Bulletin No. 2025–22

HIGHLIGHTS

OF THIS ISSUE





Bulletin No. 2025–22

May 27, 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.

EMPLOYEE PLANS

Rev. Proc. 2025-21, page 1448.

Section 12.02 of Rev. Proc. 2024-32 specifies that, in

conjunction with the replacement of the generally applicable mortality tables, certain plan sponsors that wish

to continue using plan-specific mortality tables must

develop and request approval for the use of new plan-specific substitute mortality tables for plan years beginning

on or after January 1, 2026. Rev. Proc. 2025-21 modifies section 12.02 of Rev. Proc. 2024-32 and provides

immediate relief for some of those plan sponsors by narrowing the category of plan sponsors that are required to

Finding Lists begin on page ii.

request approval of new plan-specific substitute mortality

tables.

INCOME TAX

Rev. Proc. 2025-20, page 1448.

Revenue Procedure 2025-20 provides domestic asset/liability percentages and domestic investment yields needed

by foreign life insurance companies and foreign property

and liability insurance companies to compute their minimum

effectively connected net investment income under section

842(b) of the Internal Revenue Code for taxable years beginning after December 31, 2023.

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 27, 2025 

Bulletin No. 2025–22

Part III

26 CFR 601.105: Examination of returns and claims

for refund; credit or abatement; determination of tax

liability

(Also: 842(b))

Rev. Proc. 2025-20

SECTION 1. PURPOSE

This revenue procedure provides the

domestic asset/liability percentages and

domestic investment yields needed by

foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income

under section 842(b) of the Internal Revenue Code for taxable years beginning

after December 31, 2023. Instructions are

provided for computing foreign insurance

companies’ liabilities for the estimated tax

and installment payments of estimated tax

for taxable years beginning after December 31, 2023. For more specific guidance

regarding the computation of the amount

of net investment income to be included

by a foreign insurance company on its

U.S. income tax return, see Notice 89-96,

1989-2 C.B. 417. For the domestic asset/

liability percentage and domestic investment yield, as well as instructions for

computing foreign insurance companies’

liabilities for estimated tax and installment payments of estimated tax for taxable years beginning after December 31,

2022, see Rev. Proc. 2024-20, 2024-19

I.R.B. 1053.

SECTION 2. PERCENTAGES AND

YIELDS

.01 DOMESTIC ASSET/LIABILITY

PERCENTAGES FOR 2024. The Secretary determines the domestic asset/liability percentage separately for life insurance companies and property and liability

insurance companies. For the first taxable

year beginning after December 31, 2023,

the relevant domestic asset/liability percentages are:

121.2 percent for foreign life insurance

companies, and

203.1 percent for foreign property and

liability insurance companies.

.02 DOMESTIC INVESTMENT

YIELDS FOR 2024. The Secretary is

required to prescribe separate domestic

investment yields for foreign life insurance companies and for foreign property

and liability insurance companies. For the

first taxable year beginning after December 31, 2023, the relevant domestic investment yields are:

1.0 percent for foreign life insurance

companies, and

1.7 percent for foreign property and

liability insurance companies.

.03 SOURCE OF DATA FOR 2024.

The section 842(b) percentages to be used

for the 2024 taxable year are based on tax

return data from the 2022 taxable year.

SECTION 3. ESTIMATED TAXES

To compute estimated tax and the

installment payments of estimated tax

due for taxable years beginning after

December 31, 2023, a foreign insurance

company must compute its estimated tax

payments by adding to its income other

than net investment income the greater

of (i) its net investment income as determined under section 842(b)(5) that is

actually effectively connected with the

conduct of a trade or business within the

United States for the relevant period, or

(ii) the minimum effectively connected

net investment income under section

842(b) that would result from using the

most recently available domestic asset/liability percentage and domestic investment

yield. Thus, for installment payments due

after the publication of this revenue procedure, the domestic asset/liability percentages and the domestic investment yields

provided in this revenue procedure must

be used to compute the minimum effectively connected net investment income.

However, if the due date of an installment

is less than 20 days after the date this revenue procedure is published in the Internal

Revenue Bulletin, the asset/liability percentages and domestic investment yields

provided in Rev. Proc. 2024-20 may be

used to compute the minimum effectively

connected net investment income for such

installment. For further guidance in computing estimated tax, see Notice 89-96.

