Bulletin No. 2025–19

Agency decision

Ask Donna

What actually matters in this document.

Text

HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2025–19

May 5, 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

INCOME TAX

Notice 2025-24, page 1429.

Notice 2025-20, page 1423.

This notice provides relief from penalties under section

6707A(a) and 6707(a) for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax

Shelter Analysis (OTSA) under sections 6011 and 6111,

as set forth in §§ 1.6011-10(h)(2) and (3) and 1.601111(h)(2) and (3), respectively. This relief applies only if the

required disclosure statements are filed with OTSA by July

31, 2025.

ADMINISTRATIVE, INCOME TAX

Rev. Proc. 2025-18, page 1430.

This Revenue Procedure provides issuers of qualified mortgage bonds and mortgage credit certificates with (1) the

nationwide average purchase price for residences located in

the United States, and (2) the average area purchase price

safe harbors for residences located in statistical areas in

each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and

Guam.

EMPLOYEE PLANS

Notice 2025-21, page 1424.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment rates

for March 2025 used under § 417(e)(3)(D), the 24-month

average segment rates applicable for April 2025, and the

30-year Treasury rates, as reflected by the application of

§ 430(h)(2)(C)(iv).

Finding Lists begin on page ii.

This notice announces the applicable percentage under section 613A(c)(6)(C) for marginal oil and gas properties in the

2025 calendar year. The applicable percentage is used to

determine the amount of the percentage depletion deduction

allowable under section 613A(c)(6) with respect to oil and

natural gas produced from marginal properties.

Notice 2025-23, page 1428.

Notice 2025-23 informs taxpayers and material advisors

that final regulations regarding the identification of certain

partnership related-party basis adjustment transactions as

transactions of interest will be withdrawn through the forthcoming publication of proposed and final regulations and that

they can rely on the notice for relief from applicable penalties

for failure to file disclosure statements. In addition, Notice

2025-23 revokes Notice 2024-54, which informed taxpayers of intended proposed regulations that would provide substantive technical rules to discourage basis shifting among

related partners.

Rev. Rul. 2025-10, page 1421.

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 May 2025.

SPECIAL ANNOUNCEMENT

Notice 2025-22, page 1427.

This notice starts the process of eliminating extraneous and

unnecessary Internal Revenue Bulletin (IRB) guidance by identifying and obsoleting nine IRB guidance documents.

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.

May 5, 2025

Bulletin No. 2025–19

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. 2025-10

This revenue ruling provides various prescribed rates for federal income

Annual

AFR

110% AFR

120% AFR

130% AFR

4.05%

4.46%

4.87%

5.28%

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

4.10%

4.52%

4.93%

5.35%

6.18%

7.24%

AFR

110% AFR

120% AFR

130% AFR

4.62%

5.09%

5.56%

6.03%

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

Bulletin No. 2025–19

tax purposes for May 2025 (the current

month). Table 1 contains the shortterm, 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, mid-term, 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 long-term

tax-exempt rate described in section

382(f). Table 4 contains the appropri-

ate 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. 2025-10 TABLE 1

Applicable Federal Rates (AFR) for May 2025

Period for Compounding

Semiannual

Quarterly

Short-term

4.01%

3.99%

4.41%

4.39%

4.81%

4.78%

5.21%

5.18%

Mid-term

4.06%

4.04%

4.47%

4.45%

4.87%

4.84%

5.28%

5.25%

6.09%

6.04%

7.11%

7.05%

Long-term

4.57%

4.54%

5.03%

5.00%

5.48%

5.44%

5.94%

5.90%

Annual

3.06%

3.10%

3.50%

REV. RUL. 2025-10 TABLE 2

Adjusted AFR for May 2025

Period for Compounding

Semiannual

3.04%

3.08%

3.47%

1421

Quarterly

3.03%

3.07%

3.46%

Monthly

3.98%

4.37%

4.76%

5.15%

4.03%

4.43%

4.82%

5.22%

6.01%

7.01%

4.53%

4.98%

5.42%

5.87%

Monthly

3.02%

3.06%

3.45%

May 5, 2025

REV. RUL. 2025-10 TABLE 3

Rates Under Section 382 for May 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.)

3.50%

3.64%

REV. RUL. 2025-10 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for May 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

8.01%

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

3.43%

REV. RUL. 2025-10 TABLE 5

Rate Under Section 7520 for May 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

May 2025. See Rev. Rul. 2025-10, page 1421.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

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

May 2025. See Rev. Rul. 2025-10, page 1421.

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 May 2025. See Rev.

Rul. 2025-10, page 1421.

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

May 2025. See Rev. Rul. 2025-10, page 1421.

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 May 2025. See Rev. Rul.

2025-10, page 1421.

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

May 2025. See Rev. Rul. 2025-10, page 1421.

5.00%

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

May 2025. See Rev. Rul. 2025-10, page 1421.

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

May 2025. See Rev. Rul. 2025-10, page 1421.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of May 2025. See Rev. Rul.

2025-10, page 1421.

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

May 2025. See Rev. Rul. 2025-10, page 1421.

May 5, 2025

1422

Bulletin No. 2025–19

Part III

2025 Marginal Production

Rates

Notice 2025-20

This notice announces the applicable

percentage under § 613A of the Internal

Revenue Code to be used in determining

percentage depletion for marginal proper

ties for the 2025 calendar year.

Section 613A(c)(6)(C) defines the term

“applicable percentage” for purposes of

determining percentage depletion for oil

and gas produced from marginal properties. The applicable percentage is the

percentage (not greater than 25 percent)

equal to the sum of 15 percent, plus one

percentage point for each whole dollar

by which $20 exceeds the reference price

(determined under § 45K(d)(2)(C)) for

crude oil for the calendar year preceding

the calendar year in which the taxable year

begins. The ref

erence price determined

under § 45K(d)(2)(C) for the 2024 calendar year is $74.48. Accordingly, 15% is

the applicable percentage under § 613A to

be used in determining percentage depletion for marginal properties for the 2025

calendar year.

The following table contains the appli

cable percentages for marginal production

for taxable years beginning in calendar

years 1991 through 2025.

Notice 2025-20

Applicable Percentage for Marginal Production

Calendar Year

Applicable Percentage

1991

15 percent

1992

18 percent

1993

19 percent

1994

20 percent

1995

21 percent

1996

20 percent

1997

16 percent

1998

17 percent

1999

24 percent

2000

19 percent

2001

15 percent

2002

15 percent

2003

15 percent

2004

15 percent

2005

15 percent

2006

15 percent

2007

15 percent

2008

15 percent

2009

15 percent

2010

15 percent

2011

15 percent

2012

15 percent

2013

15 percent

2014

15 percent

2015

15 percent

2016

15 percent

2017

15 percent

2018

15 percent

2019

15 percent

2020

15 percent

2021

15 percent

2022

15 percent

2023

15 percent

2024

15 percent

2025

15 percent

Bulletin No. 2025–19

1423

May 5, 2025

The principal author of this notice

is Derek Gimbel of the Office of Associate Chief Counsel (Energy, Credits,

and Excise Tax). For further information

regarding this notice contact Derek Gimbel at 202-317-6853 (not a toll-free number).

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

Notice 2025-21

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the

Internal Revenue Code. In addition, this

notice provides guidance as to the interest rate on 30-year Treasury securities

under § 417(e)(3)(A)(ii)(II) as in effect for

plan years beginning before 2008 and the

30-year Treasury weighted average rate

under § 431(c)(6)(E)(ii)(I).

Applicable Month

April 2025

YIELD CURVE AND SEGMENT

RATES

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC plans

under § 414(y)) pursuant to § 412. Section

430(h)(2) specifies the interest rates that

must be used to determine a plan’s target

normal cost and funding target. Under this

provision, present value is generally determined using three 24-month average interest rates (“segment rates”), each of which

applies to cash flows during specified periods. To the extent provided under § 430(h)

(2)(C)(iv), these segment rates are adjusted

by the applicable percentage of the 25-year

average segment rates for the period ending

September 30 of the year preceding the calendar year in which the plan year begins.1

However, an election may be made under

§ 430(h)(2)(D)(ii) to use the monthly yield

curve in place of the segment rates.

Section 1.430(h)(2)-1(d) provides

rules for determining the monthly corporate bond yield curve,2 and § 1.430(h)

(2)-1(c) provides rules for determining

the 24-month average corporate bond

segment rates used to compute the target normal cost and the funding target.

Consistent with the methodology spec-

ified in § 1.430(h)(2)-1(d), the monthly

corporate bond yield curve derived from

March 2025 data is in Table 2025-3 at the

end of this notice. The spot first, second,

and third segment rates for the month of

March 2025 are, respectively, 4.50, 5.33,

and 5.86.

The 24-month average segment rates

determined under § 430(h)(2)(C)(i)

through (iii) must be adjusted pursuant to

§ 430(h)(2)(C)(iv) to be within the applicable minimum and maximum percentages of the corresponding 25-year average segment rates. Those percentages are

95% and 105% for plan years beginning

in 2024 and 2025. For this purpose, any

25-year average segment rate that is less

than 5% is deemed to be 5%. The 25-year

average segment rates for plan years

beginning in 2024 and 2025 were published in Notice 2023-66, 2023-40 I.R.B.

992 and Notice 2024-67, 2024-41 I.R.B.

726, respectively.

24-MONTH AVERAGE CORPORATE

BOND SEGMENT RATES

The three 24-month average corporate

bond segment rates applicable for April

2025 without adjustment for the 25-year

average segment rate limits are as follows:

24-Month Average Segment Rates Without 25-Year Average Adjustment

First Segment

Second Segment

Third Segment

4.97

5.31

5.51

The adjusted 24-month average segment rates set forth in the chart below

reflect § 430(h)(2)(C)(iv) of the Code. The

24-month averages applicable for April

2025, adjusted to be within the applicable

minimum and maximum percentages of

the corresponding 25-year average segment rates in accordance with § 430(h)(2)

(C)(iv) of the Code, are as follows:

Adjusted 24-Month Average Segment Rates

For Plan Years

Beginning In

Applicable Month

First Segment

Second Segment

Third Segment

2024

April 2025

4.97

5.31

5.59

2025

April 2025

4.97

5.31

5.51

Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount

of the full funding limitation under § 433(c)(7)(C)).

For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts

the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market.

Those enhancements are described in the preamble to TD 9986 (89 FR 2127).

May 5, 2025

1424

Bulletin No. 2025–19

30-YEAR TREASURY SECURITIES

INTEREST RATES

Section 431 specifies the minimum

funding requirements that apply to multiemployer plans pursuant to § 412. Section

431(c)(6)(B) specifies a minimum amount

for the full-funding limitation described in

§ 431(c)(6)(A), based on the plan’s current

liability. Section 431(c)(6)(E)(ii)(I) pro-

vides that the interest rate used to calculate

current liability for this purpose must be

no more than 5 percent above and no more

than 10 percent below the weighted average of the rates of interest on 30-year Treasury securities during the four-year period

ending on the last day before the beginning

of the plan year. Notice 88-73, 1988-2 C.B.

383, provides guidelines for determining

the weighted average interest rate. The

rate of interest on 30-year Treasury securities for March 2025 is 4.60 percent. The

Service determined this rate as the average

of the daily determinations of yield on the

30-year Treasury bond maturing in February 2055. For plan years beginning in April

2025, the weighted average of the rates of

interest on 30-year Treasury securities and

the permissible range of rates used to calculate current liability are as follows:

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

April 2025

3.98

3.58 to 4.18

under § 417(e)(3)(D) are segment rates

computed without regard to a 24-month

average. Section 1.417(e)-1(d)(3) provides guidelines for determining the min-

imum present value segment rates. Pursuant to that section, the minimum present

value segment rates determined for March

2025 are as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

March 2025

Minimum Present Value Segment Rates

First Segment

Second Segment

4.50

5.33

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2025–19

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

1425

Third Segment

5.86

of this guidance. For further information

regarding this notice, contact Mr. Morgan

at 202-317-6700 or Tony Montanaro at

626-927-1475 (not toll-free calls).

May 5, 2025

Table 2025-3

Monthly Yield Curve for March 2025

Derived from March 2025 Data

Maturity

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0

4.5

5.0

5.5

6.0

6.5

7.0

7.5

8.0

8.5

9.0

9.5

10.0

10.5

11.0

11.5

12.0

12.5

13.0

13.5

14.0

14.5

15.0

15.5

16.0

16.5

17.0

17.5

18.0

18.5

19.0

19.5

20.0

Yield

4.46

4.43

4.42

4.44

4.47

4.52

4.57

4.62

4.67

4.73

4.79

4.85

4.91

4.96

5.02

5.07

5.12

5.16

5.21

5.25

5.29

5.33

5.36

5.39

5.42

5.45

5.48

5.50

5.52

5.55

5.57

5.58

5.60

5.62

5.63

5.65

5.66

5.67

5.68

May 5, 2025

Maturity

20.5

21.0

21.5

22.0

22.5

23.0

23.5

24.0

24.5

25.0

25.5

26.0

26.5

27.0

27.5

28.0

28.5

29.0

29.5

30.0

30.5

31.0

31.5

32.0

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

38.0

38.5

39.0

39.5

40.0

Yield

5.69

5.70

5.71

5.72

5.73

5.74

5.75

5.76

5.77

5.78

5.79

5.80

5.81

5.82

5.83

5.84

5.85

5.86

5.87

Maturity

40.5

41.0

41.5

42.0

42.5

43.0

43.5

44.0

44.5

45.0

45.5

46.0

46.5

47.0

47.5

48.0

48.5

49.0

49.5

50.0

50.5

51.0

51.5

52.0

52.5

53.0

53.5

54.0

54.5

55.0

55.5

56.0

56.5

57.0

57.5

58.0

58.5

59.0

59.5

60.0

Yield

5.88

5.89

5.90

5.91

5.92

5.93

5.94

5.95

1426

Maturity

60.5

61.0

61.5

62.0

62.5

63.0

63.5

64.0

64.5

65.0

65.5

66.0

66.5

67.0

67.5

68.0

68.5

69.0

69.5

70.0

70.5

71.0

71.5

72.0

72.5

73.0

73.5

74.0

74.5

75.0

75.5

76.0

76.5

77.0

77.5

78.0

78.5

79.0

79.5

80.0

Yield

5.95

5.96

5.97

5.98

5.99

Maturity

80.5

81.0

81.5

82.0

82.5

83.0

83.5

84.0

84.5

85.0

85.5

86.0

86.5

87.0

87.5

88.0

88.5

89.0

89.5

90.0

90.5

91.0

91.5

92.0

92.5

93.0

93.5

94.0

94.5

95.0

95.5

96.0

96.5

97.0

97.5

98.0

98.5

99.0

99.5

100.0

Yield

5.99

6.00

6.01

Bulletin No. 2025–19

Eliminating Unnecessary

IRS Internal Revenue

Bulletin Guidance

Notice 2025-22

This notice starts the process of eliminating extraneous and unnecessary Internal Revenue Bulletin (IRB) guidance by

identifying and obsoleting nine IRB guidance documents.

BACKGROUND

On February 19, 2025, the President

issued Executive Order 14219, Ensuring

Lawful Governance and Implementing

the President’s ‘Department of Government Efficiency’ Deregulatory Initiative

(Executive Order). The purpose of the

Executive Order includes focusing the

executive branch’s limited enforcement

resources on regulations and other guidance documents “squarely authorized by

constitutional Federal statutes,” eliminating “overbearing and burdensome”

regulations and other guidance documents, and “ending Federal overreach.”

To further these goals, the Executive

Order directs agency heads to coordinate with the Department of Government

Efficiency (DOGE) Team Leads and the

Office of Management and Budget to

identify regulations and other guidance

documents to be eliminated.

Consistent with the Executive Order,

the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS), in conjunction with

DOGE, have undertaken a review of regulations and IRB guidance issued under the

Internal Revenue Code (Code)1 to identify

guidance to be eliminated. This review is

ongoing. In this notice, nine IRB guidance

documents are being obsoleted. These

guidance documents no longer provide

useful information and clarifying their

status as obsolete will streamline administration of the tax laws; reduce the volume of guidance that taxpayers and their

advisors need to review for compliance

with the tax laws; and increase clarity of

the tax law. The Treasury Department and

the IRS anticipate revoking or obsoleting

hundreds of similar guidance documents

in the near future.

GUIDANCE TO BE ELIMINATED

.01 The following document relates to

a listed transaction identified by a notice

issued under § 1.6011-4:

Notice 2015-73, Listing Notice – Basket Option Contracts, 2015-46 IRB 660

(11-16-2015). Notice 2015-73 identifies

as a listed transaction a type of structured

financial transaction in which a taxpayer

attempts to defer and treat ordinary income

and short-term capital gain (earned under

a contract denominated as an option contract that references a basket of securities)

as long-term capital gain. The IRS will no

longer defend this listed transaction notice

in accordance with Action on Decision

2024-1, 2024-52 IRB 1354 (12-24-2024).

.02 The following notice applied to the

Troubled Asset Relief Program, which is

no longer operative:

Notice 2009-49, Guidance Under §

409A(a)(2)(A)(v) on Certain Transactions

Pursuant to the Emergency Economic

Stabilization Act of 2008, 2009-25 IRB

1093 (6-22-2009). This notice provides

that, if the Treasury Department acquires

preferred stock, common stock, warrants

to purchase common stock or other types

of equity of a financial institution or other

entity pursuant to the Emergency Economic Stabilization Act of 2008, Public

Law 110-343, 122 Stat. 3765 (October

3, 2008), then such acquisition is not a

change in control event with respect to

which a payment can be made under a

nonqualified deferred compensation plan

pursuant to § 409A(a)(2)(A)(v).

.03 The following guidance relates to

repealed Code provisions:

(1) Notice 2018-10, Medical Device

Excise Tax Deposit Penalty Relief, 2018-8

IRB 359 (2-20-2018). This notice provides guidance relating to the excise tax

on medical devices imposed by § 4191

by providing temporary relief, for the first

three calendar quarters of 2018, to medical device manufacturers, producers, and

importers from the failure to deposit penalties imposed by § 6656, where the taxpayer demonstrates good faith.

(2) Announcement 2013-23, Taxable

Medical Devices; Correction, 2013-16

IRB 940 (4-15-2013). This document

republishes corrections to final regulations

(T.D. 9604, 2012-52 IRB 730) that provide guidance on the excise tax imposed

on the sale of certain medical devices.

(3) Announcement 2013-19, Taxable

Medical Devices; Correction, 201314 IRB 760 (4-1-2013). This document

republishes corrections to final regulations

(T.D. 9604, 2012-52 IRB 730) that provide guidance on the excise tax imposed

on the sale of certain medical devices.

