Internal Revenue Bulletin 2025-49 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2025–49
December 1, 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.
EMPLOYEE PLANS
Notice 2025-67, page 761.
Section 415 of the Internal Revenue Code provides for dol-
lar limitations on benefits and contributions under qualified
retirement plans. Section 415(d) requires that the Secre-
tary of the Treasury annually adjust these limits for cost
of living increases. Other limitations applicable to deferred
compensation plans are also affected by these adjustments
under § 415. Under § 415(d), the adjustments are to be
made under adjustment procedures similar to those used
to adjust benefit amounts under § 215(i)(2)(A) of the Social
Security Act.
INCOME TAX
Rev. Rul. 2025-23, page 749.
2025 Base Period T-Bill Rate. The “base period T-bill rate”
for the period ending September 30, 2025 is published as
required by section 995(f) of the Internal Revenue Code.
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.
December 1, 2025 Bulletin No. 2025–49

Part I
Section 995.—Taxation
of DISC Income to
Shareholders
2025 Base Period T-Bill Rate. The “base period
T-bill rate” for the period ending September 30,
2025, is published as required by section 995(f) of
the Internal Revenue Code.
Rev. Rul. 2025-23
Section 995(f)(1) of the Internal Rev-
enue Code provides that a shareholder of
a domestic international sales corporation
(“DISC”) shall pay interest for each tax-
able year in an amount equal to the prod-
uct of the “shareholder’s DISC-related
deferred tax liability” for the year (as
defined in section 995(f)(2)) and the “base
period T-bill rate.” Under section 995(f)
(4), the base period T-bill rate is “the
annual rate of interest determined by the
Secretary to be equivalent to the average
of the 1-year constant maturity Treasury
yields, as published by the Board of Gov-
ernors of the Federal Reserve System, for
the 1-year period ending on September 30
of the calendar year ending with (or of the
most recent calendar year ending before)
the close of the taxable year of the share-
holder.”
The base period T-bill rate for the
period ending September 30, 2025, is 4.08
percent.
Pursuant to section 6622 of the Inter-
nal Revenue Code, interest must be com-
pounded daily. The table below provides
factors for compounding the 2025 base
period T-bill rate daily for any number
of days in the shareholder’s taxable year
(including for a 52-53 week taxable year).
To compute the amount of the interest
charge for the shareholder’s taxable year,
multiply the amount of the shareholder’s
DISC-related deferred tax liability for that
year by the base period T-bill rate factor
corresponding to the number of days in the
shareholder’s taxable year for which the
interest charge is being computed. Gener-
ally, one would use the factor for 365 days.
One would use a different factor only if
the shareholder’s taxable year for which
the interest charge is being determined is
a short taxable year, if the shareholder uses
a 52-53 week taxable year, or if the share-
holder’s taxable year is a leap year.
For the base period T-bill rates for peri-
ods ending in prior years, see Rev. Rul.
2024-27, 2024-51 I.R.B. 1240; Rev. Rul.
2023-23, 2023-51 I.R.B. 1472; Rev. Rul.
2022-21, 2022-47 I.R.B. 468; Rev. Rul.
2021-22, 2021-47 I.R.B. 726; Rev. Rul.
2020-25, 2020-48 I.R.B. 1109; and Rev.
Rul. 2019-27, 2019-51 I.R.B. 1378.
DRAFTING INFORMATION
The principal author of this revenue
ruling is Stefan A. Pruessmann of the
Office of Associate Chief Counsel (Inter-
national). For further information regard-
ing the revenue ruling, contact Mr. Pruess-
mann at (202) 317-3800 (not a toll-free
number).
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
10.000111781
20.000223574
30.000335380
40.000447198
50.000559029
60.000670872
70.000782728
80.000894597
90.001006477
100.001118371
110.001230276
120.001342195
130.001454126
140.001566069
150.001678025
Bulletin No. 2025–49 749 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
160.001789993
170.001901974
180.002013968
190.002125974
200.002237992
210.002350023
220.002462067
230.002574123
240.002686191
250.002798272
260.002910366
270.003022472
280.003134591
290.003246722
300.003358866
310.003471022
320.003583191
330.003695372
340.003807566
350.003919772
360.004031991
370.004144223
380.004256467
390.004368724
400.004480993

