Internal Revenue Bulletin 2025-44 (PDF rendition): IRS Revenue Procedures

Preserve advance releases and the authoritative Internal Revenue Bulletin rendition; directory timestamps are file-publication metadata, not legal effective dates. HTML bulletins begin June 2003; earlier available issues require full PDF parsing. Whole bulletin rendition: numbered items are identified below; other legal material and publisher context remain included. This is not a new standalone advance release.

Bulletin No. 2025–44
October 27, 2025
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2025-27, page 646.
General Rules and Specifications for Substitute Forms and
Schedules.
This procedure provides guidelines and general require-
ments for the development, printing, and approval of the
2025 substitute tax forms. This procedure will be repro-
duced as the next revision of Publication 1167. Rev. Proc.
2024-33 is superseded.
INCOME TAX
Notice 2025-49, page 627.
This notice provides additional interim guidance to reduce
the compliance burdens and costs associated with the appli-
cation of the corporate alternative minimum tax (CAMT). Spe-
cifically, this notice provides rules for certain adjustments to
adjusted financial statement income and rules for proposed
applicability dates and reliance on the CAMT Proposed Reg-
ulations.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and
enforce the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
October 27, 2025 Bulletin No. 2025–44

Part III
Additional Interim Guidance
for the Application of the
Corporate Alternative
Minimum Tax
Notice 2025-49
SECTION 1. OVERVIEW
This notice provides additional interim
guidance regarding the application of
the corporate alternative minimum tax
(CAMT) under §§ 55, 56A, and 59 of the
Internal Revenue Code (Code).
1
Prior to
the publication of any final regulations
relating to the CAMT, the Department of
the Treasury (Treasury Department) and
the Internal Revenue Service (IRS) intend
to partially withdraw the CAMT Proposed
Regulations (as defined in section 2.03 of
this notice) and to issue revised proposed
regulations (forthcoming proposed reg-
ulations) that, in part, are anticipated to
include rules similar to the interim guid-
ance described in sections 3 through 10
of this notice, Notice 2025-27, 2025-26
I.R.B. 1611 (June 23, 2025), Notice 2025-
28, 2025-34 I.R.B. 316 (August 18, 2025),
and Notice 2025-46, 2025-43 I.R.B. ____
(October 20, 2025).
Section 3 of this notice addresses the
applicability dates and reliance rules pro-
vided in the CAMT Proposed Regula-
tions. Section 4 of this notice addresses an
adjustment to adjusted financial statement
income (AFSI)
2
for a taxpayer with reg-
ulated operations that capitalizes certain
costs as regulatory assets under Account-
ing Standards Codification (ASC) 980 in its
applicable financial statement (AFS). Sec-
tion 5 of this notice addresses adjustments
to AFSI for certain items measured at fair
value. Section 6 of this notice addresses an
adjustment to AFSI for CAMT entities that
are subject to the tonnage tax regime. Sec-
tion 7 of this notice addresses an adjust-
ment to AFSI for certain depreciation
deductions that previously gave rise to a
carryover of a net operating loss (NOL),
as defined in § 172(c), for regular tax pur-
poses. Section 8 of this notice addresses
an adjustment to AFSI for nonlife insur-
ance companies that carry back an NOL
for regular tax purposes. Section 9 of this
notice addresses an adjustment to AFSI
for § 197 amortization attributable to tax
goodwill acquired in certain transactions.
Section 10 of this notice addresses adjust-
ments to AFSI for accounting principle
change adjustments and restatements of a
prior-year AFS. Section 11 of this notice
requests comments on the issues relating
to section 5 of this notice.
SECTION 2. BACKGROUND
.01 Overview of the CAMT. Section
10101 of Public Law 117-169, 136 Stat.
1818, 1818-1828 (August 16, 2022), com-
monly known as the Inflation Reduction
Act of 2022, amended § 55 to impose the
CAMT based on the AFSI of an applicable
corporation for taxable years beginning
after December 31, 2022. Section 59(k)
(1)(A) provides that, for purposes of §§ 55
through 59, the term “applicable corpora-
tion” means, with respect to any taxable
year, any corporation (other than an S cor-
poration, a regulated investment company,
or a real estate investment trust) that meets
the average annual AFSI test provided in
§ 59(k)(1)(B) for one or more taxable
years that (1) are prior to that taxable year,
and (2) end after December 31, 2021.
.02 AFSI under § 56A.
(1) General definition of AFSI. For
purposes of §§ 55 through 59, § 56A(a)
provides that the term “AFSI” means,
with respect to any corporation for any
taxable year, the net income or loss of the
taxpayer set forth on the taxpayer’s AFS
for that taxable year, adjusted as provided
in § 56A. Section 56A(c) provides general
adjustments to be made to AFSI.
(2) Provisions under § 56A relevant to
the items described in this notice.
(a) Adjustments under § 56A(c) disre-
garding certain financial statement gains
and losses for certain items measured at
fair value.
(i) With respect to investment(s) in
certain corporations, § 56A(c)(2)(C) gen-
erally provides that a taxpayer’s AFSI
with respect to another corporation that
is not included on the taxpayer’s consol-
idated return is determined by taking into
account only the dividends received from
such other corporation and certain other
amounts includible in income or deduct-
ible as a loss with respect to such corpo-
ration.
(ii) With respect to investment(s) in a
partnership, § 56A(c)(2)(D)(i) generally
provides that, except as provided by the
Secretary of the Treasury or the Secre-
tary’s delegate (Secretary), a taxpayer
that is a partner in a partnership adjusts its
AFSI with respect to such partnership to
take into account only the taxpayer’s dis-
tributive share of such partnership’s AFSI.
(iii) With respect to investment(s) in a
controlled foreign corporation (as defined
in § 957 or, if applicable, § 953(c)(1)(B))
(CFC), § 56A(c)(3)(A) generally provides
that a taxpayer that is a United States
shareholder of one or more CFCs adjusts
its AFSI with respect to the CFC to take
into account the taxpayer’s pro rata share
of items taken into account in computing
the net income or loss set forth on the AFS
of each such CFC.
(b) Authority of the Secretary to provide
necessary adjustments. Section 56A(c)
(15) authorizes the Secretary to issue reg-
ulations or other guidance to provide for
such adjustments to AFSI as the Secretary
determines necessary to carry out the pur-
poses of § 56A, including adjustments to
prevent the omission or duplication of any
item.
(c) Adjustment for financial statement
net operating losses (FSNOLs). Section
56A(d)(1) provides that AFSI is reduced
by an amount equal to the lesser of (i) the
aggregate amount of FSNOL carryovers to
the taxable year, or (ii) 80 percent of AFSI
computed without regard to the adjust-
ment under § 56A(d)(1) (FSNOL adjust-
ment). Section 56A(d)(2) provides that an
FSNOL for any taxable year is a FSNOL
carryover to each taxable year following
1
Unless otherwise provided, all "section" or "§" references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).
2
Unless otherwise specified, terms used in this notice have the same meaning as in the CAMT Proposed Regulations described in section 2.03 of this notice.
Bulletin No. 2025–44 627 October 27, 2025

the taxable year of the loss. The portion of
the FSNOL carried to subsequent taxable
years is the amount of the FSNOL remain-
ing after subtracting the adjustments to
AFSI made under § 56A(d)(1) for previ-
ous years. Section 56A(d)(3) defines an
“FSNOL” as the amount of the net loss (if
any) set forth on a corporation’s AFS as
adjusted by § 56A(c), and without regard
to the FSNOL deduction, for taxable years
ending after December 31, 2019.
(d) General authority of the Secretary.
Section 56A(e) authorizes the Secretary to
provide such regulations and other guid-
ance as necessary to carry out the pur-
poses of § 56A.
.03 CAMT Proposed Regulations.
(1) Overview. On September 13, 2024,
the Treasury Department and the IRS pub-
lished a notice of proposed rulemaking
(REG-112129-23) in the Federal Reg-
ister (89 F.R. 75062) that addressed the
application of the CAMT and permitted
taxpayers to rely on the proposed regula-
tions contained therein subject to certain
conditions and limitations. On December
26, 2024, the Treasury Department and
the IRS published in the Federal Register
(89 F.R. 104909) technical corrections to
the proposed regulations set forth in REG-
112129-23, which together with such pro-
posed regulations are referred to as the
“CAMT Proposed Regulations” in this
notice. Numerous comments were sub-
mitted in response to the CAMT Proposed
Regulations, which the Treasury Depart-
ment and the IRS continue to consider and
study.
(2) Provisions of the CAMT Pro-
posed Regulations relevant to the items
described in this notice.
(a) AFSI adjustments for changes in
accounting principles and AFS restate-
ments in proposed § 1.56A-17.
(i) Overview of proposed § 1.56A-17.
Under the authority provided in § 56A(c)
(15)(A), proposed § 1.56A-17 would pro-
vide rules regarding AFSI adjustments
to prevent the duplication or omission of
income, including rules under proposed
§ 1.56A-17(c) for adjusting AFSI to pre-
vent duplications or omissions arising
from a change in accounting principle
and proposed § 1.56A-17(d) for adjusting
AFSI to prevent duplications or omissions
arising from the restatement of a prior
year’s AFS (AFS restatement).
(ii) Accounting principle changes. Pro-
posed § 1.56A-17(c)(1) generally would
require a CAMT entity that implements a
change in accounting principle in its AFS
for a taxable year to adjust its AFSI by the
accounting principle change amount, as
described in proposed § 1.56A-17(c)(2)
(i), subject to the adjustment spread period
rules under proposed § 1.56A-17(c)(3) and
(4) that prescribe the taxable year in which
the accounting principle change amount
is taken into account to determine AFSI.
Under proposed § 1.56A-17(c)(2)(i),
the accounting principle change amount
would be equal to the net cumulative
adjustment to the CAMT entity’s begin-
ning retained earnings for the taxable year
that results from the change in accounting
principle. Under proposed § 1.56A-17(c)
(2)(i)(A), the accounting principle change
amount would be adjusted to disregard
any portion of the cumulative retained
earnings adjustment attributable to tax-
able years ending on or before December
31, 2019. Under proposed § 1.56A-17(c)
(2)(i)(B), the accounting principle change
amount also would be adjusted to reflect
any AFSI adjustments provided elsewhere
in the CAMT Proposed Regulations, to
the extent the retained earnings difference
is attributable to FSI items to which those
AFSI adjustments apply.
Proposed § 1.56A-17(c)(2)(ii) would
provide rules for determining the account-
ing principle change amount when a
CAMT entity is treated as implementing
a change in accounting principle under
proposed § 1.56A-17(c)(5) because the
priority of the CAMT entity’s AFS (as
determined under proposed § 1.56A-2(c))
for the taxable year is different from the
priority of the CAMT entity’s AFS for the
immediately preceding taxable year. In
this case, the accounting principle change
amount would be equal to the difference
between the CAMT entity’s beginning
retained earnings reflected in the CAMT
entity’s current AFS as of the beginning
of the taxable year and the CAMT enti-
ty’s ending retained earnings reflected in
its former AFS as of the end of the imme-
diately preceding taxable year (retained
earnings difference). Under § 1.56A-17(c)
(2)(ii)(A), the accounting principle
change amount would be adjusted to
disregard any portion of the cumulative
adjustment attributable to taxable years
ending on or before December 31, 2019.
Under proposed § 1.56A-17(c)(2)(ii)(B),
the accounting principle change amount
also would be adjusted to reflect any
AFSI adjustments provided elsewhere in
the CAMT Proposed Regulations, to the
extent the retained earnings difference is
attributable to FSI items to which those
AFSI adjustments apply.
(iii) AFS restatements. Proposed
§ 1.56A-17(d) would provide an adjust-
ment to AFSI when a CAMT entity issues
a restated AFS and the CAMT entity’s FSI
for a taxable year ending after December
31, 2019, is restated on or after the date
that the CAMT entity files its original
Federal income tax return for such tax-
able year (restatement year). Proposed
§ 1.56A-17(d)(1)(i) would require the
CAMT entity to adjust its AFSI for the
taxable year in which the restated AFS
is issued (AFSI restatement adjustment).
The AFSI restatement adjustment would
be equal to the cumulative effect of the
restatement on the CAMT entity’s FSI
for the restatement year, including any
restatement of the CAMT entity’s begin-
ning retained earnings for the restatement
year. However, under § 1.56A-17(d)(1)(i),
the AFSI restatement adjustment would
not take into account any retained earn-
ings restatement attributable to taxable
years ending on or before December 31,
2019. Under proposed § 1.56A-17(d)
(1)(ii), the AFSI restatement adjustment
also would be adjusted to reflect any
AFSI adjustments provided elsewhere in
the CAMT Proposed Regulations, to the
extent the retained earnings difference is
attributable to FSI items to which those
AFSI adjustments apply.
(b) AFSI adjustments for FSNOLs in
proposed § 1.56A-23. Consistent with
§ 56A(d), proposed § 1.56A-23 would
provide that, if the AFSI of a corporation
for a taxable year is positive (determined
after application of all other CAMT Pro-
posed Regulations), the corporation’s
AFSI is reduced by an amount equal to
the lesser of (i) the aggregate amount of
FSNOL carryovers to the taxable year,
or (ii) 80 percent of the AFSI of the cor-
poration (determined after application
of the CAMT Proposed Regulations
except proposed § 1.56A-23). Proposed
§ 1.56A-23(d)(1) would provide that an
FSNOL for any taxable year is carried
October 27, 2025 628 Bulletin No. 2025–44

Bulletin No. 2025–44 629 October 27, 2025
forward to each taxable year following
the taxable year of the loss, and that any
remaining FSNOL is carried forward to
the subsequent taxable year.
(c) AFSI adjustments for hedging trans-
actions and hedged items in proposed
§ 1.56A-24. Under the authority pro-
vided in § 56A(c)(15) and (e), proposed
§ 1.56A-24 would provide adjustments to
AFSI for certain hedging transactions and
hedged items to address distortions in the
determination of AFSI as a result of mis-
matches between the timing of inclusion
of gain or loss on the hedging transaction
and the hedged item. Under proposed
§ 1.56A-24(c)(2), if a CAMT entity has
a fair value measurement adjustment for
either an AFSI hedge or the hedged item,
but not both, the fair value measurement
adjustment generally would be disre-
garded if neither the AFSI hedge nor the
hedged item is marked to market for regu-
lar tax purposes. However, under proposed
§ 1.56A-24(e)(1), if a fair value measure-
ment adjustment that is disregarded in
a taxable year includes amounts corre-
sponding to items of income, gain, deduc-
tion, or loss under chapter 1 of the Code in
that taxable year, the CAMT entity would
include those amounts in AFSI in that tax-
able year. Under proposed § 1.56A-24(e)
(2), the inclusion in AFSI of a fair value
measurement adjustment that is disre-
garded under proposed § 1.56A-24(c)(2)
generally would be delayed until the AFSI
hedge or hedged item, or its correspond-
ing hedged item or AFSI hedge (as appli-
cable), matures or is sold, disposed of,
or otherwise terminated. Under proposed
§ 1.56A-24(d), to the extent a CAMT
entity marks to market a net investment
hedge for regular tax purposes, the CAMT
entity would include in AFSI the gain or
loss resulting from marking to market the
net investment hedge for regular tax pur-
poses.
(3) Proposed applicability dates and
reliance on the CAMT Proposed Regula-
tions.
(a) Proposed applicability dates. The
sections of the CAMT Proposed Regu-
lations that are “specified regulations”
(as defined in the Proposed Applicabil-
ity Dates and Reliance on the Proposed
Regulations section of the preamble to
the CAMT Proposed Regulations) were
proposed to apply to taxable years ending
after September 13, 2024. The sections of
the CAMT Proposed Regulations that are
not specified regulations were proposed
to apply to taxable years ending after the
date final regulations are published in the
Federal Register
. Proposed §§ 1.1502-
2, 1.1502-53, and 1.1502-56A were pro-
posed to apply to consolidated return
years for which the date of the income
tax return (without extensions) is after the
date final regulations are published in the
Federal Register.
(b) Reliance on the CAMT Proposed
Regulations.
(i) Reliance on the specified regula-
tions. The CAMT Proposed Regulations
provided that a taxpayer may rely on the
specified regulations for any taxable year
ending on or before September 13, 2024,
provided that the taxpayer and each mem-
ber of its test group determined under pro-
posed § 1.59-2 consistently follow all of
the specified regulations (and other enu-
merated proposed rules) in their entirety
for that taxable year and each subsequent
taxable year until the first taxable year that
the final regulations are applicable.
(ii) Reliance on non-specified regula-
tions. The CAMT Proposed Regulations
provided that taxpayers may rely on one
or more sections of the CAMT Proposed
Regulations that are not specified regu-
lations for any taxable year ending on or
before the date final regulations are pub-
lished in the Federal Register, provided
that the taxpayer and each member of
its test group determined under proposed
§ 1.59-2 consistently follow that section
and all of the specified regulations (and
other enumerated proposed rules) in their
entirety in that taxable year and each sub-
sequent taxable year until the first taxable
year that the final regulations are applica-
ble.
.04 Notices issued subsequent to CAMT
Proposed Regulations.
(1) Notice 2025-27 provides interim
guidance regarding an optional simplified
method for determining applicable corpo-
ration status and provides a limited waiver
of certain additions to tax under § 6655
with respect to a corporation’s CAMT lia-
bility for taxable years beginning during
2025.
(2) Notice 2025-28 provides interim
guidance on determining a CAMT entity’s
AFSI with respect to an investment in a
partnership, reporting by partnerships of
information needed to compute AFSI, and
the treatment of partnership contributions
and distributions. Notice 2025-28 also
announced that the Treasury Department
and the IRS anticipate that forthcoming
proposed regulations will provide that, for
taxable years beginning before the appli-
cability date of final regulations address-
ing §§ 56A(c)(2)(D) and 56A(c)(15)(B)
as applied to partnership investments, a
taxpayer may rely on proposed § 1.56A-5
(excluding proposed § 1.56A-5(l)(2)
(ii) and (iii)) as contained in the CAMT
Proposed Regulations without also being
required to rely on proposed § 1.56A-
20 as contained in the CAMT Proposed
Regulations, or vice versa, subject to
certain requirements. In addition, for tax-
able years beginning before the date the
forthcoming proposed regulations are
published in the Federal Register, Notice
2025-28 provides that a taxpayer may
rely on proposed § 1.56A-5 (excluding
proposed § 1.56A-5(l)(2)(ii) and (iii)) as
contained in the CAMT Proposed Regu-
lations without also being required to rely
on proposed § 1.56A-20 as contained in
the CAMT Proposed Regulations, or vice
versa, subject to certain requirements.
(3) Notice 2025-46 provides interim
guidance on the application of the CAMT
to domestic corporate transactions, trou-
bled companies, tax consolidated groups,
acquired FSNOLs, and certain built-in
items.
.05 Comments received on the CAMT
Proposed Regulations relevant to items in
this notice.
(1) Proposed applicability dates and
reliance on the CAMT Proposed Regula-
tions. Commenters stated that having dif-
ferent applicability dates for the specified
regulations and non-specified regulations
is confusing and inappropriately burdens
taxpayers by proposing that certain com-
plex rules contained in the specified regu-
lations would apply based on the date the
CAMT Proposed Regulations were pub-
lished in the Federal Register as opposed
to the date final regulations are published
in the Federal Register. In addition, com-
menters stated that the rules for relying on
the CAMT Proposed Regulations, which,
among other requirements, generally pro-
hibit a taxpayer from relying on a particu-
lar section of the CAMT Proposed Regu-

October 27, 2025 630 Bulletin No. 2025–44
lations unless the taxpayer also applies all
of the specified regulations, impose addi-
tional compliance burdens and costs on
taxpayers seeking to apply relevant sec-
tions of the CAMT Proposed Regulations
for taxable years ending on or before final
regulations are published in the Federal
Register. Commenters requested guidance
providing that, for taxable years ending
on or before the date the final regulations
are published in the Federal Register, a
taxpayer may rely on any section of the
CAMT Proposed Regulations without
also being required to apply the speci-
fied regulations or any additional sections
of the CAMT Proposed Regulations, as
applicable.
(2) CAMT entities with regulated oper-
ations. Commenters recommended that
an adjustment to AFSI be allowed for
certain repair or maintenance costs of
CAMT entities with regulated operations
because those CAMT entities are subject
to special financial accounting rules under
U.S. generally accepted accounting prin-
ciples (GAAP). As defined in proposed
§ 1.56A-1(b)(27), GAAP are a common
set of accounting rules, standards, and
procedures that are generally issued by
the Financial Accounting Standards Board
(FASB) and, where applicable, the U.S.
Securities and Exchange Commission.
ASC 980 contains the FASB’s financial
accounting rules and principles applicable
to regulated operations.
ASC 980-10-15-2 provides that an
entity is required to apply the ASC 980
financial accounting rules to any regulated
operations that meet certain criteria. First,
the entity’s rates for regulated services
or products provided to its customers are
established by or are subject to approval
by an independent, third-party regulator
or by its own governing board empowered
by statute or contract to establish rates
that bind customers. Second, the regulated
rates are designed to recover the specific
entity’s costs of providing the regulated
services or products. Third, based on the
demand for the regulated services or prod-
ucts and the level of competition (direct
and indirect), it is reasonable to assume
that rates set at levels that will recover the
entity’s costs can be charged to and col-
lected from customers. Companies with
regulated operations may include utilities
regulated by a state public utility commis-
sion or energy companies regulated by the
Federal Energy Regulatory Commission.
An entity that is required to apply ASC
980 to its regulated operations must cap-
italize for AFS purposes all or part of an
incurred cost (including a repair expen-
diture) that otherwise would be expensed
when incurred under GAAP, if the cost
meets the following criteria of ASC 980-
340-25-1 (regulatory asset): (i) it is prob-
able that future revenue in an amount that
equals or exceeds the capitalized cost
will result from inclusion of that cost in
allowable costs for rate-making purposes;
and (ii) based on available evidence, that
future revenue will be provided to per-
mit the recovery of that cost, rather than
to provide for expected levels of similar,
future costs.
Neither § 56A(c) nor the CAMT Pro-
posed Regulations provide an adjust-
ment to AFSI for costs capitalized to, and
included in the basis of, a regulatory asset,
unless that asset also constitutes property
to which § 168 applies for purposes of
§ 56A(c)(13) and proposed § 1.56A-15.
Comments submitted in response to the
CAMT Proposed Regulations recom-
mended that an adjustment to AFSI be
allowed for repair or maintenance costs
with respect to tangible property that are
capitalized under ASC 980-340-25-1 as
regulatory assets. The commenters indi-
cated that regulated utilities have elevated
AFSI compared to non-regulated compa-
nies because ASC 980 requires entities
with regulated operations to capitalize and
depreciate the cost of repair or mainte-
nance costs that are regulatory assets for
AFS purposes to spread the rate impact
of such costs for their customers. The
commenters explained that CAMT enti-
ties that do not have regulated operations
under ASC 980-10-15-2 are not subject
to ASC 980, and, thus, generally expense
such costs when incurred under GAAP.
The commenters observed that this ele-
vated AFSI for regulated utilities due to
the application of ASC 980 may result in
increased CAMT liability for such taxpay-
ers and, thus, an increased tax expense that
would be includible in allowable costs for
rate-making purposes.
(3) Items measured at fair value for FSI
purposes. Section 56A provides for adjust-
ments to AFSI to disregard certain finan-
cial statement gains and losses for certain
items that are measured at fair value. For
example, § 56A(c)(2)(C), (c)(2)(D)(i) and
(c)(3)(A) provide adjustments to AFSI to
disregard certain financial statement gains
and losses attributable to certain invest-
ments in domestic corporations, partner-
ships, and CFCs that are measured at fair
value. Further, the CAMT Proposed Reg-
ulations contain additional adjustments
to AFSI for certain other items measured
at fair value for FSI purposes, including
adjustments under proposed § 1.56A-24.
Comments submitted in response to
the CAMT Proposed Regulations, includ-
ing proposed § 1.56A-24, generally rec-
ommended expanding the scope of the
rules governing adjustments to items
measured at fair value for FSI purposes.
For example, one commenter recom-
mended expanding the scope of the rule
disregarding FSI resulting from the equity
or fair value methods for certain stock
investments to apply to all investment
assets, including debt, debt-like securi-
ties, warrants, and options. In addition,
commenters recommended expanding the
scope of proposed § 1.56A-24 to disre-
gard a fair value measurement adjustment
when either the hedged item or the AFSI
hedge (but not both) is reflected in FSI at
fair value, but both the hedged item and
the AFSI hedge are marked to market for
regular tax purposes. One commenter rec-
ommended expanding the scope to disre-
gard a fair value measurement adjustment
when an item is marked to market for
regular tax purposes but a deferral rule
applies to the mark-to-market gain or loss,
such as due to § 1092. Commenters also
recommended guidance that would clarify
and modify the definitions, rules related to
the application to prior years, subsequent
adjustment rules, and net investment
hedge rules in proposed § 1.56A-24.
Other commenters made broader rec-
ommendations. Three commenters rec-
ommended disregarding fair value mea-
surement adjustments for additional items
that are reflected in FSI at fair value and
that are not marked to market for regular
tax purposes, including digital assets. Two
commenters stated that Congress did not
intend for fair value measurement adjust-
ments on assets held by a CAMT entity
to be taken into account in determining
AFSI. Two commenters indicated that
including in AFSI unrealized gains and

