Bulletin No. 2025–32

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Bulletin No. 2025–32

August 4, 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

Notice 2025-39, page 308.

This notice sets forth updates on the corporate bond

monthly yield curve, the corresponding spot segment

rates for June 2025 used under § 417(e)(3)(D), the

24-month average segment rates applicable for July

2025, and the 30-year Treasury rates, as reflected by

the application of § 430(h)(2)(C)(iv).

Rev. Rul. 2025-15, page 302.

The revenue ruling provides guidance on withholding and

reporting issues relating to uncashed qualified retirement plan

distribution checks and replacement checks. The revenue ruling answers whether an adjustment or refund is available for

amounts withheld and remitted with respect to an initial check

that is not cashed and also provides guidance on the federal

income tax withholding requirements for a replacement check.

The revenue ruling also describes the reporting obligations

that apply to these checks.

ESTATE TAX

REG-107459-24, page 313.

These regulations amend the current regulations to reduce the

amount of the user fee for authorized persons who wish to

request the issuance of IRS Letter 627, also referred to as an

estate tax closing letter. Pursuant to the guidelines in OMB Circular A-25, the IRS has calculated its cost of providing the estate tax

closing letter to be $56. REG-107459-24.

T.D. 10031, page 304.

This guidance contains an interim final rule relating to the

imposition of a user fee on authorized persons requesting the issuance of IRS Letter 627, also referred to as

Finding Lists begin on page ii.

an estate tax closing letter. Pursuant to the guidelines

in OMB Circular A-25, the IRS has calculated its cost of

providing the estate tax closing letter to be $56. REG107459-24.

EXEMPT ORGANIZATIONS

Announcement 2025-21, page 312.

Revocation of IRC 501(c)(3) Organizations for failure to meet the

code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC

170(b)(1)(A).

EXEMPT ORGANIZATIONS

Rev. Proc. 2025-25, page 311.

This revenue procedure provides indexing adjustments

to the applicable percentage table (Applicable Percentage Table) in § 36B(b)(3)(A)(i) of the Internal Revenue

Code for taxable years beginning in calendar year 2026.

This table is used to calculate an individual’s premium

tax credit under § 36B. This revenue procedure also

provides the indexing adjustment for the required contribution percentage in § 36B(c)(2)(C)(i)(II) for plan years

beginning in calendar year 2026. This percentage is

used to determine whether an individual is eligible for

affordable employer-sponsored minimum essential coverage under § 36B.

Rev. Rul. 2025-14, page 300.

Federal rates; adjusted federal rates; adjusted federal

long-term rate, and the long-term tax exempt rate. For

purposes of sections 382, 1274, 1288, 7872 and other

sections of the Code, tables set forth the rates for

August 2025.

The IRS Mission

Provide America’s taxpayers top-quality service by helping

them understand and meet their tax responsibilities and

enforce the law with integrity and fairness to all.

Introduction

The Internal Revenue Bulletin is the authoritative instrument

of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service

and for publishing Treasury Decisions, Executive Orders, Tax

Conventions, legislation, court decisions, and other items of

general interest. It is published weekly.

It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application

of the tax laws, including all rulings that supersede, revoke,

modify, or amend any of those previously published in the

Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of

internal practices and procedures that affect the rights and

duties of taxpayers are published.

Revenue rulings represent the conclusions of the Service

on the application of the law to the pivotal facts stated in

the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices,

identifying details and information of a confidential nature are

deleted to prevent unwarranted invasions of privacy and to

comply with statutory requirements.

Rulings and procedures reported in the Bulletin do not have the

force and effect of Treasury Department Regulations, but they

may be used as precedents. Unpublished rulings will not be

relied on, used, or cited as precedents by Service personnel in

the disposition of other cases. In applying published rulings and

procedures, the effect of subsequent legislation, regulations,

court decisions, rulings, and procedures must be considered,

and Service personnel and others concerned are cautioned

against reaching the same conclusions in other cases unless

the facts and circumstances are substantially the same.

The Bulletin is divided into four parts as follows:

Part I.—1986 Code.

This part includes rulings and decisions based on provisions

of the Internal Revenue Code of 1986.

Part II.—Treaties and Tax Legislation.

This part is divided into two subparts as follows: Subpart A,

Tax Conventions and Other Related Items, and Subpart B,

Legislation and Related Committee Reports.

Part III.—Administrative, Procedural, and Miscellaneous.

To the extent practicable, pertinent cross references to these

subjects are contained in the other Parts and Subparts. Also

included in this part are Bank Secrecy Act Administrative

Rulings. Bank Secrecy Act Administrative Rulings are issued

by the Department of the Treasury’s Office of the Assistant

Secretary (Enforcement).

Part IV.—Items of General Interest.

This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index

for the matters published during the preceding months. These

monthly indexes are cumulated on a semiannual basis, and are

published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

August 4, 2025

Bulletin No. 2025–32

Part I

Section 1274.—

Determination of Issue

Price in the Case of Certain

Debt Instruments Issued for

Property

(Also Sections 42, 280G, 382, 467, 468, 482, 483,

1288, 7520, 7872.)

Rev. Rul. 2025-14

This revenue ruling provides various

prescribed rates for federal income tax

AFR

110% AFR

120% AFR

130% AFR

AFR

110% AFR

120% AFR

130% AFR

150% AFR

175% AFR

AFR

110% AFR

120% AFR

130% AFR

Short-term adjusted AFR

Mid-term adjusted AFR

Long-term adjusted AFR

August 4, 2025

purposes for August 2025 (the current

month). Table 1 contains the shortterm, mid-term, and long-term applicable federal rates (AFR) for the current

month for purposes of section 1274(d)

of the Internal Revenue Code. Table 2

contains the short-term, mid-term, and

long-term adjusted applicable federal

rates (adjusted AFR) for the current

month for purposes of section 1288(b).

Table 3 sets forth the adjusted federal long-term rate and the long-term

tax-exempt rate described in section

382(f). Table 4 contains the appropri-

ate percentages for determining the

low-income housing credit described in

section 42(b)(1) for buildings placed in

service during the current month. However, under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service

after July 30, 2008, shall not be less

than 9%. Finally, Table 5 contains the

federal rate for determining the present

value of an annuity, an interest for life

or for a term of years, or a remainder or

a reversionary interest for purposes of

section 7520.