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective for

taxable years beginning after December

31, 2023.

SECTION 5. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Sheila Ramaswamy of the

Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Sheila

Ramaswamy at (202) 317-6938 (not a toll

free number).

26 CFR 1.430(h)(3)-2: Plan-specific substitute mortality tables used to determine present value

(Also: § 1.430(h)(3)-1)

Rev. Proc. 2025-21

SECTION 1. PURPOSE

This revenue procedure modifies section 12 of Rev. Proc. 2024-32, 2024-34

IRB 523. Revenue Procedure 2024-32

specifies the procedure by which the sponsor of a defined benefit plan that is subject to the funding requirements of § 430

of the Internal Revenue Code (Code) may

request approval from the Internal Revenue Service (IRS) for the use of plan-specific substitute mortality tables in accordance with § 430(h)(3)(C) and § 1.430(h)

(3)-2 of the Treasury Regulations.1

Section 12.02 of Rev. Proc. 2024-32

specifies that, in conjunction with the

replacement of the generally applicable

mortality tables, certain plan sponsors

that wish to continue using plan-specific

mortality tables must develop and request

approval for the use of new plan-specific

Section 302 of the Employee Retirement Income Security Act of 1974, Pub. L. 93-406, as amended (ERISA) sets forth funding rules that are parallel to those in § 412 of the Code, and section

303 of ERISA sets forth additional funding rules for defined benefit plans (other than multiemployer plans) that are parallel to those in § 430 of the Code. Section 303(h)(3)(C) of ERISA

requires the approval of the Secretary of the Treasury for the use of substitute mortality tables, and this revenue procedure applies for that purpose.

1

May 27, 2025

1448

Bulletin No. 2025–22

substitute mortality tables for plan years

beginning on or after January 1, 2026.

This revenue procedure provides immediate relief for some of those plan sponsors

by narrowing the category of plan sponsors that are required to request approval

of new plan-specific substitute mortality

tables.

SECTION 2. BACKGROUND

.01 Statutory background. Section 412

sets forth minimum funding requirements

for defined benefit pension plans. In accordance with § 412(a)(2)(A), § 430 specifies

the minimum funding requirements for a

defined benefit plan (other than a multiemployer plan described in § 414(f) or a

CSEC plan described in § 414(y)).

.02 Generally applicable mortality

tables. Section 430(h)(3)(A) sets forth

rules regarding the use of generally applicable mortality tables for purposes of

§ 430, and § 430(h)(3)(B) requires the

Secretary to make periodic revisions (at

least every 10 years) to those mortality

tables. The generally applicable mortality

tables were replaced for valuation dates

occurring on or after January 1, 2024, in

TD 9983 at 88 FR 72357 (Oct. 20, 2023).

.03 Plan-specific substitute mortality

tables.

(1) Statutory background. Section

430(h)(3)(C) provides that the Secretary

may approve plan-specific substitute mortality tables to be used for a plan (in lieu of

the generally applicable mortality tables)

for a period not to exceed 10 years in

determining any present value or making

any computation under § 430. Substitute

mortality tables meet the requirements for

approval if the pension plan has enough

participants and has been maintained for a

long enough period of time to have credible mortality experience, and those tables

reflect the actual experience of the plan

and projected trends in general mortality

experience. Except as provided by the

Secretary, a plan sponsor may not use substitute mortality tables for any plan unless

substitute mortality tables are established

and used for each plan subject to § 430

that is maintained by the plan sponsor or

a member of the plan sponsor’s controlled

group.

(2) Regulations regarding substitute

mortality tables.

Bulletin No. 2025–22

(a) General rules. Under § 1.430(h)(3)2(c)(2), substitute mortality tables must

reflect the actual mortality experience of

the pension plan for which the tables are

to be used, and that mortality experience

must be credible. Separate mortality tables

must be established for each gender under

the plan and, in general, substitute mortality tables are permitted to be established

for a gender only if the plan has credible mortality experience (including partially credible mortality experience) with

respect to that gender.

(b) Development of substitute mortality tables. Under § 1.430(h)(3)-2(c)(3),

development of substitute mortality tables

under the regulations requires creation of

a base substitute mortality table (“Substitute Base Table”) with an associated

base year, which is used in conjunction

with mortality improvement factors to

construct generational mortality tables.