Bulletin No. 2025–44 631 October 27, 2025
losses attributable to the fair value mea-
surements would lead to distortions that
should be alleviated with an adjustment to
FSI to avoid the non-economic results that
would arise absent such an adjustment.
Two commenters stated that requiring
fair value measurement adjustments to be
taken into account in determining AFSI
would disadvantage domestic corpora-
tions compared to foreign corporations
as a result of different financial account-
ing rules. One commenter also noted that
the proposed regulations would disregard
fair value measurement adjustments for
some assets and stated that it would be
good policy to treat all assets in the same
manner. Commenters suggested issuing
guidance that would disregard fair value
measurement adjustments for AFSI pur-
poses unless the gains and losses attrib-
utable to the adjustments are taken into
account for regular tax purposes. One
commenter requested guidance that would
allow CAMT entities to elect out of the
rules disregarding fair value measurement
adjustments and instead follow FSI.
(4) CAMT and tonnage tax regime.
The CAMT Proposed Regulations did
not propose rules addressing the provi-
sions of subchapter R of chapter 1 of the
Code (tonnage tax regime). However, the
preamble to the CAMT Proposed Regula-
tions requested comments on the interac-
tion between the CAMT and the tonnage
tax regime, including comments on how
best to provide AFSI adjustments for
CAMT entities that are subject to the ton-
nage tax regime to meet the United States
national security policy goals of the ton-
nage tax regime and the Maritime Secu-
rity Program (MSP), while appropriately
imposing the CAMT with respect to other
AFSI of such entities.
Under § 1354(a), any corporation
that is a “qualifying vessel operator,” as
defined in § 1355(a)(3), may elect to be
subject to the tonnage tax imposed under
§ 1352. An election made by a member of
a controlled group, as defined in § 1355(a)
(2)(B), applies to all qualifying vessel
operators that are members of that group.
See
§ 1354(c). Any corporation subject to
this election (electing corporation) is sub-
ject to tax on a notional amount of income
from qualifying shipping activities in lieu
of the Federal income tax that otherwise
would be imposed under § 11 on the tax-
able income from those activities. See
H.R. No. 108-548 Part 1 (2004) at 177.
The notional amount of shipping income
is determined under § 1353(b) based on
the net tonnage of qualifying vessels (as
defined in § 1355(a)(4)) that the electing
corporation operates in United States for-
eign trade during the taxable year. Section
1358(b) prevents an electing corporation
from claiming any deductions against
notional shipping income and limits the
use of an NOL attributable to qualifying
shipping activities in certain instances.
As a result of an election under § 1354,
an electing corporation does not include
income from qualifying shipping activi-
ties in its gross income for regular tax pur-
poses. See § 1357(a). Further, a member of
an electing group (as defined in § 1355(a)
(2)) that is not an electing corporation
(and, thus, is not subject to tax on notional
shipping income under § 1352(2)) does
not include its income from qualifying
shipping activities in gross income for
regular tax purposes. See § 1357(b). In
addition, and subject to special rules for
depreciation and interest in § 1357(c)(2)
and (3), respectively, § 1357(c)(1) disal-
lows each item of loss, deduction (other
than for interest expense), or credit of any
taxpayer with respect to any activity that
generates income excluded under § 1357.
The disallowance for interest expense is
based on the ratio of the fair market value
of the corporation’s qualifying vessels to
the fair market value of the corporation’s
total assets or, in the case of a member
of an electing group, the electing group’s
total assets. See § 1357(c)(3)(A) and (B).
For purposes of determining gain of any
qualifying vessel, § 1357(c)(2) provides
that the adjusted basis of a qualifying
vessel is determined as if a deduction for
depreciation had been allowed.
The Treasury Department and the IRS
received comments noting that, with-
out further guidance addressing how the
CAMT interacts with the tonnage tax
regime, the CAMT would result in both
tax regimes applying simultaneously,
which could undermine the national secu-
rity purposes of the tonnage tax regime.
Commenters further noted that this out-
come could decrease the global competi-
tiveness of U.S.-flag vessels. Commenters
requested that AFSI be adjusted for corpo-
rations subject to the tonnage tax regime
so as not to undermine the tonnage tax
regime’s purpose.
(5) Depreciation deductions and NOL
carryovers. Depreciation deductions
allowed under § 167 with respect to sec-
tion 168 property for a taxable year that
give rise to an NOL (embedded depre-
ciation deductions) for that taxable year
generally are carried forward as part of
the corresponding NOL carryover. The
embedded depreciation deductions ulti-
mately reduce a CAMT entity’s regular
tax liability in the taxable year in which
the corresponding NOL carryover is
allowed as a deduction under § 172(a).
See § 172(a) and 172(b)(1)(A)(ii).
Neither § 56A(c) nor the CAMT Pro-
posed Regulations provide an adjustment
to AFSI for embedded depreciation deduc-
tions in the taxable year such amounts are
allowed as a deduction under § 172(a).
Commenters requested that an adjustment
be allowed to reduce AFSI by embedded
depreciation deductions attributable to an
NOL arising in a taxable year ending on
or before December 31, 2019 (pre-2020
embedded depreciation deductions), in the
taxable year the NOL carryover contain-
ing those embedded depreciation deduc-
tions is allowed as a deduction under
§ 172(a). Commenters noted that a CAMT
liability under § 55 could arise in a taxable
year in which an NOL carryover contain-
ing embedded depreciation deductions is
allowed as a deduction under § 172, given
that (i) neither § 56A(c) nor the CAMT
Proposed Regulations provide a corre-
sponding adjustment to AFSI for embed-
ded depreciation deductions, and (ii) no
corresponding AFSI adjustment is avail-
able under § 56A(d) or proposed § 1.56A-
23 given that the AFSI adjustment under
§ 56A(d) and proposed § 1.56A-23 is lim-
ited to FSNOLs arising in taxable years
ending after December 31, 2019.
(6) Application of FSNOL rules to
nonlife insurance companies. The pream-
ble to the CAMT Proposed Regulations
noted that the § 56A(d) rules regarding
the adjustment to AFSI for FSNOLs gen-
erally matches the rules regarding the use
of NOLs applicable to most corporations
for regular tax purposes under § 172, in
that both FSNOLs and NOLs generally
(i) may be carried forward for an indefi-
nite number of years but may not be car-
ried back, and (ii) may be used to reduce

October 27, 2025 632 Bulletin No. 2025–44
only 80 percent of AFSI (as provided in
§ 56A(d)(1)) or taxable income (as pro-
vided in § 172(a)(2)), respectively. How-
ever, § 172 provides exceptions to the
general rule for nonlife insurance com-
panies that are not found in § 56A(d). In
particular, § 172 provides that a nonlife
insurance company’s NOLs (i) may be
carried back for two years and carried for-
ward 20 years, and (ii) are not subject to
the 80-percent limit provided in § 172(a)
(2). See § 172(b)(1)(C) and (f). The pre-
amble to the CAMT Proposed Regula-
tions noted that this disparity could create
a mismatch between AFSI and regular
taxable income for CAMT entities that
are nonlife insurance companies that does
not exist for other CAMT entities. In the
preamble to the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS requested comments on how substan-
tial this mismatch may be and the severity
of the economic effects of such mismatch,
whether rules should be provided to
address this potential mismatch, and how
the rules might operate.
Commenters confirmed that a mis-
match between regular tax NOLs and
FSNOLs (book-tax NOL mismatch) may
arise for nonlife insurance companies.
Commenters asserted that this mismatch
could cause nonlife insurance compa-
nies to have higher CAMT liability in a
carryback year, and that this outcome is
contrary to Congress’s objective in pre-
serving NOL carrybacks for nonlife insur-
ance companies. Commenters further
noted that nonlife insurers provide relief
to the economy from catastrophic losses,
and that regular tax NOL carrybacks give
these companies timely access to capital
(via tax refunds for the carryback year)
to help pay claims and replenish capi-
tal quickly after loss years. Commenters
requested that adjustments be made in
the final regulations to address the book-
tax NOL mismatch for nonlife insurance
companies.
(7) Goodwill amortization. Comment-
ers requested that an adjustment to AFSI
be allowed for amortization of goodwill
under § 197. In general, amounts paid
to another party to acquire goodwill are
required to be capitalized in the taxable
year paid or incurred. See § 1.263(a)-4(c)
(1)(x). Once capitalized, such amounts are
generally recovered through amortization
deductions ratably over a 15-year period
beginning with the month in which the
goodwill is acquired (§ 197 amortization).
See § 197(a), (c) and (d)(1)(A).
In general, amounts paid or incurred
to acquire goodwill are capitalized for
AFS purposes in the year paid or incurred.
Once capitalized, those amounts generally
are not recoverable through amortization,
but rather are recoverable to the extent the
goodwill is impaired (in which case an
impairment loss would be recognized) or
upon disposition of the goodwill. See ASC
350-20-35-1; IAS 36. However, goodwill
may be recoverable through amortization
for AFS purposes under certain circum-
stances. See, e.g., ASC 350-20-35-63,
which allows certain private companies
and not-for-profit entities to amortize
goodwill on a straight-line basis over a
10-year period.
Neither § 56A(c) nor the CAMT Pro-
posed Regulations provide an adjustment
to AFSI for § 197 amortization of good-
will. Commenters requesting an adjust-
ment to AFSI for § 197 amortization of
goodwill explained that goodwill may not
be amortizable under IFRS or GAAP and,
as a consequence, a CAMT liability under
§ 55 could arise in taxable years in which
amortization of goodwill is deducted for
regular tax purposes under § 197. In addi-
tion, commenters observed that CAMT
entities could not have considered the
consequences of the CAMT, including the
treatment of goodwill under the CAMT,
in their financial modeling for business
acquisitions or in the allocation of the
purchase price among acquired assets
for acquisitions that occurred before the
CAMT was in effect and, therefore, should
be allowed an adjustment to AFSI for the
amortization of goodwill acquired prior to
that time.
(8) AFSI adjustments to retained earn-
ings for accounting principle changes.
Commenters expressed concerns with
the rules in proposed § 1.56A-17(c)(2)
(i)(A), (c)(2)(ii)(A), and (d)(1)(i) that
would require CAMT entities to disre-
gard any portion of the adjustment to
retained earnings attributable to taxable
years ending on or before December 31,
2019. Commenters indicated that bifur-
cating the adjustments between amounts
attributable to pre-2020 taxable years and
amounts attributable to subsequent tax-
able years could create higher compliance
costs and increased compliance burdens
if such amounts were not already bifur-
cated for AFS purposes. Commenters rec-
ommended permitting CAMT entities to
calculate these adjustments based on the
entire cumulative adjustment to retained
earnings rather than based on only the por-
tion of the retained earnings adjustment
attributable to taxable years ending on or
after January 1, 2020.
SECTION 3. PROPOSED
APPLICABILITY DATES AND
RELIANCE ON THE CAMT
PROPOSED REGULATIONS AND
FORTHCOMING PROPOSED
REGULATIONS
.01 Purpose. In response to numerous
comments received with respect to the
CAMT Proposed Regulations outlining
the concerns described in section 2.05(1)
of this notice, the Treasury Department
and the IRS have reconsidered the pro-
posed applicability dates and reliance
rules set forth in the “Proposed Applica-
bility Dates and Reliance on the Proposed
Regulations” section of the CAMT Pro-
posed Regulations (see 89 F.R. 75127).
The Treasury Department and the IRS
anticipate that the notice of proposed
rulemaking that will partially withdraw
the CAMT Proposed Regulations and con-
tain the forthcoming proposed regulations
will include a new “Proposed Applicabil-
ity Dates and Reliance on the Proposed
Regulations” section providing that no
section (for example, proposed § 1.56A-
1) of the CAMT Proposed Regulations
and the forthcoming proposed regulations
would be applicable for any taxable year
beginning before the date a corresponding
section of a final regulation is published
in the Federal Register. Accordingly, once
published as final regulations in the Fed-
eral Register, no section of the CAMT
Proposed Regulations will apply, and no
section of the forthcoming proposed reg-
ulations will apply, to any taxable year
beginning before the date a corresponding
section of a final regulation is published in
the Federal Register.
.02 Taxable years beginning before
final regulations.
(1) Reliance on CAMT Proposed Reg-
ulations.

Bulletin No. 2025–44 633 October 27, 2025
(a) In general. Except as provided in
section 3.02(1)(b) of this notice, a tax-
payer may rely on any section of the
CAMT Proposed Regulations for a tax-
able year beginning before the date the
corresponding final regulation is pub-
lished in the Federal Register, provided
the taxpayer consistently follows that
section in its entirety for all such taxable
years beginning with the first taxable year
with respect to which the taxpayer relies
on that section. In addition, a taxpayer
may rely on any section of the CAMT
Proposed Regulations, as modified by any
guidance (including the interim guidance
in this notice) subsequently published in
the Internal Revenue Bulletin, for a tax-
able year beginning before the date the
forthcoming proposed regulations are
published in the Federal Register, pro-
vided the taxpayer consistently follows
such section (as so modified) in its entirety
for all such taxable years beginning with
the first taxable year with respect to which
the taxpayer relies on such section.
(b) Certain related sections.
(i) In general. A taxpayer may rely on
proposed § 1.56A-4 (AFSI adjustments
and basis determinations with respect to
foreign corporations) or 1.56A-6 (AFSI
adjustments with respect to CFCs) of the
CAMT Proposed Regulations, as applica-
ble, for taxable years beginning before the
date a corresponding final regulation sec-
tion is published in the Federal Register,
provided the taxpayer -
(A) consistently follows proposed
§§ 1.56A-8 (AFSI adjustments for cer-
tain Federal and foreign income taxes)
and 1.59-4 (CAMT foreign tax credit) of
the CAMT Proposed Regulations for such
taxable years, and
(B) consistently follows each of pro-
posed § 1.56A-4 or 1.56A-6 (as applica-
ble), proposed § 1.56A-8, and proposed
§ 1.59-4 in their entirety for all such tax-
able years beginning with the taxable year
with respect to which the taxpayer relies
on proposed § 1.56A-4 or 1.56A-6 (as
applicable).
(ii) Special rule in determining eligi-
ble taxes. A taxpayer that relies on pro-
posed § 1.59-4 may treat a tax that would
otherwise not qualify as an eligible tax
solely due to the applicability of section
245A(d) as an eligible tax for purposes of
proposed § 1.59-4 if the tax is a foreign
income tax paid or accrued by the tax-
payer with respect to a dividend received
(or treated as received for purposes of sec-
tion 245A) from a CFC in which the tax-
payer is a United States shareholder. This
is the case notwithstanding that a section
245A deduction is allowed with respect to
the dividend for regular tax purposes and
therefore for CAMT purposes.
(c) Coordination with proposed
§ 1.56A-6(c)(1). If a taxpayer relies on
proposed § 1.56A-6 of the CAMT Pro-
posed Regulations pursuant to section
3.02(1)(b) of this notice, for purposes of
relying on proposed § 1.56A-6(c)(1), the
term “section 56A regulations” means the
CAMT Proposed Regulations, as modified
by any guidance (including the interim
guidance in this notice) published in the
Internal Revenue Bulletin subsequent
to the CAMT Proposed Regulations that
the taxpayer has relied on for purposes of
making AFSI adjustments.
(2) Reliance on interim guidance pro-
vided in Notice 2025-27, Notice 2025-28,
and Notice 2025-46. For a taxable year
described in section 3.05 of Notice 2025-
27, section 9 of Notice 2025-28, or section
9 of Notice 2025-46, as applicable, a tax-
payer may rely on the guidance described
in section 3.03 of Notice 2025-27, sec-
tions 3 through 7 of Notice 2025-28, or
sections 3 through 6 of Notice 2025-46,
without being required to follow any sec-
tion, or part thereof, of the CAMT Pro-
posed Regulations (except to the extent
required by, or incorporated into, these
Notices). Consequently, a taxpayer’s reli-
ance on any of the guidance provided in
section 3.03 of Notice 2025-7, sections 3
through 7 of Notice 2025-28, or sections 3
through 6 of Notice 2025-46 for a taxable
year described in this section 3.02(2) will
not cause the taxpayer to become subject
to, or to violate, the reliance rules, includ-
ing the consistency requirements, pro-
vided in section 3.02(1) of this notice for
such taxable year and any other relevant
taxable years.
(3) Statement of guidance applied on
Form 4626. In addition to any reporting
required by a form, publication, or other
guidance, a corporation must include
with its Form 4626, Alternative Mini-
mum Tax—Corporations, for a particular
taxable year a statement describing the
approach taken in completing Form 4626
for such taxable year and the guidance it
relied upon for such taxable year. See page
2 of the instructions to Form 4626.
3
SECTION 4. AFSI ADJUSTMENT FOR
ELIGIBLE REGULATORY ASSETS
.01 Purpose. In response to comments
received on the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS anticipate that the forthcoming pro-
posed regulations will include proposed
regulations under § 56A(c)(15) and (e)
consistent with the guidance provided in
this section 4 to allow a CAMT entity sub-
ject to ASC 980 to adjust AFSI for eligible
regulatory assets. In addition, the Trea-
sury Department and the IRS anticipate
that the forthcoming proposed regulations
will propose a modification to proposed
§ 1.59-2(c) to provide that, for purposes
of applying the average annual AFSI test
in § 59(k)(1)(B) or proposed § 1.59-2(c),
AFSI is determined without regard to the
AFSI adjustment provided in this section
4.
.02 Definitions. For purposes of this
section 4:
(1) CAMT entity subject to ASC 980.
The term CAMT entity subject to ASC 980
means a CAMT entity that has regulated
operations that meet the criteria of ASC
980-10-15-2 and has an AFS prepared in
accordance with GAAP, including ASC
980.
(2) Eligible regulatory asset. The term
eligible regulatory asset means any cost
attributable to tangible property repairs or
maintenance that is capitalized under ASC
980-340-25-1 and subject to depreciation
for AFS purposes. An eligible regulatory
asset does not include any other costs
capitalized for AFS purposes under ASC
980 or any other provision of GAAP, as
defined in proposed § 1.56A-1(b)(27).
The term eligible regulatory asset includes
costs attributable to tangible property
repairs or maintenance that are capitalized
under ASC 980-340-25-01 and placed in
service by a CAMT entity subject to ASC
980 in any taxable year, including taxable
3
https://www.irs.gov/forms-pubs/about-form-4626

October 27, 2025 634 Bulletin No. 2025–44
years ending on or before December 31,
2019.
(3) Regulatory asset book COGS
depreciation. The term regulatory asset
book COGS depreciation means any of
the following items that are taken into
account as part of cost of goods sold (or
as part of the computation of gain or loss
from the sale or exchange of property held
for sale) in FSI with respect to an eligible
regulatory asset--
(a) Depreciation expense;
(b) Other recovery of AFS basis
(including from an impairment loss) that
occurs either:
(i) Prior to the taxable year in which the
complete disposition of the eligible regu-
latory asset occurs for AFS purposes, or
(ii) In the taxable year in which the com-
plete disposition of the eligible regulatory
asset occurs for AFS purposes to determine
any FSI gain or loss from the disposition of
the eligible regulatory asset; or
(c) Impairment loss reversal.
(4) Regulatory asset book deprecia-
tion expense. The term regulatory asset
book depreciation expense means any of
the following items other than regulatory
asset book COGS depreciation that are
taken into account in FSI with respect to
an eligible regulatory asset--
(a) Depreciation expense;
(b) Other recovery of AFS basis
(including from an impairment loss) that
occurs either:
(i) Prior to the taxable year in which the
complete disposition of the eligible regu-
latory asset occurs for AFS purposes, or
(ii) In the taxable year in which the com-
plete disposition of the eligible regulatory
asset occurs for AFS purposes to determine
any FSI gain or loss from the disposition of
the eligible regulatory asset; or
(c) Impairment loss reversal.
(5) Regulatory asset book inventori-
able depreciation. The term regulatory
asset book inventoriable depreciation
means any of the following items that are
included in inventoriable cost (or capital-
ized as part of the cost of non-inventory
property held for sale) in the AFS of a
CAMT entity subject to ASC 980 with
respect to an eligible regulatory asset--
(a) Depreciation expense;
(b) Other recovery of AFS basis
(including from an impairment loss) that
occurs either:
(i) Prior to the taxable year in which the
complete disposition of the eligible regu-
latory asset occurs for AFS purposes, or
(ii) In the taxable year in which the
complete disposition of the eligible reg-
ulatory asset occurs for AFS purposes to
determine any FSI gain or loss from the
disposition of the eligible regulatory asset;
or
(c) Impairment loss reversal.
.03 AFSI adjustment for eligible regu-
latory assets. The AFSI of a CAMT entity
subject to ASC 980 for a taxable year may
be adjusted as follows:
(1) Reduced by the amount of costs
incurred under GAAP and capitalized
under ASC 980-340-25-1 as eligible regu-
latory assets during such taxable year, but
only to the extent that such amounts are--
(a) Not otherwise required to be capi-
talized for AFS purposes under any other
GAAP rule, standard, or procedure, and
(b) Not required to be capitalized under
§ 263(a) for regular tax purposes; and
(2) Adjusted to disregard any regu-
latory asset book COGS depreciation
and regulatory asset book depreciation
expense with respect to any eligible reg-
ulatory asset.
.04 Determining regulatory asset book
COGS depreciation adjustment.
(1) Except as provided in section
4.04(2) of this notice, a CAMT entity sub-
ject to ASC 980 is required to apply the
method(s) of accounting the CAMT entity
uses for AFS purposes to determine reg-
ulatory asset book inventoriable depre-
ciation for purposes of determining the
regulatory asset book COGS depreciation
adjustment under section 4.03(2) of this
notice.
(2) A CAMT entity subject to ASC 980
is permitted to use any reasonable method
to determine regulatory asset book inven-
toriable depreciation for purposes of deter-
mining the regulatory asset book COGS
depreciation adjustment under section
4.03(2) of this notice, provided that such
reasonable method is consistent with and
reflects the method(s) of accounting the
CAMT entity uses for AFS purposes. In
the case of a CAMT entity subject to ASC
980 that uses the Last-In-First-Out (LIFO)
method to identify inventories for AFS
purposes, a reasonable method includes a
method similar to the method provided in
proposed § 1.56A-15(d)(3)(ii)(C).
(3) Reporting requirement. If a CAMT
entity makes the AFSI adjustment pro-
vided in section 4 of this notice for a
taxable year and is using a reasonable
method to determine regulatory asset
book inventoriable depreciation under
section 4.04(2) of this notice, it must
attach a statement to its Federal income
tax return for such taxable year. The state-
ment must be titled “AFSI adjustment for
eligible regulatory assets” and include the
CAMT entity’s name, address, and tax-
payer identification number, and a state-
ment that the CAMT entity is using a rea-
sonable method to determine regulatory
asset book inventoriable depreciation for
purposes of determining the regulatory
asset book COGS depreciation adjust-
ment under section 4.03(2) of Notice
2025-49 for the taxable year. In addition,
the statement must describe the method
used to determine regulatory asset book
inventoriable depreciation and include a
declaration that the method used is con-
sistent with and reflects the method(s)
of accounting the CAMT entity uses for
AFS purposes.
.05 Consistency requirement. If a
CAMT entity subject to ASC 980 makes
the AFSI adjustment provided in section
4.03 of this notice for a taxable year, it
must continue to make the adjustment
provided in section 4.03 of this notice for
all subsequent taxable years until all eli-
gible regulatory assets are disposed of for
regular tax purposes or such time as pre-
scribed by the Treasury Department and
IRS in regulations or other guidance.
.06 Determining applicable corpo-
ration status. For purposes of applying
the average annual AFSI test in § 59(k)
(1)(B) or proposed § 1.59-2(c), AFSI is
determined without regard to the AFSI
adjustment provided in section 4.03 of
this notice.
.07 Coordination with CAMT Proposed
Regulations. For purposes of coordinating
with relevant provisions of the CAMT
Proposed Regulations (for example, pro-
posed § 1.56A-15), the reduction to AFSI
described in section 4.03(1) of this notice
is treated as if it were an expense for
FSI purposes. For example, the amount
described in section 4.03(1) may be
considered a covered book expense, as
defined in proposed § 1.56A-15(b)(4), if
applicable.

