Internal Revenue Bulletin 2025-49

Official source: Internal Revenue Bulletin (https://www.irs.gov/pub/irs-irbs/irb25-49.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.

Section 415 of the Internal Revenue Code provides for dollar limitations on benefits and contributions under qualified retirement plans. Section 415(d) requires that the Secretary of the Treasury annually adjust these limits for cost of living increases. Other limitations applicable to deferred compensation plans are also affected by these adjustments under § 415. Under § 415(d), the adjustments are to be

Finding Lists begin on page ii.

made under adjustment procedures similar to those used to adjust benefit amounts under § 215(i)(2)(A) of the Social Security Act.

2025 Base Period T-Bill Rate. The “base period T-bill rate” for the period ending September 30, 2025 is published as required by section 995(f) of the Internal Revenue Code.

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.

December 1, 2025 Bulletin No. 2025–49

Section 995.—Taxation of DISC Income to Shareholders

2025 Base Period T-Bill Rate. The “base period T-bill rate” for the period ending September 30, 2025, is published as required by section 995(f) of the Internal Revenue Code.

Section 995(f)(1) of the Internal Revenue Code provides that a shareholder of a domestic international sales corporation (“DISC”) shall pay interest for each taxable year in an amount equal to the product of the “shareholder’s DISC-related deferred tax liability” for the year (as defined in section 995(f)(2)) and the “base period T-bill rate.” Under section 995(f) (4), the base period T-bill rate is “the annual rate of interest determined by the Secretary to be equivalent to the average of the 1-year constant maturity Treasury

yields, as published by the Board of Governors of the Federal Reserve System, for the 1-year period ending on September 30 of the calendar year ending with (or of the most recent calendar year ending before) the close of the taxable year of the shareholder.”

The base period T-bill rate for the period ending September 30, 2025, is 4.08 percent.

Pursuant to section 6622 of the Internal Revenue Code, interest must be compounded daily. The table below provides factors for compounding the 2025 base period T-bill rate daily for any number of days in the shareholder’s taxable year (including for a 52-53 week taxable year). To compute the amount of the interest charge for the shareholder’s taxable year, multiply the amount of the shareholder’s DISC-related deferred tax liability for that year by the base period T-bill rate factor corresponding to the number of days in the shareholder’s taxable year for which the interest charge is being computed. Gener

ally, one would use the factor for 365 days. One would use a different factor only if the shareholder’s taxable year for which the interest charge is being determined is a short taxable year, if the shareholder uses a 52-53 week taxable year, or if the shareholder’s taxable year is a leap year.

For the base period T-bill rates for periods ending in prior years, see Rev. Rul. 2024-27, 2024-51 I.R.B. 1240; Rev. Rul. 2023-23, 2023-51 I.R.B. 1472; Rev. Rul. 2022-21, 2022-47 I.R.B. 468; Rev. Rul. 2021-22, 2021-47 I.R.B. 726; Rev. Rul. 2020-25, 2020-48 I.R.B. 1109; and Rev. Rul. 2019-27, 2019-51 I.R.B. 1378.

DRAFTING INFORMATION

The principal author of this revenue ruling is Stefan A. Pruessmann of the Office of Associate Chief Counsel (International). For further information regarding the revenue ruling, contact Mr. Pruessmann at (202) 317-3800 (not a toll-free number).

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR 1 0.000111781 2 0.000223574 3 0.000335380 4 0.000447198 5 0.000559029

