These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

INCOME TAX

Notice 2025-19, page 1418.

This notice requests recommendations for the 2025-2026

Priority Guidance Plan.

Finding Lists begin on page ii.





Bulletin No. 2025–17

April 21, 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 Unpublished rulings will not be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.

April 21, 2025 

Bulletin No. 2025–17

Part III

Public Recommendations

Invited on Items to be

Included on the 2025-2026

Priority Guidance Plan

Notice 2025-19

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) invite the public to

submit recommendations for items to be

included on the 2025-2026 Priority Guidance Plan.

The Treasury Department’s Office of

Tax Policy and the IRS use the Priority

Guidance Plan each year to identify and

prioritize the tax issues that should be

addressed through regulations, revenue

rulings, revenue procedures, notices, and

other published administrative guidance.

The 2025-2026 Priority Guidance Plan

will identify guidance projects that the

Treasury Department and the IRS intend

to actively work on as priorities during the

period from July 1, 2025, through June 30,

2026.

The Treasury Department and the IRS

recognize the importance of public input in

formulating a Priority Guidance Plan that

focuses resources on guidance items that

are most important to taxpayers and tax

administration. Published guidance plays

an important role in increasing voluntary

compliance by helping to clarify ambiguous areas of the tax law. The published

guidance process is most successful if the

Treasury Department and the IRS have the

benefit of the experience and knowledge

of taxpayers and practitioners who must

apply the rules implementing the tax laws.

In reviewing recommendations and

selecting additional projects for inclusion

on the 2025-2026 Priority Guidance Plan,

the Treasury Department and the IRS will

consider the following:

1. Whether taxpayers have identified

that the recommended guidance relates to

regulations potentially described in Executive Order 14219 (90 FR 10583) Section

2(a):

(i) unconstitutional regulations and

regulations that raise serious constitutional difficulties, such as exceeding the

April 21, 2025

scope of the power vested in the Federal

Government by the Constitution;

(ii) regulations that are based on unlawful delegations of legislative power;

(iii) regulations that are based on anything other than the best reading of the

underlying statutory authority or prohibition;

(iv) regulations that implicate matters

of social, political, or economic significance that are not authorized by clear statutory authority;

(v) regulations that impose significant

costs upon private parties that are not outweighed by public benefits;

(vi) regulations that harm the national

interest by significantly and unjustifiably

impeding technological innovation, infrastructure development, disaster response,

inflation reduction, research and development, economic development, energy

production, land use, and foreign policy

objectives; and

(vii) regulations that impose undue

burdens on small business and impede private enterprise and entrepreneurship.

2. Whether the recommendation

involves existing regulations or other

guidance that is outdated, unnecessary,

ineffective, insufficient, or unnecessarily

burdensome and that should be modified,

streamlined, expanded, replaced, or withdrawn;

3. Whether the recommended guidance

reduces controversy and lessens the burden on taxpayers or the IRS;

4. Whether the recommended guidance

would be in accordance with Executive

Order 14192 (90 FR 9065) or other executive orders.

5. Whether the recommended guidance

resolves significant issues relevant to a

broad class of taxpayers;

6. Whether the recommended guidance

promotes sound tax administration;

7. Whether the IRS can administer

the recommended guidance on a uniform

basis; and

8. Whether the recommended guidance

can be drafted in a manner that will enable

taxpayers to easily understand and apply

the guidance.

Please submit recommendations for

guidance by Friday, May 30, 2025, for possible inclusion on the original 2025-2026

1418

Priority Guidance Plan. Taxpayers may,

however, submit recommendations for guidance at any time during the year. The Treasury Department and the IRS will update the

2025-2026 Priority Guidance Plan periodically to reflect additional guidance that the

Treasury Department and the IRS intend to

publish or have published during the plan

year. The periodic updates allow the Treasury Department and the IRS to respond in

a timely manner to the need for additional

guidance that may arise during the plan year.

Taxpayers are not required to submit recommendations for guidance in

any particular format. Taxpayers should,

however, briefly describe the recommended guidance and explain the need

for the guidance. In addition, taxpayers

may include an analysis of how the issue

should be resolved. For recommendations

to modify, streamline, or withdraw existing regulations or other guidance, taxpayers should explain how the changes

would reduce taxpayer cost and/or burden

or benefit tax administration, or how the

changes properly address issues described

in Executive Order 14219 Sections 2(a)

(i) – (vii). It would be helpful if taxpayers suggesting more than one guidance

project prioritize the projects by order of

importance. If a large number of projects

are being suggested, it would be helpful if

the projects were grouped by subject matter and then in terms of high, medium, or

low priority. Requests for guidance in the

form of petitions for rulemaking will be

considered with other recommendations

for guidance in accordance with the considerations described in this notice.

Taxpayers are strongly encouraged to

submit recommendations for guidance

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

(type IRS-2025-0036 in the search field

on the regulations.gov homepage to find

this notice and submit recommendations).

