IRS Bulletin 2025-37 covers Q4 interest rate updates, withdrawal of DPL rules, extended transition relief, and proposed regulations on U.S. real property transactions.
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ADMINISTRATIVE
Rev. Rul. 2025-18, page 365.
Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the calendar quarter beginning October 1, 2025, will be 7 percent for overpayments (6 percent in the case of a corporation), 7 percent for underpayments, and 9 percent for large corporate underpayments. The rate of interest paid on the portion of a corporate overpayment exceeding $10,000 will be 4.5 percent.
INCOME TAX
Notice 2025-44, page 386.
This notice announces a forthcoming withdrawal of the disregarded payment loss (“DPL”) rules under § 1.1503(d)-1(d). The DPL rules were finalized on January 14, 2025 and would have been applicable with respect to losses incurred in taxable years beginning on or after January 1, 2026. In addition, this notice announces an additional extension of the transition relief initially announced in Notice 2023-80 with respect to the interaction of the dual consolidated loss rules and the model rules published by the OECD/G20 Inclusive Framework on BEPS.
Notice 2025-45, page 388.
This notice announces that the Department of the Treasury and the Internal Revenue Service intend to issue proposed regulations under sections 897(d) and (e) to modify the rules under §§1.897-5T and 1.897-6T, Notice 89-85, 1989-2 C.B. 403, and Notice 2006-46, 2006-1 C.B. 1044, regarding certain transactions involving the transfer of United States real property interests. When issued, the regulations will propose to revise the rules that apply to certain inbound asset reorganizations under section 368(a) (1)(F) that constitute a “covered inbound F reorganization” as defined in section 3.02 of this notice. This notice also announces that the Department of the Treasury and the Internal Revenue Service intend to issue proposed regulations to revise §1.368-2(m) to clarify that qualification of a potential F reorganization (as defined in §1.368-2(m)(1)) as a reorganization under section 368(a)(1)(F) would not be affected by a disposition of stock in either the transferor corporation or the resulting corporation if that disposition is not included in the plan of reorganization.