410.004593274
420.004705569
430.004817876
440.004930195
450.005042527
460.005154871
470.005267228
480.005379598
490.005491980
500.005604375
December 1, 2025 750 Bulletin No. 2025–49

Bulletin No. 2025–49 751 December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
510.005716782
520.005829202
530.005941634
540.006054079
550.006166537
560.006279007
570.006391490
580.006503985
590.006616493
600.006729013
610.006841546
620.006954092
630.007066650
640.007179221
650.007291804
660.007404400
670.007517008
680.007629630
690.007742263
700.007854909
710.007967568
720.008080240
730.008192924
740.008305620
750.008418330
760.008531051
770.008643786
780.008756533
790.008869293
800.008982065
810.009094850
820.009207647
830.009320457
840.009433280
850.009546115

December 1, 2025 752 Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
860.009658963
870.009771824
880.009884697
890.009997582
900.010110481
910.010223392
920.010336315
930.010449252
940.010562200
950.010675162
960.010788136
970.010901123
980.011014122
990.011127134
1000.011240159
1010.011353196
1020.011466246
1030.011579308
1040.011692384
1050.011805471
1060.011918572
1070.012031685
1080.012144811
1090.012257949
1100.012371100
1110.012484264
1120.012597440
1130.012710629
1140.012823831
1150.012937045
1160.013050272
1170.013163511
1180.013276764
1190.013390029
1200.013503306

Bulletin No. 2025–49 753 December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
121
FACTOR
0.013616596
1220.013729899
1230.013843215
1240.013956543
1250.014069884
1260.014183238
1270.014296604
1280.014409983
1290.014523374
1300.014636778
1310.014750195
1320.014863625
1330.014977067
1340.015090522
1350.015203990
1360.015317470
1370.015430963
1380.015544469
1390.015657987
1400.015771518
1410.015885062
1420.015998619
1430.016112188
1440.016225770
1450.016339364
1460.016452972
1470.016566591
1480.016680224
1490.016793869
1500.016907528
1510.017021198
1520.017134882
1530.017248578
1540.017362287
1550.017476008

December 1, 2025 754 Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
156
FACTOR
0.017589743
1570.017703490
1580.017817249
1590.017931022
1600.018044807
1610.018158605
1620.018272416
1630.018386239
1640.018500075
1650.018613924
1660.018727785
1670.018841659
1680.018955546
1690.019069446
1700.019183359
1710.019297284
1720.019411222
1730.019525172
1740.019639136
1750.019753112
1760.019867101
1770.019981102
1780.020095116
1790.020209143
1800.020323183
1810.020437236
1820.020551301
1830.020665379
1840.020779470
1850.020893574
1860.021007690
1870.021121819
1880.021235961
1890.021350115
1900.021464283

Bulletin No. 2025–49 755 December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
1910.021578463
1920.021692656
1930.021806861
1940.021921080
1950.022035311
1960.022149555
1970.022263812
1980.022378081
1990.022492363
2000.022606658
2010.022720966
2020.022835287
2030.022949620
2040.023063966
2050.023178325
2060.023292697
2070.023407082
2080.023521479
2090.023635889
2100.023750312
2110.023864747
2120.023979196
2130.024093657
2140.024208131
2150.024322618
2160.024437118
2170.024551630
2180.024666155
2190.024780693
2200.024895244
2210.025009808
2220.025124384
2230.025238973
2240.025353575
2250.025468190

December 1, 2025 756 Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
2260.025582818
2270.025697458
2280.025812112
2290.025926778
2300.026041457
2310.026156149
2320.026270853
2330.026385571
2340.026500301
2350.026615044
2360.026729800
2370.026844568
2380.026959350
2390.027074144
2400.027188952
2410.027303772
2420.027418604
2430.027533450
2440.027648309
2450.027763180
2460.027878064
2470.027992961
2480.028107871
2490.028222794
2500.028337730
2510.028452678
2520.028567639
2530.028682613
2540.028797600
2550.028912600
2560.029027613
2570.029142638
2580.029257677
2590.029372728
2600.029487792

