This week's highlights include IRS guidance on micro-captive disclosure relief, mortgage bond safe harbors, employee plan rates, oil depletion deductions, and revocation of basis shift rules.
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The Internal Revenue Bulletin (IRB) is the authoritative instrument for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest.
ADMINISTRATIVE
Notice 2025-24, page 1429.
This notice provides relief from penalties under section 6707A(a) and 6707(a) for participants in and material advisors to micro-captive reportable transactions for disclosure statements required to be filed with the Office of Tax Shelter Analysis (OTSA) under sections 6011 and 6111, as set forth in §§ 1.6011-10(h)(2) and (3) and 1.6011- 11(h)(2) and (3), respectively. This relief applies only if the required disclosure statements are filed with OTSA by July 31, 2025.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2025-18, page 1430.
This Revenue Procedure provides issuers of qualified mortgage bonds and mortgage credit certificates with (1) the nationwide average purchase price for residences located in the United States, and (2) the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam.
EMPLOYEE PLANS
Notice 2025-21, page 1424.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for March 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for April 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
INCOME TAX
Notice 2025-20, page 1423.
This notice announces the applicable percentage under section 613A(c)(6)(C) for marginal oil and gas properties in the 2025 calendar year. The applicable percentage is used to determine the amount of the percentage depletion deduction allowable under section 613A(c)(6) with respect to oil and natural gas produced from marginal properties.
Notice 2025-23, page 1428.
Notice 2025-23 informs taxpayers and material advisors that final regulations regarding the identification of certain partnership related-party basis adjustment transactions as transactions of interest will be withdrawn through the forthcoming publication of proposed and final regulations and that they can rely on the notice for relief from applicable penalties for failure to file disclosure statements. In addition, Notice 2025-23 revokes Notice 2024-54, which informed taxpayers of intended proposed regulations that would provide substantive technical rules to discourage basis shifting among related partners.
Rev. Rul. 2025-10, page 1421.
Federal rates; adjusted federal rates; adjusted federal longterm rate, and the long-term tax-exempt rate. For purposes of sections 382, 1274, 1288, 7872 and other sections of the Code, tables set forth the rates for May 2025.
SPECIAL ANNOUNCEMENT
Notice 2025-22, page 1427.
This notice starts the process of eliminating extraneous and unnecessary Internal Revenue Bulletin (IRB) guidance by identifying and obsoleting nine IRB guidance documents.