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IRS roundup: August 12 – August 20, 2025

by , , , and | Aug 27, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for August 12, 2025 – August 20, 2025.

IRS guidance

August 15, 2025: The IRS issued Notice 2025-42, providing guidance consistent with Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy. This notice specifically provided guidance on when construction of an applicable wind facility or solar facility has begun, which determines whether that facility is subject to the credit termination provisions added to Internal Revenue Code §§ 45Y and 48E by §§ 70512 and 70513 of Public Law 119-21, also known as the One Big Beautiful Bill Act.

August 18, 2025: The IRS issued Notice 2025-43, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates in Code § 417(e)(3), and the 24-month average segment rate in Code § 430(h)(2). This notice also provides guidance on the interest rate on 30-year Treasury securities in Code § 417(e)(3)(A)(ii)(II) for plan years commencing prior to 2008, as well as the 30-year Treasury weighted average rate in Code § 431(c)(6)(E)(ii)(I).

August 18, 2025: The IRS issued Revenue Ruling 2025-17, providing prescribed rates for federal income tax for September 2025, including:

  • The short-, mid-, and long-term applicable federal rates (AFRs) for purposes of Code § 1274(d).
  • The short-, mid-, and long-term adjusted AFRs for purposes of Code § 1288(b).
  • The adjusted long-term rate and the long-term tax-exempt rate from Code § 382(f).
  • The appropriate percentages for determining the low-income housing credit under Code § 42(b)(1) for buildings placed in service during September 2025.
  • The federal rate for determining the present value of an annuity, an interest for life, a term of years, or a remainder or a reversionary interest under Code § 7520.

August 19, 2025: The IRS issued Notice 2025-45, announcing its intent to issue proposed regulations under Code §§ 897(d) and (e), which would modify the application of Treas. Regs. §§ 1.897-5T and 1.897-6T to certain transactions involving the transfer of US real property interests. The proposed regulations would also revise rules applying to inbound asset reorganizations in Code § 368(a)(1)(F). This notice also announced the US Department of the Treasury and IRS’s intent to issue proposed regulations, revising Treas. Reg. § 1.368-2(m) and clarifying that qualification as a potential F reorganization under § 368(a)(1)(F) would not be affected by a disposition of stock.

August 20, 2025: The IRS issued Notice 2025-44, requesting comments on certain dual consolidated loss (DCL) rules and announcing its intent to issue proposed regulations removing (see our discussion of the notice in this On the Subject):

  • The disregarded payment loss rules in Treas. Reg. § 1.1503(d)-1(d).
  • Recent modifications to the DCL rules in Code § 1503(d) as they relate to the deemed ordering rules under Trea. Reg. § 1.1503(d)-3(c)(3).

The proposed regulations would also [...]

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IRS roundup: July 12 – July 29, 2025

by , , , and | Aug 15, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025.

IRS guidance 

July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for federal income tax purposes for August 2025, including but not limited to:

  • Short-, mid-, and long-term applicable federal rates for August 2025 for purposes of Internal Revenue Code (Code) Section 1274(d).
  • Short-, mid-, and long-term adjusted applicable federal rates for August 2025 for purposes of Code Section 1288(b).
  • The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code Section 382(f).
  • The appropriate percentages for determining the low-income housing credit described in Section 42(b)(1) for buildings placed in service during the current month.
  • The federal rate for determining the present value of an annuity, an interest for life, a term of years, a remainder, or a reversionary interest for purposes of Code Section 7520.

July 15, 2025: The IRS issued Notice 2025-39, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Code Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code Section 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code Section 431(c)(6)(E)(ii)(I).

July 16, 2025: The IRS issued Revenue Ruling 2025-15, clarifying certain withholding and reporting requirements with respect to uncashed retirement plan distribution checks. The IRS held that no adjustment or refund is available under Sections 6413 and 6414 with respect to amounts withheld and remitted when more than the correct amount of tax was not withheld or paid.

