’s

regular rate that is required and paid under

29 USC § 207. In order for overtime to

be required under 29 USC § 207, it must,

among other requirements, be paid to an

individual who is both covered by and

not exempt from the FLSA (an FLSA-eligible employee).15 Thus, an individual

who is ineligible for Federal overtime (an

FLSA-ineligible employee) will generally not be paid overtime. However, some

FLSA-ineligible employees are eligible

for overtime under State law or are paid

premium rates for certain work for other

reasons. Overtime compensation paid to

FLSA-ineligible employees is not qualified overtime compensation within the

meaning of section 225(c) with respect to

such employment, regardless of applicable State law provisions or other circumstances causing these amounts to be paid.

Because employers and other payors

will not be required to separately account

for qualified overtime compensation, a

separate accounting of qualified overtime

compensation will not appear on written

statements furnished to individuals for

tax year 2025 absent an entry in box 14

of Form W-2 or a separate statement containing that information. Consequently,

individuals who are not furnished a separate accounting of qualified overtime

compensation in box 14 of Form W-2 (or

on a separate statement) must make a reasonable effort to determine whether they

are considered FLSA-eligible employees,

which may include asking their employers

or other service recipients about their status under the FLSA.

2. Determining the amount of qualified

overtime compensation

Under section 225(a), an individual

may deduct an amount equal to the qualified overtime compensation received

during the taxable year and included on

a statement furnished to the individual

(a Form W-2, Form 1099-NEC, or Form

1099-MISC). Under section 6051(a)(19),

employers must include on the Form W-2

the total amount of qualified overtime

compensation. Similarly, under section

6041(d)(4), payors must include on the

applicable Form 1099 the portion of payments that are qualified overtime compensation. For tax year 2025, a separate

accounting of qualified overtime compensation may not appear on the written

statement furnished to the individual.

Some employers may choose to report

the amount of qualified overtime compensation to employees using box 14 of

Form W-2 or on a separate statement, in

which case employees may treat the separate accounting requirement as satisfied

for purposes of their eligibility for the

deduction and use this amount for purposes of determining the deduction under

section 225. If the amount of qualified

overtime compensation is not provided by

the employer in box 14 of the Form W-2

or on a separate statement, the Treasury

Department and the IRS have determined

that, for tax year 2025, an FLSA-eligible employee may (1) treat the separate

accounting requirement as satisfied if the

qualified overtime compensation is properly reported on the individual’s Form

W-2, Form 1099-NEC, or From 1099MISC, without regard to the requirements

of section 6051(a)(19) (to separately

account for the amount of qualified overtime compensation), copies of which are

furnished to the individual, and (2) base

the determination of the amount of qualified overtime compensation (subject to

the other limitations and requirements for

qualified overtime compensation in section 225 of the Code) on other documentation such as earnings or pay statements,

invoices, or similar statements that support the determination, using a reasonable

method described below to determine the

amount of the qualified overtime compensation. Individuals who had multiple

employers during 2025 may use different

methods for each employer.

Individuals may use any of the following reasonable methods for purposes of

determining the amount of qualified overtime compensation under section 225(c)

for tax year 2025:

(A) If the individual is paid overtime

compensation at a rate of one and onehalf times the individual’s regular rate for

hours worked in excess of 40 hours in a

workweek, as generally required by 29

USC § 207(a), and receives a statement

covering the entire 2025 tax year that separately accounts for the overtime premium,

which is generally, the “half” portion of

the “one and one-half times” amount (the

FLSA Overtime Premium), the individual

may use that separate amount. See example 1.

(B) If the individual is paid overtime

compensation at a rate of one and onehalf times the individual’s regular rate for

hours worked in excess of 40 hours in a

workweek, as generally required by 29

USC § 207(a), and receives a statement

covering the entire 2025 tax year that does

not separately account for the FLSA Overtime Premium, but does include an entry

showing the aggregate dollar amount of

the FLSA Overtime Premium combined

with the portion of the individual’s regular

wages for the hours worked over 40 in a

workweek, the individual may use onethird of that aggregate dollar amount. See

example 2.

(C) If the individual is paid overtime

compensation at a rate in excess of one

and one-half times the individual’s regular

rate for hours worked in excess of 40 hours

in a workweek, as generally required by

29 USC § 207(a) (for example, two times

the individual’s regular rate), and receives

a statement covering the entire 2025 tax

year that separately accounts for the portion in excess of the employee’s regular

rate, the individual may multiply that

separate amount by an appropriate fraction to approximate the FLSA Overtime

Premium (for example, if overtime is paid

For more information on coverage and exemption under the FLSA, see WHD Fact Sheets | U.S. Department of Labor, https://www.dol.gov/agencies/whd/fact-sheets (last visited Oct. 28,

2025).

15

Bulletin No. 2025–50

771

December 8, 2025

at a rate of two times the regular rate, the

appropriate fraction is one-half) and use

the product. See example 3.

(D) If the individual is paid overtime

compensation at a rate in excess of one and

one-half times the individual’s regular rate

for hours worked in excess of 40 hours in

a workweek, as generally required by 29

USC § 207(a) (for example, two times the

individual’s regular rate), and receives a

statement that does not separately account

for the FLSA Overtime Premium but does

include an entry showing the aggregate

dollar amount of overtime compensation

at that higher rate for the hours worked

over 40 hours combined with the portion

of the individual’s regular wages for the

hours worked over 40 in a workweek covering the entire 2025 tax year, then the

individual may multiply the aggregate

dollar amount by an appropriately smaller

fraction (for example, if overtime is paid

at a rate of two times the regular rate, the

appropriate fraction is one-fourth) and use

the product. See example 4.

(E) If the method for determining the

amount of qualified overtime compensation described in paragraph (B) or (D)

above would result in underestimating the

employee’s qualified overtime compensation (for example, because the individual’s

regular rate is increased by a nondiscretionary bonus), the individual may adjust

the method described in paragraph (B) or

(D) to take the difference into account.

(F) If the individual is paid overtime

compensation at a rate described in

paragraphs (A)-(E) above but does not

receive any statement covering the entire

2025 tax year separately accounting for

the FLSA Overtime Premium, the aggregate dollar amount of FLSA overtime, or

the aggregate dollar amount of overtime

compensation paid at a higher rate, the

individual may use a reasonable method

that takes into account (1) the regular

rate under 29 USC § 207(e) paid to the

individual by the employer (or a reasonable approximation of this amount), and

(2) the individual’s hours of service in

excess of 40 hours in a workweek (or a

reasonable approximation if the individual does not have records of actual hours

of service) for purposes of determining

the amount of qualified overtime compensation under section 225(c). A reasonable method includes requesting information from the individual’s employer

and using the information provided by

the employer for purposes of calculating

the deduction.16

(G) If an individual’s employer satisfies the requirements under 29 USC

§ 207 by operation of another subsection

of the FLSA other than 29 USC § 207(a)

(including but not limited to public sector employees in fire protection and

law enforcement (29 USC § 207(k))17,

employees of a political subdivision

of a State or an interstate governmental agency who receives compensatory

time off in certain circumstances in lieu

of cash overtime compensation (29 USC

§ 207(o))18, and employees of hospitals or

certain residential care facilities (29 USC

§ 207(j)),19 the individual must compute

the amount of overtime compensation

by operation of the different overtime

rules used in the relevant provision of

29 USC § 207 that apply to the individual and may use any reasonable method

contained in this notice that takes those

alternative overtime rules into account.

See examples 5 and 6.

The Treasury Department and the IRS

are aware that documents such as earnings statements and pay stubs take a variety of forms, and employers and other

service-recipients provide overtime compensation in a variety of ways (including,

for example, combining State-required

and FLSA-required overtime). Individ-

uals may use the amounts reported as

overtime compensation on earnings statements, pay stubs, and other documentation provided by payors to calculate the

FLSA Overtime Premium for 2025. For

example, individuals may approximate

the amounts of FLSA Overtime Premium

by using overtime amounts reported on

a pay statement or similar document that

covers all wages paid in 2025. See Example 1. In all cases, individuals must maintain copies of any documents they rely

on in accordance with IRS recordkeeping

requirements.20

3. Examples

The following examples illustrate how

an individual may determine the amount

of qualified overtime compensation that

may be allowed as an income tax deduction under section 225 of the Code for tax

year 2025 and are not intended to address

the full universe of situations in which

overtime payments may be required

under the FLSA. These examples are

intended to assist a taxpayer in determining the amount of qualified overtime

under section 225(c) and do not address

other limitations on the deduction

allowed under section 225(a), including

the overall limit on deductions in section 224(b)(1), the MAGI limit in section

225(b)(2), and the social security number

requirement in section 225(d). See 2025

Form 1040 instructions for more details

on how to apply these limitations. The

examples assume: (1) each individual is

furnished a Form W-2 without a discrete

entry reporting qualified overtime in box

14 or on a separate statement; (2) each

individual is an FLSA-eligible employee;

and (3) all other requirements for claiming the deduction are satisfied.

Example 1. Individual A has access

to a payroll system that shows totals of

See Fact Sheet #21: Recordkeeping Requirements under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.dol.gov/agencies/whd/fact-sheets/21-flsa-recordkeeping (last visited Oct. 28, 2025) regarding employer’s recordkeeping requirements.

17

See Fact Sheet #8: Law Enforcement and Fire Protection Employees Under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.dol.gov/agencies/whd/

fact-sheets/8-flsa-police-firefighters (last visited Oct. 28, 2025).

18

Amounts described in 29 USC § 207(o) must be properly included on the employee’s Form W-2 to be considered qualified overtime compensation. Accordingly, individuals receiving

compensatory time under 29 USC § 207(o)(3)(B) in satisfaction of overtime amounts due under 29 USC § 207 may take the overtime amount into account for purposes of section 225 only

in the year the compensatory time is paid.

19

See Fact Sheet #33: Residential Care Facilities (Group Homes) Under the Fair Labor Standards Act | U.S. Department of Labor, https://www.dol.gov/agencies/whd/fact-sheets/33-flsagroup-homes (last visited Oct. 28, 2025).

20

Taxpayers claiming the deduction under section 225 on their tax return must demonstrate they meet the requirements of section 225 and establish that they are entitled to the deduction as

well as determine the appropriate amount of the deduction. See also § 6001; Treas. Reg. § 1.6001-1; see generally Publication 17, pp. 17-18.