Bulletin No. 2025–49 757 December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYS
261
FACTOR
0.029602869
2620.029717959
2630.029833062
2640.029948177
2650.030063306
2660.030178447
2670.030293601
2680.030408768
2690.030523948
2700.030639141
2710.030754347
2720.030869565
2730.030984797
2740.031100041
2750.031215298
2760.031330569
2770.031445852
2780.031561147
2790.031676456
2800.031791778
2810.031907112
2820.032022460
2830.032137820
2840.032253193
2850.032368579
2860.032483978
2870.032599390
2880.032714815
2890.032830253
2900.032945703
2910.033061167
2920.033176643
2930.033292133
2940.033407635
2950.033523150

December 1, 2025 758 Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
2960.033638678
2970.033754219
2980.033869773
2990.033985340
3000.034100920
3010.034216512
3020.034332118
3030.034447736
3040.034563368
3050.034679012
3060.034794669
3070.034910340
3080.035026023
3090.035141719
3100.035257428
3110.035373150
3120.035488885
3130.035604632
3140.035720393
3150.035836167
3160.035951953
3170.036067753
3180.036183565
3190.036299391
3200.036415229
3210.036531081
3220.036646945
3230.036762822
3240.036878712
3250.036994615
3260.037110532
3270.037226461
3280.037342403
3290.037458358
3300.037574326

Bulletin No. 2025–49 759 December 1, 2025
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
3310.037690307
3320.037806300
3330.037922307
3340.038038327
3350.038154360
3360.038270406
3370.038386464
3380.038502536
3390.038618621
3400.038734718
3410.038850829
3420.038966953
3430.039083089
3440.039199239
3450.039315401
3460.039431577
3470.039547765
3480.039663967
3490.039780181
3500.039896409
3510.040012649
3520.040128903
3530.040245169
3540.040361449
3550.040477741
3560.040594047
3570.040710365
3580.040826696
3590.040943041
3600.041059398
3610.041175769
3620.041292152
3630.041408549
3640.041524958
3650.041641381

December 1, 2025 760 Bulletin No. 2025–49
ANNUAL RATE (4.08%), COMPOUNDED DAILY
DAYSFACTOR
3660.041757816
3670.041874265
3680.041990726
3690.042107201
3700.042223689
3710.042340189

