us-irs-revenue-rulings-irb-2025-19-pdf•Internal Revenue Bulletin 2025-19 (PDF rendition): IRS Revenue Rulings
Internal Revenue Bulletin 2025-19 (PDF rendition): IRS Revenue Rulings
us-irs-revenue-rulings-irb-2025-19-pdfInternal Revenue Bulletin 2025-19 (PDF rendition): IRS Revenue RulingsGuidance
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Bulletin No. 2025–19 May 5, 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 2025-24, page 1429. This notice provides relief from penalties under section 6707A(a) and 6707(a) for participants in and material advi- sors to micro-captive reportable transactions for disclo- sure statements required to be filed with the Office of Tax Shelter Analysis (OTSA) under sections 6011 and 6111, as set forth in §§ 1.6011-10(h)(2) and (3) and 1.6011- 11(h)(2) and (3), respectively. This relief applies only if the required disclosure statements are filed with OTSA by July 31, 2025. ADMINISTRATIVE, INCOME TAX Rev. Proc. 2025-18, page 1430. This Revenue Procedure provides issuers of qualified mort- gage bonds and mortgage credit certificates with (1) the nationwide average purchase price for residences located in the United States, and (2) the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia, Puerto Rico, the North- ern Mariana Islands, American Samoa, the Virgin Islands, and Guam. EMPLOYEE PLANS Notice 2025-21, page 1424. This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for March 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv). INCOME TAX Notice 2025-20, page 1423. This notice announces the applicable percentage under sec- tion 613A(c)(6)(C) for marginal oil and gas properties in the 2025 calendar year. The applicable percentage is used to determine the amount of the percentage depletion deduction allowable under section 613A(c)(6) with respect to oil and natural gas produced from marginal properties. Notice 2025-23, page 1428. Notice 2025-23 informs taxpayers and material advisors that final regulations regarding the identification of certain partnership related-party basis adjustment transactions as transactions of interest will be withdrawn through the forth- coming publication of proposed and final regulations and that they can rely on the notice for relief from applicable penalties for failure to file disclosure statements. In addition, Notice 2025-23 revokes Notice 2024-54, which informed taxpay- ers of intended proposed regulations that would provide sub- stantive technical rules to discourage basis shifting among related partners. Rev. Rul. 2025-10, page 1421. Federal rates; adjusted federal rates; adjusted federal long- term rate, and the long-term tax exempt rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for May 2025. SPECIAL ANNOUNCEMENT Notice 2025-22, page 1427. This notice starts the process of eliminating extraneous and unnecessary Internal Revenue Bulletin (IRB) guidance by iden- tifying and obsoleting nine IRB guidance documents. 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. May 5, 2025 Bulletin No. 2025–19 Part I Section 1274.— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also, Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. Rul. 2025-10 This revenue ruling provides vari- ous prescribed rates for federal income tax purposes for May 2025 (the current month). Table 1 contains the short- term, mid-term, and long-term applica- ble federal rates (AFR) for the current month for purposes of section 1274(d) of the Internal Revenue Code. Table 2 contains the short-term, mid-term, and long-term adjusted applicable federal rates (adjusted AFR) for the current month for purposes of section 1288(b). Table 3 sets forth the adjusted fed- eral long-term rate and the long-term tax-exempt rate described in section 382(f). Table 4 contains the appropri- ate percentages for determining the low-income housing credit described in section 42(b)(1) for buildings placed in service during the current month. How- ever, under section 42(b)(2), the appli- cable percentage for non-federally sub- sidized new buildings placed in service after July 30, 2008, shall not be less than 9%. Finally, Table 5 contains the federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of section 7520. REV. RUL. 2025-10 TABLE 1 Applicable Federal Rates (AFR) for May 2025 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term AFR4.05%4.01%3.99%3.98% 110% AFR4.46%4.41%4.39%4.37% 120% AFR4.87%4.81%4.78%4.76% 130% AFR5.28%5.21%5.18%5.15% Mid-term AFR4.10%4.06%4.04%4.03% 110% AFR 4.52%4.47%4.45%4.43% 120% AFR4.93%4.87%4.84%4.82% 130% AFR5.35%5.28%5.25%5.22% 150% AFR6.18%6.09%6.04%6.01% 175% AFR7.24%7.11%7.05%7.01% Long-term AFR4.62%4.57%4.54%4.53% 110% AFR5.09%5.03%5.00%4.98% 120% AFR5.56%5.48%5.44%5.42% 130% AFR6.03%5.94%5.90%5.87% REV. RUL. 2025-10 TABLE 2 Adjusted AFR for May 2025 Period for Compounding AnnualSemiannualQuarterlyMonthly Short-term adjusted AFR3.06%3.04%3.03%3.02% Mid-term adjusted AFR3.10%3.08%3.07%3.06% Long-term adjusted AFR3.50%3.47%3.46%3.45% Bulletin No. 2025–19 1421 May 5, 2025 REV. RUL. 2025-10 TABLE 3 Rates Under Section 382 for May 2025 Adjusted federal long-term rate for the current month3.50% Long-term tax-exempt rate for ownership changes during the current month (the highest of the adjusted federal long-term rates for the current month and the prior two months.) 3.64% REV. RUL. 2025-10 TABLE 4 Appropriate Percentages Under Section 42(b)(1) for May 2025 Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new buildings placed in service after July 30, 2008, shall not be less than 9%. Appropriate percentage for the 70% present value low-income housing credit8.01% Appropriate percentage for the 30% present value low-income housing credit 3.43% REV. RUL. 2025-10 TABLE 5 Rate Under Section 7520 for May 2025 Applicable federal rate for determining the present value of an annuity, an interest for life or a term of years, or a remainder or reversionary interest 5.00% Section 42.—Low-Income Housing Credit The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 280G.—Golden Parachute Payments The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 382.—Limitation on Net Operating Loss Carryforwards and Certain Built-In Losses Following Ownership Change The adjusted applicable federal long-term rate is set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 467.—Certain Payments for the Use of Property or Services The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 468.—Special Rules for Mining and Solid Waste Reclamation and Closing Costs The applicable federal short-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 482.—Allocation of Income and Deductions Among Taxpayers The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 483.—Interest on Certain Deferred Payments The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 1288.—Treatment of Original Issue Discount on Tax-Exempt Obligations The adjusted applicable federal short-term, mid- term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 7520.—Valuation Tables The applicable federal mid-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. Section 7872.—Treatment of Loans With Below- Market Interest Rates The applicable federal short-term, mid-term, and long-term rates are set forth for the month of May 2025. See Rev. Rul. 2025-10, page 1421. May 5, 2025 1422 Bulletin No. 2025–19 Bulletin No. 2025–19 1423 May 5, 2025 Part III 2025 Marginal Production Rates Notice 2025-20 This notice announces the applicable percentage under § 613A of the Internal Revenue Code to be used in determining percentage depletion for marginal proper- ties for the 2025 calendar year. Section 613A(c)(6)(C) defines the term “applicable percentage” for purposes of determining percentage depletion for oil and gas produced from marginal prop- erties. The applicable percentage is the percent age (not greater than 25 percent) equal to the sum of 15 percent, plus one percentage point for each whole dollar by which $20 exceeds the reference price (determined under § 45K(d)(2)(C)) for crude oil for the calendar year preceding the calendar year in which the taxable year begins. The ref erence price determined under § 45K(d)(2)(C) for the 2024 calen- dar year is $74.48. Accordingly, 15% is the applicable percentage under § 613A to be used in determining percentage deple- tion for marginal properties for the 2025 calendar year. The following table contains the appli- cable percentages for marginal production for taxable years beginning in calendar years 1991 through 2025. Notice 2025-20 Applicable Percentage for Marginal Production Calendar YearApplicable Percentage 199115 percent 199218 percent 199319 percent 199420 percent 199521 percent 199620 percent 199716 percent 199817 percent 199924 percent 200019 percent 200115 percent 200215 percent 200315 percent 200415 percent 200515 percent 200615 percent 200715 percent 200815 percent 200915 percent 201015 percent 201115 percent 201215 percent 201315 percent 201415 percent 201515 percent 201615 percent 201715 percent 201815 percent 201915 percent 202015 percent 202115 percent 202215 percent 202315 percent 202415 percent 202515 percent May 5, 2025 1424 Bulletin No. 2025–19 The principal author of this notice is Derek Gimbel of the Office of Asso- ciate Chief Counsel (Energy, Credits, and Excise Tax). For further information regarding this notice contact Derek Gim- bel at 202-317-6853 (not a toll-free num- ber). Update for Weighted Average Interest Rates, Yield Curves, and Segment Rates Notice 2025-21 This notice provides guidance on the corporate bond monthly yield curve, the corresponding spot segment rates used under § 417(e)(3), and the 24-month aver- age segment rates under § 430(h)(2) of the Internal Revenue Code. In addition, this notice provides guidance as to the inter- est rate on 30-year Treasury securities under § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under § 431(c)(6)(E)(ii)(I). YIELD CURVE AND SEGMENT RATES Section 430 specifies the minimum funding requirements that apply to sin- gle-employer plans (except for CSEC plans under § 414(y)) pursuant to § 412. Section 430(h)(2) specifies the interest rates that must be used to determine a plan’s target normal cost and funding target. Under this provision, present value is generally deter- mined using three 24-month average inter- est rates (“segment rates”), each of which applies to cash flows during specified peri- ods. To the extent provided under § 430(h) (2)(C)(iv), these segment rates are adjusted by the applicable percentage of the 25-year average segment rates for the period ending September 30 of the year preceding the cal- endar year in which the plan year begins. 