# Bulletin No. 2025–22

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3Ac6442a2bb51cfa82

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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

INTERNAL REVENUE BULLETIN

The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.

We Welcome Comments About the Internal Revenue Bulletin

If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Ac6442a2bb51cfa82. Public record. Not legal advice.