Internal Revenue Bulletin 2025-48 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2025–48
November 24, 2025
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Notice 2025-62, page 740.
Notice 2025-62 provides penalty relief for taxable year 2025
in connection with the implementation of the new information
reporting requirements related to the deductions for qualified
tips and qualified overtime compensation that were added to
the Internal Revenue Code (Code) by Public Law 119-21, 139
Stat. 72 (July 4, 2025), commonly known as the One, Big, Beau-
tiful Bill Act (OBBBA). Specifically, this notice provides relief from
the penalty under section 6721 for failure to file correct infor-
mation returns and the penalty under section 6722 for failure
to furnish correct payee statements. This relief applies only for
taxable year 2025.
Rev. Rul. 2025-22, page 719.
Interest rates: underpayments and overpayments. The rates
for interest determined under Section 6621 of the code for
the calendar quarter beginning January 1, 2026, will be 7
percent for overpayments (6 percent in the case of a cor-
poration), 7 percent for underpayments, and 9 percent for
large corporate underpayments. The rate of interest paid on
the portion of a corporate overpayment exceeding $10,000
will be 4.5 percent.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2025-31, page 743.
This revenue procedure describes a safe harbor for trusts
that otherwise qualify as investment trusts under § 301.7701-
4(c) and as grantor trusts to stake their digital assets without
jeopardizing their tax status as investment trusts and grantor
trusts for Federal income tax purposes. This revenue proce-
dure also provides a limited time period for an existing trust
to amend its governing instrument to adopt the requirements
of the safe harbor.
Finding Lists begin on page ii.

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 offi-
cial 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 sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of inter-
nal 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 rul-
ings 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, disbar-
ment 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.
November 24, 2025 Bulletin No. 2025–48

Part I
Section 6621.—
Determination of Rate of
Interest
26 CFR 301.6621-1: Interest rate.
Rev. Rul. 2025-22
Section 6621 of the Internal Reve-
nue Code establishes the interest rates
on overpayments and underpayments of
tax. Under section 6621(a)(1), the over-
payment rate is the sum of the federal
short-term rate plus 3 percentage points (2
percentage points in the case of a corpo-
ration), except the rate for the portion of
a corporate overpayment of tax exceeding
$10,000 for a taxable period is the sum
of the federal short-term rate plus 0.5 of
a percentage point. Under section 6621(a)
(2), the underpayment rate is the sum of
the federal short-term rate plus 3 percent-
age points.
Section 6621(c) provides that for pur-
poses of interest payable under section
6601 on any large corporate underpay-
ment, the underpayment rate under sec-
tion 6621(a)(2) is determined by sub-
stituting “5 percentage points” for “3
percentage points.” See section 6621(c)
and section 301.6621-3 of the Regu-
lations on Procedure and Administra-
tion for the definition of a large corpo-
rate underpayment and for the rules for
determining the applicable date. Section
6621(c) and section 301.6621-3 are gen-
erally effective for periods after Decem-
ber 31, 1990.
Section 6621(b)(1) provides that the
Secretary will determine the federal short-
term rate for the first month in each cal-
endar quarter. Section 6621(b)(2)(A)
provides that the federal short-term rate
determined under section 6621(b)(1) for
any month applies during the first calen-
dar quarter beginning after that month.
Section 6621(b)(3) provides that the fed-
eral short-term rate for any month is the
federal short-term rate determined during
that month by the Secretary in accordance
with section 1274(d), rounded to the near-
est full percent (or, if a multiple of 1/2 of
1 percent, the rate is increased to the next
highest full percent).
Notice 88-59, 1988-1 C.B. 546,
announced that in determining the quar-
terly interest rates to be used for overpay-
ments and underpayments of tax under
section 6621, the Internal Revenue Ser-
vice will use the federal short-term rate
based on daily compounding because that
rate is most consistent with section 6621
which, pursuant to section 6622, is subject
to daily compounding.
The federal short-term rate determined
in accordance with section 1274(d) during
October 2025 is the rate published in
Revenue Ruling 2025-21, 2025-45 IRB
690, to take effect beginning Novem-
ber 1, 2025. The federal short-term rate,
rounded to the nearest full percent, based
on daily compounding determined during
the month of October 2025 is 4 percent.
Accordingly, an overpayment rate of 7
percent (6 percent in the case of a cor-
poration) and an underpayment rate of 7
percent are established for the calendar
quarter beginning January 1, 2026. The
overpayment rate for the portion of a cor-
porate overpayment exceeding $10,000
for the calendar quarter beginning January
1, 2026, is 4.5 percent. The underpayment
rate for large corporate underpayments for
the calendar quarter beginning January 1,
2026, is 9 percent. These rates apply to
amounts bearing interest during that cal-
endar quarter.
Sections 6654(a)(1) and 6655(a)
(1) provide that the underpayment rate
established under section 6621 applies
in determining the addition to tax under
sections 6654 and 6655 for failure to pay
estimated tax for any taxable year. Thus,
the 7 percent rate also applies to estimated
tax underpayments for the first calendar
quarter beginning January 1, 2026. Pursu-
ant to section 6621(b)(2)(B), in determin-
ing the addition to tax under section 6654
for any taxable year for an individual, the
federal short-term rate that applies during
the third month following the taxable year
also applies during the first 15 days of the
fourth month following the taxable year.
In addition, pursuant to section 6603(d)
(4), the rate of interest on section 6603
deposits is 4 percent for the first calendar
quarter in 2026.
Interest factors for daily compound
interest for annual rates of 4.5 percent, 6
percent, 7 percent and 9 percent are pub-
lished in Tables 14, 17, 19 and 23 of Rev.
Proc. 95-17, 1995-1 C.B. 568, 571, 573,
and 577.
Annual interest rates to be compounded
daily pursuant to section 6622 that apply
for prior periods are set forth in the tables
accompanying this revenue ruling.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Casey R. Conrad of the Office of
the Associate Chief Counsel (Procedure
and Administration). For further informa-
tion regarding this revenue ruling, contact
Mr. Conrad at (202) 317-6844 (not a toll-
free call).
Bulletin No. 2025–48 719 November 24, 2025

365 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013699630.0008633801250.001713784
20.000027397640.0008770911260.001727506
30.000041096650.0008908011270.001741228
40.000054796660.0009045121280.001754951
50.000068495670.0009182231290.001768673
60.000082195680.0009319341300.001782396
70.000095894690.0009456461310.001796119
80.000109594700.0009593571320.001809843
90.000123294710.0009730691330.001823566
100.000136995720.0009867811340.001837290
110.000150695730.0010004931350.001851013
120.000164396740.0010142061360.001864737
130.000178097750.0010279181370.001878462
140.000191798760.0010416311380.001892186
150.000205499770.0010553441390.001905910
160.000219201780.0010690571400.001919635
170.000232902790.0010827701410.001933360
180.000246604800.0010964841420.001947085
190.000260306810.0011101971430.001960811
200.000274008820.0011239111440.001974536
210.000287711830.0011376251450.001988262
220.000301413840.0011513391460.002001988
230.000315116850.0011650541470.002015714
240.000328819860.0011787681480.002029440
250.000342522870.0011924831490.002043166
260.000356225880.0012061981500.002056893
270.000369929890.0012199131510.002070620
280.000383633900.0012336291520.002084347
290.000397336910.0012473441530.002098074
300.000411041920.0012610601540.002111801
310.000424745930.0012747761550.002125529
320.000438449940.0012884921560.002139257
330.000452154950.0013022081570.002152985
340.000465859960.0013159251580.002166713
350.000479564970.0013296411590.002180441
360.000493269980.0013433581600.002194169
370.000506974990.0013570751610.002207898
380.0005206801000.0013707921620.002221627
390.0005343861010.0013845101630.002235356
400.0005480921020.0013982271640.002249085
410.0005617981030.0014119451650.002262815
420.0005755041040.0014256631660.002276544
November 24, 2025 720 Bulletin No. 2025–48

Bulletin No. 2025–48 721 November 24, 2025
430.0005892111050.0014393811670.002290274
440.0006029171060.0014531001680.002304004
450.0006166241070.0014668181690.002317734
460.0006303311080.0014805371700.002331465
470.0006440391090.0014942561710.002345195
480.0006577461100.0015079751720.002358926
490.0006714541110.0015216941730.002372657
500.0006851611120.0015354141740.002386388
510.0006988691130.0015491331750.002400120
520.0007125781140.0015628531760.002413851
530.0007262861150.0015765731770.002427583
540.0007399951160.0015902931780.002441315
550.0007537031170.0016040141790.002455047
560.0007674121180.0016177341800.002468779
570.0007811211190.0016314551810.002482511
580.0007948311200.0016451761820.002496244
590.0008085401210.0016588971830.002509977
600.0008222501220.0016726191840.002523710
610.0008359601230.001686340
620.0008496701240.001700062

November 24, 2025 722 Bulletin No. 2025–48
366 Day Year
0.5% Compound Rate 184 Days
DaysFactorDaysFactorDaysFactor
10.000013661630.0008610201250.001709097
20.000027323640.0008746931260.001722782
30.000040984650.0008883661270.001736467
40.000054646660.0009020401280.001750152
50.000068308670.0009157131290.001763837
60.000081970680.0009293871300.001777522
70.000095632690.0009430611310.001791208
80.000109295700.0009567351320.001804893
90.000122958710.0009704091330.001818579
100.000136620720.0009840841340.001832265
110.000150283730.0009977581350.001845951
120.000163947740.0010114331360.001859638
130.000177610750.0010251081370.001873324
140.000191274760.0010387831380.001887011
150.000204938770.0010524591390.001900698
160.000218602780.0010661341400.001914385
170.000232266790.0010798101410.001928073
180.000245930800.0010934861420.001941760
190.000259595810.0011071621430.001955448
200.000273260820.0011208391440.001969136
210.000286924830.0011345151450.001982824
220.000300590840.0011481921460.001996512
230.000314255850.0011618691470.002010201
240.000327920860.0011755461480.002023889
250.000341586870.0011892231490.002037578
260.000355252880.0012029001500.002051267
270.000368918890.0012165781510.002064957
280.000382584900.0012302561520.002078646
290.000396251910.0012439341530.002092336
300.000409917920.0012576121540.002106025
310.000423584930.0012712911550.002119715
320.000437251940.0012849691560.002133405
330.000450918950.0012986481570.002147096
340.000464586960.0013123271580.002160786
350.000478253970.0013260061590.002174477
360.000491921980.0013396851600.002188168
370.000505589990.0013533651610.002201859
380.0005192571000.0013670441620.002215550
390.0005329251010.0013807241630.002229242
400.0005465941020.0013944041640.002242933
410.0005602621030.0014080851650.002256625
420.0005739311040.0014217651660.002270317

Bulletin No. 2025–48 723 November 24, 2025
430.0005876001050.0014354461670.002284010
440.0006012691060.0014491271680.002297702
450.0006149391070.0014628081690.002311395
460.0006286081080.0014764891700.002325087
470.0006422781090.0014901701710.002338780
480.0006559481100.0015038521720.002352473
490.0006696181110.0015175331730.002366167
500.0006832891120.0015312151740.002379860
510.0006969591130.0015448971750.002393554
520.0007106301140.0015585801760.002407248
530.0007243011150.0015722621770.002420942
540.0007379721160.0015859451780.002434636
550.0007516431170.0015996281790.002448331
560.0007653151180.0016133111800.002462025
570.0007789861190.0016269941810.002475720
580.0007926581200.0016406781820.002489415
590.0008063301210.0016543611830.002503110
600.0008200031220.0016680451840.002516806
610.0008336751230.001681729
620.0008473481240.001695413