(4) Notice 2015-16, Excise Tax on

High Cost Employer-Sponsored Health

Coverage, 2015-10 IRB 732 (3-92015). This notice describes potential

approaches with regard to a number of

issues under § 4980I, including the definition of applicable coverage, the determination of the cost of applicable coverage, and the application of the annual

statutory dollar limit to the cost of applicable coverage.

(5) Notice 2015-52, Section 4980l –

Excise Tax on High Cost Employer-Sponsored Health Coverage, 2015-35 IRB 227

(8-31-2015). This notice addresses additional issues under § 4980l, including the

identification of taxpayers who may be

liable for the excise tax, employer aggregation, exclusion from the cost of applicable coverage amounts attributable to the

excise tax, age and gender adjustment to

the dollar limit, the allocation of the tax

among applicable taxpayers, and payment

of the applicable tax.

.04 The following guidance relates to

outdated Code provisions:

Notice 2005-64, Foreign Tax Credit

and Other Guidance Under Section 965,

2005-36 IRB 471 (9-6-2005). This notice

provides guidance on the one-time dividends received deduction under former

§ 965 for certain cash dividends from

controlled foreign corporations that are

invested in the United States, foreign tax

credit and related issues, foreign currency

translation, the alternative minimum tax,

and the credit for prior year minimum tax.

.05 The following guidance relates to a

topic now squarely addressed by amendments made to the Code by Public Law

115-97, 131 Stat. 2054 (December 22,

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

Bulletin No. 2025–19

1427

May 5, 2025

2017), commonly known as the Tax Cuts

and Jobs Act.

Rev. Rul. 91-32, Partnership Effectively Connected Income Lookthrough,

199-20 IRB 20 (5-20-1991). This revenue ruling addresses the United States

tax consequences of the disposition of a

foreign partner’s interest in a domestic or

foreign partnership that conducts a trade

or business through a fixed place of business or has a permanent establishment in

the United States.

EFFECT ON OTHER DOCUMENTS

Notice 2015-73 is obsoleted.

Notice 2009-49 is obsoleted.

Notice 2018-10 is obsoleted.

Announcement 2013-23 is obsoleted.

Announcement 2013-19 is obsoleted.

Notice 2015-16 is obsoleted.

Notice 2015-52 is obsoleted.

Notice 2005-64 is obsoleted.

Rev. Rul. 91-32 is obsoleted.

DRAFTING INFORMATION

This notice was drafted by the Office

of the Associate Chief Counsel (Procedure

and Administration). For further information, contact the Office of the Associate

Chief Counsel (Procedure and Administration) at (202) 317-3400 (not a toll-free

number).

Notice of Intent to Remove

26 CFR 1.6011-18; Waiver

of Penalties under Sections

6707A(a), 6707(a), and

6708; Withdrawal of Notice

2024-54

Notice 2025-23

SECTION 1. PURPOSE

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 NPRM) propos1

ing to remove § 1.6011-181 (Basis Shifting

TOI Regulations) from the Income Tax

Regulations (26 CFR part 1). This notice

provides immediate relief from (i) penalties under § 6707A(a) to participants in

transactions identified as transactions of

interest in the Basis Shifting TOI Regulations that are required to file disclosure

statements under § 6011, and (ii) penalties

under §§ 6707(a) and 6708 for material

advisors to transactions identified as transactions of interest in the Basis Shifting TOI

Regulations that are required to file disclosure statements under § 6111 and maintain

lists under § 6112. Lastly, this notice withdraws Notice 2024-54, 2024-28 I.R.B. 24

(Basis Shifting Notice), which describes

certain proposed regulations that the Treasury Department and the IRS intended to

issue addressing partnership related-party

basis shifting transactions.

SECTION 2. BACKGROUND

On February 19, 2025, the President

issued Executive Order 14219, Ensuring

Lawful Governance and Implementing the

President’s “Department of Government

Efficiency” Deregulatory Initiative (Executive Order 14219). Executive Order 14219

directs agencies to initiate a review process

for the identification and removal of certain

regulations and other guidance that meet any

of the factors set forth in Executive Order

14219. Pursuant to the review directed

by Executive Order 14219, the Treasury

Department and the IRS have identified the

Basis Shifting TOI Regulations for removal

and the Basis Shifting Notice for withdrawal

as described in this notice.

SECTION 3. FORTHCOMING

REMOVAL OF THE BASIS

SHIFTING TOI REGULATIONS

AND RELATED APPLICABILITY

DATES

.01 Effective January 14, 2025, the Basis

Shifting TOI Regulations identify certain

partnership related-party basis adjustment

transactions and substantially similar transactions as transactions of interest. Taxpayers and their material advisors have criticized the Basis Shifting TOI Regulations

as imposing complex, burdensome, and

retroactive disclosure obligations on many

ordinary-course and tax-compliant business activities, creating costly compliance

obligations and uncertainty for businesses.

.02 Pursuant to Executive Order 14219,

the Treasury Department and the IRS have

identified the Basis Shifting TOI Regulations as appropriate for removal and intend

to publish the forthcoming NPRM proposing to remove the Basis Shifting TOI Regulations from 26 CFR part 1. The forthcoming NPRM, when finalized, will obviate the

need for participants and material advisors

to comply with all of the transaction of

interest requirements they would otherwise

be required to follow because of the Basis

Shifting TOI Regulations.

.03 The forthcoming NPRM will have

a proposed applicability date that corresponds with the date this notice is issued

to the public. See § 7805(b)(1)(C).

.04 The forthcoming NPRM will propose that taxpayers and material advisors

may choose to apply the final regulations

retroactively to January 14, 2025, which is

the applicability date of the Basis Shifting

TOI Regulations. See § 7805(b)(7).

.05 Taxpayers and material advisors

may rely on this notice until the forthcoming NPRM is finalized.

SECTION 4. WAIVER OF RELATED

DISCLOSURE STATEMENT

PENALTIES

.01 Participant penalty waiver. Given

the Treasury Department and the IRS’s

intent to propose the removal of the Basis

Shifting TOI Regulations, the IRS will, in

the interest of sound tax administration,

waive penalties under § 6707A(a) for any

failure to file a Form 8886, Reportable

Transaction Disclosure Statement, that is

otherwise required because of the Basis

Shifting TOI Regulations.

.02 Material advisor penalty waiver.

Given the Treasury Department and the

IRS’s intent to propose the removal of the

Basis Shifting TOI Regulations, the IRS

will, in the interest of sound tax administration, waive penalties under § 6707(a)

for any failure to file a Form 8918, Material Advisor Disclosure Statement, and

also will waive penalties under § 6708 for

any failure to maintain a list under § 6112,

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

May 5, 2025

1428

Bulletin No. 2025–19

that is otherwise required because of the

Basis Shifting TOI Regulations.

SECTION 5. WITHDRAWAL OF THE

BASIS SHIFTING NOTICE

The Basis Shifting Notice announced

the Treasury Department and the IRS’s

intention to publish certain proposed regulations addressing partnership related-party

basis shifting transactions. Stakeholders

have stated that the intended proposed

regulations, if finalized, would impose

complex, burdensome, and retroactive

technical rules on many ordinary-course

and tax-compliant business activities, creating costly compliance obligations and

uncertainty for businesses. After the review

directed by Executive Order 14219, the

Basis Shifting Notice is hereby withdrawn.

SECTION 6. EFFECT ON OTHER

DOCUMENTS

Notice 2024-54 is withdrawn.

SECTION 7. DRAFTING

INFORMATION

The principal authors of this notice are

Anthony Sacco, Jeremy Milton, and Elizabeth Zanet of the Office of the Associate

Chief Counsel (Passthroughs, Trusts, and

Estates). For further information regarding this notice contact Mr. Sacco, Mr. Milton, or Ms. Zanet at (202) 317-5279 (not a

toll-free number).

Limited Waiver of Penalties

for Certain Disclosure

Statements for Microcaptive Reportable

Transactions

Notice 2025-24

SECTION 1. PURPOSE

This notice provides relief from penalties under section 6707A(a) of the Internal

Revenue Code (Code)1 to participants in

micro-captive reportable transactions that

fail to file certain disclosure statements

required under section 6011 and § 1.601110(h)(2) or § 1.6011-11(h)(2) by April

14, 2025. This relief applies only if such

participants file the required disclosure

statement with the Office of Tax Shelter

Analysis (OTSA) by July 31, 2025. In

addition, this notice provides relief from

penalties under section 6707(a) for material advisors to certain micro-captive

reportable transactions that are required

under section 6111 and § 1.6011‑10(h)(3)

or § 1.6011-11(h)(3) to file a disclosure

statement with OTSA by April 30, 2025, if

such material advisors file the disclosure

statement with OTSA by July 31, 2025.

The relevant penalties will be waived as

described in section 3 of this notice.

SECTION 2. BACKGROUND

On January 14, 2025, the Department

of the Treasury (Treasury Department)

and the Internal Revenue Service (IRS)

published final regulations under section

6011 (§§ 1.6011-10 and 1.6011-11) in the

Federal Register (TD 10029, 90 FR 3559,

90 FR 3562). Section 1.6011‑10(a) identifies transactions that are the same as, or

substantially similar to, certain micro-captive transactions as listed transactions, a

type of reportable transaction (Micro-captive Listed Transaction). Section 1.601111(a) identifies transactions that are the

same as, or substantially similar to, certain other micro-captive transactions as

transactions of interest, another type of

reportable transaction (Micro-captive

Transaction of Interest). Material advisors

and certain participants in these reportable

transactions are required to file disclosure

statements with the IRS and OTSA and are

subject to penalties if they fail to timely

make such disclosures. In describing the

disclosure obligations for participants and

material advisors, respectively, §§ 1.601110 and 1.6011-11 reference the provisions

of § 1.6011-4(e), for participants, and

§ 301.6111-3, for material advisors.