1 However, an election may be made under § 430(h)(2)(D)(ii) to use the monthly yield curve in place of the segment rates. Section 1.430(h)(2)-1(d) provides rules for determining the monthly cor- porate bond yield curve, 2 and § 1.430(h) (2)-1(c) provides rules for determining the 24-month average corporate bond segment rates used to compute the tar- get normal cost and the funding target. Consistent with the methodology spec- ified in § 1.430(h)(2)-1(d), the monthly corporate bond yield curve derived from March 2025 data is in Table 2025-3 at the end of this notice. The spot first, second, and third segment rates for the month of March 2025 are, respectively, 4.50, 5.33, and 5.86. The 24-month average segment rates determined under § 430(h)(2)(C)(i) through (iii) must be adjusted pursuant to § 430(h)(2)(C)(iv) to be within the appli- cable minimum and maximum percent- ages of the corresponding 25-year aver- age segment rates. Those percentages are 95% and 105% for plan years beginning in 2024 and 2025. For this purpose, any 25-year average segment rate that is less than 5% is deemed to be 5%. The 25-year average segment rates for plan years beginning in 2024 and 2025 were pub- lished in Notice 2023-66, 2023-40 I.R.B. 992 and Notice 2024-67, 2024-41 I.R.B. 726, respectively. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for April 2025 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment April 2025 4.97 5.31 5.51 The adjusted 24-month average seg- ment rates set forth in the chart below reflect § 430(h)(2)(C)(iv) of the Code. The 24-month averages applicable for April 2025, adjusted to be within the applicable minimum and maximum percentages of the corresponding 25-year average seg- ment rates in accordance with § 430(h)(2) (C)(iv) of the Code, are as follows: Adjusted 24-Month Average Segment Rates For Plan Years Beginning InApplicable MonthFirst SegmentSecond SegmentThird Segment 2024April 20254.975.315.59 2025April 20254.975.315.51 1 Pursuant to § 433(h)(3)(A), the third segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount of the full funding limitation under § 433(c)(7)(C)). 2 For months before February 2024, the monthly corporate bond yield curve was determined in accordance with Notice 2007-81, 2007-44 I.R.B. 899. Section 1.430(h)(2)-1(d) generally adopts the methodology for determining the monthly corporate bond yield curve under Notice 2007-81 but includes two enhancements to take into account subsequent changes in the bond market. Those enhancements are described in the preamble to TD 9986 (89 FR 2127). Bulletin No. 2025–19 1425 May 5, 2025 30-YEAR TREASURY SECURITIES INTEREST RATES Section 431 specifies the minimum funding requirements that apply to multi- employer plans pursuant to § 412. Section 431(c)(6)(B) specifies a minimum amount for the full-funding limitation described in § 431(c)(6)(A), based on the plan’s current liability. Section 431(c)(6)(E)(ii)(I) pro- vides that the interest rate used to calculate current liability for this purpose must be no more than 5 percent above and no more than 10 percent below the weighted aver- age of the rates of interest on 30-year Trea- sury securities during the four-year period ending on the last day before the beginning of the plan year. Notice 88-73, 1988-2 C.B. 383, provides guidelines for determining the weighted average interest rate. The rate of interest on 30-year Treasury secu- rities for March 2025 is 4.60 percent. The Service determined this rate as the average of the daily determinations of yield on the 30-year Treasury bond maturing in Febru- ary 2055. For plan years beginning in April 2025, the weighted average of the rates of interest on 30-year Treasury securities and the permissible range of rates used to cal- culate current liability are as follows: Treasury Weighted Average Rates For Plan Years Beginning In30-Year Treasury Weighted AveragePermissible Range 90% to 105% April 20253.983.58 to 4.18 MINIMUM PRESENT VALUE SEGMENT RATES In general, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. Section 1.417(e)-1(d)(3) pro- vides guidelines for determining the min- imum present value segment rates. Pursu- ant to that section, the minimum present value segment rates determined for March 2025 are as follows: Minimum Present Value Segment Rates Month First Segment Second Segment Third Segment March 2025 4.50 5.33 5.86 DRAFTING INFORMATION The principal author of this notice is Tom Morgan of the Office of Associ- ate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). However, other personnel from the IRS participated in the development of this guidance. For further information regarding this notice, contact Mr. Morgan at 202-317-6700 or Tony Montanaro at 626-927-1475 (not toll-free calls). May 5, 2025 1426 Bulletin No. 2025–19 Table 2025-3 Monthly Yield Curve for March 2025 Derived from March 2025 Data MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield 0.54.4620.55.6940.55.8860.55.9580.55.99 1.04.4321.05.7041.05.8861.05.9581.05.99 1.54.4221.55.7141.55.8861.55.9581.55.99 2.04.4222.05.7242.05.8862.05.9582.05.99 2.54.4422.55.7242.55.8962.55.9682.55.99 3.04.4723.05.7343.05.8963.05.9683.05.99 3.54.5223.55.7443.55.8963.55.9683.55.99 4.04.5724.05.7444.05.8964.05.9684.05.99 4.54.6224.55.7544.55.9064.55.9684.55.99 5.04.6725.05.7545.05.9065.05.9685.05.99 5.54.7325.55.7645.55.9065.55.9685.56.00 6.04.7926.05.7646.05.9066.05.9686.06.00 6.54.8526.55.7746.55.9166.55.9686.56.00 7.04.9127.05.7747.05.9167.05.9787.06.00 7.54.9627.55.7847.55.9167.55.9787.56.00 8.05.0228.05.7848.05.9168.05.9788.06.00 8.55.0728.55.7848.55.9168.55.9788.56.00 9.05.1229.05.7949.05.9269.05.9789.06.00 9.55.1629.55.7949.55.9269.55.9789.56.00 10.05.2130.05.8050.05.9270.05.9790.06.00 10.55.2530.55.8050.55.9270.55.9790.56.00 11.05.2931.05.8151.05.9271.05.9791.06.00 11.55.3331.55.8151.55.9271.55.9791.56.00 12.05.3632.05.8252.05.9372.05.9892.06.00 12.55.3932.55.8252.55.9372.55.9892.56.00 13.05.4233.05.8353.05.9373.05.9893.06.00 13.55.4533.55.8353.55.9373.55.9893.56.00 14.05.4834.05.8354.05.9374.05.9894.06.01 14.55.5034.55.8454.55.9374.55.9894.56.01 15.05.5235.05.8455.05.9475.05.9895.06.01 15.55.5535.55.8555.55.9475.55.9895.56.01 16.05.5736.05.8556.05.9476.05.9896.06.01 16.55.5836.55.8556.55.9476.55.9896.56.01 17.05.6037.05.8657.05.9477.05.9897.06.01 17.55.6237.55.8657.55.9477.55.9897.56.01 18.05.6338.05.8658.05.9478.05.9998.06.01 18.55.6538.55.8758.55.9578.55.9998.56.01 19.05.6639.05.8759.05.9579.05.9999.06.01 19.55.6739.55.8759.55.9579.55.9999.56.01 20.05.6840.05.8760.05.9580.05.99100.06.01 Bulletin No. 2025–19 1427 May 5, 2025 Eliminating Unnecessary IRS Internal Revenue Bulletin Guidance Notice 2025-22 This notice starts the process of elimi- nating extraneous and unnecessary Inter- nal Revenue Bulletin (IRB) guidance by identifying and obsoleting nine IRB guid- ance documents. BACKGROUND On February 19, 2025, the President issued Executive Order 14219, Ensuring Lawful Governance and Implementing the President’s ‘Department of Govern- ment Efficiency’ Deregulatory Initiative (Executive Order). The purpose of the Executive Order includes focusing the executive branch’s limited enforcement resources on regulations and other guid- ance documents “squarely authorized by constitutional Federal statutes,” elimi- nating “overbearing and burdensome” regulations and other guidance docu- ments, and “ending Federal overreach.” To further these goals, the Executive Order directs agency heads to coordi- nate with the Department of Government Efficiency (DOGE) Team Leads and the Office of Management and Budget to identify regulations and other guidance documents to be eliminated. Consistent with the Executive Order, the Department of the Treasury (Trea- sury Department) and the Internal Rev- enue Service (IRS), in conjunction with DOGE, have undertaken a review of regu- lations and IRB guidance issued under the Internal Revenue Code (Code) 1 to identify guidance to be eliminated. This review is ongoing. In this notice, nine IRB guidance documents are being obsoleted. These guidance documents no longer provide useful information and clarifying their status as obsolete will streamline admin- istration of the tax laws; reduce the vol- ume of guidance that taxpayers and their advisors need to review for compliance with the tax laws; and increase clarity of the tax law. The Treasury Department and the IRS anticipate revoking or obsoleting hundreds of similar guidance documents in the near future. GUIDANCE TO BE ELIMINATED .01 The following document relates to a listed transaction identified by a notice issued under § 1.6011-4: Notice 2015-73, Listing Notice – Bas- ket Option Contracts, 2015-46 IRB 660 (11-16-2015). Notice 2015-73 identifies as a listed transaction a type of structured financial transaction in which a taxpayer attempts to defer and treat ordinary income and short-term capital gain (earned under a contract denominated as an option con- tract that references a basket of securities) as long-term capital gain. The IRS will no longer defend this listed transaction notice in accordance with Action on Decision 2024-1, 2024-52 IRB 1354 (12-24-2024). .02 The following notice applied to the Troubled Asset Relief Program, which is no longer operative: Notice 2009-49, Guidance Under § 409A(a)(2)(A)(v) on Certain Transactions Pursuant to the Emergency Economic Stabilization Act of 2008, 2009-25 IRB 1093 (6-22-2009). This notice provides that, if the Treasury Department acquires preferred stock, common