November 24, 2025 724 Bulletin No. 2025–48
TABLE OF INTEREST RATES
PERIODS BEFORE JUL. 1, 1975 - PERIODS ENDING DEC. 31, 1986
OVERPAYMENTS AND UNDERPAYMENTS
PERIODRATEIn 1995-1 C.B.
DAILY RATE TABLE
Before Jul. 1, 19756%Table2,pg.557
Jul. 1, 1975–Jan. 31, 19769%Table4,pg.559
Feb. 1, 1976–Jan. 31, 19787%Table3,pg.558
Feb. 1, 1978–Jan. 31, 19806%Table2,pg.557
Feb. 1, 1980–Jan. 31, 198212%Table5,pg.560
Feb. 1, 1982–Dec. 31, 198220%Table6,pg.560
Jan. 1, 1983–Jun. 30, 198316%Table37,pg.591
Jul. 1, 1983–Dec. 31, 198311%Table27,pg.581
Jan. 1, 1984–Jun. 30, 198411%Table75,pg.629
Jul. 1, 1984–Dec. 31, 198411%Table75,pg.629
Jan. 1, 1985–Dec. 31, 198513%Table31,pg.585
Jul. 1, 1985–Dec. 31, 198511%Table27,pg.581
Jan. 1, 1986–Jun. 30, 198610%Table25,pg.579
Jul. 1, 1986–Dec. 31, 19869%Table23,pg.577
TABLE OF INTEREST RATES
FROM JAN. 1, 1987 - Dec. 31, 1998
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B. RATE
RATETABLEPGRATETABLEPG
Jan. 1, 1987–Mar. 31, 19878%215759%23577
Apr. 1, 1987–Jun. 30, 19878%215759%23577
Jul. 1, 1987–Sep. 30, 19878%215759%23577
Oct. 1, 1987–Dec. 31, 19879%2357710%25579
Jan. 1, 1988–Mar. 31, 198810%7362711%75629
Apr. 1, 1988–Jun. 30, 19889%7162510%73627
Jul. 1, 1988–Sep. 30, 19889%7162510%73627
Oct. 1, 1988–Dec. 31, 198810%7362711%75629
Jan. 1, 1989–Mar. 31, 198910%2557911%27581
Apr. 1, 1989–Jun. 30, 198911%2758112%29583
Jul. 1, 1989–Sep. 30, 198911%2758112%29583
Oct. 1, 1989–Dec. 31, 198910%2557911%27581
Jan. 1, 1990–Mar. 31, 199010%2557911%27581
Apr. 1, 1990–Jun. 30, 199010%2557911%27581
Jul. 1, 1990–Sep. 30, 199010%2557911%27581
Oct. 1, 1990–Dec. 31, 199010%2557911%27581
Jan. 1, 1991–Mar. 31, 199110%2557911%27581
Apr. 1, 1991–Jun. 30, 19919%2357710%25579
Jul. 1, 1991–Sep. 30, 19919%2357710%25579
Oct. 1, 1991–Dec. 31, 19919%2357710%25579
Jan. 1, 1992–Mar. 31, 19928%696239%71625

Bulletin No. 2025–48 725 November 24, 2025
Apr. 1, 1992–Jun. 30, 19927%676218%69623
Jul. 1, 1992–Sep. 30, 19927%676218%69623
Oct. 1, 1992–Dec. 31, 19926%656197%67621
Jan. 1, 1993–Mar. 31, 19936%175717%19573
Apr. 1, 1993–Jun. 30, 19936%175717%19573
Jul. 1, 1993–Sep. 30, 19936%175717%19573
Oct. 1, 1993–Dec. 31, 19936%175717%19573
Jan. 1, 1994–Mar. 31, 19946%175717%19573
Apr. 1, 1994–Jun. 30, 19946%175717%19573
Jul. 1, 1994–Sep. 30, 19947%195738%21575
Oct. 1, 1994–Dec. 31, 19948%215759%23577
Jan. 1, 1995–Mar. 31, 19958%215759%23577
Apr. 1, 1995–Jun. 30, 19959%2357710%25579
Jul. 1, 1995–Sep. 30, 19958%215759%23577
Oct. 1, 1995–Dec. 31, 19958%215759%23577
Jan. 1, 1996–Mar. 31, 19968%696239%71625
Apr. 1, 1996–Jun. 30, 19967%676218%69623
Jul. 1, 1996–Sep. 30, 19968%696239%71625
Oct. 1, 1996–Dec. 31, 19968%696239%71625
Jan. 1, 1997–Mar. 31, 19978%215759%23577
Apr. 1, 1997–Jun. 30, 19978%215759%23577
Jul. 1, 1997–Sep. 30, 19978%215759%23577
Oct. 1, 1997–Dec. 31, 19978%215759%23577
Jan. 1, 1998–Mar. 31, 19988%215759%23577
Apr. 1, 1998–Jun. 30, 19987%195738%21575
Jul. 1, 1998–Sep. 30, 19987%195738%21575
Oct. 1, 1998–Dec. 31, 19987%195738%21575

November 24, 2025 726 Bulletin No. 2025–48
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
NONCORPORATE OVERPAYMENTS AND UNDERPAYMENTS
1995-1 C.B.
RATETABLEPAGE
Jan. 1, 1999–Mar. 31, 19997%19573
Apr. 1, 1999–Jun. 30, 19998%21575
Jul. 1, 1999–Sep. 30, 19998%21575
Oct. 1, 1999–Dec. 31, 19998%21575
Jan. 1, 2000–Mar. 31, 20008%69623
Apr. 1, 2000–Jun. 30, 20009%71625
Jul. 1, 2000–Sep. 30, 20009%71625
Oct. 1, 2000–Dec. 31, 20009%71625
Jan. 1, 2001–Mar. 31, 20019%23577
Apr. 1, 2001–Jun. 30, 20018%21575
Jul. 1, 2001–Sep. 30, 20017%19573
Oct. 1, 2001–Dec. 31, 20017%19573
Jan. 1, 2002–Mar. 31, 20026%17571
Apr. 1, 2002–Jun. 30, 20026%17571
Jul. 1, 2002–Sep. 30, 20026%17571
Oct. 1, 2002–Dec. 31, 20026%17571
Jan. 1, 2003–Mar. 31, 20035%15569
Apr. 1, 2003–Jun. 30, 20035%15569
Jul. 1, 2003–Sep. 30, 20035%15569
Oct. 1, 2003–Dec. 31, 20034%13567
Jan. 1, 2004–Mar. 31, 20044%61615
Apr. 1, 2004–Jun. 30, 20045%63617
Jul. 1, 2004–Sep. 30, 20044%61615
Oct. 1, 2004–Dec. 31, 20045%63617
Jan. 1, 2005–Mar. 31, 20055%15569
Apr. 1, 2005–Jun. 30, 20056%17571
Jul. 1, 2005–Sep. 30, 20056%17571
Oct. 1, 2005–Dec. 31, 20057%19573
Jan. 1, 2006–Mar. 31, 20067%19573
Apr. 1, 2006–Jun. 30, 20067%19573
Jul. 1, 2006–Sep. 30, 20068%21575
Oct. 1, 2006–Dec. 31, 20068%21575
Jan. 1, 2007–Mar. 31, 20078%21575
Apr. 1, 2007–Jun. 30, 20078%21575
Jul. 1, 2007–Sep. 30, 20078%21575
Oct. 1, 2007–Dec. 31, 20078%21575
Jan. 1, 2008–Mar. 31, 20087%67621
Apr. 1, 2008–Jun. 30, 20086%65619
Jul. 1, 2008–Sep. 30, 20085%63617
Oct. 1, 2008–Dec. 31, 20086%65619
Jan. 1, 2009–Mar. 31, 20095%15569

Bulletin No. 2025–48 727 November 24, 2025
Apr. 1, 2009–Jun. 30, 20094%13567
Jul. 1, 2009–Sep. 30, 20094%13567
Oct. 1, 2009–Dec. 31, 20094%13567
Jan. 1, 2010–Mar. 31, 20104%13567
Apr. 1, 2010–Jun. 30, 20104%13567
Jul. 1, 2010–Sep. 30, 20104%13567
Oct. 1, 2010–Dec. 31, 20104%13567
Jan. 1, 2011–Mar. 31, 20113%11565
Apr. 1, 2011–Jun. 30, 20114%13567
Jul. 1, 2011–Sep. 30, 20114%13567
Oct. 1, 2011–Dec. 31, 20113%11565
Jan. 1, 2012–Mar. 31, 20123%59613
Apr. 1, 2012–Jun. 30, 20123%59613
Jul. 1, 2012–Sep. 30, 20123%59613
Oct. 1, 2012–Dec. 31, 20123%59613
Jan. 1, 2013–Mar. 31, 20133%11565
Apr. 1, 2013–Jun. 30, 20133%11565
Jul. 1, 2013–Sep. 30, 20133%11565
Oct. 1, 2013–Dec. 31, 20133%11565
Jan. 1, 2014–Mar. 31, 20143%11565
Apr. 1, 2014–Jun. 30, 20143%11565
Jul. 1, 2014–Sep. 30, 20143%11565
Oct. 1, 2014–Dec. 31, 20143%11565
Jan. 1, 2015–Mar. 31, 20153%11565
Apr. 1, 2015–Jun. 30, 20153%11565
Jul. 1, 2015–Sep. 30, 20153%11565
Oct. 1, 2015–Dec. 31, 20153%11565
Jan. 1, 2016–Mar. 31, 20163%59613
Apr. 1, 2016–Jun. 30, 20164%61615
Jul. 1, 2016–Sep. 30, 20164%61615
Oct. 1, 2016–Dec. 31, 20164%61615
Jan. 1, 2017–Mar. 31, 20174%13567
Apr. 1, 2017–Jun. 30, 20174%13567
Jul. 1, 2017–Sep. 30, 20174%13567
Oct. 1, 2017–Dec. 31, 20174%13567
Jan. 1, 2018–Mar. 31, 20184%13567
Apr. 1, 2018–Jun. 30, 20185%15569
Jul. 1, 2018–Sep. 30, 20185%15569
Oct. 1, 2018–Dec. 31, 20185%15569
Jan. 1, 2019–Mar. 31, 20196%17571
Apr. 1, 2019–Jun. 30, 20196%17571
Jul. 1, 2019–Sep. 30, 20195%15569
Oct. 1, 2019–Dec. 31, 20195%15569
Jan. 1, 2020–Mar. 31, 20205%63617
Apr. 1, 2020–Jun. 30, 20205%63617

November 24, 2025 728 Bulletin No. 2025–48
Jul. 1, 2020–Sep. 30, 20203%59613
Oct. 1, 2020–Dec. 31, 20203%59613
Jan. 1, 2021–Mar. 31, 20213%11565
Apr. 1, 2021–Jun. 30, 20213%11565
Jul. 1, 2021–Sep. 30, 20213%11565
Oct. 1, 2021–Dec. 31, 20213%11565
Jan. 1, 2022–Mar. 31, 20223%11565
Apr. 1, 2022–Jun. 30, 20224%13567
Jul. 1, 2022–Sep. 30, 20225%15569
Oct. 1, 2022–Dec. 31, 20226%17571
Jan. 1, 2023–Mar. 31, 20237%19573
Apr. 1, 2023–Jun. 30, 20237%19573
Jul. 1, 2023–Sep. 30, 2023 7%19573
Oct. 1, 2023–Dec. 31, 20238%21575
Jan. 1, 2024–Mar. 31, 20248%69623
Apr. 1, 2024–Jun. 30, 20248%69623
Jul. 1, 2024–Sep. 30, 20248%69623
Oct. 1, 2024–Dec. 31, 20248%69623
Jan. 1, 2025–Mar. 31, 20257%19573
Apr. 1, 2025–Jun. 30, 20257%19573
Jul. 1, 2025–Sep. 30, 20257%19573
Oct. 1, 2025–Dec. 31, 20257%19573
Jan. 1, 2026–Mar. 31, 20267%19573

