Bulletin No. 2025–27

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HIGHLIGHTS

OF THIS ISSUE

Bulletin No. 2025–27

June 30, 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

Notice 2025-33, page 4.

This notice extends the transitional relief from backup withholding taxes and associated penalties in Notice 2024-56 for

any broker that fails to withhold and pay the backup withholding tax for: (1) any sale of a digital asset effected by a broker

during calendar year 2026; and, (2) any sale of a digital asset

effected by a broker during calendar year 2027 for a customer, if the broker submits that customer’s name and tax

identification number (TIN) combination to the IRS’s TIN Matching Program and receives a response that the name and TIN

combination matches IRS records. This notice also extends

the transitional relief from penalties in Notice 2024-56 for

brokers who fail to backup withhold and pay the full backup

withholding tax due, if such failure is due to a decrease in

the value of withheld digital assets in a sale of digital assets

in return for different digital assets effected during calendar

year 2027, and the broker immediately liquidates the withheld

digital assets for cash. Finally, this notice also provides new

transitional relief from information reporting penalties and

from backup withholding taxes and associated penalties for

any sale of a digital asset effected by a broker during calendar

year 2027 for certain customers that have not been previously classified by the broker as U.S. persons.

ADMINISTRATIVE

Notice 2025-35, page 8.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment rates

Finding Lists begin on page ii.

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

average segment rates applicable for June 2025, and the

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

§ 430(h)(2)(C)(iv).

INCOME TAX

Notice 2025-32, page 1.

The notice announces the inflation adjustment factor and

phase-out amount for the enhanced oil recovery credit for

taxable years beginning in the 2025 calendar year. The

notice concludes that because the reference price for the

2024 calendar year ($74.48) exceeds $28 multiplied by the

inflation adjustment factor for the 2025 calendar year ($28

multiplied by 2.1115 = $59.12) by $15.36, the enhanced oil

recovery credit for qualified costs paid or incurred in 2025 is

phased-out completely.

Notice 2025-34, page 6.

The notice provides the applicable reference price for qualified natural gas production from qualified marginal wells

during taxable years beginning in calendar year 2025 for

the purpose of determining the marginal well production

credit under IRC § 45I. The applicable reference price for

taxable years beginning in calendar year 2025 is $1.64

per 1,000 cubic feet. The notice also provides the credit

amount used for the purpose of determining the marginal

well production credit. The credit amount for taxable years

beginning in calendar year 2025 is $0.79 per 1,000 cubic

feet.

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.

June 30, 2025

Bulletin No. 2025–27

Part III

2025 Section 43 Inflation

Adjustment

Notice 2025-32

Section 43(a) of the Internal Revenue

Code provides that for purposes of section 38, the enhanced oil recovery credit

for any taxable year is an amount equal

to 15 percent of the taxpayer’s qualified

enhanced oil recovery costs for such taxable year.

Section 43(b)(1) provides that the

amount of the credit determined under

subsection (a) for any taxable year shall

be reduced by an amount which bears the

same ratio to the amount of such credit

(determined without regard to this paragraph) as — (A) the amount by which

the reference price for the calendar year

preceding the calendar year in which the

taxable years begins exceeds $28, bears to

(B) $6.

Section 43(b)(3)(B) requires the Secretary to publish an inflation adjustment

factor. The enhanced oil recovery credit

under § 43 for any taxable year is reduced

if the “reference price,” determined under

§ 45K(d)(2)(C), for the calendar year preceding the calendar year in which the taxable year begins is greater than $28 multiplied by the inflation adjustment factor for

the current calendar year.

The term “inflation adjustment factor”

means, with respect to any calendar year,

a fraction the numerator of which is the

GNP implicit price deflator for the preceding calendar year and the denominator of

which is the GNP implicit price deflator

for 1990.

Because the reference price for the

2024 calendar year ($74.48) exceeds $28

multiplied by the inflation adjustment factor for the 2025 calendar year ($28 multiplied by 2.1115 = $59.12) by $15.36, the

enhanced oil recovery credit for qualified

costs paid or incurred in 2025 is phased

out completely.

Table 1 contains the GNP implicit price

deflator used for the 2024 calendar year,

as well as the previously published GNP

implicit price deflators used for the 1991

through 2023 calendar years.