16

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Bulletin No. 2025–50

amounts paid to Individual A in 2025,

including the FLSA Overtime Premium

paid during 2025. In 2025, Individual

A is last paid wages on December 22,

2025, for the payroll period beginning

on November 30, 2025, and ending on

December 13, 2025.21 The payroll system

shows $5,000 as the “overtime premium”

that Individual A was paid during 2025.

For purposes of determining the amount

of qualified overtime compensation

received in tax year 2025, Individual A

may include $5,000 (the FLSA Overtime

Premium).

Example 2. Assume the same facts

as in example 1 except that Individual

A’s pay stub, shows a total “overtime”

amount of $15,000 (which is the FLSA

Overtime Premium combined with the

portion of the individual’s regular wages

for the hours worked over 40 in a workweek). For purposes of determining the

amount of qualified overtime compensation received in tax year 2025, the individual may include $5,000 (the FLSA

Overtime Premium, computed by dividing $15,000 by 3).

Example 3. Individual B’s employer

has a practice of paying overtime at a

rate of two times an employee’s regular rate of pay and Individual B was

paid $20,000 in overtime pay under that

practice, although 29 USC § 207 only

requires Individual B’s employer to pay

at one and one-half times the employee’s

regular rate. Individual B’s last pay stub

for 2025 shows “overtime premium” of

$10,000 paid in 2025 (which is Individual B’s overtime premium paid at a rate

of two times the individual’s regular

rate). For purposes of determining the

amount of qualified overtime compensation received in tax year 2025, Individual

B may include $5,000 ($10,000 divided

by 2).

Example 4. Assume the same facts as

in example 3 except that Individual B’s

pay stub shows a total “overtime” amount

of $20,000 (which is Individual B’s overtime premium paid at a rate of two times

the individual’s regular rate of pay com-

bined with the portion of the individual’s

regular wages for the hours worked over

40 in a workweek). For purposes of determining the amount of qualified overtime

compensation received in tax year 2025,

Individual B may include $5,000 (the

FLSA Overtime Premium, computed by

dividing $20,000 by 4).

Example 5. Individual C works in law

enforcement and is paid $15,000 of total

annual overtime pay on a “work period”

basis of 14 days that complies with section 207(k) of the FLSA.22 For purposes of

determining the amount of qualified overtime compensation received in tax year

2025, Individual C may include $5,000

($15,000 divided by 3).

Example 6. Individual D works for

a State or local government agency that

gives compensatory time at a rate of one

and one-half hours for each overtime hour

worked under 29 USC 207(o). In 2025,

Individual D was paid wages of $4,500

with respect to compensatory time off

taken in accordance with section 207(o).

For purposes of determining the amount

of qualified overtime compensation

received in tax year 2025, Individual D

may include $1,500, one-third of these

wages for purposes of determining qualified overtime compensation under section

225(c).

to substantiate their tax deductions for

tax year 2025. These records are considered general tax records under 26 CFR

6001-1. General tax records are already

approved by OMB under 1545-0074.

Additionally, taxpayers report the deductions using Form 1040, which is already

approved by OMB under 1545-0074.

This Notice is not changing the already

approved OMB collection.

The Notice mentions new information

collection requirements for various forms

in tax year 2026. These collections will

be submitted for OMB approval when the

forms and their instructions are updated

for tax year 2026.

IV. Paperwork Reduction Act

Request for Comments

on Individual Tax Credit

for Qualified Contributions

to Scholarship Granting

Organizations

The Paperwork Reduction Act of 1995

(44 USC 3501-3520) (PRA) generally

requires that a Federal agency obtain the

approval of the Office of Management and

Budget (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 Office of Management

and Budget.

This Notice mentions collection

requirements for taxpayers to keep records

V. APPLICABILITY DATE

This notice applies to the 2025 tax year.

VI. DRAFTING INFORMATION

The principal author of this notice is

the Office of Associate Chief Counsel

(Employee Benefits, Exempt Organizations, and Employment Taxes). For further information regarding this notice,

call (202) 317-6000 (not a toll-free number).

Notice 2025-70

SECTION 1. PURPOSE

The Department of the Treasury

(Treasury Department) and the Internal

Revenue Service (IRS) intend to issue

proposed regulations (forthcoming proposed regulations) to implement new

§ 25F of the Internal Revenue Code

The employee’s earning statement relating to the payroll period beginning on December 14, 2025, and ending on December 27, 2025, shows amounts that are not actually paid until January

6, 2026. Thus, it would not include any FLSA Overtime Premium paid in 2025.

22

See Fact Sheet #8: Law Enforcement and Fire Protection Employees Under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.dol.gov/agencies/whd/

fact-sheets/8-flsa-police-firefighters (last visited Oct. 28, 2025).

21

Bulletin No. 2025–50

773

December 8, 2025

(Code),1 as added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4,

2025), commonly known as the One,

Big, Beautiful Bill Act (OBBBA). Section 25F provides a new credit for an

individual’s qualified contribution to

a scholarship granting organization

(as defined in § 25F(c)(5)) (SGO) that

provides qualified elementary and secondary scholarships. In anticipation of

issuing the forthcoming proposed regulations, this notice requests comments

regarding issues arising under § 25F

that should be addressed in guidance,

emphasizing issues on which guidance is most quickly needed, including

issues relating to the annual certification by a State2 and SGO requirements.

Comments detailing factual situations

that differ from those addressed in this

notice, and the application of the statute to these factual situations, would be

especially helpful in the development of

the forthcoming proposed regulations.

SECTION 2. BACKGROUND

.01 Overview of § 25F Credit. Section

25F provides a nonrefundable income tax

credit (§ 25F credit) allowable to a taxpayer for qualified contributions to SGOs

made by an individual who is a citizen or

resident of the United States (within the

meaning of § 7701(a)(9)). Section 25F(c)

(3) defines a “qualified contribution” as a

charitable contribution of cash to an SGO

that uses the contribution to fund scholarships for eligible students (as defined

in § 25F(c)(2)) solely within the State in

which the organization is listed pursuant

to § 25F(g). In order for a contribution

made by a taxpayer to an SGO in a State

to be a qualified contribution eligible for

a § 25F credit, the State must have voluntarily elected to participate under § 25F and

must have identified the SGO as one that

satisfies the requirements of § 25F(c)(5) for

the applicable calendar year in accordance

with § 25F(g). See sections 2.04 and 3 of

this notice regarding State lists and certifications necessary for State elections.

.02 Amount of § 25F Credit. Section

25F(a) provides that, in the case of an

1

2

individual who is a citizen or resident of

the United States (within the meaning of

§ 7701(a)(9)), there is allowed as a credit

against the tax imposed by chapter 1 of

the Code for the taxable year an amount

equal to the aggregate amount of qualified contributions made by the taxpayer

during the taxable year. The amount of

the § 25F credit allowable to a taxpayer

for a taxable year is subject to two limitations in § 25F(b). First, § 25F(b)(1) provides that the amount of the § 25F credit

allowed to any taxpayer for any taxable

year may not exceed $1,700. Second,

§ 25F(b)(2) provides that the amount

allowed as a § 25F credit for a taxable

year is reduced by the amount allowed

as a credit on any State tax return of the

taxpayer for qualified contributions made

by the taxpayer during the taxable year.

In addition, § 25F(e) prohibits a double

benefit to a taxpayer by providing that

any qualified contribution for which a

§ 25F credit is allowed cannot be taken

into account as a charitable contribution

for purposes of § 170.

Section 25F(f) provides for the carryforward of unused § 25F credit amounts.

Section 25F(f)(1) provides that, if the

§ 25F credit allowable for any taxable year

exceeds the limitation imposed by § 26(a)

for such taxable year reduced by the sum

of the credits allowable under §§ 21, 22,

24, 25, 25A, 25B, 25C, 25E, and 26, such

excess is carried to the succeeding taxable year and added to the credit allowable under § 25F(a) for such taxable year.

In addition, § 25F(f)(2) provides that

no credit may be carried forward under

§ 25F(f) to any taxable year following the

fifth taxable year after the taxable year in

which the credit arose. For this purpose,

§ 25F(f) provides that § 25F credits are

treated as used on a first-in, first-out basis.

.03 SGO Requirements.

(1) Section 25F(c)(5). An organization

can qualify as an SGO only if it satisfies

each requirement set forth in § 25F(c)(5).

The SGO requirements under § 25F(c)(5)

are that the organization must:

(a) be described in § 501(c)(3), be

exempt from tax under § 501(a), and not

be a private foundation;

(b) prevent the co-mingling of qualified contributions with other amounts by

maintaining one or more separate accounts

exclusively for qualified contributions;

(c) satisfy each of the requirements of

§ 25F(d); and

(d) be included on the list submitted

for the applicable covered State under

§ 25F(g) for the applicable year. For this

purpose, § 25F(c)(1) defines a “covered

State” as “one of the States, or the District

of Columbia,” that, for a calendar year,

voluntarily elects to participate under

§ 25F and to identify the SGOs located in

the State, in accordance with § 25F(g).

(2) Section 25F(d). The requirements

in § 25F(d) that an SGO must satisfy are

as follows:

(a) The organization must provide

scholarships to 10 or more students who

do not all attend the same school.

(b) The organization cannot spend less

than 90 percent of its income on scholarships for eligible students.

(c) The organization cannot provide

scholarships for any expenses other than

qualified elementary or secondary education expenses. Section 25F(c)(4) defines

a qualified elementary or secondary education expense as any expense described

in § 530(b)(3)(A) (relating to Coverdell

education savings accounts) of an eligible

student. Section 530(b)(3)(A) identifies

these expenses to include certain expenses

incurred at, required by, or provided by a

public, private, or religious school.

(d) The organization must provide

scholarships to eligible students with a

priority for:

(i) students awarded a scholarship the

previous school year, and thereafter, and

(ii) any eligible students who have a

sibling who was awarded a scholarship

from such organization.

(e) The organization cannot earmark or

set aside contributions for scholarships on

behalf of any particular student.

(f) The organization must:

(i) verify the annual household income

and family size of eligible students who

apply for scholarships to ensure such students meet the area median gross income

requirement of § 25F(c)(2)(A), and

Unless otherwise provided, all "section" or "§" references are to sections of the Code.

Pursuant to § 25F(c)(1), for purposes of this notice, the term “State” means one of the 50 States or the District of Columbia.