REV. RUL. 2025-14 TABLE 1

Applicable Federal Rates (AFR) for August 2025

Period for Compounding

Annual

Semiannual

Quarterly

Short-term

4.03%

3.99%

3.97%

4.44%

4.39%

4.37%

4.85%

4.79%

4.76%

5.26%

5.19%

5.16%

Mid-term

4.06%

4.02%

4.00%

4.47%

4.42%

4.40%

4.88%

4.82%

4.79%

5.30%

5.23%

5.20%

6.12%

6.03%

5.99%

7.16%

7.04%

6.98%

Long-term

4.82%

4.76%

4.73%

5.31%

5.24%

5.21%

5.79%

5.71%

5.67%

6.29%

6.19%

6.14%

Annual

3.05%

3.07%

3.64%

REV. RUL. 2025-14 TABLE 2

Adjusted AFR for August 2025

Period for Compounding

Semiannual

3.03%

3.05%

3.61%

300

Monthly

3.96%

4.35%

4.74%

5.13%

3.99%

4.38%

4.77%

5.17%

5.96%

6.94%

4.71%

5.18%

5.64%

6.11%

Quarterly

3.02%

3.04%

3.59%

Monthly

3.01%

3.03%

3.58%

Bulletin No. 2025–32

REV. RUL. 2025-14 TABLE 3

Rates Under Section 382 for August 2025

Adjusted federal long-term rate for the current month

Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal

long-term rates for the current month and the prior two months.)

3.64%

3.71%

REV. RUL. 2025-14 TABLE 4

Appropriate Percentages Under Section 42(b)(1) for August 2025

Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after

July 30, 2008, shall not be less than 9%.

Appropriate percentage for the 70% present value low-income housing credit

8.03%

Appropriate percentage for the 30% present value low-income housing credit

3.44%

REV. RUL. 2025-14 TABLE 5

Rate Under Section 7520 for August 2025

Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years,

or a remainder or reversionary interest

Section 42.—Low-Income

Housing Credit

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Section 280G.—Golden

Parachute Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Section 382.—Limitation

on Net Operating Loss

Carryforwards and

Certain Built-In Losses

Following Ownership

Change

The adjusted applicable federal long-term rate

is set forth for the month of August 2025. See Rev.

Rul. 2025-14, page 300.

Section 467.—Certain

Payments for the Use of

Property or Services

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Section 468.—Special

Rules for Mining and Solid

Waste Reclamation and

Closing Costs

The applicable federal short-term rates are set

forth for the month of August 2025. See Rev. Rul.

2025-14, page 300.

Section 482.—Allocation

of Income and Deductions

Among Taxpayers

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

4.80%

Section 483.—Interest on

Certain Deferred Payments

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Section 1288.—Treatment

of Original Issue Discount

on Tax-Exempt Obligations

The adjusted applicable federal short-term, midterm, and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Section 7520.—Valuation

Tables

The applicable federal mid-term rates are set

forth for the month of August 2025. See Rev. Rul.

2025-14, page 300.

Section 7872.—Treatment

of Loans With BelowMarket Interest Rates

The applicable federal short-term, mid-term,

and long-term rates are set forth for the month of

August 2025. See Rev. Rul. 2025-14, page 300.

Bulletin No. 2025–32

301

August 4, 2025

Section 6047. — Information

Relating to Certain Trusts and

Annuity Plans

(Also: §§ 3405, 6413, 6414)

Rev. Rul. 2025-15

ISSUES

(1) Under the facts presented (in which a

retirement plan distribution check, defined

in the facts presented as Check 1, was not

cashed), is an adjustment or refund available under sections 6413 and 6414 of the

Internal Revenue Code for amounts withheld and remitted with respect to Check 1?

(2) Under the facts presented (in which

a subsequent retirement plan distribution

check, defined in the facts presented as

Check 2, was mailed), what federal income

tax withholding obligations apply under

section 3405 with respect to Check 2?

(3) Under the facts presented, what

reporting obligations apply under section 6047(d) with respect to Check 1?

(4) Under the facts presented, what

reporting obligations apply under section 6047(d) with respect to Check 2?

FACTS

Employer M is the plan administrator of Plan X, a qualified retirement plan

under section 401(a) that does not include

designated Roth accounts under section 402A, hold employer securities, or

provide benefits described in section 104

(compensation for injuries or sickness)

or section 105 (amounts received under

accident and health plans). Individual C,

a U.S. person under section 7701(a)(30)

(A) with a calendar year taxable year,

has an accrued benefit in Plan X with a

value of $800, has not made a withholding

election under section 3405 with respect

to the accrued benefit, and has no investment in the contract within the meaning

of section 72 with respect to the accrued

benefit. In 2024, Employer M made a des-

ignated distribution within the meaning of

section 3405(e)(1) of Individual C’s $800

accrued benefit by withholding federal

income tax in the amount required under

section 3405 (and, thus, reducing the

accrued benefit by the withheld amount),

remitting that amount to the Department

of the Treasury (Treasury Department),

and mailing a check for the remainder

(Check 1) to Individual C at Individual

C’s address on file. After the designated

distribution was made, Individual C did

not earn any additional accrued benefit

under Plan X on account of compensation

from or service for Employer M. Check 1

was not cashed within six months after the

date on the check, and Employer M cancelled the check.1 Subsequently, Employer

M mailed a second check (Check 2) in the

amount of Individual C’s accrued benefit

at the time of issuance of Check 2 (net of

applicable withholding, if any, required

under section 3405) to Individual C.

LAW AND ANALYSIS

(1) Withholding

(A) In general

Section 3405 provides federal income

tax withholding rules with respect to designated distributions as defined under section 3405(e)(1). With respect to specified

plans, including a plan described in section 401(a), section 3405(d)(2) provides

that the plan administrator shall withhold and be liable for payment of the tax

required to be withheld under section 3405

unless the plan administrator directs the

payor to withhold the tax and provides the

payor with such information as the Secretary may require by regulations.

(B) Issuance of Check 1

(i) Possibility of adjustments for

income tax withheld with respect to a

designated distribution

Section 6413(a)(1) provides that,

if more than the correct amount of tax

imposed by section 34022 is paid with

respect to any payment of remuneration,

proper adjustments,3 with respect to both

the tax and the amount to be deducted,

shall be made, without interest, in such

manner and at such times as the Secretary

may prescribe by regulations.4 Treas. Reg.

§ 31.6413(b)‑1 refers to § 31.6413(a)‑2 for

provisions related to adjustment of overpayment of tax imposed by section 3402.

Pursuant to § 31.6413(a)‑2(c), an adjustment is available under section 6413(a)(1)

only to the extent that more than the

amount required was deducted and withheld by the employer or withholding agent

and the employee was reimbursed within

the same calendar year in accordance

with § 31.6413(a)‑1(b)(1)(i), or there

was an overpayment of tax attributable

to an administrative error, that is, an error

involving the inaccurate reporting of the

amount withheld.