Bulletin No. 2025–48 729 November 24, 2025
TABLE OF INTEREST RATES
FROM JANUARY 1, 1999 - PRESENT
CORPORATE OVERPAYMENTS AND UNDERPAYMENTS
OVERPAYMENTSUNDERPAYMENTS
1995-1 C.B.1995-1 C.B.
RATETABLEPGRATETABLEPG
Jan. 1, 1999–Mar. 31, 19996%175717%19573
Apr. 1, 1999–Jun. 30, 19997%195738%21575
Jul. 1, 1999–Sep. 30, 19997%195738%21575
Oct. 1, 1999–Dec. 31, 19997%195738%21575
Jan. 1, 2000–Mar. 30, 20007%676218%69623
Apr. 1, 2000–Jun. 30, 20008%696239%71625
Jul. 1, 2000–Sep. 30, 20008%696239%71625
Oct. 1, 2000–Dec. 31, 20008%696239%71625
Jan. 1, 2001–Mar. 31, 20018%215759%23577
Apr. 1, 2001–Jun. 30, 20017%195738%21575
Jul. 1, 2001–Sep. 30, 20016%175717%19573
Oct. 1, 2001–Dec. 31, 20016%175717%19573
Jan. 1, 2002–Mar. 31, 20025%155696%17571
Apr. 1, 2002–Jun. 30, 20025%155696%17571
Jul. 1, 2002–Sep. 30, 20025%155696%17571
Oct. 1, 2002–Dec. 31, 20025%155696%17571
Jan. 1, 2003–Mar. 31, 20034%135675%15569
Apr. 1, 2003–Jun. 30, 20034%135675%15569
Jul. 1, 2003–Sep. 30, 20034%135675%15569
Oct. 1, 2003–Dec. 31, 20033%115654%13567
Jan. 1, 2004–Mar. 31, 20043%596134%61615
Apr. 1, 2004–Jun. 30, 20044%616155%63617
Jul. 1, 2004–Sep. 30, 20043%596134%61615
Oct. 1, 2004–Dec. 31, 20044%616155%63617
Jan. 1, 2005–Mar. 31, 20054%135675%15569
Apr. 1, 2005–Jun. 30, 20055%155696%17571
Jul. 1, 2005–Sep. 30, 20055%155696%17571
Oct. 1, 2005–Dec. 31, 20056%175717%19573
Jan. 1, 2006–Mar. 31, 20066%175717%19573
Apr. 1, 2006–Jun. 30, 20066%175717%19573
Jul. 1, 2006–Sep. 30, 20067%195738%21575
Oct. 1, 2006–Dec. 31, 20067%195738%21575
Jan. 1, 2007–Mar. 31, 20077%195738%21575
Apr. 1, 2007–Jun. 30, 20077%195738%21575
Jul. 1, 2007–Sep. 30, 20077%195738%21575
Oct. 1, 2007–Dec. 31, 20077%195738%21575
Jan. 1, 2008–Mar. 31, 20086%656197%67621
Apr. 1, 2008–Jun. 30, 20085%636176%65619
Jul. 1, 2008–Sep. 30, 20084%616155%63617
Oct. 1, 2008–Dec. 31, 20085%636176%65619

November 24, 2025 730 Bulletin No. 2025–48
Jan. 1, 2009–Mar. 31, 20094%135675%15569
Apr. 1, 2009–Jun. 30, 20093%115654%13567
Jul. 1, 2009–Sep. 30, 20093%115654%13567
Oct. 1, 2009–Dec. 31, 20093%115654%13567
Jan. 1, 2010–Mar. 31, 20103%115654%13567
Apr. 1, 2010–Jun. 30, 20103%115654%13567
Jul. 1, 2010–Sep. 30, 20103%115654%13567
Oct. 1, 2010–Dec. 31, 20103%115654%13567
Jan. 1, 2011–Mar. 31, 20112%95633%11565
Apr. 1, 2011–Jun. 30, 20113%115654%13567
Jul. 1, 2011–Sep. 30, 20113%115654%13567
Oct. 1, 2011–Dec. 31, 20112%95633%11565
Jan. 1, 2012–Mar. 31, 20122%576113%59613
Apr. 1, 2012–Jun. 30, 20122%576113%59613
Jul. 1, 2012–Sep. 30, 20122%576113%59613
Oct. 1, 2012–Dec. 31, 20122%576113%59613
Jan. 1, 2013–Mar. 31, 20132%95633%11565
Apr. 1, 2013–Jun. 30, 20132%95633%11565
Jul. 1, 2013–Sep. 30, 20132%95633%11565
Oct. 1, 2013–Dec. 31, 20132%95633%11565
Jan. 1, 2014–Mar. 31, 20142%95633%11565
Apr. 1, 2014–Jun. 30, 20142%95633%11565
Jul. 1, 2014–Sep. 30, 20142%95633%11565
Oct. 1, 2014–Dec. 31, 20142%95633%11565
Jan. 1, 2015–Mar. 31, 20152%95633%11565
Apr. 1, 2015–Jun. 30, 20152%95633%11565
Jul. 1, 2015–Sep. 30, 20152%95633%11565
Oct. 1, 2015–Dec. 31, 20152%95633%11565
Jan. 1, 2016–Mar. 31, 20162%576113%59613
Apr. 1, 2016–Jun. 30, 20163%596134%61615
Jul. 1, 2016–Sep. 30, 20163%596134%61615
Oct. 1, 2016–Dec. 31, 20163%596134%61615
Jan. 1, 2017–Mar. 31, 20173%115654%13567
Apr. 1, 2017–Jun. 30, 20173%115654%13567
Jul. 1, 2017–Sep. 30, 20173%115654%13567
Oct. 1, 2017–Dec. 31, 20173%115654%13567
Jan. 1, 2018–Mar. 31, 20183%115654%13567
Apr. 1, 2018–Jun. 30, 20184%135675%15569
Jul. 1, 2018–Sep. 30, 20184%135675%15569
Oct. 1, 2018–Dec. 31, 20184%135675%15569
Jan. 1, 2019–Mar. 31, 20195%155696%17571
Apr. 1, 2019–Jun. 30, 20195%155696%17571
Jul. 1, 2019–Sep. 30, 20194%135675%15569
Oct. 1, 2019–Dec. 31, 20194%135675%15569
Jan. 1, 2020–Mar. 31, 20204%616155%63617

Bulletin No. 2025–48 731 November 24, 2025
Apr. 1, 2020–Jun. 30, 20204%616155%63617
Jul. 1, 2020–Sep. 30, 20202%576113%59613
Oct. 1, 2020–Dec. 31, 20202%576113%59613
Jan. 1, 2021–Mar. 31, 20212%95633%11565
Apr. 1, 2021–Jun. 30, 20212%95633%11565
Jul. 1, 2021–Sep. 30, 20212%95633%11565
Oct. 1, 2021–Dec. 31, 20212%95633%11565
Jan. 1, 2022–Mar. 31, 20222%95633%11565
Apr. 1, 2022–Jun. 30, 20223%115654%13567
Jul. 1, 2022–Sep. 30, 20224%135675%15569
Oct. 1, 2022–Dec. 31, 20225%155696%17571
Jan. 1, 2023–Mar. 31, 20236%175717%19573
Apr. 1, 2023–Jun. 30, 20236%175717%19573
Jul. 1, 2023–Sep. 30, 20236%175717%19573
Oct. 1, 2023–Dec. 31, 20237%195738%21575
Jan. 1, 2024–Mar. 31, 20247%676218%69623
Apr. 1, 2024–Jun. 30, 20247%676218%69623
Jul. 1, 2024–Sep. 30, 20247%676218%69623
Oct. 1, 2024–Dec. 31, 20247%676218%69623
Jan. 1, 2025–Mar. 31, 2025 6%175717%19573
Apr. 1, 2025–Jun. 30, 20256%175717%19573
Jul. 1, 2025–Sep. 30, 20256%175717%19573
Oct. 1, 2025–Dec. 31, 20256%175717%19573
Jan. 1, 2026–Mar. 31, 20266%175717%19573

November 24, 2025 732 Bulletin No. 2025–48
TABLE OF INTEREST RATES
FOR LARGE CORPORATE UNDERPAYMENTS
FROM JANUARY 1, 1991 – PRESENT
1995-1 C.B.
PERIODRATETABLEPG
Jan. 1, 1991–Mar. 31, 199113%31585
Apr. 1, 1991–Jun. 30, 199112%29583
Jul. 1, 1991–Sep. 30, 199112%29583
Oct. 1, 1991–Dec. 31, 199112%29583
Jan. 1, 1992–Mar. 31, 199211%75629
Apr. 1, 1992–Jun. 30, 199210%73627
Jul. 1, 1992–Sep. 30, 199210%73627
Oct. 1, 1992–Dec. 31, 19929%71625
Jan. 1, 1993–Mar. 31, 19939%23577
Apr. 1, 1993–Jun. 30, 19939%23577
Jul. 1, 1993–Sep. 30, 19939%23577
Oct. 1, 1993–Dec. 31, 19939%23577
Jan. 1, 1994–Mar. 31, 19949%23577
Apr. 1, 1994–Jun. 30, 19949%23577
Jul. 1, 1994–Sep. 30, 199410%25579
Oct. 1, 1994–Dec. 31, 199411%27581
Jan. 1, 1995–Jun. 30, 199511%27581
Apr. 1, 1995–Jun. 30, 199512%29583
Jul. 1, 1995–Sep. 30, 199511%27581
Oct. 1, 1995–Dec. 31, 199511%27581
Jan. 1, 1996–Mar. 31, 199611%75629
Apr. 1, 1996–Jun. 30, 199610%73627
Jul. 1, 1996–Sep. 30, 199611%75629
Oct. 1, 1996–Dec. 31, 199611%75629
Jan. 1, 1997–Mar. 31, 199711%27581
Apr. 1, 1997–Jun. 30, 199711%27581
Jul. 1, 1997–Sep. 30, 199711%27581
Oct. 1, 1997–Dec. 31, 199711%27581
Jan. 1, 1998–Mar. 31, 199811%27581
Apr. 1, 1998–Jun. 30, 199810%25579
Jul. 1, 1998–Sep. 30, 199810%25579
Oct. 1, 1998–Dec. 31, 199810%25579
Jan. 1, 1999–Mar. 31, 19999%23577
Apr. 1, 1999–Jun. 30, 199910%25579
Jul. 1, 1999–Sep. 30, 199910%25579
Oct. 1, 1999–Dec. 31, 199910%25579
Jan. 1, 2000–Mar. 31, 200010%73627
Apr. 1, 2000–Jun. 30, 200011%75629
Jul. 1, 2000–Sep. 30, 200011%75629
Oct. 1, 2000–Dec. 31, 200011%75629
Jan. 1, 2001–Mar. 31, 200111%27581

Bulletin No. 2025–48 733 November 24, 2025
Apr. 1, 2001–Jun. 30, 200110%25579
Jul. 1, 2001–Sep. 30, 20019%23577
Oct. 1, 2001–Dec. 31, 20019%23577
Jan. 1, 2002–Mar. 31, 20028%21575
Apr. 1, 2002–Sep. 30, 20028%21575
Jul. 1, 2002–Sep. 30, 20028%21575
Oct. 1, 2002–Dec. 31, 20028%21575
Jan. 1, 2003–Mar. 31, 20037%19573
Apr. 1, 2003–Jun. 30, 20037%19573
Jul. 1, 2003–Sep. 30, 20037%19573
Oct. 1, 2003–Dec. 31, 20036%17571
Jan. 1, 2004–Mar. 31, 20046%65619
Apr. 1, 2004–Jun. 30, 20047%67621
Jul. 1, 2004–Sep. 30, 20046%65619
Oct. 1, 2004–Dec. 31, 20047%67621
Jan. 1, 2005–Mar. 31, 20057%19573
Apr. 1, 2005–Jun. 30, 20058%21575
Jul. 1, 2005–Sep. 30, 20058%21575
Oct. 1, 2005–Dec. 31, 20059%23577
Jan. 1, 2006–Mar. 31, 20069%23577
Apr. 1, 2006–Jun. 30, 20069%23577
Jul. 1, 2006–Sep. 30, 200610%25579
Oct. 1, 2006–Dec. 31, 200610%25579
Jan. 1, 2007–Mar. 31, 200710%25579
Apr. 1, 2007–Jun. 30, 200710%25579
Jul. 1, 2007–Sep. 30, 200710%25579
Oct. 1, 2007–Dec. 31, 200710%25579
Jan. 1, 2008–Mar. 31, 20089%71625
Apr. 1, 2008–Sep. 30, 20088%69623
Jul. 1, 2008–Sep. 30, 20087%67621
Oct. 1, 2008–Dec. 31, 20088%69623
Jan. 1, 2009–Mar. 31, 20097%19573
Apr. 1, 2009–Jun. 30, 20096%17571
Jul. 1, 2009–Sep. 30, 20096%17571
Oct. 1, 2009–Dec. 31, 20096%17571
Jan. 1, 2010–Mar. 31, 20106%17571
Apr. 1, 2010–Jun. 30, 20106%17571
Jul. 1, 2010–Sep. 30, 20106%17571
Oct. 1, 2010–Dec. 31, 20106%17571
Jan. 1, 2011-Mar. 31, 20115%15569
Apr. 1, 2011–Jun. 30, 20116%17571
Jul. 1, 2011–Sep. 30, 20116%17571
Oct. 1, 2011–Dec. 31, 20115%15569
Jan. 1, 2012–Mar. 31, 20125%63617
Apr. 1, 2012-Jun. 30, 20125%63617