December 8, 2025

774

Bulletin No. 2025–50

(ii) limit the awarding of scholarships

to eligible students who are members of

a household for which the income does

not exceed the amount established under

§ 25F(c)(2)(A).

(g) The organization cannot award a

scholarship to any disqualified person,

which § 25F(d)(2)(B) provides is determined pursuant to rules similar to the rules

of § 4946 (relating to private foundations).

.04 State lists and certifications. Section 25F(g) provides that:

(1) Not later than January 1 of each

calendar year (or, with respect to the 2027

calendar year, as early as practicable), a

State that voluntarily elects to participate

under § 25F must provide to the Secretary

of the Treasury or the Secretary’s delegate

(Secretary) a list of the SGOs that meet

the requirements described in § 25F(c)(5)

and are located in the State (State list).

(2) The election under § 25F(g) must

be made by the Governor of the State or

by such other individual, agency, or entity

as is designated under State law to make

such elections on behalf of the State with

respect to Federal tax benefits.

(3) Each State list must include a certification that the individual, agency, or

entity submitting such list on behalf of

the State has the authority to perform this

function.

.05 Regulations and guidance. Section

25F(h) directs the Secretary to issue such

regulations or other guidance as the Secretary determines necessary to carry out the

purposes of § 25F, including regulations

or other guidance:

(1) providing for enforcement of the

requirements under § 25F(d) and (g), and

(2) with respect to recordkeeping or

information reporting for purposes of

administering the requirements of § 25F.

SECTION 3. REQUEST FOR

COMMENTS ON STATE LISTS AND

CERTIFICATIONS

.01 Overview. Sections 3.02 and 3.03

of this notice describe the certification

process currently envisioned by the Treasury Department and the IRS for covered

States to elect to participate under § 25F

in accordance with § 25F(g). The Treasury

Department and the IRS request comments

on all aspects of this certification process.

Sections 3.04 through 3.06 of this notice

Bulletin No. 2025–50

set forth specific questions regarding particular aspects of the State certification

process on which the Treasury Department and the IRS request comments.

.02 State election and list. Section

25F(g) provides that a State that voluntarily elects to participate under § 25F must

provide to the Secretary a list of the SGOs

that meet the requirements described in

§ 25F(c)(5) and are located in the State.

Thus, the election by a State to participate under § 25F (State election) may be

made prior to or contemporaneously with

the submission of the State’s list of those

organizations. The Treasury Department

and the IRS anticipate that the forthcoming proposed regulations would require

each State electing to participate under

§ 25F for the 2027 calendar year to submit to the IRS, by a specified date before

January 1, 2027, the State’s list of organizations located in that State meeting the

requirements of § 25F(c)(5) for the 2027

calendar year along with the State’s certification under § 25F(g)(2). The forthcoming proposed regulations would include

a similar requirement for submission of

an annual list and certification from each

electing State for subsequent years.

However, the Treasury Department and

the IRS understand that potential SGOs

may need sufficient time to prepare for the

commencement of this new credit in 2027

and assurance that the State in which they

are located will elect to participate under

§ 25F. Accordingly, the Treasury Department and the IRS intend to issue future

published guidance providing States with

the option to submit, beginning early

in 2026, the State election to participate

under § 25F for calendar year 2027.

The Treasury Department and the IRS

anticipate that the forthcoming proposed

regulations would require the State to

electronically submit the State election,

the State list and certification to the IRS,

as an electronic submission is more efficient and timelier than paper submissions.

The Treasury Department and the IRS

anticipate that the forthcoming proposed

regulations would provide, consistent with

§ 25F(g)(1)(A), that the State list must

include all organizations located in the

State that have requested to be designated

as an SGO and that meet the § 25F(c)

(5) statutory requirements. However, the

Treasury Department and the IRS do not

775

anticipate that the forthcoming proposed

regulations would prohibit an SGO from

itself imposing additional governing provisions beyond the requirements imposed

by § 25F(c)(5) unless such a provision

would conflict with the ability of the SGO

to satisfy such requirements.

The Treasury Department and the IRS

anticipate that the forthcoming proposed

regulations would provide that, if a donor

makes a contribution to an organization

that, at the time of the contribution, is on

the list of organizations for that taxable

year, the donor would generally be treated

as having made a contribution to an SGO

for purposes of § 25F. However, if the

recipient organization is later determined

not to qualify as an SGO, the IRS would

not be precluded from disallowing a § 25F

credit for any contribution made to that

organization if the donor either was aware

of, or was responsible to any extent for,

the activities or deficiencies that gave rise

to the organization’s eventual loss of SGO

status.

.03 Contents of State certification.

The Treasury Department and the IRS

interpret § 25F(g) as requiring each

covered State to verify that each organization on the State’s list satisfies all

of the requirements of § 25F(c)(5). The

Treasury Department and the IRS also

understand that organizations seeking to

satisfy the requirements to be an SGO

for purposes of § 25F may be structured

and/or operated in different ways. Specifically, some organizations may operate

entirely within a single State, and some

may raise funds and award scholarships

to eligible students in a region consisting

of multiple States. The forthcoming proposed regulations would require covered

States to verify information about each of

these types of organizations that qualify

as an SGO. Reliance by a covered State

on self-certifications by SGOs would not

be sufficient for this purpose. The Treasury Department and the IRS anticipate

that the annual certification of the State’s

list that would be required of each covered State would include certification by

the individual who, or an authorized representative of the agency or entity that,

has authority to perform this function on

behalf of the State, under penalties of

perjury, of at least the following information:

December 8, 2025

(1) Identification and contact information: The name, IRS employer identification number (EIN), address, and telephone

number of each organization on the State

list; the name, title and contact information of the covered State’s point of contact

for this credit; and the identification of

each organization as a State or multistate

organization.

(2) Federal tax-exempt status: That

each organization on the State list is currently described in § 501(c)(3) and exempt

from tax pursuant to § 501(a), and is not a

private foundation, as defined in § 509.

(3) No co-mingling: That each organization on the State list maintains one

or more separate accounts exclusively

for qualified contributions, as that term

is defined in § 25F(c)(3), to prevent the

co-mingling of qualified contributions

with other amounts.

(4) Information regarding single-State

organizations: If the organization is

located solely in one State (single-State

organization), then, in accordance with

§ 25F and any regulations thereunder,

certification that the single-State organization:

(a) Provides scholarships to ten (10) or

more students in that State who do not all

attend the same school;

(b) Spends not less than ninety (90)

percent of its income on scholarships for

eligible students, as that term is defined in

§ 25F(c)(2);

(c) Does not provide scholarships for

any expenses other than qualified elementary or secondary education expenses, as

that term is defined in § 25F(c)(4);

(d) Selects students receiving scholarships only from among eligible students

who reside in that State, and only from

among eligible students who are members

of a household for which the income does

not exceed the amount established under

§ 25F(c)(2)(A), and by giving priority first

to those who received a scholarship from

the organization for the previous school

year, and then those who have a sibling

who received a scholarship from the organization for the previous school year;

(e) Does not earmark or set aside contributions for scholarships on behalf of

any particular student; and

(f) Does not award a scholarship to any

disqualified person, as defined for purposes of § 25F(d)(2).

December 8, 2025

(5) Information regarding multistate

organizations: If the organization is not

solely located in one State and grants

scholarships in more than one State (multistate organization), then certification that

the multistate organization:

(a) Funds scholarships to eligible students in the State providing the certification;

(b) Requires donors to designate the

State, on whose State list the organization

is named, in which their qualified contribution is to be used;

(c) Tracks and matches qualifying contributions that are designated by the donor

to be spent within the State with scholarships to eligible students within the State;

and

(d) Satisfies each of the requirements

for single-State organizations in the State,

as set forth in section 3.03(4) of this notice.

(6) State policies and procedures: That

the State has adopted, and is complying

with, policies and procedures designed to

enable the State to make its own independent determination that each organization

on the State list is required by the organization’s organizational documents or bylaws

to satisfy, and is operating in a manner

that satisfies, each of the requirements of

§ 25F(c)(5), as provided in section 2.03

of this Notice. With respect to a State’s

independent determination that an organization is described in § 501(c)(3) and

exempt from tax under § 501(a), and is not

a private foundation, policies and procedures that include, for example, consideration of whether the organization is identified as an exempt organization with 501(c)

(3) status (and not a private foundation) in

the EO BMF Extract available on irs.gov

(https://www.irs.gov/charities-non-profits/exempt-organizations-business-master-file-extract-eo-bmf) would be sufficient for purposes of § 25F(c)(5)(A).

(7) Notification to the IRS of removal

from State list: That the State will

promptly notify the IRS of any determination by the State that an organization listed

on its State list is being removed from its

State list and the effective date of removal.

(8) Applicable State tax credits: If

applicable, that, for the calendar year for

which the State list is submitted to the

IRS, the State offers a tax credit for qualified contributions pursuant to State law,

and a description of that credit including

776

relevant State statutes, regulations, and

other authoritative guidance.

(9) Authority to act on behalf of State:

That the individual, agency, or entity submitting the election, the list, and these certifications on behalf of the State has the

authority to perform this function.

.04 Request for comments on State

policies and procedures. Section 25F(g)

requires that a State that voluntarily elects

to participate under § 25F must provide to

the Secretary a list of the SGOs “that meet

the requirements” described in § 25F(c)

(5) and are located in the State. The Treasury Department and the IRS anticipate

that States will be required to have implemented, and to comply with, various procedures to verify that the required information submitted by the covered State is

accurate and complete.

(1) What types of uniform policies,

procedures, recordkeeping or other

requirements would be reasonable to help

ensure that a State will be able to reliably

verify that each SGO meets each of the

requirements in § 25F(c)(5)?

(2) For States already participating

in State-level programs similar to § 25F,

how do those States determine that organizations are meeting the applicable State

requirements?

.05 Request for comments on “located

in the State.” Section 25F(g)(1)(A)

requires the State list to identify the SGOs

that meet the requirements described in

§ 25F(c)(5) and are “located in the State.”

(1) How should “located” be defined

for this purpose? Should organizations

that are authorized to operate in the State

be considered located in the State?

(2) For States that currently offer tax

credits for contributions to scholarship

awarding entities, are there jurisdictional

or other similar nexus requirements that

an organization must satisfy in order for

contributions to the organization to qualify for the State tax credit?