Under the facts presented, Employer

M made a designated distribution within

the meaning of section 3405(e)(1) with

respect to Individual C’s accrued benefit by withholding federal income tax in

the amount required under section 3405,

remitting that amount to the Treasury

Department, and mailing Check 1 to Individual C. The amount deducted and withheld by Employer M from the designated

distribution was the amount required by

section 3405, and that amount was remitted to the Treasury Department. Accordingly, because more than the correct

amount of tax was not withheld or paid,

Employer M is not entitled to an adjustment under section 6413(a)(1).

(ii) Possibility for refund of income tax

withheld with respect to a designated

distribution

Section 6413(b) provides that, if more

than the correct amount of tax imposed

by section 3402 is paid or deducted with

respect to any payment of remuneration

and the overpayment cannot be adjusted

under section 6413(a), a refund may be

available in such manner and at such

times as the Secretary may prescribe by

The results under this revenue ruling would be the same if the drawee was no longer obligated to make a payment with respect to Check 1 for any other reason.

Section 3405(f)(1) provides that any designated distribution is treated as if it were wages paid by an employer to an employee with respect to which there has been withholding under

section 3402.

Proper adjustment of an overpayment of income tax withholding may involve offsetting future withholding obligations. See §§ 31.6413(a)‑1(b) and 31.6413(a)‑2(c).

Section 6413(a)(1) also applies with respect to sections 3101, 3111, 3201, and 3221, which relate to the Federal Insurance Contributions Act and the Railroad Retirement Tax Act.

August 4, 2025

302

Bulletin No. 2025–32

regulations.5 In part, § 31.6413(b)‑1 refers

to § 31.6414‑1 for provisions related to

refunds of tax imposed by section 3402.

Pursuant to § 31.6414‑1(a)(1), the refund

authority under section 6413(b) applies

only to the extent that the amount paid to

the Treasury Department was in excess of

the amount deducted and withheld by the

employer or withholding agent.

Similar to section 6413(b), section 6414 provides that, in certain circumstances involving income tax withholding,

a refund or credit to the employer or to the

withholding agent may be available. Pursuant to section 6414 and § 31.6414‑1(a)(1),

the refund or credit authority under section 6414 applies only to the extent that the

amount paid to the Treasury Department

was in excess of the amount deducted and

withheld by the employer or withholding

agent.

Under the facts presented, Employer

M made a designated distribution within

the meaning of section 3405(e)(1) with

respect to Individual C’s accrued benefit by withholding federal income tax

as required under section 3405, remitting that amount to the Treasury Department, and mailing Check 1. Accordingly,

because the amount deducted and withheld by Employer M from the designated

distribution was the same amount paid by

Employer M to the Treasury Department,

Employer M is not entitled to a refund

under section 6413(b) or 6414.

Under the facts presented, Employer M

mailed a second check, Check 2, to Individual C. If the amount of Individual C’s

accrued benefit under Plan X at the time

of the issuance of Check 2 is less than or

equal to the amount of Check 1, no federal income tax withholding is required in

connection with the issuance of Check 2

because Employer M withheld the amount

required under section 3405 from Individual C’s accrued benefit under Plan X

in connection with the issuance of Check

1. If the amount of Individual C’s accrued

benefit under Plan X at the time of the

issuance of Check 2 is greater than the

amount of Check 1 (for example, because

of earnings), the excess amount is a separate designated distribution subject to

withholding at the time of the issuance of

Check 2.6

(2) Reporting

(A) In General

Section 6047(d) provides that the Secretary of the Treasury shall, by forms or

regulations, require the employer maintaining a plan from which designated distributions (as defined in section 3405(e)(1))

may be made, or the plan administrator

of that plan, to make returns and reports

regarding the plan. However, pursuant

to section 6047(d)(1), no such return or

report may be required with respect to distributions to any person during any year

unless the distributions aggregate $10 or

more.

Form 1099‑R, Distributions From

Pensions, Annuities, Retirement or Profit‑Sharing Plans, IRAs, Insurance Contracts, etc., is used to satisfy the reporting

obligations under section 6047(d). Under

the 2024 instructions to Form 1099‑R, a

Form 1099‑R must be filed for each person to whom a designated distribution of

$10 or more has been made, and the total

amount of the distribution (before federal

income tax or other withholding) must be

reported in Box 1 of that form. In addition, under those instructions, the taxable

amount must be reported in Box 2a unless

the plan administrator is unable to reasonably obtain the data needed to compute the

taxable amount, and the federal income

tax withheld must be reported in Box 4 of

the Form 1099‑R.

(B) Issuance of Check 1

With respect to the distribution of

Individual C’s accrued benefit at the

time of issuance of Check 1, Employer

M must report the designated distribution ($800) in Box 1 of Form 1099‑R

for 2024.7 In addition, because Individual C has no investment in the contract

within the meaning of section 72 and no

exception to income inclusion under section 402(a) applies, Employer M must

report the same amount ($800) in Box 2a

and must report the federal income tax

withheld in Box 4.

With respect to the distribution of Individual C’s accrued benefit at the time of

issuance of Check 2, if the amount of Individual C’s accrued benefit under Plan X

at the time of the issuance of Check 2 is

less than or equal to the amount of Check

1, Employer M is not required to report

the distribution on Form 1099‑R. If the

amount of Individual C’s accrued benefit

under Plan X at the time of the issuance

of Check 2 is greater than the amount of

Check 1, Employer M generally8 must

report the excess amount in Box 1 and

Box 2a on Form 1099‑R for the year of

the distribution and report any federal

income tax withheld in Box 4 on that

Form 1099‑R.

HOLDINGS9

(1) No adjustment or refund is available

under sections 6413 and 6414 with respect

to the amounts withheld and remitted with

respect to Check 1.

Section 6413(b) also applies with respect to sections 3101, 3111, 3201, and 3221.

Under certain circumstances, federal income tax withholding with respect to a designated distribution is not required. For example, under § 31.3405(c)‑1, Q&A‑14, no withholding is required

if the amount of an eligible rollover distribution (as defined in section 402(f)(2)(A)) is less than $200 (subject to rules with respect to aggregating distributions within one taxable year).

This reporting requirement applies without regard to whether the check is returned as undeliverable or remains uncashed for any other reason.

See section 6047(d)(1) (regarding $10 reporting threshold).