November 24, 2025 734 Bulletin No. 2025–48
Jul. 1, 2012–Sep. 30, 20125%63617
Oct. 1, 2012–Dec. 31, 20125%63617
Jan. 1, 2013–Mar. 31, 20135%15569
Apr. 1, 2013–Jun. 30, 20135%15569
Jul. 1, 2013–Sep. 30, 20135%15569
Oct. 1, 2013–Dec. 31, 20135%15569
Jan. 1, 2014–Mar. 31, 20145%15569
Apr. 1, 2014–Jun. 30, 20145%15569
Jul. 1, 2014–Sep. 30, 20145%15569
Oct. 1, 2014–Dec. 31, 20145%15569
Jan. 1, 2015–Mar. 31, 20155%15569
Apr. 1, 2015–Jun. 30, 20155%15569
Jul. 1, 2015–Sep. 30, 20155%15569
Oct. 1, 2015–Dec. 31, 20155%15569
Jan. 1, 2016–Mar. 31, 20165%63617
Apr. 1, 2016–Jun. 30, 20166%65619
Jul. 1, 2016–Sep. 30, 20166%65619
Oct. 1, 2016–Dec. 31, 20166%65619
Jan. 1, 2017–Mar. 31, 20176%17571
Apr. 1, 2017–Jun. 30, 20176%17571
Jul. 1, 2017–Sep. 30, 20176%17571
Oct. 1, 2017–Dec. 31, 20176%17571
Jan. 1, 2018–Mar. 31, 20186%17571
Apr. 1, 2018–Jun. 30, 20187%19573
Jul. 1, 2018–Sep. 30, 20187%19573
Oct. 1, 2018–Dec. 31, 20187%19573
Jan. 1, 2019–Mar. 31, 20198%21575
Apr. 1, 2019–Jun. 30, 20198%21575
Jul. 1, 2019–Sep. 30, 20197%19573
Oct. 1, 2019–Dec. 31, 20197%19573
Jan. 1, 2020–Mar. 31, 20207%67621
Apr. 1, 2020–Jun. 30, 20207%67621
Jul. 1, 2020–Sep. 30, 20205%63617
Oct. 1, 2020–Dec. 31, 20205%63617
Jan. 1, 2021–Mar. 31, 20215%15569
Apr. 1, 2021–Jun. 30, 20215%15569
Jul. 1, 2021–Sep. 30, 20215%15569
Oct. 1, 2021–Dec. 31, 20215%15569
Jan. 1, 2022–Mar. 31, 20225%15569
Apr. 1, 2022–Jun. 30, 20226%17571
Jul. 1, 2022–Sep. 30, 20227%19573
Oct. 1, 2022–Dec. 31, 20228%21575
Jan. 1, 2023–Mar. 31, 20239%23577
Apr. 1, 2023-Jun. 30, 20239%23577
Jul. 1, 2023–Sep. 30, 20239%23577

Bulletin No. 2025–48 735 November 24, 2025
Oct. 1, 2023–Dec. 31, 202310%25579
Jan. 1, 2024–Mar. 31, 202410%73627
Apr. 1, 2024–Jun. 30, 202410%73627
Jul. 1, 2024–Sep. 30, 202410%73627
Oct. 1, 2024–Dec. 31, 202410%73627
Jan. 1, 2025–Mar. 31, 20259%23577
Apr. 1, 2025–Jun. 30, 20259%23577
Jul. 1, 2025–Sep. 30, 20259%23577
Oct. 1, 2025–Dec. 31, 20259%23577
Jan. 1, 2026–Mar. 31, 20269%23577

November 24, 2025 736 Bulletin No. 2025–48
TABLE OF INTEREST RATES FOR CORPORATE
OVERPAYMENTS EXCEEDING $10,000
FROM JANUARY 1, 1995 – PRESENT
1995-1 C.B.
PERIODRATETABLEPG
Jan. 1, 1995–Mar. 31, 19956.5%18572
Apr. 1, 1995–Jun. 30, 19957.5%20574
Jul. 1, 1995–Sep. 30, 19956.5%18572
Oct. 1, 1995–Dec. 31, 19956.5%18572
Jan. 1, 1996–Mar. 31, 19966.5%66620
Apr. 1, 1996–Jun. 30, 19965.5%64618
Jul. 1, 1996–Sep. 30, 19966.5%66620
Oct. 1, 1996–Dec. 31, 19966.5%66620
Jan. 1, 1997–Mar. 31, 19976.5%18572
Apr. 1, 1997–Jun. 30, 19976.5%18572
Jul. 1, 1997–Sep. 30, 19976.5%18572
Oct. 1, 1997–Dec. 31, 19976.5%18572
Jan. 1, 1998–Mar. 31, 19986.5%18572
Apr. 1, 1998–Jun. 30, 19985.5%16570
Jul. 1, 1998–Sep. 30, 19985.5%16570
Oct. 1, 1998–Dec. 31, 19985.5%16570
Jan. 1, 1999–Mar. 31, 19994.5%14568
Apr. 1, 1999–Sep. 30, 19995.5%16570
Jul. 1, 1999–Sep. 30, 19995.5%16570
Oct. 1, 1999–Dec. 31, 19995.5%16570
Jan. 1, 2000–Mar. 31, 20005.5%64618
Apr. 1, 2000–Jun. 30, 20006.5%66620
Jul. 1, 2000–Sep. 30, 20006.5%66620
Oct. 1, 2000–Dec. 31, 20006.5%66620
Jan. 1, 2001–Mar. 31, 20016.5%18572
Apr. 1, 2001–Jun. 30, 20015.5%16570
Jul. 1, 2001–Sep. 30, 20014.5%14568
Oct. 1, 2001–Dec. 31, 20014.5%14568
Jan. 1, 2002–Mar. 31, 20023.5%12566
Apr. 1, 2002–Jun. 30, 20023.5%12566
Jul. 1, 2002–Sep. 30, 20023.5%12566
Oct. 1, 2002–Dec. 31, 20023.5%12566
Jan. 1, 2003–Mar. 31, 20032.5%10564
Apr. 1, 2003–Jun. 30, 20032.5%10564
Jul. 1, 2003–Sep. 30, 20032.5%10564
Oct. 1, 2003–Dec. 31, 20031.5%8562
Jan. 1, 2004–Mar. 31, 20041.5%56610
Apr. 1, 2004–Jun. 30, 20042.5%58612

Bulletin No. 2025–48 737 November 24, 2025
Jul. 1, 2004–Sep. 30, 20041.5%56610
Oct. 1, 2004–Dec. 31, 20042.5%58612
Jan. 1, 2005–Mar. 31, 20052.5%10564
Apr. 1, 2005–Jun. 30, 20053.5%12566
Jul. 1, 2005–Sep. 30, 20053.5%12566
Oct. 1, 2005–Dec. 31, 20054.5%14568
Jan. 1, 2006–Mar. 31, 20064.5%14568
Apr. 1, 2006–Jun. 30, 20064.5%14568
Jul. 1, 2006–Sep. 30, 20065.5%16570
Oct. 1, 2006–Dec. 31, 20065.5%16570
Jan. 1, 2007–Mar. 31, 20075.5%16570
Apr. 1, 2007–Jun. 30, 20075.5%16570
Jul. 1, 2007–Sep. 30, 20075.5%16570
Oct. 1, 2007–Dec. 31, 20075.5%16570
Jan. 1, 2008–Mar. 31, 20084.5%62616
Apr. 1, 2008–Jun. 30, 20083.5%60614
Jul. 1, 2008–Sep. 30, 20082.5%58612
Oct. 1, 2008–Dec. 31, 20083.5%60614
Jan. 1, 2009–Mar. 31, 20092.5%10564
Apr. 1, 2009–Jun. 30, 20091.5%8562
Jul. 1, 2009–Sep. 30, 20091.5%8562
Oct. 1, 2009–Dec. 31, 20091.5%8562
Jan. 1, 2010–Mar. 31, 20101.5%8562
Apr. 1, 2010–Jun. 30, 20101.5%8562
Jul. 1, 2010–Sep. 30, 20101.5%8562
Oct. 1, 2010–Dec. 31, 20101.5%8562
Jan. 1, 2011–Mar. 31, 20110.5%*
Apr. 1, 2011–Jun. 30, 20111.5%8562
Jul. 1, 2011–Sep. 30, 20111.5%8562
Oct. 1, 2011–Dec. 31, 20110.5%*
Jan. 1, 2012–Mar. 31, 20120.5%*
Apr. 1, 2012–Jun. 30, 20120.5%*
Jul. 1, 2012–Sep. 30, 20120.5%*
Oct. 1, 2012–Dec. 31, 20120.5%*
Jan. 1, 2013–Mar. 31, 20130.5%*
Apr. 1, 2013–Jun. 30, 20130.5%*
Jul. 1, 2013–Sep. 30, 20130.5%*
Oct. 1, 2013–Dec. 31, 20130.5%*
Jan. 1, 2014–Mar. 31, 20140.5%*
Apr. 1, 2014–Jun. 30, 20140.5%*
Jul. 1, 2014–Sep. 30, 20140.5%*
Oct. 1, 2014–Dec. 31, 20140.5%*

November 24, 2025 738 Bulletin No. 2025–48
Jan. 1, 2015–Mar. 31, 20150.5%*
Apr. 1, 2015–Jun. 30, 20150.5%*
Jul. 1, 2015–Sep. 30, 20150.5%*
Oct. 1, 2015–Dec. 31, 20150.5%*
Jan. 1, 2016–Mar. 31, 20160.5%*
Apr. 1, 2016–Jun. 30, 20161.5%56610
Jul. 1, 2016–Sep. 30, 20161.5%56610
Oct. 1, 2016–Dec. 31, 20161.5%56610
Jan. 1, 2017–Mar. 31, 20171.5%8562
Apr. 1, 2017–Jun. 30, 20171.5%8562
Jul. 1, 2017–Sep. 30, 20171.5%8562
Oct. 1, 2017–Dec. 31, 20171.5%8562
Jan. 1, 2018–Mar. 31, 20181.5%8562
Apr. 1, 2018–Jun. 30, 20182.5%10564
Jul. 1, 2018–Sep. 30, 20182.5%10564
Oct. 1, 2018–Dec. 31, 20182.5%10564
Jan. 1, 2019–Mar. 31, 20193.5%12566
Apr. 1, 2019–Jun. 30, 20193.5%12566
Jul. 1, 2019–Sep. 30, 20192.5%10564
Oct. 1, 2019–Dec. 31, 20192.5%10564
Jan. 1, 2020–Mar. 31, 20202.5%58612
Apr. 1, 2020–Jun. 30, 20202.5%58612
Jul. 1, 2020–Sep. 30, 20200.5%*
Oct. 1, 2020–Dec. 31, 20200.5%*
Jan. 1, 2021–Mar. 31, 20210.5%*
Apr. 1, 2021–Jun. 30, 20210.5%*
Jul. 1, 2021–Sep. 30, 20210.5%*
Oct. 1, 2021–Dec. 31, 20210.5%*
Jan. 1, 2022–Mar. 31, 20220.5%*
Apr. 1, 2022–Jun. 30, 20221.5%8562
Jul. 1, 2022–Sep. 30, 20222.5%10564
Oct. 1, 2022–Dec. 31, 20223.5%12566
Jan. 1, 2023–Mar. 31, 20234.5%14568
Apr. 1, 2023–Jun. 30, 20234.5%14568
Jul. 1, 2023–Sep. 30, 2023 4.5%14568
Oct. 1, 2023–Dec. 31, 20235.5%16570
Jan. 1, 2024–Mar. 31, 2024 5.5%64618
Apr. 1, 2024–Jun. 30, 20245.5%64618
Jul. 1, 2024–Sep. 30, 20245.5%64618
Oct. 1, 2024–Dec. 31, 20245.5%64618
Jan. 1, 2025–Mar. 31, 20254.5%14568
Apr. 1, 2025–Jun. 30, 20254.5%14568

Bulletin No. 2025–48 739 November 24, 2025
Jul. 1, 2025–Sep. 30, 20254.5%14568
Oct. 1, 2025–Dec. 31, 20254.5%14568
Jan. 1, 2026–Mar. 31, 20264.5%14568
* The asterisk reflects the interest factors for daily compound interest for annual rates of 0.5 percent published in Appendix A of
this Revenue Ruling.

