These synopses are intended only as aids to the reader in

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–2

January 6, 2025

These synopses are intended only as aids to the reader in

identifying the subject matter covered. They may not be

relied upon as authoritative interpretations.

ADMINISTRATIVE

Announcement 2025-3, page 306.

This announcement amends the announcement number of

Announcement 2024-39, 2024-39 I.R.B. 639, to Announcement 2024-33 by correcting several administrative references.

EMPLOYEE PLANS, EXCISE TAX,

INCOME TAX

Announcement 2025-2, page 305.

On July 19, 2024, the Treasury Department and the

IRS published proposed regulations regarding required

minimum distributions (RMDs) under section 401(a)(9)

Finding Lists begin on page ii.

of the Internal Revenue Code and related provisions in

the Federal Register (89 FR 58644). The proposed regulations were generally proposed to apply for purposes

of determining RMDs for calendar years beginning on or

after January 1, 2025. This announcement provides that

the Treasury Department and the IRS anticipate that certain portions of future regulations finalizing the proposed

regulations will apply beginning in the 2026 distribution

calendar year.

INCOME TAX

Announcement 2025-4, page 306.

This announcement corrects the publication of TD 10015

to add information about the Federal Register filing date

and publication information.

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.

January 6, 2025 

Bulletin No. 2025–2

Part III

Anticipated Applicability

Date for Future Final

Regulations Relating

to Required Minimum

Distributions

Announcement 2025-2

I. PURPOSE

This announcement provides that the

Department of the Treasury (Treasury

Department) and the Internal Revenue

Service (IRS) anticipate that certain portions of future final regulations relating to

required minimum distributions (RMDs)

under section 401(a)(9) of the Internal

Revenue Code (Code) will apply no earlier than the 2026 distribution calendar

year.

II. BACKGROUND

Section 401(a)(9) of the Code requires

a stock bonus, pension, or profit-sharing plan described in section 401(a) (or

an annuity contract described in section

403(a)) to make minimum distributions

starting by the required beginning date

(as well as minimum distributions to

beneficiaries if the employee dies before

the required beginning date). Individual

retirement accounts and individual retirement annuities described in section 408(a)

and (b), respectively, annuity contracts,

custodial accounts, and retirement income

accounts described in section 403(b),

and eligible deferred compensation plans

under section 457(b) are also subject to

the rules of section 401(a)(9) pursuant to

sections 408(a)(6) and (b)(3), 403(b)(10),

and 457(d)(2), respectively, and the regulations under those sections.

The Treasury Department and the IRS

published proposed regulations regarding

RMDs under section 401(a)(9) and related

Bulletin No. 2025–2

provisions in the Federal Register on February 24, 2022 (87 FR 10504). The 2022

proposed regulations reflected changes

made by the Setting Every Community

Up for Retirement Enhancement Act of

2019 (SECURE Act), enacted on December 20, 2019, as Division O of the Further

Consolidated Appropriations Act, 2020,

Pub. L. 116-94, 133 Stat. 2534 (2019),

and also included a comprehensive update

and restatement of the regulations under

section 401(a)(9).

After the 2022 proposed regulations

were issued, the SECURE 2.0 Act of 2022

(SECURE 2.0 Act) was enacted as Division T of the Consolidated Appropriations

Act, 2023, Pub. L. 117-328, 136 Stat. 4459

(2022). The SECURE 2.0 Act included a

number of provisions relating to RMDs.

After considering the comments received

in response to the 2022 proposed regulations and reviewing the changes made in

the SECURE 2.0 Act, the Treasury Department and the IRS determined that certain

of those changes could be included in final

regulations, but that other changes should

be addressed in new proposed regulations.

Accordingly, on July 19, 2024, the Treasury Department and the IRS published

final regulations regarding RMDs under

section 401(a)(9) and related provisions

in the Federal Register (89 FR 58886) and

also published proposed regulations under

section 401(a)(9) and related provisions

(89 FR 58644).