Revenue rulings represent the conclusions of the Internal Revenue Service on the application of the specific provisions of law addressed in the revenue ruling to the pivotal facts stated in

the ruling. Accordingly, for example, this revenue ruling does not address: (1) the appropriateness of mailing a check to an address on file that the plan administrator has reason to believe is

incorrect; (2) a situation in which a second check is issued by any person other than the issuer of Check 1, including, for example, the Pension Benefit Guaranty Corporation (PBGC) following

a transfer of an amount to the PBGC’s Missing Participants Program (29 CFR Part 4050), or issued to anyone other than Individual C (for example, to the surviving spouse of Individual C);

(3) any aspect of the PBGC’s Missing Participants Program; or (4) issues under title I of the Employee Retirement Income Security Act of 1974, Pub. L. 93-406, 88 Stat. 829, as amended.

With respect to item (3), PBGC has informed the Treasury Department and the Internal Revenue Service that PBGC is considering possible modifications to its Missing Participants Program

regarding the treatment of prior tax withholding in connection with the transfer of benefits to the program.

Bulletin No. 2025–32

303

August 4, 2025

(2) If the amount of Individual C’s

accrued benefit under Plan X at the time

of the issuance of Check 2 is less than or

equal to the amount of Check 1, no federal

income tax withholding obligations apply

with respect to Check 2. If the amount of

Individual C’s accrued benefit at the time

of issuance of Check 2 is greater than the

amount of Check 1, the excess amount is

subject to withholding in accordance with

section 3405.

(3) With respect to Check 1, Employer

M must report, on Form 1099‑R for 2024,

the designated distribution ($800) in

Boxes 1 and 2a and the federal income tax

withheld in Box 4.

(4) If the amount of Individual C’s

accrued benefit under Plan X at the time

of the issuance of Check 2 is less than

or equal to the amount of Check 1, no

reporting obligations apply with respect

to Check 2. If the amount of Individual

C’s accrued benefit at the time of issuance

of Check 2 is at least $10 greater than the

amount of Check 1, the excess amount is

subject to reporting in accordance with

section 6047(d).

DRAFTING INFORMATION

The principal author of this revenue

ruling is Christina Cerasale of the Office

of Associate Chief Counsel (Employee

Benefits, Exempt Organizations, and

Employment Taxes). Ms. Cerasale may be

reached at (202) 317-4102 (not a toll-free

number).

CFR part 300

TD 10031

DEPARTMENT OF THE

TREASURY

Internal Revenue Service

26 CFR Part 300

Estate Tax Closing Letter

User Fee Update

AGENCY: Internal Revenue Service

(IRS), Treasury.

August 4, 2025

ACTION: Interim final rule.

SUMMARY: This document contains

interim final regulations relating to the

imposition of a user fee on authorized persons requesting the issuance of IRS Letter 627, also referred to as an estate tax

closing letter. These regulations reduce

the amount of the user fee imposed on a

request for the issuance of an estate tax

closing letter. The Independent Offices

Appropriations Act of 1952 authorizes

the charging of user fees. The text of the

interim final regulations also serves as the

text of the proposed regulations set forth

in the notice of proposed rulemaking on

this subject in the Proposed Rules section

of this edition of the Federal Register.

DATES: Effective date: These regulations

are effective on May 20, 2025.

Applicability date: For date of applicability, see §300.12(d).

FOR FURTHER INFORMATION

CONTACT: Concerning the interim

final regulations, Juli Ro Kim at (202)

317-6859; concerning cost methodology,

Maria E. Arias-Buchanan at (202) 8039569 (not toll-free numbers).

SUPPLEMENTARY INFORMATION:

Authority

This document contains interim final

amendments to 26 CFR part 300 regarding user fees for authorized persons who

request the issuance of an estate tax closing letter (IRS Letter 627).

The Independent Offices Appropriations Act of 1952 (IOAA) (31 U.S.C.

9701) authorizes each agency to prescribe regulations that establish user fees

for services provided by the agency. The

IOAA provides that regulations implementing user fees are subject to policies

prescribed by the President; these policies

are set forth in the Office of Management

and Budget Circular A-25, 58 FR 38142

(July 15, 1993) (OMB Circular A-25).

The IOAA states that the services provided by an agency should be self-sustaining to the extent possible. Under OMB

Circular A-25, agencies that provide services that confer special benefits on identi-

304

fiable recipients beyond those accruing to

the general public must identify those services, determine whether user fees should

be assessed for those services, and, if so,

establish user fees that recover the full

cost of providing those services, unless

an exception to the full cost requirement

is granted. As required by the IOAA and

OMB Circular A-25, agencies are to

review user fees biennially and update

them as necessary to reflect changes in the

cost of providing the underlying services.

Background and Explanation of

Provisions

A. Estate Tax Closing Letter User Fee

On September 28, 2021, the Department of the Treasury (Treasury Department) and the IRS published final regulations (TD 9957) in the Federal Register

(86 FR 53539) establishing a $67 user

fee to apply to requests for the issuance

of an estate tax closing letter, based on

a 2019 Cost Model. As explained in the

Background section of the preamble of

TD 9957, the issuance of an estate tax

closing letter constitutes the provision of

a service and confers special benefits to

authorized persons requesting such letters beyond those accruing to the general

public. Therefore, the IRS is authorized,

pursuant to the IOAA and OMB Circular

A-25, to charge a user fee for the issuance

of an estate tax closing letter that reflects

the full cost of providing this service. See

also section 6103(p)(2)(B) (allowing for a

reasonable fee for furnishing return information to any person).

In 2021, the IRS conducted a biennial

review of the estate tax closing letter user

fee and issued a new Cost Model that

resulted in no change to the $67 user fee.

In 2023, the IRS conducted a biennial

review of the estate tax closing letter user

fee and issued a new Cost Model, which

determined that the full cost of issuing

estate tax closing letters to authorized persons is $56.

B. Calculation of User Fees Generally

The IRS follows generally accepted

accounting principles (GAAP) in calculating the full cost of providing services.

Bulletin No. 2025–32

The Federal Accounting Standards Advisory Board (FASAB) is the body that

establishes GAAP that apply for Federal reporting entities, such as the IRS.

FASAB publishes the FASAB Handbook

of Accounting Standards and Other Pronouncements, as amended, available at

https://fasab.gov/accounting-standards/.

The FASAB Handbook includes the Statement of Federal Financial Accounting

Standards 4: Managerial Cost Accounting

Standards and Concepts (SFFAS No. 4)

for the Federal government. SFFAS No.

4 establishes internal costing standards

under GAAP to accurately measure and

manage the full cost of Federal programs.

The methodology described below is in

accordance with SFFAS No. 4.

1. Cost Center Allocation

The IRS determines the cost of its services and the activities involved in producing them through a cost accounting

system that tracks costs to organizational

units. The lowest organizational unit in

the IRS’s cost accounting system is a

cost center. Cost centers usually are separate offices distinguished by subject-matter area of responsibility or geographic

region. All costs of operating a cost center

are recorded in the IRS’s cost accounting

system and allocated to that cost center.