Notice 2025-32 TABLE 1

GNP IMPLICIT PRICE DEFLATORS

Calendar Year

GNP Implicit Price Deflator

1990

112.9

(used for 1991)

1991

117.0

(used for 1992)

1992

120.9

(used for 1993)

1993

124.1

(used for 1994)

1994

126.0

(used for 1995)*

1995

107.5

(used for 1996)

1996

109.7

(used for 1997)**

1997

112.35 (used for 1998)

1998

112.64 (used for 1999)***

1999

104.59 (used for 2000)

2000

106.89 (used for 2001)

2001

109.31 (used for 2002)

2002

110.63 (used for 2003)

2003

105.67 (used for 2004)****

2004

108.23 (used for 2005)

2005

112.129 (used for 2006)

2006

116.036 (used for 2007)

2007

119.656 (used for 2008)

2008

122.407 (used for 2009)

2009

109.764 (used for 2010)*****

2010

110.654 (used for 2011)

2011

113.347 (used for 2012)******

2012

115.387 (used for 2013)

2013

106.710 (used for 2014)*******

Bulletin No. 2025–27

June 30, 2025

Notice 2025-32 TABLE 1

GNP IMPLICIT PRICE DEFLATORS

Calendar Year

GNP Implicit Price Deflator

2014

108.407 (used for 2015)********

2015

109.868 (used for 2016)

2016

111.528 (used for 2017)

2017

113.500 (used for 2018)

2018

110.308 (used for 2019)*********

2019

112.257 (used for 2020)

2020

113.586 (used for 2021)

2021

118.586 (used for 2022)**********

2022

127.194 (used for 2023)

2023

122.179 (used for 2024)***********

2024

125.139 (used for 2025)

* Beginning in 1995, the GNP implicit price deflator was rebased relative to 1992. The 1990 GNP implicit price deflator used to

compute the 1996 § 43 inflation adjustment factor is 93.6.

** Beginning in 1997, two digits follow the decimal point in the GNP implicit price deflator. The 1990 GNP price deflator used to

compute the 1998 § 43 inflation adjustment factor is 93.63.

*** Beginning in 1999, the GNP implicit price deflator was rebased relative to 1996. The 1990 GNP implicit price deflator used to

compute the 2000 § 43 inflation adjustment factor is 86.53.

**** Beginning in 2003, the GNP implicit price deflator was rebased, and the 1990 GNP implicit price deflator used to compute the

2004 § 43 inflation adjustment factor is 81.589.

***** Beginning in 2009, the GNP implicit price deflator was rebased, and the 1990 GNP implicit price deflator used to compute

the 2010 § 43 inflation adjustment factor is 72.199.

****** Beginning in 2011, the 1990 GNP implicit price deflator used to compute the 2012 § 43 inflation adjustment factor is

72.260.

******* Beginning in 2013, the GNP implicit price deflator was rebased, and the 1990 GNP implicit price deflator used to compute

the 2014 § 43 inflation adjustment factor is 66.803.

******** Beginning in 2014, the 1990 GNP implicit price deflator used to compute the 2015 § 43 inflation adjustment factor is

66.732.

********* Beginning in 2018, the 1990 GNP implicit price deflator used to compute the 2019 § 43 inflation adjustment factor is

63.637.

********** Beginning in 2021, the 1990 GNP implicit price deflator used to compute the 2022 § 43 inflation adjustment factor is

63.604.

*********** Beginning in 2023, the 1990 GNP implicit price deflator used to compute the 2024 § 43 inflation adjustment factor is

59.266.

June 30, 2025

Bulletin No. 2025–27

Table 2 contains the inflation adjustment factor and the phase-out amount

for taxable years beginning in the 2025

Calendar Year

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

DRAFTING INFORMATION

The principal author of this notice is

Bulletin No. 2025–27

calendar year as well as the previously

published inflation adjustment factors

and phase-out amounts for taxable years

Notice 2025-32 TABLE 2

INFLATION ADJUSTMENT FACTORS AND

PHASE-OUT AMOUNTS

Inflation Adjustment Factor

1.0000

1.0363

1.0708

1.0992

1.1160

1.1485

1.1720

1.1999

1.2030

1.2087

1.2353

1.2633

1.2785

1.2952

1.3266

1.3743

1.4222

1.4666

1.5003

1.5203

1.5326

1.5686

1.5968

1.5974

1.6245

1.6464

1.6713

1.7008

1.7334

1.7640

1.7849

1.8607

1.9998

2.0615

2.1115

Whitney Brady of the Office of Associate

Chief Counsel (Energy, Credits & Excise

Tax). For further information regarding

beginning in the 1991 through 2024 calendar years.