Bulletin No. 2025–49 761 December 1, 2025
Part III
2026 Amounts Relating to
Retirement Plans and IRAs,
as Adjusted for Changes in
Cost-of-Living
Notice 2025-67
Section 415 of the Internal Revenue
Code (“Code”) provides for limitations on
benefits and contributions under qualified
retirement plans. Section 415(d) requires
that the Secretary of the Treasury annu-
ally adjust these limitations for cost-of-
living increases. Under section 415(d),
the adjustments are to be made under
adjustment procedures similar to those
used to adjust benefit amounts under sec-
tion 215(i)(2)(A) of the Social Security
Act. Other amounts applicable to deferred
compensation plans are also adjusted for
cost-of-living increases using a variation
of the methodology used for the adjust-
ments under section 415(d).
Cost-of-Living Adjusted Limitations
for 2026
Effective January 1, 2026, the limita-
tion on the annual benefit under a defined
benefit plan under section 415(b)(1)(A)
of the Code is increased from $280,000
to $290,000.
For a participant who separated from
service before January 1, 2026, the par-
ticipant’s limitation under a defined ben-
efit plan under section 415(b)(1)(B) is
computed by multiplying the participant’s
compensation limitation, as adjusted
through 2025, by 1.0288.
The limitation for defined contribu-
tion plans under section 415(c)(1)(A)
is increased in 2026 from $70,000 to
$72,000.
The Code provides that various other
amounts are to be adjusted at the same
time and in the same manner as the lim-
itation of section 415(b)(1)(A). After tak-
ing into account the applicable rounding
rules, the amounts for 2026 are as follows:
The limitation under section 402(g)(1)
on the exclusion for elective deferrals
described in section 402(g)(3), which
includes elective deferrals made to the
Thrift Savings Plan, is increased from
$23,500 to $24,500.
The limitation on deferrals under sec-
tion 457(e)(15) concerning deferred
compensation plans of state and local
governments and tax-exempt organi-
zations is increased from $23,500 to
$24,500.
The limitation under section 414(v)
(2)(B)(i) for catch-up contributions
to an applicable employer plan other
than a plan described in section 401(k)
(11) or section 408(p) that generally
applies for individuals aged 50 or over
is increased from $7,500 to $8,000.
The limitation under section 414(v)(2)
(E)(i) for catch-up contributions to an
applicable employer plan other than a
plan described in section 401(k)(11)
or section 408(p) that applies for indi-
viduals who attain age 60, 61, 62, or
63 in 2026 remains $11,250. The Roth
catch-up wage threshold for 2025,
which under section 414(v)(7)(A) is
used to determine whether an individu-
al’s catch-up contributions to an appli-
cable employer plan (other than a plan
described in section 408(k) or (p)) for
2026 must be designated as Roth con-
tributions, is increased from $145,000
to $150,000.
The limitation under section 408(p)
(2)(E)(i)(III) that generally applies to
salary reduction contributions under a
SIMPLE retirement account or elec-
tive contributions under a SIMPLE
401(k) plan is increased from $16,500
to $17,000. The limitation for cer-
tain of those accounts or plans under
section 408(p)(2)(E)(i)(I) or (II) is
increased from $17,600 to $18,100.
The limitation under section 414(v)(2)
(B)(ii) for catch-up contributions to an
applicable employer plan described in
section 401(k)(11) or section 408(p)
that generally applies for individu-
als aged 50 or over is increased from
$3,500 to $4,000. The limitation under
section 414(v)(2)(E)(ii) for catch-up
contributions to an applicable employer
plan described in section 401(k)(11) or
section 408(p) that applies for indi-
viduals who attain age 60, 61, 62, or
63 in 2026 remains $5,250. The lim-
itation under section 414(v)(2)(B)(iii)
for catch-up contributions to certain
accounts or plans described in sec-
tion 401(k)(11) or section 408(p) that
generally applies for individuals aged
50 or over remains $3,850.
The limitation under section 401(k)
(16)(D)(i)(II) and 403(b)(16)(D)(i)
(II) that generally applies for elective
contributions made to a starter 401(k)
deferral-only arrangement described in
section 401(k)(16)(B) or a safe harbor
deferral-only plan described in section
403(b)(16)(B), respectively, remains
$6,000. This limitation is increased for
individuals who attain age 50 before
the end of the taxable year by $1,100.
The threshold used in the definition
of “highly compensated employee”
under section 414(q)(1)(B) remains
$160,000.
The threshold under section 416(i)
(1)(A)(i) concerning the definition of
“key employee” for top-heavy plan
purposes is increased from $230,000 to
$235,000.
The annual compensation lim-
itation under sections 401(a)
(17), 404(l), 408(k)(3)(C), and 408(k)
(6)(D)(ii) is increased from $350,000
to $360,000. The annual compensation
limitation under section 401(a)(17) for
eligible participants in certain govern-
mental plans that, under the plan as in
effect on July 1, 1993, allowed cost-of-
living adjustments to the compensation
limitation under the plan under section
401(a)(17) to be taken into account, is
increased from $520,000 to $535,000.
The limitation under section 402A(e)
(3)(A)(i) concerning pension-linked
emergency savings accounts that may
be included in certain types of defined