stock, warrants to purchase common stock or other types of equity of a financial institution or other entity pursuant to the Emergency Eco- nomic Stabilization Act of 2008, Public Law 110-343, 122 Stat. 3765 (October 3, 2008), then such acquisition is not a change in control event with respect to which a payment can be made under a nonqualified deferred compensation plan pursuant to § 409A(a)(2)(A)(v). .03 The following guidance relates to repealed Code provisions: (1) Notice 2018-10, Medical Device Excise Tax Deposit Penalty Relief, 2018-8 IRB 359 (2-20-2018). This notice pro- vides guidance relating to the excise tax on medical devices imposed by § 4191 by providing temporary relief, for the first three calendar quarters of 2018, to medi- cal device manufacturers, producers, and importers from the failure to deposit pen- alties imposed by § 6656, where the tax- payer demonstrates good faith. (2) Announcement 2013-23, Taxable Medical Devices; Correction, 2013-16 IRB 940 (4-15-2013). This document republishes corrections to final regulations (T.D. 9604, 2012-52 IRB 730) that pro- vide guidance on the excise tax imposed on the sale of certain medical devices. (3) Announcement 2013-19, Taxable Medical Devices; Correction, 2013- 14 IRB 760 (4-1-2013). This document republishes corrections to final regulations (T.D. 9604, 2012-52 IRB 730) that pro- vide guidance on the excise tax imposed on the sale of certain medical devices. (4) Notice 2015-16, Excise Tax on High Cost Employer-Sponsored Health Coverage, 2015-10 IRB 732 (3-9- 2015). This notice describes potential approaches with regard to a number of issues under § 4980I, including the defi- nition of applicable coverage, the deter- mination of the cost of applicable cov- erage, and the application of the annual statutory dollar limit to the cost of appli- cable coverage. (5) Notice 2015-52, Section 4980l – Excise Tax on High Cost Employer-Spon- sored Health Coverage, 2015-35 IRB 227 (8-31-2015). This notice addresses addi- tional issues under § 4980l, including the identification of taxpayers who may be liable for the excise tax, employer aggre- gation, exclusion from the cost of appli- cable coverage amounts attributable to the excise tax, age and gender adjustment to the dollar limit, the allocation of the tax among applicable taxpayers, and payment of the applicable tax. .04 The following guidance relates to outdated Code provisions: Notice 2005-64, Foreign Tax Credit and Other Guidance Under Section 965, 2005-36 IRB 471 (9-6-2005). This notice provides guidance on the one-time div- idends received deduction under former § 965 for certain cash dividends from controlled foreign corporations that are invested in the United States, foreign tax credit and related issues, foreign currency translation, the alternative minimum tax, and the credit for prior year minimum tax. .05 The following guidance relates to a topic now squarely addressed by amend- ments made to the Code by Public Law 115-97, 131 Stat. 2054 (December 22, 1 Unless otherwise specified, all “Section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1). May 5, 2025 1428 Bulletin No. 2025–19 2017), commonly known as the Tax Cuts and Jobs Act. Rev. Rul. 91-32, Partnership Effec- tively Connected Income Lookthrough, 199-20 IRB 20 (5-20-1991). This reve- nue ruling addresses the United States tax consequences of the disposition of a foreign partner’s interest in a domestic or foreign partnership that conducts a trade or business through a fixed place of busi- ness or has a permanent establishment in the United States. EFFECT ON OTHER DOCUMENTS Notice 2015-73 is obsoleted. Notice 2009-49 is obsoleted. Notice 2018-10 is obsoleted. Announcement 2013-23 is obsoleted. Announcement 2013-19 is obsoleted. Notice 2015-16 is obsoleted. Notice 2015-52 is obsoleted. Notice 2005-64 is obsoleted. Rev. Rul. 91-32 is obsoleted. DRAFTING INFORMATION This notice was drafted by the Office of the Associate Chief Counsel (Procedure and Administration). For further informa- tion, contact the Office of the Associate Chief Counsel (Procedure and Adminis- tration) at (202) 317-3400 (not a toll-free number). Notice of Intent to Remove 26 CFR 1.6011-18; Waiver of Penalties under Sections 6707A(a), 6707(a), and 6708; Withdrawal of Notice 2024-54 Notice 2025-23 SECTION 1. PURPOSE This notice announces that the Depart- ment of the Treasury (Treasury Depart- ment) and the Internal Revenue Service (IRS) intend to publish a notice of proposed rulemaking (forthcoming NPRM) propos- ing to remove § 1.6011-18 1 (Basis Shifting TOI Regulations) from the Income Tax Regulations (26 CFR part 1). This notice provides immediate relief from (i) pen- alties under § 6707A(a) to participants in transactions identified as transactions of interest in the Basis Shifting TOI Regu- lations that are required to file disclosure statements under § 6011, and (ii) penalties under §§ 6707(a) and 6708 for material advisors to transactions identified as trans- actions of interest in the Basis Shifting TOI Regulations that are required to file disclo- sure statements under § 6111 and maintain lists under § 6112. Lastly, this notice with- draws Notice 2024-54, 2024-28 I.R.B. 24 (Basis Shifting Notice), which describes certain proposed regulations that the Trea- sury Department and the IRS intended to issue addressing partnership related-party basis shifting transactions. SECTION 2. BACKGROUND On February 19, 2025, the President issued Executive Order 14219, Ensuring Lawful Governance and Implementing the President’s “Department of Government Efficiency” Deregulatory Initiative (Execu- tive Order 14219). Executive Order 14219 directs agencies to initiate a review process for the identification and removal of certain regulations and other guidance that meet any of the factors set forth in Executive Order 14219. Pursuant to the review directed by Executive Order 14219, the Treasury Department and the IRS have identified the Basis Shifting TOI Regulations for removal and the Basis Shifting Notice for withdrawal as described in this notice. SECTION 3. FORTHCOMING REMOVAL OF THE BASIS SHIFTING TOI REGULATIONS AND RELATED APPLICABILITY DATES .01 Effective January 14, 2025, the Basis Shifting TOI Regulations identify certain partnership related-party basis adjustment transactions and substantially similar trans- actions as transactions of interest. Taxpay- ers and their material advisors have criti- cized the Basis Shifting TOI Regulations as imposing complex, burdensome, and retroactive disclosure obligations on many ordinary-course and tax-compliant busi- ness activities, creating costly compliance obligations and uncertainty for businesses. .02 Pursuant to Executive Order 14219, the Treasury Department and the IRS have identified the Basis Shifting TOI Regula- tions as appropriate for removal and intend to publish the forthcoming NPRM propos- ing to remove the Basis Shifting TOI Regu- lations from 26 CFR part 1. The forthcom- ing NPRM, when finalized, will obviate the need for participants and material advisors to comply with all of the transaction of interest requirements they would otherwise be required to follow because of the Basis Shifting TOI Regulations. .03 The forthcoming NPRM will have a proposed applicability date that corre- sponds with the date this notice is issued to the public. See § 7805(b)(1)(C). .04 The forthcoming NPRM will pro- pose that taxpayers and material advisors may choose to apply the final regulations retroactively to January 14, 2025, which is the applicability date of the Basis Shifting TOI Regulations. See § 7805(b)(7). .05 Taxpayers and material advisors may rely on this notice until the forthcom- ing NPRM is finalized. SECTION 4. WAIVER OF RELATED DISCLOSURE STATEMENT PENALTIES .01 Participant penalty waiver. Given the Treasury Department and the IRS’s intent to propose the removal of the Basis Shifting TOI Regulations, the IRS will, in the interest of sound tax administration, waive penalties under § 6707A(a) for any failure to file a Form 8886, Reportable Transaction Disclosure Statement, that is otherwise required because of the Basis Shifting TOI Regulations. .02 Material advisor penalty waiver. Given the Treasury Department and the IRS’s intent to propose the removal of the Basis Shifting TOI Regulations, the IRS will, in the interest of sound tax admin- istration, waive penalties under § 6707(a) for any failure to file a Form 8918, Mate- rial Advisor Disclosure Statement, and also will waive penalties under § 6708 for any failure to maintain a list under § 6112, 1 Unless otherwise specified, all “Section” or “§” references are to sections of the Internal Revenue Code or the Income Tax Regulations (26 CFR part 1). Bulletin No. 2025–19 1429 May 5, 2025 that is otherwise required because of the Basis Shifting TOI Regulations. SECTION 5. WITHDRAWAL OF THE BASIS SHIFTING NOTICE The Basis Shifting Notice announced the Treasury Department and the IRS’s intention to publish certain proposed regu- lations addressing partnership related-party basis shifting transactions. Stakeholders have stated that the intended proposed regulations, if finalized, would impose complex, burdensome, and retroactive technical rules on many ordinary-course and tax-compliant business activities, cre- ating costly compliance obligations and uncertainty for businesses. After the review directed by Executive Order 14219, the Basis Shifting Notice is hereby withdrawn. SECTION 6. EFFECT ON OTHER DOCUMENTS Notice 2024-54 is withdrawn. SECTION 7. DRAFTING INFORMATION The principal authors of this notice are Anthony Sacco, Jeremy Milton, and Eliz- abeth Zanet of the Office of the Associate Chief Counsel (Passthroughs, Trusts, and Estates). For further information regard- ing this notice contact Mr. Sacco, Mr. Mil- ton, or Ms. Zanet at (202) 317-5279 (not a toll-free number). Limited Waiver of Penalties for Certain Disclosure Statements for Micro- captive Reportable Transactions Notice 2025-24 SECTION 1. PURPOSE This notice provides relief from penal- ties under section 