Phase-out Amount

100 percent

1.069 percent

100 percent

this notice, contact Ms. Brady at (202)

317-6853 (not a toll-free number).

June 30, 2025

Extension and Modification

of Transitional Relief Under

Sections 3403, 3406,

6721, 6722, 6651, and

6656 with Respect to the

Reporting of Information

and Backup Withholding on

Digital Assets by Brokers

under Section 6045

Notice 2025-33

SECTION 1. PURPOSE

This notice extends for an additional

year the transitional relief provided in

sections 3.01, 3.02, and 3.06 of Notice

2024-56, 2024 29 I.R.B. 64 (July 15,

2024). Specifically, this notice provides

transitional relief from penalties with

respect to certain information reporting

obligations under section 60451 and also

provides transitional relief from the liability for the payment of backup withholding

tax required to be withheld under section

3406 and its accompanying regulations as

well as from penalties for brokers who fail

to pay that tax with respect to certain sales

of digital assets required to be reported

under section 6045.

This notice also provides additional

transitional relief from penalties to brokers with respect to sales of digital assets

effected for certain customers that have

not been previously classified by the broker as U.S. persons.

SECTION 2. BACKGROUND

.01 Section 6045 and the Final Regulations

Section 6045(a) provides that every

person doing business as a broker shall

make a return to the Internal Revenue Service (IRS) showing the name and address

of each customer, with details regarding

gross proceeds and other information as

required. These rules apply when required

by the Secretary of the Treasury or the

Secretary’s delegate (Secretary) and in

accordance with regulations prescribed

by the Secretary. On July 9, 2024, the

Department of the Treasury (Treasury

Department) and the IRS published Treasury Decision 10000 in the Federal Register (89 FR 56480) (final regulations) to

require brokers to file information returns

on Form 1099-DA and furnish payee

statements reporting gross proceeds for

sales of digital assets effected on or after

January 1, 2025 and, in certain circumstances, adjusted basis on sales of digital

assets effected for customers for sales of

digital assets effected on or after January

1, 2026.

Section 1.6045-1(g)(1) provides that

no return of information is required with

respect to a sale effected for a customer

that is considered to be an exempt foreign person. Under sections 1.6045-1(g)

(4)(ii)(B) and (g)(4)(vi)(A)(1), a broker

effecting a sale of digital assets may treat

a customer as an exempt foreign person if

the broker receives valid documentation

upon which it may rely for this purpose

(for example, Form W-8BEN, Certificate

of Foreign Status of Beneficial Owner

for United States Tax Withholding and

Reporting (Individuals)).

.02 Sections 6721, 6722, and 6724

Section 6721 imposes a penalty for

any failure to file an information return on

or before the required filing date and for

any failure to include all the information

required to be shown on a return or the

inclusion of incorrect information. Section 6724(d)(1)(B)(iii) defines an information return for this purpose as a return

required by section 6045(a) or (d).

Section 6722 imposes a penalty for

any failure to furnish a payee statement

on or before the required furnishing date

to the person to whom such statement is

required to be furnished and for any failure to include all the information required

to be shown on a payee statement or the

inclusion of incorrect information. Section

6724(d)(2)(H) defines a payee statement

for this purpose as a statement required by

section 6045(b) or (d).

Section 6724 provides that no penalty

shall be imposed under sections 6721 and

6722 if the filer (payor) shows that the

failure was due to reasonable cause and

was not due to willful neglect.

.03 Sections 3403 and 3406

Section 3406(a)(1) requires certain

payors of reportable payments to deduct

and withhold a tax, equal to the fourth

lowest rate of tax applicable under section 1(c) (currently 24 percent), from that

payment (backup withholding tax) if the

payee fails to furnish the payee’s tax identification number (TIN) to the payor in the

manner required or if the IRS notifies the

payor that the name and TIN combination

reported by the payor to the IRS for the

payee is incorrect. Under section 3406(b)

(3)(C), a reportable payment includes payments made by a payor that are required to

be shown on an information return filed by

a broker under section 6045. Pursuant to

sections 31.3406(d)-1 and 31.3406(h)-3(a)

(1), a payee that is not an exempt foreign

person must generally furnish to the broker on a Form W-9, Request for Taxpayer

Identification Number and Certification,

the payee’s TIN and certify under penalties of perjury that the furnished TIN is

correct (certified TIN).