Taxpayers submitting recommendations

by mail should send them to:

Internal Revenue Service

Attn: CC:PA:01:PR (Notice 2025-19)

Room 5203

P.O. Box 7604

Ben Franklin Station

Washington, D.C. 20044

Bulletin No. 2025–17

All recommendations for guidance

submitted by the public in response to

this notice will be available for public

Bulletin No. 2025–17

inspection and copying in their entirety.

For further information regarding this

notice, contact the Office of the Asso-

1419

ciate Chief Counsel (Procedure and

Administration) at (202) 317-3400 (not

a toll-free call).

April 21, 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. 2025–17

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.

April 21, 2025

Numerical Finding List1

Bulletin 2025–17

Announcements:

2025-2, 2025-2 I.R.B. 305

2025-3, 2025-2 I.R.B. 306

2025-4, 2025-2 I.R.B. 306

2025-1, 2025-3 I.R.B. 431

2025-5, 2025-3 I.R.B. 433

2025-6, 2025-5 I.R.B. 526

2025-8, 2025-13 I.R.B. 1384

2025-13, 2025-15 I.R.B. 1392

Notices:

2025-1, 2025-3 I.R.B. 415

2025-2, 2025-3 I.R.B. 418

2025-4, 2025-3 I.R.B. 419

2025-5, 2025-3 I.R.B. 426

2025-3, 2025-4 I.R.B. 488

2025-7, 2025-5 I.R.B. 524

2025-9, 2025-6 I.R.B. 681

2025-10, 2025-6 I.R.B. 682

2025-11, 2025-6 I.R.B. 704

2025-13, 2025-6 I.R.B. 710

2025-6, 2025-8 I.R.B. 799

2025-8, 2025-8 I.R.B. 800

2025-12, 2025-8 I.R.B. 813

2025-14, 2025-10 I.R.B. 980

2025-15, 2025-11 I.R.B. 1089

2025-16, 2025-13 I.R.B. 1378

2025-17, 2025-14 I.R.B. 1387

2025-18, 2025-16 I.R.B. 1416

2025-19, 2025-17 I.R.B. 1418

Proposed Regulations:

REG-117213-24, 2025-3 I.R.B. 433

REG-134420-10, 2025-4 I.R.B. 513

REG-105479-18, 2025-5 I.R.B. 527

REG-116610-20, 2025-5 I.R.B. 638

REG-115560-23, 2025-6 I.R.B. 716

REG-123525-23, 2025-6 I.R.B. 726

REG-124930-21, 2025-7 I.R.B. 772

REG‑100669‑24, 2025-8 I.R.B. 819

REG-101268-24, 2025-8 I.R.B. 836

REG-107420-24, 2025-8 I.R.B. 854

REG-116085-23, 2025-8 I.R.B. 865

REG-118988-22, 2025-8 I.R.B. 869

REG-107895-24, 2025-9 I.R.B. 972

REG-110878-24, 2025-9 I.R.B. 979

REG-112261-24, 2025-10 I.R.B. 983

Revenue Procedures:—Continued

2025-5, 2025-1 I.R.B. 260

2025-7, 2025-1 I.R.B. 301

2025-8, 2025-3 I.R.B. 427

2025-9, 2025-4 I.R.B. 491

2025-10, 2025-4 I.R.B. 492

2025-11, 2025-4 I.R.B. 501

2025-12, 2025-4 I.R.B. 512

2025-6, 2025-6 I.R.B. 713

2025-14, 2025-7 I.R.B. 770

2025-13, 2025-8 I.R.B. 816

2025-15, 2025-11 I.R.B. 1090

2025-16, 2025-11 I.R.B. 1100

2025-17, 2025-13 I.R.B. 1382

Revenue Rulings:

2025-1, 2025-3 I.R.B. 307

2025-2, 2025-3 I.R.B. 309

2025-3, 2025-4 I.R.B. 443

2025-4, 2025-7 I.R.B. 758

2025-5, 2025-7 I.R.B. 767

2025-6, 2025-11 I.R.B. 1064

2025-7, 2025-13 I.R.B. 1239

2025-8, 2025-15 I.R.B. 1390

2025-9, 2025-16 I.R.B. 1415

Treasury Decisions:

10016, 2025-3 I.R.B. 313

10020, 2025-3 I.R.B. 408

10018, 2025-4 I.R.B. 446

10019, 2025-4 I.R.B. 482

10017, 2025-5 I.R.B. 517

10028, 2025-6 I.R.B. 660

10022, 2025-8 I.R.B. 773

10026, 2025-9 I.R.B. 878

10027, 2025-9 I.R.B. 897

10029, 2025-9 I.R.B. 936

10030, 2025-11 I.R.B. 1066

10024, 2025-12 I.R.B. 1104

10023, 2025-13 I.R.B. 1259

Revenue Procedures:

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

2025-2, 2025-1 I.R.B. 118

2025-3, 2025-1 I.R.B. 142

2025-4, 2025-1 I.R.B. 158

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

April 21, 2025

ii

Bulletin No. 2025–17

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–17

A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin

2024–52, dated December 23, 2024.

1

Bulletin No. 2025–17

iii

April 21, 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

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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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