6707A(a) of the Internal Revenue Code (Code) 1 to participants in micro-captive reportable transactions that fail to file certain disclosure statements required under section 6011 and § 1.6011- 10(h)(2) or § 1.6011-11(h)(2) by April 14, 2025. This relief applies only if such participants file the required disclosure statement with the Office of Tax Shelter Analysis (OTSA) by July 31, 2025. In addition, this notice provides relief from penalties under section 6707(a) for mate- rial advisors to certain micro-captive reportable transactions that are required under section 6111 and § 1.6011-10(h)(3) or § 1.6011-11(h)(3) to file a disclosure statement with OTSA by April 30, 2025, if such material advisors file the disclosure statement with OTSA by July 31, 2025. The relevant penalties will be waived as described in section 3 of this notice. SECTION 2. BACKGROUND On January 14, 2025, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) published final regulations under section 6011 (§§ 1.6011-10 and 1.6011-11) in the Federal Register (TD 10029, 90 FR 3559, 90 FR 3562). Section 1.6011-10(a) iden- tifies transactions that are the same as, or substantially similar to, certain micro-cap- tive transactions as listed transactions, a type of reportable transaction (Micro-cap- tive Listed Transaction). Section 1.6011- 11(a) identifies transactions that are the same as, or substantially similar to, cer- tain other micro-captive transactions as transactions of interest, another type of reportable transaction (Micro-captive Transaction of Interest). Material advisors and certain participants in these reportable transactions are required to file disclosure statements with the IRS and OTSA and are subject to penalties if they fail to timely make such disclosures. In describing the disclosure obligations for participants and material advisors, respectively, §§ 1.6011- 10 and 1.6011-11 reference the provisions of § 1.6011-4(e), for participants, and § 301.6111-3, for material advisors. Generally, § 1.6011-4(e)(1) provides that the disclosure statement for a report- able transaction must be attached to the taxpayer’s tax return for each taxable year for which a taxpayer participates in a reportable transaction. In addition, a dis- closure statement for a reportable trans- action must be attached to each amended return that reflects a taxpayer’s participa- tion in a reportable transaction. A copy of the disclosure statement must be sent to OTSA at the same time that any disclo- sure statement is first filed by the taxpayer pertaining to a particular reportable trans- action. In addition, § 1.6011-4(e)(2)(i) pro- vides that if a transaction becomes a listed transaction or a transaction of interest after the filing of a taxpayer’s tax return (including an amended return) reflecting the taxpayer’s participation in the transac- tion and before the end of the period of limitations for assessment of tax for any taxable year in which the taxpayer par- ticipated in the transaction, then a disclo- sure statement must be filed, regardless of whether the taxpayer participated in the transaction in the year the transaction became a listed transaction or a transac- tion of interest, with OTSA within 90 calendar days after the date on which the transaction became a listed transaction or a transaction of interest (Participant Later Identified Transaction rule). Participants required to disclose these transactions pursuant to section 6011 and § 1.6011-4 who fail to do so may be subject to a pen- alty under section 6707A(a). Section 301.6111-3(e) provides that a material advisor’s disclosure statement for a reportable transaction must be filed with OTSA by the last day of the month that follows the end of the calendar quar- ter in which the advisor became a mate- rial advisor with respect to the reportable transaction or in which the circumstances necessitating an amended disclosure statement occur. Section 301.6111-3(b) (4)(iii) provides that if a transaction that was not a reportable transaction is iden- tified as a listed transaction or a transac- tion of interest in published guidance after the occurrence of the events described in § 301.6111-3(b)(4)(i), the person will be treated as becoming a material advisor on the date the transaction is identified as a listed transaction or a transaction of 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). May 5, 2025 1430 Bulletin No. 2025–19 interest (Material Advisor Later Identi- fied Transaction rule). Material advisors required to disclose these transactions pursuant to section 6111 and § 301.6111-3 who fail to do so may be subject to a pen- alty under section 6707(a). Sections 1.6011-10(a) and 1.6011- 11(a) identified certain micro-captive transactions as Micro-captive Listed Transactions or Micro-captive Transac- tions of Interest effective as of January 14, 2025. Consequently, as described in §§ 1.6011-10(h)(2) and 1.6011-11(h)(2), participants in transactions identified in §§ 1.6011-10(a) and 1.6011-11(a) who filed returns reflecting their participation in such transactions and for which the period of limitations for assessment of tax had not ended on or before January 14, 2025, generally must file initial disclo- sure statements with OTSA by April 14, 2025, as required by the Participant Later Identified Transaction rule. The Partici- pant Later Identified Transaction rule may not apply for taxpayers who have final- ized a settlement agreement, as set forth in §§ 1.6011-10(h)(2) and 1.6011-11(h) (2). Further, the Participant Later Iden- tified Transaction rule may not apply for participants in Micro-captive Transactions of Interest that filed disclosure statements pursuant to Notice 2016-66, 2016-47 I.R.B. 745, as set forth in § 1.6011-11(h) (2). As described in §§ 1.6011-10(h)(3) and 1.6011-11(h)(3), material advisors to transactions identified in §§ 1.6011-10(a) and 1.6011-11(a) who made a tax state- ment on or after January 14, 2019, must file the required disclosure with OTSA by April 30, 2025, as required by the Mate- rial Advisor Later Identified Transaction rule. Transactions for which the Partici- pant Later Identified Transaction rule or Material Advisor Later Identified Trans- action rule apply are referred to as “Later Identified Micro-captive Listed Transac- tions” and “Later Identified Micro-captive Transactions of Interest.” Stakeholders have raised concerns regarding the ability of micro-captive reportable transaction participants to timely comply with their initial filing obligations with respect to Later Identi- fied Micro-captive Listed Transactions and Later Identified Micro-captive Trans- actions of Interest. As further described in section 3 of this notice, the Treasury Department and the IRS are providing a limited waiver of penalties under sections 6707A(a) and 6707(a). SECTION 3. LIMITED WAIVER OF PENALTIES .01 Participant penalty waiver. In light of potential challenges associated with preparing disclosure statements during tax return filing season and in the interest of sound tax administration, the IRS will waive penalties under section 6707A(a) with respect to Later Identified Micro-cap- tive Listed Transaction and Later Identi- fied Micro-captive Transaction of Inter- est disclosure statements completed in accordance with § 1.6011-4(d) and the Instructions to Form 8886, Reportable Transaction Disclosure Statement, if the participant files the required disclosure statement with OTSA by July 31, 2025. This relief is limited to Later Identi- fied Micro-captive Listed Transactions and Later Identified Micro-captive Trans- actions of Interest. This notice does not provide relief from penalties under sec- tion 6707A(a) for participants required to file a copy of their disclosure statements with OTSA at the same time the partici- pant first files a disclosure statement by attaching it to the participant’s tax return pursuant to § 1.6011-4(e)(1). Taxpayers concerned about meeting the due date for such disclosure statements can request an extension of the due date for their tax return to obtain additional time to file such disclosure statements. Disclosures required from participants with respect to Micro-captive Listed Transactions and Micro-captive Transactions of Interest on or after July 31, 2025, remain due as oth- erwise set forth in § 1.6011-4(e). .02 Material advisor penalty waiver. In light of potential challenges associ- ated with preparing disclosure statements during tax return filing season and in the interest of sound tax administration, the IRS will waive penalties under sec- tion 6707(a) with respect to Later Identi- fied Micro-captive Listed Transaction and Later Identified Micro-captive Transac- tion of Interest disclosure statements com- pleted in accordance with § 301.6111-3(d) and the instructions to Form 8918, Mate- rial Advisor Disclosure Statement, if the material advisor files the required disclo- sure statement with OTSA by July 31, 2025. Disclosures required from material advisors with respect to Micro-captive Listed Transactions and Micro-captive Transactions of Interest on or after July 31, 2025, remain due as otherwise set forth in § 301.6111-3(e). This notice does not modify any list maintenance and furnishment obligations of material advisors as set forth in section 6112 and § 301.6112-1. SECTION 4. DRAFTING INFORMATION The principal author of this notice is Allan H. Sakaue of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regard- ing this notice contact Mr. Sakaue at (202) 317-6995 (not a toll-free number). 