A broker required to file Form 1099DA with respect to a payee’s digital asset

transaction is also required to report to the

IRS the amount of backup withholding

tax the broker withheld from the payee

on Form 945, Annual Return of Withheld

Federal Income Tax, and on Form 1099DA. The broker must also furnish a statement with this information to the payee.

The payee may then report this tax as an

income tax payment on the payee’s Federal income tax return.

The consequences to a broker for

failing to backup withhold and pay the

amount withheld to the IRS are significant. First, a broker subject to backup

withholding under section 3406 is liable

under section 3403 for the payment of

the backup withholding tax required to be

withheld. Additionally, a broker who fails

to withhold and pay backup withholding

tax when required may be subject to civil

penalties under sections 6651 for a failure

to pay and 6656 for a failure to deposit

unless the failure is due to reasonable

cause and not due to willful neglect.

.04 TIN Matching Program

Section 31.3406(j)-1(a) provides that

the Commissioner of Internal Revenue

Unless otherwise specified, all “section” references are to sections of the Internal Revenue Code, the Income Tax Regulations (26 CFR part 1), or to the Employment Taxes and Collection

of Income Tax at Source Regulations (26 CFR part 31).

June 30, 2025

Bulletin No. 2025–27

(Commissioner) has the authority to

establish TIN matching programs (IRS

TIN Matching Programs) and may prescribe by revenue procedure or other guidance the scope and terms and conditions

for participating in such programs. Section 31.3406(j)-1(b) provides that none of

the matching details received by a payor

through an IRS TIN Matching Program

will constitute an IRS notification regarding incorrect name and TIN combination

for purposes of imposing backup withholding under section 3406(a)(1)(B). Section 31.3406(j)-1(d) provides that the IRS

will not use a payor’s decision not to participate in an IRS TIN Matching Program

as a basis to assert that the payor lacks reasonable cause under section 6724(a) for

failure to file a correct information return

under section 6721 or to furnish a correct

payee statement under section 6722.

Revenue Procedure 97-31, 1997-26

I.R.B. 6 (June 30, 1997), established procedures under which Federal agencies

could submit payee names and TINs and

the IRS would inform the agency whether

the names and TINs matched the information in the IRS’s database for the program.

Revenue Procedure 2003-9, 2003-8 I.R.B.

516 (February 24, 2003), established an

IRS TIN Matching Program that permits

payors to verify name and TIN combinations provided by payees that are required

to be reported on information returns and

payee statements. To participate in this

IRS TIN Matching Program, the payor

must complete an application. Then, prior

to filing an information return, the IRS

TIN Matching Program participant may

check the name and TIN combination

furnished by the payee against the name

and TIN combination contained in the

IRS-maintained database. More information is available at https://www.irs.gov/

tax-professionals/taxpayer-identification-number-tin-matching. See Publication 2108A, On-Line Taxpayer Identification Number (TIN) Matching Program.

.05 Notice 2024-56

Notice 2024-56 provides transitional

relief for brokers who are otherwise

required to file information returns under

section 6045 and backup withhold under

section 3406 with respect to sales of digital assets effected by the brokers for their

customers. In addition to penalty relief

for certain brokers that fail to file Forms

Bulletin No. 2025–27

1099-DA and furnish payee statements

with respect to certain sales of digital

assets, Notice 2024-56 provides temporary transitional relief from the obligation

to backup withhold under section 3406

and pay such amounts to the IRS under

section 3403 with respect to certain sales

of digital assets. Specifically, section 3.01

of Notice 2024-56 provides that backup

withholding will not be required on sales

of digital assets effected by the broker on

behalf of customers during calendar year

2025.

In addition, for digital asset sales

effected by the broker before January

1, 2027, section 3.02 of Notice 2024-56

permits brokers to use alternative procedures to obtain TINs from customers that

opened accounts with the broker prior to

January 1, 2026 (preexisting customers) if

the broker submits the payee’s name and

TIN combination to the IRS TIN Matching Program and receives a response that

the name and TIN combination furnished

by the payee matches the name and TIN

combination for that payee in IRS records.

