SECTION 1. PURPOSE
Internal Revenue Bulletin 2025-50 · 2026-10-03 edition · updated 2026-10-04 · United States
The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations (forthcoming proposed regulations) to implement new § 25F of the Internal Revenue Code
21 The employee’s earning statement relating to the payroll period beginning on December 14, 2025, and ending on December 27, 2025, shows amounts that are not actually paid until January 6, 2026. Thus, it would not include any FLSA Overtime Premium paid in 2025.
22 See Fact Sheet #8: Law Enforcement and Fire Protection Employees Under the Fair Labor Standards Act (FLSA) | U.S. Department of Labor, https://www.dol.gov/agencies/whd/ fact-sheets/8-flsa-police-firefighters (last visited Oct. 28, 2025).
Bulletin No. 2025–50 773 December 8, 2025
(Code), 1 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). Section 25F provides a new credit for an individual’s qualified contribution to a scholarship granting organization (as defined in § 25F(c)(5)) (SGO) that provides qualified elementary and secondary scholarships. In anticipation of issuing the forthcoming proposed regulations, this notice requests comments regarding issues arising under § 25F that should be addressed in guidance, emphasizing issues on which guidance is most quickly needed, including issues relating to the annual certification by a State 2 and SGO requirements. Comments detailing factual situations that differ from those addressed in this notice, and the application of the statute to these factual situations, would be especially helpful in the development of the forthcoming proposed regulations.
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