Highlights of Internal Revenue Bulletin 2025-50– 12/8/2025

Highlights of Internal Revenue Bulletin 2025-50– 12/8/2025

In this article, we highlight key items from Internal Revenue Bulletin 2025-50, including OPR announcements, employment tax guidance under OBBBA, energy credit allocations, and income tax updates.

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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

Announcement 2025-29, page 785.

The Office of Professional Responsibility (OPR) announces recent disciplinary sanctions imposed on attorneys, certified public accountants, enrolled agents, enrolled actuaries, enrolled retirement plan agents, and appraisers. The OPR also announces when certain unenrolled, unlicensed tax return preparers (individuals who are not enrolled to practice before the Internal Revenue Service (IRS) and are not licensed as attorneys or certified public accountants) have been disciplined. Licensed or enrolled practitioners are subject to the regulations governing practice before the IRS, which are set out in Title 31, Code of Federal Regulations, Subtitle A, Part 10, and which are released as Treasury Department Circular No. 230. The regulations prescribe the duties and restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations. Unenrolled/unlicensed return preparers who choose to participate in the IRS’s voluntary Annual Filing Season Program (AFSP) are subject to the guidance in Revenue Procedure 2014-42, which governs a preparer’s eligibility to represent taxpayers before the IRS in examinations of tax returns the preparer both prepared for the taxpayer and signed as the preparer. Additionally, unenrolled/unlicensed return preparers who participate in the AFSP agree to be subject to the duties and restrictions in Circular 230, including the restrictions on incompetence or disreputable conduct.

EMPLOYMENT TAX

Notice 2025-69, page 766.

Notice 2025-69 provides guidance to individual taxpayers who are eligible for the federal income tax deductions for qualified tips or qualified overtime compensation for tax year 2025. These new deductions were added by Public Law 119- 21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). As part of the phased implementation of the OBBBA, there will be no changes to the 2025 Form W-2, Form 1099-NEC, Form 1099-MISC, or Form 1099-K to account for the new reporting requirements in the OBBBA. As a result, employers and other payors will not be required to separately account for cash tips or qualified overtime compensation on those forms furnished to individuals for 2025. In the absence of this information reporting, this Notice provides guidance for individual taxpayers on how to satisfy the requirements for the deductions, including how to determine the amount of the qualified tips or qualified overtime compensation, for tax year 2025. This Notice also provides transition relief for taxpayers regarding the requirement that qualified tips must not be received in the course of a trade or business that is a specified service trade or business. This Notice does not affect any rights or responsibilities regarding tips or overtime compensation under the Fair Labor Standards Act of 1938, as amended.

INCOME TAX

Announcement 2025-22, page 783.

Section 48C(e)(1) directs the Secretary to establish the § 48C(e) program to consider and award certifications for qualified investments eligible for § 48C credits to qualifying advanced energy project sponsors. Section 48C(e)(7) provides that upon making a certification under § 48C(e), the Secretary is required to disclose publicly the identity of the applicant and the amount of the § 48C credit certified with respect to such applicant. Notice 2023-18 established the program under § 48C(e)(1). The Treasury Department and the IRS provided two allocation rounds. For Round 1, the IRS allocated approximately $4 billion. Round 1 allocation notification letters were issued on March 29, 2024. Announcement 2025-22 provides the identity of each taxpayer and the amount of the § 48C credits allocated to each taxpayer with respect to projects that have been allocated a § 48C credit and for which a certification was issued during the period beginning on March 29, 2024, and September 30, 2025. The announcement also provides that the IRS will publish additional such announcements annually for certifications issued during each successive 12-month period beginning on October 1, 2025.

Announcement 2025-23, page 784. 

Section 48C(e)(1) directs the Secretary to establish the § 48C(e) program to consider and award certifications for qualified investments eligible for § 48C credits to qualifying advanced energy project sponsors. Section 48C(e)(7) provides that upon making a certification under § 48C(e), the Secretary is required to disclose publicly the identity of the applicant and the amount of the § 48C credit certified with respect to such applicant. Notice 2023-18 established the program under § 48C(e)(1). The Treasury Department and the IRS provided two allocation rounds. For Round 2, the IRS allocated approximately $6 billion. Round 2 allocation notification letters were issued on January 10, 2025. Announcement 2025-23 provides the identity of each taxpayer and the amount of the § 48C credits allocated to each taxpayer with respect to projects that have been allocated a § 48C credit and for which a certification was issued during the period beginning on January 10, 2025, and September 30, 2025. The announcement also provides that the IRS will publish additional such announcements annually for certifications issued during each successive 12-month period beginning on October 1, 2025.

Notice 2025-70, page 773. 

In anticipation of issuing proposed regulations to implement new § 25F of the Internal Revenue Code, as added by § 70411 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), this notice requests comments regarding issues arising under § 25F that should be addressed in guidance. This notice emphasizes issues on which guidance is most quickly needed, including issues relating to the annual certification by a State, as well as scholarship granting organization requirements.

Notice 2025-71, page 779. 

This notice provides interim rules under section 139L, which was added to the Code by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA). This notice clarifies the partial exclusion from gross income of interest received by qualified lenders on loans secured by rural or agricultural property. The interim guidance defines key terms from section 139L, establishes standards for determining whether a loan is secured by rural or agricultural property, and provides rules regarding refinancings.

 

Rev. Rul. 2025-24, page 764.

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 December 2025

 

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