SECTION 3. EFFECTIVE DATE

.01 General Rule . Except as provided in section 3.02 of this revenue procedure, this revenue procedure applies to taxable years beginning in 2025.

.02 Calendar Year Rule . This revenue procedure applies to transactions or events occurring in calendar year 2025 for purposes of sections 2.08 (rehabilitation expenditures treated as separate new building), 2.09 (low-income housing credit), 2.14 (transportation mainline pipeline construction industry optional expense substantiation rules for payments to employees under accountable plans), 2.20 (private activity bonds volume cap), 2.21 (loan limits on agricultural bonds), 2.22 (general arbitrage rebate rules), 2.23 (safe harbor rules for broker commissions on guaranteed investment contracts or investments purchased for a yield restricted defeasance escrow), 2.37 (expatriation to avoid taxes), 2.40 (debt instruments arising out of sales or exchanges), 2.41 (unified credit against

estate tax), 2.42 (valuation of qualified real property in decedent’s gross estate), 2.43 (annual exclusion for gifts), 2.44 (tax on arrow shafts), 2.45 (passenger air transportation excise tax), 2.46 (tax on certain uses of crude oil and petroleum products), 2.49 (persons against whom a federal tax lien is not valid), 2.50 (property exempt from levy), 2.52 (interest on a certain portion of the estate tax payable in installments), 2.60 (revocation or denial of passport in case of certain tax delinquencies), 2.61 (attorney fee awards), and 2.62 (periodic payments received under qualified long-term care insurance contracts or under certain life insurance contracts) of this revenue procedure.