6 0.000670872 7 0.000782728 8 0.000894597 9 0.001006477 10 0.001118371

11 0.001230276 12 0.001342195 13 0.001454126 14 0.001566069 15 0.001678025

Bulletin No. 2025–49 749 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

16 0.001789993 17 0.001901974 18 0.002013968 19 0.002125974 20 0.002237992

21 0.002350023 22 0.002462067 23 0.002574123 24 0.002686191 25 0.002798272

26 0.002910366 27 0.003022472 28 0.003134591 29 0.003246722 30 0.003358866

31 0.003471022 32 0.003583191 33 0.003695372 34 0.003807566 35 0.003919772

36 0.004031991 37 0.004144223 38 0.004256467 39 0.004368724 40 0.004480993

41 0.004593274 42 0.004705569 43 0.004817876 44 0.004930195 45 0.005042527

46 0.005154871 47 0.005267228 48 0.005379598 49 0.005491980 50 0.005604375

December 1, 2025 750 Bulletin No. 2025–49

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

51 0.005716782 52 0.005829202 53 0.005941634 54 0.006054079 55 0.006166537

56 0.006279007 57 0.006391490 58 0.006503985 59 0.006616493 60 0.006729013

61 0.006841546 62 0.006954092 63 0.007066650 64 0.007179221 65 0.007291804

66 0.007404400 67 0.007517008 68 0.007629630 69 0.007742263 70 0.007854909

71 0.007967568 72 0.008080240 73 0.008192924 74 0.008305620 75 0.008418330

76 0.008531051 77 0.008643786 78 0.008756533 79 0.008869293 80 0.008982065

81 0.009094850 82 0.009207647 83 0.009320457 84 0.009433280 85 0.009546115

Bulletin No. 2025–49 751 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

86 0.009658963 87 0.009771824 88 0.009884697 89 0.009997582 90 0.010110481

91 0.010223392 92 0.010336315 93 0.010449252 94 0.010562200 95 0.010675162

96 0.010788136 97 0.010901123 98 0.011014122 99 0.011127134 100 0.011240159

101 0.011353196 102 0.011466246 103 0.011579308 104 0.011692384 105 0.011805471

106 0.011918572 107 0.012031685 108 0.012144811 109 0.012257949 110 0.012371100

111 0.012484264 112 0.012597440 113 0.012710629 114 0.012823831 115 0.012937045

116 0.013050272 117 0.013163511 118 0.013276764 119 0.013390029 120 0.013503306

December 1, 2025 752 Bulletin No. 2025–49

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS

FACTOR

121 0.013616596

122 0.013729899 123 0.013843215 124 0.013956543 125 0.014069884

126 0.014183238 127 0.014296604 128 0.014409983 129 0.014523374 130 0.014636778

131 0.014750195 132 0.014863625 133 0.014977067 134 0.015090522 135 0.015203990

136 0.015317470 137 0.015430963 138 0.015544469 139 0.015657987 140 0.015771518

141 0.015885062 142 0.015998619 143 0.016112188 144 0.016225770 145 0.016339364

146 0.016452972 147 0.016566591 148 0.016680224 149 0.016793869 150 0.016907528

151 0.017021198 152 0.017134882 153 0.017248578 154 0.017362287 155 0.017476008

Bulletin No. 2025–49 753 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS

FACTOR

156 0.017589743

157 0.017703490 158 0.017817249 159 0.017931022 160 0.018044807

161 0.018158605 162 0.018272416 163 0.018386239 164 0.018500075 165 0.018613924

166 0.018727785 167 0.018841659 168 0.018955546 169 0.019069446 170 0.019183359

171 0.019297284 172 0.019411222 173 0.019525172 174 0.019639136 175 0.019753112

176 0.019867101 177 0.019981102 178 0.020095116 179 0.020209143 180 0.020323183

181 0.020437236 182 0.020551301 183 0.020665379 184 0.020779470 185 0.020893574

186 0.021007690 187 0.021121819 188 0.021235961 189 0.021350115 190 0.021464283

December 1, 2025 754 Bulletin No. 2025–49

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

191 0.021578463 192 0.021692656 193 0.021806861 194 0.021921080 195 0.022035311

196 0.022149555 197 0.022263812 198 0.022378081 199 0.022492363 200 0.022606658

201 0.022720966 202 0.022835287 203 0.022949620 204 0.023063966 205 0.023178325

206 0.023292697 207 0.023407082 208 0.023521479 209 0.023635889 210 0.023750312

