Notice 2025-70, page 773.

In anticipation of issuing proposed regulations to implement new § 25F of the Internal Revenue Code, as added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), this notice requests comments regarding issues arising under § 25F that should be addressed in guidance. This notice emphasizes issues on which guidance is most quickly needed, including issues relating to the annual certification by a State, as well as scholarship granting organization requirements.