Additionally, for sales of digital assets

in exchange for different digital assets

effected on behalf of customers before

January 1, 2027, section 3.06 of Notice

2024-56 limits the amount of backup

withholding tax that brokers must withhold and pay as a tax to the IRS to the

amount that the broker receives upon

the immediate liquidation of 24 percent

of the customer’s received digital assets,

notwithstanding that such amount may

be less than the value of 24 percent of the

customer’s received digital assets determined at the time of the transaction giving

rise to the backup withholding obligation.

Finally, section 3.06 of Notice 2024-56

also provides penalty relief from information reporting penalties and relief from

penalties under sections 6651 and 6656

with respect to any decrease in the value

of received digital assets between the time

of the transaction giving rise to the backup

withholding obligation and the time the

broker liquidates 24 percent of a customer’s received digital assets.

.06 Treatment of Certain Preexisting

Customers as Exempt Foreign Persons

The relief provided in section 3.02 of

Notice 2024-56 applies only to customers

with certified TINs, which are generally

U.S. persons. To provide additional time

for brokers to collect the necessary documentation to treat preexisting customers

as exempt foreign persons with respect to

digital asset sales effected prior to January 1, 2027, section 1.6045-1(g)(4)(vi)

(F) permits a broker to treat a customer

with an account established prior to January 1, 2026, as an exempt foreign person

if the customer has not been previously

classified as a U.S. person by the broker

and the information the broker has for the

customer in its files includes a residence

address that is not a U.S. address.

SECTION 3. DISCUSSION

.01 Sales Effected in Calendar Year

2026

Digital asset brokers are in the process

of building and implementing systems

and procedures that will enable them to

comply with the section 6045 information

reporting obligations for digital asset sales

set forth in the final regulations. These

brokers are also building and implementing systems and procedures that will

enable them to comply with associated

backup withholding tax obligations for

customers who do not supply certified

TINs or otherwise do not provide documentation establishing they are exempt

from backup withholding. The Treasury

Department and the IRS understand that,

notwithstanding the transitional relief

provided in Notice 2024-56, digital asset

brokers may need additional time to build

and implement backup withholding systems prior to the application of the backup

withholding rules for transactions on or

after January 1, 2026, as required after the

application of Notice 2024-56. Accordingly, the Treasury Department and the

IRS are extending for one additional year

the backup withholding relief provided

by section 3.01 of Notice 2024-56 with

respect to sales of digital assets. Therefore, backup withholding tax obligations

under sections 3406 and 3403 will not be

required on any digital asset sale effected

by a broker during calendar year 2025 or

calendar year 2026.

.02 TIN Collection for Sales Effected

in Calendar Year 2027

The Treasury Department and the IRS

are aware that some brokers may need

additional time to obtain certified TINs

from preexisting customers. Accordingly,

June 30, 2025

the Treasury Department and the IRS are

extending the relief provided by section

3.02 of Notice 2024-56 to permit brokers

to rely on uncertified TINs of payees that

are preexisting customers if the broker,

prior to effecting the digital asset sale

transaction for the customer, submits the

payee’s name and TIN combination to the

IRS TIN Matching Program and receives

a response that the submitted name and

TIN combination matches the name and

TIN combination for that payee in the IRS

records. This alternative TIN collection

relief is permitted for digital asset sales

effected in calendar year 2027 on behalf

of payees that are preexisting customers.

.03 Treatment of Certain Preexisting

Customers as Exempt Foreign Persons for

Sales Effected in Calendar Year 2027

The Treasury Department and the IRS

are aware that some brokers may need

additional time beyond that provided in

section 1.6045-1(g)(4)(vi)(F) to obtain

documentation necessary to treat customers with an account established prior

to January 1, 2026, as exempt foreign

persons. Accordingly, to provide this

additional time, the IRS will not impose

penalties under sections 6721 and 6722 on

brokers that fail to file information returns

and furnish payee statements with respect

to sales of digital assets effected during

calendar year 2027 for any customer with

an account established prior to January 1,

2026, if the customer has not been previously classified as a U.S. person by the

broker and the information the broker has

in its files for the customer includes a residence address that is not a U.S. address.