November 24, 2025 740 Bulletin No. 2025–48
Part III
Relief from Certain
Penalties Related to
Information Reporting
Required in Connection
with No Tax on Tips and
Overtime
Notice 2025-62
SECTION 1. PURPOSE
This notice provides penalty relief
for taxable year 2025 in connection with
the implementation of the new informa-
tion reporting requirements related to the
deductions for qualified tips and qualified
overtime compensation that were added
to the Internal Revenue Code (Code)
1
by
Public Law 119-21, 139 Stat. 72 (July 4,
2025), commonly known as the One, Big,
Beautiful Bill Act (OBBBA). Specifically,
this notice provides relief from the pen-
alty under section 6721 for failure to file
correct information returns and the pen-
alty under section 6722 for failure to fur-
nish correct payee statements. This relief
applies only for taxable year 2025.
Additional guidance for individual
taxpayers that addresses how they can
claim the deductions for qualified tips and
qualified overtime compensation when
they file their taxable year 2025 returns is
forthcoming.
SECTION 2. BACKGROUND
.01 Filing and Information Reporting
Requirements Generally
Section 6041(a) requires a person
engaged in a trade or business generally
to file an information return with the Sec-
retary of the Treasury or the Secretary’s
delegate (Secretary) if the person made
payments in the course of such trade or
business to another person of fixed or
determinable income such as rent, sala-
ries, wages, premiums, annuities, or com-
pensation in amounts above the applicable
reporting threshold in any taxable year.
The information return must include the
amount of the gains, profits, and income
and the name and address of the recipi-
ent of the payment. A person who files a
return pursuant to section 6041(a) must
also, pursuant to section 6041(d), furnish
to the payee a written statement showing
the name, address, and phone number of
the person required to make the return,
and the aggregate amount of payments to
the payee.
Section 6041A imposes similar filing
and furnishing requirements as section
6041(a) with respect to persons engaged
in a trade or business and who pay in the
course of such trade or business remuner-
ation to any person for services performed
in amounts aggregating above the applica-
ble reporting threshold during the calen-
dar year. The information return required
under section 6041A(a) must include the
aggregate amount of the payments and
the name and address of the recipient. A
person who files a return under section
6041A(a) is required by section 6041A(e)
to furnish to the payee a written statement
showing the name, address, and phone
number of the person required to make
such return, and the aggregate amount of
payments to the payee.
Information returns are also required
to be filed pursuant to section 6050W(a)
by certain payment settlement entities
with respect to payments made in settle-
ment of reportable payment transactions.
Returns required by section 6050W(a)
must include the name, address, and tax-
payer identification number of the payee,
and the gross amount of the reportable
payment transactions to the payee. Under
section 6050W(f), a payment settlement
entity required to file a return must also
furnish to each payee a written statement
showing the name, address, and phone
number of the information contact of the
person required to make such return, and
the gross amount paid to the payee.
Section 6050W applies to two types
of transactions: (1) payment card trans-
actions and (2) third party network trans-
actions. All payments made in settlement
of payment card transactions must be
reported in the manner described above.
Section 6050W(e) provides that payments
made by a third party settlement organi-
zation (TPSO) in settlement of third party
network transactions must be reported
only if the gross amount of payments to
a payee exceeds the de minimis reporting
threshold rules.
For wages paid to an employee,
an employer is required under section
6051(a) to furnish a written statement to
the employee if it is required to deduct and
withhold from the employee a tax under
section 3101 or 3402, or would have been
required to deduct and withhold a tax
under section 3402 if the employee had
claimed no more than one withholding
exemption, or if it pays remuneration for
services performed by the employee. The
written statement must show, among other
things, the total amount of wages paid,
including tips received by an employee in
the course of his employment, but only if
such tips are included in statements fur-
nished to the employer pursuant to section
6053(a), and the amount of income and
employment taxes deducted and withheld.
An employer required to furnish a writ-
ten statement to an employee under sec-
tion 6051(a) must also file a copy of each
written statement with the Social Security
Administration (SSA) pursuant to section
6051(d).
.02 OBBBA Amendments to Sections
6041, 6041A, and 6050W
Before amendment by section 70433
of the OBBBA, the applicable reporting
threshold in each of section 6041 and
6041A was $600. Section 70433(a) of the
OBBBA increased the reporting threshold
under section 6041(a) from $600 to $2,000
with respect to payments made after
December 31, 2025, and before January
1, 2027. For payments made after Decem-
ber 31, 2026, section 6041(h), as added by
section 70433(b) of the OBBBA, provides
for an annual inflation adjustment to the
reporting threshold under section 6041(a).
Section 70433(c) of the OBBBA amended
the reporting threshold under section
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code.

Bulletin No. 2025–48 741 November 24, 2025
6041A from $600 or more to an amount
that equals or exceeds the dollar amount in
effect for such taxable year under section
6041(a).
Before amendment by section 70432
of the OBBBA, the de minimis reporting
threshold in section 6050W(e) was $600
as enacted by section 9674(a) of the Amer-
ican Rescue Plan Act of 2021, Public Law
117-2, 135 Stat. 4 (March 11, 2021). Sec-
tion 70432(a) of the OBBBA retroactively
amended the de minimis reporting thresh-
old rules of section 6050W(e) by specify-
ing that the amendment “take effect as if
included in section 9674 of the American
Rescue Plan Act.” After amendment by
the OBBBA, section 6050W(e) provides
that payments made by a TPSO in settle-
ment of third party network transactions
must be reported only if the gross amount
of payments to a payee exceeds $20,000
and the number of transactions exceed
200 with respect to the payee.
.03 New Filing and Information Report-
ing Requirements Under the OBBBA
(a) Deduction for Qualified Tips
Section 70201(a) of the OBBBA added
new section 224 to the Code, providing
an income tax deduction for “qualified
tips” that are received during the taxable
year. Qualified tips are cash tips received
by individuals in an occupation that cus-
tomarily and regularly received tips on or
before December 31, 2024, subject to cer-
tain exclusions. Specifically, individuals
are allowed a deduction, subject to limita-
tions, in an amount equal to the qualified
tips received during the taxable year that
are included on statements furnished to
the individual pursuant to section 6041(d)
(3), 6041A(e)(3), 6050W(f)(2), or 6051(a)
(18), or reported by the individual on
Form 4137 (or successor). An individual
is not eligible to claim the tip deduction
under section 224 if the individual is not
furnished such a statement.
Section 70201(f) of the OBBBA added
to the information reporting requirements
of the Code for certain payments of cash
tips by:
(1) amending section 6041(a) to
require a payor to include on the informa-
tion return filed a separate accounting of
any such amounts reasonably designated
as cash tips and the occupation described
in section 224(d)(1) of the person receiv-
ing such tips;
(2) adding new paragraph (d)(3) to
section 6041 to provide that in the case of
compensation to non-employees, a payor
is required to include on the written state-
ment furnished to the payee the portion of
payments reasonably designated as cash
tips and the occupation described in section
224(d)(1) of the person receiving such tips;
(3) amending section 6041A(a) to
require a payor to include on the informa-
tion return filed a separate accounting of
any such amounts reasonably designated
as cash tips and the occupation described
in section 224(d)(1) of the person receiv-
ing such tips;
(4) adding new paragraph (e)(3) to sec-
tion 6041A to provide that in the case of
section 6041A(a), a payor is required to
include on the written statement furnished
to the payee the portion of payments rea-
sonably designated as cash tips and the
occupation described in section 224(d)(1)
of the person receiving such tips;
(5) adding new paragraph (a)(3) to sec-
tion 6050W to provide that in the case of a
TPSO, the TPSO is required to include on
the information return filed the portion of
reportable payment transactions that have
been reasonably designated by payors as
cash tips and the occupation described in
section 224(d)(1) of the person receiving
such tips;
(6) amending section 6050W(f)(2) to
require a TPSO to include on the written
statement furnished to the payee a separate
accounting of any such amounts that have
been reasonably designated by payors as
cash tips and the occupation described in
section 224(d)(1) of the person receiving
such tips; and
(7) adding new paragraph (a)(18) to
section 6051 to provide that an employer
must include on the written statement fur-
nished to the employee the total amount
of cash tips reported by the employee
under section 6053(a) and the occupation
described in section 224(d)(1) such per-
son.
Section 70201(j) of the OBBBA pro-
vides that the amendments made by sec-
tion 70201 of the OBBBA with respect
to qualified tips, including the additional
information reporting requirements, apply
to taxable years beginning after December
31, 2024.
(b) Deduction for Qualified Overtime
Compensation
Section 70202(a) of the OBBBA added
new section 225 to the Code, providing an
income tax deduction, subject to limita-
tions, in an amount equal to the qualified
overtime compensation received during
the taxable year and included on state-
ments furnished to the individual pursuant
to section 6041(d)(4) or 6051(a)(19).
Section 70202(c) of the OBBBA added
to the information reporting requirements
of the Code for certain payments of quali-
fied overtime compensation by:
(1) adding new paragraph (a)(19) to
section 6051 to provide that an employer
must include on the written statement fur-
nished to the employee the total amount
of qualified overtime compensation (as
defined in section 225(c));
(2) amending section 6041(a) to require
a payor to include on the information
return filed a separate accounting of any
amount of qualified overtime compensa-
tion (as defined in section 225(c)); and
(3) adding new paragraph (d)(4) to
section 6041 to provide that a payor is
required to include on the written state-
ment furnished to the payee the portion of
payments that are qualified overtime com-
pensation (as defined in section 225(c)).
Section 70202(g) of the OBBBA pro-
vides that the amendments made by sec-
tion 70202 of the OBBBA, including the
additional information reporting require-
ments, apply to taxable years beginning
after December 31, 2024.
.04 Penalties
Penalties under sections 6721 and
6722 are applicable to payors subject to
the requirements of sections 6041, 6041A,
6050W, and 6051.
Section 6721 imposes a penalty for any
failure to file an information return on or
before the required filing date, and for any
failure to include all of the information
required to be shown on the return or the
inclusion of incorrect information.
Section 6722 imposes a penalty for
any failure to furnish a payee statement
on or before the required furnishing date
to the person to whom such statement
is required to be furnished, and for any
failure to include all of the information
required to be shown on a payee statement
or the inclusion of incorrect information.
Section 6724(a) provides an exception
to a penalty for any failure under sections
6721 and 6722 if it is shown that the fail-