Under § 1.430(h)(3)-2(d), the Substitute Base Table for a population within

the plan must be constructed in a multiple-step process based on (i) a projection of the generally applicable mortality

table for that population to the base year

for the Substitute Base Table, and (ii) an

amounts-weighted mortality ratio calculated from the experience study for that

population. Under § 1.430(h)(3)-2(d)(6),

Substitute Base Tables for a plan may be

constructed by developing and applying

a single mortality ratio for both genders,

but only if the substitute mortality tables

used for all plans maintained by members

of the plan sponsor’s controlled group

(except for plans for which both the male

and female populations, considered separately, have mortality experience with full

credibility) are constructed in this manner.

(c) Early termination of approved substitute mortality tables. Section 1.430(h)

(3)-2(c)(6)(ii) provides for early termination of the use of approved substitute

mortality tables when certain changes

in circumstances occur, with the year of

termination dependent on the particular

change in circumstance.

Under § 1.430(h)(3)-2(c)(6)(ii)(C),

early termination applies to the second plan year following the plan year

for which there is a significant change

in the individuals covered by the plan,

as described in § 1.430(h)(3)-2(c)(6)

(iii). Section 1.430(h)(3)-2(c)(6)(iii)(A)

1449

provides that a significant change in coverage occurs if the number of individuals

covered by the substitute mortality table

for the plan year is less than 80 percent

or more than 120 percent of the average

number of individuals in that population

over the years covered by the experience

study on which the substitute mortality

tables are based. However, § 1.430(h)

(3)-2(c)(6)(iii)(A) provides that a change

in coverage is not treated as significant if

the plan’s actuary certifies in writing to

the satisfaction of the Commissioner that

the substitute mortality tables used for the

population continue to be accurately predictive of future mortality for that population (taking into account the effect of the

change in the population).

Section 1.430(h)(3)-2(c)(6)(ii)(E) provides that the use of an approved substitute mortality table must be terminated

in conjunction with the replacement of

the generally applicable mortality tables

specified in § 430(h)(3)(A) and § 1.430(h)

(3)-1 and that the date of the termination

will be specified in guidance published in

the Internal Revenue Bulletin.

(d) Amendments to regulations relating

to substitute mortality tables. The regulations related to the construction and use of

substitute mortality tables were amended by

TD 10005 at 89 FR 61345 (July 31, 2024).

Under those amendments, in determining

the mortality ratio used to develop plan-specific substitute mortality tables, certain

adjustments to the probability of death must

be made to the mortality rates from the standard mortality table. These adjustments,

which are specified in § 1.430(h)(3)-2(d)(4)

(iii)(B), apply for 12-month periods beginning in 2020, 2021, or 2022.

.04 Revenue Procedure 2024-32. Revenue Procedure 2024-32 was issued to

provide the procedure for the approval of

substitute mortality tables that would first

apply for a plan year beginning on or after

January 1, 2025. Rev. Proc. 2024-32 also

specified the plan year for which the use

of certain previously approved substitute

mortality tables must be terminated in conjunction with the replacement of the generally applicable mortality tables specified

in § 430(h)(3)(A) and § 1.430(h)(3)-1. Specifically, section 12.02 of Rev. Proc. 202432 provided that if a substitute mortality

table was first approved for use for a plan

year that began before January 1, 2025,

May 27, 2025

and the number of individuals covered by

the substitute mortality table is less than

80 percent or more than 120 percent of the

average number of individuals in that population over the 12-month periods covered

by the experience study, then the substitute

mortality table may not be used for a plan

year beginning on or after January 1, 2026.

This termination, which is pursuant to §

1.430(h)(3)-2(c)(6)(ii)(E), applies without regard to whether the actuary makes

the certification described in § 1.430(h)

(3)-2(c)(6)(iii)(A). Section 12.03 of Rev.

Proc. 2024-32 provides that if a plan is not

described in section 12.02 of that revenue

procedure, there is no early termination

of the use of previously approved substitute mortality tables merely because of the

replacement of the generally applicable

mortality tables specified in § 430(h)(3)(A)

and § 1.430(h)(3)-1.

.05 Executive Order 14219. 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 determined

that the modification of section 12 of Rev.

Proc. 2024-32 that is provided in this revenue procedure will reduce burden and

provide immediate relief for certain plan

sponsors that maintain plans described

in section 12.02 of Rev. Proc. 2024-32.