Additionally, backup withholding under

section 3406 will not be required on any

digital asset sale effected by brokers

during calendar year 2027 for these customers. Finally, the IRS will not impose

penalties on brokers that would otherwise be required to file Form 945 with

respect to the backup withholding tax due

with respect to digital asset sales effected

during calendar year 2027 for these customers.

.04 Amount of Backup Withholding for

Sales Effected in Calendar Year 2027

In the case of a sale of a digital asset

for different digital assets other than specified nonfungible tokens (specified NFTs),

as defined in section 1.6045-1(d)(10)(iv)

(A) through (C), brokers may need addi-

June 30, 2025

tional time to implement new backup

withholding procedures because the value

of the digital assets received in such sales

can change between the time of the transaction and the time the received digital

assets are liquidated into U.S. dollars for

depositing with the IRS. Accordingly, to

provide brokers additional time to develop

appropriate procedures, the Treasury

Department and the IRS are extending the

relief provided by section 3.06 of Notice

2024-56 to limit the amount that the broker must pay as backup withholding tax

for reportable digital asset sales effected

in calendar year 2027 to the amount that

the broker receives upon the immediate

liquidation of 24 percent of the customer’s

received digital assets, notwithstanding

that such amount may be less than 24 percent of customer’s received digital assets

at the time of the transaction giving rise

to the backup withholding obligation. This

relief also includes the penalty relief from

information reporting penalties and relief

from penalties under sections 6651 and

6656 with respect to any decrease in the

value of received digital assets between

the time of the transaction giving rise to

the backup withholding obligation and the

time the broker liquidates 24 percent of a

customer’s received digital assets. Finally,

the IRS will not impose penalties on brokers that are required to file Form 945

with respect to the backup withholding tax

due as described in this section 3.04 with

respect to digital asset sales, provided the

broker pays and reports the amount of

backup withholding tax that is withheld

and deposited with the IRS in accordance

with this section 3.04.

further information regarding this notice,

please call (202) 317-5436 (not a toll-free

number).

SECTION 4. EFFECTIVE DATE

SECTION 2. BACKGROUND

This notice is effective for digital asset

sales effected on or after January 1, 2025.

Section 45I(a), as it relates to qualified natural gas production, provides that,

for purposes of § 38, the MWC for any

taxable year is an amount equal to the

product of (1) the credit amount and (2)

the qualified natural gas production that is

attributable to the taxpayer.

Section 45I(c)(1) provides that “qualified natural gas production” means

domestic natural gas produced from a

qualified marginal well. Section 45I(c)(3)

(A) provides that a qualified marginal well

is a domestic well (i) the production from

which during the taxable year is treated as

SECTION 5. EFFECT ON OTHER

DOCUMENTS

Notice 2024-56 is modified.

SECTION 6. DRAFTING

INFORMATION

The principal author of this notice is

the Office of the Associate Chief Counsel (Procedure and Administration). For

Reference Price for Section

45I Credit for Production of

Natural Gas from Marginal

Wells During Taxable Years

Beginning in Calendar Year

2025

Notice 2025-34

SECTION 1. PURPOSE

This notice provides the applicable

reference price for qualified natural gas

production from qualified marginal wells

during taxable years beginning in calendar year 2025 for the purpose of determining the marginal well production credit

(MWC) under § 45I of the Internal Revenue Code. The applicable reference price

for taxable years beginning in calendar

year 2025 is $1.64 per 1,000 cubic feet

(Mcf).

This notice also provides the credit

amount used for the purpose of determining the MWC for taxable years beginning in calendar year 2025. The credit

amount is determined using the 2025

inflation adjustment factor of 1.5821 and

the applicable reference price of $1.64 per

Mcf. The credit amount for taxable years

beginning in calendar year 2025 is $0.79

per Mcf.

Bulletin No. 2025–27

marginal production under § 613A(c)(6),

or (ii) which, during the taxable year (I)

has average production of not more than

25 barrel-of-oil equivalents per day, and

(II) produces water at a rate not less than

95 percent of total well effluent.

Section 613A(c)(6)(D) and (E) provide that “marginal production” means

domestic natural gas produced during

any taxable year from a property which

is a stripper well property for the calendar

year in which the taxable year begins. A

“stripper well property” is, with respect to

any calendar year, any property producing

not more than 15 barrel equivalents per

day, determined by dividing the average

daily production of domestic crude oil

and domestic natural gas from producing

wells on the property for such calendar

year by the number of such wells.