Generally, § 1.6011-4(e)(1) provides

that the disclosure statement for a reportable transaction must be attached to the

taxpayer’s tax return for each taxable

year for which a taxpayer participates in

a reportable transaction. In addition, a disclosure statement for a reportable transaction must be attached to each amended

return that reflects a taxpayer’s participation in a reportable transaction. A copy of

the disclosure statement must be sent to

OTSA at the same time that any disclosure statement is first filed by the taxpayer

pertaining to a particular reportable transaction.

In addition, § 1.6011-4(e)(2)(i) provides that if a transaction becomes a listed

transaction or a transaction of interest

after the filing of a taxpayer’s tax return

(including an amended return) reflecting

the taxpayer’s participation in the transaction and before the end of the period of

limitations for assessment of tax for any

taxable year in which the taxpayer participated in the transaction, then a disclosure statement must be filed, regardless

of whether the taxpayer participated in

the transaction in the year the transaction

became a listed transaction or a transaction of interest, with OTSA within 90

calendar days after the date on which the

transaction became a listed transaction or

a transaction of interest (Participant Later

Identified Transaction rule). Participants

required to disclose these transactions

pursuant to section 6011 and § 1.6011-4

who fail to do so may be subject to a penalty under section 6707A(a).

Section 301.6111-3(e) provides that a

material advisor’s disclosure statement

for a reportable transaction must be filed

with OTSA by the last day of the month

that follows the end of the calendar quarter in which the advisor became a material advisor with respect to the reportable

transaction or in which the circumstances

necessitating an amended disclosure

statement occur. Section 301.6111-3(b)

(4)(iii) provides that if a transaction that

was not a reportable transaction is identified as a listed transaction or a transaction of interest in published guidance after

the occurrence of the events described in

§ 301.6111-3(b)(4)(i), the person will be

treated as becoming a material advisor

on the date the transaction is identified

as a listed transaction or a transaction of

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

CFR part 301).

Bulletin No. 2025–19

1429

May 5, 2025

interest (Material Advisor Later Identified Transaction rule). Material advisors

required to disclose these transactions

pursuant to section 6111 and § 301.6111-3

who fail to do so may be subject to a penalty under section 6707(a).

Sections 1.6011-10(a) and 1.601111(a) identified certain micro-captive

transactions as Micro-captive Listed

Transactions or Micro-captive Transactions of Interest effective as of January

14, 2025. Consequently, as described in

§§ 1.6011-10(h)(2) and 1.6011-11(h)(2),

participants in transactions identified in

§§ 1.6011-10(a) and 1.6011-11(a) who

filed returns reflecting their participation

in such transactions and for which the

period of limitations for assessment of tax

had not ended on or before January 14,

2025, generally must file initial disclosure statements with OTSA by April 14,

2025, as required by the Participant Later

Identified Transaction rule. The Participant Later Identified Transaction rule may

not apply for taxpayers who have finalized a settlement agreement, as set forth

in §§ 1.6011-10(h)(2) and 1.6011-11(h)

(2). Further, the Participant Later Identified Transaction rule may not apply for

participants in Micro-captive Transactions

of Interest that filed disclosure statements

pursuant to Notice 2016-66, 2016-47

I.R.B. 745, as set forth in § 1.6011-11(h)

(2). As described in §§ 1.6011-10(h)(3)

and 1.6011-11(h)(3), material advisors to

transactions identified in §§ 1.6011-10(a)

and 1.6011-11(a) who made a tax statement on or after January 14, 2019, must

file the required disclosure with OTSA by

April 30, 2025, as required by the Material Advisor Later Identified Transaction

rule. Transactions for which the Participant Later Identified Transaction rule or

Material Advisor Later Identified Transaction rule apply are referred to as “Later

Identified Micro-captive Listed Transactions” and “Later Identified Micro-captive

Transactions of Interest.”

Stakeholders have raised concerns

regarding the ability of micro-captive

reportable transaction participants to

timely comply with their initial filing

obligations with respect to Later Identified Micro-captive Listed Transactions

and Later Identified Micro-captive Trans-

actions of Interest. As further described

in section 3 of this notice, the Treasury

Department and the IRS are providing a

limited waiver of penalties under sections

6707A(a) and 6707(a).

SECTION 3. LIMITED WAIVER OF

PENALTIES

.01 Participant penalty waiver. In light

of potential challenges associated with

preparing disclosure statements during

tax return filing season and in the interest

of sound tax administration, the IRS will

waive penalties under section 6707A(a)

with respect to Later Identified Micro-captive Listed Transaction and Later Identified Micro-captive Transaction of Interest disclosure statements completed in

accordance with § 1.6011-4(d) and the

Instructions to Form 8886, Reportable

Transaction Disclosure Statement, if the

participant files the required disclosure

statement with OTSA by July 31, 2025.

This relief is limited to Later Identified Micro-captive Listed Transactions

and Later Identified Micro-captive Transactions of Interest. This notice does not

provide relief from penalties under section 6707A(a) for participants required to

file a copy of their disclosure statements

with OTSA at the same time the participant first files a disclosure statement by

attaching it to the participant’s tax return

pursuant to § 1.6011-4(e)(1). Taxpayers

concerned about meeting the due date for

such disclosure statements can request

an extension of the due date for their tax

return to obtain additional time to file

such disclosure statements. Disclosures

required from participants with respect

to Micro-captive Listed Transactions and

Micro-captive Transactions of Interest on

or after July 31, 2025, remain due as otherwise set forth in § 1.6011-4(e).

.02 Material advisor penalty waiver.

In light of potential challenges associated with preparing disclosure statements

during tax return filing season and in

the interest of sound tax administration,

the IRS will waive penalties under section 6707(a) with respect to Later Identified Micro-captive Listed Transaction and

Later Identified Micro-captive Transaction of Interest disclosure statements com-

pleted in accordance with § 301.6111-3(d)

and the instructions to Form 8918, Material Advisor Disclosure Statement, if the

material advisor files the required disclosure statement with OTSA by July 31,

2025.

Disclosures required from material

advisors with respect to Micro-captive

Listed Transactions and Micro-captive

Transactions of Interest on or after July

31, 2025, remain due as otherwise set

forth in § 301.6111-3(e). This notice

does not modify any list maintenance

and furnishment obligations of material

advisors as set forth in section 6112 and

§ 301.6112-1.

SECTION 4. DRAFTING

INFORMATION

The principal author of this notice is

Allan H. Sakaue of the Office of Associate

Chief Counsel (Financial Institutions &

Products). For further information regarding this notice contact Mr. Sakaue at (202)

317-6995 (not a toll-free number).

26 CFR 601.601: Rules and Regulations

(Also: Part 1, §§ 25, 143, 6a.103A-1(b)(4),

6a.103A-2(f)(5).)

Rev. Proc. 2025-18

SECTION 1. PURPOSE

This revenue procedure provides

issuers of qualified mortgage bonds, as

defined in § 143(a) of the Internal Revenue Code1, and issuers of mortgage credit

certificates, as defined in § 25(c), with (1)

the nationwide average purchase price for

residences located in the United States,

and (2) average area purchase price safe

harbors for residences located in statistical areas in each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin

Islands, and Guam.

SECTION 2. BACKGROUND

.01 Section 103(a) provides that,

except as provided in § 103(b), gross

Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code or the Temporary Regulations under Title II of the Omnibus Reconciliation Act of

1980 (26 CFR part 6a).

May 5, 2025

1430

Bulletin No. 2025–19

income does not include interest on any

State or local bond. Section 103(b)(1) provides that § 103(a) shall not apply to any

private activity bond that is not a “qualified bond” within the meaning of § 141.

Section 141(e) provides, in part, that the

term “qualified bond” means any private

activity bond if such bond (1) is a qualified mortgage bond under § 143, (2) meets

the volume cap requirements under § 146,

and (3) meets the applicable requirements

under § 147.

.02 Section 143(a)(1) provides that the

term “qualified mortgage bond” means a

bond that is issued as part of a qualified

mortgage issue. Section 143(a)(2)(A) provides that the term “qualified mortgage

issue” means an issue of one or more

bonds by a State or political subdivision thereof, but only if: (i) all proceeds

of the issue (exclusive of issuance costs

and a reasonably required reserve) are to

be used to finance owner-occupied residences; (ii) the issue meets the requirements of subsections (c), (d), (e), (f), (g),

(h), (i), and (m)(7) of § 143; (iii) the issue

does not meet the private business tests

of paragraphs (1) and (2) of § 141(b);

and (iv) with respect to amounts received

more than 10 years after the date of issuance, repayments of $250,000 or more of

principal on mortgage financing provided

by the issue are used by the close of the

first semiannual period beginning after the

date the prepayment (or complete repayment) is received to redeem bonds that are

part of the issue.

Average Area Purchase Price

.03 Section 143(e)(1) provides that an

issue of bonds meets the purchase price

requirements of § 143(e) if the acquisition cost of each residence financed by

the issue does not exceed 90 percent of

the average area purchase price applicable

to such residence. Section 143(e)(5) provides that, in the case of a targeted area

residence (as defined in § 143(j)), § 143(e)

(1) shall be applied by substituting 110

percent for 90 percent.

