Internal Revenue Bulletin 2025-17

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb25-17.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.

This notice requests recommendations for the 2025-2026 Priority Guidance Plan.

Finding Lists begin on page ii.

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 Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.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 21, 2025 Bulletin No. 2025–17

Public Recommendations Invited on Items to be Included on the 2025-2026 Priority Guidance Plan

The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) invite the public to submit recommendations for items to be included on the 2025-2026 Priority Guidance Plan.

The Treasury Department’s Office of Tax Policy and the IRS use the Priority Guidance Plan each year to identify and prioritize the tax issues that should be addressed through regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. The 2025-2026 Priority Guidance Plan will identify guidance projects that the Treasury Department and the IRS intend to actively work on as priorities during the period from July 1, 2025, through June 30, 2026. The Treasury Department and the IRS recognize the importance of public input in formulating a Priority Guidance Plan that focuses resources on guidance items that are most important to taxpayers and tax administration. Published guidance plays an important role in increasing voluntary compliance by helping to clarify ambiguous areas of the tax law. The published guidance process is most successful if the Treasury Department and the IRS have the benefit of the experience and knowledge of taxpayers and practitioners who must apply the rules implementing the tax laws.

In reviewing recommendations and selecting additional projects for inclusion on the 2025-2026 Priority Guidance Plan, the Treasury Department and the IRS will consider the following:

1. Whether taxpayers have identified that the recommended guidance relates to regulations potentially described in Executive Order 14219 (90 FR 10583) Section 2(a): (i) unconstitutional regulations and regulations that raise serious constitutional difficulties, such as exceeding the

scope of the power vested in the Federal Government by the Constitution;

(ii) regulations that are based on unlawful delegations of legislative power;

(iii) regulations that are based on anything other than the best reading of the underlying statutory authority or prohibition;

(iv) regulations that implicate matters of social, political, or economic significance that are not authorized by clear statutory authority;

(v) regulations that impose significant costs upon private parties that are not outweighed by public benefits;

(vi) regulations that harm the national interest by significantly and unjustifiably impeding technological innovation, infrastructure development, disaster response, inflation reduction, research and development, economic development, energy production, land use, and foreign policy objectives; and

(vii) regulations that impose undue burdens on small business and impede private enterprise and entrepreneurship.

2. Whether the recommendation involves existing regulations or other guidance that is outdated, unnecessary, ineffective, insufficient, or unnecessarily burdensome and that should be modified, streamlined, expanded, replaced, or withdrawn;

3. Whether the recommended guidance reduces controversy and lessens the burden on taxpayers or the IRS;

4. Whether the recommended guidance would be in accordance with Executive Order 14192 (90 FR 9065) or other executive orders.

5. Whether the recommended guidance resolves significant issues relevant to a broad class of taxpayers;

6. Whether the recommended guidance promotes sound tax administration;

7. Whether the IRS can administer the recommended guidance on a uniform basis; and

8. Whether the recommended guidance can be drafted in a manner that will enable taxpayers to easily understand and apply the guidance.

Please submit recommendations for guidance by Friday, May 30, 2025, for possible inclusion on the original 2025-2026

Priority Guidance Plan. Taxpayers may, however, submit recommendations for guidance at any time during the year. The Treasury Department and the IRS will update the 2025-2026 Priority Guidance Plan periodically to reflect additional guidance that the Treasury Department and the IRS intend to publish or have published during the plan year. The periodic updates allow the Treasury Department and the IRS to respond in a timely manner to the need for additional guidance that may arise during the plan year.

Taxpayers are not required to submit recommendations for guidance in any particular format. Taxpayers should, however, briefly describe the recommended guidance and explain the need for the guidance. In addition, taxpayers may include an analysis of how the issue should be resolved. For recommendations to modify, streamline, or withdraw existing regulations or other guidance, taxpayers should explain how the changes would reduce taxpayer cost and/or burden or benefit tax administration, or how the changes properly address issues described in Executive Order 14219 Sections 2(a) (i) – (vii). It would be helpful if taxpayers suggesting more than one guidance project prioritize the projects by order of importance. If a large number of projects are being suggested, it would be helpful if the projects were grouped by subject matter and then in terms of high, medium, or low priority. Requests for guidance in the form of petitions for rulemaking will be considered with other recommendations for guidance in accordance with the considerations described in this notice.

Taxpayers are strongly encouraged to submit recommendations for guidance electronically via the Federal eRulemaking Portal at https://www.regulations.gov (type IRS-2025-0036 in the search field on the regulations.gov homepage to find this notice and submit recommendations). Taxpayers submitting recommendations by mail should send them to:

Internal Revenue Service Attn: CC:PA:01:PR (Notice 2025-19) Room 5203 P.O. Box 7604 Ben Franklin Station Washington, D.C. 20044

April 21, 2025 1418 Bulletin No. 2025–17

All recommendations for guidance submitted by the public in response to this notice will be available for public

inspection and copying in their entirety. For further information regarding this notice, contact the Office of the Asso

ciate Chief Counsel (Procedure and Administration) at (202) 317-3400 (not a toll-free call).

Bulletin No. 2025–17 1419 April 21, 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. 2025–17 i April 21, 2025

Numerical Finding List ¹

Bulletin 2025–17

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 2025-19, 2025-17 I.R.B. 1418

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

Revenue Procedures:—Continued

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

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 21, 2025 ii Bulletin No. 2025–17

Finding List of Current Actions on Previously Published Items ¹

Bulletin 2025–17

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. 2025–17 iii April 21, 2025

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