.06 Request for comments on State tax

credit offset. Section 25F(b)(2) requires

that the amount of a § 25F credit allowed

under § 25F must be reduced by the amount

allowed as a State tax credit for qualified

contributions made by the taxpayer during

the taxable year. What information can a

State provide to the IRS, consistent with

applicable State law, to ensure taxpayer

compliance with this requirement?

Bulletin No. 2025–50

SECTION 4. REQUEST FOR

COMMENTS REGARDING SGO

REQUIREMENTS

.01 Request for comments regarding

income. Section 25F(d)(1)(B) requires an

SGO to spend “not less than 90 percent of

the income of the organization on scholarships for eligible students.” The Treasury

Department and the IRS anticipate that the

forthcoming proposed regulations would

provide that the income of the organization includes all income of the organization, including unrelated business income,

and is not limited to qualified contributions segregated in the separate account(s)

described in § 25F(c)(5)(B).

(1) Does this interpretation of income

pose practical challenges for SGOs? If so,

what alternative interpretation would be

allowed under the statute, and why would

any alternative interpretation be a superior

reading of the statute?

(2) Should forthcoming proposed regulations address potential fluctuations in

income and expenses, such as potential

start-up costs to the organization in its

first year of operation or the smoothing of

this calculation over a certain number of

years?

.02 Request for comments on multistate

organizations. The Treasury Department

and the IRS are aware that organizations

may fundraise and award scholarships in

more than one State (see section 3.03(5)

of this notice). However, § 25F(c)(3)

requires that a qualifying contribution

must be used to fund scholarships for eligible students “solely within the State in

which the organization is listed.”

(1) As noted above, the Treasury

Department and the IRS anticipate that the

forthcoming proposed regulations would

require a multistate organization to ask

donors to designate the State in which the

donor intends the qualified contribution to

be used. If a donor does not designate a

particular State, what rules should apply?

(2) For a multistate organization,

should the requirement that it provide

scholarships to 10 or more students who

do not all attend the same school apply

with respect to scholarships provided by

the organization in all states in the aggregate or on a state-by-state basis?

(3) For a multistate organization,

should the requirement that it spend not

Bulletin No. 2025–50

less than 90 percent of its income on

scholarships for eligible students apply

with respect to the organization’s operations in all states in the aggregate or on

a state-by-state basis? If the latter, how

should the organization’s income be allocated for this purpose?

(4) For a multistate organization,

should satisfaction of the following

requirements be analyzed with respect to

all states on whose State list it appears, or

on a state-by-state basis:

(a) does not provide scholarships for

any expenses other than qualified elementary or secondary education expenses,

(b) provides a scholarship to eligible students with a priority for students

awarded a scholarship the previous school

year, and then for any eligible students

who have a sibling who was awarded a

scholarship from such organization,

(c) does not earmark or set aside contributions for scholarships on behalf of any

particular student,

(d) verifies the annual household

income and family size of eligible students who apply for scholarships to ensure

the annual household income of such students does not exceed 300 percent of area

median gross income (as such term is

used in § 42), and limits the awarding of

scholarships to eligible students who are

a member of a household whose income

does not exceed such income limit, and

(e) does not engage in self-dealing?

.03 Request for comments on other

fact patterns. The Treasury Department

and the IRS are aware that there currently

are organizations operating in other ways

or under other fact patterns that may

wish to qualify as SGOs. For example,

there currently are “fundraising organizations” raising funds to provide scholarships that, instead of awarding scholarships themselves, make distributions to

other organizations that may be defined

as SGOs. In addition, there are organizations that operate in States with State

tax credits similar to the § 25F credit that

may want to qualify as SGOs described in

§ 25F(c)(5) but currently have structures

or operations not expressly addressed in

this notice. The Treasury Department and

the IRS request additional information

regarding such organizations and whether

they could satisfy all of the requirements

of § 25F(c)(5).

777

.04 Request for comments on definition

of disqualified person. Section 25F(d)(2)

prohibits an SGO from awarding a scholarship to any “disqualified person” and

provides that, for this purpose, a disqualified person is determined pursuant to rules

similar to the rules of § 4946 (relating to

private foundations). Section 4946 provides that “substantial contributors” to a

private foundation are considered disqualified persons. For purposes of § 4946, a

“substantial contributor” includes any

person that made contributions during the

taxable year in the aggregate of at least

$5,000, if that amount is more than 2 percent of the total contributions the foundation or organization received from its

inception through the end of the taxable

year in which that person’s contributions

were received.

(1) The Treasury Department and the

IRS are considering whether the forthcoming proposed regulations should

propose to modify this definition, for

purposes of § 25F, to state that the term

“substantial contributor,” with respect

to an SGO, means any person who contributed an aggregate amount of more

than 2 percent of the total contributions

received by the SGO from its inception

through the end of the taxable year in

which that person’s contributions were

received. The Treasury Department and

the IRS request comments on this potential definition and whether any alternative interpretation would be a superior

reading of the statute.

(2) The Treasury Department and the

IRS expect that the forthcoming proposed

regulations would provide that an individual who is a member of the SGO’s selection committee, or part of the immediate

family of such a member, is a disqualified

person with respect to that SGO. Under

what circumstances should such an individual not be considered a disqualified

person for purposes of the § 25F credit?

.05 Request for comments on reporting

and recordkeeping requirements.

(1) Pursuant to the authority provided

by § 25F(h), the Treasury Department

and the IRS anticipate issuing guidance

that would require organizations seeking

to satisfy the requirements to be an SGO

to report certain information to the IRS

and to retain certain records to ensure

that the requirements of § 25F are met.

December 8, 2025

This required reporting and recordkeeping may include the following information:

(a) Information on an IRS form or

schedule pertaining to § 25F to be filed

annually by the organization with the

IRS;

(b) Information on each qualified contribution received by the organization,

including the donor’s taxpayer identification number, to facilitate comparison with the donor’s Federal tax credit

claimed; and

(c) Information on each scholarship

recipient awarded a scholarship by the

organization, to ensure that each recipient

meets the requirements of § 25F.

(2) These reporting requirements

would apply to charitable organizations

seeking to satisfy the requirements to

be an SGO that may not normally be

required under § 6033 to file an annual

return with the IRS. These reporting

requirements also would apply to subordinate organizations recognized as

tax-exempt under § 501(c)(3) on the

basis of a group exemption letter issued

to a central organization.

(a) How should reporting and recordkeeping requirements be designed to

balance the IRS’s need for information

for Federal income tax administration

purposes with the burden imposed on the

reporting organizations?

(b) Is there any current reporting by

such organizations of such information

to States, and, if so, what is reported and

what form does the reporting take?

(c) Under what circumstances, if any,

would relief from these requirements be

justified?

(3) Section 25F(c)(2)(A) defines an

“eligible student” as an individual who is

a member of a household with an income

that, for the calendar year prior to the

date of the application for a scholarship,

is not greater than 300 percent of the area

median gross income (as such term is used

in § 42). How should an SGO verify this

information? For example, should the

SGO require the eligible student to provide a copy of the most recently filed Federal income tax return (Form 1040, U.S.

Individual Income Tax Return) that was

filed for each member of the household

with a Federal tax return filing require-

December 8, 2025

ment? Should additional information be

required? If any member of the household

of the eligible student did not have a Federal return filing requirement, how should

the SGO verify such household member’s

income?

(4) Section 25F(c)(5)(B) prohibits an

SGO from co-mingling qualified contributions with other amounts and requires

that it maintain one or more separate

accounts exclusively for qualified contributions.

(a) At the time of a donation, what kind

of information would allow the SGO to

determine that the cash is intended to be

a qualified contribution entitling the donor

to a credit under § 25F that thus needs to

be segregated?

(b) Should the donor be required to

provide this information to the SGO in

order to take the § 25F credit?

(c) Should the SGO be required to provide the donor with written substantiation

in order for the donor to take the § 25F

credit?

(5) What information should an SGO

be required to provide to its donor?

(a) Should the SGO be required to

inform the donor that only the first $1,700

of qualified contributions to SGOs may

entitle the donor to a § 25F credit?

(b) Should the SGO be required to

inform the donor that additional amounts

over the first $1,700 may qualify for a

Federal tax deduction under § 170 (but

that any qualified contribution for which

a § 25F credit is allowed may not be taken

into account as a charitable contribution

for purposes of § 170)?

(c) Should the SGO be required to

inform the donor that any § 25F credit

must be reduced by any credit on any

State tax return of the taxpayer for qualified contributions made by the taxpayer

during the taxable year. If so, when should

the SGO be required to inform the donor

of the requirement to reduce the § 25F

credit by any such State credit?

(6) For a multistate organization (see

sections 3.03(5) and 4.02 of this notice),

what types of reporting and recordkeeping requirements could allow the organization to demonstrate that it satisfies, for

each State on whose State list it appears,

the requirements of § 25F(c)(5), including

that at least 90 percent of its income allo-

778

cated to a State is spent on scholarships

within that State?

(7) For multistate organizations, if

such an organization could be eligible

to be listed on one or more State lists as

an SGO, what recordkeeping or other

requirements could allow such an organization to establish that contributions to it

qualify as contributions to an SGO defined

in § 25F(c)(5)?

SECTION 5. SUBMISSION OF

COMMENTS

.01 Written comments should be submitted on or before December 26, 2025.

Consideration will be given, however,

to any written comment submitted after

December 26, 2025, if such consideration

will not delay the issuance of guidance.

The subject line for the comments should

include a reference to Notice 2025-70.

Comments may be submitted in one of

two ways:

(1) Electronically via the Federal

eRulemaking Portal at www.regulations.

gov (type IRS-2025-0466 in the search

field on the regulations.gov homepage to

find this notice and submit comments).

(2) Alternatively, by mail to: Internal

Revenue Service, CC:PA:01:PR (Notice

2025-70), Room 5503, P.O. Box 7604,

Ben Franklin Station, Washington, DC

20044.

.02 All commenters are strongly

encouraged to submit comments electronically. The Treasury Department and the

IRS will publish for public availability

any comment submitted electronically, or

on paper, to its public docket on www.regulations.gov.

SECTION 6. DRAFTING

INFORMATION

The principal author of this notice

is Edward Waters of the Office of the

Associate Chief Counsel (Income Tax &

Accounting). However, other personnel

from the Treasury Department and the

IRS participated in its development. For

further information regarding this notice,

please contact Mr. Waters at (202) 3177009 (not a toll-free number).

