Internal Revenue Bulletin 2025-16

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb25-16.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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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.

Resident populations of the 50 states, the District of Columbia, Puerto Rico, and the insular areas for purposes of determining the 2025 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k) are reproduced.

Finding Lists begin on page ii.

Fringe benefits aircraft valuation formula. For purposes of section 1.61-21(g) of the Income Tax Regulations, relating to the rule for valuing non-commercial flights on employer-provided aircraft, the Standard Industry Fare Level (SIFL) centsper-mile rates and terminal charge in effect for the first half of 2025 are set forth.

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.

The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official 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 substantive 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 otherwise indicated. Procedures relating solely to matters of internal 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 rulings 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, disbarment and suspension lists, and announcements.

The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.

The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.

April 14, 2025 Bulletin No. 2025–16

Section 61.—Gross Income Defined

26 CFR 1.61-21: Taxation of Fringe Benefits

For purposes of the taxation of fringe benefits under section 61 of the Internal

Period During Which the Flight Is Taken

Revenue Code, section 1.61-21(g) of the Income Tax Regulations provides a rule for valuing noncommercial flights on employer-provided aircraft. Section 1.61-21(g)(5) provides an aircraft valuation formula to determine the value of such flights. The value of a flight is determined under the base aircraft valuation formula (also known as the Standard Industry Fare Level formula or SIFL) by multiplying the SIFL cents-per-mile

rates applicable for the period during which the flight was taken by the appropriate aircraft multiple provided in section 1.61-21(g)(7) and then adding the applicable terminal charge. The SIFL cents-per-mile rates in the formula and the terminal charge are calculated by the Department of Transportation (DOT) and are reviewed semi-annually.

The following chart sets forth the terminal charge and SIFL mileage rates:

Terminal Charge SIFL Mileage Rates

1/1/25 - 6/30/25 $52.44 Up to 500 miles = $.2869 per mile

501-1500 miles = $.2187 per mile

Over 1500 miles = $.2103 per mile

DRAFTING INFORMATION

The principal author of this revenue ruling is Kathleen Edmondson of the Office

of Associate Chief Counsel (Employee Benefits, Exempt Organizations and Employment Taxes). For further information regarding this revenue ruling, contact

Ms. Edmondson at (202) 317-6798 (not a toll-free call).

Bulletin No. 2025–16 1415 April 14, 2025

2025 Calendar Year Resident Population Figures

This notice advises State and local housing credit agencies that allocate low-income housing tax credits under § 42 of the Internal Revenue Code, and States and other issuers of tax-exempt private activity bonds under § 141, of the population figures to use in calculating: (1) the 2025 calendar year population-based component of the State housing credit ceiling (Credit Ceiling) under § 42(h)(3) (C)(ii); (2) the 2025 calendar year volume cap (Volume Cap) under § 146; and (3) the 2025 volume limit (Volume Limit) under § 142(k)(5).

Generally, the population-based component of both the Credit Ceiling and the Volume Cap are determined under § 146(j), which requires determining the population figures for any calendar year on the basis of the most recent census estimate of the resident population of a State (or issuing authority) released by the U.S. Census Bureau before the beginning of the calendar year. Similarly, § 142(k)(5) bases the Volume Limit on the State population.

Sections 42(h)(3)(H) and 146(d)(2) require adjusting for inflation the population-based component of the Credit Ceiling and the Volume Cap. The Credit Ceiling adjustment for the 2025 calendar year is in Rev. Proc. 2024-40; 2024-45 I.R.B. 1100. Section 2.09 of Rev. Proc. 2024-40 provides that, for calendar year 2025, the amount for calculating the Credit Ceiling under § 42(h)(3)(C)(ii) is the greater of $3.00 multiplied by the State popula

tion, or $3,455,000. Further, section 2.20 of Rev. Proc. 2024-40 provides that the amount for calculating the Volume Cap under § 146(d)(1) for calendar year 2025 is the greater of $130 multiplied by the State population, or $388,780,000.

For the 50 states, the District of Columbia, and Puerto Rico, the population figures for calculating the Credit Ceiling, the Volume Cap, and the Volume Limit for the 2025 calendar year are the resident population estimates released electronically by the U.S. Census Bureau on December 19, 2024, and described in Press Release CB24-213. For American Samoa, Guam, the Northern Mariana Islands, and the U.S. Virgin Islands, the population figures for the 2025 calendar year are the 2024 midyear population figures in the U.S. Census Bureau’s International Data Base.

For convenience, these figures are reprinted below.

Resident Population Figures

Alabama 5,157,699 Alaska 740,133 American Samoa 43,895 Arizona 7,582,384 Arkansas 3,088,354 California 39,431,263 Colorado 5,957,493 Connecticut 3,675,069 Delaware 1,051,917 District of Columbia 702,250 Florida 23,372,215 Georgia 11,180,878 Guam 169,532 Hawaii 1,446,146 Idaho 2,001,619 Illinois 12,710,158 Indiana 6,924,275 Iowa 3,241,488 Kansas 2,970,606 Kentucky 4,588,372 Louisiana 4,597,740 Maine 1,405,012 Maryland 6,263,220

April 14, 2025 1416 Bulletin No. 2025–16

Resident Population Figures

Massachusetts 7,136,171 Michigan 10,140,459 Minnesota 5,793,151 Mississippi 2,943,045 Missouri 6,245,466 Montana 1,137,233 Nebraska 2,005,465 Nevada 3,267,467 New Hampshire 1,409,032 New Jersey 9,500,851 New Mexico 2,130,256 New York 19,867,248 North Carolina 11,046,024 North Dakota 796,568 Northern Mariana Islands 51,118 Ohio 11,883,304 Oklahoma 4,095,393 Oregon 4,272,371 Pennsylvania 13,078,751 Puerto Rico 3,203,295 Rhode Island 1,112,308 South Carolina 5,478,831 South Dakota 924,669 Tennessee 7,227,750 Texas 31,290,831 Utah 3,503,613 Vermont 648,493 Virginia 8,811,195 Virgin Islands, U.S. 104,377 Washington 7,958,180 West Virginia 1,769,979 Wisconsin 5,960,975 Wyoming 587,618

The principal authors of this notice are Waheed M. Olayan, Office of the Associate Chief Counsel (Energy, Credits, and

Excise), and Brian Choi, Office of the Associate Chief Counsel (Financial Institutions and Products). For further infor

mation regarding this notice, please contact Waheed M. Olayan at (202) 317-6239 (not a toll-free number).

Bulletin No. 2025–16 1417 April 14, 2025

new ruling does more than restate the substance 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 rulings in the series.

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 published 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 confusion. It is not used where a position in a prior ruling is being changed.

Distinguished describes a situation where a ruling mentions a previously published ruling and points out an essential difference between them.

where a ruling mentions a previously pub- the 1986 Code and regulations the same Suspended is used in rare situations lished ruling and points out an essential position published under the 1939 Code to show that the previous published ruldifference between them. and regulations. The term is also used ings will not be applied pending some

Modified is used where the substance when it is desired to republish in a single future action such as the issuance of new of a previously published position is being ruling a series of situations, names, etc., or amended regulations, the outcome of changed. Thus, if a prior ruling held that a that were previously published over a cases in litigation, or the outcome of a principle applied to A but not to B, and the period of time in separate rulings. If the Service study.

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 published ruling that is not considered determinative 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

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.

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.

Bulletin No. 2025–16 i April 14, 2025

Numerical Finding List ¹

Bulletin 2025–16

Announcements:

2025-2, 2025-2 I.R.B. 305 2025-3, 2025-2 I.R.B. 306 2025-4, 2025-2 I.R.B. 306 2025-1, 2025-3 I.R.B. 431 2025-5, 2025-3 I.R.B. 433 2025-6, 2025-5 I.R.B. 526 2025-8, 2025-13 I.R.B. 1384 2025-13, 2025-15 I.R.B. 1392

Notices:

2025-1, 2025-3 I.R.B. 415 2025-2, 2025-3 I.R.B. 418 2025-4, 2025-3 I.R.B. 419 2025-5, 2025-3 I.R.B. 426 2025-3, 2025-4 I.R.B. 488 2025-7, 2025-5 I.R.B. 524 2025-9, 2025-6 I.R.B. 681 2025-10, 2025-6 I.R.B. 682 2025-11, 2025-6 I.R.B. 704 2025-13, 2025-6 I.R.B. 710 2025-6, 2025-8 I.R.B. 799 2025-8, 2025-8 I.R.B. 800 2025-12, 2025-8 I.R.B. 813 2025-14, 2025-10 I.R.B. 980 2025-15, 2025-11 I.R.B. 1089 2025-16, 2025-13 I.R.B. 1378 2025-17, 2025-14 I.R.B. 1387 2025-18, 2025-16 I.R.B. 1416

Proposed Regulations:

REG-117213-24, 2025-3 I.R.B. 433 REG-134420-10, 2025-4 I.R.B. 513 REG-105479-18, 2025-5 I.R.B. 527 REG-116610-20, 2025-5 I.R.B. 638 REG-115560-23, 2025-6 I.R.B. 716 REG-123525-23, 2025-6 I.R.B. 726 REG-124930-21, 2025-7 I.R.B. 772 REG‑100669‑24, 2025-8 I.R.B. 819 REG-101268-24, 2025-8 I.R.B. 836 REG-107420-24, 2025-8 I.R.B. 854 REG-116085-23, 2025-8 I.R.B. 865 REG-118988-22, 2025-8 I.R.B. 869 REG-107895-24, 2025-9 I.R.B. 972 REG-110878-24, 2025-9 I.R.B. 979 REG-112261-24, 2025-10 I.R.B. 983

Revenue Procedures:

2025-1, 2025-1 I.R.B. 1 2025-2, 2025-1 I.R.B. 118 2025-3, 2025-1 I.R.B. 142 2025-4, 2025-1 I.R.B. 158 2025-5, 2025-1 I.R.B. 260

Revenue Procedures:—Continued

2025-7, 2025-1 I.R.B. 301 2025-8, 2025-3 I.R.B. 427 2025-9, 2025-4 I.R.B. 491 2025-10, 2025-4 I.R.B. 492 2025-11, 2025-4 I.R.B. 501 2025-12, 2025-4 I.R.B. 512 2025-6, 2025-6 I.R.B. 713 2025-14, 2025-7 I.R.B. 770 2025-13, 2025-8 I.R.B. 816 2025-15, 2025-11 I.R.B. 1090 2025-16, 2025-11 I.R.B. 1100 2025-17, 2025-13 I.R.B. 1382

Revenue Rulings:

2025-1, 2025-3 I.R.B. 307 2025-2, 2025-3 I.R.B. 309 2025-3, 2025-4 I.R.B. 443 2025-4, 2025-7 I.R.B. 758 2025-5, 2025-7 I.R.B. 767 2025-6, 2025-11 I.R.B. 1064 2025-7, 2025-13 I.R.B. 1239 2025-8, 2025-15 I.R.B. 1390 2025-9, 2025-16 I.R.B. 1415

Treasury Decisions:

10016, 2025-3 I.R.B. 313 10020, 2025-3 I.R.B. 408 10018, 2025-4 I.R.B. 446 10019, 2025-4 I.R.B. 482 10017, 2025-5 I.R.B. 517 10028, 2025-6 I.R.B. 660 10022, 2025-8 I.R.B. 773 10026, 2025-9 I.R.B. 878 10027, 2025-9 I.R.B. 897 10029, 2025-9 I.R.B. 936 10030, 2025-11 I.R.B. 1066 10024, 2025-12 I.R.B. 1104 10023, 2025-13 I.R.B. 1259

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin 2024–52, dated December 23, 2024.

April 14, 2025 ii Bulletin No. 2025–16

Finding List of Current Actions on Previously Published Items ¹

Bulletin 2025–16

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin 2024–52, dated December 23, 2024.

Bulletin No. 2025–16 iii April 14, 2025

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