Section 45I(c)(2)(A) provides that

generally only the first 1,095 barrels or

barrel-of-oil equivalents (as defined in

§ 45K(d)(5)) produced during the taxable

year qualify for the MWC. This limitation

is proportionately reduced in the case of a

short taxable year or in the case of a well

that is not capable of production each day

of a taxable year. See § 45I(c)(2)(B). The

number of wells on which a taxpayer may

claim the MWC is not limited.

Section 45I(d)(2) provides that to claim

the credit a taxpayer must hold an operating

interest in the qualified marginal well producing the natural gas to which the credit

relates. Under § 45I(d)(1) if a well is owned

by more than one owner and the natural gas

production exceeds the limitation under

§ 45I(c)(2), the qualifying natural gas production attributable to the taxpayer is determined on the basis of the ratio which the

taxpayer’s revenue interest in the production bears to the aggregate of the revenue

interests of all operating interest owners

in the production. Finally, § 45I(d)(3) provides that the MWC is not allowable if the

taxpayer is also eligible to claim the § 45K

nonconventional sources credit for the taxable year, unless the taxpayer elects not to

claim the credit under § 45K for the well.

For purposes of § 45I(a)(1), the credit

amount is 50 cents (adjusted for inflation)

per Mcf of qualified natural gas production (tentative credit amount). See § 45I(b)

(1)(B) and (b)(2)(B).

Section 45I(b)(2)(A) and (B) provide

that the tentative credit amount (adjusted

for inflation) is reduced (but not below zero)

to the extent that the applicable reference

price exceeds $1.67 (adjusted for inflation).

More specifically, § 45I(b)(2)(A) provides

that the tentative credit amount (adjusted

for inflation) is reduced by an amount

which bears the same ratio to the tentative

credit amount (adjusted for inflation) as the

excess (if any) of the applicable reference

price over $1.67 (adjusted for inflation),

bears to $0.33 (adjusted for inflation). As

a result, the MWC is not available if the

applicable reference price for qualified natural gas production is $2.00 (adjusted for

inflation) or more.

Section 45I(b)(2)(A) also provides that

the applicable reference price for a taxable

year is the reference price for the calendar

year preceding the calendar year in which

the taxable year begins. Section 45I(b)(2)

(C)(ii) provides that the term “reference

price” means, with respect to any calendar

year, in the case of qualified natural gas

production, the Secretary’s estimate of the

annual average wellhead price per Mcf for

all domestic natural gas.

Section 45I(b)(2)(B) provides that in

the case of any taxable year beginning in a

calendar year after 2005, each of the dollar

amounts contained in § 45I(b)(2)(A) will

be increased to an amount equal to such

dollar amount multiplied by the inflation

adjustment factor for such calendar year

(determined under § 43(b)(3)(B) by substituting “2004” for “1990”).

SECTION 3. INFLATION

ADJUSTMENT FACTOR AND

REFERENCE PRICE

.1 Inflation Adjustment. The inflation

adjustment factor under § 45I(b)(2)(B) for

calendar year 2025 is 1.5821.

.2 Reference Price. The Secretary’s

estimate of the calendar year 2024 annual

average wellhead price per Mcf for all

domestic natural gas under § 45I(b)(2)

(C)(ii) was calculated by applying the

Producer Price Index commodity index

for “Natural Gas from the Wellhead”

(WPU053101051)1 published by the

Bureau of Labor Statistics (BLS) as part

of its Producer Price Index program, to

the 2023 annual average wellhead price

($2.04) published in Notice 2024-52,

2024-27 I.R.B. 2. The annual Producer

Price Index commodity index for natural

gas published by the BLS was 63.423 in

2023 and 50.869 in 2024, which implies

a ratio of 2024 to 2023 average wellhead

prices of 0.802 (50.869/63.423). Therefore, the Secretary’s estimate of the calendar year 2024 annual average wellhead

price per Mcf for all domestic natural gas

is $1.64 per Mcf (0.802 × $2.04 per Mcf).

The one cent difference is due to rounding.