November 24, 2025 742 Bulletin No. 2025–48
ure is due to reasonable cause and not due
to willful neglect. Under § 301.6724-1 of
the Procedure and Administration Regula-
tions, a penalty may be waived for reason-
able cause if the filer establishes that there
are significant mitigating factors with
respect to the failure or the failure arose
from events beyond the filer’s control. In
addition, the filer generally must establish
that the filer acted in a responsible manner
both before and after the failure occurred.
SECTION 3. TRANSITION
PENALTY RELIEF
.01 Qualified Tips and Occupations
Prior to the enactment of the OBBBA,
payors reporting payments pursuant to
sections 6041, 6041A, and 6050W, were
not required to include a separate account-
ing of amounts designated as cash tips or
the occupation of recipients. Employers
reporting the payment of wages pursuant
to section 6051 generally were required to
report certain tips but were not required
to report the occupations of employees.
The Department of the Treasury (Trea-
sury Department) and the Internal Reve-
nue Service (IRS) are aware that payors
and employers may not currently have
the information required to be reported
under the information reporting changes
made by the OBBBA, or the systems
or procedures in place to be able to cor-
rectly file the additional information with
the Secretary (or the SSA in the case of a
Form W-2) and furnish such information
to payees and employees. Moreover, the
IRS has already announced that Forms
W-2 and 1099 for taxable year 2025 will
not be updated to account for the OBB-
BA-related changes. Therefore, taxable
year 2025 will be regarded as a transition
period for purposes of IRS enforcement
and administration of the new information
reporting requirements for cash tips added
to the Code under section 70201(f) of the
OBBBA.
For taxable year 2025, the IRS will
not impose a penalty under section 6721
or 6722 in any of the following circum-
stances:
(1) if a payor required to file an infor-
mation return under section 6041(a)
fails to provide on that return a separate
accounting of any such amounts reason-
ably designated as cash tips or the occupa-
tion described in section 224(d)(1) of the
person receiving such tips;
(2) if a payor required to furnish a writ-
ten statement under section 6041(d) fails
to provide on that statement the portion
of payments that have been reasonably
designated as cash tips or the occupation
described in section 224(d)(1) of the per-
son receiving such tips;
(3) if a payor required to file an infor-
mation return under section 6041A(a)
fails to provide on that return a separate
accounting of any such amounts reason-
ably designated as cash tips or the occupa-
tion described in section 224(d)(1) of the
person receiving such tips;
(4) if a payor required to furnish a writ-
ten statement under section 6041A(e) fails
to provide on that statement the portion
of payments that have been reasonably
designated as cash tips or the occupation
described in section 224(d)(1) of the per-
son receiving such tips;
(5) if a TPSO required to file an infor-
mation return under section 6050W(a)
fails to provide on that return the portion of
reportable payment transactions that have
been reasonably designated by payors as
cash tips or the occupation described in
section 224(d)(1) of the person receiving
such tips;
(6) if a TPSO required to furnish a writ-
ten statement under section 6050W(f) fails
to provide on that statement a separate
accounting of any such amounts that have
been reasonably designated by payors as
cash tips or the occupation described in
section 224(d)(1) of the person receiving
such tips;
(7) if an employer required to furnish
a written statement under section 6051(a)
fails to provide on that statement the
total amount of cash tips reported by the
employee under section 6053(a) or the
occupation described in section 224(d)(1)
of such employee; or
(8) if an employer required to file a
copy of the written statement under sec-
tion 6051(a) with the SSA pursuant to sec-
tion 6051(d) fails to provide on that state-
ment the total amount of cash tips reported
by the employee under section 6053(a) or
the occupation described in section 224(d)
(1) of such employee.
The penalty relief provided in this
notice is limited to returns and statements
filed and furnished with respect to taxable
year 2025. The penalty relief applies only
to the extent that the person required to
make the return or statement otherwise
files and furnishes a complete and correct
return or statement. A complete return or
statement must include the amount of cash
tips that would otherwise be required to
be separately accounted for on the return
or statement in the aggregate amount of
payments required to be reported under
section 6041(a) or (d), section 6041A(a)
or (e), the gross amount of reportable pay-
ment transactions required to be reported
under section 6050W(a) or (f), or the
total amount of wages paid required to be
reported under section 6051(a) or (d).
While not a requirement to receive
the penalty relief provided in this notice,
employers and payors are encouraged to
provide employees and payees, particu-
larly those in a tipped occupation, with the
occupation codes and separate account-
ings of cash tips, such that the employee
or payee has the information the employee
or payee needs to determine whether the
employee or payee can claim the deduc-
tion for qualified tips under section 224
for taxable year 2025. Employers are
also encouraged to provide employees
with information regarding whether the
employer’s trade or business is a speci-
fied service trade or business as defined in
section 199A(d)(2). Employers and pay-
ors can make such information available
to their employees and payees through
an online portal, additional written state-
ments furnished to the employees or pay-
ees, or other secure methods.
.02 Qualified Overtime Compensation
Prior to the enactment of the OBBBA,
payors reporting payments pursuant to
section 6041 were not required to file
returns and furnish statements containing
a separate accounting of amounts desig-
nated as qualified overtime compensa-
tion. Employers reporting the payment of
wages pursuant to section 6051 generally
were also not required to separately report
the total amount of qualified overtime
compensation. The Treasury Department
and the IRS are aware that payors and
employers may not currently have the
information required to be reported by the
OBBBA or the systems or procedures in
place to be able to correctly file the addi-
tional information with the Secretary (or
the SSA in the case of a Form W-2) and

Bulletin No. 2025–48 743 November 24, 2025
furnish such information to payees and
employees. Therefore, taxable year 2025
will be regarded as a transition period for
purposes of IRS enforcement and admin-
istration of the new information reporting
requirements for qualified overtime com-
pensation added to the Code under section
70202(c) of the OBBBA.
The IRS will not impose a penalty
under sections 6721, or 6722 in any of the
following circumstances:
(1) if an employer required to furnish
a written statement under section 6051(a)
fails to separately provide on that state-
ment the total amount of qualified over-
time compensation (as defined in section
225(c));
(2) if an employer required to file a
copy of the written statement under sec-
tion 6051(a) with the SSA pursuant to sec-
tion 6051(d) fails to separately provide on
that statement the total amount of quali-
fied overtime compensation (as defined in
section 225(c));
(3) if a payor required to file an infor-
mation return under section 6041(a)
fails to provide on that return a separate
accounting of any amount of qualified
overtime compensation (as defined in sec-
tion 225(c)); or
(4) if a payor required to furnish a writ-
ten statement under section 6041(d) fails
to provide on that statement the portion of
payments that are qualified overtime com-
pensation (as defined in section 225(c)).
The penalty relief provided in this
notice is limited to returns and statements
filed and furnished with respect to taxable
year 2025. The penalty relief applies only
to the extent that the person required to
make the return or statement otherwise
files and furnishes a complete and correct
return or statement. A complete return
or statement must include the amount
of qualified overtime compensation that
would otherwise be required to be sepa-
rately accounted for on the return or state-
ment in the aggregate amount of payments
required to be reported under section
6041(a) or (d), or in the total amount of
wages required to be reported under sec-
tion 6051(a).
While not a requirement to receive
the penalty relief provided in this notice,
employers and payors are encouraged to
provide employees and payees with sep-
arate accountings of overtime compensa-
tion such that the employee or payee has
the information the employee or payee
needs to determine whether the employee
or payee can claim the deduction for qual-
ified overtime compensation under section
225 for taxable year 2025. Employers and
payors can make such information avail-
able to their employees and payees by
including it in box 14 of the employee’s
Form W-2, or through an online portal,
additional written statements furnished to
the employees or payees, or other secure
methods.
SECTION 5. EFFECTIVE DATE
This notice is effective for returns and
statements related to amounts paid during
2025.
SECTION 6. DRAFTING
INFORMATION
The principal author of this notice
is the Office of Associate Chief Coun-
sel (Procedure and Administration). For
further information regarding this notice
contact the office at (202) 317-3400 (not
a toll-free number).
26 CFR 601.105: Examination of returns and claims
for refund, credit or abatement; determination of
correct tax liability.
(Also: Part I, §§ 671, 677; 301.7701-2, 301.7701-4)
Rev. Proc. 2025-31
SECTION 1. PURPOSE
This revenue procedure describes a
safe harbor for trusts that otherwise qual-
ify as investment trusts under § 301.7701-
4(c) and as grantor trusts to stake their
digital assets without jeopardizing their
tax status as investment trusts and grantor
trusts for Federal income tax purposes.
This revenue procedure also provides a
limited time period for an existing trust
to amend its governing instrument (trust
agreement) to adopt the requirements of
the safe harbor.
SECTION 2. BACKGROUND –
DIGITAL ASSETS AND STAKING
.01 Digital assets are digital repre-
sentations of value recorded on a cryp-
tographically secured distributed ledger
or similar technology within the meaning
of section 6045(g)(3)(D) of the Internal
Revenue Code (Code) (digital assets).
1

Digital assets generally are treated as
property for Federal income tax purposes
and Federal income tax principles apply
to digital asset transactions.
2
This revenue
procedure addresses only digital assets for
which transactions are carried out on a
permissionless network that uses a proof-
of-stake consensus mechanism to validate
those transactions.
.02 The operation of each digital asset
blockchain network is governed by soft-
ware that programmatically enforces cer-
tain network rules and technical require-
ments, as well as distributions of rewards
(protocol). For a digital asset transaction
to be recognized by the blockchain net-
work, the transaction must be added to
the network’s decentralized digital ledger
(blockchain).
.03 Digital assets rely on cryptogra-
phy and economic mechanisms designed
to reduce reliance on designated trusted
intermediaries to verify transactions and
provide settlement assurances to users.
Each protocol has a consensus mech-
anism that enables a distributed set of
unrelated computers (commonly referred
to as “nodes”) to agree on the authorita-
tive record of digital asset address own-
ership balances, transactions, and other
data relating to a digital asset’s blockchain
at any given time (state). The consensus
mechanism is intended to maintain the
integrity of the blockchain by validating
transactions and ensuring transactions
added to the blockchain are valid. This
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code, the Income Tax Regulations (26 CFR Part 1), or the Procedure and Administration Regulations (26
CFR Part 301).
2
See Notice 2014-21, 2014-16 I.R.B. 938.

November 24, 2025 744 Bulletin No. 2025–48
can be done, for example, by rejecting
transactions that attempt to move the same
units to two different wallet addresses at
the same time (so-called “double spend-
ing”). Preventing such transactions from
being recorded on a blockchain is essen-
tial to the security and integrity of a digital
asset’s blockchain. Absent such assurance,
users could lose confidence in the digital
asset network and the corresponding digi-
tal assets could lose value.
.04 Proof-of-stake is a type of consen-
sus mechanism. In a proof-of-stake con-
sensus mechanism, a validator node is a
type of node that actively participates in
the consensus mechanism (in addition to
the typical duties of a node, which include
maintaining and verifying blockchain
data). Non-validator nodes typically only
store and relay blockchain data, and do
not propose or create new blocks. Valida-
tor node operators commit or “stake” digi-
tal assets to become eligible to be selected
by the relevant protocol to validate a new
block of data to, and update the state of,
the network’s blockchain. While staked,
digital assets are “locked up” and cannot
be transferred for a period of time under
the terms of the applicable protocol. Some
protocols employ specific criteria for
selecting validators, such as the number of
digital assets staked by the validator node
operator.
.05 For the validation process to be
effective in ensuring the security and
integrity of a digital asset’s blockchain,
there must be enough node operators that
no one validator or group of validators can
control a majority of the total staked dig-
ital assets, which would allow that party
or group to manipulate the blockchain by
influencing the validation of transactions
and potentially altering the blockchain’s
transaction history. Consequently, an
increase in the number of digital assets
staked by different validator nodes can
increase the security of blockchains using
proof-of-stake consensus mechanisms. To
incentivize multiple validator node oper-
ators to participate, and in exchange for
providing validation and related activi-
ties, newly minted digital assets specified
by the protocol and/or fees paid by par-
ties seeking to add their transactions to
the blockchain (collectively, “rewards”)
are credited or transferred to validators.
Rewards generally are received in the
form of a blockchain’s native digital asset.
Conversely, if a validator fails to act in
accordance with a blockchain network’s
consensus mechanism, some staked units
may be forfeited as a penalty (slashing).
.06 Digital asset owners can participate
in staking in various forms. One such form
is custodial staking, in which a third party
(custodian) takes custody of the owner’s
digital assets and facilitates the staking
of such digital assets on behalf of the
owner. Generally, a custodian focuses on
securely holding, storing, and safeguard-
ing digital assets on behalf of digital asset
owners. The custodian, acting on behalf
of the owner, selects and enters into con-
tractual arrangements with one or more
validator node operators who engage in
proof-of-stake activities for digital asset
blockchains (staking provider). In some
cases, the legal entity that is the custodian
also may act as the staking provider. The
arrangement between the custodian and
the staking provider generally provides
that an agreed-on portion of the staking
rewards are allocated to the owner of the
digital assets.
.07 Some legal entities formed as trusts
under applicable State law that hold digi-
tal assets intend to be treated for Federal
income tax purposes as investment trusts
under § 301.7701-4(c) and as grantor
trusts. Certain actions of the trust may be
directed by the trust’s sponsor.
.08 The Department of the Treasury
and the Internal Revenue Service have
received requests for guidance on: (1)
whether staking prevents a legal entity
formed as a trust under applicable State
law from qualifying for Federal income
tax purposes as a trust classified as an
investment trust under § 301.7701-4(c)
and as a grantor trust; and (2) if not,
whether an existing trust agreement may
be amended to authorize the staking of
some or all of its digital assets without
impairing qualification of the trust as an
investment trust under § 301.7701-4(c)
and as a grantor trust.
SECTION 3. BACKGROUND -
TRUSTS
.01 Section 301.7701-2(a) defines a
“business entity” as an entity recognized
for Federal tax purposes (including an
entity with a single owner that may be
disregarded as an entity separate from
its owner under § 301.7701-3) that is
not properly classified as a trust under
§ 301.7701-4 or otherwise subject to spe-
cial treatment under the Code.
.02 Section 301.7701-4(a) provides
generally that an arrangement is treated as
a trust if the purpose of the arrangement is
to vest in trustees the responsibility to pro-
tect or conserve property for beneficiaries
who cannot share in the discharge of this
responsibility and, therefore, are not asso-
ciates in a joint enterprise for the conduct
of business for profit.
.03 Section 301.7701-4(b) provides
that there are other arrangements known
as trusts because the legal title to property
is conveyed to trustees for the benefit of
beneficiaries, but that are not classified
as trusts for Federal tax purposes because
they are not simply arrangements to pro-
tect or conserve the property for the ben-
eficiaries. These trusts, which are often
known as business or commercial trusts,
generally are created by the beneficiaries
simply as a device to carry on a prof-
it-making business that normally would
have been carried on through a business
organization classified as a corporation or
partnership.
.04 Section 301.7701-4(c) provides
that an “investment” trust is not classified
as a trust if there is a power under the trust
agreement to vary the investment of the
certificate holders. An investment trust
with a single class of ownership interests,
representing undivided beneficial interests
in the assets of the trust, is classified as a
trust if there is no power under the trust
agreement to vary the investments of the
certificate holders.
.05 A power to vary the investment of
the certificate holders exists where there is
a managerial power under the trust instru-
ment that enables a trust to take advantage
of variations in the market to improve the
investments of the certificate holders. See
Comm’r v. North American Bond Trust,
122 F.2d 545 (2d Cir. 1941), cert. denied,
314 U.S. 701 (1942).
.06 Rev. Rul. 75-192, 1975-1 C.B. 384,
discusses the situation where a provision
in the trust agreement requires the trustee
to invest cash on hand between quarterly
distribution dates. The trustee is required
to invest the money in short-term obli-
gations of (or guaranteed by) the United

