These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

REG-129260-16, page 410.

This document withdraws REG-129260-16, an NPRM published in the Federal Register on March 13, 2018, that proposed regulations under IRC section 6103(n).

Finding Lists begin on page ii.





Bulletin No. 2025–39

September 22, 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 Unpublished rulings will not be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.

September 22, 2025 

Bulletin No. 2025–39

Part IV

Notice of Proposed

Rulemaking

Disclosure of Returns

and Return Information in

Connection with Written

Contracts or Agreements

for the Acquisition of

Property or Services

for Tax Administration

Purposes; Withdrawal

REG-129260-16

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Withdrawal of notice of proposed rulemaking.

SUMMARY: This document withdraws

a notice of proposed rulemaking that has

been determined to be unnecessary. The

notice of proposed rulemaking proposed

to authorize the Department of State (State

Department) to disclose returns and return

information to its contractors who assist

the State Department in carrying out certain responsibilities related to revoking or

denying a passport of any individual certified to have a seriously delinquent tax debt.

DATES: The notice of proposed rulemaking that was published in the Federal Register on March 13, 2018, is withdrawn as

of September 3, 2025.

FOR FURTHER INFORMATION

CONTACT: Alexander Wu of the Office

of Associate Chief Counsel (Procedure

and Administration), (202) 317-6845 (not

a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

Section 7345 of the Internal Revenue

Code (Code), which was added to the

Code by section 32101(a) of the Fixing

America’s Surface Transportation (FAST)

September 22, 2025

Act, Public Law 114-94, 129 Stat. 1312

(2015), requires the IRS to notify the State

Department about any tax debt of an individual that the IRS certifies as seriously

delinquent. Section 32101(e) of the FAST

Act requires the State Department to deny

such individual a passport (or the renewal

of a passport) if the IRS notifies the State

Department that the individual has been

certified as having a seriously delinquent

tax debt. Section 32101(e) of the FAST

Act also permits the State Department

to revoke a passport previously issued to

such person. The State Department procures services from outside contractors in

connection with carrying out its responsibilities under the FAST Act.

Under section 6103(a) of the Code,

returns and return information are confidential unless the Code otherwise authorizes disclosure. Section 6103(n) authorizes, pursuant to regulations prescribed

by the Secretary of the Treasury or the

Secretary’s delegate (Secretary), the disclosure of returns and return information

to any person for purposes of tax administration to the extent necessary in connection with, among other things, a written

contract for services. Section 6103(b)(4)

defines the term “tax administration” to

include “the administration, management,

conduct, direction, and supervision of the

execution and application of the internal

revenue laws or related statutes.” Because

implementation of the FAST Act relates to

the administration, management, conduct,

direction, and supervision of the execution and application of the internal revenue laws and related statutes, disclosure of

return information for the purpose of carrying out responsibilities under the FAST

Act is a tax administration purpose.

On March 13, 2018, the Department of

the Treasury (Treasury Department) and

the IRS published a notice of proposed

rulemaking in the Federal Register (83

FR 10811) containing proposed regulations that would add the State Department

to the list of agencies in §301.6103(n)-1(a)

(1) whose officers and employees may disclose returns and return information to any

person or to an officer or employee of such

person for tax administration purposes to

the extent necessary in connection with a

written contract for the acquisition of prop-

410

erty or services. The proposed regulations

would authorize the State Department to

disclose returns and return information to

its contractors providing services in connection with the revocation or denial of

passports pursuant to the requirements of

the FAST Act and section 7345.

The proposed regulations are unnecessary because the State Department is already

authorized under §301.6103(n)-1(a)(2)(ii)

to disclose returns and return information

to its contractors providing services in

connection with the revocation or denial

of passports pursuant to the FAST Act and

section 7345, so long as the IRS authorizes

the disclosure in writing and the disclosure conforms to the other provisions of

§301.6103(n)-1. Under §301.6103(n)-1(a)

(2)(ii), if an officer or employee of the Treasury Department has disclosed returns or

return information to the State Department

for purposes of the provision of services in

furtherance of tax administration, then the

State Department may further disclose the

returns or return information, when authorized in writing by the IRS, to the extent

necessary to carry out the tax administration purpose. Under §301.6103(n)-1(a)(2)

(ii), such further disclosures may include

disclosures to an agent or subcontractor of

the person, or officer or employee of the

agent or subcontractor.

List of Subjects in 26 CFR Part 301

Employment taxes, Estate taxes, Excise

taxes, Gift taxes, Income taxes, Penalties,

Reporting and recordkeeping requirements.

Withdrawal of Notice of Proposed

Rulemaking

Under the authority of 26 U.S.C. 7805,

the notice of proposed rulemaking (REG129260-16) published in the Federal Register on March 13, 2018 (83 FR 10811) is

withdrawn.

Edward T. Killen,

Acting Chief Tax Compliance Officer.

(Filed by the Office of the Federal Register September 2, 2025, 8:45 a.m., and published in the issue of

the Federal Register for September 3, 2025, 90 FR

42551)

Bulletin No. 2025–39

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. 2025–39

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.

September 22, 2025

Numerical Finding List1

Bulletin 2025–39

Announcements:

2025-19, 2025-29 I.R.B. 191

2025-20, 2025-31 I.R.B. 271

2025-21, 2025-32 I.R.B. 312

2025-24, 2025-36 I.R.B. 359

2025-25, 2025-36 I.R.B. 360

Notices:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Proposed Regulations:

REG-125710-18, 2025-30 I.R.B. 263

REG-107459-24, 2025-32 I.R.B. 313

REG-132805-17, 2025-35 I.R.B. 342

REG-108822-25, 2025-36 I.R.B. 361

REG-129260-16, 2025-39 I.R.B. 410

Revenue Procedures:

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

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

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

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

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

Revenue Rulings:

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

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

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

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

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

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

Treasury Decisions:

10021, 2025-31 I.R.B. 264

10031, 2025-32 I.R.B. 304

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

2025–52, dated December 22, 2025.

1

September 22, 2025

ii

Bulletin No. 2025–39

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–39

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

2025–52, dated December 22, 2025.

1

Bulletin No. 2025–39

iii

September 22, 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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