In this week’s IRS Bulletin 2025-43, learn about new guidance on Corporate AMT, excise tax relief, rural area rules, low-income housing credit updates, and Israel relief.
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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, INCOME TAX
Notice 2025-46, page 533.
This notice provides interim guidance regarding the application of the Corporate Alternative Minimum Tax to domestic corporate transactions, financially troubled companies, and tax consolidated groups.
EXCISE TAX
Notice 2025-55, page 625.
This notice provides relief for the first three calendar quarters of 2026 regarding the failure to deposit penalties imposed by section 6656 of the Internal Revenue Code (Code) as those penalties relate to the remittance transfer excise tax imposed by section 4475 of the Code. This notice also provides that a remittance transfer provider’s ability to use the deposit safe harbor under § 40.6302(c)-1(b)(2) of the Excise Tax Procedural Regulations (26 CFR part 40) (part 40) will not be affected by a failure during the first three calendar quarters of 2026 to make deposits of the remittance transfer tax as required under part 40, provided the remittance transfer provider satisfies the reasonable cause standard for those quarters.
INCOME TAX
Notice 2025-50, page 542.
This notice provides a definition for “rural area” under § 1400Z-2(b)(2)(C)(ii) of the Internal Revenue Code (Code), as amended by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). This notice is also intended to provide guidance to taxpayers applying the substantial improvement provisions of § 1400Z-2(d)(2)(D)(ii), as amended by OBBBA.
T.D. 10034, page 523.
This document contains final regulations that remove the associated property rule and similar rules from the existing regulations regarding the interest capitalization requirements for improvements to designated property. In addition, this document contains final regulations that modify the definition of “improvement” for purposes of applying those existing regulations. Lastly, this document contains final regulations that modify other rules in those existing regulations in light of the removal of the associated property rule. The final regulations affect taxpayers making improvements to real or tangible personal property that constitute the production of designated property.
T.D. 10036, page 525.
These final regulations provide recordkeeping and reporting requirements for the average income test for purposes of the section 42 low-income housing credit. If a building is part of a residential rental project that satisfies this test, the building may be eligible to earn low-income housing credits. These final regulations affect owners of low-income housing projects and State or local housing credit agencies that monitor compliance with the requirements for low-income housing credits.
SPECIAL ANNOUNCEMENT
Notice 2025-53, page 624.
This notice grants relief under section 7508A for persons that the Secretary of the Treasury has determined to be affected by the 2024-2025 terroristic action in the State of Israel. The notice postpones deadlines for certain time-sensitive taxpayer acts, such as filing and paying taxes, and government acts, such as assessing and collecting taxes, for affected taxpayers for a full year, until September 30, 2026. The covered area includes the State of Israel, the West Bank and Gaza. The separate determination of terroristic action and grant of relief in this notice will also postpone the taxpayer acts and government acts that were postponed by Notice 2024-72 (or by both Notice 2024-72 and Notice 2023-71) until September 30, 2026, for taxpayers eligible for relief under both (or all) notices.