These costs include the direct costs for

the cost center’s activities and all indirect

costs, including overhead, associated with

that cost center. Each cost is recorded in

only one cost center.

2. Cost Estimation of Direct Labor and

Benefits

Not all cost centers are fully devoted

to only one service for which the IRS

charges a user fee. When cost centers

include multiple services, the IRS measures the time required to accomplish

activities associated with each service to

estimate the average time spent on the service in the related cost center. The average

time devoted is multiplied by the relevant

organizational unit’s average labor and

benefits cost per unit of time to determine

the direct labor and benefits cost incurred

to provide the service. To determine the

full cost, the IRS then adds an appropriate

overhead charge.

3. Calculating Overhead

Overhead is an indirect cost of operating an organization that cannot be immediately associated with an activity that the

organization performs. Overhead includes

costs of resources that are jointly or commonly consumed by one or more organizational unit’s activities but are not specifically identifiable to a single activity, such

as the following:

• General management and administrative services of sustaining and supporting organizations

• Facilities management and ground

maintenance services (security, rent,

utilities, and building maintenance)

• Procurement and contracting services

• Financial management and accounting services

• Information technology services

• Services to acquire and operate property, plants, and equipment

• Publication, reproduction, and graphics and video services

• Research, analytical, and statistical

services

• Human resources/personnel services

• Library and legal services

To calculate the overhead allocable to

a service, the IRS multiplies the current

overhead rate by the direct labor and benefits costs of the service. The overhead rate

is the ratio of the IRS’s indirect labor, benefits, and non-labor costs of business divisions that do not interact with taxpayers to

the direct labor and benefits costs of business divisions that interact with taxpay-

Direct Staff Hours

Indirect Hours (60%)

Total Hours

To determine the labor and benefits

costs, the IRS divided the 9,250 total

hours by 2,080 (the total annual hours

worked by a full-time employee (FTE))

Bulletin No. 2025–32

ers. The IRS calculates the overhead rate

annually based on cost elements underlying the Statement of Net Cost included

in the IRS Annual Financial Statements,

which are audited by the Government

Accountability Office.

For this estate tax closing letter user fee

review, the fiscal year (FY) 2023 overhead

rate, based on FY 2022 costs, of 62.50

percent was used.

C. Full Cost Determination for the

Estate Tax Closing Letter User Fee

The IRS followed the guidance provided by the OMB Circular A-25 guidance to compute the full cost of issuing

estate tax closing letters to authorized

persons. OMB Circular A-25 explains that

the full cost includes all indirect and direct

costs to any part of the Federal Government including but not limited to, direct

and indirect personnel costs, physical

overhead, rents, utilities, travel, and management costs.

1. Request Processing Costs

Requests for estate tax closing letters

are processed by employees at grades 5,

8, and 11 of the general schedule (GS-5,

GS-8, and GS-11). Approximately 0.65

staff hours are required to review the

return, create the estate tax closing letters,

and prepare the letters for mailing. The

IRS received an average of 8,894 annual

requests for estate tax closing letters in FY

2021 and FY 2022, requiring 5,781 staff

hours.

Total hours allocated to the cost also

must include indirect hours for campus

employees, which are calculated by multiplying the number of direct hours by the

applicable 60 percent indirect employee

rate. Using this information, IRS determined that the total staff hours for processing requests for estate tax closing letters are 9,250 annually.

5,781

+ 3,469

9,250

to convert the hours to a 4.45 FTE equivalent. The processing of requests for

estate tax closing letters is performed

primarily (87.7 percent) by employees at

305

the GS-5 level, but also by employees at

the GS-8 level (1.7 percent) and GS-11

level (10.6 percent). The average salary

and benefit cost for each of those levels

August 4, 2025

was multiplied by that grade’s percentage

of processing time to arrive at a $67,355

total cost per FTE. Multiplying the cost

per FTE by the 4.45 FTE equivalent

resulted in a total labor and benefits cost

of $299,730, as follows:

Total Cost Per FTE

Total FTE

Processing Labor & Benefits

2. Quality Assurance Review Costs

Outgoing estate tax closing letters are

reviewed by quality assurance professionals at the following Internal Revenue

(IR) paybands of the IRS Payband System: IR-10 (87.7 percent) and IR-06 (12.3

percent). Three out of every 100 estate

$67,355

× 4.45

$299,730

tax closing letters mailed are reviewed to

verify (1) the estate tax closing letter was

authorized, (2) the information included

in the letter was accurate, and (3) the

address was correct. The 8,894 average

number of requests for FY 2021 and FY

2022 resulted in 266 letters reviewed. On

average, quality assurance profession-

als spend 0.5 hours reviewing one estate

tax closing letter, totaling 133 direct staff

hours. The direct staff hours were multiplied by the 60 percent indirect employee

rate for campus employees, resulting in a

combined total of 213 annual staff hours

allocated for quality assurance (QA)

reviews, as follows:

Direct Staff Hours

Indirect Hours (60%)

Total Hours

QA reviews are processed by employees at various IR levels. Dividing the total

hours by 2,080 (the total annual hours for

each FTE), resulted in 0.10 FTEs. The

133

+ 80

213

average salary and benefits for both IR

paybands conducting quality assurance

reviews was multiplied by that IR payband’s percentage of processing time to

arrive at the $95,460 total cost per FTE.

The total cost per FTE was then multiplied

by the total FTE to determine the labor and

benefits cost for QA reviews, as follows:

Total Cost per FTE

Total FTE

Quality Assurance Labor & Benefits

3. Full Cost Per Request Calculation

The IRS applied the 62.5 percent over-

head rate to the total labor and benefits

cost to calculate the full cost of the estate

tax closing letter program.

Processing Labor & Benefits

Quality Assurance Labor & Benefits

Total Labor and Benefits

Overhead (62.50%)

Full Cost

The $56 cost per request was determined by dividing the full cost by the

$502,573

÷ 8,894

$56

Special Analyses

II. Regulatory Flexibility Act

I. Regulatory Planning and Review

Pursuant to the Regulatory Flexibility Act (5 U.S.C. chapter 6), it is hereby

certified that these interim final regulations will not have a significant economic

impact on a substantial number of small

entities. These regulations, which reduce

the amount of a fee to obtain a particular

August 4, 2025

$299,730

+ $9,546

$309,276

$193,297

$502,573

average annual volume of requests, as follows:

Full Cost

Estimated Annual Request Volume

Cost Per Request

The OMB’s Office of Information and

Regulatory Analysis has determined that

these regulations are not significant and

subject to review under section 6(b) of

Executive Order 12866.