Bulletin No. 2025–50

Interim Guidance

Regarding Interest on

Loans Secured by Rural or

Agricultural Real Property

under Section 139L of the

Internal Revenue Code

Notice 2025-71

SECTION 1. OVERVIEW

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service

(IRS) intend to publish a notice of proposed rulemaking (forthcoming proposed

regulations) addressing the exclusion

of interest on loans secured by rural or

agricultural real property under § 139L

of the Internal Revenue Code (Code).1

Section 139L was added to the Code by

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

2025), commonly known as the One, Big,

Beautiful Bill Act (OBBBA). The Treasury Department and the IRS intend to

propose rules in the forthcoming proposed

regulations similar to the interim guidance

provided in section 3 of this notice. Taxpayers may rely on the interim guidance

in section 3 of this notice in accordance

with section 4 of this notice. Section 5 of

this notice requests comments on issues

addressed in this notice and certain additional issues, as well as other issues on

which taxpayers believe guidance would

be helpful.

SECTION 2. BACKGROUND

.01 Partial exclusion for certain interest income.

(1) Overview. Section 139L(a)

excludes from gross income 25 percent of

the interest received by a qualified lender

on any qualified real estate loan.

(2) Qualified lender. For purposes of

§ 139L, § 139L(b) defines the term qualified lender to mean-(a) any bank or savings association the

deposits of which are insured under the

Federal Deposit Insurance Act (12 U.S.C.

1811 et seq.);

1

(b) any State- or federally-regulated

insurance company;

(c) any entity wholly owned, directly or

indirectly, by a company that is treated as

a bank holding company for purposes of

section 8 of the International Banking Act

of 1978 (12 U.S.C. 3106) if such entity

is organized, incorporated, or established

under the laws of the United States or

any State, and the principal place of business of such entity is in the United States

(including any territory of the United

States);

(d) any entity wholly owned, directly

or indirectly, by a company that is considered an insurance holding company

under the laws of any State if such entity

is organized, incorporated, or established

under the laws of the United States or

any State, and the principal place of business of such entity is in the United States

(including any territory of the United

States); and

(e) with respect to interest received on

a qualified real estate loan secured by real

property which is substantially used for

the production of one or more agricultural

products, any federally chartered instrumentality of the United States established

under section 8.1(a) of the Farm Credit

Act of 1971 (12 U.S.C. 2279aa-1(a)).

(3) Qualified real estate loan.

(a) In general. For purposes of § 139L,

§ 139L(c)(1) defines a qualified real estate

loan as any loan secured by rural or agricultural real estate, or a leasehold mortgage (with a status as a lien) on rural or

agricultural real estate; made to a person

other than a specified foreign entity (as

defined in § 7701(a)(51)); and made after

the date of the enactment of § 139L (July

4, 2025). The determination of whether a

property securing a loan is rural or agricultural real estate must be made as of the

time the interest income on such loan is

accrued.

(b) Refinancings. Pursuant to § 139L(c)

(2), a loan is not treated as made after the

date of the enactment of § 139L to the

extent that the proceeds of such loan are

used to refinance a loan which was made

on or before the date of the enactment of

§ 139L (or, in the case of any series of refinancings, the original loan was made on

or before such date).

(c) Rural or agricultural real estate.

For purposes of § 139L, § 139L(c)(3)

defines the term rural or agricultural real

estate as any real property which is substantially used for the production of one

or more agricultural products; any real

property which is substantially used in the

trade or business of fishing or seafood processing; and any aquaculture facility. Such

term does not include any property which

is not located in a State or a possession of

the United States.

(d)

Aquaculture

facility.

Section 139L(c)(4) defines the term aquaculture facility to mean any land, structure, or

other appurtenance that is used for aquaculture (including any hatchery, rearing

pond, raceway, pen, or incubator).

.02 Effective date. Section 139L applies

to taxable years ending after July 4, 2025

(that is, the date of the enactment of the

OBBBA).

SECTION 3. INTERIM GUIDANCE

REGARDING THE APPLICATION

OF § 139L

.01 Purpose of this notice. The Treasury Department and the IRS are issuing

this notice to provide interim guidance

regarding the application of § 139L prior

to the publication of the forthcoming proposed regulations.

.02 Defined terms. Any term not defined

in this notice has the meaning provided in

§ 139L. For purposes of this notice:

(1) Interest received. The term interest received means the interest, including amounts treated as interest under the

Code, that is includible in gross income

by a qualified lender. For purposes of the

preceding sentence, the amount of interest includible in gross income by a qualified lender is determined without regard

to § 139L, and the time at which interest

is includible in gross income is determined under the qualified lender’s overall

method of accounting (for example, the

cash receipts and disbursements method

of accounting or an accrual method of

accounting) or, if applicable, under a special method of accounting (for example,

§ 1272 for original issue discount).

(2) Pre-enactment loan. The term

pre-enactment loan means any debt

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

Bulletin No. 2025–50

779

December 8, 2025

instrument with an issue date (within the

meaning of § 1.1273-2) on or before July

4, 2025, or in the case of a refinancing or

any series of refinancings, any debt instrument for which the issue date of the original loan was on or before July 4, 2025.

(3) Qualified rural or agricultural

property. The term qualified rural or agricultural property means rural or agricultural real estate or a leasehold mortgage

(with a status as a lien) on rural or agricultural real estate.

.03 Interest received by a qualified

lender under § 139L(a).

(1) Allocation of exclusion. For purposes of applying § 139L(a), a qualified

lender excludes from gross income 25

percent of the interest received on a qualified real estate loan in a taxable year and

includes in gross income 75 percent of the

interest received on a qualified real estate

loan in the taxable year.

(2) No origination requirement. A qualified lender is not required to have been

the original holder of a qualified real estate

loan on the issue date of the qualified real

estate loan in order to exclude interest

income under § 139L(a). For example, a

qualified lender may include a subsequent

holder of a qualified real estate loan, if the

subsequent holder is a qualified lender.

.04 Qualified real estate loan.

(1) Determining whether a loan is

secured by qualified rural or agricultural

property.

(a) A qualified real estate loan is secured

by qualified rural or agricultural property

only if, at the time interest income on such

loan accrues, the qualified lender holds

a valid and enforceable security interest

with respect to the qualified rural or agricultural property under applicable law.

(b) Subject to the safe harbor described

in section 3.04(2) of this notice, the

amount of a loan that is a qualified real

estate loan is limited to the fair market

value of the qualified rural or agricultural

property securing the loan, determined as

of the issue date of the loan. If the amount

of the loan, that is, the issue price of the

loan, exceeds the fair market value of the

qualified rural or agricultural property

securing the loan, determined as of the

issue date of the loan, only the portion of

the loan that does not exceed such value is

a qualified real estate loan. For example,

if, on the issue date of a loan, the loan is

December 8, 2025

secured by qualified rural or agricultural

property with a fair market value of $10x

and the amount of the loan is $100x, then

only $10x of the loan is a qualified real

estate loan.

(c) A qualified lender that is a subsequent holder may apply section 3.04(1)

(b) of this notice either based on the fair

market value of the qualified rural or agricultural property securing the loan and the

issue price of the loan on the issue date,

or based on the fair market value of such

property and the adjusted issue price of

the loan on the date the qualified lender

acquires the loan.

(2) Safe harbor for determining

whether a loan is secured by qualified

rural or agricultural property.

(a) Notwithstanding section 3.04(1) of

this notice, a qualified lender may treat

a loan as fully secured by qualified rural

or agricultural property for purposes of

§ 139L(c) if the terms of the loan provide

the qualified lender an interest described

in section 3.04(1)(a) of this notice with

respect to the property and the fair market value of the qualified rural or agricultural property securing the loan is at least

80 percent of the issue price of the loan

on the issue date. For example, if, on the

issue date of a loan, the loan is secured

by qualified rural or agricultural property

with a fair market value of $85x and the

issue price of the loan is $100x, then the

entire loan is treated as a qualified real

estate loan.

(b) A qualified lender that is a subsequent holder may apply section 3.04(2)

(a) of this notice either based on the fair

market value of the qualified rural or agricultural property securing the loan and the

issue price of the loan on the issue date,

or based on the fair market value of such

property and the adjusted issue price of

the loan on the date the qualified lender

acquires the loan.

(3) Determining fair market value.

(a) For purposes of this section 3.04,

a qualified lender may determine the

fair market value of property by using

any commercially reasonable valuation

method. A commercially reasonable valuation method includes a method the qualified lender uses in the ordinary course of

its trade or business for valuing property

that secures loans. A commercially reasonable valuation method may take into

780

account expectations regarding the rural

or agricultural real estate’s production of

income from the activities conducted on

such real estate, as described in § 139L(c)

(3). For example, a qualified lender’s commercially reasonable valuation method

may take into account the value of crops

on or the projected income from harvesting crops on the rural or agricultural real

estate securing the loan.

(b) For purposes of this section 3.04,

a qualified lender may, subject to the

limitation in the following sentence,

add to the fair market value of the rural

or agricultural real estate the fair market

value of any personal property used in

the course of the activities conducted on

such real estate, as described in § 139L(c)

(3), such as farm equipment and machinery or livestock. A qualified lender may

include the value of personal property in

such determination only if the qualified

lender holds a valid and enforceable security interest with respect to such personal

property under applicable law, and only

if the relevant loan is secured to a substantial extent by rural or agricultural real

estate. For example, if real property substantially used for the production of corn

is valued at $500x, and farm equipment

and machinery used for the production

of corn on such real property is valued

at $50x, the total value that may be used

to determine the fair market value of the

qualified rural and agricultural property

for purposes of section 3.04(1) and (2) of

this notice would be $550x.

(4) Subsequent fair market value testing not required. For purposes of section

3.04(1) and (2) of this notice, so long as

the qualified real estate loan continues to

be secured by the qualified rural or agricultural property and there is not a subsequent significant modification of such

loan under § 1.1001-3, retesting of the fair

market value of such property other than

on the relevant date provided by section

3.04(1) or (2) of this notice is not required.