December 1, 2025 762 Bulletin No. 2025–49
contribution plans is increased from
$2,500 to $2,600.
The compensation threshold under sec-
tion 408(k)(2)(C) regarding simplified
employee pensions is increased from
$750 to $800.
The amount under section 409(o)(1)
(C)(ii) for determining the maximum
account balance in an employee stock
ownership plan subject to a 5-year
distribution period is increased from
$1,415,000 to $1,455,000, while the
dollar amount used to determine the
lengthening of the 5-year distribution
period is increased from $280,000 to
$290,000.
The limitation on the aggregate amount
of length of service awards accruing
with respect to any year of service
for any bona fide volunteer under
section 457(e)(11)(B)(ii) concerning
deferred compensation plans of state
and local governments and tax-exempt
organizations is increased from $7,500
to $8,000.
The limitation under section 664(g)
(7) concerning the qualified gratuitous
transfer of qualified employer securi-
ties to an employee stock ownership
plan is increased from $60,000 to
$65,000.
The compensation amount under §
1.61-21(f)(5)(i) of the Income Tax
Regulations concerning the definition
of “control employee” for fringe ben-
efit valuation purposes is increased
from $140,000 to $145,000. The com-
pensation amount under § 1.61-21(f)
(5)(iii) is increased from $285,000 to
$290,000.
The limitation on premiums paid for a
qualifying longevity annuity contract
under § 1.401(a)(9)-6(q)(2)(ii) remains
$210,000.
The $1,000,000,000 threshold used
to determine whether a multiemployer
plan is a systemically important plan
under section 432(e)(9)(H)(v)(III)(aa) is
adjusted using the cost-of-living adjust-
ment provided under section 432(e)(9)(H)
(v)(III)(bb). After taking the applicable
rounding rule into account, the threshold
used to determine whether a multiem-
ployer plan is a systemically important
plan under section 432(e)(9)(H)(v)(III)
(aa) is increased from $1,441,000,000 to
$1,505,000,000.
The Code also provides that several
retirement-related amounts are to be
adjusted using a variation of the method-
ology used for the cost-of-living adjust-
ments under section 1(f)(3). After taking
the applicable rounding rules into account,
the amounts for 2026 are as follows:
The adjusted gross income limitation
under section 25B(b)(1)(A) for deter-
mining the retirement savings contri-
butions credit for married taxpayers
filing a joint return is increased from
$47,500 to $48,500; the limitation
under section 25B(b)(1)(B) is increased
from $51,000 to $52,500; and the lim-
itation under sections 25B(b)(1)(C)
and 25B(b)(1)(D) is increased from
$79,000 to $80,500.
The adjusted gross income limitation
under section 25B(b)(1)(A) for deter-
mining the retirement savings contri-
butions credit for taxpayers filing as
head of household is increased from
$35,625 to $36,375; the limitation
under section 25B(b)(1)(B) is increased
from $38,250 to $39,375; and the lim-
itation under sections 25B(b)(1)(C)
and 25B(b)(1)(D) is increased from
$59,250 to $60,375.
The adjusted gross income limitation
under section 25B(b)(1)(A) for deter-
mining the retirement savings contri-
butions credit for all other taxpayers
is increased from $23,750 to $24,250;
the limitation under section 25B(b)
(1)(B) is increased from $25,500 to
$26,250; and the limitation under sec-
tions 25B(b)(1)(C) and 25B(b)(1)(D) is
increased from $39,500 to $40,250.
The deductible amount under section
219(b)(5)(A), which limits the amount
of an individual’s deductible qualified
retirement contributions for a tax-
able year is increased from $7,000 to
$7,500. The deductible amount pur-
suant to section 219(b)(5)(B)(ii) for
individuals who have attained age 50
before the close of the taxable year is
increased from $1,000 to $1,100.
The applicable amount under section
219(g)(3)(B)(i) for determining the
deductible amount of an IRA contri-
bution for taxpayers who are active
participants filing a joint return or as
a qualifying widow(er) is increased
from $126,000 to $129,000. The appli-
cable amount under section 219(g)(3)
(B)(ii) for all other taxpayers who are
active participants (other than married
taxpayers filing separate returns) is
increased from $79,000 to $81,000.
If an individual or the individual’s
spouse is an active participant, the
applicable amount under section
219(g)(3)(B)(iii) for a married indi-
vidual filing a separate return is not
subject to an annual cost-of-living
adjustment and remains $0. The appli-
cable amount under section 219(g)
(7)(A) for a taxpayer who is not an
active participant but whose spouse is
an active participant is increased from
$236,000 to $242,000.
In light of the changes to the applica-
ble amounts, under section 219(g)(2)
(A), the deduction for taxpayers mak-
ing contributions to a traditional IRA
is phased out for single individuals and
heads of household who are active par-
ticipants in a qualified plan (or another
retirement plan specified in section
219(g)(5)) and have adjusted gross
incomes (as defined in section 219(g)
(3)(A)) between $81,000 and $91,000,
increased from between $79,000 and
$89,000. For married couples filing
jointly, if the spouse who makes the
IRA contribution is an active partic-
ipant, the income phase-out range
is between $129,000 and $149,000,
increased from between $126,000 and
$146,000. For an IRA contributor who
is not an active participant and is mar-
ried to someone who is an active partic-
ipant, the deduction is phased out if the
couple’s income is between $242,000
and $252,000, increased from between
$236,000 and $246,000. For a mar-
ried individual filing a separate return
who is an active participant, the phase-
out range is not subject to an annual