$95,460

× 0.1

$9,546

306

service, affect decedents’ estates, which

generally are not small entities as defined

under 5 U.S.C. 601(6). Thus, these regulations have no economic impact on small

entities. In addition, the interim final regulations will establish a $56 fee, which is a

reduction from the previously established

fee and is not substantial enough to have

a significant economic impact on any enti-

Bulletin No. 2025–32

ties that could be affected by establishing

such a fee. Accordingly, the Secretary

certifies that the rule will not have a significant economic impact on a substantial

number of small entities.

III. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandates

Reform Act of 1995 requires that agencies

assess anticipated costs and benefits and

take certain other actions before issuing a

final rule that includes any Federal mandate that may result in expenditures in any

one year by a State, local, or Tribal government, in the aggregate, or by the private sector, of $100 million in 1995 dollars, updated annually for inflation. This

rule does not include any Federal mandate

that may result in expenditures by State,

local, or Tribal governments, or by the private sector in excess of that threshold.

IV. Executive Order 13132: Federalism

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

compliance costs on State and local governments, and is not required by statute,

or preempts State law, unless the agency

meets the consultation and funding

requirements of section 6 of the Executive order. These proposed regulations do

not have federalism implications and do

not impose substantial direct compliance

costs on State and local governments or

preempt State law within the meaning of

the Executive order.

closing letter on https://www.pay.gov. It

would be unnecessary and contrary to the

public interest for the IRS to continue to

charge the current, higher user fee during

the period provided for public comment

on the proposal to reduce that fee. To

enable the reduced fee amount to be in

effect immediately for authorized persons

requesting an estate tax closing letter, the

Treasury Department and the IRS find that

there is good cause to dispense with (1)

notice and public comment pursuant to 5

U.S.C. 553(b) and (c) and (2) a delayed

effective date pursuant to 5 U.S.C. 553(d).

The Treasury Department and the IRS

will consider public comments submitted

in response to the cross-referenced notice

of proposed rulemaking published in the

Proposed Rules section of this issue of

the Federal Register and will promulgate

a final rule after considering those comments.

VI. Submission to Small Business

Administration

Pursuant to section 7805(f) of the

Internal Revenue Code, this regulation

has been submitted to the Chief Counsel

for the Office of Advocacy of the Small

Business Administration for comment on

its impact on small business.

VII. Congressional Review Act

Pursuant to the Congressional Review

Act (5 U.S.C. 801 et seq.), the Office of

Information and Regulatory Affairs designated this rule as not a major rule, as

defined by 5 U.S.C. 804(2).

V. Good Cause

Drafting Information

The user fee for the estate tax closing letter applies to all individuals who

make a request and pay for the estate tax

The principal author of these regulations is Juli Ro Kim of the Office of the

Associate Chief Counsel (Passthroughs,

Bulletin No. 2025–32

307

Trusts, and Estates). Other personnel from

the Treasury Department and the IRS participated in the development of the regulations.

List of Subjects in 26 CFR Part 300

Estate taxes, Reporting and recordkeeping requirements.

Amendments to the Regulations

Accordingly, 26 CFR part 300 is

amended as follows:

PART 300—USER FEES

Paragraph 1. The authority citation

for part 300 continues to read in part as

follows:

Authority: 31 U.S.C. 9701.

Par. 2. Section 300.12 is amended by

revising paragraphs (b) and (d) to read as

follows:

§300.12 Fee for estate tax closing letter.

*****

(b) Fee. The fee for issuing an estate

tax closing letter is $56.

*****

(d) Applicability date. This section

applies to requests received by the IRS

after May 20, 2025.

Edward Killen,

Acting Chief Tax Compliance Officer.

Approved: May 5, 2025.

Kevin M. Salinger,

Acting Assistant Secretary of

the Treasury (Tax Policy).

(Filed by the Office of the Federal Register May 16,

2025, 8:45 a.m., and published in the issue of the

Federal Register for May 20, 2025, 90 FR 21410)

August 4, 2025

Part III

Update for Weighted

Average Interest Rates,

Yield Curves, and Segment

Rates

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 corporate 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 June 2025

Notice 2025-39

This notice provides guidance on the

corporate bond monthly yield curve, the

corresponding spot segment rates used

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).

YIELD CURVE AND SEGMENT

RATES

Section 430 specifies the minimum

funding requirements that apply to single-employer plans (except for CSEC plans

Applicable Month

July 2025

data is in Table 2025-6 at the end of this

notice. The spot first, second, and third

segment rates for the month of June 2025

are, respectively, 4.43, 5.46, and 6.13.

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, 2023-40 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 July

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

4.90

5.36

5.62

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 July

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

July 2025

4.90

5.36

5.62

2025

July 2025

4.90

5.31

5.62

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).

August 4, 2025

308

Bulletin No. 2025–32

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) pro-

vides 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 June 2025 is 4.89 percent. The Service determined this rate as

the average of the daily determinations of

yield on the 30-year Treasury bond maturing in May 2055. For plan years beginning

in July 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:

For Plan Years Beginning In

Treasury Weighted Average Rates

30-Year Treasury Weighted Average

Permissible Range 90% to 105%

July 2025

4.12

3.71 to 4.33

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 June

2025 are as follows:

MINIMUM PRESENT VALUE

SEGMENT RATES

In general, the applicable interest rates

Month

June 2025

Minimum Present Value Segment Rates

First Segment

Second Segment

4.43

5.46

DRAFTING INFORMATION

The principal author of this notice

is Tom Morgan of the Office of Associ-

Bulletin No. 2025–32

ate Chief Counsel (Employee Benefits,

Exempt Organizations, and Employment

Taxes). However, other personnel from

the IRS participated in the development

309

Third Segment

6.13

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).

August 4, 2025

Table 2025-6

Monthly Yield Curve for June 2025

Derived from June 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

4.48

4.42

4.37

4.35

4.37

4.40

4.45

4.51

4.57

4.64

4.71

4.79

4.86

4.94

5.01

5.08

5.15

5.21

5.28

5.33

5.39

5.44

5.49

5.54

5.58

5.62

5.66

5.69

5.73

5.76

5.78

5.81

5.84

5.86

5.88

5.90

5.91

5.93

5.94

August 4, 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

5.96

5.97

5.98

5.99

6.00

6.01

6.02

6.03

6.04

6.05

6.06

6.07

6.08

6.09

6.10

6.11

6.12

6.13

6.14

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

6.15

6.16

6.17

6.18

6.19

6.20

6.21

6.22

6.23

6.24

310

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

6.25

6.26

6.27

6.28

6.29

6.30

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

6.30

6.31

6.32

6.33

Bulletin No. 2025–32

26 CFR 601.105: Examination of returns and claims

for refund, credit, or abatement; determination of

correct tax liability.