Bulletin No. 2025–48 745 November 24, 2025
States, or any agency or instrumentality
thereof, and in certificates of deposit of any
bank or trust company having a minimum
stated surplus and capital. The trustee is
permitted to invest only in obligations
maturing before the next distribution date
and is required to hold such obligations
until maturity. Rev. Rul. 75-192 concludes
that, because the restrictions on the types
of permitted investments limit the trustee
to a fixed return like that earned on a bank
account and eliminate any opportunity to
profit from market fluctuations, the power
to invest in the specified kinds of short-
term investments is not a power to vary
the trust’s investment.
.07 Rev. Rul. 78-371, 1978-2 C.B. 344,
concludes that a trust established by the
heirs of a number of contiguous parcels
of real estate is an association taxable as
a corporation for Federal income tax pur-
poses where the trustees have the power to
purchase and sell contiguous or adjacent
real estate, accept or retain contributions
of contiguous or adjacent real estate, raze
or erect any building or structure, make
any improvements to the land originally
contributed, borrow money, and mortgage
or lease the property.
.08 Rev. Rul. 79-77, 1979-1 C.B. 448,
concludes that a trust formed by three par-
ties to hold a single parcel of real estate
is classified as a trust for Federal income
tax purposes when the trustee was autho-
rized to sign a long-term net lease for the
property, with options to renew the lease
with recomputed rent; to hold title to the
land and building and to proceeds and
income of the property; to distribute all
trust income and otherwise to protect or
conserve the property. See Wyman Build-
ing Trust v. Commissioner, 45 B.T.A. 155
(1941), acq., 1941-2 C.B. 14 (trust not
treated as association taxable as a corpora-
tion where trust held a single property, the
trustee executed and extended net leases
to the same tenant at the same rental, and
collected and distributed the rents).
.09 Rev. Rul. 81-238, 1981-2 C.B. 248,
establishes that an automatic reinvestment
plan in which trust interest holders elect
to use distributions to purchase interests in
new fixed investment trusts does not con-
stitute a power to vary. The plan does not
involve reinvestment in the original trust
and there is no change in, or addition to,
the assets of the original trust.
.10 Rev. Rul. 90-63, 1990-2 C.B. 270,
holds that the power to consent to changes
in the credit support for debt obligations
held in an investment trust is not a “power
to vary the investment” within the mean-
ing of § 301.7701-4(c) if that power is
exercisable only to the extent that the
trustee reasonably believes the change is
advisable to maintain the value of trust
property by preserving the credit rating of
the bonds.
.11 Rev. Rul. 2004-86, 2004-2 C.B.
191, concludes that a Delaware statu-
tory trust is classified as an investment
trust where the trust holds a single prop-
erty subject to a mortgage and net lease,
the trustee is permitted to renegotiate the
lease or enter into leases with other tenants
in the event of the tenant’s bankruptcy or
insolvency, and otherwise has very limited
powers.
.12 Section 671 provides that, where
the grantor or another person is treated as
the owner of any portion of a trust (com-
monly referred to as a “grantor trust”),
there shall be included in computing the
taxable income and credits of the grantor
or the other person those items of income,
deductions, and credits against tax of the
trust which are attributable to that portion
of the trust to the extent that the items
would be taken into account under chap-
ter 1 of the Code in computing taxable
income or credits against the tax of an
individual.
.13 Section 677(a) provides that the
grantor is treated as the owner of any por-
tion of a trust whose income without the
approval or consent of any adverse party
is, or, in the discretion of the grantor or
a nonadverse party, or both, may be dis-
tributed, or held or accumulated for future
distribution, to the grantor or the grantor’s
spouse.
.14 A person that is treated as the
owner of an undivided fractional interest
in a trust under subpart E of part I, sub-
chapter J of chapter 1 of the Code (sec-
tions 671 and following), is considered
to own the trust assets attributable to that
undivided fractional interest of the trust
for Federal income tax purposes. See Rev.
Rul. 88-103, 1988-2 C.B. 304; and Rev.
Rul. 85-13, 1985-1 C.B. 184; see also
§ 1.1001-2(c), Example 5.
SECTION 4. BACKGROUND –
APPLICABLE REGULATORY
RULES
.01 SEC Rules. The offer and sale of
interests in a trust holding digital assets
to investors in a public offering is sub-
ject to regulation by the U.S. Securities
and Exchange Commission (SEC). The
regulations and rules of the SEC address,
among other matters, the public disclo-
sure by the trust of its activities, includ-
ing with respect to staking. Accordingly,
the SEC reviews and must approve such
disclosure before the trust is permitted to
make a public offering of trust interests.
SEC rules also may require an issuer to
provide additional disclosure to investors
when material facts relating to its offering
change, which disclosure the SEC also
reviews and approves.
.02 SEC Statement and Orders Relat-
ing to Staking. On May 29, 2025, the SEC
Division of Corporation Finance issued
a Statement on Certain Protocol Stak-
ing Activities.
3
The Statement addresses
certain activities known as “staking”
on digital asset networks that use proof-
of-stake as a consensus mechanism. On
July 29, 2025, the SEC approved In-Kind
Creations and Redemptions for Crypto
ETPs.
4
On September 17, 2025, the SEC
approved rule changes proposed by three
national securities exchanges to adopt
generic listing standards for exchange-
traded products that hold commodities,
which as defined in the SEC order include
certain digital assets.
5
.03 Exchange Rules. Interests in trusts
holding digital assets may be listed and
traded on a national securities exchange
that is a self-regulatory organization. The
rules of the national securities exchange,
3
SEC, Statement on Certain Protocol Staking Activities (May 29, 2025), https://www.sec.gov/newsroom/speeches-statements/statement-certain-protocol-staking-activities-052925.
4
SEC Release No. 34-103571, 90 FR 36248 (Aug. 1, 2025); SEC, SEC Permits In-Kind Creations and Redemptions for Crypto ETPs (July 29, 2025), https://www.sec.gov/newsroom/press-
releases/2025-101-sec-permits-kind-creations-redemptions-crypto-etps. An ETP is an exchange-traded product.
5
SEC Release No. 34-103995, 90 FR 45414 (Sept. 22, 2025).

November 24, 2025 746 Bulletin No. 2025–48
approved by the SEC, prescribe conditions
that must be satisfied in order for shares
(including trust interests) to be listed.
Under those rules, certain trust interest
holders are issued interests in the trust in
a specified aggregate minimum number
in return for a deposit of a quantity of the
underlying digital asset and/or cash; and
when aggregated in the same specified
minimum number, the trust interests may
be redeemed at such holder’s request by
the trust, which will deliver to the redeem-
ing holder the quantity of the underlying
digital asset and/or cash.
.04 Liquidity Policies and Proce-
dures. The generic listing standards of
the national securities exchange where a
trust’s interests are listed and traded that
have been approved by the SEC require
that the trust have in place liquidity risk
policies and procedures to ensure that the
trust can redeem trust interests at a trust
interest holder’s request.
6
Pursuant to
these generic listing standards, if a trust
has on a daily basis less than 85 percent
of its assets readily available to meet
redemption requests, the trust must have
and disclose written liquidity risk poli-
cies and procedures reasonably designed
to address the risk that it could not meet
requests to redeem interests issued by
the trust without significant dilution of
the remaining holders’ interests in the
trust. For this purpose, an asset is deemed
not readily available to meet redemp-
tion requests if it is segregated, pledged,
hypothecated, encumbered, or otherwise
restricted or prevented from being liq-
uidated, sold, transferred, or assigned
within one business day. These policies
and procedures must be periodically
reviewed, no less frequently than annu-
ally. The exchange’s disclosure require-
ments regarding liquidity risk are intended
to cover situations such as staking by the
trust of its digital assets, particularly if the
staked amount exceeds 15 percent of the
trust’s assets on any given day and such
staked assets are not readily available for
redemption requests within one business
day. The generic listing standards require
that the trust’s liquidity risk policies and
procedures be prominently displayed on
the trust’s website.
SECTION 5. SCOPE
This revenue procedure applies to an
arrangement formed as a trust under appli-
cable State law that: (i) would be treated
for Federal income tax purposes as a trust
that qualifies as an investment trust under
§ 301.7701-4(c), and as a grantor trust, if
the trust agreement did not authorize stak-
ing and the trust’s digital assets were not
staked; and (ii) with respect to a trust in
existence prior to the date on which its
trust agreement first authorizes staking and
related activities in a manner that satisfies
each of the requirements of section 6.02
hereof, qualified as an investment trust
under § 301.7701-4(c), and as a grantor
trust, immediately before that date.
SECTION 6. SAFE HARBOR
.01 Safe Harbor. Provided all the
requirements in section 6.02 of this reve-
nue procedure are satisfied, a trust’s autho-
rization, pursuant to its trust agreement,
to stake its digital assets and the result-
ing staking of the trust’s digital assets do
not prevent the trust from qualifying for
Federal income tax purposes as a trust
classified as an investment trust under
§ 301.7701-4(c) and as a grantor trust.
References in section 6 of this revenue
procedure to actions taken by the trust also
include actions directed by the sponsor of
the trust pursuant to the trust agreement.
.02 Requirements.
(1) Interests in the trust are traded on
a national securities exchange. The trust’s
activities comply with the SEC’s regu-
lations and rules. The trust’s disclosure
regarding the staking of its digital assets
has been reviewed and approved by the
SEC. The trust’s assets and activities are
described in the May 29, 2025, Statement
on Certain Protocol Staking Activities
of the SEC’s Division of Corporation
Finance. The trust has written liquidity
risk policies and procedures that comply
with the rules of the national securities
exchange on which the trust interests are
listed and traded.
(2) The trust owns only cash and units
of a single type of digital asset (as defined
by section 6045(g)(3)(D)), transactions
for which are carried out on a permission-
less network that uses a proof-of-stake
consensus mechanism to validate those
transactions.
(3) The trust’s digital assets are held by
a custodian, acting on behalf of the trust,
at digital asset addresses controlled by the
custodian. Only the custodian has access
to the private keys associated with those
digital asset addresses; accordingly, only
the custodian can effect a sale, transfer, or
exercise the rights of ownership over the
trust’s digital assets, including while those
assets are staked. For Federal income tax
purposes, the trust retains ownership of
the digital assets at all times, including
while they are staked.
(4) The trust’s staking of its digital
assets protects and conserves trust prop-
erty by mitigating the risk that another
party or group could control a majority
of the total staked digital assets of that
type and engage in transactions that could
reduce the value of the trust’s digital
assets.
(5) The trust’s activities relating to
digital assets are limited to: (i) accept-
ing deposits of the digital asset or cash
in exchange for newly issued interests
in the trust; (ii) holding the digital assets
and cash; (iii) paying trust expenses and
selling digital assets for cash to pay trust
expenses or to make cash redemptions of
trust interests; (iv) purchasing additional
digital assets with cash contributed to the
trust; (v) distributing digital assets or cash
to trust interest holders in redemption of
their interests in the trust; (vi) selling dig-
ital assets for cash in connection with the
trust’s liquidation; and (vii) directing the
staking of its digital assets in a manner
consistent with the applicable require-
ments of the national securities exchange
on which the trust interests are traded and
this safe harbor, including providing for a
liquidity reserve to the extent provided in
section 6.02(9) of this revenue procedure
and entering into a contingent liquidity
arrangement to the extent provided in sec-
tion 6.02(12) of this revenue procedure.
Pursuant to the trust agreement, the trust
is prohibited from seeking to take advan-
tage of variations in the market to improve
the investments of trust interest holders,
6
See SEC Release No. 34-103972, 90 FR 45075 (Sept. 18, 2025); SEC Release No. 34-103974, 90 FR 45082 (Sept. 18, 2025); SEC Release No. 34-103973, 90 FR 45089 (Sept. 18, 2025).

