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## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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 Unpublished rulings will not be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
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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NW, IR-6230 Washington, DC 20224.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A4005ac694a632364. Public record. Not legal advice.