With the exception of proposed

§ 1.401(a)(9)-5(a)(5)(v) (relating to the

valuation of an annuity contract under

the partial annuitization option provided

for in section 204 of the SECURE 2.0

Act), the provisions of the 2024 proposed

regulations were proposed to apply for

purposes of determining RMDs for calendar years beginning on or after January 1, 2025 (so that they would begin to

apply at the same time as the 2024 final

regulations). In written comments and

at the public hearing held on Septem-

305

ber 25, 2024, commenters raised issues

regarding some of the provisions of the

proposed regulations. Commenters were

also concerned that it would be difficult

to implement many of the provisions of

the future final regulations in a timely

manner if the January 1, 2025, applicability date set forth in the 2024 proposed

regulations is retained in the final regulations. Commenters said that this difficulty arises from the expected timing of

the future final regulations along with

the uncertainty regarding the resolution

of issues commenters raised. Commenters expressed specific concerns with the

challenges of implementing the final

regulations to be adopted pursuant to the

proposed amendments to §§ 1.401(a)(9)4, 1.401(a)(9)-5, and 1.401(a)(9)-6.

III. ANTICIPATED APPLICABILITY

DATE OF FUTURE FINAL

REGULATIONS

In response to concerns raised by commenters, the provisions of future final

regulations amending §§ 1.401(a)(9)-4,

1.401(a)(9)-5, and 1.401(a)(9)-6 to be

issued pursuant to the 2024 proposed regulations are anticipated to apply beginning

in the 2026 distribution calendar year. For

periods before the applicability date of

these amendments, taxpayers must apply

a reasonable, good-faith interpretation of

the statutory provisions underlying the

amendments.

IV. DRAFTING INFORMATION

The principal author of this announcement is Jessica Weinberger of the Office of

Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). For further information

regarding this announcement, contact Ms.

Weinberger at 202-317-6349 (not a tollfree number).

January 6, 2025

Correction to

Announcement 2024-39,

I.R.B. 2024-39

The correct article number is Announcement 2024-33.

Announcement 2025-3

On Page 639, the article number incorrectly appears as Announcement 2024-39.

Announcement 2024-39, 2024-39 I.R.B.

639 (Sept. 23, 2024), was incorrectly

numbered. This announcement amends

the announcement number to Announcement 2024-33 by correcting the following

administrative items.

The correct article number is Announcement 2024-33.

Correction 1:

In Highlights of This Issue, the article

number incorrectly appears as Announcement 2024-39.

January 6, 2025

Correction 2:

Correction 3:

On Page ii, Numerical Finding List, the

article number incorrectly appears under

Announcements: as 2024-39. The correct

article number is 2024-33.

Correction to TD 10015,

IRB 2024-52

Announcement 2025-04

This document contains a correction to TD

10015, as published on Monday, December 23, 2024 (I.R.B. 2024-52, 1355). In

particular, this announcement corrects the

following administrative item.

Correction 1:

In the filing information found at the end

of the document on page 1424, the filing

dates and Federal Register publication

information are omitted. It should state:

(Filed by the Office of the Federal Register December 04, 2024, and published in the issue of the Federal Register for December 12, 2024, 89 FR 100598)

306

Bulletin No. 2025–2

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. 2025–2

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.

January 6, 2025

Numerical Finding List1

Bulletin 2025–2

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

Revenue Procedures:

2025-1, 2025-01 I.R.B. 1

2025-2, 2025-01 I.R.B. 118

2025-3, 2025-01 I.R.B. 142

2025-4, 2025-01 I.R.B. 158

2025-5, 2025-01 I.R.B. 260

2025-7, 2025-01 I.R.B. 301

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

2024–52, dated December 23, 2024.

1

January 6, 2025

ii

Bulletin No. 2025–2

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–2

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

2024–52, dated December 23, 2024.

1

Bulletin No. 2025–2

iii

January 6, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

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