211 0.023864747 212 0.023979196 213 0.024093657 214 0.024208131 215 0.024322618

216 0.024437118 217 0.024551630 218 0.024666155 219 0.024780693 220 0.024895244

221 0.025009808 222 0.025124384 223 0.025238973 224 0.025353575 225 0.025468190

Bulletin No. 2025–49 755 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

226 0.025582818 227 0.025697458 228 0.025812112 229 0.025926778 230 0.026041457

231 0.026156149 232 0.026270853 233 0.026385571 234 0.026500301 235 0.026615044

236 0.026729800 237 0.026844568 238 0.026959350 239 0.027074144 240 0.027188952

241 0.027303772 242 0.027418604 243 0.027533450 244 0.027648309 245 0.027763180

246 0.027878064 247 0.027992961 248 0.028107871 249 0.028222794 250 0.028337730

251 0.028452678 252 0.028567639 253 0.028682613 254 0.028797600 255 0.028912600

256 0.029027613 257 0.029142638 258 0.029257677 259 0.029372728 260 0.029487792

December 1, 2025 756 Bulletin No. 2025–49

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS

FACTOR

261 0.029602869

262 0.029717959 263 0.029833062 264 0.029948177 265 0.030063306

266 0.030178447 267 0.030293601 268 0.030408768 269 0.030523948 270 0.030639141

271 0.030754347 272 0.030869565 273 0.030984797 274 0.031100041 275 0.031215298

276 0.031330569 277 0.031445852 278 0.031561147 279 0.031676456 280 0.031791778

281 0.031907112 282 0.032022460 283 0.032137820 284 0.032253193 285 0.032368579

286 0.032483978 287 0.032599390 288 0.032714815 289 0.032830253 290 0.032945703

291 0.033061167 292 0.033176643 293 0.033292133 294 0.033407635 295 0.033523150

Bulletin No. 2025–49 757 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

296 0.033638678 297 0.033754219 298 0.033869773 299 0.033985340 300 0.034100920

301 0.034216512 302 0.034332118 303 0.034447736 304 0.034563368 305 0.034679012

306 0.034794669 307 0.034910340 308 0.035026023 309 0.035141719 310 0.035257428

311 0.035373150 312 0.035488885 313 0.035604632 314 0.035720393 315 0.035836167

316 0.035951953 317 0.036067753 318 0.036183565 319 0.036299391 320 0.036415229

321 0.036531081 322 0.036646945 323 0.036762822 324 0.036878712 325 0.036994615

326 0.037110532 327 0.037226461 328 0.037342403 329 0.037458358 330 0.037574326

December 1, 2025 758 Bulletin No. 2025–49

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

331 0.037690307 332 0.037806300 333 0.037922307 334 0.038038327 335 0.038154360

336 0.038270406 337 0.038386464 338 0.038502536 339 0.038618621 340 0.038734718

341 0.038850829 342 0.038966953 343 0.039083089 344 0.039199239 345 0.039315401

346 0.039431577 347 0.039547765 348 0.039663967 349 0.039780181 350 0.039896409

351 0.040012649 352 0.040128903 353 0.040245169 354 0.040361449 355 0.040477741

356 0.040594047 357 0.040710365 358 0.040826696 359 0.040943041 360 0.041059398

361 0.041175769 362 0.041292152 363 0.041408549 364 0.041524958 365 0.041641381

Bulletin No. 2025–49 759 December 1, 2025

ANNUAL RATE (4.08%), COMPOUNDED DAILY

DAYS FACTOR

366 0.041757816 367 0.041874265 368 0.041990726 369 0.042107201 370 0.042223689

371 0.042340189

December 1, 2025 760 Bulletin No. 2025–49

2026 Amounts Relating to Retirement Plans and IRAs, as Adjusted for Changes in Cost-of-Living

Section 415 of the Internal Revenue Code (“Code”) provides for limitations on benefits and contributions under qualified retirement plans. Section 415(d) requires that the Secretary of the Treasury annually adjust these limitations for cost-ofliving increases. Under section 415(d), the adjustments are to be made under adjustment procedures similar to those used to adjust benefit amounts under section 215(i)(2)(A) of the Social Security Act. Other amounts applicable to deferred compensation plans are also adjusted for cost-of-living increases using a variation of the methodology used for the adjustments under section 415(d).