(Also Part 1, §§ 36B, 1.36B-2, 1.36B-3.)

Rev. Proc. 2025-25

SECTION 1. PURPOSE

This revenue procedure provides

indexing adjustments to the applicable

percentage table (Applicable Percentage

Table) in § 36B(b)(3)(A)(i) of the Internal Revenue Code (Code)1 for taxable

years beginning in calendar year 2026.

This table is used to calculate an individual’s premium tax credit under § 36B.

This revenue procedure also provides the

indexing adjustment for the required contribution percentage (Required Contribution Percentage) in § 36B(c)(2)(C)(i)(II)

for plan years beginning in calendar year

2026. This percentage is used to determine whether an individual is eligible for

affordable employer-sponsored minimum

essential coverage under § 36B.

For plan years beginning in calendar

year 2026, the Applicable Percentage

Table and the Section 36B Required Contribution Percentage indexing adjustments

are based on the most recent projections of

premium growth and income growth.2 See

§§ 1.36B-2(c)(3)(v)(C) and 1.36B-3(g).

In addition, the additional adjustment

provided in § 36B(b)(3)(A)(ii)(II) is not

required for plan years beginning in 2026

because the Department of the Treasury

(Treasury Department) and the Internal

Revenue Service (IRS) have determined

that the failsafe exception described in

§ 36B(b)(3)(A)(ii)(III) applies for plan

years beginning in calendar year 2026.

SECTION 2. CHANGE

TO PREMIUM GROWTH

ADJUSTMENT METHODOLOGY

The Applicable Percentage Table

and the Section 36B Required Contribution Percentage indexing adjustments

are computed using the methodology

described in section 4 of Rev. Proc.

2014-37, 2014-2 C.B. 363, and in guidance issued by the Department of Health

and Human Services (HHS). For 2025

and a number of years prior to 2025,

the rate of premium growth was based

Household income percentage of Federal poverty line:

Less than 133%

At least 133% but less than 150%

At least 150% but less than 200%

At least 200% but less than 250%

At least 250% but less than 300%

At least 300% but not more than 400%

.02 Required Contribution Percentage

for 2026. For plan years beginning in calendar year 2026, the Required Contribution Percentage for purposes of § 36B(c)

(2)(C)(i)(II) and § 1.36B-2(c)(3)(v)(C) is

9.96%.

SECTION 4. EFFECT ON OTHER

DOCUMENTS

Rev. Proc. 2014-37 is supplemented.

on per enrollee spending for employer-sponsored insurance as published

in the National Health Expenditure

Account. However, beginning in calendar year 2026, HHS guidance provides

a new premium growth measure that

captures increases in individual market premiums in addition to increases

in employer-sponsored insurance premiums for purposes of calculating the

premium adjustment percentage for the

2026 benefit year and beyond. See HHS

Marketplace Integrity and Affordability

rule, 90 Fed. Reg. 27074 (June 25, 2025).

The Treasury Department and the IRS

adopt the new premium growth measure

provided in the 2026 HHS Marketplace

Integrity and Affordability rule for purposes of the Applicable Percentage Table

and the Section 36B Required Contribution Percentage indexing adjustments.

SECTION 3. ADJUSTED ITEMS

.01 Applicable Percentage Table for

2026. For taxable years beginning in calendar year 2026, the Applicable Percentage Table for purposes of § 36B(b)(3)(A)

(i) and § 1.36B-3(g) is:

Initial percentage

2.10%

3.14%

4.19%

6.60%

8.44%

9.96%

SECTION 5. EFFECTIVE DATE

This revenue procedure is effective for

taxable years and plan years beginning in

calendar year 2026.

Final percentage

2.10%

4.19%

6.60%

8.44%

9.96%

the Office of Associate Chief Counsel

(Income Tax and Accounting). For further

information regarding this revenue procedure, contact Ms. Raymond at (202) 3174718 (not a toll-free number).

SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue procedure is Clara L. Raymond of

Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

The rate of premium growth and the rate of income growth are calculated using the NHEA Projections, 2024-2033, available at: https://www.cms.gov/Research-Statistics-Data-and-Systems/

Statistics-Trends-and-Reports/NationalHealthExpendData/NationalHealthAccountsProjected.

Bulletin No. 2025–32

311

August 4, 2025

Part IV

Deletions From Cumulative List of Organizations, Contributions to Which are

Deductible Under Section 170 of the Code

Announcement 2025-21

The Internal Revenue Service has revoked its determination that the organizations listed below qualify as organizations described in

sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986.

Generally, the IRS will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the IRS is not precluded from disallowing a

deduction for any contributions made after an organization ceases to qualify under section 170(c)(2) if the organization has not timely

filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or

determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities

or omissions of the organization that brought about this revocation.

If on the other hand a suit for declaratory judgment has been timely filed, contributions from individuals and organizations described

in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on

July 17, 2025, and would end on the date the court first determines the organization is not described in section 170(c)(2) as more

particularly set for in section 7428(c)(1). For individual contributors, the maximum deduction protected is $1,000, with a husband

and wife treated as one contributor. This benefit is not extended to any individual, in whole or in part, for the acts or omissions of the

organization that were the basis for revocation.

Name Of Organization

Just 4 Jacks Ranch & Sanctuary

Youth Inventors Lab

Childrens Community Services Inc

Effective Date of Revocation

01/01/2023

01/01/2021

07/01/2021

August 4, 2025

312

Location

Lyons, CO

Inner Grove, MN

Laurelton, NY

Bulletin No. 2025–32

Notice of Proposed

Rulemaking

ments, Publications and Regulations

Branch at (202) 317-6901 (not toll-free

numbers).

Estate Tax Closing Letter

User Fee Update

SUPPLEMENTARY INFORMATION:

REG-107459-24

This notice of proposed rulemaking

proposes amendments to 26 CFR part

300 regarding user fees for authorized

persons who request the issuance of an

estate tax closing letter (IRS Letter 627)

by cross-reference to interim final regulations in the Rules and Regulations section of this issue of the Federal Register

regarding this topic.

The Independent Offices Appropriations Act of 1952 (IOAA) (31 U.S.C.

9701) authorizes each agency to prescribe regulations that establish user fees

for services provided by the agency. The

IOAA provides that regulations implementing user fees are subject to policies

prescribed by the President; these policies

are set forth in the Office of Management

and Budget Circular A-25, 58 FR 38142

(July 15, 1993) (OMB Circular A-25).

