Notice 2025-22

This notice starts the process of eliminating extraneous and unnecessary Internal Revenue Bulletin (IRB) guidance by identifying and obsoleting nine IRB guidance 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 guidance documents “squarely authorized by constitutional Federal statutes,” eliminating “overbearing and burdensome” regulations and other guidance documents, and “ending Federal overreach.” To further these goals, the Executive Order directs agency heads to coordinate 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 (Treasury Department) and the Internal Revenue Service (IRS), in conjunction with DOGE, have undertaken a review of regulations 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 administration of the tax laws; reduce the volume 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: