Internal Revenue Bulletin 2025-16 (PDF rendition): IRS Revenue Rulings

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Bulletin No. 2025–16
April 14, 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.
INCOME TAX
Notice 2025-18, page 1416.
Resident populations of the 50 states, the District of Colum-
bia, Puerto Rico, and the insular areas for purposes of deter-
mining the 2025 calendar year (1) state housing credit ceil-
ing under section 42(h) of the Code, (2) private activity bond
volume cap under section 146, and (3) private activity bond
volume limit under section 142(k) are reproduced.
Rev. Rul. 2025-9, page 1415.
Fringe benefits aircraft valuation formula. For purposes of
section 1.61-21(g) of the Income Tax Regulations, relating to
the rule for valuing non-commercial flights on employer-pro-
vided aircraft, the Standard Industry Fare Level (SIFL) cents-
per-mile rates and terminal charge in effect for the first half
of 2025 are set forth.
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.
April 14, 2025 Bulletin No. 2025–16

Part I
Section 61.—Gross Income
Defined
26 CFR 1.61-21: Taxation of Fringe Benefits
Rev. Rul. 2025-9
For purposes of the taxation of fringe
benefits under section 61 of the Internal
Revenue Code, section 1.61-21(g) of
the Income Tax Regulations provides a
rule for valuing noncommercial flights
on employer-provided aircraft. Section
1.61-21(g)(5) provides an aircraft val-
uation formula to determine the value
of such flights. The value of a flight is
determined under the base aircraft valua-
tion formula (also known as the Standard
Industry Fare Level formula or SIFL)
by multiplying the SIFL cents-per-mile
rates applicable for the period during
which the flight was taken by the appro-
priate aircraft multiple provided in sec-
tion 1.61-21(g)(7) and then adding the
applicable terminal charge. The SIFL
cents-per-mile rates in the formula and
the terminal charge are calculated by the
Department of Transportation (DOT) and
are reviewed semi-annually.
The following chart sets forth the ter-
minal charge and SIFL mileage rates:
Period During Which
the Flight Is Taken
Terminal ChargeSIFL Mileage Rates
1/1/25 - 6/30/25 $52.44Up to 500 miles
= $.2869 per mile
501-1500 miles
= $.2187 per mile
Over 1500 miles
= $.2103 per mile
DRAFTING INFORMATION
The principal author of this revenue rul-
ing is Kathleen Edmondson of the Office
of Associate Chief Counsel (Employee
Benefits, Exempt Organizations and
Employment Taxes). For further informa-
tion regarding this revenue ruling, contact
Ms. Edmondson at (202) 317-6798 (not a
toll-free call).
Bulletin No. 2025–16 1415 April 14, 2025