The IOAA states that the services provided by an agency should be self-sustaining to the extent possible. Under OMB

Circular A-25, agencies that provide services that confer special benefits on identifiable recipients beyond those accruing to

the general public must identify those services, determine whether user fees should

be assessed for those services, and, if so,

establish user fees that recover the full

cost of providing those services, unless

an exception to the full cost requirement

is granted. As required by the IOAA and

OMB Circular A-25, agencies are to

review user fees biennially and update

them as necessary to reflect changes in the

cost of providing the underlying services.

AGENCY: Internal Revenue Service

(IRS), Treasury.

ACTION: Notice of proposed rulemaking.

SUMMARY: In the Rules and Regulations section of this issue of the Federal

are issuing interim final regulations that

amend the current regulations to reduce

the amount of the user fee imposed on

authorized persons requesting the issuance of IRS Letter 627, also referred to as

an estate tax closing letter. The text of the

interim final regulations also serves as the

text of these proposed regulations.

DATES: Electronic or written comments

must be received by July 21, 2025.

ADDRESSES: Commenters are strongly

encouraged to submit public comments

electronically. Submit electronic submissions via the Federal eRulemaking Portal

at https://www.regulations.gov (indicate

IRS and REG-107459-24) by following

the online instructions for submitting

comments. Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The Treasury

Department and the IRS will publish for

public availability any comments submitted to the IRS’s public docket. Send paper

submissions to: CC:PA:01:PR (REG107459-24), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin

Station, Washington, D.C. 20044.

FOR FURTHER INFORMATION

CONTACT: Concerning the proposed

regulations, Juli Ro Kim at (202) 3176859; concerning cost methodology,

Maria E. Arias-Buchanan at (202) 8039569; concerning submissions of com-

Bulletin No. 2025–32

Authority

Background and Explanation of

Provisions

Interim final regulations in the Rules

and Regulations section of this issue of

the Federal Register amend regulations

under 26 CFR part 300 setting a user fee

for authorized persons who request the

issuance of an estate tax closing letter. The

text of the interim final regulations also

313

serves as the text of these proposed regulations. The preamble to the interim final

regulations explains the interim final regulations and these proposed regulations.

Special Analyses

I. Regulatory Planning and Review

The OMB’s Office of Information and

Regulatory Analysis has determined that

this regulation is not significant and is not

subject to review under section 6(b) of

Executive Order 12866.

II. Regulatory Flexibility Act

Pursuant to the Regulatory Flexibility

Act (5 U.S.C. chapter 6), it is hereby certified that these proposed regulations will

not have a significant economic impact

on a substantial number of small entities.

The proposed regulations, which reduce

the amount of a fee to obtain a particular service, affect decedents’ estates,

which generally are not “small entities”

as defined under 5 U.S.C. 601(6). Thus,

these proposed regulations have no economic impact on small entities. In addition, the interim final regulations will

establish a $56 fee, which is a reduction

from the previously established fee and is

not substantial enough to have a significant economic impact on any entities that

could be affected by establishing such a

fee. Accordingly, the Secretary certifies

that the rule will not have a significant

economic impact on a substantial number

of small entities.

III. Unfunded Mandates Reform Act

Section 202 of the Unfunded Mandates

Reform Act of 1995 requires that agencies

assess anticipated costs and benefits and

take certain other actions before issuing a

final rule that includes any Federal mandate that may result in expenditures in any

one year by a State, local, or Tribal government, in the aggregate, or by the private sector, of $100 million in 1995 dollars, updated annually for inflation. This

rule does not include any Federal mandate

that may result in expenditures by State,

local, or Tribal governments, or by the private sector in excess of that threshold.

August 4, 2025

IV. Executive Order 13132: Federalism

Executive Order 13132 (Federalism)

prohibits an agency from publishing any

rule that has federalism implications if

the rule either imposes substantial, direct

compliance costs on State and local governments, and is not required by statute, or

preempts State law, unless the agency meets

the consultation and funding requirements

of section 6 of the Executive order. These

proposed regulations do not have federalism

implications and do not impose substantial

direct compliance costs on State and local

governments or preempt State law within

the meaning of the Executive order.

V. Submission to Small Business

Administration

Pursuant to section 7805(f) of the Internal Revenue Code, this notice of proposed

rulemaking has been submitted to the

Chief Counsel of the Office of Advocacy

of the Small Business Administration for

comment on its impact on small business.

Comments

Consideration will be given to comments that are submitted timely to the

August 4, 2025

IRS as prescribed in this preamble under

the ADDRESSES heading of this preamble. The Treasury Department and

IRS request comments on all aspects

of the proposed regulations. Any comments submitted will be made available

at https://www.regulations.gov or upon

request.

Drafting Information

The principal author of these regulations is Juli Ro Kim of the Office of the

Associate Chief Counsel (Passthroughs,

Trusts, and Estates). Other personnel from

the Treasury Department and the IRS participated in the development of the regulations.

List of Subjects in 26 CFR Part 300

Estate taxes, Reporting and recordkeeping requirements.

Proposed Amendments to the

Regulations

Accordingly, the Treasury Department

and the IRS propose to amend 26 CFR

part 300 as follows:

314

PART 300—USER FEES

Paragraph 1. The authority citation

for part 300 continues to read, in part, as

follows:

Authority: 31 U.S.C. 9701.

Par. 2. Section 300.12 is amended by

revising paragraph (b) and (d) to read as

follows:

§ 300.12 Fee for estate tax closing

letter.

*****

(b) [The text of proposed § 300.12(b) is

the same as the text of § 300.12(b) in the

interim final rule published elsewhere in

this issue of the Federal Register].

*****

(d) [The text of proposed § 300.12(d)

is the same as the text of § 300.12(d)

in the interim final rule published elsewhere in this issue of the Federal Register].

Edward Killen,

Acting Chief Tax Compliance Officer.

(Filed by the Office of the Federal Register May 16,

2025, 8:45 a.m., and published in the issue of the

Federal Register for May 20, 2025, 90 FR 21439)

Bulletin No. 2025–32

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. 2025–32

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.

August 4, 2025

Numerical Finding List1

Bulletin 2025–32

Announcements:

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

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

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

Notices:

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

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

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

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

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

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

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

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

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

Proposed Regulations:

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

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

Revenue Procedures:

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

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

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

Revenue Rulings:

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

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

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

Treasury Decisions:

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

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

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

2025–52, dated December 22, 2025.

August 4, 2025

Bulletin No. 2025–32

Finding List of Current Actions on

Previously Published Items1

Bulletin 2025–32

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. 2025–32

iii

August 4, 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

www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.

NW, IR-6230 Washington, DC 20224.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.