26 CFR 601.601: Rules and Regulations (Also: Part 1, §§ 25, 143, 6a.103A-1(b)(4), 6a.103A-2(f)(5).) Rev. Proc. 2025-18 SECTION 1. PURPOSE This revenue procedure provides issuers of qualified mortgage bonds, as defined in § 143(a) of the Internal Reve- nue Code 1 , and issuers of mortgage credit certificates, as defined in § 25(c), with (1) the nationwide average purchase price for residences located in the United States, and (2) average area purchase price safe harbors for residences located in statis- tical areas in each state, the District of Columbia, Puerto Rico, the Northern Mar- iana Islands, American Samoa, the Virgin Islands, and Guam. SECTION 2. BACKGROUND .01 Section 103(a) provides that, except as provided in § 103(b), gross 1 Unless otherwise specified, all “section” or “§” references are to sections of the Internal Revenue Code or the Temporary Regulations under Title II of the Omnibus Reconciliation Act of 1980 (26 CFR part 6a). Bulletin No. 2025–19 1431 May 5, 2025 income does not include interest on any State or local bond. Section 103(b)(1) pro- vides that § 103(a) shall not apply to any private activity bond that is not a “quali- fied bond” within the meaning of § 141. Section 141(e) provides, in part, that the term “qualified bond” means any private activity bond if such bond (1) is a quali- fied mortgage bond under § 143, (2) meets the volume cap requirements under § 146, and (3) meets the applicable requirements under § 147. .02 Section 143(a)(1) provides that the term “qualified mortgage bond” means a bond that is issued as part of a qualified mortgage issue. Section 143(a)(2)(A) pro- vides that the term “qualified mortgage issue” means an issue of one or more bonds by a State or political subdivi- sion thereof, but only if: (i) all proceeds of the issue (exclusive of issuance costs and a reasonably required reserve) are to be used to finance owner-occupied res- idences; (ii) the issue meets the require- ments of subsections (c), (d), (e), (f), (g), (h), (i), and (m)(7) of § 143; (iii) the issue does not meet the private business tests of paragraphs (1) and (2) of § 141(b); and (iv) with respect to amounts received more than 10 years after the date of issu- ance, repayments of $250,000 or more of principal on mortgage financing provided by the issue are used by the close of the first semiannual period beginning after the date the prepayment (or complete repay- ment) is received to redeem bonds that are part of the issue. Average Area Purchase Price .03 Section 143(e)(1) provides that an issue of bonds meets the purchase price requirements of § 143(e) if the acquisi- tion cost of each residence financed by the issue does not exceed 90 percent of the average area purchase price applicable to such residence. Section 143(e)(5) pro- vides that, in the case of a targeted area residence (as defined in § 143(j)), § 143(e) (1) shall be applied by substituting 110 percent for 90 percent. .04 Section 143(e)(2) provides that the term “average area purchase price” means, with respect to any residence, the average purchase price of single-family residences (in the statistical area in which the res- idence is located) that were purchased during the most recent 12-month period for which sufficient statistical informa- tion is available. Under §§ 143(e)(3) and (4), respectively, separate determinations of average area purchase price are to be made for new and existing residences, and for two-, three-, and four-family res- idences. .05 Section 143(e)(2) also provides that the determination of the average area pur- chase price shall be made as of the date on which the commitment to provide the financing is made or, if earlier, the date of the purchase of the residence. .06 Section 143(k)(2)(A) provides that the term “statistical area” means (i) a met- ropolitan statistical area (MSA), and (ii) any county (or the portion thereof) that is not within an MSA. Section 143(k)(2)(C) further provides that if sufficient recent statistical information with respect to a county (or portion thereof) is unavailable, the Secretary may substitute another area for which there is sufficient recent statis- tical information for such county (or por- tion thereof). In the case of any portion of a State which is not within a county, § 143(k)(2)(D) provides that the Secretary may designate an area that is the equiva- lent of a county. Section 6a.103A-1(b)(4) (i) (issued under § 103A of the Internal Revenue Code of 1954, the predecessor of § 143) provides that the term “State” includes a possession of the United States and the District of Columbia. .07 Section 6a.103A-2(f)(5)(i) provides that an issuer may rely upon the average area purchase price safe harbors published by the Department of the Treasury (Trea- sury Department) for the statistical area in which a residence is located. Section 6a.103A-2(f)(5)(i) further provides that an issuer may use an average area pur- chase price limitation different from the published safe harbor if the issuer has more accurate and comprehensive data for the statistical area. Qualified Mortgage Credit Certificate Program .08 Section 25(c) permits a State or political subdivision thereof to establish a qualified mortgage credit certificate program. In general, a qualified mortgage credit certificate program is a program under which the issuing authority elects not to issue an amount of private activity bonds that it may otherwise issue during the calendar year under § 146, and in its place, issues mortgage credit certificates to taxpayers in connection with the acqui- sition of their principal residences. Sec- tion 25(a)(1) provides, in general, that the holder of a mortgage credit certificate may claim a federal income tax credit equal to the product of the credit rate specified in the certificate and the interest paid or accrued during the tax year on the remain- ing principal of the indebtedness incurred to acquire the residence. Section 25(c)(2) (A)(iii)(III) generally provides that res- idences acquired in connection with the issuance of mortgage credit certificates must meet the purchase price require- ments of § 143(e). Income Limitations for Qualified Mortgage Bonds and Mortgage Credit Certificates .09 Section 143(f) imposes limitations on the income of mortgagors for whom financing may be provided by qualified mortgage bonds. In addition, § 25(c) (2)(A)(iii)(IV) provides that holders of mortgage credit certificates must meet the income requirement of § 143(f). Generally, under §§ 143(f)(1) and 25(c) (2)(A)(iii)(IV), the income requirement is met only if all owner-financing under a qualified mortgage bond and all mort- gage credit certificates issued under a qualified mortgage credit certificate pro- gram are provided to mortgagors whose family income is 115 percent or less of the applicable median family income. Section 143(f)(5), however, generally provides for an upward adjustment to the percentage limitation in high hous- ing cost areas. High housing cost areas are defined in § 143(f)(5)(C) as any sta- tistical area for which the housing cost/ income ratio is greater than 1.2. .10 Under § 143(f)(5)(D), the hous- ing cost/income ratio with respect to any statistical area is determined by dividing (a) the applicable housing price ratio for such area by (b) the ratio that the area median gross income for such area bears to the median gross income for the United States. The applicable housing price ratio is the new housing price ratio (new hous- ing average area purchase price divided May 5, 2025 1432 Bulletin No. 2025–19 by the new housing average purchase price for the United States) or the exist- ing housing price ratio (existing housing average area purchase price divided by the existing housing average purchase price for the United States), whichever results in the housing cost/income ratio being closer to 1. Average Area and Nationwide Purchase Price Limitations .11 Average area purchase price safe harbors for each state, the District of Columbia, Puerto Rico, the Northern Mar- iana Islands, American Samoa, the Virgin Islands, and Guam were last published in Rev. Proc. 2024-21, 2024-19 I.R.B. 1054. .12 The nationwide average purchase price was last published in section 4.02 of Rev. Proc. 2024-21. Guidance with respect to the United States and area median gross income figures that are used in computing the housing cost/income ratio described in § 143(f)(5) was published in Rev. Proc. 2021-19, 2021-15 I.R.B. 1008. .13 This revenue procedure uses Fed- eral Housing Administration (FHA) loan limits for a given statistical area to calcu- late the average area purchase price safe harbor for that area. FHA sets limits on the dollar value of loans it will insure based on median home prices and conforming loan limits established by the Federal Home Loan Mortgage Corporation. In particular, FHA sets an area’s loan limit at 95 per- cent of the median home sales price for the area, subject to certain floors and caps measured against conforming loan limits. .14 To calculate the average area pur- chase price safe harbors in this reve- nue procedure, the FHA loan limits are adjusted to take into account the differ- ences between average and median pur- chase prices. Because FHA loan limits do not differentiate between new and existing residences, this revenue procedure con- tains a single average area purchase price safe harbor for both new and existing res- idences in a statistical area. .15 The average area purchase price safe harbors listed in section 4.01 of this revenue procedure are based on FHA loan limits released November 26, 2024. FHA loan limits are available for statis- tical areas in each state, the District of Columbia, Puerto Rico, the Northern Mar- iana Islands, American Samoa, the Virgin Islands, and Guam. See section 3.03 of this revenue procedure with respect to FHA loan limits revised after November 26, 2024. .16 OMB Bulletin No. 03-04, dated and effective June 6, 2003, revised the definitions of the nation’s metropolitan areas and recognized 49 new MSAs. The OMB bulletin no longer includes primary MSAs. SECTION 3. APPLICATION Average Area Purchase Price Safe Harbors .01 Average area purchase price safe harbors for statistical areas in each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam are set forth in section 4.01 of this revenue procedure. Average area purchase price safe harbors are provided for single-fam- ily and two to four-family residences. For each type of residence, section 4.01 of this revenue procedure contains a single safe harbor that may be used for both new and existing residences. Issuers of