Bulletin No. 2025–48 747 November 24, 2025
including variations based on the value of
the digital assets or the amount of staking
rewards.
(6) The trust directs the staking of its
digital assets through one or more cus-
todians who facilitate the staking of the
digital assets on the trust’s behalf with
one or more staking providers. The trust
and the sponsor are unrelated to the stak-
ing provider. The trustee, sponsor, or cus-
todian performs all appropriate due dili-
gence with regard to the selection of each
staking provider and negotiates, on behalf
of the trust, the provisions of the contract
with the staking provider. The staking
provider regularly enters into arrange-
ments with unrelated persons involving
similar activities, and such other per-
sons are also unrelated to the trust, the
custodian, and the sponsor. The staking
provider bears its own expenses. The
allocation of staking rewards between
the staking provider and the custodian on
behalf of the trust is an arm’s length allo-
cation that is independent of the expenses
of the staking provider or custodian, and
may be stated as a percentage of the stak-
ing rewards derived from staking the
trust’s digital assets. The other terms and
conditions of the custodian’s arrange-
ments with the staking provider reflect
arm’s length terms.
(7) The trust, the custodian in its capac-
ity as such, and the sponsor have no legal
right or arrangement to participate in or
direct or control the activities of the stak-
ing provider in any way, and do not do so,
except to direct the staking and unstaking
of the trust’s digital assets as provided in
this section 6.02.
(8) All of the digital assets of the trust
must be made available to the staking pro-
vider to be staked at all times, except as
provided in sections 6.02(9), (10), (11),
and (12) of this revenue procedure.
(9) When appropriate in the trust-
ee’s or sponsor’s reasonable judgment
to comply with the trust’s liquidity risk
policies and procedures required by the
national securities exchange on which
the interests in the trust are listed and
traded, a trust may stake less than all
its digital assets to create and maintain
a liquidity reserve. The trust’s liquid-
ity risk policies and procedures must
be based solely on factors relating to
the requirement of the national secu-
rities exchange that assets be readily
available to meet redemption requests
within the required period. The trust
may increase or decrease the liquidity
reserve in compliance with its liquidity
risk policies and procedures, provided
that, to the extent the liquidity reserve
is reduced, the trust shall resume mak-
ing the digital assets not subject to the
liquidity reserve available for staking
as soon as and to the extent reasonably
possible. On the occurrence of one or
more of the events described in section
6.02(10) and (11) of this revenue pro-
cedure, the trust shall direct the staking
or unstaking of a necessary number of
its digital assets to satisfy its liquidity
reserve as soon as and to the extent rea-
sonably possible.
(10) In addition to holding in a liquid-
ity reserve (as described in section 6.02(9)
of this revenue procedure), if any, digital
assets that are not staked, the trust also
may, on a short-term temporary basis and
in connection with one or more of the
following events, hold additional digital
assets that are not staked, provided that
the trust shall make such digital assets
available for staking (subject to section
6.02(9) of this revenue procedure, if appli-
cable) as soon as and to the extent reason-
ably possible:
(i) the sale of digital assets for cash to
pay trust expenses;
(ii) the contribution of digital assets in
connection with the creation of interests in
the trust or distributions of digital assets
to trust interest holders in redemption of
their interests in the trust;
(iii) the purchase of digital assets in
connection with the creation of trust inter-
ests for cash or the sale of digital assets to
make cash redemptions of trust interests;
or
(iv) the ownership of additional digital
assets received as, or available for receipt,
as staking rewards.
(11) In addition to holding in a liquid-
ity reserve (as described in section 6.02(9)
of this revenue procedure), if any, digital
assets that are not staked, the trust also
may, in connection with one or more of
the following events, hold additional dig-
ital assets that are not staked, provided
that the trust shall make such digital assets
available for staking (subject to section
6.02(9) of this revenue procedure, if appli-
cable) as soon as and to the extent reason-
ably possible:
(i) obtaining or disposing of digital
assets through the contingent liquidity
arrangement described in section 6.02(12)
of this revenue procedure pursuant to
applicable law or regulatory rules;
(ii) the sale of digital assets for cash in
connection with the trust’s liquidation;
(iii) the need to take protective mea-
sures against potential systemic vulnera-
bilities in the network’s protocol, the stak-
ing smart contracts, or the validator client
software;
(iv) the cessation of the arrangement
between the trust and a custodian, but only
with respect to the digital assets affected
by the cessation;
(v) the cessation of the arrangement
between a custodian and a staking pro-
vider, but only with respect to the staked
digital assets affected by the cessation; or
(vi) a change in applicable law or reg-
ulation.
(12) When appropriate in the trust-
ee’s or sponsor’s reasonable judgment
to comply with the trust’s liquidity risk
policies and procedures required by the
national securities exchange on which
the interests in the trust are listed and
traded, the trust may enter into a contin-
gent liquidity arrangement intended to
mitigate an adverse liquidity event that
otherwise would prevent the fund from
distributing digital assets or cash to trust
interest holders in redemption of their
interests in the trust, provided that the
digital assets or cash obtained through
the contingent liquidity arrangement are
expected to be distributed, or included
in a pool of assets expected to be dis-
tributed, in the near future. For purposes
of the foregoing sentence, a contingent
liquidity arrangement is (a) a lending
facility or other arrangement permit-
ting the trust to borrow cash or (b) an
arrangement to sell or purchase digital
assets for cash or digital assets on a cur-
rent or deferred basis.
(13) To protect or conserve the trust’s
property, the trust’s digital assets are
indemnified from slashing due to the
activities of staking providers.
(14) The only new assets received by
the trust as a result of staking its digital
assets are additional units, in the same
form, of the single type of digital asset

November 24, 2025 748 Bulletin No. 2025–48
held by the trust. The trust’s staking
rewards, net of trust expenses, are, in pro-
portion to the trust interest holders’ rela-
tive interests in the trust, either distributed
in-kind to trust interest holders or sold for
cash and the proceeds distributed to trust
interest holders, in each case on a periodic
basis that is no less frequently than quar-
terly. The trust treats all staking rewards
consistently.
.03 Amendment. A trust may amend its
trust agreement to authorize staking at any
time during the nine-month period begin-
ning on November 10, 2025 and such an
amendment will not prevent a trust from
being treated as a trust that qualifies as an
investment trust under § 301.7701-4(c) or
as a grantor trust if the requirements set
forth in section 6.02 of this revenue proce-
dure are satisfied.
SECTION 7. NO INFERENCES ON
L AW
.01 No inferences should be drawn
about whether similar consequences
would result if actions taken by or on
behalf of a trust fall outside the limited
scope of this revenue procedure.
.02 No inferences should be drawn as
to any Federal income tax consequences
not expressly addressed in this reve-
nue procedure, including with respect to
whether income attributable to staking
would be treated as income effectively
connected with the conduct of a trade or
business within the United States or as
unrelated business taxable income. No
inferences should be drawn regarding
the Federal income tax treatment of other
transactions involving digital assets not
expressly addressed in this revenue proce-
dure, including with respect to forks and
airdrops.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective for
tax years ending on or after November 10,
2025.
SECTION 9. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Andrew B. Christopherson
of the Office of Associate Chief Counsel
(Passthroughs, Trusts, and Estates). For
further information, contact Andrew B.
Christopherson at (202) 317-3889 (not a
toll-free number).

Bulletin No. 2025–48 i November 24, 2025
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 pub-
lished 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 confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished 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 pub-
lished ruling that is not considered deter-
minative 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 sub-
stance 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 rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings 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.
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.

November 24, 2025 ii Bulletin No. 2025–48
Numerical Finding List
1
Bulletin 2025–48
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
2025-24, 2025-36 I.R.B. 359
2025-25, 2025-36 I.R.B. 360
2025-26, 2025-40 I.R.B. 444
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
2025-28, 2025-34 I.R.B. 316
2025-41, 2025-34 I.R.B. 325
2025-42, 2025-36 I.R.B. 351
2025-43, 2025-36 I.R.B. 356
2025-44, 2025-37 I.R.B. 386
2025-45, 2025-37 I.R.B. 388
2025-38, 2025-38 I.R.B. 392
2025-47, 2025-40 I.R.B. 441
2025-51, 2025-41 I.R.B. 448
2025-52, 2025-41 I.R.B. 474
2025-54, 2025-41 I.R.B. 479
2025-46, 2025-43 I.R.B. 533
2025-50, 2025-43 I.R.B. 542
2025-53, 2025-43 I.R.B. 624
2025-55, 2025-43 I.R.B. 625
2025-49, 2025-44 I.R.B. 627
2025-57, 2025-45 I.R.B. 692
2025-61, 2025-45 I.R.B. 693
2025-63, 2025-46 I.R.B. 709
2025-65, 2025-47 I.R.B. 717
2025-62, 2025-48 I.R.B. 740
Proposed Regulations:
REG-125710-18, 2025-30 I.R.B. 263
REG-107459-24, 2025-32 I.R.B. 313
REG-132805-17, 2025-35 I.R.B. 342
REG-108822-25, 2025-36 I.R.B. 361
REG-129260-16, 2025-39 I.R.B. 410
REG-108673-25, 2025-42 I.R.B. 494
REG-110032-25, 2025-42 I.R.B. 495
REG-112261-24; REG-116085-23, 2025-42
I.R.B. 522
REG-109742-25, 2025-46 I.R.B. 712
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
2025-26, 2025-33 I.R.B. 315
2025-28, 2025-38 I.R.B. 393
2025-30, 2025-42 I.R.B. 489
2025-27, 2025-44 I.R.B. 646
2025-32, 2025-45 I.R.B. 695
2025-31, 2025-48 I.R.B. 743
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
2025-16, 2025-35 I.R.B. 342
2025-17, 2025-36 I.R.B. 349
2025-18, 2025-37 I.R.B. 365
2025-19, 2025-41 I.R.B. 445
2025-20, 2025-41 I.R.B. 447
2025-21, 2025-45 I.R.B. 690
2025-22, 2025-48 I.R.B. 719
Treasury Decisions:
10021, 2025-31 I.R.B. 264
10031, 2025-32 I.R.B. 304
10033, 2025-40 I.R.B. 411
10035, 2025-42 I.R.B. 484
10034, 2025-43 I.R.B. 523
10036, 2025-43 I.R.B. 525
1
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. 2025–48 iii November 24, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–48
1
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.

Internal Revenue Service
Washington, DC 20224
Official Business
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