One Big Beautiful Bill Act Archives

IRS roundup: September 19 – October 1, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for September 19, 2025 – October 1, 2025.

September 19, 2025: The US Department of the Treasury (Treasury) and the IRS issued proposed regulations, providing guidance on the “no tax on tips” provision of the One Big Beautiful Bill Act. The proposed regulations define “qualified tips” and identify which occupations customarily and regularly receive tips on or before December 31, 2024.

September 23, 2025: The IRS issued Notice 2025-54, providing guidance on the 2025 – 2026 special per diem rates for taxpayers when determining their ordinary and necessary business expenses incurred while traveling away from home, including meal and incidental expenses rates, rates for the incidental expenses only deduction, and rates for (and a list of) high-cost localities for purposes of the high-low substantiation method.

September 29, 2025: The IRS issued Revenue Procedure 2025-30, providing updated procedures for taxpayers requesting private letter rulings from the IRS after September 29, 2025, regarding transactions intended to qualify under Internal Revenue Code § 3551. This guidance specially provides details on the representations, information, and analysis taxpayers should submit when requesting these rulings.

September 30, 2025: The IRS issued Notice 2025-46 and Notice 2025-49, providing guidance on the application of the corporate alternative minimum tax (CAMT).

Notice 2025-46 provides interim guidance to domestic corporate transactions, financially troubled companies, and tax consolidated groups. This notice also announces the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 6 of this notice. The proposed regulations will reduce compliance burdens related to, and costs associated with, application of the CAMT.

Notice 2025-49 provides interim guidance regarding application of the CAMT as it relates to §§ 55, 56A, and 59. This notice also announced the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 10 of this notice.

October 1, 2025: The Treasury and the IRS issued final regulations, providing guidance on interest capitalization requirements on designated property. The final regulations specifically remove the associated property rule (including similar rules in existing regulations), modifies how “improvement” is defined when applying those similar rules, and primarily affects taxpayers making improvements to real or tangible personal property if those improvements are the production of designated property.

October 1, 2025: The US Court of Appeals for the Eighth Circuit released its opinion in 3M Company v. Commissioner. The Eighth Circuit reversed the US Tax Court’s decision that 3M must pay taxes on royalties – that it could not legally receive – from a Brazilian subsidiary and remanded the Tax Court’s decision with instructions to redetermine 3M’s tax liability. Relying [...]

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IRS roundup: August 12 – August 20, 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):