Bulletin No. 2025–49 763 December 1, 2025
cost-of-living adjustment and remains
$0 to $10,000.
The adjusted gross income limitation
under section 408A(c)(3)(B)(ii)(I) for
determining the maximum Roth IRA con-
tribution for married taxpayers filing a joint
return or for taxpayers filing as a qualify-
ing widow(er) is increased from $236,000
to $242,000. The adjusted gross income
limitation under section 408A(c)(3)(B)
(ii)(II) for all other taxpayers (other than
married taxpayers filing separate returns)
is increased from $150,000 to $153,000.
The applicable amount under section
408A(c)(3)(B)(ii)(III) for a married indi-
vidual filing a separate return is not sub-
ject to an annual cost-of-living adjustment
and remains $0.
In light of the changes to the adjusted
gross income limitations, under sec-
tion 408A(c)(3)(A), the adjusted gross
income phase-out range for taxpayers
making contributions to a Roth IRA
is between $242,000 and $252,000
for married couples filing jointly,
increased from between $236,000 and
$246,000. For singles and heads of
household, the income phase-out range
is between $153,000 and $168,000,
increased from between $150,000
and $165,000. For a married individ-
ual filing a separate return, the phase-
out range is not subject to an annual
cost-of-living adjustment and remains
between $0 and $10,000.
The aggregate amount of qualified
charitable distributions that are not
includible in gross income under sec-
tion 408(d)(8)(A) is increased from
$108,000 to $111,000. The amount
of qualified charitable distributions
made directly to a split-interest entity
that are not includible in gross income
under section 408(d)(8)(F)(i)(II) pursu-
ant to a one-time election is increased
from $54,000 to $55,000.
The annual compensation limitation
under section 45E(f)(2)(C) for employ-
ees excluded from the calculation of
the additional small employer pen-
sion plan startup cost credit for certain
employer contributions is increased
from $105,000 to $110,000.
1
The limitation under section 72(t)(2)
(K)(ii)(I) for eligible distributions
to victims of domestic abuse from
applicable eligible retirement plans is
increased from $10,300 to $10,500.
The limitation under section 401(a)
(39)(B)(i)(III) on a qualified long-
term care distribution from a qualified
defined contribution plan with respect
to certified long-term care insurance
remains $2,600.
The limitation under section 408(p)
(2)(A)(iv) for additional nonelective
contributions for an employee to a
SIMPLE retirement account or a SIM-
PLE 401(k) plan is increased from
$5,100 to $5,300.
Drafting Information
The principal author of this notice
is Tom Morgan of the Office of Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employ-
ment Taxes). However, other personnel
from the IRS participated in the devel-
opment of this guidance. For further
information regarding this notice, con-
tact Mr. Morgan at (202) 317-6700 (not
a toll-free call).
1
Pursuant to section 45E(f)(2)(C)(iii), for a taxable year beginning in a calendar year after 2023, this limitation is equal to the initial limitation of $100,000, multiplied by the cost-of-living
adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting “calendar year 2007” for “calendar year 2016” in section 1(f)
(3)(A)(ii). Because the specification of a 2007 base period to be used for computing an adjustment that is first made for 2024 appears to be an error that has been identified as the subject of
future legislative correction, the IRS will calculate and apply the limitation in section 45E(f)(2)(C) by substituting “calendar year 2022” for “calendar year 2007” in section 45E(f)(2)(C)(iii).

Bulletin No. 2025–49 i December 1, 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.

December 1, 2025 ii Bulletin No. 2025–49
Numerical Finding List
1
Bulletin 2025–49
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
2025-67, 2025-49 I.R.B. 761
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
2025-23, 2025-48 I.R.B. 749
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. 2025–49 iii December 1, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–49
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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