Bulletin No. 2025–44 635 October 27, 2025
.08 Applicability date and reliance. It
is anticipated that the forthcoming pro-
posed regulations will provide that rules
consistent with the guidance described in
this section 4 will apply for taxable years
beginning on or after the date the final reg-
ulations addressing the AFSI adjustment
for eligible regulatory assets are published
in the Federal Register. For taxable years
beginning before the date such forthcom-
ing proposed regulations are published
in the Federal Register, CAMT entities
may rely on the guidance in this section
4. A CAMT entity’s reliance on any of the
guidance in this section 4 for a taxable
year will not cause the CAMT entity to
become subject to, or to violate, the pro-
posed reliance rules, including the consis-
tency requirements, provided in section
3.02(1) of this notice.
SECTION 5. AFSI ADJUSTMENTS
FOR CERTAIN ITEMS MEASURED AT
FAIR VALUE
.01 Purpose. In response to comments,
the Treasury Department and the IRS
anticipate that the forthcoming proposed
regulations will propose modifications to
the rules in proposed § 1.56A-24, other
than the rules for net investment hedges,
that would be consistent with the interim
guidance provided in this section 5. The
Treasury Department and the IRS are pro-
viding this interim guidance prior to the
issuance of the forthcoming proposed
regulations to provide taxpayers with an
alternative approach to determine AFSI
with respect to certain gains and losses
that are included in FSI but generally are
not included in gross income for regular
tax purposes. Instead of being limited to
AFSI hedges and hedged items as in pro-
posed § 1.56A-24, this interim guidance
applies more broadly to certain items that
are measured at fair value for FSI pur-
poses. For example, depending on the
applicable financial accounting principles,
this interim guidance may apply to (1)
holdings of digital assets, (2) debt secu-
rities that are classified as trading securi-
ties, and (3) derivatives that are not part of
a hedging transaction, if those items are
measured at fair value for FSI purposes
but are not marked to market for regu-
lar tax purposes. However, this interim
guidance does not apply to a partnership
investment, stock in a domestic corpora-
tion that is not a member of a tax consoli-
dated group of which the CAMT entity is
a member, stock in a foreign corporation,
a net investment hedge, an asset or liabil-
ity entered into as a hedging transaction
by a covered insurance company in cer-
tain circumstances, a covered insurance
company’s assets in a covered investment
pool, or a covered insurance company’s
covered obligations.
In general, the interim guidance in this
section 5 provides that for certain items
that are measured at fair value, a CAMT
entity may adjust AFSI to disregard gains
and losses that are unrealized for regu-
lar tax purposes (see section 5.03 of this
notice, which describes the FVI exclusion
option). The interim guidance in this sec-
tion 5 also provides that a CAMT entity
may adjust AFSI to disregard certain
gains and losses for certain AFSI hedges
and hedged items (see section 5.04 of this
notice, which describes the hedge coordi-
nation option).
.02 Definitions. For purposes of this
section 5:
(1) Fair value item. The term fair value
item means an asset or liability of a CAMT
entity for which there are fair value mea-
surement adjustments. The term fair value
item does not include--
(a) Items subject to § 56A(c)(2)(C), (c)
(2)(D), or (c)(3) and the guidance thereun-
der, including the CAMT Proposed Regu-
lations, Notice 2025-28, and Notice 2025-
46 (for example, the term fair value item
does not include a partnership investment,
stock in a domestic corporation that is not
a member of a tax consolidated group of
which the CAMT entity is a member, or
stock in a foreign corporation);
(b) Assets or liabilities entered into as
a hedging transaction, as described in pro-
posed § 1.56A-24(b)(1)(ii), by a covered
insurance company;
(c) A covered insurance company’s
assets in a covered investment pool; or
(d) A covered insurance company’s
covered obligations.
(2) Fair value measurement adjust-
ment. The term fair value measurement
adjustment means a change in the value
of an asset or a liability due to required
periodic determinations at least annu-
ally of the increases or decreases in fair
value of that asset or liability included
in a CAMT entity’s FSI, regardless of
whether the determinations are required
due to the type of asset or liability or due
to an election by the CAMT entity. The
term fair value measurement adjustment
includes changes in value resulting from
the application of the lower of cost or mar-
ket accounting method under GAAP or
the lower of cost and net realizable value
accounting method under IFRS. The term
fair value measurement adjustment does
not include an impairment loss or impair-
ment loss reversal.
(3) Subsequent adjustment date. The
term subsequent adjustment date means
the earliest day the fair value item matures
or is sold, exchanged, terminated, or oth-
erwise disposed of for regular tax pur-
poses. For purposes of the hedge coordi-
nation option, a subsequent adjustment
date also includes the earliest day on
which the AFSI hedge or the hedged item
(as applicable) that corresponds to the
hedged item or the AFSI hedge with the
fair value measurement adjustment that
was disregarded under section 5.04 of
this notice matures or is sold, exchanged,
terminated, or otherwise disposed of for
regular tax purposes. In addition, a sub-
sequent adjustment date includes the first
day of the taxable year in which the FVI
exclusion option or hedge coordination
option, as applicable, is no longer applied
by a CAMT entity that previously applied
the FVI exclusion option or hedge coordi-
nation option, as applicable.
.03 FVI exclusion option. Provided the
requirements described in section 5.03(1)
through (4) and section 5.05 of this notice
are satisfied, a CAMT entity may adjust
AFSI for a taxable year to disregard a
fair value measurement adjustment for a
fair value item for that taxable year if the
CAMT entity does not mark to market the
fair value item for regular tax purposes.
For purposes of the FVI exclusion option,
a CAMT entity marks to market the fair
value item for regular tax purposes to the
extent that the CAMT entity recognizes
unrealized gain or loss in a taxable year
for the fair value item and takes such gain
or loss into account in the taxable year.
For example, a CAMT entity may mark a
fair value item to market for tax purposes
due to the application of § 475, § 1256,
or a similar provision. The determination
regarding whether a CAMT entity rec-

October 27, 2025 636 Bulletin No. 2025–44
ognizes unrealized gain or loss in a tax-
able year and takes such gain or loss into
account in the taxable year is made after
taking into account any elections made
by the CAMT entity and the application
of other applicable provisions that may
result in unrealized gain or loss not being
recognized.
(1) Consistency requirement. A CAMT
entity must consistently apply the FVI
exclusion option to all fair value items,
except for a hedged item or AFSI hedge
to which the hedge coordination option in
section 5.04 of this notice applies.
(2) Application of FVI exclusion option.
(a) In general. Except as provided in
section 5.03(2)(b) of this notice, a CAMT
entity (or a controlling domestic share-
holder of a CFC under section 5.03(4) of
this notice) must indicate in a statement
attached to its Federal income tax return
that the CAMT entity intends to apply
the FVI exclusion option for purposes of
determining AFSI. The statement must be
titled “FVI Exclusion Option for CAMT”
and include the CAMT entity’s name,
address, taxpayer identification number,
and a statement that the CAMT entity is
choosing the FVI exclusion option under
section 5.03 of Notice 2025-49. The FVI
exclusion option will apply for the taxable
year beginning after the date on which the
CAMT entity files an original or amended
Federal income tax return containing that
statement.
(b) Transition period. A CAMT entity
may apply the FVI exclusion option for
purposes of determining AFSI for its first
taxable year beginning on any day during
2024, if the CAMT entity indicates in the
statement described in section 5.03(2)(a)
of this notice, attached to its original or
amended Federal income tax return for that
taxable year, that the CAMT entity intends
to apply the FVI exclusion option for that
taxable year. Alternatively, a CAMT entity
may apply the FVI exclusion option for
purposes of determining AFSI for its first
taxable year beginning on any day during
2025, if the CAMT entity indicates in the
statement described in section 5.03(2)
(a) of this notice attached to its Federal
income tax return for that taxable year that
the CAMT entity intends to apply the FVI
exclusion option for that taxable year.
(3) Duration of FVI exclusion option.
A CAMT entity applying the FVI exclu-
sion option for a taxable year must con-
tinue to apply the FVI exclusion option
for purposes of determining AFSI for
all subsequent taxable years beginning
before the date the forthcoming proposed
regulations addressing AFSI adjustments
for certain items measured at fair value
are published in the Federal Register or
until the CAMT entity (or a controlling
domestic shareholder of a CFC under sec-
tion 5.03(4) of this notice) indicates in a
statement attached to its Federal income
tax return that the CAMT entity intends to
no longer apply the FVI exclusion option.
The statement must be titled “Cessation
of FVI Exclusion Option for CAMT” and
include the CAMT entity’s name, address,
taxpayer identification number, and a
statement that the CAMT entity intends to
no longer apply the FVI exclusion option
under section 5.03 of Notice 2025-49. The
FVI exclusion option ceases to apply for
the taxable year beginning after the date
on which the CAMT entity files an origi-
nal or amended Federal income tax return
containing that statement.
(4) CFCs. In the case of a CAMT entity
that is a CFC, the controlling domestic
shareholders (as defined in § 1.964-1(c)
(5)) of the CFC must file a statement
described in section 5.03(2)(a), (2)(b), or
(3) of this notice on behalf of the CFC
in accordance with the procedures set
forth in § 1.964-1(c)(3). The statement
described in § 1.964-1(c)(3)(ii) must be
titled “FVI Exclusion Option for CAMT
on Behalf of CFC” or “Cessation of FVI
Exclusion Option for CAMT on Behalf of
CFC,” as applicable, and, in addition to
the information set forth in § 1.964-1(c)
(3)(ii), must include a statement that the
CFC intends to apply or cease to apply the
FVI exclusion option under Notice 2025-
49. Applying or ceasing to apply the FVI
exclusion option on behalf of a CFC is
binding on all United States shareholders
(as defined in § 951(b) or, if applicable,
§ 953(c)(1)(A)) of the CFC.
.04 Hedge coordination option. Pro-
vided the requirements described in sec-
tion 5.04(1) through (4) and 5.05 of this
notice are satisfied, if a CAMT entity has
a hedged item and a corresponding AFSI
hedge that are each marked to market for
regular tax purposes, as defined in section
5.03 of this notice, but either the hedged
item or the AFSI hedge (but not both)
does not have a fair value measurement
adjustment, the CAMT entity may adjust
AFSI for a taxable year to disregard the
fair value measurement adjustment on the
AFSI hedge or hedged item with the fair
value measurement adjustment.
(1) Consistency requirement. A CAMT
entity that applies the hedge coordination
option must apply the option to all trans-
actions involving a hedged item and a
corresponding AFSI hedge that are each
marked to market for regular tax purposes
but either the hedged item or the AFSI
hedge (but not both) does not have a fair
value measurement adjustment.
(2) Application of hedge coordination
option.
(a) In general. Except as provided
in section 5.04(2)(b) of this notice, a
CAMT entity (or a controlling domes-
tic shareholder of a CFC under section
5.04(4) of this notice) must indicate in a
statement attached to its Federal income
tax return that the CAMT entity intends
to apply the hedge coordination option
for purposes of determining AFSI. The
statement must be titled “Hedge Coor-
dination Option for CAMT” and include
the CAMT entity’s name, address, tax-
payer identification number, and a state-
ment that the CAMT entity is choosing
the hedge coordination option under sec-
tion 5.04 of Notice 2025-49. The hedge
coordination option will apply for the
taxable year beginning after the date on
which the CAMT entity files an original
or amended Federal income tax return
containing that statement.
(b) Transition period. A CAMT entity
may apply the hedge coordination option
for purposes of determining AFSI for its
first taxable year beginning on any day
during 2024, if the CAMT entity indi-
cates in the statement described in section
5.04(2)(a) of this notice attached to its
original or amended Federal income tax
return for that taxable year that the CAMT
entity intends to apply the hedge coordi-
nation option for that taxable year. Alter-
natively, a CAMT entity may apply the
hedge coordination option for purposes of
determining AFSI for its first taxable year
beginning on any day during 2025, if the
CAMT entity indicates in the statement
described in section 5.04(2)(a) of this
notice attached to its Federal income tax
return for that taxable year that the CAMT

Bulletin No. 2025–44 637 October 27, 2025
entity intends to apply the hedge coordi-
nation option for that taxable year.
(3) Duration of hedge coordination
option. A CAMT entity applying the hedge
coordination option for a taxable year must
continue to apply the hedge coordination
option for purposes of determining AFSI
for all subsequent taxable years beginning
before the date the forthcoming proposed
regulations addressing AFSI adjustments
for certain items measured at fair value
are published in the Federal Register or
until the CAMT entity (or a controlling
domestic shareholder of a CFC under sec-
tion 5.04(4) of this notice) indicates in a
statement attached to its Federal income
tax return that the CAMT entity intends
to no longer apply the hedge coordina-
tion option. The statement must be titled
“Cessation of Hedge Coordination Option
for CAMT” and include the CAMT enti-
ty’s name, address, taxpayer identification
number, and a statement that the CAMT
entity intends to no longer apply the hedge
coordination option under section 5.04 of
Notice 2025-49. The hedge coordination
option ceases to apply for the taxable year
beginning after the date on which the
CAMT entity files an original or amended
Federal income tax return containing that
statement.
(4) CFCs. In the case of a CAMT entity
that is a CFC, the controlling domestic
shareholders of the CFC must file a state-
ment described in section 5.04(2)(a), (2)
(b), or (3) of this notice on behalf of the
CFC in accordance with the procedures
set forth in § 1.964-1(c)(3). The statement
described in § 1.964-1(c)(3)(ii) must be
titled “Hedge Coordination Option for
CAMT on Behalf of CFC” or “Cessa-
tion of Hedge Coordination Option for
CAMT on Behalf of CFC,” as applica-
ble, and, in addition to the information set
forth in § 1.964-1(c)(3)(ii), must include
a statement that the CFC intends to apply
or cease to apply the hedge coordination
option under Notice 2025-49. Applying or
ceasing to apply the hedge coordination
option on behalf of a CFC is binding on
all United States shareholders (as defined
in § 951(b) or, if applicable, § 953(c)(1)
(A)) of the CFC.
.05 Adjustments for disregarded fair
value measurement adjustments. A CAMT
entity that disregards a fair value measure-
ment adjustment under the FVI exclusion
option or the hedge coordination option
must apply the guidance provided in this
section 5.05.
(1) Other adjustments to a CAMT
entity’s FSI. If a fair value measurement
adjustment disregarded by a CAMT entity
under section 5.03 or 5.04 of this notice
for a taxable year includes amounts corre-
sponding to items of income, gain, deduc-
tion, or loss under chapter 1 of the Code in
that taxable year (other than gain or loss
from marking to market an item for reg-
ular tax purposes), then the CAMT entity
includes those amounts in AFSI in that
taxable year. See
proposed § 1.56A-24(f)
(5) (Example 5) for an example of a disre-
garded fair value measurement adjustment
that includes taxable income from original
issue discount.
(2) Appropriate adjustments. If a
CAMT entity disregards a fair value
measurement adjustment from AFSI for
a taxable year under section 5.03 or 5.04
of this notice, appropriate adjustments
are made to any relevant CAMT attri-
butes (for example, the CAMT basis of
the fair value item) to reflect that such fair
value measurement adjustment has not
been included in AFSI and to reflect any
amounts included in AFSI under section
5.05(1) of this notice.
(3) Inclusion of disregarded fair value
measurement adjustment. In the taxable
year of a subsequent adjustment date, the
CAMT entity includes in AFSI the cumu-
lative fair value measurement adjustments
previously disregarded in determining
AFSI under section 5.03 or 5.04 of this
notice, net of any amounts included in
AFSI under section 5.05(1) of this notice.
The CAMT basis and any other rele-
vant CAMT attributes of the fair value
item that was subject to section 5.03 or
5.04 of this notice are adjusted to reflect
the amounts included in AFSI under this
section 5.05(3). Following a subsequent
adjustment date, the CAMT entity uses
the CAMT basis of the fair value item that
was subject to section 5.03 or 5.04 of this
notice immediately following the subse-
quent adjustment date in order to deter-
mine any further income, gain, deduction,
and loss included in AFSI with respect to
the fair value item.
.06 Examples. The following examples
illustrate the application of the guidance
in section 5.03(2) and (3) of this notice.
For purposes of these examples, X is an
applicable corporation and uses the cal-
endar year for its taxable year. The anal-
ysis in these examples similarly applies to
situations involving the application of the
guidance in section 5.04(2) and (3) of this
notice.
(1) Example 1: Application of FVI exclusion
option.
(a) Facts. X files its 2026 Federal income tax
return on April 15, 2027. X indicates in a statement
satisfying the requirements of section 5.03(2)(a) of
this notice attached to its 2026 Federal income tax
return that X intends to apply the FVI exclusion
option for purposes of determining AFSI.
(b) Analysis. For purposes of determining the
AFSI of X, X will begin to apply the FVI exclusion
option for its taxable year beginning January 1, 2028,
because this is the taxable year that begins after April
15, 2027, the date on which X filed a Federal income
tax return containing a statement indicating its intent
to apply the FVI exclusion option.
(2) Example 2: No longer applying the FVI
exclusion option.
(a) Facts. X previously indicated in a valid state-
ment attached to its Federal income tax return its
intent to apply the FVI exclusion option and has con-
tinued to apply the FVI exclusion option. X files its
2027 Federal income tax return on April 15, 2028. X
indicates in a statement satisfying the requirements
of section 5.03(3) of this notice attached to its 2027
Federal income tax return that X intends to no lon-
ger apply the FVI exclusion option for purposes of
determining AFSI.
(b) Analysis. For purposes of determining the
AFSI of X, X will cease to apply the FVI exclusion
option for its taxable year beginning January 1, 2029,
because this is the taxable year that begins after April
15, 2028, the date on which X filed its Federal income
tax return containing a statement indicating its intent
to no longer apply the FVI exclusion option.
.07 Applicability date and reliance. It
is anticipated that the forthcoming pro-
posed regulations will provide that rules
consistent with the guidance described in
this section 5 will apply for taxable years
beginning on or after the date the final reg-
ulations addressing AFSI adjustments for
certain items measured at fair value are
published in the Federal Register. For tax-
able years beginning before the date those
forthcoming proposed regulations are
published in the Federal Register, taxpay-
ers may rely on the guidance described in
this section 5. A CAMT entity’s reliance
on the FVI exclusion option or the hedge
coordination option to determine AFSI for
a taxable year will not cause the CAMT
entity to become subject to, or to violate,
the reliance rules, including the consis-
tency requirements, provided in section
3.02(1) of this notice for that taxable year.
A CAMT entity that does not rely on the

October 27, 2025 638 Bulletin No. 2025–44
FVI exclusion option or hedge coordina-
tion option may continue to rely on pro-
posed § 1.56A-24 until the first taxable
year in which the forthcoming proposed
regulations are published in the Federal
Register.
SECTION 6. AFSI ADJUSTMENTS
FOR CAMT ENTITIES SUBJECT TO
THE TONNAGE TAX REGIME
.01 Purpose. In response to com-
ments, the Treasury Department and the
IRS anticipate that forthcoming pro-
posed regulations will include proposed
regulations issued under § 56A(c)(15)
and (e) consistent with the guidance in
this section 6, which provides adjust-
ments to AFSI for CAMT entities sub-
ject to subchapter R of chapter 1 of the
Code (tonnage tax regime). In addition,
the Treasury Department and the IRS
anticipate that the forthcoming proposed
regulations will propose modifications
to proposed § 1.59-2 to provide that, for
purposes of applying the average annual
AFSI test in § 59(k)(1)(B) or proposed
§ 1.59-2(c), AFSI is determined without
regard to the AFSI adjustments provided
in this section 6.
.02 Coordination of the CAMT rules
with the tonnage tax regime.
(1) CAMT entities to which this sec-
tion applies. The guidance in this sec-
tion applies only to a CAMT entity that
is an electing corporation as defined in
§ 1355(a)(1) or a corporation that is a
member of an electing group as defined in
§ 1355(a)(2).
(2) Gross income excluded under the
tonnage tax regime. The AFSI of a CAMT
entity is adjusted to disregard all or a por-
tion of any item of income on the CAMT
entity’s AFS that corresponds to all or
a portion of any item of income that is
excluded from the CAMT entity’s gross
income under § 1357(a) or (b) for regular
tax purposes.
(3) Deductions, credits, and losses dis-
allowed under the tonnage tax regime.
The AFSI of a CAMT entity is adjusted
to disregard all or a portion of any item
of expense, loss, or other reduction or
increase on the CAMT entity’s AFS that
corresponds to all or a portion of any item
of deduction, credit, or loss (including an
NOL deduction) that is disallowed under
§ 1357(c)(1) or 1358(b) for regular tax
purposes.
(4) Interest expense disallowed under
the tonnage tax regime. The AFSI of a
CAMT entity is adjusted to disregard the
portion of any item on the CAMT enti-
ty’s AFS that corresponds to an item of
interest expense that is disallowed under
§ 1357(c)(3) for regular tax purposes.
(5) Determination of gain or loss on
the disposition of a qualifying vessel. The
AFSI of a CAMT entity is adjusted to dis-
regard any gain or loss on the CAMT enti-
ty’s AFS from the disposition of a quali-
fying vessel (as defined by § 1355(a)(4)).
The AFSI of a CAMT entity is further
adjusted to include any gain or loss, for
regular tax purposes, resulting from the
CAMT entity’s disposition of such quali-
fying vessel, taking into account the rules
of § 1357(c)(2).
(6) Increase to AFSI for notional ship-
ping income. The AFSI of a CAMT entity
is increased by an amount equal to the
CAMT entity’s notional shipping income
for the taxable year as determined under
§ 1353.
.03 Determining applicable corpo-
ration status. For purposes of applying
the average annual AFSI test in § 59(k)
(1)(B) or proposed § 1.59-2(c), AFSI is
determined without regard to the AFSI
adjustments provided in section 6.02 of
this notice.
.04 Applicability date and reliance. It is
anticipated that the forthcoming proposed
regulations will provide that rules consis-
tent with the guidance described in section
6 of this notice will apply for taxable years
beginning on or after the date the final reg-
ulations addressing AFSI adjustments for
CAMT entities subject to the tonnage tax
regime are published in the Federal Reg-
ister. A CAMT entity that is subject to the
tonnage tax regime may rely on the guid-
ance described in this section 6 for taxable
years ending before the date the final reg-
ulations addressing the coordination of the
CAMT rules with the tonnage tax regime
are published in the Federal Register. A
CAMT entity that relies on the guidance
described in this section 6 must apply
section 6 in its entirety. A CAMT entity’s
reliance on any of the guidance in this
section 6 for a taxable year will not cause
the CAMT entity to become subject to,
or to violate, the proposed reliance rules,
including the consistency requirements,
provided in section 3.02(1) of this notice
for such taxable year.
SECTION 7. AFSI ADJUSTMENT
FOR CERTAIN EMBEDDED
DEPRECIATION DEDUCTIONS
.01 Purpose. In response to comments
provided on the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS anticipate that the forthcoming pro-
posed regulations will include proposed
regulations under § 56A(c)(15) and (e)
consistent with the guidance provided in
this section 7 to allow a CAMT entity to
reduce AFSI for a taxable year by the por-
tion of an NOL carryover attributable to
pre-2020 embedded depreciation deduc-
tions that is allowed as an NOL deduction
for such taxable year under § 172(a). In
addition, the Treasury Department and
the IRS anticipate that the forthcoming
proposed regulations will propose modi-
fications to proposed § 1.59-2 to provide
that, for purposes of applying the aver-
age annual AFSI test in § 59(k)(1)(B) or
proposed § 1.59-2(c), AFSI is determined
without regard to the AFSI adjustments
provided in section 7.03 of this notice.
.02 Definitions. For purposes of this
section 7:
(1) Applicable depreciation percent-
age. The term applicable depreciation
percentage means the fraction determined
under section 7.03(4) of this notice.
(2) Deductible tax depreciation. The
term deductible tax depreciation has the
same meaning as provided in proposed
§ 1.56A-15(b)(5).
(3) Eligible NOL deduction. The term
eligible NOL deduction means, with
respect to any pre-CAMT NOL(s), the
amount of the pre-CAMT NOL(s) carried
forward and allowed as a deduction under
§ 172(a) in computing taxable income for
the taxable year.
(4) Historical tax depreciation. The
term historical tax depreciation means the
amount of deductible tax depreciation and
tax COGS depreciation taken into account
in determining the pre-CAMT NOL for a
pre-CAMT NOL year.
(5) Original depreciation carryfor-
ward. The term original depreciation car-
ryforward means the amount determined
in section 7.03(5)(b)(i) of this notice.