(5) Reasonable belief. If a qualified

lender initially determined a loan was

secured by qualified rural or agricultural

property under section 3.04(1) or (2) of

this notice, and reasonably believes in

good faith that the loan continues to be

so secured, then the qualified lender may

rely on that initial determination at the

time interest income on such loan accrues

Bulletin No. 2025–50

for purposes of § 139L(c) and this section 3.04. A reasonable, good-faith belief

exists only if the qualified lender reasonably believes in good faith both that the

security interest remains in place and that

the rural or agricultural real estate continues to be used in a manner that qualifies

it as rural or agricultural real estate. A

qualified lender may base this reasonable,

good-faith belief on covenants or other

certifications made by the borrower of

the loan or other parties that have actual

knowledge or reason to know that the loan

is secured by qualified rural or agricultural

property.

(6) Later discovery that a loan is not

secured under § 139L(c).

(a) Except as provided in section

3.04(6)(b) of this notice, if, despite the

qualified lender’s previous reasonable,

good-faith belief described in section

3.04(5) of this notice, the qualified lender,

on a later date, learns or has reason to

believe that a loan is no longer secured by

qualified rural or agricultural property, the

loan will lose its status as a qualified real

estate loan under § 139L on that date.

(b) A loan will be treated as not losing

its status as a qualified real estate loan

under section 3.04(6)(a) of this notice if the

qualified lender, borrower, or other party

causes the loan to be secured by qualified

rural or agricultural property within 90

days following the date on which the qualified lender learns or has reason to believe

that the loan is not secured by qualified

rural or agricultural property.

(7) Use of loan proceeds. For purposes

of section 3.04(1) or (2) of this notice, a

borrower’s use of loan proceeds does not

affect whether a loan may be treated as a

qualified real estate loan.

.05 Refinancings, significant modifications, and pre-enactment loans.

(1) Partial refinancing. For purposes

of § 139L(c)(2), if the proceeds of a loan

(new loan) are used in part to refinance a

pre-enactment loan and in part for other

purposes, the portion of the new loan

used to refinance the pre-enactment loan

is treated as made on or before July 4,

2025 (that is, the date of enactment of

§ 139L). The amount of the new loan that

may be treated as a qualified real estate

loan is limited to the portion of the new

loan that exceeds the outstanding balance

of the pre-enactment loan as of the date

Bulletin No. 2025–50

of the refinancing. In such case, a qualified lender must allocate the principal

of the new loan between amounts used

to refinance any pre-enactment loan and

amounts borrowed for other purposes

accordingly. Any payments of interest or

principal on the new loan are allocated

to the portion of the new loan that is a

pre-enactment loan and the portion that

may be a qualified real estate loan on a

pro rata basis.

(2) Significant modifications. A significant modification within the meaning

of § 1.1001-3 of a pre-enactment loan is

treated as a refinancing of the pre-enactment loan for purposes of § 139L(c)(2).

(3) Additional borrowings. A borrowing

after the date of the enactment of § 139L

that is added to the principal amount of

any pre-enactment loan or a borrowing

after the date of enactment of § 139L pursuant to a line of credit or similar agreement entered into on or before the date

of enactment that allows the borrower to

borrow periodically under the agreement

(post-enactment amount), is not treated as

a pre-enactment loan to the extent of the

post-enactment amount. For purposes of

this section 3.05(3), the post-enactment

amount does not include any amount

that is used to refinance a pre-enactment

loan. In cases where the outstanding principal includes both a pre-enactment loan

and a post-enactment amount, a qualified

lender must allocate the principal amount

between the pre-enactment loan and the

post-enactment amount and must allocate

payments of principal or interest on a pro

rata basis.

.06 Use described in § 139L(c)(3).

For purposes of § 139L(c)(3) and section

3.04(1) or (2) of this notice, the presence

of a residence on qualified rural or agricultural property, or intermittent periods

when such property is not used for the

purposes described in § 139L(c)(3) due

to seasonality, fallowing, or similar circumstances, does not prevent such property from being qualified rural or agricultural property as long as the property

satisfies the substantial use requirement.

By contrast, property with only minimal

or incidental agricultural activity generally would not be considered to be used

for the purposes described in § 139L(c)

(3), including for this purpose a small

personal garden, backyard beekeeping,

781

and keeping chickens to produce eggs for

household use.

SECTION 4. APPLICABILITY

DATES

It is anticipated that the forthcoming

proposed regulations will include proposed rules consistent with the interim

guidance provided in section 3 of this

notice and that the proposed regulations,

when finalized, will apply for taxable

years beginning after final regulations are

published in the Federal Register. Taxpayers may rely on the interim guidance set

forth in section 3 of this notice for loans

made after July 4, 2025, and on or before

the date that is 30 days after the forthcoming proposed regulations are published in

the Federal Register.

SECTION 5. REQUEST FOR

COMMENTS

.01 Comments regarding § 139L. The

Treasury Department and the IRS request

comments on the issues addressed in this

notice as well as other issues on which

taxpayers believe guidance would be

helpful. The Treasury Department and the

IRS also request comments on the following specific issues:

(1) To what extent should the forthcoming proposed regulations address the

meaning of the terms rural or agricultural

real estate, real property, agricultural

products, fishing or seafood processing,

or aquaculture facility? Should the forthcoming proposed regulations consider

definitions and guidance relating to similar terms, including under § 2032A, §

1.199A-8, and § 1.856-10?

(2) To what extent should the forthcoming proposed regulations address

whether property is substantially used for

the production of one or more agricultural

products, or in the trade or business of

fishing or seafood processing? For example, are factors such as time spent, amount

of land used, or revenue relevant, and to

what extent should seasonality or periods

of non-use be further considered?

(3) To what extent should the forthcoming proposed regulations address how

the substantial use requirement applies to

properties with mixed uses, such as farmland that is used to host events or other

December 8, 2025

non-agricultural activity, or properties that

are also used (in whole or part) for personal purposes?

(4) How should the forthcoming proposed regulations address changes involving qualified rural or agricultural property

following the issuance of a qualified real

estate loan, including changes in the use

of the property, changes to the property, or

changes affecting the collateral of a loan?

(5) How should the forthcoming proposed regulations address how a qualified lender determines whether the loan

remains secured by qualified rural or agricultural property?

(6) To what extent should the forthcoming proposed regulations address how

§ 139L applies in securitization structures,

including a securitization involving a trust

for which holders of trust certificates are

treated as holding an interest in the underlying loan assets?

(7) To what extent should the forthcoming proposed regulations address

December 8, 2025

§ 139L(d), regarding the application of

§ 265 to any qualified real estate loan?

.02 Procedures for submitting comments.

(1) Deadline. Written comments

should be submitted by January 20, 2026.

Consideration will also be given to any

written comment submitted after January

20, 2026, though such comments may not

be considered in the development of the

forthcoming proposed regulations if such

consideration would delay the publication of the forthcoming proposed regulations.

(2) Form and manner. The subject line

for the comments should include a reference to Notice 2025-71. All commenters

are strongly encouraged to submit comments electronically. Comments may be

submitted in one of two ways:

(a) electronically via the Federal

eRulemaking Portal at https://www.regulations.gov (type IRS-2025-0400 in the

search field on the https://www.regula-

782

tions.gov homepage to find this notice and

submit comments); or

(b) by mail to: Internal Revenue Service, CC:PA:01:PR (Notice 2025-71),

Room 5503, P.O. Box 7604, Ben Franklin

Station, Washington, D.C., 20044.

(3) Publication of comments. The Treasury Department and the IRS will publish

for public availability any comment submitted electronically and on paper to the

IRS’s public docket on https://www.regulations.gov.

SECTION 6. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice is

Matthew DeBenedetto of the Office of the

Associate Chief Counsel (Financial Institutions & Products). For further information regarding this notice, please contact

Mr. DeBenedetto at (202) 317-3998 (not a

toll-free number).

Bulletin No. 2025–50

Part IV

Certifications Issued for

Round 1 of the Qualifying

Advanced Energy Project

Credit Allocation Program

Under Section 48C(e)

Announcement 2025-22

This announcement discloses the first

set of certifications from the period beginning March 29, 2024, through September

30, 2025, resulting from the Round 1 allocation of the qualifying advanced energy

project credit provided by § 48C(e) of the

Internal Revenue Code.

SECTION 1. QUALIFYING

ADVANCED ENERGY PROJECT

CREDIT

Notice 2023-18 established the program under § 48C(e)(1) of the Internal

Revenue Code (Code) to allocate $10 billion of credits ($4 billion of which may be

allocated only to projects located in certain energy communities) (§ 48C credits)

for qualified investments in eligible qualifying advanced energy projects (§ 48C(e)

program).

For purposes of § 48C credit allocations

under the § 48C(e) program, § 48C(e)(4)

(A) provides a base credit rate of 6 percent

of the qualified investment (as defined in §

48C(b)). In the case of any project which

satisfies the requirements of § 48C(e)(5)

(A) and (6) (prevailing wage and apprenticeship requirements), § 48C(e)(4)(B)

provides an alternative rate of 30 percent

of the qualified investment.

The Treasury Department and the IRS

provided two allocation rounds under the

§ 48C(e) program. For the first allocation

round (Round 1) of the § 48C(e) program,

which began on May 31, 2023, the IRS

allocated $4 billion1 of the § 48C credits

with approximately $1.6 billion in § 48C

credits allocated to projects located in certain energy communities. Section 70515

of Public Law 119-21, 139 Stat. 72, 276

(July 4, 2025), commonly known as the

One, Big, Beautiful Bill Act (OBBBA)

amended § 48C(e)(3)(C) to limit the

availability of previously allocated § 48C

credits that were subsequently revoked for

future § 48C(e) program allocations.

SECTION 2. CERTIFICATION

Section 48C(e)(3)(B) provides that

each applicant for certification has 2 years

Applicant

Power Brace LLC

Hemlock Semiconductor Operations LLC

Essex Furukawa Magnet Wire USA LLC

JSW Steel USA Ohio, Inc.

Pennsylvania Transformer Technology Inc.

Voith Hydro Inc.

Electric Hydrogen Co.

Delta Star Inc.

MP Magnetics LLC

Beam Suntory Inc.

Bekaert Corporation

Electric Research and Manufacturing Cooperative Inc.

American Battery Technology Company

1

from the date of acceptance by the Secretary of the § 48C(e) application during

which to provide to the Secretary evidence

that the requirements of the certification

have been met.

Section 48C(e)(7) provides that

upon making a certification under §

48C(e), the Secretary is required to disclose publicly the identity of the applicant and the amount of the § 48C credit

certified with respect to such applicant.