qualified mortgage bonds and issuers of mortgage credit certificates may rely on these safe harbors to satisfy the requirements of §§ 143(e) and (f). Section 4.01 of this reve- nue procedure provides safe harbors for MSAs and for certain counties and county equivalents. If no purchase price safe har- bor is available for a statistical area, the safe harbor for “ALL OTHER AREAS” may be used for that statistical area. .02 If a residence is in an MSA, the safe harbor applicable to it is the limitation of that MSA. If an MSA falls in more than one state, the MSA is listed in section 4.01 of this revenue procedure under each state. .03 If the FHA revises the FHA loan limit for any statistical area after Novem- ber 26, 2024, an issuer of qualified mort- gage bonds or mortgage credit certificates may use the revised FHA loan limit for that statistical area to compute (as provided in the next sentence) a revised average area purchase price safe harbor for the statisti- cal area provided that the issuer maintains records evidencing the revised FHA loan limit. The revised average area purchase price safe harbor for that statistical area is computed by dividing the revised FHA loan limit by 0.867. .04 If, pursuant to § 6a.103A-2(f)(5)(i), an issuer uses more accurate and compre- hensive data to determine the average area purchase price for a statistical area, the issuer must make separate average area purchase price determinations for new and existing residences. Moreover, when computing the average area purchase price for a statistical area that is an MSA, as defined in OMB Bulletin No. 23-01, the issuer must make the computation for the entire applicable MSA. When computing the average area purchase price for a sta- tistical area that is not an MSA, the issuer must make the computation for the entire statistical area and may not combine sta- tistical areas. Thus, for example, the issuer may not combine two or more counties. .05 If an issuer receives a ruling per- mitting it to rely on an average area pur- chase price limitation that is higher than the applicable safe harbor in this revenue procedure, the issuer may rely on that higher limitation for the purpose of satis- fying the requirements of §§ 143(e) and (f) for bonds sold, and mortgage credit certificates issued, not more than 30 months following the termination date of the 12-month period used by the issuer to compute the limitation. Nationwide Average Purchase Price .06 Section 4.02 of this revenue pro- cedure sets forth a single nationwide average purchase price for purposes of computing the housing cost/income ratio under § 143(f)(5). .07 Issuers must use the nationwide average purchase price set forth in sec- tion 4.02 of this revenue procedure when computing the housing cost/income ratio under § 143(f)(5) regardless of whether they are relying on the average area pur- chase price safe harbors contained in this revenue procedure or using more accu- rate and comprehensive data to determine average area purchase prices for new and existing residences for a statistical area that are different from the published safe harbors in this revenue procedure. .08 If, pursuant to section 6.02 of this revenue procedure, an issuer relies on the average area purchase price safe harbors contained in Rev. Proc. 2024-21, the issuer Bulletin No. 2025–19 1433 May 5, 2025 must use the nationwide average purchase price set forth in section 4.02 of Rev. Proc. 2024-21 in computing the housing cost/ income ratio under § 143(f)(5). Likewise, if, pursuant to section 6.04 of this revenue procedure, an issuer relies on the nation- wide average purchase price published in Rev. Proc. 2024-21, the issuer must use the average area purchase price safe har- bors set forth in section 4.01 of Rev. Proc. 2024-21 in computing the housing cost/ income ratio under § 143(f)(5). SECTION 4. AVERAGE AREA AND NATIONWIDE AVERAGE PURCHASE PRICES .01 Average area purchase prices for single-family and two to four-family res- idences in MSAs, and for certain coun- ties and county equivalents are set forth below. The safe harbor for “ALL OTHER AREAS” (found at the end of the table below) may be used for a statistical area that is not listed below. 2025 Average Area Purchase Prices for Mortgage Revenue Bonds County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit ALEUTIANS WESTAK675,212864,3891,044,8571,298,515 HOONAH-ANGOON CAK604,905774,357936,0221,163,265 JUNEAU CITY ANDAK638,068816,864987,3541,227,055 KODIAK ISLAND BAK624,803799,849966,8211,201,562 SITKA CITY ANDAK676,538866,0611,046,8751,301,053 SKAGWAY MUNICIPAK604,905774,357936,0221,163,265 COCONINOAZ650,007832,1481,005,8681,250,010 MARICOPAAZ630,109806,655975,0691,211,771 PINALAZ630,109806,655975,0691,211,771 ALAMEDACA1,395,4681,786,7712,159,6452,684,092 CONTRA COSTACA1,395,4681,786,7712,159,6452,684,092 EL DORADOCA880,8261,127,6221,363,0551,693,941 LOS ANGELESCA1,395,4681,786,7712,159,6452,684,092 MARINCA1,395,4681,786,7712,159,6452,684,092 MENDOCINOCA630,109806,655975,0691,211,771 MONOCA895,4181,146,3091,385,6061,721,972 MONTEREYCA1,119,6051,433,3041,732,5262,153,157 NAPACA1,173,9931,502,9191,816,6752,257,723 NEVADACA742,866951,0181,149,5381,428,632 ORANGECA1,395,4681,786,7712,159,6452,684,092 PLACERCA880,8261,127,6221,363,0551,693,941 RIVERSIDECA776,029993,4671,200,8701,492,364 SACRAMENTOCA880,8261,127,6221,363,0551,693,941 SAN BENITOCA1,395,4681,786,7712,159,6452,684,092 SAN BERNARDINOCA776,029993,4671,200,8701,492,364 SAN DIEGOCA1,242,9731,591,2201,923,4342,390,378 SAN FRANCISCOCA1,395,4681,786,7712,159,6452,684,092 SAN JOAQUINCA782,6621,001,9461,211,1361,505,168 SAN LUIS OBISPOCA1,115,6251,428,2281,726,3552,145,486 SAN MATEOCA1,395,4681,786,7712,159,6452,684,092 SANTA BARBARACA1,053,2771,348,4051,629,9212,025,578 SANTA CLARACA1,395,4681,786,7712,159,6452,684,092 SANTA CRUZCA1,395,4681,786,7712,159,6452,684,092 May 5, 2025 1434 Bulletin No. 2025–19 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit SOLANOCA790,6211,012,1541,223,4211,520,452 SONOMACA1,034,7061,324,6421,601,1411,989,876 STANISLAUSCA618,170791,371956,5551,188,816 VENTURACA1,173,9931,502,9191,816,6752,257,723 YOLOCA880,8261,127,6221,363,0551,693,941 ADAMSCO961,7461,231,2071,488,2691,849,551 ARAPAHOECO961,7461,231,2071,488,2691,849,551 BOULDERCO994,9091,273,6571,539,6001,913,340 BROOMFIELDCO961,7461,231,2071,488,2691,849,551 CHAFFEECO769,396984,9891,190,6041,479,618 CLEAR CREEKCO961,7461,231,2071,488,2691,849,551 DENVERCO961,7461,231,2071,488,2691,849,551 DOUGLASCO961,7461,231,2071,488,2691,849,551 EAGLECO1,395,4681,786,7712,159,6452,684,092 EL PASOCO615,517787,968952,4601,183,682 ELBERTCO961,7461,231,2071,488,2691,849,551 GARFIELDCO1,395,4681,786,7712,159,6452,684,092 GILPINCO961,7461,231,2071,488,2691,849,551 GRANDCO1,008,1751,290,6711,560,0751,938,833 GUNNISONCO862,2551,103,8591,334,2741,658,182 JEFFERSONCO961,7461,231,2071,488,2691,849,551 LA PLATACO795,9271,018,9021,231,6691,530,661 LARIMERCO729,600934,0041,129,0061,403,082 MONTROSECO866,2341,108,9351,340,4461,665,853 OURAYCO866,2341,108,9351,340,4461,665,853 PARKCO961,7461,231,2071,488,2691,849,551 PITKINCO1,395,4681,786,7712,159,6452,684,092 ROUTTCO1,167,3601,494,4401,806,4672,244,977 SAN MIGUELCO1,205,8301,543,6951,865,9882,318,975 SUMMITCO1,231,0341,575,9361,904,9772,367,423 TELLERCO615,517787,968952,4601,183,682 WELDCO650,007832,1481,005,8681,250,010 FAIRFIELDCT981,6441,256,7001,519,0681,887,790 DISTRICT OF COLDC1,395,4681,786,7712,159,6452,684,092 NEW CASTLEDE685,824878,0001,061,2941,318,932 BAKERFL669,906857,5831,036,6671,288,307 BROWARDFL754,804966,3021,167,9951,451,587 CLAYFL669,906857,5831,036,6671,288,307 COLLIERFL882,1531,129,2941,365,0731,696,479 DUVALFL669,906857,5831,036,6671,288,307 MANATEEFL631,436808,328977,0871,214,308 MARTINFL688,477881,3451,065,3891,324,008 MIAMI-DADEFL754,804966,3021,167,9951,451,587 Bulletin No. 2025–19 1435 May 5, 2025 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit MONROEFL1,115,6251,428,2281,726,3552,145,486 NASSAUFL669,906857,5831,036,6671,288,307 OKALOOSAFL696,436891,5541,077,6741,339,292 PALM BEACHFL754,804966,3021,167,9951,451,587 SARASOTAFL631,436808,328977,0871,214,308 ST. JOHNSFL669,906857,5831,036,6671,288,307 ST. LUCIEFL688,477881,3451,065,3891,324,008 WALTONFL696,436891,5541,077,6741,339,292 BARROWGA794,6011,017,2301,229,5931,528,123 BARTOWGA794,6011,017,2301,229,5931,528,123 BUTTSGA794,6011,017,2301,229,5931,528,123 CARROLLGA794,6011,017,2301,229,5931,528,123 CHEROKEEGA794,6011,017,2301,229,5931,528,123 CLARKEGA696,436891,5541,077,6741,339,292 CLAYTONGA794,6011,017,2301,229,5931,528,123 COBBGA794,6011,017,2301,229,5931,528,123 COWETAGA794,6011,017,2301,229,5931,528,123 DAWSONGA794,6011,017,2301,229,5931,528,123 DEKALBGA794,6011,017,2301,229,5931,528,123 DOUGLASGA794,6011,017,2301,229,5931,528,123 FAYETTEGA794,6011,017,2301,229,5931,528,123 FORSYTHGA794,6011,017,2301,229,5931,528,123 FULTONGA794,6011,017,2301,229,5931,528,123 GREENEGA640,722820,209991,4491,232,188 GWINNETTGA794,6011,017,2301,229,5931,528,123 HARALSONGA794,6011,017,2301,229,5931,528,123 HEARDGA794,6011,017,2301,229,5931,528,123 HENRYGA794,6011,017,2301,229,5931,528,123 JASPERGA794,6011,017,2301,229,5931,528,123 LAMARGA794,6011,017,2301,229,5931,528,123 MADISONGA696,436891,5541,077,6741,339,292 MERIWETHERGA794,6011,017,2301,229,5931,528,123 MORGANGA794,6011,017,2301,229,5931,528,123 NEWTONGA794,6011,017,2301,229,5931,528,123 OCONEEGA696,436891,5541,077,6741,339,292 OGLETHORPEGA696,436891,5541,077,6741,339,292 PAULDINGGA794,6011,017,2301,229,5931,528,123 PICKENSGA794,6011,017,2301,229,5931,528,123 PIKEGA794,6011,017,2301,229,5931,528,123 ROCKDALEGA794,6011,017,2301,229,5931,528,123 SPALDINGGA794,6011,017,2301,229,5931,528,123 WALTONGA794,6011,017,2301,229,5931,528,123 GUAMGU650,007832,1481,005,8681,250,010 May 5, 2025 1436 Bulletin No. 2025–19 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit HAWAIIHI659,293844,0291,020,2291,267,889 HONOLULUHI899,3981,151,3841,391,7771,729,643 KALAWAOHI1,268,1781,623,5191,962,4802,438,883 KAUAIHI1,281,4431,640,4761,982,9552,464,376 MAUIHI1,268,1781,623,5191,962,4802,438,883 