Bulletin No. 2025–44 639 October 27, 2025
(6) Pre-CAMT NOL. The term pre-
CAMT NOL means an NOL, as deter-
mined under § 172(c), arising in a taxable
year ending on or before December 31,
2019.
(7) Pre-CAMT NOL year. The term
pre-CAMT NOL year means, with respect
to any pre-CAMT NOL, the taxable year
in which such pre-CAMT NOL arose.
(8) Remaining depreciation carryfor-
ward. The term remaining depreciation
carryforward means the amount deter-
mined in section 7.03(5)(b) of this notice.
(9) Section 168 property. The term sec-
tion 168 property has the same meaning
as provided in proposed § 1.56A-15(b)(6).
(10) Tax COGS depreciation. The
term tax COGS depreciation has the
same meaning as provided in proposed
§ 1.56A-15(b)(7), as determined under
proposed § 1.56A-15(d)(3).
.03 AFSI adjustment for pre-2020
embedded depreciation deductions.
(1) In general. A CAMT entity may
reduce its AFSI for a taxable year by an
amount equal to the portion of an eligible
NOL deduction for such taxable year that
is attributable to historical tax deprecia-
tion, as determined under section 7.03(2)
of this notice. This adjustment does not
apply for purposes of computing a CFC’s
adjusted net income or loss.
(2) Determination of the historical
depreciation portion of an eligible NOL
deduction. A CAMT entity may use any
reasonable approach to determine the por-
tion of an eligible NOL deduction that is
attributable to historical tax depreciation
(historical depreciation portion). The
Proportional Approach described in sec-
tion 7.03(4) and the Lesser-of Approach
described in section 7.03(5) are deemed
to be reasonable approaches. To the
extent a CAMT entity has an eligible
NOL deduction for a taxable year that is
attributable to more than one pre-CAMT
NOL, the CAMT entity may use different
approaches for determining the historical
depreciation portion of the eligible NOL
deduction with respect to each pre-CAMT
NOL.
(3) Reporting and consistency require-
ments.
(a) Reporting requirement. If a CAMT
entity makes the AFSI adjustment pro-
vided in section 7.03(1) of this notice for
a taxable year, it must attach a statement
to its Federal income tax return for such
taxable year. The statement must be titled
“AFSI adjustment for embedded depreci-
ation deductions” and include the CAMT
entity’s name, address, and taxpayer iden-
tification number, and a statement that
the CAMT entity is choosing to make the
AFSI adjustment for pre-2020 embedded
depreciation deductions under section
7.03(1) of Notice 2025-49 for the taxable
year. In addition, for each pre-CAMT NOL
comprising the AFSI adjustment for pre-
2020 embedded depreciation deductions,
the statement must provide the pre-CAMT
NOL year, the approach used to determine
the historical depreciation portion of an
eligible NOL deduction attributable to
such pre-CAMT NOL, and the amount
of the historical depreciation portion of
the eligible NOL deduction attributable
to such pre-CAMT NOL for the taxable
year. If the CAMT entity chooses to use
an approach for determining the histor-
ical depreciation portion other than the
Proportional Approach or the Lesser-of
Approach described in section 7.03(4)
and (5) of this notice, the statement must
include a description of the approach used.
(b) Consistency requirement. Once a
CAMT entity chooses to make the AFSI
adjustment under section 7.03(1) of this
notice for a taxable year with respect to
a pre-CAMT NOL, the CAMT entity
must continue making such AFSI adjust-
ment for each subsequent taxable year
in which the CAMT entity is allowed an
eligible NOL deduction with respect to
that pre-CAMT NOL or until such time
as prescribed by the Treasury Department
and IRS in regulations or other guidance.
Further, for each taxable year in which a
CAMT entity makes the adjustment under
section 7.03(1) of this notice with respect
to a pre-CAMT NOL, the CAMT entity
must use the same approach for determin-
ing the historical depreciation portion of
an eligible NOL deduction with respect to
such pre-CAMT NOL.
(4) Proportional Approach. Under
the Proportional Approach, the historical
depreciation portion of an eligible NOL
deduction for a taxable year is calculated
by multiplying the eligible NOL deduc-
tion for the taxable year by the applicable
depreciation percentage for the corre-
sponding pre-CAMT NOL. The applicable
depreciation percentage for a correspond-
ing pre-CAMT NOL means the fraction:
(i) the numerator of which is the CAMT
entity’s historical tax depreciation for the
pre-CAMT NOL year, and (ii) the denom-
inator of which is the sum of the CAMT
entity’s total cost of goods sold taken into
account in computing gross income for
regular tax purposes for that pre-CAMT
NOL year and the CAMT entity’s total
deductions allowed in computing taxable
income for regular tax purposes for that
pre-CAMT NOL year.
(5) Lesser-of Approach.
(a) In general. Under the Lesser-of
Approach, the historical depreciation por-
tion of an eligible NOL deduction for a
taxable year is the lesser of (i) the amount
of the remaining depreciation carryfor-
ward for the corresponding pre-CAMT
NOL as of the beginning of the taxable
year, as determined under section 7.03(5)
(b) of this notice, or (ii) the amount of the
eligible NOL deduction attributable to the
pre-CAMT NOL for such taxable year. If
the amounts in (i) and (ii) are equal, the
historical depreciation portion of an eli-
gible NOL deduction for the taxable year
equals such equal amount.
(b) Determination of remaining depre-
ciation carryforward as of the beginning
of the taxable year.
(i) Step 1. Calculate the amount of the
original depreciation carryforward for the
applicable pre-CAMT NOL as the lesser
of:
(A) the amount of the CAMT entity’s
historical tax depreciation for the pre-
CAMT NOL year; or
(B) the amount of the pre-CAMT NOL
for such pre-CAMT NOL year.
(ii) Step 2. The amount of the remain-
ing depreciation carryforward of the
pre-CAMT NOL as of the beginning of
a taxable year is the amount of the orig-
inal depreciation carryforward described
in Step 1 minus the cumulative amounts
attributable to such pre-CAMT NOL that
reduced AFSI under section 7.03(1) of this
notice for taxable years preceding the cur-
rent taxable year. For this purpose, such
cumulative amounts include amounts that
would have reduced AFSI if the CAMT
had been in effect in all taxable years pre-
ceding the taxable year and the CAMT
entity chose to make the adjustment under
this section 7.03(1) using the Lesser-of
Approach with respect to the correspond-

October 27, 2025 640 Bulletin No. 2025–44
ing pre-CAMT NOL in all such preceding
taxable years, as applicable.
.04 Determining applicable corpora-
tion status. For purposes of applying the
average annual AFSI test in § 59(k)(1)(B)
or proposed § 1.59-2(c), AFSI is deter-
mined without regard to the AFSI adjust-
ment provided in section 7.03(1) of this
notice.
.05 Examples. The following examples
illustrate the guidance in section 7.03 of
this notice. Unless otherwise specified, X
is an applicable corporation, uses the cal-
endar year for its taxable year and for its
financial accounting period year, and none
of its NOLs may be carried back under
§ 172(b)(1).
(1) Example 1. Proportional Approach.
(a) Facts: Taxable year 2018. For regular tax
purposes, X had a pre-CAMT NOL of $100x for its
taxable year ending December 31, 2018 (2018 pre-
CAMT NOL). For its taxable year ending Decem-
ber 31, 2018, X had $200x of total cost of goods
sold taken into account in computing gross income
and $300x of total deductions allowed in comput-
ing taxable income for regular tax purposes. The
amount of tax COGS depreciation and deductible
tax depreciation taken into account in determining
the 2018 pre-CAMT NOL (the historical tax depre-
ciation for the 2018 pre-CAMT NOL) was $50x.
X carried its 2018 pre-CAMT NOL forward under
§ 172(b)(2).
(b) Facts: Taxable year 2024. X’s taxable year
ending December 31, 2024, was the first taxable year
in which X was eligible to claim an NOL deduction
under § 172(a) with respect to the 2018 pre-CAMT
NOL. For its taxable year ending December 31,
2024, X claimed an eligible NOL deduction under
§ 172(a) attributable to the 2018 pre-CAMT NOL
of $30x. As such, X’s unused 2018 pre-CAMT NOL
to carry forward to its taxable year ending Decem-
ber 31, 2025, and subsequent taxable years under
§ 172(b)(2) is $70x.
(c) Facts: Taxable year 2025. During its tax-
able year ending December 31, 2025, X claims its
remaining 2018 pre-CAMT NOL carryforward as an
eligible NOL deduction under § 172(a) ($70x).
(d) Facts: AFSI adjustment for taxable years
2024 and 2025. For the taxable years ending
December 31, 2024, and December 31, 2025, X
makes the AFSI adjustment provided in section
7.03(1) of this notice with respect to its 2018
pre-CAMT NOL, and X attaches the statement
described in section 7.03(3)(a) of this notice to its
Federal income tax returns for both taxable years.
X chose to use the Proportional Approach to deter-
mine its historical depreciation portion of the eli-
gible NOL deductions that are attributable to the
2018 pre-CAMT NOL.
(e) Analysis: Determination of applicable depre-
ciation percentage for 2018 pre-CAMT NOL. Under
section 7.03(4) of this notice, X’s applicable depre-
ciation percentage for the 2018 pre-CAMT NOL is
10%, computed by dividing $50x, X’s historical tax
depreciation for the 2018 pre-CAMT NOL year, by
$500x, the sum of X’s total cost of goods sold taken
into account in computing gross income ($200x) and
X’s total deductions allowed in computing taxable
income for regular tax purposes ($300x) for the 2018
pre-CAMT NOL year ($50x / ($200x + $300x) =
10%).
(f) Analysis: AFSI adjustment for taxable year
ending December 31, 2024. Under the Proportional
Approach described in section 7.03(4) of this notice,
the historical depreciation portion of the eligible
NOL deduction for X’s taxable year ending Decem-
ber 31, 2024, is $3x, determined by multiplying the
amount of the eligible NOL deduction for 2024,
$30x, by the applicable depreciation percentage for
the 2018 pre-CAMT NOL, 10%. Accordingly, X
reduces AFSI for its taxable year ending December
31, 2024, under section 7.03(1) of this notice by $3x
($30x x 10%).
(g) Analysis: AFSI adjustment for taxable year
ending December 31, 2025. Since X chose to make
the AFSI adjustment under section 7.03(1) of this
notice with respect to the 2018 pre-CAMT NOL for
the taxable year ending December 31, 2024, X must
continue making the AFSI adjustment for the eligible
NOL deduction attributable to the 2018 pre-CAMT
NOL for its taxable year ending December 31, 2025.
Further, X must continue using the Proportional
Approach for determining the historical depreciation
portion of eligible NOL deductions attributable to
the 2018 pre-CAMT NOL. Thus, for its taxable year
ending December 31, 2025, X’s historical deprecia-
tion portion of the eligible NOL deduction attribut-
able to the 2018 pre-CAMT NOL is $7x, calculated
by multiplying the eligible NOL deduction for its
taxable year ending December 31, 2025, $70x, by
the applicable depreciation percentage for the 2018
pre-CAMT NOL, 10%. Accordingly, X reduces
AFSI for its taxable year ending December 31, 2025,
under section 7.03(1) of this notice by $7x ($70x x
10%).
(2) Example 2. Lesser-of Approach.
(a) Facts: Taxable year 2019. For regular tax
purposes, X had a pre-CAMT NOL of $30x (2019
pre-CAMT NOL) and $60x of historical tax depreci-
ation for its taxable year ending December 31, 2019.
X carried its 2019 pre-CAMT NOL forward under
§ 172(b)(2).
(b) Facts: Taxable year 2025. X’s taxable year
ending December 31, 2025, is the first taxable year
in which X is eligible to claim an NOL deduc-
tion under § 172(a) with respect to the 2019 pre-
CAMT NOL. X claims an eligible NOL deduction
for its taxable year ending December 31, 2025,
with respect to its 2019 pre-CAMT NOL of $5x.
As of December 31, 2025, X has an unused 2019
pre-CAMT NOL of $25x, which is carried forward
under § 172(b).
(c) Facts: Taxable year 2026. During its tax-
able year ending December 31, 2026, X claims the
remaining amount of its 2019 pre-CAMT NOL
carryforward as an eligible NOL deduction under
§ 172(a) ($25x).
(d) Facts: AFSI adjustment for taxable years
2025 and 2026. For the taxable years ending
December 31, 2025, and December 31, 2026, X
makes the AFSI adjustment provided in section
7.03(1) of this notice with respect to its 2019
pre-CAMT NOL, and X attaches the statement
described in section 7.03(3)(a) of this notice to its
Federal income tax returns for both taxable years.
X chooses to use the Lesser-of Approach to deter-
mine its historical depreciation portion of the eli-
gible NOL deductions that are attributable to the
2019 pre-CAMT NOL.
(e) Analysis: Determination of original depreci-
ation carryforward. Under section 7.03(5)(b)(i) of
this notice, X determines the amount of the original
depreciation carryforward for the 2019 pre-CAMT
NOL of $30x, which is the lesser of X’s historical
tax depreciation for the 2019 pre-CAMT NOL year,
$60x, or the amount of the pre-CAMT NOL for the
2019 pre-CAMT NOL year, $30x.
(f) Analysis: Determination of remaining depre-
ciation carryforward as of the beginning of the
taxable year ending December 31, 2025. As of the
beginning of X’s taxable year ending December 31,
2025, the amount of remaining depreciation carry-
forward of the 2019 pre-CAMT NOL is $30x, com-
puted by subtracting from the amount of the original
depreciation carryforward, $30x, the cumulative
amounts that reduced AFSI under section 7.03(1) of
this notice with respect to the 2019 pre-CAMT NOL
for taxable years preceding 2025, $0x.
(g) Analysis: AFSI adjustment for taxable year
ending December 31, 2025. Under the Lesser-of
Approach described in section 7.03(5) of this notice,
X’s historical depreciation portion of its eligible
NOL deduction attributable to its 2019 pre-CAMT
NOL is $5x, determined as the lesser of the remain-
ing depreciation carryforward attributable to the
2019 pre-CAMT NOL as of the beginning of X’s
taxable year ending December 31, 2025, $30x, or the
amount of the eligible NOL deduction attributable
to the 2019 pre-CAMT NOL, $5x. Accordingly, X
reduces its AFSI under section 7.03(1) of this notice
for its taxable year ending December 31, 2025, by
$5x.
(h) Analysis: AFSI adjustment for taxable year
ending December 31, 2026. Since X chose to make
the AFSI adjustment under section 7.03(1) of this
notice with respect to the 2019 pre-CAMT NOL
for the taxable year ending December 31, 2025,
X must continue making the AFSI adjustment for
the eligible NOL deduction attributable to the 2019
pre-CAMT NOL for its taxable year ending Decem-
ber 31, 2026. Further, X must continue using the
Lesser-of Approach for determining the historical
depreciation portion of eligible NOL deductions
attributable to the 2019 pre-CAMT NOL. Thus, as
of the beginning of X’s taxable year ending Decem-
ber 31, 2026, X’s remaining depreciation carryfor-
ward under section 7.03(5) of this notice for the
2019 pre-CAMT NOL is $25x, computed as the
original depreciation carryforward, $30x, minus the
cumulative amounts that reduced AFSI under sec-
tion 7.03(1) of this notice with respect to the 2019
pre-CAMT NOL for the taxable years preceding
X’s taxable year ending December 31, 2026, $5x.
Under section 7.03(5), X’s historical depreciation
portion of its eligible NOL deduction attributable
to its 2019 pre-CAMT NOL for its taxable year
ending December 31, 2026, is $25x, determined
as the lesser of the remaining depreciation carry-
forward for the 2019 pre-CAMT NOL as of the
beginning of the taxable year, $25x, or the amount
of the eligible NOL deduction for the taxable year

Bulletin No. 2025–44 641 October 27, 2025
ending December 31, 2026, attributable to the 2019
pre-CAMT NOL, $25x. Accordingly, X reduces its
AFSI under section 7.03(1) for its taxable year end-
ing December 31, 2026, by $25x.
.06 Applicability date and reliance. It
is anticipated that the forthcoming pro-
posed regulations will provide that rules
consistent with the guidance described
in this section 7 will apply for taxable
years beginning on or after the date the
final regulations addressing the adjust-
ment to AFSI for pre-2020 embedded
depreciation deductions are published in
the Federal Register. For taxable years
beginning before the date such forth-
coming proposed regulations are pub-
lished in the Federal Register, taxpayers
may rely on the guidance in this section
7. A CAMT entity’s reliance on any of
the guidance in this section 7 for a tax-
able year will not cause the CAMT entity
to become subject to, or to violate, the
proposed reliance rules, including the
consistency requirements, provided in
section 3.02(1) of this notice for such
taxable year.
SECTION 8. AFSI ADJUSTMENTS
FOR NONLIFE INSURANCE
COMPANY NOL CARRYBACKS
.01 Purpose. In response to comments
received on the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS anticipate that the forthcoming pro-
posed regulations will include proposed
regulations under § 56A(c)(15) and (e)
consistent with the guidance provided in
this section 8 to allow an eligible CAMT
entity to make certain adjustments to
AFSI for nonlife insurance company
NOL carrybacks. In addition, the Trea-
sury Department and the IRS anticipate
that the forthcoming proposed regula-
tions will propose a modification to pro-
posed § 1.59-2(c) to provide that, for
purposes of applying the average annual
AFSI test in § 59(k)(1)(B) or proposed
§ 1.59-2(c), AFSI is determined without
regard to the AFSI adjustments provided
in this section 8.
.02 Definitions. For purposes of this
section 8:
(1) Eligible CAMT entity. The term eli-
gible CAMT entity means a CAMT entity
that is a nonlife insurance company.
(2) Eligible return. The term eligible
return means either an amended return for
an NOL carryback year or an application
for tentative carryback adjustment that
includes the carryback of a nonlife insur-
ance company NOL to an NOL carryback
year.
(3) Financial statement net operating
loss (FSNOL). The term financial state-
ment net operating loss has the meaning
provided in proposed § 1.56A-23(b).
(4) Loss year. The term loss year
means the taxable year in which an NOL
arose for regular tax purposes.
(5) NOL carryback year. The term
NOL carryback year means a taxable year
to which a nonlife insurance company
NOL is carried under § 172(b)(1)(C)(i).
(6) Nonlife insurance company. The
term nonlife insurance company means an
insurance company, as defined in § 816(a),
other than a life insurance company.
(7) Nonlife insurance company NOL.
The term nonlife insurance company NOL
means a net operating loss of a nonlife
insurance company subject to § 172(b)(1)
(C) for regular tax purposes.
.03 AFSI adjustments for nonlife insur-
ance companies.
(1) AFSI adjustment for an NOL car-
ryback year. If an eligible CAMT entity
takes an NOL deduction for regular tax
purposes on an eligible return for an NOL
carryback year, the AFSI for such taxable
year is reduced by an amount equal to the
NOL deduction taken for regular tax pur-
poses for such taxable year (NOL carry-
back amount).
(2) AFSI adjustment for taxable years
succeeding a loss year.
(a) In general. If an eligible CAMT
entity reduces AFSI by an NOL carryback
amount for an NOL carryback year under
section 8.03(1) of this notice, that CAMT
entity has a corresponding increase to
AFSI in one or more later taxable years
under section 8.03(2)(b) of this notice
equal to the absolute value of the reduc-
tion to AFSI for the NOL carryback year
under section 8.03(1) of this notice (NOL
inclusion). If a nonlife insurance company
NOL results in an NOL deduction for
more than one NOL carryback year, the
NOL inclusions resulting from those NOL
carryback amounts must be combined and
treated as a single NOL inclusion for pur-
poses of section 8.03(2)(b) of this notice.
(b) Timing and amount of NOL inclu-
sion.
(i) In general. The entire amount of
an NOL inclusion is carried to the first
taxable year succeeding the loss year of
the nonlife insurance company NOL, the
carryback of which gave rise to the NOL
inclusion. For such taxable year and any
relevant subsequent taxable year, AFSI is
increased by the lesser of—
(A) The remaining NOL inclusion as of
the beginning of the taxable year; or
(B) The absolute value of any reduc-
tion to AFSI taken into account for the
taxable year under § 56A(d) or proposed
§ 1.56A-23(c), reduced (but not below
zero) by the amount of any other increase
to AFSI for an NOL inclusion for the tax-
able year that is attributable to an earlier
loss year.
(ii) Remaining NOL inclusion. For
purposes of section 8.03(2)(b)(i)(A) of
this notice, the remaining NOL inclusion
means the amount of the NOL inclusion
determined under section 8.03(2)(a) of
this notice, reduced (but not below zero)
by any amount of that NOL inclusion
taken into account as an increase to AFSI
under section 8.03(2)(b)(i) of this notice
in a prior taxable year.
.04 Determining applicable corpora-
tion status. For purposes of applying the
average annual AFSI test in § 59(k)(1)(B)
or proposed § 1.59-2(c) for any taxable
year, AFSI is determined without regard
to the AFSI adjustments provided in sec-
tion 8.03 of this notice.
.05 Applicability date and reliance. It
is anticipated that the forthcoming pro-
posed regulations will provide that rules
consistent with the guidance described
in section 8 of this notice will apply
for taxable years beginning on or after
the date the final regulations address-
ing AFSI adjustments related to nonlife
insurance company NOL carrybacks
are published in the Federal Register.
For taxable years beginning before the
date those forthcoming regulations are
published in the Federal Register, tax-
payers may rely on the guidance in this
section 8. A taxpayer’s reliance on the
guidance in this section 8 for a taxable
year will not cause the corporation to
become subject to, or to violate, the
proposed reliance rules, including the
consistency requirements, provided in
section 3.02(1) of this notice for that
taxable year.

October 27, 2025 642 Bulletin No. 2025–44
SECTION 9. AFSI ADJUSTMENT
FOR ELIGIBLE GOODWILL
AMORTIZATION
.01 Purpose. In response to comments
received on the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS anticipate that the forthcoming pro-
posed regulations will include proposed
regulations under § 56A(c)(15) and (e)
consistent with the guidance provided in
this section 9 to allow a CAMT entity to
adjust AFSI for eligible goodwill that is
amortizable under § 197 and acquired in
a transaction that was announced to the
public on or before October 28, 2021 (the
date the House of Representatives Com-
mittee on Rules released the first version
of the legislative text of H.R. 5376 that
contained the CAMT), or if such trans-
action was not announced to the public,
closed and completed on or before Octo-
ber 28, 2021. In addition, the Treasury
Department and the IRS anticipate that
the forthcoming proposed regulations
will propose modifications to proposed
§ 1.59-2 to provide that, for purposes of
applying the average annual AFSI test in
§ 59(k)(1)(B) or proposed § 1.59-2(c),
AFSI is determined without regard to the
AFSI adjustments provided in sections
9.04 and 9.05 of this notice.
.02 Definitions. For purposes of this
section 9:
(1) Covered book goodwill amorti-
zation expense. The term covered book
goodwill amortization expense means any
of the following items that are taken into
account in FSI with respect to eligible
goodwill--
(a) Amortization expense;
(b) Other recovery of AFS basis
(including from an impairment loss) that
occurs prior to the taxable year in which
the disposition of the eligible goodwill
occurs for regular tax purposes; or
(c) Impairment loss reversal.
(2) Covered book goodwill expense.
The term covered book goodwill expense
means an amount (if any), other than cov-
ered book goodwill amortization expense,
that--
(a) Reduces FSI; and
(b) Is reflected in the basis for depre-
ciation, as defined in §§ 1.167(g)-1 and
1.197-2(f)(1)(ii) (determined without
regard to any basis adjustments described
in § 1016(a)(2) and (3)), of eligible good-
will for regular tax purposes.
(3) Deductible goodwill tax amorti-
zation. The term deductible goodwill tax
amortization means eligible goodwill tax
amortization, as defined in section 9.02(5)
of this notice, that is allowed as a deduc-
tion in computing taxable income.
(4) Eligible goodwill. The term eligible
goodwill means goodwill that meets the
requirements of section 9.03 of this notice.
(5) Eligible goodwill tax amortization.
The term eligible goodwill tax amorti-
zation means amortization deductions
allowed under § 197 with respect to eligi-
ble goodwill.
.03 Eligible goodwill.
(1) In general. For purposes of section
9 of this notice, eligible goodwill is good-
will that is--
(a) An amortizable section 197 intangi-
ble under § 197(c)(1) and (d)(1)(A); and
(b) Acquired in a transaction that was
either (i) announced to the public on or
before October 28, 2021, or (ii) if such
transaction was not announced to the pub-
lic, closed and completed on or before
October 28, 2021.
(2) Eligible goodwill that is not depre-
ciable under § 197 for regular tax pur-
poses. Eligible goodwill does not include
goodwill that is not subject to amortiza-
tion under § 197 for regular tax purposes.
.04 AFSI adjustment for eligible good-
will.
(1) In general. The AFSI of a CAMT
entity for a taxable year may be adjusted
as follows--
(a) Reduced by deductible goodwill tax
amortization with respect to eligible good-
will, but only to the extent of the amount
allowed as a deduction in computing tax-
able income for the taxable year; and
(b) Adjusted to disregard covered book
goodwill amortization expense and cov-
ered book goodwill expense, and amounts
described in section 9.05(6) of this notice
with respect to eligible goodwill, includ-
ing eligible goodwill placed in service
for regular tax purposes in a taxable year
subsequent to the taxable year the eligible
goodwill is treated as placed in service for
AFS purposes
(2) Eligible goodwill held by a part-
nership. If eligible goodwill is held by
a partnership, rules similar to proposed
§ 1.56A-16(d)(2) apply. However, if
the CAMT entity otherwise applies any
proposed modifications to the proposed
CAMT regulations in Notice 2025-28, the
CAMT entity must apply any applicable
modifications in determining the effect
of the partnership’s eligible goodwill on
AFSI for the taxable year.
(3) Consistency requirement. If a
CAMT entity chooses to make the adjust-
ment to AFSI provided in this section
9.04 for a taxable year and has eligible
goodwill attributable to more than one
transaction described in section 9.03(1)
(b) of this notice as of the beginning of
such taxable year, the CAMT entity must
make the AFSI adjustment provided in
this section 9.04 with respect to all such
eligible goodwill. In addition, once a
CAMT entity chooses to make the AFSI
adjustment provided in this section 9.04
for a taxable year, such CAMT entity must
continue making such adjustment for all
subsequent taxable years until all such eli-
gible goodwill is disposed of for regular
tax purposes or such time as prescribed by
the Treasury Department and IRS in regu-
lations or other guidance.
.05 AFSI adjustment upon disposition
of eligible goodwill.
(1) In general. In the case of a CAMT
entity that makes the adjustment provided
in section 9.04 of this notice to determine
AFSI for any taxable year, except as oth-
erwise provided in section 9.05(7) of this
notice, if such CAMT entity disposes of
eligible goodwill for regular tax purposes,
the CAMT entity must adjust AFSI for
the taxable year in which the disposition
occurs to redetermine any gain or loss
taken into account in the CAMT entity’s
FSI with respect to the disposition for the
taxable year (including a gain or loss of
zero) by reference to the CAMT basis (in
lieu of the AFS basis) of the eligible good-
will as of the date of the disposition (dis-
position date), as determined under sec-
tion 9.05(2) of this notice. To the extent
the CAMT basis of the eligible goodwill is
negative (for example, because of differ-
ences between regular tax basis and AFS
basis), this negative amount is required to
be recognized as AFSI gain upon disposi-
tion of the eligible goodwill.
(2) Adjustments to the AFS basis of eli-
gible goodwill. For purposes of applying
section 9.05(1) of this notice, the CAMT
basis of the eligible goodwill as of the dis-