July 16, 2025: The IRS issued Notice 2025-40, providing updated static mortality tables for defined benefit pension plans under Code Section 430(h)(3)(A) and Section 303(h)(3)(A) of the Employee Retirement Income Security Act of 1974 (ERISA). These updated static mortality tables apply for purposes of calculating the funding target and other items for valuation dates occurring during the 2026 calendar year.

The notice also includes a modified unisex version of the mortality tables for determining the minimum present value under ERISA Sections 417(e)(3) and 205(g)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2026 calendar year. 

July 21, 2025: The IRS issued Notice 2025-36, identifying and making obsolete 83 Internal Revenue Bulletin guidance documents. The notice cites Executive Order 14192, Unleashing Prosperity Through Deregulation, which directed agencies to identify regulations to be repealed and other guidance that are appropriate for withdrawal. The 83 obsolete regulations span multiple contexts and Code sections.

July 21, 2025: The IRS issued Notice 2025-37, which includes the inflation adjustment factors and applicable amounts for calendar year 2025 for the zero-emission nuclear power production credit under Code Section 45U. It [...]

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IRS roundup: June 18 – July 11, 2025

by , , , and | Jul 15, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025.

“One Big Beautiful Bill Act” tax provisions

On July 4, 2025, US President Donald Trump signed the “One Big Beautiful Bill Act” (OBBBA) into law, which enacted several changes to federal tax law. Some of the key changes that affect IRS administration and/or federal tax procedure include:

  • Form 1099-NEC reporting threshold. The reporting threshold for payments to non-employees for personal services will be raised from $600 to $2,000 beginning in 2026. While amounts below the threshold will still constitute income subject to taxation, an employer will not be subject to backup withholding requirements or be required to issue a Form 1099 if the total value of the services provided cost less than $2,000.
  • Controlled foreign corporations (CFCs). The look-through rule for CFCs under Internal Revenue Code Section 954 is permanently extended. New Section 951B extends the CFC inclusion rules to “foreign controlled US shareholders” of foreign-controlled CFCs (the US shareholder must own more than 50% by value or vote of the foreign corporation to be designated as such). The tax law also creates a one-month deferral election for determining a CFC’s tax year.
  • Opportunity zone designation. The OBBBA establishes a permanent opportunity zone policy, maintaining current designation guidelines. For investors with investments made after December 31, 2026, gains deferred via investment in the Qualified Opportunity Zone program will now be recognized on the fifth anniversary of the investment date.

Additionally, the OBBBA introduces a detailed reporting regime as included in new Code Sections 6039K and 6039L. A penalty provision in Code Section 6726 is also included to improve oversight and transparency regarding the economic impact of qualified opportunity investments. The reporting penalties can be as high as $10,000 per return or up to $50,000 for qualified opportunity funds with assets worth more than $10 million. The US Department of the Treasury must publish annual reports on opportunity zone investments and economic performance of the designated tracts.

  • Employee Retention Credit (ERC) update. Pending ERC claims filed after January 31, 2024, for the third or fourth quarters of 2021 are disallowed under the tax law. The statute of limitations on assessment for ERC (i.e., the period during which the IRS may recapture ERC through assessment) was also extended to six years. The OBBBA also imposes penalties on ERC promoters who fail to comply with due diligence requirements and demonstrate that they did not facilitate the making of fraudulent claims.

IRS guidance

June 23, 2025: The IRS issued Notice 2025-30, publishing the inflation adjustment factor and reference price for calendar year 2025 for the renewable electricity production credit under Code Section 45. The inflation adjustment factor for calendar year 2025 for qualified energy resources is 1.9971, and the reference price for calendar year 2025 for facilities producing electricity from wind is 3.1 cents per [...]

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IRS roundup: June 3 – 17, 2025

by , , , and | Jun 26, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 3, 2025 – June 17, 2025.

Commissioner update

June 16, 2025: Billy Long was sworn in as the 51st IRS Commissioner after having been confirmed by the US Senate on June 12. Long served as a US Representative for Missouri’s 7th congressional district from 2011 to 2023. His term will run through November 12, 2027.

IRS guidance

June 12, 2025: The IRS has announced that it is experiencing a delay in processing electronic payments and that some taxpayers are receiving notices indicating a balance due even though payments were timely made.

Taxpayers who receive a balance due notice but electronically paid the tax they owed in full and on time do not need to respond. The IRS has said that any associated penalties and interest will be automatically adjusted once the payment(s) are applied correctly.

June 12, 2025: The IRS released Tax Tip 2025-39, reminding businesses about the Childcare Tax Credit. Taxpayers may receive a credit of up to $150,000 per year to offset 10% of qualified childcare resource and referral costs and 25% of qualified childcare facility costs.

To be eligible for the credit, an employer must have paid or incurred qualified childcare costs during the tax year to provide childcare services to employees. Employers should complete Form 8882, Credit for Employer-Provided Childcare Facilities and Services, to claim the credit. The credit is subject to the carryback and carryover rules for business credits.

June 12, 2025: The IRS issued Notice 2025-33, extending for an additional year the transitional relief provided in Sections 3.01, 3.02, and 3.06 of Notice 2024-59. Notice 2025-33 provides transitional relief from penalties with respect to certain information reporting obligations under Section 6045 and provides transitional relief from the liability for the payment of backup withholding tax required to be withheld under Section 3406 and its accompanying regulators.

This notice also provides transitional relief from penalties for brokers who fail to pay that tax with respect to certain sales of digital assets required to be reported under Section 6045, as well as a digital asset sale relief for certain customers that have not been previously classified by the broker as US persons.

June 13, 2025: The IRS issued Notice 2025-35, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code Section 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code Section 431(c)(6)(E)(ii)(I).

June 17, 2025: The IRS issued Revenue Ruling 2025-13, providing prescribed rates for federal income tax purposes for July 2025, including but not limited to:



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IRS Roundup May 15 – June 2, 2025

by , , , and | Jun 5, 2025 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025.

IRS GUIDANCE

May 15, 2025: The IRS issued Notice 2025-29, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) § 417(e)(3), and the 24-month average segment rates under Code § 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code § 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code § 431(c)(6)(E)(ii)(I).

May 15, 2025: The IRS issued Revenue Ruling 2025-12, providing prescribed rates for federal income tax purposes for June 2025, including, but not limited to:

  1. Short-, mid-, and long-term applicable federal rates for June 2025 for purposes of Code § 1274(d)
  2. Short-, mid-, and long-term adjusted applicable federal rates for June 2025 for purposes of Code § 1288(b)
  3. The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code § 382(f)
  4. The federal rate for determining the present value of an annuity, an interest for life, or for a term of years, or a remainder or a reversionary interest for purposes of Code § 7520.

May 19, 2025: The IRS released Internal Revenue Bulletin 2025-21. It includes Revenue Procedure 2025-19, which provides the 2026 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under Code § 223, as well as the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements under Code § 54.9831-1(c)(3)(viii). Revenue Procedure 2025-19 is effective for HSAs for the 2026 calendar year and for excepted benefit health reimbursement arrangements beginning in 2026.

May 22, 2025: The IRS issued a notice to US taxpayers living or working abroad, encouraging them to file their 2024 federal income tax returns by June 16, 2025.

June 2, 2025: The IRS issued Notice 2025-27, providing interim guidance on the application of the corporate alternative minimum tax (CAMT), as well as relief from certain additions to tax for a corporation’s underpayment of estimated tax under Code § 6655. Among other things, this notice also provides an optional simplified method for determining applicable corporation status and waives certain additions to tax under Code § 6655 concerning a corporation’s CAMT liability under Code § 55. The US Department of the Treasury (Treasury) and the IRS also plan on issuing a notice of proposed rulemaking, revising the CAMT proposed regulations in § 2.02(2) of this notice to include a method for determining applicable corporation status.

The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).

TAX CONTROVERSY DEVELOPMENTS

On May 22, 2025, the US Tax Court issued its opinion in Facebook Inc. v. Commissioner.

THE “BIG, BEAUTIFUL BILL”

The “
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“Big, Beautiful Bill”: Federal Tax Bill Would Restrict the Employee Retention Credit

by , and | May 20, 2025 |

A sweeping federal tax bill that is currently under consideration in the US House of Representatives contains provisions that would significantly change the administration and enforcement of the Employee Retention Credit (ERC).

The ERC was enacted in 2020 as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial relief to businesses affected by the COVID-19 pandemic by incentivizing employers to retain employees on payroll and rehire displaced workers. The ERC allowed employers that experienced significant disruptions due to government orders or a substantial decline in gross receipts to claim a tax credit equal to a percentage of qualified wages paid to employees. Millions of employers have filed refund claims seeking ERC for periods in 2020 and 2021. Since the enactment of the CARES Act, the Internal Revenue Service (IRS) has issued roughly $250 billion in ERC. More than 500,000 claims remained pending as of April 2025.

The federal tax bill, dubbed the “Big, Beautiful Bill” by US President Donald Trump, would prevent the IRS from allowing ERC that was claimed by a taxpayer on or before January 31, 2024. The deadline to claim ERC for taxable quarters in 2020 was April 15, 2024, and the deadline to claim ERC for taxable quarters in 2021 was April 15, 2025. The tax bill would thus appear to render ineligible all pending claims that were made after January 31, 2024, which are likely to be considerable in number. The bill is ambiguous as to whether taxpayers who have already been allowed ERC would need to repay those amounts to the extent their claims were made after January 31, 2024.

The tax bill would also extend the statute of limitations on the IRS’s ability to assess amounts attributable to ERC. Presently, the IRS has three years to assess amounts associated with ERC for all periods in 2020 and for Q1 and Q2 of 2021. The IRS has five years to assess amounts associated with ERC for Q3 and Q4 of 2021. The proposed legislation would extend both of these limitations periods to six years. This change would be significant, especially because the IRS is authorized to assess and collect erroneously allowed ERC by notice and demand.

Practice Point: Taxpayers with pending ERC claims should be alert to ongoing legislative developments – as this area continues to be a prominent focus of federal tax policy – and prepare now to defend ERC claims (even those filed after the potentially new deadline of January 31, 2024). Enactment of the changes proposed in the tax bill could dramatically restrict the amount of ERC currently eligible to be paid or credited and may empower the IRS to recapture a greater amount of claims already allowed. But considerable uncertainties remain as to the scope of the changes proposed in the bill. In the face of this uncertainty, taxpayers should consult experienced counsel who can assist them in preparing to defend ERC claims to which they are entitled.



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IRS Roundup May 2 – May 13, 2025

by , , , and | May 19, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 2, 2025 – May 13, 2025.

IRS GUIDANCE

May 2, 2025: The IRS issued Revenue Procedure 2025-20, providing guidance on the domestic asset/liability percentages and domestic investment yields used by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Section 842(b) of the Internal Revenue Code (Code) for taxable years beginning after December 31, 2023.

May 5, 2025: The IRS released Internal Revenue Bulletin 2025-19, which includes Revenue Ruling 2025-10 and Revenue Procedure 2025-18.

Revenue Ruling 2025-10 provides various prescribed rates for federal income tax purposes for May 2025, including:

  • The short-, mid-, and long-term applicable federal rates for purposes of Code Section 1274(d).
  • The short-, mid-, and long-term adjusted applicable federal rates for purposes of Code Section 1288(b).
  • The adjusted federal long-term rate and the long-term tax-exempt rate from Code Section 382(f).
  • The appropriate percentages for determining the low-income housing credit from Code Section 42(b)(1) (but only for buildings placed in service during May 2025).
  • The federal rate for determining the present value of an annuity, an interest for life or for a term of years, or a remainder or a reversionary interest for purposes of Code Section 752.

Revenue Procedure 2025-18 provides issuers of qualified mortgage bonds (defined in Code Section 143(a)) and mortgage credit certificates (defined in Code Section 25(c)) with guidance related to nationwide purchase prices for residences, as well as the average area purchase price for residences located in statistical areas in each US state, the District of Columbia, Puerto Rico, the Northern Mariana Islands, American Samoa, the Virgin Islands, and Guam.

May 6, 2025: The IRS issued Revenue Procedure 2025-21, modifying Section 12 of Revenue Procedure 2024-32.

Executive Order 14219, issued through the Department of Government Efficiency’s deregulatory initiative, directed agencies to initiate a review process for identification and removal of certain regulations and guidance. Pursuant to Executive Order 14219, the US Department of the Treasury and the IRS identified Section 12 of Revenue Procedure 2024-32 as a regulation needing modification.

Revenue Procedure 2024-32 specifies the procedure by which the sponsor of a defined benefit plan, which is subject to the funding requirements of Code Section 430, may request approval from the IRS for the use of plan-specific substitute mortality tables. Section 12.02 of Revenue Procedure 2024-32 specifies that if a plan sponsor wishes to use plan-specific mortality tables, it must develop and request approval for the use of new plan-specific mortality tables for plan years beginning on or after January 1, 2026. Revenue Procedure 2025-21 provides immediate relief for some of those plan sponsors by narrowing the category of plan sponsors that must request approval of new plan-specific substitute mortality tables.

May 12, 2025: The IRS issued Revenue Ruling 2025-11, determining the interest rates [...]

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IRS Roundup April 1 – April 17, 2025

by , , , and | May 1, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 1, 2025 – April 17, 2025.

April 4, 2025: The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax issues that should be addressed via regulations, revenue rulings, revenue procedures, notices, and other published administrative guidance. A list of factors the IRS considers when selecting projects for inclusion is outlined in the notice.

April 9, 2025: The US Department of the Treasury (Treasury), along with the IRS and the Financial Crimes Enforcement Network, eliminated 15 rules and guidance materials, in addition to two rules already rescinded by the Office of the Comptroller of the Currency. The stated purpose of these actions was to remove rules that the government says are now obsolete and hamper the growth of US small businesses. These actions were some of the many that the Treasury says it will take over the next several months to eliminate unnecessary IRS rules and to “unleash the regulated banking sector.”

April 10, 2025: US President Donald Trump signed legislation blocking an IRS reporting rule that would have required decentralized digital asset platforms to report statistics showing customers’ gross sales on their platforms.

April 11, 2025: The IRS issued Notice 2025-24, providing penalty relief under Section 6707A(a) of the Internal Revenue Code to participants in micro-captive reportable transactions that fail to timely file (i.e., by April 14, 2025) certain disclosure statements as required under Section 6011; Treas. Reg. §§ 1.6011-10(h)(2) or 1.6011-11(h)(2); Section 6111; and Treas. Reg. §§ 1.6011-10(h)(3) or 1.6011-11(h)(3)). Participants will only qualify for relief if they file the required disclosure statement with the Office of Tax Shelter Analysis by July 31, 2025.

April 14, 2025: The IRS issued Notice 2025-22, providing for the elimination of extraneous and unnecessary Internal Revenue Bulletin guidance. This notice was prompted by the issuance of Executive Order 14219 on February 19, 2025. The purpose of Executive Order 14219 is to focus the IRS’s limited enforcement resources on regulations “squarely authorized by constitutional Federal statutes” while eliminating “overbearing and burdensome” regulations and “ending Federal overreach.” In Notice 2025-22, the IRS eliminated several current sources of guidance and stated that it anticipates revoking or obsoleting hundreds of similar guidance documents in the near future.

April 15, 2025: The IRS issued Notice 2025-21, providing updates on the corporate bond monthly yield curve, spot segment rates used under § 417(e)(3), and the 24-month average segment rates under § 430(h)(2) of the Code. This notice also provides guidance on the interest rates for 30-year Treasury securities and the 30-year Treasury weighted average for plan years beginning before 2008.

April 17, 2025: The IRS issued Notice 2025-23, announcing its intent to publish a notice of proposed rulemaking, proposing [...]

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IRS Roundup March 15 – March 28, 2025

by , , , , and | Apr 7, 2025 | , ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025.

IRS GUIDANCE

March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing the April 2025 short-, mid-, and long-term applicable federal rates for purposes of Internal Revenue Code Section 1274(d), as well as other provisions.

March 21, 2025: The IRS released Announcement 2025-8, which displays a copy of the competent authority arrangement entered into by the United States and Switzerland under paragraph 3 of Article 25 of the Convention Between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation. The agreement details US and Swiss pension and retirement arrangements, including individual retirement savings plans that may be eligible for benefits.

March 21, 2025: The IRS issued Private Letter Ruling 202512002, concluding that a trust was properly classified as a “liquidating trust” for federal tax purposes, despite several extensions of the trust’s term. Pursuant to Revenue Procedure 94-45, a trust instrument must contain a fixed or determinable termination date, which is usually not more than five years from the date of the trust’s creation. However, Revenue Procedure 94-45 also provides that, if warranted by the facts and circumstances, a trust’s term may be extended for a finite time, subject to the approval of the bankruptcy court with jurisdiction over the case.

The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).

TRANSFER PRICING

March 27, 2025: The IRS released its annual report on advance pricing agreements (APAs) for 2024 as part of its Advance Pricing and Mutual Agreement Program. The report summarized key APA trends and statistics, including the number of applications filed, pending APAs, and executed APAs. The report also details APA trends and statistics executed by country and by industry and provides a breakdown of the types of transactions covered by APAs, the transfer pricing methods used, and other APA characteristics from 2024.



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IRS Roundup February 10 – 14, 2025

by , , and | Feb 25, 2025 | ,

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 10, 2025 – February 14, 2025.

TAX-CONTROVERSY-RELATED DEVELOPMENTS

The previous IRS Roundup provided general coverage of the proposed Taxpayer Assistance and Service (TAS) Act. This post highlights Section 310 of the TAS Act, which would give the US Tax Court authority to hear general refund suits similar to those currently heard in the US district courts and the US Court of Federal Claims.

Historically, taxpayers could only contest their tax liability by first paying the tax and then suing for a refund in a district court or the Court of Federal Claims. The Board of Tax Appeals (BTA), the forerunner to the Tax Court, was created in 1924 to give taxpayers a prepayment forum in which to dispute their tax liability. The BTA was initially proposed to have general refund suit jurisdiction, but Congress limited its jurisdiction to cases brought in response to a notice of deficiency. Several proposals have been made over the years to expand the jurisdiction of the BTA and (now) the Tax Court to include general refund suits, which they would share with the district courts and the Court of Federal Claims. Recent support for this approach has come from National Taxpayer Advocates Nina Olson and Erin Collins. As one commentator noted, the proposed expansion to the Tax Court’s jurisdiction has the potential to improve access to justice for taxpayers and reduce the burden on district courts and the Court of Federal Claims.

IRS GUIDANCE

February 12, 2025: The IRS issued Revenue Procedure 2015-16, which provides depreciation deduction limitations for “passenger automobiles” (including trucks and vans) placed in service during 2025 and income inclusion amounts for lessees of such vehicles. The revenue procedure also includes two tables detailing depreciation limits based on whether the Internal Revenue Code (Code) § 168(k) additional first-year depreciation deduction applies. Additionally, the revenue procedure outlines the inflation adjustment calculation for these limits and provides a table for determining income inclusions for leased passenger automobiles. The tables reflect the automobile price inflation adjustments required by Code § 280F(d)(7).

February 12, 2025: The IRS released Notice 2025-14, which provides guidance on the corporate bond monthly yield curve, spot segment rates under Code § 417(e)(3), and 24-month average segment rates under Code § 430(h)(2). The notice also provides guidance as to the interest rate on 30-year Treasury securities under Code § 417(e)(3)(A)(ii)(II) as in effect for plan years beginning before 2008 and the 30-year Treasury weighted average rate under Code § 431(c)(6)(E)(ii)(I).

February 13, 2025: The IRS issued Revenue Procedure 2025-15, which provides discount factors for the 2024 accident year for insurance companies to use when computing discounted unpaid losses under Code § 846 and discounted estimated salvage recoverable under Code § 832. The revenue procedure includes tables with discount factors for various lines of business (both short- and long-tail) and addresses the use of [...]

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