Cost-of-Living Adjusted Limitations for 2026

Effective January 1, 2026, the limitation on the annual benefit under a defined benefit plan under section 415(b)(1)(A) of the Code is increased from $280,000 to $290,000.

For a participant who separated from service before January 1, 2026, the participant’s limitation under a defined benefit plan under section 415(b)(1)(B) is computed by multiplying the participant’s compensation limitation, as adjusted through 2025, by 1.0288.

The limitation for defined contribution plans under section 415(c)(1)(A) is increased in 2026 from $70,000 to $72,000.

The Code provides that various other amounts are to be adjusted at the same time and in the same manner as the limitation of section 415(b)(1)(A). After taking into account the applicable rounding rules, the amounts for 2026 are as follows:

The limitation under section 402(g)(1) on the exclusion for elective deferrals

described in section 402(g)(3), which includes elective deferrals made to the Thrift Savings Plan, is increased from $23,500 to $24,500.

The limitation on deferrals under section 457(e)(15) concerning deferred compensation plans of state and local governments and tax-exempt organizations is increased from $23,500 to $24,500.

The limitation under section 414(v) (2)(B)(i) for catch-up contributions to an applicable employer plan other than a plan described in section 401(k) (11) or section 408(p) that generally applies for individuals aged 50 or over is increased from $7,500 to $8,000. The limitation under section 414(v)(2) (E)(i) for catch-up contributions to an applicable employer plan other than a plan described in section 401(k)(11) or section 408(p) that applies for individuals who attain age 60, 61, 62, or 63 in 2026 remains $11,250. The Roth catch-up wage threshold for 2025, which under section 414(v)(7)(A) is used to determine whether an individu­ al’s catch-up contributions to an appli­ cable employer plan (other than a plan described in section 408(k) or (p)) for 2026 must be designated as Roth con­ tributions, is increased from $145,000 to $150,000.

The limitation under section 408(p) (2)(E)(i)(III) that generally applies to salary reduction contributions under a SIMPLE retirement account or elective contributions under a SIMPLE 401(k) plan is increased from $16,500 to $17,000. The limitation for certain of those accounts or plans under section 408(p)(2)(E)(i)(I) or (II) is increased from $17,600 to $18,100.

The limitation under section 414(v)(2) (B)(ii) for catch-up contributions to an applicable employer plan described in section 401(k)(11) or section 408(p) that generally applies for individuals aged 50 or over is increased from $3,500 to $4,000. The limitation under

section 414(v)(2)(E)(ii) for catch-up contributions to an applicable employer plan described in section 401(k)(11) or section 408(p) that applies for individuals who attain age 60, 61, 62, or 63 in 2026 remains $5,250. The limitation under section 414(v)(2)(B)(iii) for catch-up contributions to certain accounts or plans described in section 401(k)(11) or section 408(p) that generally applies for individuals aged 50 or over remains $3,850.

The limitation under section 401(k) (16)(D)(i)(II) and 403(b)(16)(D)(i) (II) that generally applies for elective contributions made to a starter 401(k) deferral-only arrangement described in section 401(k)(16)(B) or a safe harbor deferral-only plan described in section 403(b)(16)(B), respectively, remains $6,000. This limitation is increased for individuals who attain age 50 before the end of the taxable year by $1,100.

The threshold used in the definition of “highly compensated employee” under section 414(q)(1)(B) remains $160,000.

The threshold under section 416(i) (1)(A)(i) concerning the definition of “key employee” for top-heavy plan purposes is increased from $230,000 to $235,000.

The annual compensation limitation under sections 401(a) (17), 404(l), 408(k)(3)(C), and 408(k) (6)(D)(ii) is increased from $350,000 to $360,000. The annual compensation limitation under section 401(a)(17) for eligible participants in certain governmental plans that, under the plan as in effect on July 1, 1993, allowed cost-ofliving adjustments to the compensation limitation under the plan under section 401(a)(17) to be taken into account, is increased from $520,000 to $535,000.

