Internal Revenue Bulletin 2025-2 (PDF rendition): IRS Announcements

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Bulletin No. 2025–2
January 6, 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
Announcement 2025-3, page 306.
This announcement amends the announcement number of
Announcement 2024-39, 2024-39 I.R.B. 639, to Announce-
ment 2024-33 by correcting several administrative refer-
ences.
EMPLOYEE PLANS, EXCISE TAX,
INCOME TAX
Announcement 2025-2, page 305.
On July 19, 2024, the Treasury Department and the
IRS published proposed regulations regarding required
minimum distributions (RMDs) under section 401(a)(9)
of the Internal Revenue Code and related provisions in
the Federal Register (89 FR 58644). The proposed reg-
ulations were generally proposed to apply for purposes
of determining RMDs for calendar years beginning on or
after January 1, 2025. This announcement provides that
the Treasury Department and the IRS anticipate that cer-
tain portions of future regulations finalizing the proposed
regulations will apply beginning in the 2026 distribution
calendar year.
INCOME TAX
Announcement 2025-4, page 306.
This announcement corrects the publication of TD 10015
to add information about the Federal Register filing date
and publication information.
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.
January 6, 2025 Bulletin No. 2025–2

Part III
Anticipated Applicability
Date for Future Final
Regulations Relating
to Required Minimum
Distributions
Announcement 2025-2
I. PURPOSE
This announcement provides that the
Department of the Treasury (Treasury
Department) and the Internal Revenue
Service (IRS) anticipate that certain por-
tions of future final regulations relating to
required minimum distributions (RMDs)
under section 401(a)(9) of the Internal
Revenue Code (Code) will apply no ear-
lier than the 2026 distribution calendar
year.
II. BACKGROUND
Section 401(a)(9) of the Code requires
a stock bonus, pension, or profit-shar-
ing plan described in section 401(a) (or
an annuity contract described in section
403(a)) to make minimum distributions
starting by the required beginning date
(as well as minimum distributions to
beneficiaries if the employee dies before
the required beginning date). Individual
retirement accounts and individual retire-
ment annuities described in section 408(a)
and (b), respectively, annuity contracts,
custodial accounts, and retirement income
accounts described in section 403(b),
and eligible deferred compensation plans
under section 457(b) are also subject to
the rules of section 401(a)(9) pursuant to
sections 408(a)(6) and (b)(3), 403(b)(10),
and 457(d)(2), respectively, and the regu-
lations under those sections.
The Treasury Department and the IRS
published proposed regulations regarding
RMDs under section 401(a)(9) and related
provisions in the Federal Register on Feb-
ruary 24, 2022 (87 FR 10504). The 2022
proposed regulations reflected changes
made by the Setting Every Community
Up for Retirement Enhancement Act of
2019 (SECURE Act), enacted on Decem-
ber 20, 2019, as Division O of the Further
Consolidated Appropriations Act, 2020,
Pub. L. 116-94, 133 Stat. 2534 (2019),
and also included a comprehensive update
and restatement of the regulations under
section 401(a)(9).
After the 2022 proposed regulations
were issued, the SECURE 2.0 Act of 2022
(SECURE 2.0 Act) was enacted as Divi-
sion T of the Consolidated Appropriations
Act, 2023, Pub. L. 117-328, 136 Stat. 4459
(2022). The SECURE 2.0 Act included a
number of provisions relating to RMDs.
After considering the comments received
in response to the 2022 proposed regula-
tions and reviewing the changes made in
the SECURE 2.0 Act, the Treasury Depart-
ment and the IRS determined that certain
of those changes could be included in final
regulations, but that other changes should
be addressed in new proposed regulations.
Accordingly, on July 19, 2024, the Trea-
sury Department and the IRS published
final regulations regarding RMDs under
section 401(a)(9) and related provisions
in the Federal Register (89 FR 58886) and
also published proposed regulations under
section 401(a)(9) and related provisions
(89 FR 58644).
With the exception of proposed
§ 1.401(a)(9)-5(a)(5)(v) (relating to the
valuation of an annuity contract under
the partial annuitization option provided
for in section 204 of the SECURE 2.0
Act), the provisions of the 2024 proposed
regulations were proposed to apply for
purposes of determining RMDs for cal-
endar years beginning on or after Janu-
ary 1, 2025 (so that they would begin to
apply at the same time as the 2024 final
regulations). In written comments and
at the public hearing held on Septem-
ber 25, 2024, commenters raised issues
regarding some of the provisions of the
proposed regulations. Commenters were
also concerned that it would be difficult
to implement many of the provisions of
the future final regulations in a timely
manner if the January 1, 2025, applica-
bility date set forth in the 2024 proposed
regulations is retained in the final regu-
lations. Commenters said that this diffi-
culty arises from the expected timing of
the future final regulations along with
the uncertainty regarding the resolution
of issues commenters raised. Comment-
ers expressed specific concerns with the
challenges of implementing the final
regulations to be adopted pursuant to the
proposed amendments to §§ 1.401(a)(9)-
4, 1.401(a)(9)-5, and 1.401(a)(9)-6.
III. ANTICIPATED APPLICABILITY
DATE OF FUTURE FINAL
REGULATIONS
In response to concerns raised by com-
menters, the provisions of future final
regulations amending §§ 1.401(a)(9)-4,
1.401(a)(9)-5, and 1.401(a)(9)-6 to be
issued pursuant to the 2024 proposed reg-
ulations are anticipated to apply beginning
in the 2026 distribution calendar year. For
periods before the applicability date of
these amendments, taxpayers must apply
a reasonable, good-faith interpretation of
the statutory provisions underlying the
amendments.
IV. DRAFTING INFORMATION
The principal author of this announce-
ment is Jessica Weinberger of the Office of
Associate Chief Counsel (Employee Ben-
efits, Exempt Organizations, and Employ-
ment Taxes). For further information
regarding this announcement, contact Ms.
Weinberger at 202-317-6349 (not a toll-
free number).
Bulletin No. 2025–2 305 January 6, 2025

Correction to
Announcement 2024-39,
I.R.B. 2024-39
Announcement 2025-3
Announcement 2024-39, 2024-39 I.R.B.
639 (Sept. 23, 2024), was incorrectly
numbered. This announcement amends
the announcement number to Announce-
ment 2024-33 by correcting the following
administrative items.
Correction 1:
In Highlights of This Issue, the article
number incorrectly appears as Announce-
ment 2024-39.
The correct article number is Announce-
ment 2024-33.
Correction 2:
On Page 639, the article number incor-
rectly appears as Announcement 2024-39.
The correct article number is Announce-
ment 2024-33.
Correction 3:
On Page ii, Numerical Finding List,

the
article number incorrectly appears under
Announcements: as 2024-39. The correct
article number is 2024-33.
Correction to TD 10015,
IRB 2024-52
Announcement 2025-04
This document contains a correction to TD
10015, as published on Monday, Decem-
ber 23, 2024 (I.R.B. 2024-52, 1355). In
particular, this announcement corrects the
following administrative item.
Correction 1:
In the filing information found at the end
of the document on page 1424, the filing
dates and Federal Register publication
information are omitted. It should state:
(Filed by the Office of the Federal Register Decem-
ber 04, 2024, and published in the issue of the Fed-
eral Register for December 12, 2024, 89 FR 100598)
January 6, 2025 306 Bulletin No. 2025–2

Bulletin No. 2025–2 i January 6, 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.

January 6, 2025 ii Bulletin No. 2025–2
Numerical Finding List
1
Bulletin 2025–2
Announcements:
2025-2, 2025-2 I.R.B. 305
2025-3, 2025-2 I.R.B. 306
2025-4, 2025-2 I.R.B. 306
Revenue Procedures:
2025-1, 2025-01 I.R.B. 1
2025-2, 2025-01 I.R.B. 118
2025-3, 2025-01 I.R.B. 142
2025-4, 2025-01 I.R.B. 158
2025-5, 2025-01 I.R.B. 260
2025-7, 2025-01 I.R.B. 301
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 23, 2024.

Bulletin No. 2025–2 iii January 6, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–2
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 23, 2024.

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