Part III
2025 Calendar Year
Resident Population
Figures
Notice 2025-18
This notice advises State and local
housing credit agencies that allocate
low-income housing tax credits under § 42
of the Internal Revenue Code, and States
and other issuers of tax-exempt private
activity bonds under § 141, of the pop-
ulation figures to use in calculating: (1)
the 2025 calendar year population-based
component of the State housing credit
ceiling (Credit Ceiling) under § 42(h)(3)
(C)(ii); (2) the 2025 calendar year volume
cap (Volume Cap) under § 146; and (3) the
2025 volume limit (Volume Limit) under
§ 142(k)(5).
Generally, the population-based com-
ponent of both the Credit Ceiling and
the Volume Cap are determined under §
146(j), which requires determining the
population figures for any calendar year
on the basis of the most recent census esti-
mate of the resident population of a State
(or issuing authority) released by the U.S.
Census Bureau before the beginning of the
calendar year. Similarly, § 142(k)(5) bases
the Volume Limit on the State population.
Sections 42(h)(3)(H) and 146(d)(2)
require adjusting for inflation the popula-
tion-based component of the Credit Ceil-
ing and the Volume Cap. The Credit Ceil-
ing adjustment for the 2025 calendar year
is in Rev. Proc. 2024-40; 2024-45 I.R.B.
1100. Section 2.09 of Rev. Proc. 2024-40
provides that, for calendar year 2025, the
amount for calculating the Credit Ceil-
ing under § 42(h)(3)(C)(ii) is the greater
of $3.00 multiplied by the State popula-
tion, or $3,455,000. Further, section 2.20
of Rev. Proc. 2024-40 provides that the
amount for calculating the Volume Cap
under § 146(d)(1) for calendar year 2025
is the greater of $130 multiplied by the
State population, or $388,780,000.
For the 50 states, the District of Colum-
bia, and Puerto Rico, the population fig-
ures for calculating the Credit Ceiling, the
Volume Cap, and the Volume Limit for the
2025 calendar year are the resident pop-
ulation estimates released electronically
by the U.S. Census Bureau on December
19, 2024, and described in Press Release
CB24-213. For American Samoa, Guam,
the Northern Mariana Islands, and the
U.S. Virgin Islands, the population figures
for the 2025 calendar year are the 2024
midyear population figures in the U.S.
Census Bureau’s International Data Base.
For convenience, these figures are
reprinted below.
Resident Population Figures
Alabama 5,157,699
Alaska 740,133
American Samoa 43,895
Arizona 7,582,384
Arkansas 3,088,354
California 39,431,263
Colorado 5,957,493
Connecticut 3,675,069
Delaware 1,051,917
District of Columbia 702,250
Florida 23,372,215
Georgia 11,180,878
Guam 169,532
Hawaii 1,446,146
Idaho 2,001,619
Illinois 12,710,158
Indiana 6,924,275
Iowa 3,241,488
Kansas 2,970,606
Kentucky 4,588,372
Louisiana 4,597,740
Maine 1,405,012
Maryland 6,263,220
April 14, 2025 1416 Bulletin No. 2025–16

Bulletin No. 2025–16 1417 April 14, 2025
Resident Population Figures
Massachusetts 7,136,171
Michigan 10,140,459
Minnesota 5,793,151
Mississippi 2,943,045
Missouri 6,245,466
Montana 1,137,233
Nebraska 2,005,465
Nevada 3,267,467
New Hampshire 1,409,032
New Jersey 9,500,851
New Mexico 2,130,256
New York 19,867,248
North Carolina 11,046,024
North Dakota 796,568
Northern Mariana Islands 51,118
Ohio 11,883,304
Oklahoma 4,095,393
Oregon 4,272,371
Pennsylvania 13,078,751
Puerto Rico 3,203,295
Rhode Island 1,112,308
South Carolina 5,478,831
South Dakota 924,669
Tennessee 7,227,750
Texas 31,290,831
Utah 3,503,613
Vermont 648,493
Virginia 8,811,195
Virgin Islands, U.S. 104,377
Washington 7,958,180
West Virginia 1,769,979
Wisconsin 5,960,975
Wyoming 587,618
The principal authors of this notice are
Waheed M. Olayan, Office of the Associ-
ate Chief Counsel (Energy, Credits, and
Excise), and Brian Choi, Office of the
Associate Chief Counsel (Financial Insti-
tutions and Products). For further infor-
mation regarding this notice, please con-
tact Waheed M. Olayan at (202) 317-6239
(not a toll-free number).

Bulletin No. 2025–16 i April 14, 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.