The limitation under section 402A(e) (3)(A)(i) concerning pension-linked emergency savings accounts that may be included in certain types of defined

Bulletin No. 2025–49 761 December 1, 2025

contribution plans is increased from $2,500 to $2,600.

The compensation threshold under section 408(k)(2)(C) regarding simplified employee pensions is increased from $750 to $800.

The amount under section 409(o)(1) (C)(ii) for determining the maximum account balance in an employee stock ownership plan subject to a 5‑year distribution period is increased from $1,415,000 to $1,455,000, while the dollar amount used to determine the lengthening of the 5-year distribution period is increased from $280,000 to $290,000.

The limitation on the aggregate amount of length of service awards accruing with respect to any year of service for any bona fide volunteer under section 457(e)(11)(B)(ii) concerning deferred compensation plans of state and local governments and tax-exempt organizations is increased from $7,500 to $8,000.

The limitation under section 664(g) (7) concerning the qualified gratuitous transfer of qualified employer securities to an employee stock ownership plan is increased from $60,000 to $65,000.

The compensation amount under § 1.61-21(f)(5)(i) of the Income Tax Regulations concerning the definition of “control employee” for fringe benefit valuation purposes is increased from $140,000 to $145,000. The compensation amount under § 1.61-21(f) (5)(iii) is increased from $285,000 to $290,000.

The limitation on premiums paid for a qualifying longevity annuity contract under § 1.401(a)(9)-6(q)(2)(ii) remains $210,000.

The $1,000,000,000 threshold used to determine whether a multiemployer plan is a systemically important plan under section 432(e)(9)(H)(v)(III)(aa) is adjusted using the cost-of-living adjustment provided under section 432(e)(9)(H)

(v)(III)(bb). After taking the applicable rounding rule into account, the threshold used to determine whether a multiemployer plan is a systemically important plan under section 432(e)(9)(H)(v)(III) (aa) is increased from $1,441,000,000 to $1,505,000,000.

The Code also provides that several retirement-related amounts are to be adjusted using a variation of the methodology used for the cost-of-living adjustments under section 1(f)(3). After taking the applicable rounding rules into account, the amounts for 2026 are as follows:

The adjusted gross income limitation under section 25B(b)(1)(A) for determining the retirement savings contributions credit for married taxpayers filing a joint return is increased from $47,500 to $48,500; the limitation under section 25B(b)(1)(B) is increased from $51,000 to $52,500; and the limitation under sections 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $79,000 to $80,500.

The adjusted gross income limitation under section 25B(b)(1)(A) for determining the retirement savings contributions credit for taxpayers filing as head of household is increased from $35,625 to $36,375; the limitation under section 25B(b)(1)(B) is increased from $38,250 to $39,375; and the limitation under sections 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $59,250 to $60,375.

The adjusted gross income limitation under section 25B(b)(1)(A) for determining the retirement savings contributions credit for all other taxpayers is increased from $23,750 to $24,250; the limitation under section 25B(b) (1)(B) is increased from $25,500 to $26,250; and the limitation under sections 25B(b)(1)(C) and 25B(b)(1)(D) is increased from $39,500 to $40,250.

The deductible amount under section 219(b)(5)(A), which limits the amount of an individual’s deductible qualified retirement contributions for a taxable year is increased from $7,000 to $7,500. The deductible amount pursuant to section 219(b)(5)(B)(ii) for

individuals who have attained age 50 before the close of the taxable year is increased from $1,000 to $1,100.

The applicable amount under section 219(g)(3)(B)(i) for determining the deductible amount of an IRA contribution for taxpayers who are active participants filing a joint return or as a qualifying widow(er) is increased from $126,000 to $129,000. The applicable amount under section 219(g)(3) (B)(ii) for all other taxpayers who are active participants (other than married taxpayers filing separate returns) is increased from $79,000 to $81,000. If an individual or the individual’s spouse is an active participant, the applicable amount under section 219(g)(3)(B)(iii) for a married individual filing a separate return is not subject to an annual cost-of-living adjustment and remains $0. The applicable amount under section 219(g) (7)(A) for a taxpayer who is not an active participant but whose spouse is an active participant is increased from $236,000 to $242,000.