This notice provides the identity of the

taxpayer and the amount of the § 48C

credits allocated to the taxpayer with

respect to projects that have been allocated a § 48C credit and for which a certification was issued during the period

beginning on March 29, 2024, the day

that Round 1 allocation notification

letters were issued, and ending on September 30, 2025, for Round 1 of the §

48C(e) program. The IRS will publish

additional such notices annually for

certifications issued during each successive 12-month period beginning on

October 1, 2025.

Accordingly, the certifications issued

to date for Round 1 of the § 48C(e) program are as follows:

Amount

$ 628,168.00

$ 86,400,000.00

$ 11,520,000.00

$ 43,500,000.00

$ 2,100,000.00

$ 5,826,254.00

$ 18,348,108.00

$ 1,803,480.00

$ 58,500,000.00

$ 9,495,900.00

$ 4,061,559.00

$ 4,762,743.00

$ 19,575,896.00

The IRS allocated approximately $6 billion of the § 48C credits in the second allocation round (Round 2) of the § 48C(e) program. See Announcement 2025-23 in I.R.B. 2025-50.

Bulletin No. 2025–50

783

December 8, 2025

SECTION 3. DRAFTING

INFORMATION

The principal author of this

announcement is Jean Elting Rowe of

the Large Business and International

Division. However, other personnel

from the Treasury Department and

Office of Associate Chief Counsel

(Energy, Credits, and Excise Tax) participated in its development. For further

information regarding this announcement, call (202) 317-5254 (not a tollfree number).

Certifications Issued

for Round 2 of the

Qualifying Advanced

Energy Project Credit

Allocation Program Under

Section 48C(e)

Announcement 2025-23

This announcement discloses the

first set of certifications from the period

beginning January 10, 2025, through

September 30, 2025, resulting from the

Round 2 allocation of the qualifying

advanced energy project credit provided

by § 48C(e) of the Internal Revenue

Code.

SECTION 1. QUALIFYING

ADVANCED ENERGY PROJECT

CREDIT

ability of previously allocated § 48C credits

that were subsequently revoked for future §

48C(e) program allocations.

Notice 2023-18 established the program under § 48C(e)(1) of the Internal

Revenue Code (Code) to allocate $10 billion of credits ($4 billion of which may be

allocated only to projects located in certain energy communities) (§ 48C credits)

for qualified investments in eligible qualifying advanced energy projects (§ 48C(e)

program).

For purposes of § 48C credit allocations

under the § 48C(e) program, § 48C(e)(4)

(A) provides a base credit rate of 6 percent

of the qualified investment (as defined in §

48C(b)). In the case of any project which

satisfies the requirements of § 48C(e)(5)

(A) and (6) (prevailing wage and apprenticeship requirements), § 48C(e)(4)(B)

provides an alternative rate of 30 percent

of the qualified investment.

The Treasury Department and the IRS

provided two allocation rounds under the §

48C(e) program. For the second allocation

round (Round 2) of the § 48C(e) program,

which began on May 22, 2024, the IRS

allocated approximately $6 billion1 of the

§ 48C credits with approximately $2.5 billion in § 48C credits allocated to projects

in designated energy communities. Section

70515 of Public Law 119-21, 139 Stat. 72,

276 (July 4, 2025), commonly known as

the One, Big, Beautiful Bill Act (OBBBA),

amended § 48C(e)(3)(C) to limit the avail-

SECTION 2. CERTIFICATION

Taxpayer

Ozinga Cement, Inc.

Tesla, Inc.

SECTION 3. DRAFTING

INFORMATION

The principal author of this announcement is Jean Elting Rowe of the Large

1

Section 48C(e)(3)(B) provides that

each applicant for certification has 2 years

from the date of acceptance by the Secretary of the § 48C(e) application during

which to provide to the Secretary evidence

that the requirements of the certification

have been met.

Section 48C(e)(7) provides that upon

making a certification under § 48C(e),

the Secretary is required to disclose publicly the identity of the applicant and the

amount of the § 48C credit certified with

respect to such applicant. This notice provides the identity of the taxpayer and the

amount of the § 48C credits allocated to

the taxpayer with respect to projects that

have been allocated a § 48C credit and for

which a certification was issued during

the period beginning on January 10, 2025,

the day that Round 2 allocation notification letters were issued, and ending on

September 30, 2025, for Round 2 of the

§ 48C(e) program. The IRS will publish

additional such notices annually for certifications issued during each successive

12-month period beginning on October 1,

2025.

Accordingly, the certifications issued

to date for Round 2 of the § 48C(e) program are as follows:

Amount of Credit Certified

$ 14,930,597.75

$ 240,289,310.00

Business and International Division.

However, other personnel from the Treasury Department and the Office of Associate Chief Counsel (Energy, Credits, and

Excise Tax) participated in its develop-

ment. For further information regarding

this announcement, call (202) 317-5254

(not a toll-free number).

The IRS allocated approximately $4 billion of the § 48C credits in the first allocation round (Round 1) of the § 48C(e) program. See Announcement 2025-22 in I.R.B. 2025-50.

December 8, 2025

784

Bulletin No. 2025–50

Announcement of

Disciplinary Sanctions

From the Office of

Professional Responsibility

Announcement 2025-29

The Office of Professional Responsibility (OPR) announces recent disciplinary

sanctions imposed on attorneys, certified public accountants, enrolled agents,

enrolled actuaries, enrolled retirement

plan agents, and appraisers. The OPR also

announces when certain unenrolled, unlicensed tax return preparers (individuals

who are not enrolled to practice before

the Internal Revenue Service (IRS) and

are not licensed as attorneys or certified

public accountants) have been disciplined.

Licensed or enrolled practitioners are subject to the regulations governing practice

before the IRS, which are set out in Title

31, Code of Federal Regulations, Subtitle A, Part 10, and which are released as

Treasury Department Circular No. 230.

The regulations prescribe the duties and

restrictions relating to such practice and

prescribe the disciplinary sanctions for

violating the regulations. Unenrolled/

unlicensed return preparers who choose to

participate in the IRS’s voluntary Annual

Filing Season Program (AFSP) are subject to the guidance in Revenue Procedure

2014-42, which governs a preparer’s eligibility to represent taxpayers before the IRS

in examinations of tax returns the preparer

both prepared for the taxpayer and signed

as the preparer. Additionally, unenrolled/

unlicensed return preparers who participate in the AFSP agree to be subject to

the duties and restrictions in Circular 230,

including the restrictions on incompetence

or disreputable conduct.

The disciplinary sanctions imposed for

violation of the applicable standards are:

Disbarred from practice before the

IRS—An individual who is disbarred

is not eligible to practice before the IRS

as defined at 31 C.F.R. § 10.2(a)(4) for a

minimum period of five (5) years and until

reinstated to practice.

Suspended from practice before the

IRS—An individual who is suspended is

not eligible to practice before the IRS as

defined at 31 C.F.R. § 10.2(a)(4) during

Bulletin No. 2025–50

the term of the suspension and until reinstated to practice.

Censured—Censure is a public reprimand. Unlike disbarment or suspension,

censure does not affect an individual’s eligibility to practice before the IRS, but the

OPR may subject the individual’s future

practice rights to conditions designed to

promote high standards of conduct.

Monetary penalty—A monetary penalty may be imposed on an individual who

engages in conduct subject to sanction, or

on an employer, firm, or other entity if the

individual was acting on its behalf and it

knew, or reasonably should have known,

of the individual’s conduct.

Disqualification of appraiser—An

appraiser who is disqualified is barred

from presenting evidence or testimony in

any administrative proceeding before the

Department of the Treasury or the IRS.

Additionally, any appraisal made by the

disqualified appraiser after the effective

date of disqualification will not have any

probative effect in any administrative proceeding before the Treasury Department

or the IRS.

Ineligible for limited practice—An

unenrolled/unlicensed tax return preparer

who participates in the AFSP and who fails

to comply with Circular 230 as required

by Revenue Procedure 2014-42 may have

their AFSP credential revoked and may be

determined ineligible to engage in future

limited practice under the program as a

representative of a taxpayer.

Under the regulations, individuals

subject to Circular 230 may not assist, or

accept assistance from, individuals who

are suspended or disbarred with respect

to matters constituting practice (i.e., representation) before the IRS, and they may

not aid or abet suspended or disbarred

individuals to practice before the IRS.

Disciplinary sanctions are described in

these terms:

Disbarred by decision, Suspended by

decision, Censured by decision, Monetary penalty imposed by decision, and

Disqualified by decision (including after

a hearing)—An administrative law judge

(ALJ), upon the OPR’s complaint alleging violation of the regulations, issued a

decision imposing one of these sanctions

after the ALJ either (1) granted the government’s motion for summary adjudication or (2) after conducting an evidentiary

785

hearing. After 30 days from the issuance

of the decision, in the absence of an

appeal, the ALJ’s decision becomes the

final agency decision.

Disbarred by default decision, Suspended by default decision, Censured

by default decision, Monetary penalty imposed by default decision, and

Disqualified by default decision—An

ALJ, after finding that no answer to the

OPR’s complaint was filed or timely filed,

granted the OPR’s motion for a default

judgment and issued a decision imposing

one of these sanctions.

Disbarred by decision on appeal,

Suspended by decision on appeal, Censured by decision on appeal, Monetary penalty imposed by decision on

appeal, and Disqualified by decision

on appeal—The decision of the ALJ was

appealed to the agency’s appellate authority, acting as the delegate of the Secretary

of the Treasury, and the appellate authority issued a decision imposing one of these

sanctions.

Disbarred by consent, Suspended by

consent, Censured by consent, Monetary penalty imposed by consent, and

Disqualified by consent—In lieu of a

disciplinary proceeding being instituted or

continued, an individual offered their consent to one of these sanctions (or a firm or

other entity offered to consent to a monetary penalty) and the OPR accepted the

offer and the parties entered into a consent

agreement. Typically, an offer of consent

will provide for: suspension for an indefinite term; conditions that the individual

must observe during the suspension; and

the individual’s opportunity, after a stated

number of months, to file with the OPR

a petition for reinstatement affirming

compliance with the terms of the consent

agreement and affirming current fitness

and eligibility to practice (i.e., an active

professional license or active enrollment

status, with no intervening violations of

the regulations).

Suspended indefinitely by decision

in expedited proceeding, Suspended

indefinitely by default decision in expedited proceeding—The OPR instituted

an expedited proceeding for suspension

(based on certain limited grounds, including loss of a professional license for cause,

and criminal convictions) that resulted in

suspension.

