This summary covers key administrative, employee plan, estate, excise, exempt organization, and income tax guidance in Internal Revenue Bulletin 2025-51.
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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
REG-124791-11, page 852.
This document withdraws a notice of proposed rulemaking regarding the eligibility of tax return preparers to obtain a preparer tax identification number (PTIN).
EMPLOYEE PLANS
Notice 2025-73, page 845.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for September 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for October 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
Notice 2025-74, page 848.
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for October 2025 used under § 417(e)(3)(D), the 24-month average segment rates applicable for November 2025, and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
ESTATE TAX
T.D. 10038, page 838.
This guidance contains a final rule relating to the imposition of a user fee on authorized persons requesting the issuance of IRS Letter 627, also referred to as an estate tax closing letter. Pursuant to the guidelines in OMB Circular A-25, the IRS has calculated its cost of providing the estate tax closing letter to be $56. REG-107459-24
EXCISE TAX
T.D. 10037, page 788.
Section 10201 of Public Law 117-169, 136 Stat. 1818 (August 16, 2022), commonly referred to as the Inflation Reduction Act of 2022, enacted section 4501 of the Internal Revenue Code. Section 4501 imposes a one percent excise tax on repurchases of stock of a publicly traded corporation. These final regulations under subpart A of part 58 contain operative rules that provide further clarity regarding the application of the excise tax to corporations that repurchase their stock.
EXEMPT ORGANIZATIONS
Announcement 2025-27, page 851.
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 2025-72, page 840.
This notice describes proposed regulations that Treasury and the IRS intend to issue under section 70352(c)(1)(C) of Public Law 119-21, 139. Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), providing for the allocation of foreign taxes of foreign corporations affected by the repeal of section 898(c)(2). This notice also announces that Treasury and the IRS intend to issue proposed regulations under section 987 that would modify the election to recognize pretransition section 987 gain or loss ratably over the transition period pursuant to §1.987-10(e)(5)(ii)(A).