In light of the changes to the applicable amounts, under section 219(g)(2) (A), the deduction for taxpayers making contributions to a traditional IRA is phased out for single individuals and heads of household who are active participants in a qualified plan (or another retirement plan specified in section 219(g)(5)) and have adjusted gross incomes (as defined in section 219(g) (3)(A)) between $81,000 and $91,000, increased from between $79,000 and $89,000. For married couples filing jointly, if the spouse who makes the IRA contribution is an active participant, the income phase‑out range is between $129,000 and $149,000, increased from between $126,000 and $146,000. For an IRA contributor who is not an active participant and is married to someone who is an active participant, the deduction is phased out if the couple’s income is between $242,000 and $252,000, increased from between $236,000 and $246,000. For a married individual filing a separate return who is an active participant, the phaseout range is not subject to an annual

December 1, 2025 762 Bulletin No. 2025–49

cost‑of‑living adjustment and remains $0 to $10,000.

The adjusted gross income limitation under section 408A(c)(3)(B)(ii)(I) for determining the maximum Roth IRA contribution for married taxpayers filing a joint return or for taxpayers filing as a qualifying widow(er) is increased from $236,000 to $242,000. The adjusted gross income limitation under section 408A(c)(3)(B) (ii)(II) for all other taxpayers (other than married taxpayers filing separate returns) is increased from $150,000 to $153,000. The applicable amount under section 408A(c)(3)(B)(ii)(III) for a married individual filing a separate return is not subject to an annual cost-of-living adjustment and remains $0.

In light of the changes to the adjusted gross income limitations, under section 408A(c)(3)(A), the adjusted gross income phase-out range for taxpayers making contributions to a Roth IRA is between $242,000 and $252,000 for married couples filing jointly, increased from between $236,000 and $246,000. For singles and heads of household, the income phase-out range

is between $153,000 and $168,000, increased from between $150,000 and $165,000. For a married individual filing a separate return, the phaseout range is not subject to an annual cost-of-living adjustment and remains between $0 and $10,000.

The aggregate amount of qualified charitable distributions that are not includible in gross income under section 408(d)(8)(A) is increased from $108,000 to $111,000. The amount of qualified charitable distributions made directly to a split-interest entity that are not includible in gross income under section 408(d)(8)(F)(i)(II) pursuant to a one-time election is increased from $54,000 to $55,000.

The annual compensation limitation under section 45E(f)(2)(C) for employees excluded from the calculation of the additional small employer pension plan startup cost credit for certain employer contributions is increased from $105,000 to $110,000. ¹

The limitation under section 72(t)(2) (K)(ii)(I) for eligible distributions

to victims of domestic abuse from applicable eligible retirement plans is increased from $10,300 to $10,500.

The limitation under section 401(a) (39)(B)(i)(III) on a qualified longterm care distribution from a qualified defined contribution plan with respect to certified long-term care insurance remains $2,600.

The limitation under section 408(p) (2)(A)(iv) for additional nonelective contributions for an employee to a SIMPLE retirement account or a SIMPLE 401(k) plan is increased from $5,100 to $5,300.

Drafting Information

The principal author of this notice is Tom Morgan of the Office of Associate 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 (not a toll-free call).

1 Pursuant to section 45E(f)(2)(C)(iii), for a taxable year beginning in a calendar year after 2023, this limitation is equal to the initial limitation of $100,000, multiplied by the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting “calendar year 2007” for “calendar year 2016” in section 1(f) (3)(A)(ii). Because the specification of a 2007 base period to be used for computing an adjustment that is first made for 2024 appears to be an error that has been identified as the subject of future legislative correction, the IRS will calculate and apply the limitation in section 45E(f)(2)(C) by substituting “calendar year 2022” for “calendar year 2007” in section 45E(f)(2)(C)(iii).