For years after 2024, the Secretary

intends to continue calculating the reference price by application of the Producer Price Index commodity index

for “Natural Gas from the Wellhead”

(WPU053101051) published by the BLS

to the previous year’s reference price.

SECTION 4. CALCULATION OF

CREDIT AMOUNT

Under § 45I(b)(1)(B) and (2)(B), the

tentative credit amount used to calculate

the MWC for taxable years beginning in

calendar year 2025 is $0.79 per Mcf ($0.50

× 1.5821 inflation adjustment factor).

Pursuant to § 45I(b)(2)(A), the tentative credit amount is reduced (but not

below zero) by an amount (the Reduction

Amount) which bears the same ratio to

such amount as (i) the excess (if any) of

the applicable reference price over $2.64

($1.67 × 1.5821 inflation adjustment factor), bears to (ii) $0.52 ($0.33 × 1.5821

inflation adjustment factor). The Reduction Amount (as adjusted for inflation) is

computed as follows:

Reduction Amount

Applicable Reference Price – $2.64

Tentative Credit Amount

$0.52

Reduction Amount $1.64 – $2.64

$0.79

$0.52

https://data.bls.gov/cgi-bin/srgate. The BLS publishes indexes and not actual or average prices.

Bulletin No. 2025–27

June 30, 2025

The Reduction Amount is $ -1.52

(($1.64 - $2.64) ÷ $0.52 × $0.79), which

is less than zero, therefore, the tentative

credit amount ($0.79) is not reduced.

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).

SECTION 5. EFFECTIVE DATE

This notice is effective for qualified

natural gas production during taxable

years beginning in calendar year 2025.

YIELD CURVE AND SEGMENT

RATES

SECTION 6. DRAFTING AND

CONTACT INFORMATION

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 cor-

The principal authors of this notice

are Boris Kukso and David Villagrana

of the Office of Associate Chief Counsel

(Energy, Credits, and Excise Tax). For further information regarding this notice contact Mr. Kukso or Mr. Villagrana at (202)

317-6853 (not a toll-free number).

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

Notice 2025-35

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

Applicable Month

June 2025

porate 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 specified in

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

bond yield curve derived from May 2025

data is in Table 2025-5 at the end of this

notice. The spot first, second, and third

segment rates for the month of May 2025

are, respectively, 4.50, 5.57, and 6.23.

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, 202340 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 June

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

4.94

5.35

5.58

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 June

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

June 2025

4.94

5.35

5.59

2025

June 2025

4.94

5.31

5.58

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).

June 30, 2025

Bulletin No. 2025–27

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) provides 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 May 2025 is 4.91 percent. The Service determined this rate as

the average of the daily determinations of

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

June 2025

4.07

3.66 to 4.27

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 May

2025 are as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

May 2025

Minimum Present Value Segment Rates

First Segment

Second Segment

4.50

5.57

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2025–27

yield on the 30-year Treasury bond maturing in February 2055 determined each day

through May 7, 2025 and the yield on the

30-year Treasury bond maturing in May

2055 determined each day for the balance

of the month. For plan years beginning in

June 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:

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

Third Segment

6.23

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 numbers).

June 30, 2025

Table 2025-5

Monthly Yield Curve for May 2025

Derived from May 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

4.51

4.46

4.42

4.41

4.42

4.45

4.49

4.55

4.61

4.68

4.75

4.82

4.90

4.98

5.05

5.13

5.20

5.26

5.33

5.39

5.45

5.50

5.55

5.60

5.65

5.69

5.73

5.77

5.81

5.84

5.87

5.90

5.93

5.95

5.97

5.99

6.01

6.03

6.05

6.06

June 30, 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

6.07

6.08

6.09

6.10

6.11

6.12

6.13

6.14

6.15

6.16

6.17

6.18

6.19

6.20

6.21

6.22

6.23

6.24

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

6.24

6.25

6.26

6.27

6.28

6.29

6.30

6.31

6.32

6.33

6.34

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

6.34

6.35

6.36

6.37

6.38

6.39

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

6.39

6.40

6.41

6.42

Bulletin No. 2025–27

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.

Bulletin No. 2025–27

ER—Employer.

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.

June 30, 2025

Numerical Finding List1

Bulletin 2025–27

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

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.

June 30, 2025

Bulletin No. 2025–27

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–27

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.

Bulletin No. 2025–27

iii

June 30, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue

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