.04 Section 143(e)(2) provides that the

term “average area purchase price” means,

with respect to any residence, the average

purchase price of single-family residences

(in the statistical area in which the residence is located) that were purchased

Bulletin No. 2025–19

during the most recent 12-month period

for which sufficient statistical information is available. Under §§ 143(e)(3) and

(4), respectively, separate determinations

of average area purchase price are to be

made for new and existing residences,

and for two-, three-, and four-family residences.

.05 Section 143(e)(2) also provides that

the determination of the average area purchase price shall be made as of the date

on which the commitment to provide the

financing is made or, if earlier, the date of

the purchase of the residence.

.06 Section 143(k)(2)(A) provides that

the term “statistical area” means (i) a metropolitan statistical area (MSA), and (ii)

any county (or the portion thereof) that is

not within an MSA. Section 143(k)(2)(C)

further provides that if sufficient recent

statistical information with respect to a

county (or portion thereof) is unavailable,

the Secretary may substitute another area

for which there is sufficient recent statistical information for such county (or portion thereof). In the case of any portion

of a State which is not within a county,

§ 143(k)(2)(D) provides that the Secretary

may designate an area that is the equivalent of a county. Section 6a.103A-1(b)(4)

(i) (issued under § 103A of the Internal

Revenue Code of 1954, the predecessor

of § 143) provides that the term “State”

includes a possession of the United States

and the District of Columbia.

.07 Section 6a.103A-2(f)(5)(i) provides

that an issuer may rely upon the average

area purchase price safe harbors published

by the Department of the Treasury (Treasury Department) for the statistical area

in which a residence is located. Section

6a.103A-2(f)(5)(i) further provides that

an issuer may use an average area purchase price limitation different from the

published safe harbor if the issuer has

more accurate and comprehensive data for

the statistical area.

Qualified Mortgage Credit Certificate

Program

.08 Section 25(c) permits a State or

political subdivision thereof to establish

a qualified mortgage credit certificate

program. In general, a qualified mortgage

credit certificate program is a program

under which the issuing authority elects

1431

not to issue an amount of private activity

bonds that it may otherwise issue during

the calendar year under § 146, and in its

place, issues mortgage credit certificates

to taxpayers in connection with the acquisition of their principal residences. Section 25(a)(1) provides, in general, that the

holder of a mortgage credit certificate may

claim a federal income tax credit equal to

the product of the credit rate specified

in the certificate and the interest paid or

accrued during the tax year on the remaining principal of the indebtedness incurred

to acquire the residence. Section 25(c)(2)

(A)(iii)(III) generally provides that residences acquired in connection with the

issuance of mortgage credit certificates

must meet the purchase price requirements of § 143(e).

Income Limitations for Qualified

Mortgage Bonds and Mortgage Credit

Certificates

.09 Section 143(f) imposes limitations

on the income of mortgagors for whom

financing may be provided by qualified

mortgage bonds. In addition, § 25(c)

(2)(A)(iii)(IV) provides that holders of

mortgage credit certificates must meet

the income requirement of § 143(f).

Generally, under §§ 143(f)(1) and 25(c)

(2)(A)(iii)(IV), the income requirement

is met only if all owner-financing under

a qualified mortgage bond and all mortgage credit certificates issued under a

qualified mortgage credit certificate program are provided to mortgagors whose

family income is 115 percent or less of

the applicable median family income.

Section 143(f)(5), however, generally

provides for an upward adjustment to

the percentage limitation in high housing cost areas. High housing cost areas

are defined in § 143(f)(5)(C) as any statistical area for which the housing cost/

income ratio is greater than 1.2.

.10 Under § 143(f)(5)(D), the housing cost/income ratio with respect to any

statistical area is determined by dividing

(a) the applicable housing price ratio for

such area by (b) the ratio that the area

median gross income for such area bears

to the median gross income for the United

States. The applicable housing price ratio

is the new housing price ratio (new housing average area purchase price divided

May 5, 2025

by the new housing average purchase

price for the United States) or the existing housing price ratio (existing housing

average area purchase price divided by the

existing housing average purchase price

for the United States), whichever results

in the housing cost/income ratio being

closer to 1.

Average Area and Nationwide Purchase

Price Limitations

.11 Average area purchase price safe

harbors for each state, the District of

Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin

Islands, and Guam were last published in

Rev. Proc. 2024-21, 2024-19 I.R.B. 1054.

.12 The nationwide average purchase

price was last published in section 4.02 of

Rev. Proc. 2024-21. Guidance with respect

to the United States and area median gross

income figures that are used in computing

the housing cost/income ratio described in

§ 143(f)(5) was published in Rev. Proc.

2021-19, 2021-15 I.R.B. 1008.

.13 This revenue procedure uses Federal Housing Administration (FHA) loan

limits for a given statistical area to calculate the average area purchase price safe

harbor for that area. FHA sets limits on the

dollar value of loans it will insure based on

median home prices and conforming loan

limits established by the Federal Home

Loan Mortgage Corporation. In particular,

FHA sets an area’s loan limit at 95 percent of the median home sales price for

the area, subject to certain floors and caps

measured against conforming loan limits.

.14 To calculate the average area purchase price safe harbors in this revenue procedure, the FHA loan limits are

adjusted to take into account the differences between average and median purchase prices. Because FHA loan limits do

not differentiate between new and existing

residences, this revenue procedure contains a single average area purchase price

safe harbor for both new and existing residences in a statistical area.

.15 The average area purchase price

safe harbors listed in section 4.01 of this

revenue procedure are based on FHA

loan limits released November 26, 2024.

FHA loan limits are available for statistical areas in each state, the District of

Columbia, Puerto Rico, the Northern Mar-

May 5, 2025

iana Islands, American Samoa, the Virgin

Islands, and Guam. See section 3.03 of

this revenue procedure with respect to

FHA loan limits revised after November

26, 2024.

.16 OMB Bulletin No. 03-04, dated

and effective June 6, 2003, revised the

definitions of the nation’s metropolitan

areas and recognized 49 new MSAs. The

OMB bulletin no longer includes primary

MSAs.

SECTION 3. APPLICATION

Average Area Purchase Price Safe

Harbors

.01 Average area purchase price safe

harbors for statistical areas in each state,

the District of Columbia, Puerto Rico,

the Northern Mariana Islands, American

Samoa, the Virgin Islands, and Guam are

set forth in section 4.01 of this revenue

procedure. Average area purchase price

safe harbors are provided for single-family and two to four-family residences. For

each type of residence, section 4.01 of this

revenue procedure contains a single safe

harbor that may be used for both new and

existing residences. Issuers of qualified

mortgage bonds and issuers of mortgage

credit certificates may rely on these safe

harbors to satisfy the requirements of §§

143(e) and (f). Section 4.01 of this revenue procedure provides safe harbors for

MSAs and for certain counties and county

equivalents. If no purchase price safe harbor is available for a statistical area, the

safe harbor for “ALL OTHER AREAS”

may be used for that statistical area.

.02 If a residence is in an MSA, the safe

harbor applicable to it is the limitation of

that MSA. If an MSA falls in more than

one state, the MSA is listed in section 4.01

of this revenue procedure under each state.

.03 If the FHA revises the FHA loan

limit for any statistical area after November 26, 2024, an issuer of qualified mortgage bonds or mortgage credit certificates

may use the revised FHA loan limit for that

statistical area to compute (as provided in

the next sentence) a revised average area

purchase price safe harbor for the statistical area provided that the issuer maintains

records evidencing the revised FHA loan

limit. The revised average area purchase

price safe harbor for that statistical area

1432

is computed by dividing the revised FHA

loan limit by 0.867.

.04 If, pursuant to § 6a.103A-2(f)(5)(i),

an issuer uses more accurate and comprehensive data to determine the average area

purchase price for a statistical area, the

issuer must make separate average area

purchase price determinations for new

and existing residences. Moreover, when

computing the average area purchase

price for a statistical area that is an MSA,

as defined in OMB Bulletin No. 23-01, the

issuer must make the computation for the

entire applicable MSA. When computing

the average area purchase price for a statistical area that is not an MSA, the issuer

must make the computation for the entire

statistical area and may not combine statistical areas. Thus, for example, the issuer

may not combine two or more counties.

.05 If an issuer receives a ruling permitting it to rely on an average area purchase price limitation that is higher than

the applicable safe harbor in this revenue

procedure, the issuer may rely on that

higher limitation for the purpose of satisfying the requirements of §§ 143(e) and

(f) for bonds sold, and mortgage credit

certificates issued, not more than 30

months following the termination date of

the 12-month period used by the issuer to

compute the limitation.

Nationwide Average Purchase Price

.06 Section 4.02 of this revenue procedure sets forth a single nationwide

average purchase price for purposes of

computing the housing cost/income ratio

under § 143(f)(5).

.07 Issuers must use the nationwide

average purchase price set forth in section 4.02 of this revenue procedure when

computing the housing cost/income ratio

under § 143(f)(5) regardless of whether

they are relying on the average area purchase price safe harbors contained in this

revenue procedure or using more accurate and comprehensive data to determine

average area purchase prices for new and

existing residences for a statistical area

that are different from the published safe

harbors in this revenue procedure.