Bulletin No. 2025–44 643 October 27, 2025
position date is the AFS basis of the eligi-
ble goodwill as of that date--
(a) Decreased by the full amount of
eligible goodwill tax amortization with
respect to such goodwill as of the dis-
position date (regardless of whether any
amount of eligible goodwill tax amorti-
zation was capitalized for regular tax pur-
poses and not yet taken into account as a
reduction to AFSI through an adjustment
described in section 9.04(1)(a) of this
notice as of the disposition date);
(b) Increased by the amount of any
covered book goodwill expense with
respect to such property;
(c) Increased by the amount of any cov-
ered book goodwill amortization expense,
if any, that reduced the AFS basis of such
property as of the disposition date;
(d) Decreased by any reduction to the
CAMT basis of such property under pro-
posed § 1.56A-21, taking into account
the proposed modifications to proposed
§ 1.56A-21 contained in Notice 2025-46
if the CAMT entity otherwise applies such
modifications in determining AFSI for the
taxable year; and
(e) Increased or decreased, as appropri-
ate, by the amount of any adjustments to
AFS basis that are disregarded for AFSI
and CAMT basis purposes under the
CAMT Proposed Regulations with respect
to such goodwill, taking into account any
proposed modifications to the CAMT Pro-
posed Regulations contained in Notice
2025-46 if the CAMT entity otherwise
applies such modifications in determining
AFSI for the taxable year.
(3) Special rules regarding adjustments
to the AFS basis of eligible goodwill. For
purposes of determining the CAMT basis
of the eligible goodwill under section
9.05(2) of this notice, rules similar to pro-
posed § 1.56A-16(e)(2)(ii) apply.
(4) Disposition of eligible goodwill by
a partnership. If a partnership disposes
of eligible goodwill, rules similar to pro-
posed § 1.56A-16(e)(3) apply. However,
if the CAMT entity otherwise applies any
proposed modifications to the proposed
CAMT regulations in Notice 2025-28, the
CAMT entity must apply any applicable
modifications in determining the effect of
the disposition on AFSI for the taxable
year.
(5) Treatment of amounts recognized
in FSI upon the disposition of eligible
goodwill. Except as otherwise provided
in the CAMT Proposed Regulations (or
as otherwise provided in Notice 2025-28
or Notice 2025-46 if the CAMT entity
applies a proposed modification to the
CAMT Proposed Regulations contained in
such notices), if a CAMT entity disposes
of eligible goodwill for regular tax pur-
poses and recognizes gain or loss from the
disposition in its FSI, the gain or loss (as
redetermined under section 9.05(1) of this
notice) is recognized for AFSI purposes in
the taxable year of disposition, regardless
of whether any gain or loss with respect
to the disposition is realized, recognized,
deferred, or otherwise taken into account
for regular tax purposes.
(6) Subsequent AFS dispositions. If eli-
gible goodwill is disposed of for regular
tax purposes before it is treated as dis-
posed of for AFS purposes, any AFS basis
recovery with respect to such eligible
goodwill that is reflected in FSI following
the date such eligible goodwill is disposed
of for regular tax purposes is disregarded
in determining AFSI.
(7) Intercompany transactions. If a
member of a tax consolidated group dis-
poses of eligible goodwill for regular tax
purposes in an intercompany transaction,
rules similar to proposed § 1.56A-16(e)
(6) apply, taking into account any appli-
cable proposed modifications to proposed
§ 1.1502-56A contained in Notice 2025-
46 if the member otherwise applies such
modifications in determining AFSI for the
taxable year.
.06 Determining applicable corpora-
tion status. For purposes of applying the
average annual AFSI test in § 59(k)(1)(B)
or proposed § 1.59-2(c), AFSI is deter-
mined without regard to the AFSI adjust-
ments provided in sections 9.04 and 9.05
of this notice.
.07 Applicability date and reliance. It is
anticipated that the forthcoming proposed
regulations will provide that rules consis-
tent with the guidance described in section
9 of this notice will apply for taxable years
beginning on or after the date of the final
regulations addressing the adjustment to
AFSI for eligible goodwill are published
in the Federal Register. For taxable years
beginning before the date such forthcom-
ing proposed regulations are published in
the Federal Register, taxpayers may rely
on the guidance in this section 9. A CAMT
entity’s reliance on any of the guidance in
this section 9 for a taxable year will not
cause the CAMT entity to become sub-
ject to, or to violate, the proposed reliance
rules, including the consistency require-
ments, provided in section 3.02(1) of this
notice for such taxable year.
SECTION 10. AFSI ADJUSTMENTS
FOR ACCOUNTING PRINCIPLE
CHANGES AND RESTATEMENTS OF
A PRIOR YEAR AFS
.01 Purpose. In response to comments
received on the CAMT Proposed Regu-
lations, the Treasury Department and the
IRS anticipate that the forthcoming pro-
posed regulations will include modifica-
tions to proposed § 1.56A-17(c)(2) and (d)
(1) consistent with the guidance provided
in this section 10, which provides a sim-
plified approach to determine the account-
ing principle change amount and the AFSI
restatement adjustment.
.02 Accounting principle change
amount.
(1) In general. (a) Except as provided in
section 10.02(2) of this notice, if a CAMT
entity implements a change in accounting
principle in its AFS for a taxable year, the
accounting principle change amount is
equal to the amount of the net cumulative
adjustment to the CAMT entity’s begin-
ning retained earnings for the taxable year
that results from the change in accounting
principle, adjusted to--
(i) Disregard any portion of the cumu-
lative retained earnings adjustment attrib-
utable to taxable years ending on or before
December 31, 2019; and
(ii) Reflect the AFSI adjustments pro-
vided in § 56A, the CAMT Proposed Reg-
ulations, or other guidance to the extent
the cumulative retained earnings adjust-
ment is attributable to FSI items to which
those AFSI adjustments apply.
(b) Except as provided in section
10.02(2) of this notice, if a CAMT entity
is treated as implementing a change in
accounting principle under proposed
§ 1.56A-17(c)(5) for a taxable year, the
accounting principle change amount
is equal to the difference between the
CAMT entity’s beginning retained earn-
ings reflected in the CAMT entity’s cur-
rent AFS as of the beginning of the tax-
able year and the CAMT entity’s ending

October 27, 2025 644 Bulletin No. 2025–44
retained earnings reflected in the CAMT
entity’s former AFS as of the end of the
immediately preceding taxable year
(retained earnings difference), adjusted
to--
(i) Disregard any portion of the cumu-
lative retained earnings adjustment attrib-
utable to taxable years ending on or before
December 31, 2019; and
(ii) Reflect the AFSI adjustments pro-
vided in § 56A, the CAMT Proposed Reg-
ulations, or other guidance to the extent
the cumulative retained earnings adjust-
ment is attributable to FSI items to which
those AFSI adjustments apply.
(2) Simplified accounting principle
change amount. A CAMT entity that
implements a change in accounting
principle, or is treated as implementing
a change in accounting principle under
proposed § 1.56A-17(c)(5), for a taxable
year may use the simplified account-
ing principle change amount described
in this section 10.02(2) in place of the
accounting principle change amount.
The simplified accounting principle
change amount is the accounting prin-
ciple change amount described in sec-
tion 10.02(1)(a) or (b) of this notice, as
applicable, determined without regard to
section 10.02(1)(a)(i) or 10.02(1)(b)(i) of
this notice, respectively.
.03 AFSI restatement adjustment.
(1) In general. Except as provided in
section 10.03(2) of this notice, if a CAMT
entity issues a restated AFS and, as a
result, the CAMT entity’s FSI for a tax-
able year ending after December 31, 2019,
is restated on or after the date the CAMT
entity filed its original Federal income tax
return for such taxable year (restatement
year), the CAMT entity accounts for the
restatement by adjusting its AFSI for the
taxable year in which the restated AFS
is issued (AFSI restatement adjustment).
The AFSI restatement adjustment equals
the cumulative effect of the restatement on
the CAMT entity’s FSI for the restatement
year, including any restatement of the
CAMT entity’s beginning retained earn-
ings for the restatement year, adjusted to--
(a) Disregard any portion of the
retained earnings restatement attribut-
able to taxable years ending on or before
December 31, 2019; and
(b) Reflect the AFSI adjustments pro-
vided in § 56A, the CAMT Proposed Reg-
ulations, or other guidance to the extent
the AFSI restatement adjustment relates
to one or more FSI items to which AFSI
adjustments provided in § 56A, the CAMT
Proposed Regulations, or other guidance
apply. For example, to the extent the AFSI
restatement adjustment includes a Federal
income tax component, § 56A(c)(5) and
proposed § 1.56A-8 apply to disregard
that component.
(2) Simplified AFSI restatement adjust-
ment. A CAMT entity required to make
an AFSI restatement adjustment for a
taxable year, pursuant to section 10.03(1)
of this notice, may use the simplified
restatement adjustment described in this
section 10.03(2) in place of the AFSI
restatement adjustment. The simplified
AFSI restatement adjustment is the AFSI
restatement adjustment described in sec-
tion 10.03(1) of this notice, determined
without regard to section 10.03(1)(a) of
this notice.
.04 Applicability date and reliance. It
is anticipated that the forthcoming pro-
posed regulations will provide that rules
consistent with the guidance described
in section 10 of this notice will apply to
changes in accounting principle imple-
mented in, and restated AFS issued in,
taxable years beginning on or after the
date the final regulations addressing AFSI
adjustments for accounting principle
change amounts and AFSI restatement
adjustments are published in the Fed-
eral Register. For changes in accounting
principle implemented in, and restated
AFS issued in, taxable years beginning
before the date such forthcoming pro-
posed regulations are published in the
Federal Register, taxpayers may rely on
the guidance in this section 10. However,
regardless of when such forthcoming
proposed regulations are published in the
Federal Register, a taxpayer may rely on
the guidance provided in this section 10,
for accounting principle changes imple-
mented in, and restated AFS issued in,
any taxable year beginning before Janu-
ary 1, 2026. A CAMT entity’s reliance on
any of the guidance in this section 10 for
a taxable year will not cause the CAMT
entity to become subject to, or to violate,
the proposed reliance rules, including
the consistency requirements, provided
in section 3.02(1) of this notice for such
taxable year.
SECTION 11. REQUEST FOR
COMMENTS
.01 Comments regarding guidance
provided in section 5 of this notice. The
Treasury Department and the IRS request
comments on the interim guidance set
forth in section 5 of this notice.
(1) Interim AFSI adjustments for
certain fair value items. The Treasury
Department and the IRS continue to study
whether the interim guidance described
in this section 5 creates unintended
results, including mismatches or distor-
tions between AFSI and regular taxable
income, and request comments identify-
ing those unintended results. Comment-
ers are also encouraged to specify the
issues on which additional guidance is
needed for fair value items.
(2) Coordination with proposed
§ 1.56A-22. The Treasury Department
and the IRS request comments on how
the rules in proposed § 1.56A-22(c) and
proposed § 1.56A-22(d) and the guidance
described in section 5.02 through section
5.07 of this notice should be coordinated.
.02 Procedures for Submitting Com-
ments.
(1) Deadline. Written comments should
be submitted by December 1, 2025. Con-
sideration will also be given to any writ-
ten comment submitted after December 1,
2025, although such comments may not
be considered in the development of the
forthcoming proposed regulations if such
consideration would delay the publication
of the forthcoming proposed regulations.
(2) Form and manner. The subject line
for the comments should include a refer-
ence to Notice 2025-49. All commenters
are strongly encouraged to submit com-
ments electronically. Comments may be
submitted in one of two ways:
(a) electronically via the Federal
eRulemaking Portal at https://www.reg-
ulations.gov (type IRS-2025-0202 in the
search field on the https://www.regula-
tions.gov homepage to find this notice and
submit comments); or
(b) by mail to: Internal Revenue Ser-
vice, CC:PA:01:PR (Notice 2025-49),
Room 5203, P.O. Box 7604, Ben Franklin
Station, Washington, D.C., 20044.
(3) Publication of comments. The Trea-
sury Department and the IRS will publish
for public availability any comment sub-

Bulletin No. 2025–44 645 October 27, 2025
mitted electronically and on paper to the
IRS’s public docket on https://www.regu-
lations.gov.
SECTION 12. PAPERWORK
REDUCTION ACT
The Paperwork Reduction Act of 1995
(44 U.S.C. §§ 3501-3520) (PRA) required
that a Federal agency obtain the approval
of the Office of Management and Bud-
get (OMB) before collecting information
from the public, whether such collection
of information is mandatory, voluntary, or
required to obtain or retain a benefit. An
agency may not conduct or sponsor, and a
person is not required to respond to, a col-
lection of information unless the collec-
tion of information displays a valid OMB
control number.
The collections of information in this
notice are in sections 4.04(3), 5.03(2) and
(3), 5.04(2) and (3), and 7.03(3)(a) of this
notice.
Section 4.04(3) of this notice requires
a CAMT entity to file a statement with its
Federal income tax return if it chooses to
use a reasonable method to determine reg-
ulatory asset book inventoriable depreci-
ation under section 4.04(2) of this notice
to make the AFSI adjustment described
in section 4 of this notice. The informa-
tion requested in section 4.04(3) of this
notice is required to obtain the benefit of
making the AFSI adjustment described in
section 4 of this notice. This information
will be used by the IRS to confirm com-
pliance with the guidance in section 4 of
this notice. The likely respondents are cor-
porations.
Section 5.03(2) and 5.04(2) of this
notice requires a CAMT entity to file a
statement with its Federal income tax
return if it chooses to apply the FVI
exclusion option or hedge coordination
option. The information requested in sec-
tion 5.03(2) and 5.04(2) of this notice is
required to obtain the benefit of using the
FVI exclusion option or hedge coordina-
tion option. This information will be used
by the IRS to confirm compliance with the
FVI exclusion option or hedge coordina-
tion option. The likely respondents are
corporations.
Section 5.03(3) and 5.04(3) of this
notice requires a CAMT entity to file a
statement with its Federal income tax
return if it chooses to no longer apply the
FVI exclusion option or hedge coordina-
tion option. The information requested in
section 5.03(3) and 5.04(3) of this notice
is required to no longer obtain the bene-
fit of using the FVI exclusion option or
hedge coordination option. This informa-
tion will be used by the IRS to confirm
whether the CAMT entity ceases to apply
the FVI exclusion option or hedge coordi-
nation option. The likely respondents are
corporations.
Section 7.03(3)(a) of this notice requires
a CAMT entity to file a statement with its
Federal income tax return if it chooses to
make the AFSI adjustment described in
section 7.03 of this notice. The informa-
tion requested in section 7.03(3)(a) of this
notice is required to obtain the benefit of
making the AFSI adjustment described in
section 7.03 of this notice. This informa-
tion will be used by the IRS to confirm
compliance with the guidance in section
7 of this notice. The likely respondents are
corporations.
The reporting requirements in this
notice will be included within OMB con-
trol number 1545-0123 in accordance
with the PRA procedures under 5 CFR
§ 1320.10. The recordkeeping require-
ments are considered general tax records
under § 1.6001-1(e). For PRA purposes,
general tax records are already approved
by OMB under 1545-0123 for business
filers.
Books or records relating to a collec-
tion of information must be retained as
long as their contents may become mate-
rial in the administration of any internal
revenue law. Generally, tax returns and
tax return information are confidential, as
required by § 6103.
SECTION 13. DRAFTING AND
CONTACT INFORMATION
The principal authors of this notice
are Samuel Terhaar of the Office of the
Associate Chief Counsel (Income Tax &
Accounting); Justin Karlin of the Office
of Associate Chief Counsel (Financial
Institutions & Products); and Timothy
Blauch of the Associate Chief Counsel
(International). Other personnel from the
Treasury Department and the IRS par-
ticipated in its development. For further
information regarding sections 4, 7, and
9 of this notice, contact the Office of the
Associate Chief Counsel (Income Tax
& Accounting), Branch 7, at (202) 317-
7005 (not a toll-free number). For further
information regarding section 5 of this
notice, contact Justin Karlin at (202) 317-
6842 (not a toll-free number). For further
information regarding section 6 of this
notice, please contact Timothy Blauch at
(202) 317-3485 (not a toll-free number).
For further information regarding section
10 of this notice, contact James Yu at
(202) 317-4718. For further information
regarding sections 3 and 8 and all other
aspects of this notice, contact Madeline
Padner at (202) 317-7006 (not a toll-free
number).

October 27, 2025 646 Bulletin No. 2025–44
NOTE. This revenue procedure will be reproduced as the next revision of IRS Publication 1167, General Rules and Specifications for Substitute Forms and Schedules.
Rev. Proc. 2025-27
TABLE OF CONTENTS
Part 1 – INTRODUCTION TO SUBSTITUTE FORMS
Section 1.1 – Overview of Revenue Procedure 2025-27 .....................................................647
Section 1.2 – IRS Contacts ............................................................................648
Section 1.3 – What’s New .............................................................................649
Section 1.4 – Definitions ..............................................................................649
Section 1.5 – Agreement ..............................................................................651
Part 2 – GENERAL GUIDELINES FOR SUBMISSIONS AND APPROVALS
Section 2.1 – General Specifications for Approval ..........................................................652
Section 2.2 – Highlights of Permitted Changes and Requirements .............................................654
Section 2.3 – Vouchers ...............................................................................654
Section 2.4 – Restrictions on Changes ...................................................................657
Section 2.5 – Guidelines for Obtaining IRS Approval .......................................................657
Section 2.6 – Office of Management and Budget (OMB) Requirements for All Substitute Forms .....................660
Part 3 – PHYSICAL ASPECTS AND REQUIREMENTS
Section 3.1 – General Guidelines for Substitute Forms ......................................................661
Section 3.2 – Paper ..................................................................................663
Section 3.3 – Printing ................................................................................664
Section 3.4 – Margins ................................................................................666
Section 3.5 – Miscellaneous Information for Substitute Forms ................................................666
Part 4 – ADDITIONAL RESOURCES
Section 4.1 – Guidance From Other Revenue Procedures ....................................................667
Section 4.2 – Electronic Tax Products ...................................................................667
Part 5 – REQUIREMENTS FOR SPECIFIC TAX RETURNS
Section 5.1 – Tax Returns (Forms 1040, 1040-SR, 1120, etc.). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .668
Section 5.2 – Changes Permitted to Graphics (Form 1040 or 1040-SR) .........................................669
Part 6 – FORMAT AND CONTENT OF SUBSTITUTE RETURNS
Section 6.1 – Acceptable Formats for Substitute Forms and Schedules ..........................................671
Section 6.2 – Additional Instructions for All Forms .........................................................672
Part 7 – MISCELLANEOUS FORMS AND PROGRAMS
Section 7.1 – Specifications for Substitute Schedules K-1 ....................................................674
Section 7.2 – Guidelines for Substitute Forms 8655 .........................................................680
Section 7.3 – Guidelines for Substitute Image Character Recognition (ICR) Forms ................................681
Part 8 – ADDITIONAL INFORMATION
Section 8.1 – Forms for Electronically Filed Returns ........................................................682
Section 8.2 – Effect on Other Documents .................................................................682
Section 8.3 – Exhibits ................................................................................683

Bulletin No. 2025–44 647 October 27, 2025
Part 1
Introduction to Substitute Forms
Section 1.1 – Overview of Revenue Procedure 2025-27
1.1.1
Purpose
The purpose of this revenue procedure is to provide guidelines and general requirements for the
development, printing, and approval of the 2025 substitute tax forms. Approval will be based on
these guidelines. After review and approval, submitted forms will be accepted as substitutes for
official IRS forms.
1.1.2
Unique Forms
Certain unique specialized forms require the use of other publications that supplement this
publication. See Part 4.
1.1.3
Scope
The IRS accepts quality substitute tax forms that are consistent with the official forms and have no
adverse impact on processing. The IRS Substitute Forms Program (the Program) administers the
formal acceptance and processing of these forms nationwide. While this Program deals with paper
documents, it also reviews for approval other processing and filing forms used in electronic filing.
Only those substitute forms that fully comply with these requirements are acceptable. This revenue
procedure is updated as required to reflect pertinent tax year form changes and to meet processing
and/or legislative requirements.
1.1.4
Forms Covered by This
Revenue Pr
ocedure
The following types of forms are covered by this revenue procedure.
• IRS tax forms and their related schedules.
• Worksheets as they appear in the instructions.
• Applications for permission to file returns electronically and forms used as required
documentation for electronically filed returns.
• Powers of Attorney.
• Over-the-counter estimated tax payment vouchers.
• Forms and schedules relating to partnerships, exempt organizations, and employee plans.
1.1.5
Forms Not Covered by
This
Revenue Procedure
The following types of forms are not covered by this revenue procedure. Refer to the publication
for questions.
• W-2 and W-3. See Pub. 1141, General Rules and Specifications for Substitute Forms W-2 and
W-3.
• W-2c and W-3c. See Pub. 1223, General Rules and Specifications for Substitute Forms W-2c
and W-3c.

October 27, 2025 648 Bulletin No. 2025–44
• 941 and attached schedules. See Pub. 4436, General Rules and Specifications for Substitute
Form 941, Schedule B (Form 941), Schedule D (Form 941), Schedule R (Form 941), and
Form 8974.
• 1096, 1097-BTC, 1098 series, 1099 series, 3921, 3922, 5498 series, W-2G, and 1042-S. See
Pub. 1179, General Rules and Specifications for Substitute Forms 1096, 1098, 1099, 5498,
and Certain Other Information Returns.
• 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C. See Pub. 5223, General Rules and
Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C,
and 1095-C.
• 8027. See Pub. 1239, Specifications for Electronic Filing of Form 8027, Employer’s Annual
Information Return of Tip Income and Allocated Tips.
• Forms 1040-ES (OCR) and 1041-ES (OCR), which may not be reproduced.
• Form 5500 series (for more information on these forms, go to the Department of Labor
website at https://www.efast.dol.gov).
• Forms used internally by the IRS.
• State tax forms.
• Forms developed outside the IRS.
1.1.6
Other Information Not
Covered by This Revenue
Procedure
The following information is not covered by this revenue procedure.
• Requests for information or documentation initiated by the IRS.
• General Instructions and Specific Instructions (these are not reviewed by the Program).
Section 1.2 – IRS Contacts
1.2.1
Where
To Send Substitute
Forms
Send your substitute forms for approval to the following offices. Do not send forms with taxpayer
data.
FormOffice and Address
5500Check EFAST2 information at the Department
of Labor website at https://www.efast.dol.gov.
Software developer vouchers
(see Sections 2.3.7–2.3.9)
Internal Revenue Service
Attn: Jason Lane
3211 S. Northpointe Dr.
Santa Fe Bldg. Rm 3007
Fresno, CA 93725
Jason.L.Lane@irs.gov
ACA Forms 1094-B, 1095-B, 1094-C, and
1095-C (for more information, see Pub.
5223), and Schedule K-1 forms must be
emailed for scannability testing.
mailto:scrips@irs.gov

Bulletin No. 2025–44 649 October 27, 2025
FormOffice and Address
Schedule K-1 2-D bar-coded formsFor mailing addresses for sending
Schedule K-1
2-D bar-coded forms for testing, see
Section 7.1.6.
All others covered by this publication
(see Section 1.1.4)
Internal Revenue Service
Attn: Substitute Forms Program
SE:W:CAR:MP:P:TP:TP
ATSC
4800 Buford Highway
Mail Stop: 061-N
Chamblee, GA 30341
substituteforms@irs.gov
Section 1.3 – What’s New
1.3.1
What’
s New
The following changes have been made to this year’s revenue procedure.
• .01 Editorial changes. We made editorial changes as needed and eliminated repetitive
information.
Section 1.4 – Definitions
1.4.1
Substitute Form
A tax form (or related schedule) that differs in any way from the official version and is intended to
replace the form that is printed and distributed by the IRS. This term also covers those approved
substitute forms exhibited in this revenue procedure.
1.4.2
Printed/Preprinted Form
A form produced using conventi
onal printing processes or a printed form that has been reproduced
by photocopying or a similar process.
1.4.3
Preprinted Pin-Fed Form
A printed form that has marginal perforations for use with automated and high-speed printing
equipment.
A preprinted form in which the taxpayer’s tax entry information has been inserted by a computer,
a computer printer, or other computer-type equipment.
1.4.4
Computer-Prepared
Substitute Form
1.4.5
A tax return or form that is entirely designed and printed using a computer printer on plain white
Computer- Generated
paper. This return or form must conform to the physical layout of the corresponding IRS form,
Substitute Tax Return or
although the typeface may differ. The text should match the text on the officially printed form as
Form
closely as possible. Condensed text and abbreviations will be considered on a case-by-case basis.