Bulletin No. 2025–49 763 December 1, 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. 2025–49 i December 1, 2025

Numerical Finding List ¹

Bulletin 2025–49

Announcements:

2025-19, 2025-29 I.R.B. 191 2025-20, 2025-31 I.R.B. 271 2025-21, 2025-32 I.R.B. 312 2025-24, 2025-36 I.R.B. 359 2025-25, 2025-36 I.R.B. 360 2025-26, 2025-40 I.R.B. 444

Notices:

2025-32, 2025-27 I.R.B. 1 2025-33, 2025-27 I.R.B. 4 2025-34, 2025-27 I.R.B. 6 2025-35, 2025-27 I.R.B. 8 2025-31, 2025-28 I.R.B. 14 2025-36, 2025-30 I.R.B. 192 2025-37, 2025-30 I.R.B. 198 2025-40, 2025-31 I.R.B. 266 2025-39, 2025-32 I.R.B. 308 2025-28, 2025-34 I.R.B. 316 2025-41, 2025-34 I.R.B. 325 2025-42, 2025-36 I.R.B. 351 2025-43, 2025-36 I.R.B. 356 2025-44, 2025-37 I.R.B. 386 2025-45, 2025-37 I.R.B. 388 2025-38, 2025-38 I.R.B. 392 2025-47, 2025-40 I.R.B. 441 2025-51, 2025-41 I.R.B. 448 2025-52, 2025-41 I.R.B. 474 2025-54, 2025-41 I.R.B. 479 2025-46, 2025-43 I.R.B. 533 2025-50, 2025-43 I.R.B. 542 2025-53, 2025-43 I.R.B. 624 2025-55, 2025-43 I.R.B. 625 2025-49, 2025-44 I.R.B. 627 2025-57, 2025-45 I.R.B. 692 2025-61, 2025-45 I.R.B. 693 2025-63, 2025-46 I.R.B. 709 2025-65, 2025-47 I.R.B. 717 2025-62, 2025-48 I.R.B. 740 2025-67, 2025-49 I.R.B. 761

Proposed Regulations:

REG-125710-18, 2025-30 I.R.B. 263 REG-107459-24, 2025-32 I.R.B. 313 REG-132805-17, 2025-35 I.R.B. 342 REG-108822-25, 2025-36 I.R.B. 361 REG-129260-16, 2025-39 I.R.B. 410 REG-108673-25, 2025-42 I.R.B. 494 REG-110032-25, 2025-42 I.R.B. 495 REG-112261-24; REG-116085-23, 2025-42 I.R.B. 522 REG-109742-25, 2025-46 I.R.B. 712

Revenue Procedures:

2025-22, 2025-30 I.R.B. 200 2025-24, 2025-31 I.R.B. 273 2025-25, 2025-32 I.R.B. 311 2025-26, 2025-33 I.R.B. 315 2025-28, 2025-38 I.R.B. 393 2025-30, 2025-42 I.R.B. 489 2025-27, 2025-44 I.R.B. 646 2025-32, 2025-45 I.R.B. 695 2025-31, 2025-48 I.R.B. 743

Revenue Rulings:

2025-13, 2025-28 I.R.B. 11 2025-14, 2025-32 I.R.B. 300 2025-15, 2025-32 I.R.B. 302 2025-16, 2025-35 I.R.B. 342 2025-17, 2025-36 I.R.B. 349 2025-18, 2025-37 I.R.B. 365 2025-19, 2025-41 I.R.B. 445 2025-20, 2025-41 I.R.B. 447 2025-21, 2025-45 I.R.B. 690 2025-22, 2025-48 I.R.B. 719 2025-23, 2025-48 I.R.B. 749

Treasury Decisions:

10021, 2025-31 I.R.B. 264 10031, 2025-32 I.R.B. 304 10033, 2025-40 I.R.B. 411 10035, 2025-42 I.R.B. 484 10034, 2025-43 I.R.B. 523 10036, 2025-43 I.R.B. 525

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin 2025–52, dated December 22, 2025.

December 1, 2025 ii Bulletin No. 2025–49

Finding List of Current Actions on Previously Published Items ¹

Bulletin 2025–49

1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin 2025–52, dated December 22, 2025.

Bulletin No. 2025–49 iii December 1, 2025

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