.08 If, pursuant to section 6.02 of this

revenue procedure, an issuer relies on the

average area purchase price safe harbors

contained in Rev. Proc. 2024-21, the issuer

Bulletin No. 2025–19

must use the nationwide average purchase

price set forth in section 4.02 of Rev. Proc.

2024-21 in computing the housing cost/

income ratio under § 143(f)(5). Likewise,

if, pursuant to section 6.04 of this revenue

procedure, an issuer relies on the nationwide average purchase price published in

Rev. Proc. 2024-21, the issuer must use

the average area purchase price safe harbors set forth in section 4.01 of Rev. Proc.

2024-21 in computing the housing cost/

income ratio under § 143(f)(5).

SECTION 4. AVERAGE AREA

AND NATIONWIDE AVERAGE

PURCHASE PRICES

ties and county equivalents are set forth

below. The safe harbor for “ALL OTHER

AREAS” (found at the end of the table

below) may be used for a statistical area

that is not listed below.

.01 Average area purchase prices for

single-family and two to four-family residences in MSAs, and for certain coun-

2025 Average Area Purchase Prices for Mortgage Revenue Bonds

County Name

ALEUTIANS WEST

HOONAH-ANGOON C

JUNEAU CITY AND

KODIAK ISLAND B

SITKA CITY AND

SKAGWAY MUNICIP

COCONINO

MARICOPA

PINAL

ALAMEDA

CONTRA COSTA

EL DORADO

LOS ANGELES

MARIN

MENDOCINO

MONO

MONTEREY

NAPA

NEVADA

ORANGE

PLACER

RIVERSIDE

SACRAMENTO

SAN BENITO

SAN BERNARDINO

SAN DIEGO

SAN FRANCISCO

SAN JOAQUIN

SAN LUIS OBISPO

SAN MATEO

SANTA BARBARA

SANTA CLARA

SANTA CRUZ

Bulletin No. 2025–19

State

One-Unit

Limit

675,212

604,905

638,068

624,803

676,538

604,905

650,007

630,109

1,395,468

880,826

1,395,468

630,109

895,418

1,119,605

1,173,993

742,866

1,395,468

880,826

776,029

880,826

1,395,468

776,029

1,242,973

1,395,468

782,662

1,115,625

1,395,468

1,053,277

1,395,468

1433

Two-Unit

Limit

864,389

774,357

816,864

799,849

866,061

774,357

832,148

806,655

1,786,771

1,127,622

1,786,771

806,655

1,146,309

1,433,304

1,502,919

951,018

1,786,771

1,127,622

993,467

1,127,622

1,786,771

993,467

1,591,220

1,786,771

1,001,946

1,428,228

1,786,771

1,348,405

1,786,771

Three-Unit

Limit

1,044,857

936,022

987,354

966,821

1,046,875

936,022

1,005,868

975,069

2,159,645

1,363,055

2,159,645

975,069

1,385,606

1,732,526

1,816,675

1,149,538

2,159,645

1,363,055

1,200,870

1,363,055

2,159,645

1,200,870

1,923,434

2,159,645

1,211,136

1,726,355

2,159,645

1,629,921

2,159,645

Four-Unit

Limit

1,298,515

1,163,265

1,227,055

1,201,562

1,301,053

1,163,265

1,250,010

1,211,771

2,684,092

1,693,941

2,684,092

1,211,771

1,721,972

2,153,157

2,257,723

1,428,632

2,684,092

1,693,941

1,492,364

1,693,941

2,684,092

1,492,364

2,390,378

2,684,092

1,505,168

2,145,486

2,684,092

2,025,578

2,684,092

May 5, 2025

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

SOLANO

SONOMA

STANISLAUS

VENTURA

YOLO

ADAMS

ARAPAHOE

BOULDER

BROOMFIELD

CHAFFEE

CLEAR CREEK

DENVER

DOUGLAS

EAGLE

EL PASO

ELBERT

GARFIELD

GILPIN

GRAND

GUNNISON

JEFFERSON

LA PLATA

LARIMER

MONTROSE

OURAY

PARK

PITKIN

ROUTT

SAN MIGUEL

SUMMIT

TELLER

WELD

FAIRFIELD

DISTRICT OF COL

NEW CASTLE

BAKER

BROWARD

CLAY

COLLIER

DUVAL

MANATEE

MARTIN

MIAMI-DADE

790,621

1,034,706

618,170

1,173,993

880,826

961,746

994,909

961,746

769,396

961,746

1,395,468

615,517

961,746

1,395,468

961,746

1,008,175

862,255

961,746

795,927

729,600

866,234

961,746

1,395,468

1,167,360

1,205,830

1,231,034

615,517

650,007

981,644

1,395,468

685,824

669,906

754,804

669,906

882,153

669,906

631,436

688,477

754,804

1,012,154

1,324,642

791,371

1,502,919

1,127,622

1,231,207

1,273,657

1,231,207

984,989

1,231,207

1,786,771

787,968

1,231,207

1,786,771

1,231,207

1,290,671

1,103,859

1,231,207

1,018,902

934,004

1,108,935

1,231,207

1,786,771

1,494,440

1,543,695

1,575,936

787,968

832,148

1,256,700

1,786,771

878,000

857,583

966,302

857,583

1,129,294

857,583

808,328

881,345

966,302

1,223,421

1,601,141

956,555

1,816,675

1,363,055

1,488,269

1,539,600

1,488,269

1,190,604

1,488,269

2,159,645

952,460

1,488,269

2,159,645

1,488,269

1,560,075

1,334,274

1,488,269

1,231,669

1,129,006

1,340,446

1,488,269

2,159,645

1,806,467

1,865,988

1,904,977

952,460

1,005,868

1,519,068

2,159,645

1,061,294

1,036,667

1,167,995

1,036,667

1,365,073

1,036,667

977,087

1,065,389

1,167,995

1,520,452

1,989,876

1,188,816

2,257,723

1,693,941

1,849,551

1,913,340

1,849,551

1,479,618

1,849,551

2,684,092

1,183,682

1,849,551

2,684,092

1,849,551

1,938,833

1,658,182

1,849,551

1,530,661

1,403,082

1,665,853

1,849,551

2,684,092

2,244,977

2,318,975

2,367,423

1,183,682

1,250,010

1,887,790

2,684,092

1,318,932

1,288,307

1,451,587

1,288,307

1,696,479

1,288,307

1,214,308

1,324,008

1,451,587

May 5, 2025

1434

Bulletin No. 2025–19

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

MONROE

NASSAU

OKALOOSA

PALM BEACH

SARASOTA

ST. JOHNS

ST. LUCIE

WALTON

BARROW

BARTOW

BUTTS

CARROLL

CHEROKEE

CLARKE

CLAYTON

COBB

COWETA

DAWSON

DEKALB

DOUGLAS

FAYETTE

FORSYTH

FULTON

GREENE

GWINNETT

HARALSON

HEARD

HENRY

JASPER

LAMAR

MADISON

MERIWETHER

MORGAN

NEWTON

OCONEE

OGLETHORPE

PAULDING

PICKENS

PIKE

ROCKDALE

SPALDING

WALTON

GUAM

1,115,625

669,906

696,436

754,804

631,436

669,906

688,477

696,436

794,601

696,436

794,601

640,722

794,601

696,436

794,601

696,436

794,601

650,007

1,428,228

857,583

891,554

966,302

808,328

857,583

881,345

891,554

1,017,230

891,554

1,017,230

820,209

1,017,230

891,554

1,017,230

891,554

1,017,230

832,148

1,726,355

1,036,667

1,077,674

1,167,995

977,087

1,036,667

1,065,389

1,077,674

1,229,593

1,077,674

1,229,593

991,449

1,229,593

1,077,674

1,229,593

1,077,674

1,229,593

1,005,868

2,145,486

1,288,307

1,339,292

1,451,587

1,214,308

1,288,307

1,324,008

1,339,292

1,528,123

1,339,292

1,528,123

1,232,188

1,528,123

1,339,292

1,528,123

1,339,292

1,528,123

1,250,010

Bulletin No. 2025–19

1435

May 5, 2025

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

HAWAII

HONOLULU

KALAWAO

KAUAI

MAUI

ADA

BLAINE

BOISE

CAMAS

CANYON

GEM

KOOTENAI

OWYHEE

TETON

VALLEY

BARNSTABLE

BRISTOL

DUKES

ESSEX

MIDDLESEX

NANTUCKET

NORFOLK

PLYMOUTH

SUFFOLK

ANNE ARUNDEL

BALTIMORE

BALTIMORE CITY

CALVERT

CARROLL

CECIL

CHARLES

FREDERICK

HARFORD

HOWARD

MONTGOMERY

PRINCE GEORGE'S

QUEEN ANNE'S

CUMBERLAND

SAGADAHOC

YORK

ANOKA

CARVER

CHISAGO

659,293

899,398

1,268,178

1,281,443

1,268,178

676,538

875,520

676,538

875,520

676,538

660,620

676,538

1,395,468

661,946

921,949

848,989

1,395,468

1,054,604

1,395,468

1,054,604

843,683

1,395,468

843,683

685,824

1,395,468

843,683

1,395,468

843,683

692,457

610,211

844,029

1,151,384

1,623,519

1,640,476

1,623,519

866,061

1,120,816

866,061

1,120,816

866,061

845,702

866,061

1,786,771

847,432

1,180,280

1,086,845

1,786,771

1,350,077

1,786,771

1,350,077

1,080,039

1,786,771

1,080,039

878,000

1,786,771

1,080,039

1,786,771

1,080,039

886,479

781,162

1,020,229

1,391,777

1,962,480

1,982,955

1,962,480

1,046,875

1,354,807

1,046,875

1,354,807

1,046,875

1,022,248

1,046,875

2,159,645

1,024,324

1,426,671

1,313,742

2,159,645

1,631,940

2,159,645

1,631,940

1,305,552

2,159,645

1,305,552

1,061,294

2,159,645

1,305,552

2,159,645

1,305,552

1,071,561

944,270

1,267,889

1,729,643

2,438,883

2,464,376

2,438,883

1,301,053

1,683,733

1,301,053

1,683,733

1,301,053

1,270,427

1,301,053

2,684,092

1,272,965

1,773,015

1,632,689

2,684,092

2,028,115

2,684,092

2,028,115

1,622,481

2,684,092

1,622,481

1,318,932

2,684,092

1,622,481

2,684,092

1,622,481

1,331,679

1,173,474

May 5, 2025

1436

Bulletin No. 2025–19

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

DAKOTA

HENNEPIN

ISANTI

LE SUEUR

MILLE LACS

RAMSEY

SCOTT

SHERBURNE

WASHINGTON

WRIGHT

NORTHERN ISLAND

SAIPAN

TINIAN

CARBON

FLATHEAD

GALLATIN

MISSOULA

PARK

STILLWATER

YELLOWSTONE

CAMDEN

CHATHAM

CURRITUCK

DARE

DURHAM

FRANKLIN

GATES

GRANVILLE

JOHNSTON

ORANGE

PASQUOTANK

PERQUIMANS

PERSON

WAKE

DAWSON

GOSPER

HILLSBOROUGH

ROCKINGHAM

STRAFFORD

BERGEN

BURLINGTON

CAMDEN

CAPE MAY

610,211

604,905

610,211

614,191

870,214

660,620

829,091

646,028

650,007

870,214

874,194

729,600

874,194

765,417

729,600

611,538

874,194

729,600

611,538

729,600

928,582

729,600

611,538

696,436

630,109

1,054,604

1,395,468

685,824

769,396

781,162

774,357

781,162

786,296

1,114,010

845,702

1,061,410

827,015

832,148

1,114,010

1,119,143

934,004

1,119,143

979,856

934,004

782,893

1,119,143

934,004

782,893

934,004

1,188,758

934,004

782,893

891,554

806,655

1,350,077

1,786,771

878,000

984,989

944,270

936,022

944,270

950,441

1,346,617

1,022,248

1,283,000

999,696

1,005,868

1,346,617

1,352,788

1,129,006

1,352,788

1,184,432

1,129,006

946,288

1,352,788

1,129,006

946,288

1,129,006

1,436,937

1,129,006

946,288

1,077,674

975,069

1,631,940

2,159,645

1,061,294

1,190,604

1,173,474

1,163,265

1,173,474

1,181,145

1,673,524

1,270,427

1,594,450

1,242,397

1,250,010

1,673,524

1,681,195

1,403,082

1,681,195

1,472,004

1,403,082

1,176,069

1,681,195

1,403,082

1,176,069

1,403,082

1,785,761

1,403,082

1,176,069

1,339,292

1,211,771

2,028,115

2,684,092

1,318,932

1,479,618

Bulletin No. 2025–19

1437

May 5, 2025

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

ESSEX

GLOUCESTER

HUDSON

HUNTERDON

MIDDLESEX

MONMOUTH

MORRIS

OCEAN

PASSAIC

SALEM

SOMERSET

SUSSEX

UNION

LOS ALAMOS

SANTA FE

CARSON CITY

DOUGLAS

STOREY

WASHOE

BRONX

KINGS

NASSAU

NEW YORK

PUTNAM

QUEENS

RICHMOND

ROCKLAND

SUFFOLK

WESTCHESTER

DELAWARE

FAIRFIELD

FRANKLIN

HOCKING

LICKING

MADISON

MORROW

PERRY

PICKAWAY

UNION

BENTON

CLACKAMAS

CLATSOP

COLUMBIA

1,395,468

685,824

1,395,468

685,824

1,395,468

798,581

624,803

663,273

829,091

729,600

1,395,468

656,640

689,804

802,560

647,354

802,560

1,786,771

878,000

1,786,771

878,000

1,786,771

1,022,305

799,849

849,105

1,061,410

934,004

1,786,771

840,626

883,076

1,027,438

828,745

1,027,438

2,159,645

1,061,294

2,159,645

1,061,294

2,159,645

1,235,764

966,821

1,026,400

1,283,000

1,129,006

2,159,645

1,016,134

1,067,408

1,241,935

1,001,715

1,241,935

2,684,092

1,318,932

2,684,092

1,318,932

2,684,092

1,535,736

1,201,562

1,275,560

1,594,450

1,403,082

2,684,092

1,262,756

1,326,546

1,543,407

1,244,934

1,543,407

May 5, 2025

1438

Bulletin No. 2025–19

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

DESCHUTES

HOOD RIVER

MULTNOMAH

WASHINGTON

YAMHILL

BUCKS

CHESTER

DELAWARE

MONTGOMERY

PHILADELPHIA

PIKE

AGUAS BUENAS

AIBONITO

BARCELONETA

BARRANQUITAS

BAYAMON

CAGUAS

CANOVANAS

CAROLINA

CATANO

CAYEY

CEIBA

CIALES

CIDRA

COMERIO

COROZAL

CULEBRA

DORADO

FAJARDO

FLORIDA

GUAYNABO

GURABO

HUMACAO

JUNCOS

LAS PIEDRAS

LOIZA

LUQUILLO

MANATI

MAUNABO

MOROVIS

NAGUABO

NARANJITO

OROCOVIS

822,458

879,500

802,560

685,824

1,395,468

795,927

614,191

795,927

1,052,874

1,125,949

1,027,438

878,000

1,786,771

1,018,902

786,296

1,018,902

1,272,734

1,360,978

1,241,935

1,061,294

2,159,645

1,231,669

950,441

1,231,669

1,581,646

1,691,346

1,543,407

1,318,932

2,684,092

1,530,661

1,181,145

1,530,661

Bulletin No. 2025–19

1439

May 5, 2025

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

RIO GRANDE

SAN JUAN

SAN LORENZO

TOA ALTA

TOA BAJA

TRUJILLO ALTO

VEGA ALTA

VEGA BAJA

YABUCOA

BRISTOL

KENT

NEWPORT

PROVIDENCE

WASHINGTON

BEAUFORT

BERKELEY

CHARLESTON

DORCHESTER

JASPER

LAWRENCE

CANNON

CHEATHAM

DAVIDSON

DICKSON

MACON

MAURY

ROBERTSON

RUTHERFORD

SMITH

SUMNER

TROUSDALE

WILLIAMSON

WILSON

ATASCOSA

BANDERA

BASTROP

BEXAR

CALDWELL

COLLIN

COMAL

DALLAS

DENTON

ELLIS

795,927

848,989

703,069

729,600

703,069

624,803

1,140,829

643,375

659,293

643,375

659,293

650,007

643,375

650,007

1,018,902

1,086,845

900,032

934,004

900,032

799,849

1,460,469

823,612

844,029

823,612

844,029

832,148

823,612

832,148

1,231,669

1,313,742

1,087,941

1,129,006

1,087,941

966,821

1,765,402

995,601

1,020,229

995,601

1,020,229

1,005,868

995,601

1,005,868

1,530,661

1,632,689

1,352,096

1,403,082

1,352,096

1,201,562

2,193,934

1,237,263

1,267,889

1,237,263

1,267,889

1,250,010

1,237,263

1,250,010

May 5, 2025

1440

Bulletin No. 2025–19

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

GUADALUPE

HAYS

HUNT

JOHNSON

KAUFMAN

KENDALL

MEDINA

PARKER

ROCKWALL

TARRANT

TRAVIS

WILLIAMSON

WILSON

WISE

BOX ELDER

DAVIS

GRAND

JUAB

MORGAN

RICH

SALT LAKE

SUMMIT

TOOELE

UTAH

WASATCH

WASHINGTON

WAYNE

WEBER

ALBEMARLE

ALEXANDRIA CITY

AMELIA

ARLINGTON

CHARLES CITY

CHARLOTTESVILLE

CHESAPEAKE CITY

CHESTERFIELD

CLARKE

COLONIAL HEIGHT

CULPEPER

DINWIDDIE

FAIRFAX

FAIRFAX CITY

FALLS CHURCH CI

643,375

659,293

650,007

643,375

650,007

659,293

643,375

650,007

858,275

818,479

693,783

858,275

668,579

725,620

1,342,464

725,620

693,783

1,342,464

684,498

1,150,115

858,275

683,171

1,395,468

777,356

1,395,468

777,356

683,171

874,194

777,356

1,395,468

777,356

1,395,468

777,356

1,395,468

823,612

844,029

832,148

823,612

832,148

844,029

823,612

832,148

1,098,726

1,047,798

888,151

1,098,726

855,910

928,928

1,718,626

928,928

888,151

1,718,626

876,270

1,472,350

1,098,726

874,597

1,786,771

995,140

1,786,771

995,140

874,597

1,119,143

995,140

1,786,771

995,140

1,786,771

995,140

1,786,771

995,601

1,020,229

1,005,868

995,601

1,005,868

1,020,229

995,601

1,005,868

1,328,161

1,266,563

1,073,579

1,328,161

1,034,590

1,122,834

2,077,428

1,122,834

1,073,579

2,077,428

1,059,218

1,779,763

1,328,161

1,057,142

2,159,645

1,202,889

2,159,645

1,202,889

1,057,142

1,352,788

1,202,889

2,159,645

1,202,889

2,159,645

1,202,889

2,159,645

1,237,263

1,267,889

1,250,010

1,237,263

1,250,010

1,267,889

1,237,263

1,250,010

1,650,569

1,574,033

1,334,217

1,650,569

1,285,769

1,395,468

2,581,746

1,395,468

1,334,217

2,581,746

1,316,337

2,211,813

1,650,569

1,313,799

2,684,092

1,494,959

2,684,092

1,494,959

1,313,799

1,681,195

1,494,959

2,684,092

1,494,959

2,684,092

1,494,959

2,684,092

Bulletin No. 2025–19

1441

May 5, 2025

County Name

State

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

FAUQUIER

FLUVANNA

FRANKLIN CITY

FREDERICKSBURG

GLOUCESTER

GOOCHLAND

GREENE

HAMPTON CITY

HANOVER

HENRICO

HOPEWELL CITY

ISLE OF WIGHT

JAMES CITY

KING AND QUEEN

KING WILLIAM

LOUDOUN

MADISON

MANASSAS CITY

MANASSAS PARK C

MATHEWS

NELSON

NEW KENT

NEWPORT NEWS CI

NORFOLK CITY

PETERSBURG CITY

POQUOSON CITY

PORTSMOUTH CITY

POWHATAN

PRINCE GEORGE

PRINCE WILLIAM

RAPPAHANNOCK

RICHMOND CITY

SOUTHAMPTON

SPOTSYLVANIA

STAFFORD

SUFFOLK CITY

SUSSEX

VIRGINIA BEACH

WARREN

WILLIAMSBURG CI

YORK

ST. JOHN ISLAND

ST. THOMAS ISLA

1,395,468

683,171

874,194

1,395,468

874,194

777,356

683,171

874,194

777,356

874,194

777,356

1,395,468

874,194

683,171

777,356

874,194

777,356

874,194

777,356

1,395,468

777,356

874,194

1,395,468

874,194

777,356

874,194

1,395,468

874,194

1,285,423

776,029

1,786,771