October 27, 2025 650 Bulletin No. 2025–44
Exception. All jurats (perjury statements) must be reproduced verbatim.
1.4.6
Manually Prepar
ed Form
A preprinted reproduced form in which the taxpayer’s tax entry information is entered by an
individual using a pen, a pencil, or other nonautomated equipment.
1.4.7
Graphics
Parts of a printed tax form that are not tax amount entries or required text. Examples of graphics
are line numbers, captions, shadings, special indicators, borders, rules, and strokes created by
typesetting, photographics, photocomposition, etc.
1.4.8
Acceptable Reproduced
Form
1.4.9
Supporting Statement
(Supplemental Schedule)
A legible photocopy or an exact replica of an original form.
A document providing detailed information to support a line entry on an official or approved
substitute form and filed with (attached to) a tax return.
Note. A supporting statement is not a tax form and does not take the place of an official form.
1.4.10
Specific Form Terms
The following specific terms are used throughout this revenue procedure in reference to all
substitute forms: format, sequence, line reference, item caption, and data entry field.
1.4.11
Format
The overall physical arrangement and general layout of a substitute form.
1.4.12
Sequence
Sequence is an integral part of the total format requirement. The substitute form should show the
same numeric and logical placement order of data as shown on the official form.
1.4.13
Line Reference
The line numbers, letters, or alphanumerics used to identify each captioned line on an official
form. These line references are printed to the immediate left of each caption and/or data entry
field.
1.4.14
Item Caption
The text on each line of a form that identifies the data required.
1.4.15
Data Entry Field
1.4.16
Advance Draft
Designated areas for the entry of data such as dollar amounts, quantities, responses, and checkboxes.
A draft version of a new or revised form may be posted to the IRS website (https://www.irs.gov/
draftforms) for information purposes. Substitute forms may be submitted based on these advance

Bulletin No. 2025–44 651 October 27, 2025
drafts, but any submitter who receives forms approval based on these early drafts is responsible
for monitoring and revising forms to reflect any revisions in the final forms provided by the IRS.
1.4.17
Approval
Generally,
approval could be in writing or assumed after 20 business days from our receipt for
forms that have not been substantially changed by the IRS. This does not apply to newly created
or substantially revised IRS forms. However, the Program reserves the right to notify vendors of
any inaccuracies even after 20 business days have lapsed.
1.4.18
National Association
of Computerized Tax
Processors (NACTP)
The NACTP is a nonprofit association that represents tax processing software and hardware
developers, electronic filing processors, tax form publishers, tax processing service bureaus, and
payroll processors. The association promotes standards in tax processing to advance efficient and
effective tax filing. For more information, go to https://www.nactp.org.
Section 1.5 – Agreement
1.5.1
Important Stipulation of
This Revenue Procedure
Any person or company who uses substitute forms and makes all or part of the changes specified
in this revenue procedure agrees to the following stipulations.
• The IRS presumes that any required changes are made in accordance with these revenue
procedures and will not be disruptive to the processing of the tax return.
• Should any of the changes be disruptive to the IRS’s processing of the tax return, the person or
company agrees to accept the determination of the IRS as to whether the form may continue
to be filed.
• The person or company agrees to work with the IRS in correcting noted deficiencies.
Notification of deficiencies may be made by any combination of letter, email, or phone
contact and may include the request for the resubmission of unacceptable forms.
The Program will email confirmation of receipt of your forms submission, if possible. Even if
you do not receive emailed confirmation of receipt, you will receive an emailed “submission
receipt,” which will provide feedback on your submission. If the Program anticipates problems
in completing the review of your submission within the 20-business-day period, the Program will
send an interim email notifying you of the extended period for review.
Once the substitute forms have been approved by the Program, you can release them after the final
versions of the forms have been issued by the IRS. Before releasing the forms, you are responsible
for updating forms approved as draft and for making form changes requested.
The policy has the following stipulations.
• This 20-business-day policy applies to electronic submissions only. It does not apply to
substitute submissions mailed to the Program.
• The policy applies to submissions of 15 (optimal) or fewer items and submissions containing
75 pages or less. Submissions of more than 15 items may require additional review time.
1.5.2
Response Policy and
Stipulations

October 27, 2025 652 Bulletin No. 2025–44
• If you send a large number of submissions within a short period of time, processing may be
delayed.
• Delays in processing could occur if the Program finds significant errors in your submission or
has experienced an increase in submissions. The Program will send you an interim email in
this case.
• Any anticipated problems in processing your submission within the 20-business-day period
will generate an interim email on or about the 15th business day.
• If any significant inaccuracies are discovered after the 20-business-day period, the Program
reserves the right to inform you and will require that changes be made to correct the
inaccuracies.
• The policy does not apply to substantially revised forms or to new forms created by the IRS
for which you have already made an initial submission.
Part 2
General Guidelines for Submissions and Approvals
Section 2.1 – General Specifications for Approval
2.1.1
Overview
If you produce any substitute tax forms that fully comply or follow the changes specifically outlined
by the Program, then you can generate your own substitute forms without further approval. Also,
if your substitutes have received approval in the past, and there are no substantial formatting
or text changes for the tax year, then changes can be made without additional approval. If your
changes are more extensive, you must get IRS approval before using substitute forms. More
extensive changes include different font style; decreasing or increasing the font size of caption
titles; adjusting or omitting format/layout elements; changing page orientation; and repositioning
line items, tables, and legends.
2.1.2
Email Submissions
The Program accepts submissions of substitute forms for review and approval via email. The email
address is substituteforms@irs.gov. Include the term “PDF Submissions” on the subject line.
Follow these guidelines.
• The emailed submission should include all the forms you wish to submit in one Portable
Document Format (PDF) file. Do not email or attach each form individually.
• The emailed submission should include a maximum of 3 PDF files to include a checksheet,
a cover letter or accompanying statement, and a single PDF file that includes all of the forms
listed on your checksheet, cover letter, or accompanying statement.
• A submission should contain a maximum of 15 forms.
• An approval checksheet listing the forms you are submitting should always be included in
the PDF file along with the forms. Excluding the checksheet can slow the reviewing process
down, which can result in a delayed response to your submission. See a sample checksheet in
Exhibit B.
• Optimize PDF files before submitting.
• The maximum allowable email attachment is 2.5 megabytes.

Bulletin No. 2025–44 653 October 27, 2025
• The Program accepts zip files.
• To alleviate delays during the peak time of September through December, submit advance
draft forms as early as possible.
If the guidelines are not followed, you may need to resubmit.
Emailing PDF submissions will not expedite review and approval. Submitting your substitute forms
package via email is the preferred and suggested method for submitting forms for review. If, for
some reason, you are not able to email your submission(s), you can mail your submission(s) to:
Internal Revenue Service
Attn: Substitute Forms Program
SE:W:CAR:MP:P:TP:TP
ATSC
4800 Buford Highway
Mail Stop: 061-N
Chamblee, GA 30341
2.1.3
Expediting the Process
Follow these basic guidelines for expediting the process.
• Always include a checksheet for the Program’s response.
• Include an accompanying statement identifying most, if not all, of the deviations your
substitute forms may have from the official IRS versions.
• Follow the guidance in this publication for general substitute form guidelines. Follow the
guidance in specialized publications produced by the Program for other specific forms.
• To spread out the workload, send in draft versions of substitute forms when they are posted.
Note. Be sure to make any changes to approved drafts before releasing final versions.
2.1.4
Schedules
Some schedules are considered to be an integral part of a complete tax return and must be submitted
as part of the form. Other schedules may be submitted separately and do not need to be included
with the tax form.
2.1.5
Examples of Schedules That
Must Be Submitted
With
the Return
Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, is an example
of this situation. For the Form 706 to be considered for approval, all schedules that affect or are
applicable to any election or position taken by the filer, as well as all applicable schedules that
affect the tax, must be submitted.
2.1.6
Examples of Schedules
That Can Be Submitted
Separately
Schedules C, D, and E for Form 1040, U.S. Individual Income Tax Return, or Form 1040-SR, U.S.
Tax Return for Seniors, are examples of schedules that can be submitted separately. Although
printed by the IRS as a supplement to Form 1040 or 1040-SR, these schedules are not required to
be submitted for approval with Form 1040 or 1040-SR. These schedules may be separated from
Form 1040 or 1040-SR and submitted as substitute forms.

October 27, 2025 654 Bulletin No. 2025–44
2.1.7
Use and Distribution of
Unapproved Forms
The IRS is continuing a program to identify and contact tax return preparers, forms developers,
and software publishers who use or distribute unapproved forms that do not conform to this
revenue procedure. The use of unapproved forms hinders the processing of the returns.
Section 2.2 – Highlights of Permitted Changes and Requirements
2.2.1
Methods of Reproducing
IRS Forms
There are methods of reproducing IRS printed tax forms suitable for use as substitutes without
prior approval.
• You can photocopy most tax forms and use them instead of the official ones. The entire
substitute form, including entries, must be legible.
• You can reproduce any current tax form as cut sheets, snap sets, and marginally punched,
pin-fed forms as long as you use an official IRS version as the master copy.
• You can reproduce a form that requires a signature as a valid substitute form. Many tax
forms (including returns) have a taxpayer signature requirement as part of the form layout.
The jurat/perjury statement/ signature line areas must be retained and worded exactly as on
the official form. The requirement for a signature, by itself, does not prohibit a tax form from
being properly computer generated.
Section 2.3 – Vouchers
2.3.1
Overview
All payment vouchers (Forms 940-V, 941-V, 943-V, 944-V, 945-V, 1040-ES, 1040-V, 1041-V,
and 2290-V) must be reproduced in conjunction with their forms. Substitute vouchers must be
the same size as the officially printed vouchers. Vouchers that are prepared for printing on a laser
printer may include a scan line.
2.3.2
Scan Line Specifications
NNNNNNNNNAAXXXXNNNNNNNNNNNN
Item:ABCDEF
G
A.Social Security Number/Employer Identification Number/Individual Taxpayer
Identification Number/Adoption Taxpayer Identification Number (SSN/EIN/ ITIN/ATIN)
has 9 numeric (N) spaces.
B.Check Digits have 2 alpha (A) spaces.
C.Name Control has 4 alphanumeric (X) spaces.
D.
Master File Tax (MFT) Code has 2 numeric (N) spaces (see Section 2.3.3).
E.
Taxpayer Identification Number (TIN) Type has 1 numeric (N) space (see Section 2.3.4).
F.Tax Period has 6 numeric (N) spaces in year/month format (YYYYMM).
G.Transaction Code has 3 numeric (N) spaces.
2.3.3
MFT
Code
Code Number for Forms:
• 1040 (family) – 30,
• 940 – 10,

Bulletin No. 2025–44 655 October 27, 2025
• 941 – 01,
• 943 – 11,
• 944 – 14,
• 945 – 16,
• 1041-V – 05,
• 2290 – 60, and
• 4868 – 30.
2.3.4
TIN Type
Type Number for:
• Form 1040 (family) and Form 4868 – 0; and
• Forms 940, 941, 943, 944, 945, 1041-V, and 2290 – 2.
2.3.5
Voucher
Size
The voucher size must be exactly 8.0′′ x 3.25′′ (Forms 1040-ES and 1041-ES must be 7.625′′ x
3.0′′). The document scan line must be vertically positioned 0.25 inch from the bottom of the scan
line to the bottom of the voucher. The last character on the right of the scan line must be placed
3.5 inches from the right leading edge of the document. The minimum required horizontal clear
space between characters is 0.014 inch. The line to be scanned must have a clear band 0.25 inch
in height from top to bottom of the scan line, and from border to border of the document. “Clear
band” means no printing except for dropout ink.
2.3.6
Print and Paper Weight
Vouchers must be imaged in black ink using OCR A, OCR B, or Courier 10. These fonts may not
be mixed in the scan line. The horizontal character pitch is 10 CPI. The preferred paper weight is
20 to 24 pound OCR bond.
2.3.7
Specifications for Software
Developers
Certain vouchers may be reproduced for use in the IRS lockbox system. These include the 1040-V,
1040-ES, 1041-V, 94X series, and 2290 vouchers. Software developers must follow these specific
guidelines to produce scannable vouchers strictly for lockbox purposes. Also see
Exhibit A.
• The total depth must be 3.25 inches.
• The scan line must be 0.5 inch from the bottom edge and 1.75 inches from the left edge of the
voucher and left justified.
• Software developers’ vouchers must be 8.5 inches wide (instead of 8 inches with a cut line).
Therefore, no vertical cut line is required.
• Scan line positioning must be exact.
• Do not use the over-the-counter format voucher and add the scan line to it.
• All scanned data must be in 12-point OCR A font.

October 27, 2025 656 Bulletin No. 2025–44
• The 4-digit NACTP ID code or IRS source code should be placed under the box designated
for the payment dollar amount.
• Windowed envelopes must not display the scan line in order to avoid disclosure and privacy
issues.
Note. All software developers must ensure that their software uses OCR A font so taxpayers will
be able to print the vouchers in the correct font.
2.3.8
Specific Line Positions
Follow these line specifications for entering taxpayer data in the lockbox vouchers.
Start RowStart ColumnWidth
End Column
Line Specifications for Taxpayer Data:
Taxpayer Name56636
41
Taxpayer Address, Apt.57636
41
Taxpayer City, State, ZIP
586
36
41
Foreign Country Name59636
41
Foreign Province/County60617
22
Foreign Postal Code602616
41
Line Specifications for Mail-To Data:
Mail Name564338
80
Mail Address574338
80
Mail City, State, ZIP584338
80
Line Specifications for:
Scan Line6326n/a
n/a
Send an approval sheet with each form type for IRS signature to Jason Lane at Jason.L.Lane@irs.
gov. You should include in the email an example of each type of voucher the site will be testing.
Note. Do not mail any test vouchers to Jason Lane.
You are required to send 25 voucher samples of each form in PDF format by December 5, 2025.
You should email the test vouchers to raul.t.mariduena@jpmorgan.com. You can also print the
vouchers and send them to his mailing address at:
JP Morgan Chase
Attn: Raul Mariduena
830 Tyvola Road, Suite 114
Charlotte, NC 28217
For further information, contact Jason Lane at Jason.L.Lane@irs.gov, or at 559-550-8740 (not
2.3.9
How To
Get Approval
toll free number).

Bulletin No. 2025–44 657 October 27, 2025
Section 2.4 – Restrictions on Changes
2.4.1
What Y
ou Cannot Do
to Forms Suitable for
Substitute Tax Forms
You cannot, without prior IRS approval, change any IRS tax form or use your own (nonapproved)
versions including graphics, unless specifically permitted by this revenue procedure. See Sections
2.5.7 through 2.5.11.
You cannot adjust any of the graphics on Form 1040 or 1040-SR (except in those areas specified
in Part 5 of this revenue procedure) without prior approval from the Program.
You cannot rearrange or redistribute data entry fields, and/or allow data entry fields to flow from
one page onto the next (that is, each page of a substitute form must contain the exact number of
data entry fields as there are on the official IRS form). The order of information on the substitute
form must be identical to the IRS version of the form. Publications for specific substitute forms
will state allowances for those respective forms.
Note. The 20-business-day turnaround policy may not apply to extensive changes.
2.5.1
Basic Requirements
Section 2.5 – Guidelines for Obtaining IRS Approval
Preparers who submit substitute privately designed, privately printed, computer-generated, or
computer-prepared tax forms must develop these substitutes using the guidelines established in
this part. These forms, unless there is an exception outlined by this revenue procedure, must be
approved by the IRS before being filed.
2.5.2
Conditional Approval
Based on Advance Drafts
The IRS cannot grant final approval of your substitute form until the official form has been
published. However, the IRS posts advance draft forms on its website at https://www.irs.gov/
draftforms.
Submission of proposed substitutes of these advance draft forms is encouraged, and conditional
approval will be granted based solely on these early drafts. These advance drafts are subject to
significant change before forms are finalized. If these advance drafts are used as the basis for your
substitute forms, you will be responsible for subsequently updating your final forms to agree with
the final official version. These revisions need not be resubmitted for further approval.
Note. Approval of forms based on advance drafts will not be granted after the final version of an
official form is published.
2.5.3
Submission Procedures
Follow these general guidelines when submitting substitute forms for approval.
• Any alteration of forms must be within the limits acceptable to the IRS. It is possible that,
from one filing period to another, a change in law or a change in internal need (processing,
audit, compliance, etc.) may change the allowable limits for the alteration of the official form.

October 27, 2025 658 Bulletin No. 2025–44
• When approval of any substitute form (other than those exceptions specified in Part 1,
Section 1.2) is requested, a sample of the proposed substitute form should be emailed for
consideration to the Program at the address shown in Section 1.2.1.
• Schedules and forms (for example, Forms 3468, 4136, etc.) that can be used with more than
one type of return (for example, Forms 1040, 1040-SR, 1041, 1120, etc.) should be submitted
only once for approval, without regard to the number of different tax returns with which they
may be associated. Also, all pages of multi-page forms or returns should be submitted in the
same package.
2.5.4
Approving Offices
Because
only the Program is authorized to approve substitute forms, unnecessary delays may
occur if forms are sent to the wrong office. You may receive an interim letter about the delay.
The Program may then coordinate the response with the originator responsible for revising that
particular form. Such coordination may include allowing the originator to officially approve the
form. No IRS office is authorized to allow deviations from this revenue procedure.
2.5.5
IRS Review of Software
Programs, etc.
The IRS does not review or approve the logic of specific software programs, nor does the IRS
confirm the calculations on the forms produced by these programs. The accuracy of the program
remains the responsibility of the software package developer, distributor, or user.
The Program is primarily concerned with the pre-filing quality review of the final forms that are
expected to be processed by IRS field offices. For this purpose, you should submit forms without
including any taxpayer information such as names, addresses, monetary amounts, etc.
If the software used is programmed to produce copies with populated fields, then you must use dummy
information. This will allow the Program to review and provide feedback or approval. Vendors should
use “0” for all number values and “X” for any information that requires alpha characters.
2.5.6
When To Send Proposed
Substitutes
Proposed substitutes, which are required to be submitted per this revenue procedure, should be
sent as much in advance of the filing period as possible. This is to allow adequate time for analysis
and response.
2.5.7
Accompanying Statement
When submitting sample substitutes, you should include an accompanying statement that lists
each form number and its changes from the official form (position, arrangement, appearance, line
numbers, additions, deletions, etc.). With each of the items, you should include a detailed reason
for the change.
When requesting approval, include a checksheet. Checksheets expedite the approval process. The
checksheet may look like the example in Exhibit B displayed in the back of this revenue procedure
or may be one of your own design. Include your email address on the checksheet.
2.5.8
Approval/Nonapproval
Notice
The Program will email the checksheet or an approval letter to the originator, unless:
• The requester has asked for a formal letter, or

Bulletin No. 2025–44 659 October 27, 2025
• Significant corrections to the submitted forms are required.
Notice of approval may impose qualifications before using the substitutes. Notices of unapproved
forms may specify the changes required for approval and require resubmission of the form(s) in
question. When appropriate, you will be contacted by telephone.
2.5.9
Duration of Appr
oval
Most signature tax returns and many of their schedules and related forms have the tax year printed
in the upper right corner. Approvals for these annual forms are usually good for 1 calendar year
(January through December of the year of filing). Quarterly tax forms in the 94X series and Form
720 require approval for any quarter in which the form has been revised.
Because changes are usually made to an annual form every year, each new filing season generally
requires a new submission of a substitute form. Very rarely is updating the preprinted year the
only change made to an annual form. However, if no significant content, formatting, or layout
changes were made to a tax form, then review and approval received for the prior tax year can be
carried over into the current tax year.
2.5.10
Limited Continued Use of
an Approved Change
Limited changes approved for one tax year may be allowed for the same form in the following
tax year. Examples are the use of abbreviated words, revised form spacing, compressed text lines,
shortened captions, etc., which do not change the integrity of lines or text on the official forms.
If the vendor or filer makes substantial changes to the form, new substitutes must be submitted
for approval. If the vendor or filer makes only minor editorial changes to the form, or makes any
changes that mirror changes the IRS makes to the form’s official version, the new substitute does
not need to be submitted for approval. It is the responsibility of each vendor who has been granted
permission to produce substitute forms to monitor and revise forms to mirror any revisions to the
official forms made by the IRS. If there are any questions, contact the Program.
2.5.11
When Approval Is Not
Required
If you received approval for a specific change on a form last year, you may make the same change
this year if the item is still present on the official form.
• The new substitute form does not have to be submitted to the IRS and approval based on that
change is not required.
• However, the new substitute form must conform to the official current year IRS form in
other respects, such as date, Office of Management and Budget (OMB) approval number,
attachment sequence number, Paperwork Reduction Act Notice statement, arrangement, item
caption, line number, line reference, data sequence, etc.
• The new substitute form must also comply with changes to the guidelines in this revenue
procedure. This revenue procedure may have eliminated, added to, or otherwise changed the
guideline(s) that affected the change approved in the prior year.
• An approved change is authorized only for the period from a prior tax year substitute form to
a current tax year substitute form.
Exception. Forms with temporary, limited, or interim approvals (or with approvals that state a
change is not allowed in any other tax year) are subject to review in subsequent years.

October 27, 2025 660 Bulletin No. 2025–44
2.5.12
Required Copies
Generally, you must send us one copy of each form being submitted for approval. However, if you
are producing forms for different computer platforms (for example, Microsoft vs. Apple), different
tax preparation software (for example, TurboTax® vs. TaxSlayer®), or different types of printers
(for example, inkjet vs. impact), and these forms differ significantly in appearance, submit one
copy for each type of platform, tax preparation software, or printer.
2.5.13
Requestor’s Responsibility
Following receipt of an initial approval for a substitute forms package or a software output
program to print substitute forms, it is the responsibility of the originator (designer or distributor)
to provide client firms or individuals with forms that meet the IRS’s requirements for continuing
acceptability. Examples of this responsibility include:
• Using the prescribed print paper, font size, legibility, state tax data deletion, etc.; and
• Informing all users of substitute forms of the legal requirements of the Paperwork Reduction
Act Notice, which is generally found in the instructions for the official IRS forms.
2.5.14
Source Code
The
Program will assign a unique source code to each firm that submits substitute forms for
approval. This source code will be a permanent identifier that must be used on every submission
by a particular firm.
The source code consists of three alpha characters and should generally be printed under or to the
left of the “Paperwork Reduction Act” statement. Vendors must ensure that the source code is not
printed too close to or within the left or bottom 0.5-inch margin to avoid the source code from
being cut off during printing.
Section 2.6 – Office of Management and Budget (OMB) Requirements for All Substitute Forms
2.6.1
OMB Requirements for All
Substitute Forms
There are legal requirements of the Paperwork Reduction Act of 1995 (the Act). Public Law 104-
13 requires the following.
• OMB approves all IRS tax forms that are subject to the Act.
• Each IRS form contains (in the upper right corner) the OMB number, if assigned.
• Each IRS form (or its instructions) states why the IRS needs the information, how it will be
used, and whether or not the information is required to be furnished to the IRS.
This information must be provided to every user of official or substitute IRS forms or instructions.
2.6.2
Application of the
Paperwork Reduction Act
On forms that have been assigned OMB numbers:
• All substitute forms must contain in the upper right corner the OMB number that is on the
official form, and

Bulletin No. 2025–44 661 October 27, 2025
• The required format is: OMB No. 1545-XXXX (preferred) or OMB # 1545-XXXX
(acceptable).
2.6.3
Required Explanation to
Users
You must inform the
users of your substitute forms of the IRS use and collection requirements
stated in the instructions for official IRS forms.
• If you provide your users or customers with the official IRS instructions, each form must
retain either the Paperwork Reduction Act Notice (or Disclosure, Privacy Act, and Paperwork
Reduction Act Notice), or a reference to it as the IRS does on the official forms (usually in the
lower left corner of the forms).
• This notice reads, in part, “We ask for tax return information to carry out the tax laws of the
United States. ”
Note. If no IRS instructions are provided to users of your forms, the exact text of the Paperwork
Reduction Act Notice (or Disclosure, Privacy Act, and Paperwork Reduction Act Notice) must be
furnished separately or on the form.
2.6.4
Finding the OMB Number
and Paperwork Reduction
Act Notice
The OMB number and the Paperwork Reduction
Act Notice, or references to it, may be found
printed on an official form (or its instructions). The number and the notice are included on the
official paper format and in other formats produced by the IRS.
Part 3
Physical Aspects and Requirements
Section 3.1 – General Guidelines for Substitute Forms
3.1.1
General Information
The official form is the standard. Because a substitute form is a variation from the official form,
you should know the requirements of the official form for the year of use before you modify it to
meet your needs. To obtain the most frequently used tax forms, go to https://www.irs.gov/forms
.
3.1.2
Design
Each form must follow the design of the official form as to format arrangement, item caption, line
numbers, line references, and sequence.
3.1.3
State Tax
Information
Prohibited
Generally, state tax information must not appear on the federal tax return, associated form, or
schedule that is filed with the IRS. Exceptions occur when amounts are claimed on, or required
by, the federal return (for example, state and local income taxes on Schedule A (Form 1040)).

