In this release, we cover highlights from IRS Bulletin 2025-36, including updates to partnership reporting, employment tax rates, exempt organization revocations, and renewable energy credit rules.
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ADMINISTRATIVE, INCOME TAX
REG-108822-25, page 361.
The proposed regulations modify information reporting obligations with respect to sales or exchanges of certain interests in partnerships owning inventory or unrealized receivables. Specifically, the proposed regulations would eliminate a regulatory requirement that partnerships furnish partners that bought or sold interests in the partnership certain computational information by January 31 of the year following the calendar year in which the sale or exchange occurred. As a result, the proposed regulations would result in partnerships having additional time (generally, until the due date of the partnership’s return) to compute and furnish such information.
EMPLOYMENT TAX
Notice 2025-43, page 356.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for August 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
EXEMPT ORGANIZATIONS
Announcement 2025-24, page 359.
The Internal Revenue Service has revoked its determination that Foundation for Those With Special Needs qualifies as an organization described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. The revocation is effective January 1, 2026.
Announcement 2025-25, page 360. Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).
INCOME TAX
Notice 2025-42, page 351.
This notice provides guidance regarding beginning of construction for qualified wind and solar facilities under §§ 45Y and 48E, as amended by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). Sections 70512(a) and 70513(a) of the OBBBA add new §§ 45Y(d)(4) and 48E(e)(4), respectively, to the Code which terminate the § 45Y credit and § 48E credit, respectively, for applicable wind and solar facilities placed in service after December 31, 2027. Sections 70512(l)(4) and 70513(g)(5) of the OBBBA provide that the amendments made by §§ 70512(a) and 70513(a) of the OBBBA, respectively, apply to facilities the construction of which begins after the date which is 12 months after the date of enactment of the OBBBA (July 4, 2026). This notice provides new “beginning of construction” guidance, consistent with Executive Order 14315, 90 FR 30821 (July 7, 2025), to strictly enforce when construction of an “applicable wind facility” or “applicable solar facility” (each as defined in section 2.02(1) of the notice) has begun solely for purposes of determining whether such facility is subject to credit termination provisions added to §§ 45Y and 48E of the Code by §§ 70512 and 70513 of the OBBBA.
Rev. Rul. 2025-17, page 349.
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 September 2025.