December 8, 2025

Determined ineligible for limited

practice—There has been a final determination under Revenue Procedure

2014-42 that an unenrolled/unlicensed

tax return preparer is not eligible for continued limited representation of taxpayers because the preparer violated standards of conduct prescribed in Circular

230 or failed to comply with any of the

requirements described in the revenue

procedure.

A practitioner who has been disbarred

or suspended under 31 C.F.R. § 10.60, or

suspended under § 10.82, or a disqualified

appraiser may petition for reinstatement

before the IRS after the expiration of 5

years following such disbarment, suspension, or disqualification (or immediately

following the expiration of the suspension

or disqualification period if shorter than 5

years). Reinstatement will not be granted

unless the IRS is satisfied that the petitioner is not likely to engage thereafter in

conduct contrary to Circular 230, and that

granting such reinstatement would not be

contrary to the public interest.

Reinstatement decisions are published

at the individual’s request, and described

in these terms:

Reinstated to practice before the

IRS—The OPR granted the individual’s

petition for reinstatement. The individual

is eligible to practice before the IRS, or in

the case of an appraiser, the individual is

no longer disqualified.

The OPR has authority to disclose

the grounds for disciplinary sanctions in

these situations: (1) an ALJ or the Secretary’s delegate on appeal has issued a

final decision imposing a sanction; (2) the

individual has settled a disciplinary case

by signing the OPR’s consent-to-sanction

agreement admitting to one or more violations of the regulations and consenting

to the disclosure of the admitted violations (for example, willful failure to file

Federal income tax returns, lack of due

diligence, conflict of interest, etc.); (3)

that the OPR has issued a decision in an

expedited proceeding for indefinite suspension; or (4) upon a final determination

(including any decision on appeal) that an

unenrolled/unlicensed return preparer is

no longer eligible to represent taxpayers

before the IRS under Revenue Procedure

2014-42.

Announcements of disciplinary sanctions appear in the Internal Revenue

Bulletin at the earliest practicable date.

The sanctions announced below are

alphabetized first by state and second by

the last names of the sanctioned individuals.

City & State

Name

Professional

Designation

Disciplinary Sanction

Effective Date(s)

California

Benicia

Singh, Barjinderjit

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

August 15, 2025

Chino Hills

Zhong, John Z.

CPA/

Enrolled Agent

Colorado

Englewood

Baird, Stephen

Attorney

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

September 30, 2024

Iowa

Atkins

Sweet, Kimberly S.

Enrolled Agent

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

September 9, 2025

Kansas

Leawood

Renkemeyer, Troy D.

Attorney/

CPA

Indefinite from

July 7, 2025

Wichita

Ayesh, Mark G.

Attorney/

CPA

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Censured by consent for

admitted violations of

31 C.F.R. § 10.51(a)(10)

New Jersey

Avon by the Sea

Benkoil, James H.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

August 1, 2025

December 8, 2025

786

Reinstated to

practice before

the IRS, effective

July 16, 2024

Indefinite from

June 21, 2023

Bulletin No. 2025–50

City & State

Name

Disciplinary Sanction

Effective Date(s)

Sardis, Jack N.

Professional

Designation

CPA

Englewood Cliffs

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

August 1, 2025

Tennessee

Signal Mountain

Frost, Jonathan D.

CPA

Suspended by default decision

in expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

September 30, 2024

Virginia

Alexandria

Guilliams, Roger L.

CPA

Suspended by decision in

expedited proceeding under

31 C.F.R. § 10.82(b)

Indefinite from

September 30, 2024

Bulletin No. 2025–50

787

December 8, 2025

Definition of Terms

Revenue rulings and revenue procedures

(hereinafter referred to as “rulings”) that

have an effect on previous rulings use the

following defined terms to describe the

­effect:

Amplified describes a situation where

no change is being made in a prior published position, but the prior position is

being extended to apply to a variation of

the fact situation set forth therein. Thus,

if an earlier ruling held that a principle

applied to A, and the new ruling holds that

the same principle also applies to B, the

earlier ruling is amplified. (Compare with

modified, below).

Clarified is used in those instances

where the language in a prior ruling is

being made clear because the language

has caused, or may cause, some confusion. It is not used where a position in a

prior ruling is being changed.

Distinguished describes a situation

where a ruling mentions a previously published ruling and points out an essential

difference between them.

Modified is used where the substance

of a previously published position is being

changed. Thus, if a prior ruling held that a

principle applied to A but not to B, and the

new ruling holds that it applies to both A

and B, the prior ruling is modified because

it corrects a published position. (Compare

with amplified and clarified, above).

Obsoleted describes a previously published ruling that is not considered determinative with respect to future transactions.

This term is most commonly used in a ruling

that lists previously published rulings that

are obsoleted because of changes in laws or

regulations. A ruling may also be obsoleted

because the substance has been included in

regulations subsequently adopted.

Revoked describes situations where the

position in the previously published ruling

is not correct and the correct position is

being stated in a new ruling.

Superseded describes a situation where

the new ruling does nothing more than

restate the substance and situation of a

previously published ruling (or rulings).

Thus, the term is used to republish under

the 1986 Code and regulations the same

position published under the 1939 Code

and regulations. The term is also used

when it is desired to republish in a single

ruling a series of situations, names, etc.,

that were previously published over a

period of time in separate rulings. If the

new ruling does more than restate the substance of a prior ruling, a combination of

terms is used. For example, modified and

superseded describes a situation where the

substance of a previously published ruling

is being changed in part and is continued

without change in part and it is desired to

restate the valid portion of the previously

published ruling in a new ruling that is

self contained. In this case, the previously

published ruling is first modified and then,

as modified, is superseded.

Supplemented is used in situations in

which a list, such as a list of the names of

countries, is published in a ruling and that

list is expanded by adding further names

in subsequent rulings. After the original

ruling has been supplemented several

times, a new ruling may be published that

includes the list in the original ruling and

the additions, and supersedes all prior rulings in the series.

Suspended is used in rare situations

to show that the previous published rulings will not be applied pending some

future action such as the issuance of new

or amended regulations, the outcome of

cases in litigation, or the outcome of a

Service study.

Abbreviations

The following abbreviations in current

use and formerly used will appear in

material published in the Bulletin.

A—Individual.

Acq.—Acquiescence.

B—Individual.

BE—Beneficiary.

BK—Bank.

B.T.A.—Board of Tax Appeals.

C—Individual.

C.B.—Cumulative Bulletin.

CFR—Code of Federal Regulations.

CI—City.

COOP—Cooperative.

Ct.D.—Court Decision.

CY—County.

D—Decedent.

DC—Dummy Corporation.

DE—Donee.

Del. Order—Delegation Order.

DISC—Domestic International Sales Corporation.

DR—Donor.

E—Estate.

EE—Employee.

E.O.—Executive Order.

ER—Employer.

Bulletin No. 2025–50

ERISA—Employee Retirement Income Security Act.

EX—Executor.

F—Fiduciary.

FC—Foreign Country.

FICA—Federal Insurance Contributions Act.

FISC—Foreign International Sales Company.

FPH—Foreign Personal Holding Company.

F.R.—Federal Register.

FUTA—Federal Unemployment Tax Act.

FX—Foreign corporation.

G.C.M.—Chief Counsel’s Memorandum.

GE—Grantee.

GP—General Partner.

GR—Grantor.

IC—Insurance Company.

I.R.B.—Internal Revenue Bulletin.

LE—Lessee.

LP—Limited Partner.

LR—Lessor.

M—Minor.

Nonacq.—Nonacquiescence.

O—Organization.

P—Parent Corporation.

PHC—Personal Holding Company.

PO—Possession of the U.S.

PR—Partner.

PRS—Partnership.

i

PTE—Prohibited Transaction Exemption.

Pub. L.—Public Law.

REIT—Real Estate Investment Trust.

Rev. Proc.—Revenue Procedure.

Rev. Rul.—Revenue Ruling.

S—Subsidiary.

S.P.R.—Statement of Procedural Rules.

Stat.—Statutes at Large.

T—Target Corporation.

T.C.—Tax Court.

T.D.—Treasury Decision.

TFE—Transferee.

TFR—Transferor.

T.I.R.—Technical Information Release.

TP—Taxpayer.

TR—Trust.

TT—Trustee.

U.S.C.—United States Code.

X—Corporation.

Y—Corporation.

Z—Corporation.

December 8, 2025

Numerical Finding List1

Bulletin 2025–50

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

2025-22, 2025-50 I.R.B. 783

2025-23, 2025-50 I.R.B. 784

2025-29, 2025-50 I.R.B. 785

Notices:

2025-32, 2025-27 I.R.B. 1

2025-33, 2025-27 I.R.B. 4

2025-34, 2025-27 I.R.B. 6

2025-35, 2025-27 I.R.B. 8

2025-31, 2025-28 I.R.B. 14

2025-36, 2025-30 I.R.B. 192

2025-37, 2025-30 I.R.B. 198

2025-40, 2025-31 I.R.B. 266

2025-39, 2025-32 I.R.B. 308

2025-28, 2025-34 I.R.B. 316

2025-41, 2025-34 I.R.B. 325

2025-42, 2025-36 I.R.B. 351

2025-43, 2025-36 I.R.B. 356

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2025-67, 2025-49 I.R.B. 761

2025-69, 2025-50 I.R.B. 766

2025-70, 2025-50 I.R.B. 773

2025-71, 2025-50 I.R.B. 779

Proposed Regulations:—Continued

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

Revenue Procedures:

2025-22, 2025-30 I.R.B. 200

2025-24, 2025-31 I.R.B. 273

2025-25, 2025-32 I.R.B. 311

2025-26, 2025-33 I.R.B. 315

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

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

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

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

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

Revenue Rulings:

2025-13, 2025-28 I.R.B. 11

2025-14, 2025-32 I.R.B. 300

2025-15, 2025-32 I.R.B. 302

2025-16, 2025-35 I.R.B. 342

2025-17, 2025-36 I.R.B. 349

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

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

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

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

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

2025-23, 2025-48 I.R.B. 749

2025-24, 2025-50 I.R.B. 764

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

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin

2025–52, dated December 22, 2025.

1

December 8, 2025

ii

Bulletin No. 2025–50

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–50

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. 2025–50

iii

December 8, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,

we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page

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