October 27, 2025 662 Bulletin No. 2025–44
3.1.4
Vertical Alignment of
Amount Fields
IF a form is to be...THEN...
manually prepared and the official
IRS form still has a separate cents
entry field
1.the entry column must have a vertical line or some
type of indicator in the amount field to separate
dollars from cents, and
2. the cents column must be at least 0.3 inch wide.
computer generated1.vertically align the amount entry fields where
possible, and
2.use one of the following amount formats.
a) 0,000,000.
b) 0,000,000.00.
computer prepared1.you may remove the vertical line in the amount field
that separates dollars from cents, and
2.use one of the following amount formats.
a) 0,000,000.
b) 0,000,000.00.
3.1.5
Attachment Sequence
Number
Many individual income tax forms have a required “attachment sequence number” located just
below the year designation in the upper right corner of the form. The IRS uses this number to
indicate the order in which forms are to be attached to the tax return for processing. Some of the
attachment sequence numbers may change from year to year.
The following apply to computer-prepared forms.
• The sequence number may be printed in no less than 12-point boldface type and centered
below the form’s year designation.
• The sequence number may also be placed following the year designation for the tax form and
separated with an asterisk.
• The actual number may be printed without labeling it the “Attachment Sequence Number.”
3.1.6
Assembly of Forms
When developing software or forms for use by others, inform your customers/clients that the
order in which the forms are arranged may affect the processing of the package. A return must be
arranged in the order indicated below.
IF the form is...THEN the sequence is...
1040 or 1040-SR
• Form 1040 or 1040-SR, and schedules and forms in attachment
sequence number order.
any other tax return
(Form 1120, 1120-S,
1065, 1041, etc.)
• the tax returns, directly associated schedules (Schedule D, etc.),
directly associated forms, additional schedules in alphabetical
order, and additional forms in numerical order.
Supporting statements should then follow in the same sequence as the forms they support.
Additional information required should be attached last.
In this way, the forms are received in the order in which they must be processed. If you do not send
returns to the IRS in order, processing may be delayed.

Bulletin No. 2025–44 663 October 27, 2025
3.1.7
Paid Preparer’s
Information and Signature
Area
On Forms 1040, 1040-SR, and 1120, and any other applicable tax forms, the “Paid Preparer Use
Only” area may not be rearranged or relocated. You may, however, add three extra lines to the
paid preparer’s address area, and remove the horizontal rules in that area without prior approval.
3.1.8
Some Common Reasons
for Requiring Changes to
Substitute Forms
Some reasons that substitute form submissions may require changes include the following.
• Shading areas incorrectly.
• Failing to include a reference to the location of the Paperwork Reduction Act Notice.
• Not including parentheses for losses.
• Not including “Attach Statement” when appropriate.
• Including line references or entry spaces that do not match the official form.
• Printing text that is different from the official form.
• Altering the jurat (perjury statement).
• Having an incorrect OMB number.
• Including the IRS catalog number (Cat. No.) on the form.
• Failing to include preprinted amounts in entry fields.
• Missing IRS source code or NACTP software ID.
• Missing 3-letter FFF code on paper Form 1040 from tax software companies that participate
in the IRS Free File Program.
• Incorrect dimensions.
Section 3.2 – Paper
3.2.1
Paper Content
The paper must be:
• Chemical wood writing paper that is equal to or better than the quality used for the official
form,
• At least 18 pound (17′′ x 22′′, 500 sheets), or
• At least 50 pound offset book (25′′ x 38′′, 500 sheets).
3.2.2
Paper W
ith Chemical
Transfer Properties
There are several kinds of paper prohibited for substitute forms. These are:
1. Carbon-bonded paper, and
2. Chemical transfer paper except when the following specifications are met.

October 27, 2025 664 Bulletin No. 2025–44
a. Each ply within the chemical transfer set of forms must be labeled.
b. Only the top ply (ply one and white in color), the one that contains chemical on the back
only (coated back), may be filed with the IRS.
Example. A set containing three plies would be constructed as follows: ply one (coated back),
“Federal Return, File with IRS”; ply two (coated front and back), “Taxpayer’s copy”; and ply
three (coated front), “Preparer’s copy.”
The file designation, “Federal Return, File with IRS” for ply one, must be printed in the bottom
right margin (just below the last line of the form) in 12-point boldface type.
It is not mandatory, but recommended, that the file designation “Federal Return, File with IRS” be
printed in a contrasting ink for visual emphasis.
3.2.3
Paper and Ink Color
It is preferred that
the color and opacity of paper substantially duplicate that of the original form.
This means that your substitute must be printed in black ink and may be on white paper or on the
colored paper
the IRS form is printed on. Form 1040 or 1040-SR substitute reproductions may be
in black ink without the colored shading. The only exception to this rule is Form 1041-ES, which
should be printed with a PMS 100 yellow shading in the color-screened area. This is necessary to
assist us in expeditiously separating this form from the very similar Form 1040-ES.
3.2.4
Page Size
Substitute or reproduced forms and computer-prepared/-generated substitutes may be the same
size as the official form or they may be the standard commercial size (8.5′′ x 11′′). The thickness
of the stock cannot be less than 0.003 inch.
Section 3.3 – Printing
3.3.1
Printing Medium
The private printing of all substitute tax forms must be by conventional printing processes,
photocopying, computer graphics, or similar reproduction processes.
3.3.2
Legibility
All forms must have a high standard of legibility as to printing, reproduction, and fill-in matter.
Entries of taxpayer data may be no smaller than 8 points. The IRS reserves the right to reject
those with poor legibility. The ink and printing method used must ensure that no part of a form
(including text, graphics, data entries, etc.) develops “smears” or similar quality deterioration. This
standard must be followed for any subsequent copies or reproductions made from an approved
master substitute form, either during preparation or during IRS processing.
3.3.3
Type Font
Many federal tax forms are printed using Helvetica
as the basic type font. It is preferred that you
use this type font when composing substitute forms.

Bulletin No. 2025–44 665 October 27, 2025
3.3.4
Print Spacing
Substitute forms should be printed using a 6 lines/inch vertical print option. They should also be
printed horizontally in 10-pitch pica (that is, 10 print characters per inch) or 12-pitch elite (that is,
12 print positions per inch).
3.3.5
Image Size
The image size of a printed substitute form should be as close as possible to that of the official
form. You may omit any text on both computer-prepared and computer-generated forms that is
solely instructional.
3.3.6
T
itle Area Changes
To allow a large top margin for marginal printing and more lines per page, the title line(s) for all
substitute forms (not including the form’s year designation and sequence number, when present)
may be photographically reduced by 40% or reset as one line of type. When reset as one line, the
type size may be no smaller than 14 points. You may omit “Department of the Treasury—Internal
Revenue Service” and all references to instructions in the form’s title area.
3.3.7
Remove Government
Publishing Office (GPO)
Symbol and IRS Catalog
Number
When privately printing substitute tax forms, the GPO symbol and/or jacket number must be
removed. In the same place using the same type size, print the EIN of the printer or designer, or
the IRS-assigned source code. (Preferably, this last number should be printed in the lower left area
of the first page of each form.) Also, remove the IRS catalog number (Cat. No.) and the recycle
symbol if the substitute is not produced on recycled paper.
3.3.8
Printing Single-Page Forms
Substitute single-page forms should be reproduced the same as IRS single-page forms. Other
forms or schedules should not be printed on the back or on blank portions of a single-page
form. However, printing instructions on the back or on blank portions of a single-page form is
acceptable.
3.3.9
Photocopy Equipment
The IRS does not undertake to approve or disapprove the specific equipment or process used in
reproducing official forms. Photocopies of forms must be entirely legible and satisfy the conditions
stated in this and other revenue procedures.
3.3.10
Reproductions
Reproductions of official forms and substitute forms that do not meet the requirements of this
revenue procedure may not be filed instead of the official forms. Illegible photocopies are subject
to being returned to the filer for resubmission of legible copies.
3.3.11
Removal of Instructions
Generally, you may remove references to instructions. No prior approval is needed. However, in
some instances, you may be requested to include references to instructions.
Exception. The words “For Paperwork Reduction Act Notice, see separate instructions” must be
retained, or a similar statement indicating the location of the Notice must be provided on each
form.

October 27, 2025 666 Bulletin No. 2025–44
Section 3.4 – Margins
3.4.1
Margin Size
The format of a reproduced tax form when printed on the page must have margins on all sides at
least as large as the margins on the official form. This allows room for IRS employees to make
necessary entries on the form during processing.
• A 0.5-inch to 0.25-inch margin must be maintained across the top, bottom, and both sides of
all substitute forms.
• The marginal, perforated strips containing pin-fed holes must be removed from all forms
prior to filing with the IRS.
3.4.2
Marginal Printing
Prior approval is not required for the marginal printing allowed when printed on an official form
or on a photocopy of an official form.
• With the exception of the actual tax return forms (for example, Forms 1040, 1040-SR, 1120,
940, 941, etc.), you may print in the left vertical margin and in the left half of the bottom
margin.
• Printing is never allowed in the top right margin of the tax return form (for example, Forms
1040, 1040-SR, 1120, 940, 941, etc.). The IRS uses this area to imprint a Document Locator
Number for each return. There are no exceptions to this requirement.
Section 3.5 – Miscellaneous Information for Substitute Forms
3.5.1
Filing Substitute Forms
To be acceptable for filing, a substitute form must print out in a format that will allow the filer to
follow the same instructions that accompany official forms. The form must be legible, must be on
the appropriately sized paper, and must include a jurat (perjury statement) where one appears on
the published form.
3.5.2
Caution to Softwar
e
Publishers
The IRS has received returns produced by software packages with approved output where either
the form heading was altered or the lines were spaced irregularly. This produces an illegible or
unrecognizable return or a return with the wrong number of pages. While many of these problems
are caused by individual printer differences, they may delay input of return data and, in some
cases, generate correspondence to the taxpayer. Therefore, in the instructions to the purchasers
of your product, both individual and professional, stress that their returns will be processed more
efficiently if they are properly formatted. This includes:
• Having the correct form numbers, 6-digit form identifying numbers, and titles at the top of the
returns; and
• Submitting the same number of pages as if the form were an official IRS form with the line
items on the proper pages.

Bulletin No. 2025–44 667 October 27, 2025
3.5.3
Caution to Producers of
Software Packages
If you are producing a software package that generates name and address data onto the tax return,
do not, under any circumstances, program either the IRS preprinted check digits or a practitioner-
derived name control to appear on any return prepared and filed with the IRS.
3.5.4
Programming to Print
Forms
Whenever applicable:
• Use only the following label information format for single filers: JOHN Q. DOE 000 OAK
DRIVE HOMETOWN, STATE 00000;
• Use only the following label information format for joint filers: JOHN Q. DOE MARY Q.
DOE 000 OAK DRIVE HOMETOWN, STATE 00000; and
• Use “0” for number values and “X” for alpha characters entered in data entry fields as dummy
copy.
Part 4
Additional Resources
Section 4.1 – Guidance From Other Revenue Procedures
4.1.1
General
The IRS publications listed below provide guidance for substitute tax forms not covered in this
revenue procedure. These publications are available on the IRS website. Use the publication
number listed below to search for the requested document.
• Pub. 1141, General Rules and Specifications for Substitute Forms W-2 and W-3.
• Pub. 1179, General Rules and Specifications for Substitute Forms 1096, 1098, 1099, 5498,
and Certain Other Information Returns.
• Pub. 1223, General Rules and Specifications for Substitute Forms W-2c and W-3c.
• Pub. 4436, General Rules and Specifications for Substitute Form 941, Schedule B (Form
941), Schedule D (Form 941), Schedule R (Form 941), and Form 8974.
• Pub. 5223, General Rules and Specifications for Affordable Care Act Substitute Forms 1095-
A, 1094-B, 1095-B, 1094-C, and 1095-C.
Section 4.2 – Electronic Tax Products
4.2.1
The
IRS Website
Copies of tax forms and their instructions, publications, fillable forms, and prior-year forms and
publications may be found on the IRS website at https://www.irs.gov/forms.
Draft forms and instructions may be found at https://www.irs.gov/draftforms.
Other tax-related information may be found at https://www.irs.gov.

October 27, 2025 668 Bulletin No. 2025–44
4.2.2
System Requirements
and Ordering Forms and
Instructions
For system requirements, contact the National Technical Information Service (NTIS) at https://
www.ntis.gov. Prices are subject to change.
You can order IRS forms and other tax material at https://www.irs.gov/orderforms.
Part 5
Requirements for Specific Tax Returns
Section 5.1 – Tax Returns (Forms 1040, 1040-SR, 1120, etc.)
5.1.1
Acceptable Forms
Tax return forms (such as Forms 1040, 1040-SR, and 1120) require a signature and establish tax
liability. Computer-generated versions are acceptable under the following conditions.
• These substitute forms must be printed on plain white paper.
• Substitute forms must conform to the physical layout of the corresponding IRS form although
the typeface may differ. The text should match the text on the officially published form as
closely as possible. Condensed text and abbreviations will be considered on a case-by-case
basis. Caution. All jurats (perjury statements) must be reproduced verbatim. No text can be
added, deleted, or changed in meaning.
• Various computer graphic print media such as laser printing, inkjet printing, etc., may be used
to produce the substitute forms.
• The substitute form must be the same number of pages and contain the same text on the lines
as the official form.
• All substitute forms must be submitted for approval prior to their original use. You do not
need approval for a substitute form if its only change is the preprinted year and you had
received a prior-year approval letter. Exception. If the approval letter specifies a one-time
exception for your form, the next year’s form must be approved.
5.1.2
Pr
ohibited Forms
The following are prohibited.
• Computer-generated tax forms (for example, Form 1040, 1040-SR, etc.) on lined or color-
barred paper.
• Tax forms that differ from the official IRS forms in a manner that makes them nonstandard or
unable to process.
5.1.3
Changes Permitted to Form
1040
Certain changes (listed in Section 5.2) are permitted to the graphics of the form without prior
approval, but these changes apply only to acceptable preprinted forms. Changes not requiring
prior approval are good only for the annual filing period, which is the current tax year. Such
changes are valid in subsequent years only if the official form does not change.

Bulletin No. 2025–44 669 October 27, 2025
5.1.4
Other Changes Not Listed
All changes not listed in Section 5.2 require approval from the IRS before the form can be filed.
Section 5.2 – Changes Permitted to Graphics (Form 1040 or 1040-SR)
5.2.1
Adjustments
You may make minor vertical and horizontal spacing adjustments to allow for computer or
word-processing printing. This includes widening the amount columns or tax entry areas if the
adjustments comply with other provisions stated in revenue procedures. No prior approval is
needed for these changes.
Schedules 1–3 cannot be combined for filing purposes. For the client copy of the return, the
numbered schedules may be printed two to a page (for example, Schedule 3 below Schedule 2, if
both are completed as part of the return). If numbered schedules are combined on the client copy,
it must include a statement that it is “Not for Filing.”
5.2.2
Name and Address Area
The horizontal rules and instructions within the name and address area may be removed and the
entire area left blank. No line or instruction can remain in the area. The heavy-ruled border (when
present) that outlines the name, address area, and SSN must not be removed, relocated, expanded,
or contracted.
5.2.3
Required Format
When the name and address area is left blank, the following format must be used when printing
the taxpayer’s name and address.
• 1st name line (35 characters maximum).
• 2nd name line (35 characters maximum).
• In-care-of name line (35 characters maximum).
• City, state (25 characters maximum), one blank character, and ZIP code.
5.2.4
Conventional Name and
Addr
ess Data
When there is no in-care-of name line, the name and address will consist of only three lines (single
filer) or four lines (joint filer).
Example of joint filer. Name and address (joint filer) with no in-care-of name line:
JOHN Q. DOE
MARY Q. DOE
000 ANYWHERE ST., APT. 000
ANYTOWN, STATE 00000

October 27, 2025 670 Bulletin No. 2025–44
Example of in-care-of name line. Name and address (single filer) with in-care-of name line:
JOHN Q. DOE
C/O JOHN R. DOE
0000 SOMEWHERE AVE.
SAMETOWN, STATE 00000
5.2.5
SSN and EIN
Area
The broken vertical lines separating the format arrangement of the SSN/EIN may be removed.
When the vertical lines are removed, the SSN and EIN formats must be 000-00-0000 or
00-0000000, respectively.
5.2.6
Entering Cents
• You may remove the vertical rule that separates the dollars from the cents if it is still included
on the official IRS form.
• All entries in the amount column should have a decimal point following the whole dollar
amounts whether or not the vertical line that separates the dollars from the cents is present.
• You may omit printing the cents, but all amounts entered on the form must follow a consistent
format. You are strongly urged to round off the figures to whole dollar amounts, following the
official form instructions.
• When several amounts are added together, the total should be rounded off after addition (that
is, individual amounts should not be rounded off for computation purposes).
• When printing money amounts, you must use one of the following formats: (a) 0,000,000; or
(b) 0,000,000.00.
• When there is no entry for a line, leave the line blank.
5.2.7
Changes to Lines
No prior approval is needed for the following changes (for use with computer-prepared forms
only). Specific line numbers in the following headings may have changed due to tax law changes.
5.2.8
Dependents on Form 1040
The vertical lines separating columns (1) through (4) may be removed. The captions may be
shortened to allow a one-line caption for each column.
5.2.9
Other
Lines
Any other line with text that takes up two or more vertical lines may be compressed to one line by
using contractions, etc., and by removing instructional references.
5.2.10
Form 1040 – Tax
You may change the line caption to read “Tax” and computer print the words “Total includes tax
from” and either “Form(s) 8814” or “Form 4972” or “962 election.” If both forms are used, print
both form numbers. This specific line number may have changed.

Bulletin No. 2025–44 671 October 27, 2025
5.2.11
Color Screening
It is not necessary to duplicate the color screening used on the official form. A substitute Form
1040 or 1040-SR may be printed in black and white only with no color screening.
5.2.12
Other Changes Prohibited
No other changes to the Form 1040 or 1040-SR graphics are permitted without prior approval
except for the removal of instructions and references to instructions.
Part 6
Format and Content of Substitute Returns
Section 6.1 – Acceptable Formats for Substitute Forms and Schedules
6.1.1
Exhibits and Use of
Acceptable Formats
Exhibit A is an acceptable format for Form 1040-ES.
• If your computer-generated Form 1040-ES appears exactly like Exhibit A, no prior
authorization is needed.
• You may computer-generate forms not shown here, but you must design them by following
the manner and style discussed in Part 3.
• Take care to observe the other requirements and conditions in this revenue procedure. The
IRS encourages the submission of all proposed forms covered by this revenue procedure.
6.1.2
Instructions
The format of each substitute form or schedule must follow the format of the official form or
schedule as to item captions, line references, line numbers, sequence, form arrangement and format,
etc. Basically, try to make the form look like the official one, with readability and consistency
being primary factors. You may use periods and/or other similar special characters to separate the
various parts and sections of the form. Do not use alpha or numeric characters for these purposes.
All line numbers and items must be printed even though an amount is not entered on the line.
6.1.3
Line Numbers
When a line on an official form is designated by a number or a letter, that designation (reference
code) must be used on a substitute form. The reference code must be printed to the left of the text
of each line and immediately preceding the data entry field, even if no reference code precedes
the data entry field on the official form. If an entry field contains multiple lines and shows the line
references once on the left and right sides of the form, use the same number of line references on
the substitute form.
In addition, the reference code that is immediately before the data field must either be followed
by a period or enclosed in parentheses. There must also be at least two blank spaces between the
period or the right parenthesis and the first digit of the data field. (See Section 6.1.4.)
6.1.4
Decimal Points
A decimal point (a period) should be used for each money amount regardless of whether the
amount is reported in dollars and cents or in whole dollars, or whether or not the vertical line that
separates the dollars from the cents is present. The decimal points must be vertically aligned when
possible.

October 27, 2025 672 Bulletin No. 2025–44
Example.
5 State and local taxes
a State and local income taxes.....................5a.000.00
b State and local real estate taxes................5b.
c State and local personal property taxes....5c.000.00
or
a State and local income taxes.....................(5a)000.00
b State and local real estate taxes................(5b)
c State and local personal property taxes....(5c)000.00
6.1.5
Multi-Page Forms
When submitting a multi-page form, send all its pages in the same package. If you will not be
producing certain pages, note that in your cover letter.
Section 6.2 – Additional Instructions for All Forms
6.2.1
Use of
Your Own Internal
Control Numbers and
Identifying Symbols
You may show the computer-prepared internal control numbers and identifying symbols on the
substitute form if using such numbers or symbols is acceptable to the taxpayer and the taxpayer’s
representative. Such information must not be printed in the top 0.5-inch clear area of any form or
schedule requiring a signature. Except for the actual tax return form (Forms 1040, 1040-SR, 1120,
940, 941, etc.), you may print in the left vertical and bottom left margins. The bottom left margin
you may use extends 3.5 inches from the left edge of the form. You may print internal control
numbers in place of the removed IRS catalog number.
6.2.2
Required Software ID
Number (Source Code)
on Computer- Prepared
Substitutes
In the February 2009 Government Accountability Office (GAO) report, “Many Taxpayers
Rely on Tax Software and IRS Needs to Assess Associated Risks” (GAO-09-297), the GAO
recommended that the IRS require a software identification number on all individual returns to
specifically identify the software package used to prepare each tax return. The IRS already has
this capability for all e-filed returns. In addition, many tax preparation software firms already
print an IRS-issued 3-letter source code on paper returns that are generated by their individual tax
software. This source code was assigned when the firms were seeking substitute-forms approval
under this publication.
In order to follow this GAO recommendation, the IRS will require that all tax preparation software
firms include the 3-letter source code on all paper tax returns created by their individual tax
preparation software. The many firms that currently have and display their source codes on paper
returns generated from their software should continue to do so, and no change is necessary.
We have reviewed all software companies that passed Assurance Testing System (ATS) testing
last filing season and have determined that some firms do not currently have source codes. To
save you the burden of contacting us and for your convenience, we have assigned source codes
to those firms.
You should program your source code to be placed in the bottom left-hand corner of page one of
each paper form that will be generated by your individual tax return package. You do not need to
apply for a new source code annually.