ADAID676,538866,0611,046,8751,301,053 BLAINEID875,5201,120,8161,354,8071,683,733 BOISEID676,538866,0611,046,8751,301,053 CAMASID875,5201,120,8161,354,8071,683,733 CANYONID676,538866,0611,046,8751,301,053 GEMID676,538866,0611,046,8751,301,053 KOOTENAIID660,620845,7021,022,2481,270,427 OWYHEEID676,538866,0611,046,8751,301,053 TETONID1,395,4681,786,7712,159,6452,684,092 VALLEYID661,946847,4321,024,3241,272,965 BARNSTABLEMA921,9491,180,2801,426,6711,773,015 BRISTOLMA848,9891,086,8451,313,7421,632,689 DUKESMA1,395,4681,786,7712,159,6452,684,092 ESSEXMA1,054,6041,350,0771,631,9402,028,115 MIDDLESEXMA1,054,6041,350,0771,631,9402,028,115 NANTUCKETMA1,395,4681,786,7712,159,6452,684,092 NORFOLKMA1,054,6041,350,0771,631,9402,028,115 PLYMOUTHMA1,054,6041,350,0771,631,9402,028,115 SUFFOLKMA1,054,6041,350,0771,631,9402,028,115 ANNE ARUNDELMD843,6831,080,0391,305,5521,622,481 BALTIMOREMD843,6831,080,0391,305,5521,622,481 BALTIMORE CITYMD843,6831,080,0391,305,5521,622,481 CALVERTMD1,395,4681,786,7712,159,6452,684,092 CARROLLMD843,6831,080,0391,305,5521,622,481 CECILMD685,824878,0001,061,2941,318,932 CHARLESMD1,395,4681,786,7712,159,6452,684,092 FREDERICKMD1,395,4681,786,7712,159,6452,684,092 HARFORDMD843,6831,080,0391,305,5521,622,481 HOWARDMD843,6831,080,0391,305,5521,622,481 MONTGOMERYMD1,395,4681,786,7712,159,6452,684,092 PRINCE GEORGE'SMD1,395,4681,786,7712,159,6452,684,092 QUEEN ANNE'SMD843,6831,080,0391,305,5521,622,481 CUMBERLANDME692,457886,4791,071,5611,331,679 SAGADAHOCME692,457886,4791,071,5611,331,679 YORKME692,457886,4791,071,5611,331,679 ANOKAMN610,211781,162944,2701,173,474 CARVERMN610,211781,162944,2701,173,474 CHISAGOMN610,211781,162944,2701,173,474 Bulletin No. 2025–19 1437 May 5, 2025 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit DAKOTAMN610,211781,162944,2701,173,474 HENNEPINMN610,211781,162944,2701,173,474 ISANTIMN610,211781,162944,2701,173,474 LE SUEURMN610,211781,162944,2701,173,474 MILLE LACSMN610,211781,162944,2701,173,474 RAMSEYMN610,211781,162944,2701,173,474 SCOTTMN610,211781,162944,2701,173,474 SHERBURNEMN610,211781,162944,2701,173,474 WASHINGTONMN610,211781,162944,2701,173,474 WRIGHTMN610,211781,162944,2701,173,474 NORTHERN ISLANDMP604,905774,357936,0221,163,265 SAIPANMP610,211781,162944,2701,173,474 TINIANMP614,191786,296950,4411,181,145 CARBONMT870,2141,114,0101,346,6171,673,524 FLATHEADMT660,620845,7021,022,2481,270,427 GALLATINMT829,0911,061,4101,283,0001,594,450 MISSOULAMT646,028827,015999,6961,242,397 PARKMT650,007832,1481,005,8681,250,010 STILLWATERMT870,2141,114,0101,346,6171,673,524 YELLOWSTONEMT870,2141,114,0101,346,6171,673,524 CAMDENNC874,1941,119,1431,352,7881,681,195 CHATHAMNC729,600934,0041,129,0061,403,082 CURRITUCKNC874,1941,119,1431,352,7881,681,195 DARENC765,417979,8561,184,4321,472,004 DURHAMNC729,600934,0041,129,0061,403,082 FRANKLINNC611,538782,893946,2881,176,069 GATESNC874,1941,119,1431,352,7881,681,195 GRANVILLENC729,600934,0041,129,0061,403,082 JOHNSTONNC611,538782,893946,2881,176,069 ORANGENC729,600934,0041,129,0061,403,082 PASQUOTANKNC928,5821,188,7581,436,9371,785,761 PERQUIMANSNC928,5821,188,7581,436,9371,785,761 PERSONNC729,600934,0041,129,0061,403,082 WAKENC611,538782,893946,2881,176,069 DAWSONNE696,436891,5541,077,6741,339,292 GOSPERNE696,436891,5541,077,6741,339,292 HILLSBOROUGHNH630,109806,655975,0691,211,771 ROCKINGHAMNH1,054,6041,350,0771,631,9402,028,115 STRAFFORDNH1,054,6041,350,0771,631,9402,028,115 BERGENNJ1,395,4681,786,7712,159,6452,684,092 BURLINGTONNJ685,824878,0001,061,2941,318,932 CAMDENNJ685,824878,0001,061,2941,318,932 CAPE MAYNJ769,396984,9891,190,6041,479,618 May 5, 2025 1438 Bulletin No. 2025–19 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit ESSEXNJ1,395,4681,786,7712,159,6452,684,092 GLOUCESTERNJ685,824878,0001,061,2941,318,932 HUDSONNJ1,395,4681,786,7712,159,6452,684,092 HUNTERDONNJ1,395,4681,786,7712,159,6452,684,092 MIDDLESEXNJ1,395,4681,786,7712,159,6452,684,092 MONMOUTHNJ1,395,4681,786,7712,159,6452,684,092 MORRISNJ1,395,4681,786,7712,159,6452,684,092 OCEANNJ1,395,4681,786,7712,159,6452,684,092 PASSAICNJ1,395,4681,786,7712,159,6452,684,092 SALEMNJ685,824878,0001,061,2941,318,932 SOMERSETNJ1,395,4681,786,7712,159,6452,684,092 SUSSEXNJ1,395,4681,786,7712,159,6452,684,092 UNIONNJ1,395,4681,786,7712,159,6452,684,092 LOS ALAMOSNM798,5811,022,3051,235,7641,535,736 SANTA FENM624,803799,849966,8211,201,562 CARSON CITYNV663,273849,1051,026,4001,275,560 DOUGLASNV829,0911,061,4101,283,0001,594,450 STOREYNV729,600934,0041,129,0061,403,082 WASHOENV729,600934,0041,129,0061,403,082 BRONXNY1,395,4681,786,7712,159,6452,684,092 KINGSNY1,395,4681,786,7712,159,6452,684,092 NASSAUNY1,395,4681,786,7712,159,6452,684,092 NEW YORKNY1,395,4681,786,7712,159,6452,684,092 PUTNAMNY1,395,4681,786,7712,159,6452,684,092 QUEENSNY1,395,4681,786,7712,159,6452,684,092 RICHMONDNY1,395,4681,786,7712,159,6452,684,092 ROCKLANDNY1,395,4681,786,7712,159,6452,684,092 SUFFOLKNY1,395,4681,786,7712,159,6452,684,092 WESTCHESTERNY1,395,4681,786,7712,159,6452,684,092 DELAWAREOH656,640840,6261,016,1341,262,756 FAIRFIELDOH656,640840,6261,016,1341,262,756 FRANKLINOH656,640840,6261,016,1341,262,756 HOCKINGOH656,640840,6261,016,1341,262,756 LICKINGOH656,640840,6261,016,1341,262,756 MADISONOH656,640840,6261,016,1341,262,756 MORROWOH656,640840,6261,016,1341,262,756 PERRYOH656,640840,6261,016,1341,262,756 PICKAWAYOH656,640840,6261,016,1341,262,756 UNIONOH656,640840,6261,016,1341,262,756 BENTONOR689,804883,0761,067,4081,326,546 CLACKAMASOR802,5601,027,4381,241,9351,543,407 CLATSOPOR647,354828,7451,001,7151,244,934 COLUMBIAOR802,5601,027,4381,241,9351,543,407 Bulletin No. 2025–19 1439 May 5, 2025 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit DESCHUTESOR822,4581,052,8741,272,7341,581,646 HOOD RIVEROR879,5001,125,9491,360,9781,691,346 MULTNOMAHOR802,5601,027,4381,241,9351,543,407 WASHINGTONOR802,5601,027,4381,241,9351,543,407 YAMHILLOR802,5601,027,4381,241,9351,543,407 BUCKSPA685,824878,0001,061,2941,318,932 CHESTERPA685,824878,0001,061,2941,318,932 DELAWAREPA685,824878,0001,061,2941,318,932 MONTGOMERYPA685,824878,0001,061,2941,318,932 PHILADELPHIAPA685,824878,0001,061,2941,318,932 PIKEPA1,395,4681,786,7712,159,6452,684,092 AGUAS BUENASPR795,9271,018,9021,231,6691,530,661 AIBONITOPR795,9271,018,9021,231,6691,530,661 BARCELONETAPR795,9271,018,9021,231,6691,530,661 BARRANQUITASPR795,9271,018,9021,231,6691,530,661 BAYAMONPR795,9271,018,9021,231,6691,530,661 CAGUASPR795,9271,018,9021,231,6691,530,661 CANOVANASPR795,9271,018,9021,231,6691,530,661 CAROLINAPR795,9271,018,9021,231,6691,530,661 CATANOPR795,9271,018,9021,231,6691,530,661 CAYEYPR795,9271,018,9021,231,6691,530,661 CEIBAPR795,9271,018,9021,231,6691,530,661 CIALESPR795,9271,018,9021,231,6691,530,661 CIDRAPR795,9271,018,9021,231,6691,530,661 COMERIOPR795,9271,018,9021,231,6691,530,661 COROZALPR795,9271,018,9021,231,6691,530,661 CULEBRAPR614,191786,296950,4411,181,145 DORADOPR795,9271,018,9021,231,6691,530,661 FAJARDOPR795,9271,018,9021,231,6691,530,661 FLORIDAPR795,9271,018,9021,231,6691,530,661 GUAYNABOPR795,9271,018,9021,231,6691,530,661 GURABOPR795,9271,018,9021,231,6691,530,661 HUMACAOPR795,9271,018,9021,231,6691,530,661 JUNCOSPR795,9271,018,9021,231,6691,530,661 LAS PIEDRASPR795,9271,018,9021,231,6691,530,661 LOIZAPR795,9271,018,9021,231,6691,530,661 LUQUILLOPR795,9271,018,9021,231,6691,530,661 MANATIPR795,9271,018,9021,231,6691,530,661 MAUNABOPR795,9271,018,9021,231,6691,530,661 MOROVISPR795,9271,018,9021,231,6691,530,661 NAGUABOPR795,9271,018,9021,231,6691,530,661 NARANJITOPR795,9271,018,9021,231,6691,530,661 OROCOVISPR795,9271,018,9021,231,6691,530,661 May 5, 2025 1440 Bulletin No. 2025–19 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit RIO GRANDEPR795,9271,018,9021,231,6691,530,661 SAN JUANPR795,9271,018,9021,231,6691,530,661 SAN LORENZOPR795,9271,018,9021,231,6691,530,661 TOA ALTAPR795,9271,018,9021,231,6691,530,661 TOA BAJAPR795,9271,018,9021,231,6691,530,661 TRUJILLO ALTOPR795,9271,018,9021,231,6691,530,661 VEGA ALTAPR795,9271,018,9021,231,6691,530,661 VEGA BAJAPR795,9271,018,9021,231,6691,530,661 YABUCOAPR795,9271,018,9021,231,6691,530,661 BRISTOLRI848,9891,086,8451,313,7421,632,689 KENTRI848,9891,086,8451,313,7421,632,689 NEWPORTRI848,9891,086,8451,313,7421,632,689 PROVIDENCERI848,9891,086,8451,313,7421,632,689 WASHINGTONRI848,9891,086,8451,313,7421,632,689 BEAUFORTSC703,069900,0321,087,9411,352,096 BERKELEYSC729,600934,0041,129,0061,403,082 CHARLESTONSC729,600934,0041,129,0061,403,082 DORCHESTERSC729,600934,0041,129,0061,403,082 JASPERSC703,069900,0321,087,9411,352,096 LAWRENCESD624,803799,849966,8211,201,562 CANNONTN1,140,8291,460,4691,765,4022,193,934 CHEATHAMTN1,140,8291,460,4691,765,4022,193,934 DAVIDSONTN1,140,8291,460,4691,765,4022,193,934 DICKSONTN1,140,8291,460,4691,765,4022,193,934 MACONTN1,140,8291,460,4691,765,4022,193,934 MAURYTN1,140,8291,460,4691,765,4022,193,934 ROBERTSONTN1,140,8291,460,4691,765,4022,193,934 RUTHERFORDTN1,140,8291,460,4691,765,4022,193,934 SMITHTN1,140,8291,460,4691,765,4022,193,934 SUMNERTN1,140,8291,460,4691,765,4022,193,934 TROUSDALETN1,140,8291,460,4691,765,4022,193,934 WILLIAMSONTN1,140,8291,460,4691,765,4022,193,934 WILSONTN1,140,8291,460,4691,765,4022,193,934 ATASCOSATX643,375823,612995,6011,237,263 BANDERATX643,375823,612995,6011,237,263 BASTROPTX659,293844,0291,020,2291,267,889 BEXARTX643,375823,612995,6011,237,263 CALDWELLTX659,293844,0291,020,2291,267,889 COLLINTX650,007832,1481,005,8681,250,010 COMALTX643,375823,612995,6011,237,263 DALLASTX650,007832,1481,005,8681,250,010 DENTONTX650,007832,1481,005,8681,250,010 ELLISTX650,007832,1481,005,8681,250,010 Bulletin No. 2025–19 1441 May 5, 2025 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit GUADALUPETX643,375823,612995,6011,237,263 HAYSTX659,293844,0291,020,2291,267,889 HUNTTX650,007832,1481,005,8681,250,010 JOHNSONTX650,007832,1481,005,8681,250,010 KAUFMANTX650,007832,1481,005,8681,250,010 KENDALLTX643,375823,612995,6011,237,263 MEDINATX643,375823,612995,6011,237,263 PARKERTX650,007832,1481,005,8681,250,010 ROCKWALLTX650,007832,1481,005,8681,250,010 TARRANTTX650,007832,1481,005,8681,250,010 