This relief will apply for a plan sponsor

that maintains a plan for which previously

approved substitute mortality tables were

developed using a single mortality ratio

for both genders, if the mortality table for

one gender has had a significant change

in the number of individuals covered by

that table but there has been no significant

change in the number of individuals covered by the plan as a whole.

SECTION 3. MODIFICATION OF

REVENUE PROCEDURE 2024-32

Section 12.02 of Rev. Proc. 2024-32 is

revised to read as follows:

May 27, 2025

.02 Plans with significant changes in

coverage. (1) In general. If a substitute

mortality table was first approved for use

for a plan year that began before January

1, 2025, and the number of individuals

covered by the substitute mortality table is

less than 80 percent or more than 120 percent of the average number of individuals

in that population over the 12-month periods covered by the experience study, then

the substitute mortality table may not be

used for a plan year beginning on or after

January 1, 2026. This termination, which

is pursuant to § 1.430(h)(3)-2(c)(6)(ii)

(E), applies without regard to whether the

actuary makes the certification described

in § 1.430(h)(3)-2(c)(6)(iii)(A).

(2) Exception for plans using a mortality ratio determined with combined genders. If Substitute Base Tables for a plan

(or plans) were developed using the option

in § 1.430(h)(3)-2(d)(6) to determine a

single mortality ratio for both genders in

a population, then the early termination of

the permitted use of a substitute mortality

table specified in section 12.02(1) will not

apply if the total number of individuals

covered by the substitute mortality tables

developed using that mortality ratio is not

less than 80 percent and not more than 120

percent of the average number of individuals in the population used to determine

that mortality ratio over the 12-month

periods covered by the experience study,

provided that the plan actuary certifies in

writing to the satisfaction of the Commissioner that the substitute mortality tables

used for the population continue to be

accurately predictive of future mortality

of that population (taking into account the

effect of the change in the population) as

described in § 1.430(h)(3)-2(c)(6)(iii)(A).

SECTION 4. EFFECT ON OTHER

DOCUMENTS

Section 12.02 of Rev. Proc. 2024-32 is

modified.

SECTION 5. EFFECTIVE DATE

The modification of Rev. Proc. 202432 made by this revenue procedure is

effective for all requests for approval

to use plan-specific substitute mortality

tables in accordance with § 430(h)(3)(C)

for which the first year that the substitute

1450

mortality tables would apply begins on or

after January 1, 2026.

SECTION 6. PAPERWORK

REDUCTION ACT

The Paperwork Reduction Act of 1995

(44 U.S.C. 3501-3520) (PRA) generally

requires that a Federal agency obtain the

approval of the Office of Management and

Budget (OMB) before collecting information from the public, whether such

collection of information is mandatory,

voluntary, or required to obtain or retain

a benefit. An agency may not conduct or

sponsor, and a person is not required to

respond to, a collection of information

unless it displays a valid control number

assigned by the Office of Management

and Budget.

The collections of information, related

to the procedures for obtaining IRS

approvals, mentioned in the revenue procedure 2025-21 are already approved by

the Office of Management and Budget

(OMB) under OMB number 1545-2073.

Section 3 of the revenue procedure 202521 describes the criteria for when mortality tables need IRS approval. The clarification of the criteria, in Section 3, is not

creating new collection requirements or

changing the existing collection requirements already approved under 1545-2073.

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

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. section 6103.

SECTION 7. DRAFTING

INFORMATION

The principal author of this revenue

procedure is Arslan Malik of the Office of

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

regarding the submission of a request for

approval to use substitute mortality tables,

please contact Christopher Denning at

(202) 317-5755.

Bulletin No. 2025–22

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. 2025–22

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.

May 27, 2025

Numerical Finding List1

Proposed Regulations:—Continued

Bulletin 2025–22

REG-110878-24, 2025-9 I.R.B. 979

REG-112261-24, 2025-10 I.R.B. 983

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

2025-25, 2025-20 I.R.B. 1445

2025-26, 2025-20 I.R.B. 1445

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

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

2025-19, 2025-21 I.R.B. 1447

2025-20, 2025-22 I.R.B. 1448

2025-21, 2025-22 I.R.B. 1448

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.

1

May 27, 2025

ii

Bulletin No. 2025–22

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–22

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. 2025–22

iii

May 27, 2025

Internal Revenue Service

Washington, DC 20224

Official Business

Penalty for Private Use, $300

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