Bulletin No. 2025–44 673 October 27, 2025
If you already use a 3-letter source code and we have issued you one in error, you are unsure if
you were ever issued one, or you have other questions or concerns, you may contact Tax Forms
and Publications Special Services Section at substituteforms@irs.gov.
The IRS requires tax preparation software firms that participate in the IRS Free File Program
include the 3-letter FFF code on all paper Form 1040 returns created by their individual tax
preparation software.
If you participate in the IRS Free File Program, you should program the 3-letter FFF code to
be placed in the bottom left-hand corner of the first page of each paper Form 1040 that will be
generated by your individual tax return package. The 3-letter FFF code and the 3-letter source
code should be placed next to each other for consistency. If placing the 3-letter FFF code and the
3-letter source code next to each other is not possible, then above or below will be acceptable.
Example. The 3-letter FFF code and the 3-letter source code could be BCA-FFF or BCA FFF. A
dash or a space is needed to separate the 3-letter FFF code and the 3-letter source code.
6.2.3
Descriptions for Captions,
Lines, etc.
Descriptions for captions,
lines, etc., appearing on the substitute forms may be limited to one print
line by using abbreviations and contractions, and by omitting articles, prepositions, etc. However,
sufficient keywords must be retained to permit ready identification of the caption, line, or item.
6.2.4
Determining Final Totals
Explanatory detail and/or intermediate calculations for determining final line totals may be
included on the substitute form. Preferably, such calculations should be submitted in the form of a
supporting statement. If intermediate calculations are included on the substitute form, the line on
which they appear may not be numbered or lettered. Intermediate calculations may not be printed
in the right column. This column is reserved only for official numbered and lettered lines that
correspond to the ones on the official form. Generally, you may choose the format for intermediate
calculations or subtotals on supporting statements to be submitted.
6.2.5
Instructional Text on the
Official Form
Text on the official form, which is solely instructional (for example, “See instructions,” etc.), may
generally be omitted from the substitute form.
6.2.6
Intermingling Is Prohibited
Showing more than one form or schedule on the same printout page is prohibited. Both sides of
the paper may be used for multi-page forms, but it is unacceptable to intermingle forms.
For instance, Schedule E can be printed on both sides of the paper because the official form is
multi-page, with page 2 continued on the back. However, do not print Schedule E on the front
page and Schedule SE on the back page, or Schedule A on the front and Form 8615 on the back,
etc. Both pages of a substitute form must match the official form. The back page may be left blank
if the back page of the official form contains only the instructions.
6.2.7
Identifying Substitutes
Identify
all computer-prepared substitutes clearly. Print the form designation 0.5 inch from the top
margin and 1.5 inches from the left margin. Print the title centered on the first line of print. Print
the tax year and, where applicable, the sequence number on the same line 0.5 inch to 1 inch from

October 27, 2025 674 Bulletin No. 2025–44
the right margin. Include the taxpayer’s name and SSN on all forms and attachments. Also, print
the OMB number as reflected on the official form.
6.2.8
Negative
Amounts
Negative (or loss) amount entries should be enclosed in brackets or parentheses or include a minus
sign. This assists in accurate computation and input of form data. The IRS preprints parentheses
in negative data fields on many official forms. These parentheses should be retained or inserted on
printouts of affected substitute forms.
Part 7
Miscellaneous Forms and Programs
Section 7.1 – Specifications for Substitute Schedules K-1
7.1.1
Requirements for Schedules
K-1 That Accompany
Forms 1041, 1065, and
1120-S
Because of significant changes to improve processing, prior approval is now required for substitute
Schedules K-1 that accompany Form 1041 (for estates and trusts), Form 1065 (for partnerships), or
Form 1120-S (for S corporations). Substitute Schedules K-1 should be as close as possible to exact
replicas of the official IRS schedules and follow the same process for submitting other substitute
forms and schedules. Before releasing their substitute forms, software vendors are responsible for
making any subsequent changes that have been made to the final official IRS forms after the draft
forms have been posted.
Submit substitute Schedule K-1 forms, in PDF format, to scrips@irs.gov for scannability
acceptance. Schedule K-1 forms that require testing do not need to be mailed to the Program. You
must include information on the substitute forms that can be tested. This information should be
dummy information. Use an “X” for alpha characters and “0” for numbers. The IRS will review
and provide feedback of any changes needed so that your forms can be recognized correctly.
Include the 6-digit form ID code in the upper right of Schedules K-1 of Forms 1041, 1065, and
1120-S. Allow at least 0.25 inch of white space around the 6-digit code.
• 661117 for Form 1041.
• 651123 for Form 1065.
• 671124 for Form 1120-S.
Schedules K-1 that accompany Forms 1041, 1065, or 1120-S must meet all specifications. The
specifications include, but are not limited to, the following requirements.
• You will no longer be able to produce Schedules K-1 that contain only those lines or boxes
that taxpayers are required to use. All lines must be included.
• The words “* See attached statement for additional information.” must be preprinted in the
lower right-hand side on Schedules K-1 of Forms 1041, 1065, and 1120-S.
• All Schedules K-1 that are filed with the IRS should be printed on commercial standard size
(8.5′′ x 11′′) paper (the international standard (A4) of 8.27′′ x 11.69′′ may be substituted).

Bulletin No. 2025–44 675 October 27, 2025
• 10-point Helvetica Light Standard is preferred for all entries that are typed or made using a
computer.
• Submissions should include the IRS source code or NACTP vendor ID code printed on the
lower left corner of the form or in place of the IRS catalog number.
• Each recipient’s information must be on a separate sheet of paper. Therefore, you must
separate all continuously printed substitutes, by recipient, before filing with the IRS.
• No carbon copies or pressure-sensitive copies will be accepted.
• The Schedule K-1 must contain the name, address, and SSN or EIN of both the entity (estate,
trust, partnership, or S corporation) and the recipient (beneficiary, partner, or shareholder).
• The Schedule K-1 must contain the tax year, the OMB number, the schedule number (K-1), the
related form number (1041, 1065, or 1120-S), and the official schedule name in substantially
the same position and format as shown on the official IRS schedule.
• The Schedule K-1 must contain all the line items as shown on the official form, except for the
instructions, if any are printed on the back of the official Schedule K-1.
• The line items or boxes must be in the same order and arrangement as those on the official form.
• The amount of each recipient’s share of each item must be shown. A partial percent should be
reflected as a decimal (for example, 50 1/2% should be 50.5%). Furnishing a total amount of
each item and a percentage (or decimal equivalent) to be applied to such total amount by the
recipient does not satisfy the law and the specifications of this revenue procedure.
• State or local tax-related information may not be included on the Schedules K-1 filed with the
IRS.
The entity may have to pay a penalty if substitute Schedules K-1 are filed that do not conform to
specifications.
Additionally, the IRS may consider the Schedules K-1 that do not conform to specifications as
not being able to be processed and may return Form 1041, 1065, or 1120-S to the filer to be filed
correctly.
Schedules K-1 that are 2-D bar-coded will continue to require prior approval from the IRS. (See
Sections 7.1.3 through 7.1.5.)
7.1.2
Special Requir
ements
for Recipient Copies of
Schedules K-1
Standardization for reporting information is required for recipient copies of substitute Schedules
K-1 of Forms 1041, 1065, and 1120-S. Uniform visual standards are provided to increase
compliance by allowing recipients and practitioners to more easily recognize a substitute Schedule
K-1. The entity must furnish to each recipient a copy of Schedule K-1 that meets the following
requirements.
• Include the 6-digit form ID code in the upper right of Schedules K-1 of Forms 1041, 1065,
and 1120-S. Allow white space around the 6-digit code.
– 661117 for Form 1041.
– 651123 for Form 1065.
– 671124 for Form 1120-S.

October 27, 2025 676 Bulletin No. 2025–44
• You will no longer be able to produce Schedules K-1 that contain only those lines or boxes
that taxpayers are required to use. All lines must be included.
• The words “* See attached statement for additional information.” must be preprinted in the
lower right-hand side on Schedules K-1 of Forms 1041, 1065, and 1120-S.
• The Schedule K-1 must contain the name, address, and SSN or EIN of both the entity and
recipient.
• The Schedule K-1 must contain the tax year, the OMB number, the schedule number (K-1), the
related form number (1041, 1065, or 1120-S), and the official schedule name in substantially
the same position and format as shown on the official IRS schedule.
• All applicable amounts and information required to be reported must be titled and numbered in
the same manner as shown on the official IRS schedule. The line items or boxes must be in the
same order and arrangement and must be numbered like those on the official IRS schedule.
• The Schedule K-1 must contain all items required for use by the recipient. The instructions
for the schedule must identify the line or box number and code, if any, for each item as shown
on the official IRS schedule.
• The amount of each recipient’s share of each item must be shown. A partial percent should be
reflected as a decimal (for example, 50 1/2% should be 50.5%). Furnishing a total amount of
each line item and a percentage (or decimal equivalent) to be applied to such total amount by
the recipient does not satisfy the law and the specifications of this revenue procedure.
• Instructions to the recipient that are substantially similar to those on or accompanying the
official IRS schedule must be provided to aid in the proper reporting of the items on the
recipient’s income tax return. Where items are not reported to a recipient because they do not
apply, the related instructions may be omitted.
• The quality of the ink or other material used to generate recipients’ schedules must produce
clearly legible documents. In general, black chemical transfer inks are preferred.
• In order to assure uniformity of substitute Schedules K-1, the paper size should be standard
commercial (8.5′′ x 11′′) (the international standard (A4) of 8.27′′ x 11.69′′ may be substituted).
• The paper weight, paper color, font type, font size, font color, and page layout must be such
that the average recipient can easily decipher the information on each page. The preferred
font is Helvetica and a minimum of 10-point font.
• State or local tax-related information may be included on recipient copies of substitute
Schedules K-1. All non-tax-related information should be separated from the tax information
on the substitute schedule to avoid confusion for the recipient.
• The legend “Important Tax Return Document Enclosed” must appear in a bold and
conspicuous manner on the outside of the envelope that contains the substitute recipient copy
of Schedule K-1.
• The entity may have to pay a penalty if a substitute Schedule K-1 furnished to any recipient does
not conform to the specifications of this revenue procedure and results in impeding processing.
7.1.3
Requir
ements for Schedules
K-1 With Two-Dimensional
(2- D) Bar Codes
Electronic filing is the preferred method of filing; however, 2-D bar code is the best alternative
method for paper processing.

Bulletin No. 2025–44 677 October 27, 2025
In an effort to improve efficiency and increase data accuracy, the IRS partnered with the tax
software development community on a 2-D bar code project in 2003. Certain tax software
packages have been modified to generate 2-D bar codes on Schedules K-1. As a result, when
Schedules K-1 are printed using these programs, a bar code will print on the page.
Rather than manually transcribe information from the Schedule K-1, the IRS will scan the bar
code and electronically upload the information from the Schedule K-1. This will result in more
efficient operations within the IRS and fewer transcription errors for your clients.
Note. If software vendors do not want to produce bar-coded Schedules K-1, they may produce
the official IRS Schedules K-1 but cannot use the expedited process for approving bar-coded
Schedules K-1 and their parent returns as outlined in Section 7.1.6.
In addition to the requirements in Sections 7.1.1 and 7.1.2, the bar-coded Schedules K-1 must
meet the following specifications.
• The bar code should be printed in the space labeled “For IRS Use Only” on each Schedule
K-1. The entire bar code must be printed within the “For IRS Use Only” box surrounded by
a white space of at least 0.25 inch.
• Bar codes must be printed in PDF417 format.
• The bar codes must always be in the specified format with every field represented by at least a
field delimiter (carriage return). Leaving out a field in a bar code will cause every subsequent
field to be misread.
• Be sure to include the 6-digit form ID code in the upper right of Schedules K-1 of Forms
1041, 1065, and 1120-S. Allow white space around the 6-digit code.
– 661117 for Form 1041.
– 651123 for Form 1065.
– 671124 for Form 1120-S.
7.1.4
2-D Bar Code Specifications
for Schedules K-1
Follow these general specifications for preparing all 2-D bar-coded Schedules K-1.
• Numeric fields.
– Do not include leading zeros (except TINs, ZIP codes, and percentages).
– If negative value, the minus sign “–” must be present immediately to the left of the
number and part of the 12-position field.
– Do not use non-numeric characters except that the literal “STMT” can be put in money
fields.
– All money fields should be rounded to the nearest whole dollar amount—if a money
amount ends in 00 to 49 cents, drop the cents; if it ends in 50 to 99 cents, truncate the
cents and increment the dollar amount by one. Use the same rounding technique for the
bar-coded and the printed Schedules K-1.
– All numeric-only fields are right justified (except TINs and ZIP codes).

October 27, 2025 678 Bulletin No. 2025–44
• All field lengths are expressed as maximum lengths. If the value in the field has fewer
positions or the software program does not support that many positions, put in the bar code
only those positions actually used.
• Alpha fields.
– Do not include leading blanks (left justified).
– Do not include trailing blanks.
– Use uppercase alpha characters only.
• Variable fields.
– Do not include leading blanks (left justified).
– Do not include trailing blanks.
– Use uppercase alpha characters, numerics, and special characters as defined in each field.
• Delimit each field with a carriage return.
• Express percentages as 6-digit numbers without the percent sign. Left justify with a leading
zero(s) (for percentages less than 100%) and no decimal point (decimal point is assumed
between 3rd and 4th positions). Examples: 25.32% expressed as “025320”; 105% expressed
as “105000”; 8.275% expressed as “008275”; 10.24674% expressed as“010247”.
• It is vital that the print routine reinitialize the bar code prior to printing each succeeding
Schedule K-1. Failure to do this will result in each Schedule K-1 for a parent return having
the same bar code as the document before it.
7.1.5
Appr
oval Process for Bar-
Coded Schedules K-1
Prior to releasing commercially available tax software that creates bar-coded Schedules K-1, the
printed schedule and the bar code must both be tested. If your company is creating bar-coded
Schedules K-1, you must receive certification for both the printed Schedule K-1, as well as the bar
code, before offering your product for sale. Bar-code testing must be done using the final official
IRS Schedule K-1. Bar-code approval requests must be resubmitted for any subsequent changes
to the official IRS form that would affect the bar code. Below are instructions and a sequence of
events that will comprise the testing process.
• The IRS has released the final Schedule K-1 bar-code specifications by publishing them on
the IRS website (see https://www.irs.gov/e-file-providers/k-1-bar-code-certification-process).
• The IRS will publish a set of test documents that will be used to test the ability of tax
preparation software to create bar codes in the correct format.
• Software developers will submit two identical copies of the test documents—one to the IRS
and one to a contracted testing vendor.
• The IRS will use one set to ensure the printed schedules comply with standard substitute
forms specifications.
• If the printed forms fail to meet the substitute forms criteria, the IRS will inform the software
developer of the reason for noncompliance.
• The software developer must resubmit the Schedule(s) K-1 until it passes the substitute forms
criteria.

Bulletin No. 2025–44 679 October 27, 2025
• The testing vendor will review the bar codes to ensure they meet the published bar-code
specifications.
• If the bar code(s) does not meet published specifications, the testing vendor will contact the
software developer directly, informing them of the reason for noncompliance.
• Software developers must submit new bar-coded schedules until they pass the bar-code test.
• When the bar code passes, the testing vendor will inform the IRS that the developer has
passed the bar-code test and the IRS will issue an overall approval for both the substitute form
and the bar code.
• After receiving this consolidated response, the software vendor is free to release software for
tax preparation as long as any subsequent revisions to the schedules do not change the fields.
• Find the mailing address for the testing vendor next in Section 7.1.6. Separate and simultaneous
mailings to the IRS and the vendor will reduce testing time.
7.1.6
Pr
ocedures for Reducing
Testing Time
In order to help provide incentives to the software development community to participate in the
Schedule K-1 2-D project, the IRS has committed to expediting the testing of bar-coded Schedules
K-1 and their associated parent returns. To receive this expedited service, follow the instructions
below.
• Mail the parent returns (Forms 1041, 1065, 1120-S) and associated bar-coded Schedule(s)
K-1 to the address below in a separate package from all other approval requests.
Internal Revenue Service
Attn: K-1 Substitute Forms Analyst
SE:W:CAR:MP:T:T:SP
Room 6411
1111 Constitution Ave. NW
Washington, DC 20224
• Mail one copy of the parent form(s) and Schedule(s) K-1 to the IRS and another copy to the
testing vendor at the address below.
Leidos-IRS Paper and Remittance
Processing Support (PRPS II)
Attn: Dane Hawkins
9737 Washingtonian Blvd.
Gaithersburg, MD 20878
• Include multiple email and phone contact points in the packages.
• While the IRS can expedite bar-coded Schedules K-1 and their associated parent returns, it
cannot expedite the approval of nonassociated tax returns.
• Vendors are encouraged to go to https://www.nactp.org for compliance guidelines in regards
to file size and error-correction level.
• Submissions should include the IRS source code or NACTP vendor ID code printed on the
lower left corner of the form or in place of the IRS catalog number.
• If a change is made to the bar code after approval, be sure to increment the version number.

October 27, 2025 680 Bulletin No. 2025–44
Section 7.2 – Guidelines for Substitute Forms 8655
7.2.1
Incr
eased Standardization
for Forms 8655
Increased standardization for reporting information on substitute Forms 8655 is now required to
aid in processing and for compliance purposes. Follow the guidelines in Section 7.2.2.
7.2.2
Requirements for
Substitute Forms 8655
Follow these specific requirements when producing substitute Forms 8655.
• The first line of the title must be “Reporting Agent Authorization.”
• If you want to include a reference to “State Limited Power of Attorney,” it can be in
parentheses under the title. “State” must be the first word within the parentheses.
• You must include “Form 8655” on the form.
• While the line numbers do not have to match the official form, the sequence of the information
must be in the same order.
• The size of any variable data must be printed in a font no smaller than 10 points.
• For adequate disclosure checks, the following must be included for each taxpayer.
– Name.
– EIN.
– Address.
• At this time, Form 944 will not be required if Form 941 is checked. Only those forms that the
reporting agent company supports need to be listed.
• The jurat (perjury statement) must be identical with the exception of references to line
numbers.
• A contact name and number for the reporting agent are not required.
• Any state information included should be contained in a separate section of the substitute
form. Preferably, this information will be in the same area as line 19 of the official form.
• All substitute Forms 8655 must be approved by the Program as outlined in the Form 8655
specifications in this publication.
• If you have not already been assigned a 3-letter source code, you will be given one when your
substitute form is submitted for approval. This source code should be included in the lower
left corner of the form.
• The 20-business-day assumed approval policy does not apply to Form 8655 approvals.
7.2.3
Exception for
Form 8655
Because of how Form 8655 is processed and distributed to recipients, vendors are allowed to affix
their logos onto the substitute version of the form. This exception is for Form 8655 only.

Bulletin No. 2025–44 681 October 27, 2025
Section 7.3 – Guidelines for Substitute Image Character Recognition (ICR) Forms
7.3.1
Overview
The following suggestions may be used as a guideline for creating easily scanned substitute tax
forms. If you choose to participate, use the Form 1040 format provided in Exhibit C and Exhibit
D. The grid view is for user ease of understanding only and should be removed before printing
forms for submission.
Note. The exhibits are to show formatting only and are not a current copy of the form. Use the
most current version of any form to create the substitute tax form.
7.3.2
Automated Pr
ocessing of
Certain Forms
Certain forms have been redesigned for automated processing via ICR technology. As a result,
these forms have different requirements for reproduction. These specific requirements apply to
both the form image as well as the format of the variable data.
7.3.3
Form Design Requirements
• Forms should have a 0.5-inch margin on all sides.
• Nothing should be printed within the 0.5-inch margins.
• Vertical and horizontal lines should be replicated as they are on the IRS form.
• Printing should be in black ink on white paper. No color or shading should be used.
• Reproduce the exact text on each line as it appears on the IRS form. Do not abbreviate or
leave out text.
7.3.4
Data Format Requir
ements
• See Section 3.3.
• Rows 1–3 and 64–66 and columns 1–5 and 81–85 should be left blank.
• SSN and EIN fields should have dashes (for example, 999-99-9999 or 99-9999999).
• Do not use real data unless specifically directed (for example, printing 12345678912 vs.
XXXXXXXXXXX for bank routing number as required by Pub. 1345).
• Dollar value fields should be printed with commas and no decimals (for example, 999,999,999).
• Data placement should match defined areas on the form. Variable data should not be printed
outside defined areas (for example, first, middle, last, and suffix fields should be printed where
they appear on the IRS form, not combined).
• Do not populate blank value fields with a zero. If there is no value for a field, leave it blank.
Exceptions include calculated fields with valid inputs that result in a value of zero.
• Vendor codes and company-specific printing information should only appear in the spaces
designated on the form.

October 27, 2025 682 Bulletin No. 2025–44
Part 8
Additional Information
Section 8.1 – Forms for Electronically Filed Returns
8.1.1
Electr
onic Filing Program
Electronic filing is a method by which authorized providers transmit tax return information to
an IRS Service Center in the format of the official IRS forms. The IRS accepts both refund and
balance due forms that are filed electronically.
8.1.2
Applying To Participate in
IRS e-file
Anyone wishing to participate in IRS e-file of tax returns must submit an e-file application. The
application can be completed and submitted electronically on the IRS website at https://www.irs.
gov after first registering for e-services on the website. For specific information about completing
an e-file application to participate in IRS e-file of tax returns, refer to Pub. 3112, IRS e-file
Application & Participation.
8.1.3
Obtaining the Taxpayer
Signature/Submission of
Required Paper Documents
Taxpayers choosing to electronically prepare and file their returns will be required to use the Self-
Select PIN method as their signatures.
Electronic return originators (EROs) can e-file individual income tax returns only if the returns are
signed electronically using either the Self-Select or Practitioner PIN method.
Taxpayers must use Form 8453, U.S. Individual Income Tax Transmittal for an IRS e-file Return,
to send supporting documents that are required to be submitted to the IRS.
For specific information about electronic filing, refer to Pub. 1345, Handbook for Authorized IRS
e-file Providers of Individual Income Tax Returns.
8.1.4
Guidelines for Preparing
Substitute Forms in the
Electronic Filing Program
A participant in the electronic filing program who wants to develop a substitute form should
follow the guidelines throughout this publication and send a sample form for approval to the
Program at substituteforms@irs.gov. If you do not prepare substitute Form 8453 using a font in
which all IRS wording fits on a single page, the form will not be accepted.
Note. Use of unapproved forms could result in suspension of the participant from the electronic
filing program.
Section 8.2 – Effect on Other Documents
8.2.1
Effect on Other Documents
This revenue procedure supersedes Revenue Procedure 2024-33, 2024-44 I.R.B. 1030.

Bulletin No. 2025–44 683 October 27, 2025
Section 8.3 – Exhibits
Exhibit A — Form 1040-ES Voucher 20XX
Exhibit B — Substitute Form Checksheet
Exhibit C — Form 1040 With Grid
Exhibit D — Form 1040 Without Grid

October 27, 2025 684 Bulletin No. 2025–44
40

Software Developers Voucher

Bulletin No. 2025–44 685 October 27, 2025
41

IRS Checksheet

October 27, 2025 686 Bulletin No. 2025–44
42

Form 1040 With Grid

Bulletin No. 2025–44 687 October 27, 2025
Exhibit C (continued)
Form 1040 With Grid

43

October 27, 2025 688 Bulletin No. 2025–44
44

Form 1040 Without Grid

Bulletin No. 2025–44 689 October 27, 2025
Exhibit D (continued)
Form 1040 Without Grid

45

Bulletin No. 2025–44 i October 27, 2025
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.
—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

October 27, 2025 ii Bulletin No. 2025–44
Numerical Finding List
1
Bulletin 2025–44
Announcements:
2025-19, 2025-29 I.R.B. 191
2025-20, 2025-31 I.R.B. 271
2025-21, 2025-32 I.R.B. 312
2025-24, 2025-36 I.R.B. 359
2025-25, 2025-36 I.R.B. 360
2025-26, 2025-40 I.R.B. 444
Notices:
2025-32, 2025-27 I.R.B. 1
2025-33, 2025-27 I.R.B. 4
2025-34, 2025-27 I.R.B. 6
2025-35, 2025-27 I.R.B. 8
2025-31, 2025-28 I.R.B. 14
2025-36, 2025-30 I.R.B. 192
2025-37, 2025-30 I.R.B. 198
2025-40, 2025-31 I.R.B. 266
2025-39, 2025-32 I.R.B. 308
2025-28, 2025-34 I.R.B. 316
2025-41, 2025-34 I.R.B. 325
2025-42, 2025-36 I.R.B. 351
2025-43, 2025-36 I.R.B. 356
2025-44, 2025-37 I.R.B. 386
2025-45, 2025-37 I.R.B. 388
2025-38, 2025-38 I.R.B. 392
2025-47, 2025-40 I.R.B. 441
2025-51, 2025-41 I.R.B. 448
2025-52, 2025-41 I.R.B. 474
2025-54, 2025-41 I.R.B. 479
2025-46, 2025-43 I.R.B. 533
2025-50, 2025-43 I.R.B. 542
2025-53, 2025-43 I.R.B. 624
2025-55, 2025-43 I.R.B. 625
2025-49, 2025-44 I.R.B. 627
Proposed Regulations:
REG-125710-18, 2025-30 I.R.B. 263
REG-107459-24, 2025-32 I.R.B. 313
REG-132805-17, 2025-35 I.R.B. 342
REG-108822-25, 2025-36 I.R.B. 361
REG-129260-16, 2025-39 I.R.B. 410
REG-108673-25, 2025-42 I.R.B. 494
REG-110032-25, 2025-42 I.R.B. 495
REG-112261-24; REG-116085-23, 2025-42
I.R.B. 522
Revenue Procedures:
2025-22, 2025-30 I.R.B. 200
2025-24, 2025-31 I.R.B. 273
2025-25, 2025-32 I.R.B. 311
2025-26, 2025-33 I.R.B. 315
2025-28, 2025-38 I.R.B. 393
Revenue Procedures:—Continued
2025-30, 2025-42 I.R.B. 489
2025-27, 2025-44 I.R.B. 646
Revenue Rulings:
2025-13, 2025-28 I.R.B. 11
2025-14, 2025-32 I.R.B. 300
2025-15, 2025-32 I.R.B. 302
2025-16, 2025-35 I.R.B. 342
2025-17, 2025-36 I.R.B. 349
2025-18, 2025-37 I.R.B. 365
2025-19, 2025-41 I.R.B. 445
2025-20, 2025-41 I.R.B. 447
Treasury Decisions:
10021, 2025-31 I.R.B. 264
10031, 2025-32 I.R.B. 304
10033, 2025-40 I.R.B. 411
10035, 2025-42 I.R.B. 484
10034, 2025-43 I.R.B. 523
10036, 2025-43 I.R.B. 525
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin
2025–52, dated December 22, 2025.

Bulletin No. 2025–44 iii October 27, 2025
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2025–44
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2025–27 through 2025–52 is in Internal Revenue Bulletin
2025–52, dated December 22, 2025.

Internal Revenue Service
Washington, DC 20224
Official Business
Penalty for Private Use, $300
INTERNAL REVENUE BULLETIN
The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue
Bulletins are available at www.irs.gov/irb/.
We Welcome Comments About the Internal Revenue Bulletin
If you have comments concerning the format or production of the Internal Revenue Bulletin or suggestions for improving it,
we would be pleased to hear from you. You can email us your suggestions or comments through the IRS Internet Home Page
www.irs.gov) or write to the Internal Revenue Service, Publishing Division, IRB Publishing Program Desk, 1111 Constitution Ave.
NW, IR-6230 Washington, DC 20224.