In this release, we cover key highlights from IRS Bulletin 2025-48, including penalty relief for 2025 filers, updated 2026 interest rates, and new safe harbor rules for digital asset investment trusts.
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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 2025-62, page 740.
Notice 2025-62 provides penalty relief for taxable year 2025 in connection with the implementation of the new information reporting requirements related to the deductions for qualified tips and qualified overtime compensation that were added to the Internal Revenue Code (Code) by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). Specifically, this notice provides relief from the penalty under section 6721 for failure to file correct information returns and the penalty under section 6722 for failure to furnish correct payee statements. This relief applies only for taxable year 2025.
Rev. Rul. 2025-22, page 719.
Interest rates: underpayments and overpayments. The rates for interest determined under Section 6621 of the code for the calendar quarter beginning January 1, 2026, 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.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2025-31, page 743.
This revenue procedure describes a safe harbor for trusts that otherwise qualify as investment trusts under § 301.7701- 4(c) and as grantor trusts to stake their digital assets without jeopardizing their tax status as investment trusts and grantor trusts for Federal income tax purposes. This revenue procedure also provides a limited time period for an existing trust to amend its governing instrument to adopt the requirements of the safe harbor.