TRAVISTX659,293844,0291,020,2291,267,889 WILLIAMSONTX659,293844,0291,020,2291,267,889 WILSONTX643,375823,612995,6011,237,263 WISETX650,007832,1481,005,8681,250,010 BOX ELDERUT858,2751,098,7261,328,1611,650,569 DAVISUT858,2751,098,7261,328,1611,650,569 GRANDUT818,4791,047,7981,266,5631,574,033 JUABUT693,783888,1511,073,5791,334,217 MORGANUT858,2751,098,7261,328,1611,650,569 RICHUT668,579855,9101,034,5901,285,769 SALT LAKEUT725,620928,9281,122,8341,395,468 SUMMITUT1,342,4641,718,6262,077,4282,581,746 TOOELEUT725,620928,9281,122,8341,395,468 UTAHUT693,783888,1511,073,5791,334,217 WASATCHUT1,342,4641,718,6262,077,4282,581,746 WASHINGTONUT684,498876,2701,059,2181,316,337 WAYNEUT1,150,1151,472,3501,779,7632,211,813 WEBERUT858,2751,098,7261,328,1611,650,569 ALBEMARLEVA683,171874,5971,057,1421,313,799 ALEXANDRIA CITYVA1,395,4681,786,7712,159,6452,684,092 AMELIAVA777,356995,1401,202,8891,494,959 ARLINGTONVA1,395,4681,786,7712,159,6452,684,092 CHARLES CITYVA777,356995,1401,202,8891,494,959 CHARLOTTESVILLEVA683,171874,5971,057,1421,313,799 CHESAPEAKE CITYVA874,1941,119,1431,352,7881,681,195 CHESTERFIELDVA777,356995,1401,202,8891,494,959 CLARKEVA1,395,4681,786,7712,159,6452,684,092 COLONIAL HEIGHTVA777,356995,1401,202,8891,494,959 CULPEPERVA1,395,4681,786,7712,159,6452,684,092 DINWIDDIEVA777,356995,1401,202,8891,494,959 FAIRFAXVA1,395,4681,786,7712,159,6452,684,092 FAIRFAX CITYVA1,395,4681,786,7712,159,6452,684,092 FALLS CHURCH CIVA1,395,4681,786,7712,159,6452,684,092 May 5, 2025 1442 Bulletin No. 2025–19 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit FAUQUIERVA1,395,4681,786,7712,159,6452,684,092 FLUVANNAVA683,171874,5971,057,1421,313,799 FRANKLIN CITYVA874,1941,119,1431,352,7881,681,195 FREDERICKSBURGVA1,395,4681,786,7712,159,6452,684,092 GLOUCESTERVA874,1941,119,1431,352,7881,681,195 GOOCHLANDVA777,356995,1401,202,8891,494,959 GREENEVA683,171874,5971,057,1421,313,799 HAMPTON CITYVA874,1941,119,1431,352,7881,681,195 HANOVERVA777,356995,1401,202,8891,494,959 HENRICOVA777,356995,1401,202,8891,494,959 HOPEWELL CITYVA777,356995,1401,202,8891,494,959 ISLE OF WIGHTVA874,1941,119,1431,352,7881,681,195 JAMES CITYVA874,1941,119,1431,352,7881,681,195 KING AND QUEENVA777,356995,1401,202,8891,494,959 KING WILLIAMVA777,356995,1401,202,8891,494,959 LOUDOUNVA1,395,4681,786,7712,159,6452,684,092 MADISONVA1,395,4681,786,7712,159,6452,684,092 MANASSAS CITYVA1,395,4681,786,7712,159,6452,684,092 MANASSAS PARK CVA1,395,4681,786,7712,159,6452,684,092 MATHEWSVA874,1941,119,1431,352,7881,681,195 NELSONVA683,171874,5971,057,1421,313,799 NEW KENTVA777,356995,1401,202,8891,494,959 NEWPORT NEWS CIVA874,1941,119,1431,352,7881,681,195 NORFOLK CITYVA874,1941,119,1431,352,7881,681,195 PETERSBURG CITYVA777,356995,1401,202,8891,494,959 POQUOSON CITYVA874,1941,119,1431,352,7881,681,195 PORTSMOUTH CITYVA874,1941,119,1431,352,7881,681,195 POWHATANVA777,356995,1401,202,8891,494,959 PRINCE GEORGEVA777,356995,1401,202,8891,494,959 PRINCE WILLIAMVA1,395,4681,786,7712,159,6452,684,092 RAPPAHANNOCKVA1,395,4681,786,7712,159,6452,684,092 RICHMOND CITYVA777,356995,1401,202,8891,494,959 SOUTHAMPTONVA874,1941,119,1431,352,7881,681,195 SPOTSYLVANIAVA1,395,4681,786,7712,159,6452,684,092 STAFFORDVA1,395,4681,786,7712,159,6452,684,092 SUFFOLK CITYVA874,1941,119,1431,352,7881,681,195 SUSSEXVA777,356995,1401,202,8891,494,959 VIRGINIA BEACHVA874,1941,119,1431,352,7881,681,195 WARRENVA1,395,4681,786,7712,159,6452,684,092 WILLIAMSBURG CIVA874,1941,119,1431,352,7881,681,195 YORKVA874,1941,119,1431,352,7881,681,195 ST. JOHN ISLANDVI1,285,4231,645,6091,989,1262,472,047 ST. THOMAS ISLAVI776,029993,4671,200,8701,492,364 Bulletin No. 2025–19 1443 May 5, 2025 County NameState One-Unit Limit Two-Unit Limit Three-Unit Limit Four-Unit Limit CHITTENDENVT663,273849,1051,026,4001,275,560 FRANKLINVT663,273849,1051,026,4001,275,560 GRAND ISLEVT663,273849,1051,026,4001,275,560 CHELANWA630,109806,655975,0691,211,771 CLARKWA802,5601,027,4381,241,9351,543,407 DOUGLASWA630,109806,655975,0691,211,771 ISLANDWA696,436891,5541,077,6741,339,292 KINGWA1,196,5441,531,8141,851,6272,301,095 KITSAPWA663,273849,1051,026,4001,275,560 PIERCEWA1,196,5441,531,8141,851,6272,301,095 SKAGITWA650,007832,1481,005,8681,250,010 SKAMANIAWA802,5601,027,4381,241,9351,543,407 SNOHOMISHWA1,196,5441,531,8141,851,6272,301,095 THURSTONWA643,375823,612995,6011,237,263 WHATCOMWA729,600934,0041,129,0061,403,082 WHITMANWA668,579855,9101,034,5901,285,769 PIERCEWI610,211781,162944,2701,173,474 ST. CROIXWI610,211781,162944,2701,173,474 JEFFERSONWV1,395,4681,786,7712,159,6452,684,092 TETONWY1,395,4681,786,7712,159,6452,684,092 All other areas – 2,794 counties (floor): $604,703$774,241$935,820 $1,163,092 .02 The nationwide average purchase price (for use in the housing cost/income ratio for new and existing residences) is $540,700. SECTION 5. EFFECT ON OTHER DOCUMENTS Rev. Proc. 2024-21 is obsolete except as provided in section 6 of this revenue procedure. SECTION 6. EFFECTIVE DATES .01 Issuers may rely on this revenue procedure to determine average area purchase price safe harbors for com- mitments to provide financing or issue mortgage credit certificates that are made, or (if the purchase precedes the commitment) for residences that are purchased, in the period that begins on April 16, 2025, and ends on the date as of which the safe harbors contained in section 4.01 of this revenue procedure are rendered obsolete by a new revenue procedure. .02 Notwithstanding section 5 of this revenue procedure, issuers may continue to rely on the average area purchase price safe harbors contained in Rev. Proc. 2024- 21, with respect to bonds sold, or for mort- gage credit certificates issued with respect to bond authority exchanged, before May 16, 2025, if the commitments to provide financing or issue mortgage credit certifi- cates are made on or before June 15, 2025. .03 Except as provided in section 6.04 of this revenue procedure, issuers must use the nationwide average purchase price limitation contained in this revenue proce- dure for commitments to provide financ- ing or issue mortgage credit certificates that are made, or (if the purchase precedes the commitment) for residences that are purchased, in the period that begins on April 16, 2025, and ends on the date when the nationwide average purchase price limitation is rendered obsolete by a new revenue procedure. .04 Notwithstanding sections 5 and 6.03 of this revenue procedure, issuers may continue to rely on the nationwide average purchase price set forth in Rev. Proc. 2024-21 with respect to bonds sold, or for mortgage credit certificates issued with respect to bond authority exchanged, before May 16, 2025, if the commitments to provide financing or issue mortgage credit certificates are made on or before June 15, 2025. SECTION 7. PRIOR COMMENTS RECEIVED In Section 7 of Rev. Proc. 2024-21, the Treasury Department and the Internal Revenue Service (IRS) requested com- ments for alternate data sources to cal- culate average area purchase prices. The Treasury Department and the IRS have reviewed all received comments and have determined that no changes to the data or the methodology for calculating average area purchase prices will be made. May 5, 2025 1444 Bulletin No. 2025–19 SECTION 8. PAPERWORK REDUCTION ACT The collection of information con- tained in this revenue procedure has been reviewed and approved by the Office of Management and Budget in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545- 1877. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Section 3.03 of this revenue proce- dure contains a collection of information requirement. The purpose of the collection of information is to verify the applicable FHA loan limit that issuers of qualified mortgage bonds and qualified mortgage certificates have used to calculate the average area purchase price for a given MSA for purposes of §§ 143(e) and 25(c). The collection of information is required to obtain the benefit of using revisions to FHA loan limits to determine average area purchase prices. The likely respondents are state and local governments. The estimated total annual reporting and/or recordkeeping burden is: 15 hours. The estimated annual burden per respondent and/or recordkeeper: 15 min- utes. The estimated number of respondents and/or recordkeepers: 60. Books or records relating to a collec- tion of information must be retained as long as their contents may become mate- rial in the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by 26 U.S.C. 6103. SECTION 9. DRAFTING INFORMATION The principal authors of this revenue procedure are Zoran Stojanovic and Elena Hildebrandt of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regard- ing this revenue procedure contact Ms. Hildebrandt at (202) 317-4565 (not a toll- free number). Bulletin No. 2025–19 i May 5, 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. May 5, 2025 ii Bulletin No. 2025–19 Numerical Finding List 1 Bulletin 2025–19 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 2025-15, 2025-18 I.R.B. 1420 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 2025-19, 2025-17 I.R.B. 1418 2025-20, 2025-19 I.R.B. 1423 2025-21, 2025-19 I.R.B. 1424 2025-22, 2025-19 I.R.B. 1427 2025-23, 2025-19 I.R.B. 1428 2025-24, 2025-19 I.R.B. 1429 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 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 2025-18, 2025-19 I.R.B. 1430 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 2025-10, 2025-19 I.R.B. 1421 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. 2025–19 iii May 5, 2025 Finding List of Current Actions on Previously Published Items 1 Bulletin 2025–19 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 Official Business Penalty for Private Use, $300 INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletins are available at www.irs.gov/irb/. We Welcome Comments About the Internal Revenue Bulletin If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it, we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave. NW, IR-6230 Washington, DC 20224.
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