874,597

1,119,143

1,786,771

1,119,143

995,140

874,597

1,119,143

995,140

1,119,143

995,140

1,786,771

1,119,143

874,597

995,140

1,119,143

995,140

1,119,143

995,140

1,786,771

995,140

1,119,143

1,786,771

1,119,143

995,140

1,119,143

1,786,771

1,119,143

1,645,609

993,467

2,159,645

1,057,142

1,352,788

2,159,645

1,352,788

1,202,889

1,057,142

1,352,788

1,202,889

1,352,788

1,202,889

2,159,645

1,352,788

1,057,142

1,202,889

1,352,788

1,202,889

1,352,788

1,202,889

2,159,645

1,202,889

1,352,788

2,159,645

1,352,788

1,202,889

1,352,788

2,159,645

1,352,788

1,989,126

1,200,870

2,684,092

1,313,799

1,681,195

2,684,092

1,681,195

1,494,959

1,313,799

1,681,195

1,494,959

1,681,195

1,494,959

2,684,092

1,681,195

1,313,799

1,494,959

1,681,195

1,494,959

1,681,195

1,494,959

2,684,092

1,494,959

1,681,195

2,684,092

1,681,195

1,494,959

1,681,195

2,684,092

1,681,195

2,472,047

1,492,364

May 5, 2025

1442

Bulletin No. 2025–19

County Name

State

CHITTENDEN

FRANKLIN

GRAND ISLE

CHELAN

CLARK

DOUGLAS

ISLAND

KING

KITSAP

PIERCE

SKAGIT

SKAMANIA

SNOHOMISH

THURSTON

WHATCOM

WHITMAN

PIERCE

ST. CROIX

JEFFERSON

TETON

All other areas – 2,794 counties (floor):

.02 The nationwide average purchase

price (for use in the housing cost/income

ratio for new and existing residences) is

$540,700.

SECTION 5. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 2024-21 is obsolete except

as provided in section 6 of this revenue

procedure.

SECTION 6. EFFECTIVE DATES

.01 Issuers may rely on this revenue

procedure to determine average area

purchase price safe harbors for commitments to provide financing or issue

mortgage credit certificates that are

made, or (if the purchase precedes the

commitment) for residences that are

purchased, in the period that begins on

April 16, 2025, and ends on the date as

of which the safe harbors contained in

section 4.01 of this revenue procedure

Bulletin No. 2025–19

One-Unit

Limit

Two-Unit

Limit

Three-Unit

Limit

Four-Unit

Limit

663,273

630,109

802,560

630,109

696,436

1,196,544

663,273

1,196,544

650,007

802,560

1,196,544

643,375

729,600

668,579

610,211

1,395,468

$604,703

849,105

806,655

1,027,438

806,655

891,554

1,531,814

849,105

1,531,814

832,148

1,027,438

1,531,814

823,612

934,004

855,910

781,162

1,786,771

$774,241

1,026,400

975,069

1,241,935

975,069

1,077,674

1,851,627

1,026,400

1,851,627

1,005,868

1,241,935

1,851,627

995,601

1,129,006

1,034,590

944,270

2,159,645

$935,820

1,275,560

1,211,771

1,543,407

1,211,771

1,339,292

2,301,095

1,275,560

2,301,095

1,250,010

1,543,407

2,301,095

1,237,263

1,403,082

1,285,769

1,173,474

2,684,092

are rendered obsolete by a new revenue

procedure.

.02 Notwithstanding section 5 of this

revenue procedure, issuers may continue

to rely on the average area purchase price

safe harbors contained in Rev. Proc. 202421, with respect to bonds sold, or for mortgage credit certificates issued with respect

to bond authority exchanged, before May

16, 2025, if the commitments to provide

financing or issue mortgage credit certificates are made on or before June 15, 2025.

.03 Except as provided in section 6.04

of this revenue procedure, issuers must

use the nationwide average purchase price

limitation contained in this revenue procedure for commitments to provide financing or issue mortgage credit certificates

that are made, or (if the purchase precedes

the commitment) for residences that are

purchased, in the period that begins on

April 16, 2025, and ends on the date when

the nationwide average purchase price

limitation is rendered obsolete by a new

revenue procedure.

1443

$1,163,092

.04 Notwithstanding sections 5 and

6.03 of this revenue procedure, issuers

may continue to rely on the nationwide

average purchase price set forth in Rev.

Proc. 2024-21 with respect to bonds sold,

or for mortgage credit certificates issued

with respect to bond authority exchanged,

before May 16, 2025, if the commitments

to provide financing or issue mortgage

credit certificates are made on or before

June 15, 2025.

SECTION 7. PRIOR COMMENTS

RECEIVED

In Section 7 of Rev. Proc. 2024-21,

the Treasury Department and the Internal

Revenue Service (IRS) requested comments for alternate data sources to calculate average area purchase prices. The

Treasury Department and the IRS have

reviewed all received comments and have

determined that no changes to the data or

the methodology for calculating average

area purchase prices will be made.

May 5, 2025

SECTION 8. PAPERWORK

REDUCTION ACT

The collection of information contained in this revenue procedure has been

reviewed and approved by the Office of

Management and Budget in accordance

with the Paperwork Reduction Act (44

U.S.C. 3507) under control number 15451877.

An agency may not conduct or sponsor,

and a person is not required to respond

to, a collection of information unless the

collection of information displays a valid

OMB control number.

Section 3.03 of this revenue procedure contains a collection of information

requirement. The purpose of the collection

of information is to verify the applicable

May 5, 2025

FHA loan limit that issuers of qualified

mortgage bonds and qualified mortgage

certificates have used to calculate the

average area purchase price for a given

MSA for purposes of §§ 143(e) and 25(c).

The collection of information is required

to obtain the benefit of using revisions to

FHA loan limits to determine average area

purchase prices. The likely respondents

are state and local governments.

The estimated total annual reporting

and/or recordkeeping burden is: 15 hours.

The estimated annual burden per

respondent and/or recordkeeper: 15 minutes.

The estimated number of respondents

and/or recordkeepers: 60.

Books or records relating to a collection of information must be retained as

1444

long as their contents may become material in the administration of any internal

revenue law. Generally, tax returns and

tax return information are confidential, as

required by 26 U.S.C. 6103.

SECTION 9. DRAFTING

INFORMATION

The principal authors of this revenue

procedure are Zoran Stojanovic and Elena

Hildebrandt of the Office of Associate

Chief Counsel (Financial Institutions &

Products). For further information regarding this revenue procedure contact Ms.

Hildebrandt at (202) 317-4565 (not a tollfree number).

Bulletin No. 2025–19

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. 2025–19

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.

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.

May 5, 2025

Numerical Finding List1

Bulletin 2025–19

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

2025-15, 2025-18 I.R.B. 1420

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

2025-20, 2025-19 I.R.B. 1423

2025-21, 2025-19 I.R.B. 1424

2025-22, 2025-19 I.R.B. 1427

2025-23, 2025-19 I.R.B. 1428

2025-24, 2025-19 I.R.B. 1429

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:

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

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

2025-18, 2025-19 I.R.B. 1430

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

2025-10, 2025-19 I.R.B. 1421

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

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.

May 5, 2025

Bulletin No. 2025–19

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–19

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.

Bulletin No. 2025–19

iii

May 5, 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

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.