IRS Bulletin 2025-27 highlights digital asset backup withholding relief, corporate bond rates, and updates on oil recovery and marginal well credits.
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ADMINISTRATIVE
Notice 2025-33, page 4.
This notice extends the transitional relief from backup withholding taxes and associated penalties in Notice 2024-56 for any broker that fails to withhold and pay the backup withholding tax for: (1) any sale of a digital asset effected by a broker during calendar year 2026; and, (2) any sale of a digital asset effected by a broker during calendar year 2027 for a customer, if the broker submits that customer’s name and tax identification number (TIN) combination to the IRS’s TIN Matching Program and receives a response that the name and TIN combination matches IRS records. This notice also extends the transitional relief from penalties in Notice 2024-56 for brokers who fail to backup withhold and pay the full backup withholding tax due, if such failure is due to a decrease in the value of withheld digital assets in a sale of digital assets in return for different digital assets effected during calendar year 2027, and the broker immediately liquidates the withheld digital assets for cash. Finally, this notice also provides new transitional relief from information reporting penalties and from backup withholding taxes and associated penalties for any sale of a digital asset effected by a broker during calendar year 2027 for certain customers that have not been previously classified by the broker as U.S. persons.
ADMINISTRATIVE
Notice 2025-35, page 8.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for June 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
INCOME TAX
Notice 2025-32, page 1.
The notice announces the inflation adjustment factor and phase-out amount for the enhanced oil recovery credit for taxable years beginning in the 2025 calendar year. The notice concludes that because the reference price for the 2024 calendar year ($74.48) exceeds $28 multiplied by the inflation adjustment factor for the 2025 calendar year ($28 multiplied by 2.1115 = $59.12) by $15.36, the enhanced oil recovery credit for qualified costs paid or incurred in 2025 is phased out completely.
Notice 2025-34, page 6.
The notice provides the applicable reference price for qualified natural gas production from qualified marginal wells during taxable years beginning in calendar year 2025 for the purpose of determining the marginal well production credit under IRC § 45I. The applicable reference price for taxable years beginning in calendar year 2025 is $1.64 per 1,000 cubic feet. The notice also provides the credit amount used for the purpose of determining the marginal well production credit. The credit amount for taxable years beginning in calendar year 2025 is $0.79 per 1,000 cubic feet.