April 14, 2025 ii Bulletin No. 2025–16
Numerical Finding List
1
Bulletin 2025–16
Announcements:
2025-2, 2025-2 I.R.B. 305
2025-3, 2025-2 I.R.B. 306
2025-4, 2025-2 I.R.B. 306
2025-1, 2025-3 I.R.B. 431
2025-5, 2025-3 I.R.B. 433
2025-6, 2025-5 I.R.B. 526
2025-8, 2025-13 I.R.B. 1384
2025-13, 2025-15 I.R.B. 1392
Notices:
2025-1, 2025-3 I.R.B. 415
2025-2, 2025-3 I.R.B. 418
2025-4, 2025-3 I.R.B. 419
2025-5, 2025-3 I.R.B. 426
2025-3, 2025-4 I.R.B. 488
2025-7, 2025-5 I.R.B. 524
2025-9, 2025-6 I.R.B. 681
2025-10, 2025-6 I.R.B. 682
2025-11, 2025-6 I.R.B. 704
2025-13, 2025-6 I.R.B. 710
2025-6, 2025-8 I.R.B. 799
2025-8, 2025-8 I.R.B. 800
2025-12, 2025-8 I.R.B. 813
2025-14, 2025-10 I.R.B. 980
2025-15, 2025-11 I.R.B. 1089
2025-16, 2025-13 I.R.B. 1378
2025-17, 2025-14 I.R.B. 1387
2025-18, 2025-16 I.R.B. 1416
Proposed Regulations:
REG-117213-24, 2025-3 I.R.B. 433
REG-134420-10, 2025-4 I.R.B. 513
REG-105479-18, 2025-5 I.R.B. 527
REG-116610-20, 2025-5 I.R.B. 638
REG-115560-23, 2025-6 I.R.B. 716
REG-123525-23, 2025-6 I.R.B. 726
REG-124930-21, 2025-7 I.R.B. 772
REG-100669-24, 2025-8 I.R.B. 819
REG-101268-24, 2025-8 I.R.B. 836
REG-107420-24, 2025-8 I.R.B. 854
REG-116085-23, 2025-8 I.R.B. 865
REG-118988-22, 2025-8 I.R.B. 869
REG-107895-24, 2025-9 I.R.B. 972
REG-110878-24, 2025-9 I.R.B. 979
REG-112261-24, 2025-10 I.R.B. 983
Revenue Procedures:
2025-1, 2025-1 I.R.B. 1
2025-2, 2025-1 I.R.B. 118
2025-3, 2025-1 I.R.B. 142
2025-4, 2025-1 I.R.B. 158
2025-5, 2025-1 I.R.B. 260
Revenue Procedures:—Continued
2025-7, 2025-1 I.R.B. 301
2025-8, 2025-3 I.R.B. 427
2025-9, 2025-4 I.R.B. 491
2025-10, 2025-4 I.R.B. 492
2025-11, 2025-4 I.R.B. 501
2025-12, 2025-4 I.R.B. 512
2025-6, 2025-6 I.R.B. 713
2025-14, 2025-7 I.R.B. 770
2025-13, 2025-8 I.R.B. 816
2025-15, 2025-11 I.R.B. 1090
2025-16, 2025-11 I.R.B. 1100
2025-17, 2025-13 I.R.B. 1382
Revenue Rulings:
2025-1, 2025-3 I.R.B. 307
2025-2, 2025-3 I.R.B. 309
2025-3, 2025-4 I.R.B. 443
2025-4, 2025-7 I.R.B. 758
2025-5, 2025-7 I.R.B. 767
2025-6, 2025-11 I.R.B. 1064
2025-7, 2025-13 I.R.B. 1239
2025-8, 2025-15 I.R.B. 1390
2025-9, 2025-16 I.R.B. 1415
Treasury Decisions:
10016, 2025-3 I.R.B. 313
10020, 2025-3 I.R.B. 408
10018, 2025-4 I.R.B. 446
10019, 2025-4 I.R.B. 482
10017, 2025-5 I.R.B. 517
10028, 2025-6 I.R.B. 660
10022, 2025-8 I.R.B. 773
10026, 2025-9 I.R.B. 878
10027, 2025-9 I.R.B. 897
10029, 2025-9 I.R.B. 936
10030, 2025-11 I.R.B. 1066
10024, 2025-12 I.R.B. 1104
10023, 2025-13 I.R.B. 1259
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. 2025–16 iii April 14, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–16
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.

Internal Revenue Service
Washington, DC 20224
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